00223
STATE/EPA AGREEMENTS
A Handbook for Substate Regional Agencies
OOOR79100
ENVIRONMENTAL
SOLUTIONS
NATIONAL ASSOCIATION OF
REGIONAL COUNCILS
AUGUST 1979
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THE NATIONAL ASSOCIATION OF
REGIONAL COUNCILS (NARC) IS ...
... A nonprofit membership organization serving the nation's regional
councils. Its fundamental purpose is to strengthen and assist all
regional councils.
... An association which provides its members with a variety of
technical assistance and research services, with representation before
Congress and the Administration in Washington, with regular
communications services, and with key conferences and workshops.
. . . Most important, an organization that needs its members'
involvement. NARC seeks the participation of staff directors and
policy officials through the Staff Directors Advisory Committee,
through election to the Board of Directors, through membership in
policy committees, through suggestions and comments, and through
participation in national and state meetings.
Those who wish to learn more about NARC and its membership
services are welcome to call or write the Executive Director.
©1979
National Association of Regional Councils
1700 K Street, N.W.
Washington, B.C. 20006
(202) 457-0710
The preparation and publication of this report was funded, in part, by financial support from the U.S. Environmental Protection Agency.
The views and statements expressed do not necessarily represent the policies of EPA, nor do they necessarily represent the policies of the
Board of Directors and/or the membership of the National Association of Regional Councils.
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CONTENTS
Foreword 4
Introduction 5
I. The Agreement as a Management Tool 7
II. Programs that are Covered 8
III. It is an Interactive Process 9
IV. How and Why Your Agency should be Involved 11
V. Developing a Positive Relationship with Your State 12
VI. How to Get Involved in the Process 12
VII. Overcoming Barriers 13
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FOREWORD
Over the past year or so, the Environmental
Protection Agency has been instituting
State/EPA Agreements between its regional of-
fices and the states within each region.
EPA's goal is to more effectively combat en-
vironmental problems by integrating and coor-
dinating programs developed by state and local
governments under the Clean Water Act, the
Safe Drinking Water Act, the Clean Air Act and
the Resource Conservation and Recovery Act.
The Agreements and the process of developing
them certainly have the potential of achieving
EPA's objective.
This guide has been prepared to help substate
regional councils understand the State/EPA
Agreement process and use it to work more ef-
fectively with the state. Although this may be
difficult in some cases, the potential results are
worth the effort.
NARC would like to hear from substate
regional councils about their experiences in the
State/EPA Agreement process. We will help all
regional councils function better in the State/EPA
Agreement arena by learning about the
techniques that work as well as those that don't.
We are indebted to the Water Planning Divi-
sion of EPA for its continuing support and con-
tributions in the preparation of this publication.
Richard C. Hartman
Executive Director
August 1979
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INTRODUCTION
The U.S. Environmental Protection Agency
(EPA) has put into action a new plan to improve
the coordination and effectiveness of clean-up
programs carried out under three key en-
vironmental laws.
The major feature of this plan is the annual
State-EPA Agreement — a mechanism for
managing some EPA grants to the 56 states and
territories.
Under EPA's plan, governments at the local,
state and federal levels will work closely
together both to identify priority environmental
problems and to find appropriate solutions. The
results will be more effective and coordinated
use of the sometimes overlapping authorities
contained in the Safe Drinking Water Act, the
Clean Water Act, and the Resource Conserva-
tion and Recovery Act.
The goal is to promote more creative, effective
and efficient solutions to problems affecting
public health and environment. The Agreements
will focus on priority environmental problems
and will utilize the resources and authorities
contained in the three laws to solve those
specific problems. The Agreements are also
intended to be a useful management tool in
integrating environmental programs and in con-
serving federal and state resources through such
practices as combining duplicative requirements
in two or more programs into a single product
that satisfies all administrative and legal re-
quirements.
In Fiscal Year 1980, State-EPA Agreements
will present integrated approaches to solving
water supply, solid waste and water pollution
control problems. The integration of these pro-
gram areas will be a major step toward the ob-
jectives of overall environmental planning and
management versus an approach which tries to
solve interrelated environmental problems in a
piece-meal fashion, program by program.
The State-EPA Agreement, which each state
"... governments at the local, state, and federal levels will
work closely together to identify problems and to find
appropriate solutions."
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and its corresponding EPA Region will
negotiate, will include a brief statement of en-
vironmental problems and objectives based on
state problem assessments and strategies.
Agreements will also include or make reference
to work programs which integrate the various
products under each of the "covered" programs.
The State-EPA Agreement will reflect impor-
tant decisions on environmental priorities (in-
cluding those set forth in the annual EPA
operating guidance), administrative problems,
timing, responsibilities and allocation of funds.
It will focus top management attention on the
evaluation and accomplishment of major en-
vironmental objectives.
According to EPA regulations and guidance,
substate regional planning and implementation
agencies — such as designated Water Quality
Management Planning Agencies under section
208 of the Clean Water Act or Solid Waste
Planning Agencies under subtitle D of the
Resource Conservation and Recovery Act —
shall participate in the development of relevant
portions of the Agreement and it shall reflect
their views.
Substate regional planning and implementa-
tion agencies will continue to have full interac-
tion with EPA. In programs such as areawide
water quality management planning under sec-
tion 208 of the Clean Water Act, designated
areawide agencies will continue to be funded
directly by EPA. EPA will also negotiate water
quality management work programs directly
with designated areawides and will continue to
have ultimate authority over the evaluation of
products.
Regional agencies have a lot at stake in the
State/EPA Agreement. In order for an agency's
environmental programs to receive federal fund-
ing, they must be consistent with the state pro-
gram enunciated in the Agreement. The great
advantage to this is that the Agreement puts
the state on record as to precisely what its en-
vironmental program is, thus better defining
state review and evaluation criteria. Further-
more, the development of the State/EPA Agree-
ment should give regional planning and
implementation agencies an opportunity to in-
fluence the shape of state environmental policy.
Properly implemented, the State/EPA Agree-
ment and the process of deriving it should help
to better integrate environmental programs; but
perhaps just as important, it should help to bet-
ter integrate the efforts of the various levels of
government involved. This publication is intend-
ed to help local elected officials, regional council
staff and citizens to better understand the
State/EPA Agreement and to take advantage of
the opportunities it offers.
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I. THE AGREEMENT AS A MANAGEMENT TOOL
The State/EPA Agreement will be a manage-
ment tool to ensure that the various en-
vironmental programs run by the state are well
coordinated and not conflicting or duplicative.
Integration of programs in this way will not on-
ly make the states' overall environmental
management more efficient, it will also enhance
the individual programs themselves.
'The State/EPA Agreement will be a management tool to
ensure that the various environmental programs run by the
state are well coordinated ..."
Integration
Enactment of the Clean Water Act, Safe
Drinking Water Act and Clean Air Act provided
for controls of water and air pollution. Passage
of the Resource Conservation and Recovery Act
(RCRA) in 1976 closed the gaps in the waste
disposal cycle, providing control over disposal of
pollutants on or in the land. Congress recog-
nized the relationship among air, water and
solid waste pollution and controls in Section
1002(bX3) of RCRA, which says:
... as a result of the Clean Water Act, the
Water Pollution Control Act, and other
Federal and State laws respecting public
health and the environment, greater
amounts of solid waste ... have been
created. Similary, inadequate and en-
vironmentally unsound practices for the
disposal or use of solid waste have created
greater amounts of air and water pollution
and other problems for the environment and
for health.
There are a number of reasons why it makes
sense to coordinate and integrate environmental
programs. Linking planning, implementation,
and management of major environmental pro-
grams will allow a comprehensive and
systematic approach. This type of approach
should lead, for instance, to an identification of
the best place to control pollutants in their
overall life cycle. As a result of program in-
tegration, generators of pollution should be able
to plan all controls at one time.
Efficiency
Coordination and integration of environmental
programs should also reduce duplication. Since
resources are limited at all levels of govern-
ment, an integrated approach should achieve
maximum environmental benefits from limited
resources. It should also help prevent the
unplanned movement of pollutants from one
medium to another, e.g., from the air or water
to the land and back to the water. In addition,
the Agreement must have early and continuous
public involvement. As a result, the strategy
derived from the agreement process will be
more likely to succeed and will reflect broader
public interests.
Many state governments are large, highly
decentralized organizations with numerous
centers of power. Without integration, different
state agencies can and do make conflicting deci-
sions. The State/EPA Agreement process will re-
quire greater coordination in related areas. This
should end contradictory state policies and
resolve unproductive interagency disputes.
Finally, an objective of the State/EPA Agree-
ment process is to prevent redundant paperwork
and work elements and to limit the need for
burdensome regulations.
Communication
In addition, the State/EPA Agreement will be
used to improve communication among the
various levels of government and the public and
to integrate environmental management
throughout the federal, state, area wide and local
levels.
One important link in this communications
network is that between the states and the
regional and local agencies. The states need
local government to assess problems, to develop
workable plans and to implement resulting en-
vironmental management decisions. The local
governments and their regional agencies need
the power and authority of the state to ac-
complish their local environmental management
agendas. The states will be required to consult
local and regional planning and implementation
agencies in developing the state strategy and
the State/EPA Agreement.
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II. PROGRAMS THAT ARE COVERED
The programs that must be covered under
State/EPA Agreements for fiscal year 1980 are
generally those providing federal grants to the
states for planning and management solutions
to water quality and related solid waste prob-
lems. They fall under three major federal en-
vironmental laws: The Clean Water Act, the
Safe Drinking Water Act, and the Resource
Conservation and Recovery Act. Other programs
may be included at the discretion of the
Regional Administrator.
Clean Water Act
Section 106 (federal grants to the states to ad-
minister pollution control programs) includes
point source permit programs, enforcement pro-
grams, water quality monitoring programs, and
emergency cleanup programs.
Section 205(g) (federal grants to states to ad-
minister construction of wastewater treatment
works) may also include costs of administering
point source permit programs, permit programs
for discharge of dredge or fill material,
statewide water quality management programs,
and management of treatment works construc-
tion grants for small communities,
Section 208 (Water Quality Management Plan-
ning) is a broad management program carried
out by state and areawide agencies to identify
needed treatment works; set priorities for
building them; assess advanced wastewater
treatment needs; solve nonpoint source pollution
problems from urban storm runoff, agriculture,
construction, mining, silviculture, on-lot disposal
and other nonpoint sources.
Section 314 (Clean Lakes Program) provides
grants to states to identify, classify and develop
procedures and methods to control sources of
pollution in publicly owned freshwater lakes.
Resource Conservation and
Recovery Act (RCRA)
Section 4008 (State Solid Waste Plans) pro-
vides grants to states for the development and
implementation of state solid waste manage-
ment plans and for evaluating individual
disposal sites to determine which should be
closed or upgraded. State plans address all solid
waste in the state that poses potential adverse
effects on health or the environment. They in-
clude municipal, industrial, mining, and
agricultural wastes, and pollution control wastes
'The State/EPA Agreement will cover programs conducted
under the Clean Water Act, the Safe Drinking Water Act,
the Resource Conservation and Recovery Act, and others."
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such as septic tank pumpings. The plan will also
provide for the development of policy and
strategy for resource recovery and conservation
practices.
Section 4009 (Rural Communities Assistance)
provides grants for solid waste management
facilities in rural communities.
Section 3011 (State Hazardous Waste Pro-
gram) allows states to develop a regulatory
framework for the control and disposal of haz-
ardous wastes, including appropriate permitting
mechanisms, monitoring, record keeping and
reporting procedures. RCRA regulations will
define hazardous wastes and establish re-
quirements for generators, transporters, and
owners and operators of facilities for the
disposal, treatment, and storage of hazardous
wastes.
Safe Drinking Water Act (SDWA)
Section 143(a) (State Public Water Supervi-
sion Program) establishes and maintains stan-
dards and controls for drinking water sources,
surveillance of public water systems and conduc-
ting sanitary surveys. The program also assures
adequate laboratory capacity and enforcement
capabilities.
Section 1443(b) (Underground Injection Con-
trol Programs) requires that a responsible state
agency establish and maintain an inventory of
underground waste injection practices, and
carry out surveillance and investigation of
underground injection operations.
Section 1442(bX3XC) allows grants to states
and municipalities for projects or activities to
carry out the purposes of the Safe Drinking
Water Act, other than those covered by the
previously mentioned SDWA programs.
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III. IT IS AN INTERACTIVE PROCESS
Negotiation
Development of a State/EPA Agreement is an
interactive process requiring the personal com-
mitment of high-level EPA and state officials as
well as citizens. It requires consultation among
EPA regional program managers, state agencies,
regional and local planning and implementation
agencies, related federal agencies and affected
or interested citizens. The involvement of each
group is important if the objectives of the
Agreement are to be met.
The negotiation of the State/EPA Agreement
is part of a process which gets decision-makers
together to determine priorities for environmen-
tal problems and to develop creative solutions.
EPA recommends that the state and EPA
regional personnel should begin developing the
Agreement as early as possible each year.
Before development begins, the state, EPA and
the public should review basic background infor-
mation such as current state plans, strategies,
problem assessments, annual EPA operating
guidance, applicable laws and deadlines, and
funding sources.
Consultation will be an important component
of the negotiation process. Even though the
states and EPA have primary responsibility for
negotiating the agreements, other segments of
the environmental management community
such as various state agencies, local and regional
planning and implementation agencies and the
public will be included in the process through
consultation.
Development
Developing a State/EPA Agreement is an an-
nual process which, mentioned earlier, requires
the personal commitment and constant involve-
ment of EPA, state officials, and the public. It
should bring people together to identify and
solve the environmental problems they face.
Generally, the agreement process should in-
clude the following activities:
• identify priority problems;
• identify available resources;
• consider alternative solutions and their
impacts;
• choose the best solutions;
• identify sources of funds;
• define tasks, including timing, funding, and
responsible parties;
• implement the Agreement; and
• revise the Agreement and evaluate the
process annually.
Wherever possible, the schedule for develop-
"The negotiation of the State/EPA Agreement is part of a
process which gets decision-makers together to determine
priorities for environmental problems and to develop
creative solutions."
ing the State/EPA Agreement should accom-
modate the existing schedules of the various
programs. Generally, the draft Agreement
should be completed and submitted to the
regional EPA administrator by June to cover
the federal fiscal year beginning in October. The
regional administrator will then review the
draft and provide comments to the state within
30 days. The final Agreement is to be submitted
to the regional administrator in September of
each year so that it may be signed and take
effect October 1.
Components
While the key to the success of the Agree-
ment is flexibility in accommodating differences
among individual states, it should have several
major components:
(1) A brief statement of the environmental
goals and problems to be acted on. The
statement should be based on the state's
problem assessments, strategies, or other
identification of needed activities for the
covered programs. As much as possible, the
state should prepare an integrated multi-
year strategy to be updated annually.
(2) A detailed work program based on a multi-
year strategy, or reference to such a pro-
gram in other documents.
(3) A summary of the major integrated work
elements compiled from the detailed work
programs, as well as EPA actions needed.
(4) Other information and coordination re-
quirements which the Regional Ad-
ministrator determines are necessary to
meet the goals of the Agreement, such as
formal agreements with other federal
programs.
If the Agreement is longer than 20-25 pages,
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it is recommended that a summary be prepared
as an overview of the work to be performed dur-
ing the coming year.
EPA — Local Relationships
The State/EPA Agreement is meant to assist
EPA and the states in being more responsible
for managing and coordinating environmental
programs. The agreement is not intended to in-
sulate EPA from local and regional agencies.
For instance, the Water Quality Management
regulations (40 CFR 35, May 23, 1979) state:
35.1515 State/EPA Agreement
(b) Role of areawide agencies. For
area wide agencies, the State's work program
sets a policy framework based on the State
strategy, and should include priorities for
areawide action and timing of major out-
puts. Because of the importance of their
role, areawide agencies shall be involved in
development of all relevant aspects of the
Agreement. Comments of the areawide agen-
cies (if any), the State's responses, and a
brief summary of the participation of
areawide agencies in development shall be
forwarded to EPA with the draft Agree-
ment. Nothing shall preclude the right of
the areawide agency to submit comments
directly to EPA. and
35.1513-3 WQM Work Program,
Relationship To State/EPA Agreement
(c) Areawide agencies' work programs are
separate submissions. However, the State
work program sets a policy framework for
areawide agencies based on the State
strategy, and should include priorities for
areawide action and timing of major out-
puts. Approval of areawide work programs
will not be delayed based on delay in ap-
STATE/EPA
AGREEMENTS
• Problems & Goals
• Work Program
• Summary of
Work Elements
• Other Information
proval of a State work program, unless the
Regional Administrator determines that an
unapproved element of the State's work pro-
gram is critical to the effectiveness of
areawide efforts.
As the State/EPA Agreements are formulated,
local and regional planning and implementation
agencies must continue to cultivate EPA con-
tacts and maintain relations with the EPA
regional office. As long as they want it, local
agencies will have access to EPA for assistance
and consultation as in the past.
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IV. HOW AND WHY YOUR AGENCY
SHOULD BE INVOLVED
By now it is clear that the State/EPA Agree-
ment will be the management focus for many
federal environmental programs. The states will
be responsible for the performance of those pro-
grams. If they are to be successful, they will
need help from local and regional agencies. But
many states have not yet determined how to in-
volve local governments and regional agencies
effectively in the State/EPA Agreement process.
It is up to you as a regional agency official to
demonstrate how regional agencies are impor-
tant to the success of the statewide environmen-
tal program and what your agency can do.
Regional Agencies and
State Program Management
The state can benefit greatly from working
with regional agencies. State governments are
responsible for the activities of 80,120 local
governments which spend in excess of $200
billion per year and have untold effects upon
personal lives and business. It is difficult for
state governments to deal with that level of
detail. They need regional council help to ac-
quire and diseminate information. In the final
analysis, state officials judge regional planning
and implementation agencies on the basis of
their usefulness to the state and their accep-
tance by local political leaders.
"In the final analysis, state officials judge regional agencies
on the basis of their usefulness to the state and their
acceptance by local political leaders."
Communication
While formulating an integrated environmen-
tal management program for the State/EPA
Agreement may be relatively easy, state agen-
cies may find it difficult to achieve regular,
reliable communication with all the local
governments that must participate in the im-
plementation of the program. To secure the
local governments' commitment to implementa-
tion, local interests must be respected and ad-
dressed in developing the program. Effective
communications among the various levels of
government is an objective of the State/EPA
Agreement; such communication can be provid-
ed by regional agencies.
The number of regional agencies in any state
is limited. It is less costly and easier for state
governments to establish and maintain relations
with them than with each local government.
Resolving Conflicts
State governments spend countless hours and
dollars attempting to resolve local disputes. As
problem solvers, regional agencies reduce the
number of disputes that reach state govern-
ment. They sort out conflicting local interests
and present the state with a locally negotiated
assessment of needs and expectations.
Regional agencies also provide a mechanism
for determining allocations of scarce state and
federal funds, thus placing those decisions
closer to home. Conflict resolution is a difficult
and unpopular task, but it provides regional
agencies with opportunities to prove how worth-
while they can be to state administrative and
political leaders, especially in sensitive en-
vironmental areas such as sanitary landfill
siting and sewage treatment capacity allocation.
Citizen Participation
The state is required to seek effective public
involvement in developing its State/EPA Agree-
ment. Establishing a citizen participation pro-
gram from the bottom up could be costly and
time-consuming. However, many regional agen-
cies actively involve citizens in environmental
programs. Some have already integrated various
citizen participation efforts. Regional efforts can
provide a framework for a state citizen par-
ticipation program.
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State/Regional Impact
State government, supported by regional and
local officials and citizens, can be far more ef-
fective in influencing EPA policy and funding
decisions. A state with enthusiastic local sup-
port will be negotiating its Agreement from a
position of maximum strength.
Regional agencies can help the state build
local support through:
• A ready organization, including a citizens'
participation system, for developing a unified
state-regional-local position on key environmen-
tal issues; and
• A vehicle for communicating that unified
position to Congressional representatives, state
legislators, and federal officials in Washington.
Management Improvements and
Cost Reductions
Regional agencies make it possible for local
governments to share expensive facilities,
technical equipment and specialized professional
manpower. And it becomes easier for the state
to establish local data gathering or environmen-
tal management efforts that would be too costly
or too difficult to manage on a jurisdiction-by-
jurisdiction basis.
V. DEVELOPING A POSITIVE RELATIONSHIP
WITH YOUR STATE
Whether dealing with the state on en-
vironmental matters generally or trying to in-
volve your agency in the development of the
State/EPA agreement specifically, it is impor-
tant to remember that working with state
government is, after all, working with and
through people. While laws and policies may
structure and limit the kinds of relationships
possible, intergovernmental relations are prin-
cipally interactions among the elected and ap-
pointed representatives of the agencies involved.
Now is the time to start working closely with
your state to influence the State/EPA Agree-
ment. The effort must be continuous. The peo-
ple who make the environmental management
decisions for the state must know you, and
understand that what your agency does is im-
portant and effective.
VI. HOW TO GET INVOLVED IN THE PROCESS
The best way to assure that your regional
agency is involved in the formulation of the
State/EPA Agreement is to establish and main-
tain strong relationships with each part of state
government: the governor and the executive
branch; the line agencies directly responsible to
the governor; the legislature and legislative
staff agencies; autonomous or semi-autonomous
boards, commissions and state administrative
agencies. States are governments of many parts;
a regional agency program for working with the
state should give attention to each.
Identify the Decision Makers
Identify those officials in the governor's of-
fice, at the line agencies and at the EPA
regional office who will be making decisions
about the State/EPA Agreement. This may in-
volve knowing the extent to which decisions are
delegated by the governor, the state agency
head or the regional EPA administrator.
Outline a Realistic Program and Push It
Regional agencies cannot do everything at
once. Look for achievable objectives and then
"States are governments
of many parts;
a regional agency
program for working
with the state should
give attention to each."
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follow through to complete them. Make sure the
decision makers understand your program and
see how it will benefit the state. Be aggressive
and persistent. It is good practice to initiate
proposals rather than react to the initiatives of
others.
Work Statewide
Mobilize your state association of regional
councils or state municipal league or state coun-
ty association to participate in the State/EPA
Agreement formulation process. Understandab-
ly, the state government is accustomed to deal-
ing with statewide organizations. This is
especially true on major policy issues such as
the state environmental management plan and
the State/EPA Agreement. Time limitations,
cost, and simple inertia weigh against
systematic state efforts to survey all regional or
local agencies. Because of this, benefits of state
association action accrue to both member agen-
cies and the state.
State associations should supplement your
program for working with the state, not replace
it. Some perils to avoid when working with
state associations are:
• Regional agencies that previously looked
after their own interests can be lulled into
dangerous complacency by assuming that
the association is on top of everything.
• State officials may attempt to substitute
casual consultation with the state associa-
tion for more substantial interaction with
individual agencies.
• Splits within and among regional council
and county associations and municipal
leagues can weaken the position of all local
governments before the state.
• Internal politics of an association can waste
valuable time and effort.
VII. OVERCOMING BARRIERS
There is a natural tension in the interactions
between states and local and regional agencies.
If managed properly, that tension can provide a
creative impetus leading to productive results.
Unfortunately, that tension often degenerates
into distrust and even open hostility. Of course,
when this happens the quality of government
suffers and nobody wins.
Combat Hostility
• Maintain high quality work.
• Be alert, but don't over-react.
• Be aggressive, but be constructive and
positive.
• Emphasize agency work for local government.
• Demonstrate that you can help state officials.
Be Political
• Have elected officials from your agency
communicate with state officials.
• Have your state legislators advance your
program. Use local elected officials to
accomplish this.
• Use statewide clout, either through state
associations or through ad hoc organizations
of agencies.
• Mobilize local citizen action. State officials
are responsive to constructive public
suggestions.
• Be persistent.
• Always give credit where credit is due.
• Keep the EPA regional administrator
informed of your progress, especially when
the state begins to involve your agency.
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GET IN STEP WITH YOUR STATE
Make Meetings Productive
• Know who you are meeting with and what he/she can do for you.
• Pick the proper person(s) to attend: policy officials or staff.
• Brief the state staff in advance so they can prepare their boss; avoid
surprises.
• Limit your requests.
• Include at least one item that you are sure the state official can agree to
(don't let the meeting be a total loss to both sides).
• Avoid criticism; be positive; be respectful.
• Have a draft document that can be acted upon.
• Follow up with a thank-you, regardless of the outcome.
• Inform lower-echelon state staff of what was requested and any action taken
in the meeting.
• Schedule a follow-up action if necessary.
• Give credit publicly and privately to the state official.
Assist State Officials
• Respond quickly to data requests from the state.
• On occasion, handle "hot potatoes" for the state.
• Help arrange hearings in the region (provide the hall, alert the news media,
bring a crowd, provide staff).
• Co-sponsor meetings with state agencies.
• Help state agencies make citizen participation work.
• Accompany state officials as they visit communities within the region.
• Issue news releases that provide information on state programs and the
work of specific state officials.
• Give state officials a telephone list of your staff and invite them to call
when they need help.
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STATE/EPA AGREEMENT TIMETABLE
The following schedule for development of an effective State/EPA Agreement is suggested in
EPA regulations and guidance.
Deadline Activity
by April 1 Proposed state policy framework made
available to relevant state and local agencies.
by June 1 Draft Agreement completed and submitted
to EPA regional administrator.
Within 30 days EPA regional administrator provides
of submission comments to the state.
during September Final Agreement submitted to EPA regional
administrator.
October 1 Final Agreement signed and takes effect.
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national
association
OF REGionai.
councils
1700 K Street, N.W., Washington, B.C. 20006
(202) 457-0710
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