United States
Environmental Protection
Office of Water and Waste
Washington, D.C. 20460
January 1981
 I/O I. X


"This paper presents a preliminary  draft
strategy, proposed by EPA staff, for
improving the national municipal wastewater
treatment program.  EPA is now considering
the positions offered here.  The document is
intended for public review and discussion
to assist EPA in developing its final
1990 Strategy."
            January 21, 1981
    U.S. Environmental Protection Agency
    Region  V, Library
    230 South  Dearborn  Street
    Chicago, Illinois  60604


     The proposals presented  in the  prelimiiiary  draft  strategy  are  the
result of both a major effort within the U.S.  Environmental  Protection
Agency and extensive participation on the  part of  the  interested  public
through meetings and the  distribution of relevant  issue  and  background
papers prepared by EPA.   Some of the recommendations in  the  draft
represent a compromise among  diverse positions of  various  constituents of
the program.  Further refinement of  those  recommendations  will  continue
through public participation and ongoing agency  policy review as  the
draTt~strategy is put in  final form.

     In developing the draft Strategy,  recommendations in  each  area were
based on an assumption of continued  federal  funding  support.  Given
current economic conditions and calls for  budget constraints, Congress
and the Administration may determine that  program  funding  should  be
reduced.  Substantial changes in funding levels  would  require
re-evaluation of some of  the  recommendations as  well as  revision
of the timetable for achieving the Clean Water Act goals.  A detailed
examination of a wide range of funding  alternatives can  be found in the
EPA staff paper prepared  on funding  (Task  I  of the 1990  Strategy).

     Several of the recommendations  in  the preliminary draft  Strategy
will depend on Congressional  action  for their  implementation; others will
require the amendment of  existing regulations  for  their  accomplishment;
and some can be accomplished  simply  by  administrative  action  by EPA or
other federal  agencies.   In developing  a final 1990  Strategy  and  an
action plan for its implementation,  EPA will work  closely  with
Congressional  staffs, other federal  agencies and the widely  varying
constituents of the Construction Grants Program  to insure  that  the  future
course charted for the program is a  workable and effective means  to
achieve the goals of the Clean Water  Act.

     The 1990 Strategy draft was prepared  by an  EPA Task Force  within  the
Office of Water and Waste Management.   Assistance  to EPA staff  in this
effort was provided by Temple, Barker and  Sloane,  Inc.; The  Synectics
Group; and Larry Walker Associates,  Inc.   Comments on  the  preliminary
draft strategy should be submitted to Merna  Hurd,  Associate  Assistant
Administrator for Water and Waste Management, U.S.  EPA,  (WH-556),
401 M Street,  S.W.7 Washington, D.C.  20460


     Goals	  ]
     Key Recommendations and Risks of the 1990 Strategy	  3
     Planning—The Context of the Program	  5
     Admi ni strati on of the Program	  6
     Management—Roles in Program Management:
       Federal, State and Local	10
     The Strategy  Devel opment Process	  12


     Introduction	13
     Evolution of the Construction Grants Program	^
     Rationale for Undertaking the 1990 Strategy Development	15
     The Strategy Devel opment Process	1°
     Structure of the Strategy Document	I7


     Program  Management Goals for 1990	19
     Major Themes for Achieving the 1990 Objectives	22


     PI anning--The Context of the Program	29
     Administration of the Program	35
     Management—Roles in Program Management:
       Federal,  State and Local	47


     Appendix A:   List of 1990 Issue Papers and Detailed Strategies	53
     Appendix B:   Glossary of Keywords and Acronyms	57
     Appendix C:   Meetings, Briefings,  Work Sessions, and Conferences
                  with Numerous Publics on the 1990 Strategy	63
     Appendix D:   1990 National  Construction Grants Strategy Workshop
                  Participants	65

                            EXECUTIVE  SUMMARY
     The preliminary draft 1990 Strategy  is the  product  of  the  most
comprehensive review and redirection  that EPA has  ever  conducted of its
Construction Grants Program under the Clean Water  Act.   The proposed 1990
Strategy embodies substantial  changes in  areas  such  as  the  relative roles
of the federal and state governments, a more  explicit emphasis  on water
quality impacts as the basis  for decisions, a more flexible and shorter
grants process, and a renewed  emphasis on eliminating serious  compliance

     Under this 1990 Strategy, the Construction  Grants  Program will  be
run primarily by the states, which will have  all responsibility for
individual project actions.  The federal  role will be one  of setting
goals and objectives, working  with the states, and evaluating  state
programs on the basis of progress toward  national  water  quality goals.
One of the proposed Strategy's chief  goals  is to enable tne nation to
achieve fishable /swimmable waters wherever attainable.

     The revised Construction  Grants  Program  will  be simpler and shorter
for the grantees.  It includes a goal of  saving  more than  25 percent of
the time it now takes to receive and  carry out a grant  under the.program.
Also, municipalities and states will  have more flexibility  in  responding
to program requirements in ways that  are  easiest and most  appropriate for
them.  States will be encouraged to simplify  the grants  process for small
communities so it will be tailored to their special  needs  and

     The changes proposed here are expected to significantly reduce the
incidence of facilities in serious noncompliance with their discharge
permits.  A specific goal is to reduce serious noncompliance from present
estimated levels of 30 percent or more to less than  5 percent  by 1990.
Strict enforcement coupled with diagnostic  reviews will  be  key  to
achieving such a compliance record.

     Overall, the 1990 Strategy is expected to make  more effective use of
the federal funds invested in  sewage  treatment facilities,  to  result  in a
program that is more responsive to state  and  local conditions  and needs,
and to yield significant water quality benefits to the  nation.   The
sections that follow summarize the key elements  of the  1990 Strategy.

     The preliminary draft 1990 Strategy  proposes  goals  for  the
construction grants program that are based on the  Agency's analysis  of
the viability of achieving the goals of the Clean  Water  Act  related  to
municipal dischargers.   Before these  proposed goals could be adopted as
program policy it would be necessary for Congress  to  amend the dates
contained in the Clean Water Act.  Specifically, the  major goals  of  the
Act are the elimination, by 1985, of the discharge of pollutants  into  the

navigable waters, and the achievement, by 1983, of an interim goal of
fishable/swimmable waters wherever attainable.  Further, the Act states
as a purpose of the Construction Grants Program to "require and assist  in
providing waste treatment practices that provide for the application of
best practicable waste treatment technology" (BPWTT).  At the time those
goals were set, neither the total national cost nor the environmental and
technical obstacles to achieving them were foreseen.  Based on current
cost projections and funding levels, the Strategy proposes two revised

     t    To achieve fishable/swimmable waters wherever attainable, by
          1990, and

     •    To achieve BPWTT everywhere.

     If it is necessary to reduce the funding level of the program, the dates
projected for completion of the program will have to be adjusted correspondingly.
In any case, these goals will not be easily attained.  However, the Agency
believes that through the full cooperation of federal, state and local
government agencies and the careful selection of priorities, achievement
of these goals is realistic.  States will be developing individual
strategies to achieve these goals for "completion" of the program.  They
will be encouraged to seriously consider options for lowering the federal
share of funding, re-evaluate the eligibilities of various types of
projects, and explore alternatives for providing supplemental funds
through such means as state loan programs to maximize the benefits from
limited federal funds.  EPA will also continue to assess the viability of
meeting these goals as the Strategy is implemented.

     Achieving the goal of fishable/swimmable water in many areas
depends not only on control of municipal wastewater discharges, but also
on the continued installation of industrial controls and the
implementation of nonpoint  source pollution controls.  Industrial
control has progressed well and should support attainment of the 1990
goal.  Nonpoint source control has been slower, however, and in some
cases may delay attainment of this water quality level.  There are also
areas where fishable /swimmable waters will not be achieved due to
natural conditions.  The 1990 Strategy, therefore, stresses the
importance of realistic judgments  regarding the attainability of such
water quality levels on individual waterways as a basis for allocating
limited technical and dollar resources.

     At the same time the draft Strategy also maintains the long-term
goal of secondary, or biological, treatment everywhere.  Achieving this
goal may take longer than 1990, depending on funding levels and the
personnel and other resources of states and municipalities.  It is
considered an important national objective to provide a minimum level of
removal of conventional and toxic pollutants for the enhancement of
surface and ground water quality and the protection of public health.

     Legislative and regulatory amendments will be required to effect the
proposed postponement of dates  in the Act - to allow NPDES permits to
extend beyond 1983, and to legitimately delay the attainment of goals for
fishable/swimmable waters and installation of BPWTT.  The draft Strategy
recommends these changes in order to allow the states to determine the
appropriateness  of such extensions case-by-case.


     The 1990 Strategy includes numerous recommendations  for  changes  in
the program to accomplish the proposed  goals  and  other  targets  described
above.  The most significant of these are listed  briefly  below  to
highlight the specifics and to illustrate the  thrust  of the draft
Actions Related to Increased State Responsibility
and Accountability for Program Management

     •    EPA will seek legislative  amendments  to  allow  full  delegation
          (including the  delegation  of grant making authority) to states,
          thus placing total responsibility  for project  level  decisions
          and primary responsibility for all  other  decisions  at  the  state

     •    By 1983 each state will develop  its own  strategy  for completion
          of the Construction Grants Program.   The  strategy will
          categorize projects based  on  water quality  impacts,  develop a
          schedule for completion of all projects  in  the  program,  and
          outline the necessary  program support activities  such  as
          standards reevaluation and monitoring programs.

     •    Each state will establish  compliance  goals  for  the  POTWs within
          its jurisdiction.  These goals will be incorporated  into the
          delegation agreements  and will provide one  basis  for evaluation
          of the state's  performance.

     •    States will be  held accountable  for progress towards program
          goals.  EPA will develop a management evaluation  system  that
          focuses on direct measures of performance, incl uding  the  number
          of projects constructed, the  number of plants out of
          compliance, improvements in  water  quality,  and  measures  to
          ensure fiscal integrity.

     t    EPA will request authority from  Congress  to withold  grant  funds
          in extreme cases where states have  poor  performance  records and
          inadequate programs for correction, as determined by EPA
Actions Related to POTM Responsibility and Accountability

     •    Local POTWs will be held accountable for the  long-term
          successful performance and compliance of their systems:

               second round grants to communities for expansion  will  not
               be grant eligible
               enforcement actions will be pursued where necessary  to
               ensure compliance

               a sunset date  will  eventually be  recommended by EPA for
               the time when  the construction  grants  program can be
               municipalities will  demonstrate to  the state that they
               have adequate  financial  and  management resources to become
               self-sufficient  (i.e.,  long  term  financial  management

          Local compliance  problems  will  be dealt  with through a program

               diagnostic analyses  of  operating, design and financial
               technical and  management  assistance
               a strong enforcement  program.

          EPA will request  authority from Congress to issue
          administrative orders imposing  sewer bans  and other sanctions
          in the cases of severely  recalcitrant  communities.

          Qualified local grantees  can  be certified by the state so that
          they are able to  proceed  through  most  parts of the process
          without further review by  the  states.
Actions Related to EPAs Establishment of  Reasonable  Construction Grants
Program Requirements

     •    The technical definition  of secondary  treatment  will  be
          modified to allow other biological  treatment  such  as  trickling

     •    A minimum, technology-based standard of secondary  treatment
          everywhere will be maintained,  while greater  emphasis will  be
          placed on water quality effects in  scheduling projects and
          setting priorities for funding.

     •    The time required to move through the  grants  process  will  be
          reduced by at least 25 percent.  EPA will  encourage the use of
          tools such as generic plans to  streamline  the process for  small
          communities by an even greater  amount.

     •    EPA will emphasize state  consideration  of  attainability in
          revising water quality standards and will  issue  guidance on the
          technical, environmental  and  economic  attainability of water
          quality standard;
          EPA will continue to develop  criteria  and  standards  related to
          toxic pollutants.  The Agency will  also develop  methodologies
          for evaluation of the tradeoffs  between different  pollutant
          sources as they affect municipal discharge  requirements.

          EPA will work with states and local agencies to develop  a
          combined sewer overflow and urban storm runoff control
          strategy.  The strategy will include policies to  account for
          high flows in water quality standards and NPDES permits.

          EPA will request legislative authority to modify  present
          funding policies for rural projects, innovative projects and
          alternative projects in the following ways:

               all states will be encouraged to set aside funds  for
               projects in communities under 10,000.  These funds  would
               not be restricted to alternative projects, but would  be
               available for all cost-effective projects
               innovative projects would be funded from a permanent  set
               aside at a rate ten percent higher than conventional
               projects; set aside funds not obligated by states would
               revert to a national pool for innovative projects.  Manage-
               ment assistance will be available for applicants.
               alternative projects would be funded at the  same  increased
               rate as innovative but would not be eligible for  set-aside
               funds.  An active national assistance  program for
               alternative systems will be expanded and model state
               management programs will be developed.
Risks of the 1990 Strategy

     It must be acknowledged that there  are  risks  as  well  as  benefits
associated with several of the major recommendations  in  the 1990
Strategy.  Removing the federal agency entirely  from  project  review and
decision making could lead to situations where narrowly  defined  interests
take precedence over national concerns with  improving water quality;
allowing greater flexibility to state and  local  governments in  fulfilling
the responsibilities of the program could  lead to  major  inconsistencies
and inequities for reviewers and applicants  alike;  and ironically,  the
very changes in requirements designed to streamline the  process  could
slow it down during the initial phase of implementation.   It  is  the
Agency's judgment, however, that these risks  can be minimized by  sound
management oversight, and cooperative relationships between levels  of
government, and that the potential benefits  to be  gained  from proposals
in the strategy outweigh those risks.

     Effective planning and priority-setting will  be  essential  in  order
to achieve the basic goals of the Clean Water Act  under  the  practical
resource limitations that face all  levels  of government  today.   Any
likely level of funding for the Construction Grants Program  over the  next
decade will not support funding of  all the  sewage  treatment  needs  of
communities throughout the nation.  Accordingly, the  draft 1990 Strategy
calls for an explicit emphasis on water quality  impacts  in planning,

priority-setting, and decision making  so  that  the  nation  will  get  the
most beneficial water quality results  from  its  expenditure  of  federal
funds.  In this context the  phrase  "water quality  impacts"  is  meant to be
broad enough to include effects on  surface  and  ground  water and  to
include considerations of public health.

     No extensive new planning programs are  envisioned to achieve  these
objectives.  The 1990 Strategy is calling for  effective use to be  made of
existing data and plans, professional  judgment,  and  the ongoing
monitoring which is already  being conducted  by  states  and POTWs.  The
emphasis on water quality referred  to  throughout the Strategy  is a
reference to incorporating such information  into decision making and
priority-setting at all levels of government which many states are
already doing.

     In order to accomplish  this emphasis on water quality, each state
will be asked to develop its own state strategy for  completion of  the
program and for incorporating national as well  as  state priorities into
its decision processes.  Each state will  be  requested  to  review  its list
of future project needs and  to classify them,  on the basis  of  existing
data, according to the beneficial effect  they will have on  water quality.
The most important category  will be those projects that will  lead  to
attainment of water quality  standards  and beneficial uses of waters.
States will be expected to use this categorization of  projects as  an
important factor in their planning  and priority-setting activities.  Some
states may have already accomplished much of this  activity through their
existing water quality management plan.

     States will also be asked to develop a  schedule of current  and
future projects for completion of the  entire Construction Grants Program.
Two schedules will be requested:  one  based  on  a funding  target
established by the Agency, and another showing  the fastest  possible
completion of the program if there  were no  funding constraints.  These
schedules, used in conjunction with the strategies that states will perpare
will also allow an assessment of the effects of various reduced  levels of

     In conjunction with this emphasis on water quality results, the
draft 1990 Strategy also proposes some revisions to  standards.  One
revision is to modify the technical definition  of  "secondary treatment"
to allow biological treatment processes such as trickling filters  where
appropriate.  Another is to  develop a  strategy  for controlling CSOs and
urban stormwater runoff that addresses compliance of municipal  facilities
with permit conditions during wet weather,  high-flow conditions.  A third
revision is to encourage states to  gradually phase consideration of
toxics into water quality standards.

     Significant changes are proposed  in  the  way  funding decisions are
made, in the operation of the grants process,  and  in  the follow-up to
assure that the facilities built  are in compliance with  their permits.

 In  each  area  the  1990  Strategy proposed giving states the primary
 responsibility  for  administering  the program.   The federal  role will
 be  three-fold:  to  ensure  that states are making reasonable progress
 toward national goals  and  effective use of federal funds, to provide
 management  and  technical assistance, and to represent overriding
 federal  concerns  in special  instances.

     A wide variety of alternatives for funding mechanisms, eligibilities,
and the program implications of various funding levels has been analyzed
in the development of the Funding Strategy staff paper (Task I of the
Draft 1990 Strategy), which is available for review.  EPA deemed it
inappropriate to include specific recommendations related to funding in
this draft, in light of current national economic conditions and the
necessity for the new Administration to address that situation
comprehensively and immediately.   Therefore, proposed goals and timetables
for completion of the program are based on current funding levels, with
the full understanding that those targets may need to be modified in light
of revised program funding.  As the Administration develops its new
budget, the Agency will make those revisions.
 Operations—An Efficient  and  Effective  Grants  Program

      An  important element  of  the  1990 Strategy is a  series  of  changes
 aimed  at  correcting  shortcomings  in  the present  process  of  applying  for,
 obtaining,  and carrying out grants under the program.  The  Construction
 Grants Program has been criticized for  taking  too long,  sometimes  over
 ten years,  to complete a  single,  moderate-si zed  project;  for involving
 excessive paperwork  and procedural requirements; and for  requiring small
 systems  to  meet many of the requirements that  are really  only  appropriate
 for much larger systems.

      Several changes are  intended to shorten the time  required to  get
 through  the grants process.   The  substantial delegation  of  the program
 from the federal  government to  the states  should help  shorten  time
 requirements by eliminating dual  state-federal  reviews.   In addition,
 states will be encouraged  to  hold preapplicantion conferences  and
 otherwise provide guidance to applicants early in the  process.  EPA  will
 develop  and provide  aids  to the states  such as a tracking system with a
 model  CPM chart showing the schedule of activities that  other  states,
 such as  California,  have  developed to streamline their programs.

     A  significant  change  directed  at  shortening the time in the grants
process  is  the  establishment  of contracted time schedules.  Under this
practice, the grantee  and  the state will  agree during the facility
planning stage  to  specific time schedules for' major activities for the
remainder of the project.   These schedules form a "contract" that is
binding  on  both the grantee as a condition of its grant and on the state
for  its  various review and approval  activities.  Additional timing
improvements will  also result from  changes in two other areas which are
objectives  in their own  rights—simplifying the grant procedures, and
providing more  local responsibility and flexibility.

     Simplifying the grants process is   .  be accomplished through
consolidating some  requirements and providing increased flexibility in
how  localities  and  states  meet other requirements.   EPA will revise its
grants  regulations  where  necessary  to  ensure that states have sufficient
flexibility to  implement  and  manage their programs  as efficiently as
possible.  States will  be  encouraged to make their  requirements for
localities as flexible as  possible  while  maintaining the environmental
and  economic integrity of  the program.   The procurement requirements will
be simplified as much  as possible.   EPA will  also work with other federal
agencies to determine  the  feasibility  of consolidating requirements for
compliance with the more than 50 federal  laws or regulations that affect
construction grants projects.

     Local  responsibility,  and with it  flexibility,  is to be increased
for  qualified communities  under the Strategy.  Grantees that have
demonstrated adequate  capability and sound management will be certified
to manage a substantial  part  of the grants process  themselves,  without
state or federal review of many agreed  upon activities.  In addition, the
Strategy recommends requesting the  legislative changes needed to allow
advanced work on Step  2, the  detailed  design activities, before full
approval of the Step 2 application.
     Small communities are of  special concern to EPA.   They account  for
the greatest number of grants  in the program, but  generally lack  the
technical and management staff who  are experienced with projects  such as
those funded in this program.  Their problems are  often different from
those of the larger cities, yet they are  frequently  required to  follow
the same procedures that the larger cities  follow.   To  deal  more
effectively with the special needs  and conditions  of small  communities,
the 1990 Strategy encourages states to greatly  simplify the grants
processes for small communities.  EPA will  facilitate  the simplification
effort by providing generic facility plans  that can  be  used for  common
small system conditions.  EPA  will  also encourage  the  use of third-party
management arrangements under  which an experienced outside  person manages
the community's grant  activities.

Compliance—The Integrity of the  Program

     The final step  in  administering  the Construction  Grants Program is
the follow-up to assure that facilities  funded  under the  program are in
compliance with their discharge  permits.  The  draft  1990  Strategy
includes proposals to improve  the quality of compliance  information, to
improve the  compliance  rates of  new treatment  systems  being completed
under the program, and  to improve the  compliance  rates of existing
treatment systems.

     To improve the  data on compliance,  EPA will  improve  and expand its
existing compliance  data management system to  enable the  states  and EPA
to make maximum use  of  the  present monitoring  data that  are already being
collected and reported.  Use of  POTW  performance  reviews  by the  states is
recommended  as a means  of improving the  quality of this  self-monitoring
data.  Some  redefinition and ranking  of  "noncompliance" events  must also
be developed in order to more  easily  distinguish  those systems  that have
serious compliance problems from  those that have  violations less serious
in degree, frequency, or type.

     The proposals that will improve  the compliance  records of  new
facilities are designed to  improve the design  and project management
activities of the process to ensure that the systems designed and built
will be appropriate  and operable  under various  conditions.  The  Strategy
reaffirms the necessity of  a pretreatment program for  every POTW which
has significant industrial  flows  into  it.  Moreover, the  Strategy
recommends that the  start-up assistance  eligibility  for  new plants be
expanded to  insure that each plant is  fully operational before  being
turned over  to the community.  Plans  to  modify  the guidance for
infiltration and inflow analyses  to be more realistic, and a proposal  to
develop conditions for  wet  weather deviations  in  permits  under  selected
circumstances are also a part  of  the  recommendations in the compliance

     The approach to achieve compliance  at existing  facilities  is two-
pronged:  (1) providing information and  assistance,  and  (2) maintaining a
strong enforcement program.  A key element in  the first  area is
requiring, where appropriate,  diagnostic reviews  of facilities that are
in serious noncompliance.  These  reviews can cover all aspects of
operation including  management, financial  management,  staffing,
operation, maintenance and quality control.  One  product  of such an
evaluation would be  a composite correction  program (CCP)  to correct all
the deficiencies that contribute  to noncompliance.  The community would
be responsible for carrying out the CCP  and achieving  compliance.

     The draft Strategy proposes  that the  CCP form the basis for the
state's assistance to the local community.  It  may identify specific
areas in which the community needs technical, management,  or financial
assistance,  and may  even suggest  innovative management techniques  for  the
community, such as the "circuit rider" concept.

     Finally, the CCP would also  be a  focus  of  aggressive  enforcement
actions against recalcitrant  communities.  Because  the CCP cites the
specific actions that the local community  should  undertake to achieve
compliance, it is the ideal focal  point  for  enforcement efforts.  Strong
actions, including court action,  sewer bans,  and  compulsory third-party
management, will be taken when  necessary to  get communities to implement
their CCPs on agreed upon timetables.  Communities  must realize that
they, as well as industrial sources of water pollution, will  be subject
to strong enforcement action  and  will  be responsible  for maintaining
their facilities in compliance.   Enforcement  action will be used against
existing plants as well as municipalities  which have  not yet  constructed
plants, and against minor as  well  as major facilities.

     The long-run compliance  of sewage treatment  facilities rests with
the municipalities and will be  a  function  of each POTW's management
capability and financial strength.  The  Strategy  seeks to  assure long-run
compliance by encouraging the financial  and  management self-sufficiency
of wastewater utility systems.  Localities must be  prepared to collect
adequate revenues to cover their  long  term water  quality management
needs.  This is to be accomplished by  clearly recognizing  that such
long-term responsibilities fall to localities.   Each  POTW  should develop
a financial and management plan for the  future  to demonstrate its ability
to become self-sufficient.

     As stated earlier,  a  key  element of  the  1990  Strategy is  changing
the roles of the state and federal  governments:  full  delegation  of the
operational and direct management  aspects  of  the program will  rest with
the states and policy and  managerial oversight  efforts  will  rest  with
EPA.  Under this concept,  delegated states will be responsible for
managing individual grant  projects  and for managing the grants program
within their states.  The  states will be  given  considerable flexibility
in how they choose to administer the program  and will  be held  accountable
for the achievement of the program objectives.  EPA will  set national
program goals, review and  approve  state programs,  regularly monitor the
performance of the states, and  have some  involvement in those  projects
where there is an overriding federal concern  due to special

     This  management  approach  is  built  on achieving full delegation of
all activities to all states.   Delegation is  presently being slowed, and
in  some cases stopped, by  institutional  barriers.   In order to remove
these barriers, EPA will  look  for  legislative and  regulatory changes
allowing all  operational  responsibilities to  be delegated.  This would
include such  responsibilities  as  bid protest  resolution, MBE/WBE, wage
rate determinations,  NEPA  activities,  final resolution of audit
exceptions, and other currently non-delegable activities.

     To ensure that  water  quality objectives are continuing to be met and
that the program  is  running  effectively and efficiently,  the Agency will
have to participate  in  monitoring and oversight of state programs.

     State performance  will  be  evaluated against the following four
general performance  characteristics:   quality of projects funded;
timeliness of planning,  design,  and construction of facilities;
preservation of program integrity;  and management of the program.
Specific state performance measures have been developed for each
category.  These  should  be used  as  tools for evaluating each state's

     EPA will develop a national  oversight  program that combines an
annual evaluation  (performed  by  an  evaluation team) with  periodic
regional reviews  of  state-specific  objectives.  The annual  evaluation
stresses program  outcomes  rather  than procedures and will  focus on
national objectives  such as  the  state program's fiscal  integrity, and
that high quality, environmentally  sound,  and cost effective projects are
being funded.  Specific  performance measures to be used in  these
evaluations will  be  developed.

     Some specific state objectives will  be negotiated  by the state and
Regional offices  in  a system  of  management  by objective.   The state will
submit an annual  report  detailing its progress towards  meeting the
objectives.  These reports will  be  reviewed by the Regional  office.  This
will allow EPA to  consider state  variations for particular  objectives
while not losing  sight  of  the national  objectives.

     In conjunction  with the  monitoring program, EPA will  maintain a
system of incentives and sanctions  to ensure that, once each state has
accepted full delegation,  its performance  is sustained  and  national
interests are protected.  An  effective  system rewards good  performance;
thus, the emphasis in the EPA system will  be placed on  the  positive and
incentive side of management.  States with  well  managed programs will  be
noted to Congress  and used as examples.

     If, during the  course of an  evaluation,  EPA finds  a  state's
performance is lacking  in  an  area,  it will  work directly  with the state
to provide technical  or  management  assistance.  In severe  cases, or where
state performance  deteriorates,  EPA will  request legislative adjustments
for the following two authorities:

     t    To withold the 2% of 205(g) monies for use by EPA to administer
          the program itself, either  through contract or  other third
          parties  or with  in-house  staff; and

     •    To terminate  or  suspend construction grants program assistance
          to projects in the  states,  until  such time as the state
          performance meets  national  standards.

     These sanctions will apply  only  in cases of severe performance
problems, and will be based on  uniform criteria known to  the states in
advance.  This specific  criteria  will  be  developed in conjunction with
the state and other  relevant  officials  as  part of the action plan.


     The 1990 Strategy development process  has  reached  a  major  milestone,
but it is not yet complete.  The preliminary draft Strategy  currently
comprises a set of proposals consolidating  initial work in a variety of
areas that is now ready for public review and comment.  The  development
of these proposals has already  involved the active participation  of a
diverse group of people representing state  and  local  governments,
consulting engineers, environmentalists, labor,  industry,  public  interest
groups, and the public at large.

     In the coming weeks, these and other groups will have the
opportunity to comment on the preliminary draft  strategy  in  public
meetings and in written documents.  After receiving comments, the Agency,
under the new Administration, will incorporate  appropriate modifications
and then publish a proposed 1990 Strategy.  After further comment and
revision, EPA and the states will then begin their implementation of the
final Strategy through a combination of legislative,  regulatory,  and
aministrative efforts.

                      I.   APPROACH TO THE 1990 STRATEGY


     The preliminary draft 1990 Strategy for the Construction Grants
Program proposes changes to improve the program and thereby achieve
further progress toward the goals of the Clean Water Act in the next
decade.  The proposed strategy includes recommendations for changes
designed to streamline the program, make the expenditure of grant funds
as cost-effective as possible, and reduce unnecessary regulatory require-

     Implementation of the proposals which constitute the final 1990
Strategy will require the cooperation and joint efforts of Congress, the
Administration, the States, and local governments.  In some cases
legislative changes will be required, in other instances regulations may
need to be changed, and in still other cases administrative actions such
as State-EPA delegation agreements must be developed or revised.  All of
this will require time and cooperation.  The purpose of this draft is to
solicit comments on the substance of these proposals.  EPA recognizes
that many of the proposals it is formulating in the 1990 Strategy will
eventually be made formally as proposals to Congress and could not be
implemented unilaterally.  The Agency is pledged to cooperate closely
with all parties to implement whatever modifications are needed in the
program to achieve its goals effectively.

     This preliminary strategy stems from a comprehensive examination
of the Construction Grants Program, including its successes and failures
in the past and a view of the challenges facing the program in the future.
This process has involved the active participation of hundreds of people
outside the federal government, including state, local, and county
officials, the public, professional engineers, business and industry
representatives, and others.

     The following sections of this Chapter provide a background
perspective for reading and interpreting the recommendations of the
subsequent chapters.  The first section describes the evolution of the
program and of the roles of the federal, state, and local governments.
The next summarizes EPA's rationale in undertaking the 1990 Strategy
effort.  The next section briefly describes the types of activities
and organizations that were involved in EPA's 1990 Strategy development
process.  The final section describes the structure of this document
and identifies other sources of information on the Strategy.


     The Construction Grants Program grew out of a recognition as early
as the 1950's that inadequate municipal sewage treatment was a serious
contributor to the nation's water pollution and that it was a problem for
which many municipalities were not financially prepared.  For almost 25
years the Federal government has participated with state and local
governments in controlling and abating water pollution.  As a result,
water pollution control programs are among the oldest and most
established of the government's current environmental programs.

     Historically, wastewater collection and treatment had been a
municipal responsibility; the agencies that handle wastewater treatment
had generally not operated as self-sufficient utilities.  Unlike their
water supply counterparts, many wastewater agencies were dependent on the
municipality's general funds, received largely from real estate taxes, to
support their operating costs.  In the competition for limited money,
more apparently desirable public facilities such as schools, libraries,
and police and fire stations enjoyed a big advantage over wastewater
treatment facilities in obtaining capital improvement funds for
facilities.  As a consequence, sewage treatment plants often received
the lowest of political priorities when funds for public works facilities
were allocated.  An additional problem involved the long-standing prac-
tice of locating wastewater outfalls downstream from water supply
intakes—thus passing the buck by transporting one community's wastes
to another community's environment.

     It was this background that forced an environmentally conscious
Congress to pass legislation in 1972 designed to protect public waters
from further degradation.  In the absence of an adequate ongoing local
revenue stream for wastewater operation, Congress embarked on a
substantial Construction Grants Program to assist local government in
building badly needed wastewater collection and treatment facilities.
Since local finances were so constrained and many waterways were
classified as being under interstate jurisdiction, the federal program
was in retrospect the fastest and most assured way to effect large-scale

     The Clean Water Act passed in 1972 seeks to "restore and maintain
the chemical, physical, and biological integrity of the Nation's waters."
This legislation is the basis for most of EPA's water pollution control
activities, including effluent guideline limitations for industries, and
municipal treatment works, nonpoint source programs, and the funding of
regional water quality management plans.

     The Clean Water Act identifies two goals to achieve the basic
objective of the Act.  These goals, as they appear in the Act, are
as follows:

     •    It is the national goal that the discharge of pollutants into
          navigable waters be eliminated by 1985

     •    It is the national goal that, wherever attainable, an interim
          goal of water quality which provides for the protection and
          propagation of fish, shellfish, and wildlife and provides for
          recreation in and on the water be achieved by July 1, 1983.

     The Act goes on to require (in Title III) that all publicly owned
treatment works provide a secondary (biological) treatment as a minimum
level of treatment technology everywhere, irrespective of receiving water
quality.  In addition, the Act requires that all POTWs install the best
practicable waste treatment technology (BPWTT) which represents this
minimum level of secondary treatment or whatever higher level is required
to meet water quality standards.  All POTWs are required by the Act to
have BPWTT in place no later than July 1, 1983.

     The Construction Grants Program provides financial assistance to
communities for achieving the objectives of the Clean Water Act related
to municipal sewage discharges.  The program provides funding for up to
75 percent of the eligible capital costs for the construction of
conventional sewage treatment facilities and related projects.  It also
offers incentives to communities for innovative and alternative projects
and a set-aside program for rural projects.

     As of June 30, 1980, $31.6 billion has been appropriated by Congress
under this program, of which $26 billion has been obligated by EPA in
over 19,000 grants to communities.  Of this amount approximately 2,100
projects representing a value of $2.6 billion have been completed.  It
is important to note that P.L. 92-500 is not the first effort in this
area; during the 1956-1972 period, prior to the passage of P.L. 92-500
P.L. 84-600 provided assistance to 13,764 projects in the amount of
$5.2 billion.  Despite these efforts, preliminary data from the 1980
Needs Survey report a remaining eligible need of $119 billion.

     The Construction Grants Program is a major program by any measure.
Not only has it assisted a large number of communities in the past, but
its active grants are also aiding approximately 10,000 communities
currently.  The program is the largest environmental public works effort
in this nation's history and has affected nearly every section of the

     This program is also a very significant part of EPA's overall
responsibilities.  It is a major element of the Agency's efforts to clean
up and protect the nation's waters.  Further, in dollar magnitude, the
Construction Grants Program at $3-4 billion per year has consistently
represented approximately two-thirds of the Agency's total budget, all
going directly to local communities via a state allocation/administration

     The needs of the communities across the country, as identified in the
EPA Needs Survey, will exceed the probable available funding through 1990.
However, because the program has always been viewed as remedial--to assist

communities in correcting longstanding water pollution problems—not as
a federal entitlement program, it is reasonable and responsible to look
ahead to a sunset for the program.  The development of the draft 1990
Strategy has therefore focussed on recommendations designed to make
maximum progress in the coming decade towards achieving the Act's goals
of fishable/swimmable waters.

     As with any program of this size and duration, there have been
substantial accomplishments and also criticisms.  The accomplishments
have included significant improvements in water quality in many areas
and notable progress toward the national goal of achieving an appropriate
level of sewage treatment in every community throughout the country.  •

     Critics have taken the Construction Grants Program to task for its
administrative complexity, burdensome requirements, project delays,
facility performance failures, and high costs.  In fact, the Agency's
own review of the program has documented the numerous administrative
requirements placed on grantees and has determined that for a medium-to
large-sized treatment project, with construction costs of $10-50 million,
the complete grant and construction plrocess can take seven to eleven
years.  EPA's review has also reaffirmed that many sewage treatment
facilities, perhaps as many as 30 percent to 50 percent, are seriously
out of compliance with their discharge permits for substantial portions
of each year (based on a sample of all sewage treatment plants in
operation, not just those funded since the 1972 Act).

     In order to overcome these limitations and to extend the program's
successes, EPA undertook an extensive reassessment of the Construction
Grants Program in five areas:  planning, project funding mechanisms and
priorities, operations, compliance, and management.  EPA's staff reviewed
the program's record in each of these areas and prepared numerous issue
papers outlining the major issues and options facing the Agency.

     Throughout the process, EPA has sought the active involvement of
individuals and organizations outside the federal government.  During the
last six months of 1980, over 75 meetings were held to obtain ideas and
suggestions.  Meetings were held, for example, with representatives of
such organizations as the National League of Cities, the National
Association of Counties, the Conference of State Legislators, and groups
representing sewage treatment plant executives and operators, engineers,
and public interest groups.  In addition, a Policy Board with represen-
tatives from the National Governors' Association and the Association
of State and Interstate Water Pollution Control Administrators have
also particpated in the 1990 Strategy effort.

     A milestone in this ongoing series of meetings and reviews was
marked by two workshops conducted in November at which all interested
groups were represented.  These three-day workshops covered key issues

in each of the five review areas.  The participants debated issues and
offered recommendations for basic changes in the program.  Those proposals
have been a major input to the preliminary draft strategy.

     In the weeks ahead, EPA will be soliciting comments and suggestions
on this preliminary draft 1990 Strategy from all interested parties.
As part of that process a series of workshops will be held in several
cities across the country.  Also, copies of this preliminary draft
strategy document, detailed staff strategy documents covering the five
major topic areas, and numerous issue papers will be distributed.

     Following a full comment period on the preliminary draft strategy,
EPA will revise the document to reflect the agency's response to issues
raised through the process and will include in the strategy an action
plan describing the steps needed for implementation of the recommended
strategy.  That revised document will be the subject of formal agency
policy review before it is published in the Federal Register and is
the subject of formal hearings.


     The preliminary draft 1990 Strategy is described in several documents,
at differing levels of detail.  This one provides a consolidated summary
of the major recommendations in each of the areas of the 1990 Strategy.

     This document is divided into four major sections.  The first, an
Executive Summary, provides a summary statement of the overall thrust
of the Strategy and its major recommendations for change in the current
Construction Grants Program.  This chapter provides an introduction to
the program and the strategy development process.  Chapter II describes
the proposed revised goals for the Construction Grants Program and the
major themes for accomplishing those goals.  The final chapter of this
document, Chapter III, sets forth the specific recommendations for change
in the detailed areas of the program.

     The detailed Strategy options and recommendations are available from
EPA in five separate documents covering:  Planning, Funding, Operations,
Compliance, and Management.  These are the products of the five EPA task
recommendations which are summarized in Chapter III of this document.
These are available upon request from EPA.  They and over 40 detailed
issue papers developed during the 1990 effort are listed in an attachment
following Chapter III.

     A glossary is also included describing key words and acronyms used
in this and other 1990 documents.  A list of all meetings and briefings
held to date in connection with the 1990 effort and a list of workshop
participants is included as the final attachment.

                        CONSTRUCTION GRANTS STRATEGY
     This chapter presents the goals and major foundations of the
proposed 1990 Construction Grants Strategy.  These will set the tone not
only for the construction of publicly owned treatment works over the next
ten years, but also for their operation, maintenance, and long-term
management.  When the Strategy is fully implemented it will bring a more
local, flexible, results-oriented character to the program.

     A strategy does not exist for its own ends--it must be directed
toward specific goals.  There are two types of goals involved in the 1990
Strategy.  One type is the management goals which set forth the direction
of the program over the next decade.  The other type is intermediate,
process goals which set forth the way in which the program should
operate, such as the length of time which should be adequate to
complete a grant.

     The two sections below present both types of goals for the 1990
Strategy.  The first section presents the ultimate environmental goals,
while the following section presents the process goals.

FOR 1990

     One of the prime purposes of the 1990 Strategy is to define program
management goals which will provide overall direction to the program through
the 1980s.  Ideally, the program management goal for the Construction Grants
Program would be to eliminate the discharge of pollutants to navigable
waters from publicly owned treatment works.  Achievement of this ultimate
goal of the Clean Water Act, however, is not financially feasible over
the next decade and there is serious doubt as to whether it will ever be
feasible.  For this reason, the preliminary draft 1990 Strategy has
focused on achievement of the interim water quality goal of the Act
and the implementation of best practicable waste treatment technology
(BPWTT) as the basis for program management goals through the 1980s.

     The two specific program management goals that EPA proposes to
Congress to guide the Construction Grants Program through the 1980s
are as follows:

     •    To achieve water quality wherever attainable which provides
          for the protection and propagation of fish, shellfish, and
          wildlife and provides for recreation in and on the water,
          by July 1, 1990.

     •    To achieve best practicable waste treatment technology (BPWTT)
          at all publicly owned treatment works as soon as practicable.

     These two program management goals are identical to the interim
water quality goal and the BPWTT requirements contained in the Act, with
the exception of the dates.  The 1983 dates contained in the act are no
longer considered feasible, given the magnitude of the costs necessary to
achieve these objectives and given the anticipated funding levels of the
next decade at federal, state, and local levels.


Relative Importance of Each Goal  to the Strategy

     EPA proposes that the first program management goal-achieving fish-
able/swimmable waters by 1990-should be given top priority in admini-
stering the program. That will obtain the maximum benefit from the limited
funding and other resources available, by supporting those projects which
will affect water quality the most.  While the 1990 date for achievement
of fishable/swimmable waters is the final date for completion of projects
necessary to achieve this objective, most municipalities will be required
to complete their projects earlier, in accordance with the compliance
schedules contained in their NPDES permits based on the state strategy.

     EPA proposes the second program management goal-achievement of
BPWTT as soon as practicable-to place further emphasis on achievement of
a minimum standard for wastewater treatment everywhere.  This goal of
BPWTT, presently a minimum of secondary treatment, is needed to provide
a minimum level of removal of conventional and toxic pollutants prior to
wastewater discharge everywhere.   This objective is important for the
long-term enhancement of surface water quality, maintenance of public
health and protection of ground water resources.  Achieving this
objective may extend beyond 1990 depending on funding levels and staff
resources of states and municipalities.

     These goals will be difficult to achieve and will require the
coordinated efforts of all levels of government.  However, EPA anticipates
that it would be reasonable to achieve the goal of fishable/swimmable
waters by 1990 through the careful selection of priorities and implementation
of the changes proposed in the preliminary draft 1990 Strategy.  This is
based on a review of the Needs Survey data, including a detailed case
analysis in four states and extensive discussions with state and
Federal officials over the last several months.  The states' individual
strategies for achieving the fishable/swimmable goal will provide the
basis needed to propose a specific date for the achievement of the second
program management goal for BPWTT.  The basic purpose of these two program
management goals is to provide overall national direction to the management
of the program through the 1980's, and to direct limited grants funds
towards projects which best facilitate achievement of goals of the Act.
Modified funding levels would obviously  change  the  time schedule  for
attainability of both  of  these goals.

     Although the goals support the concept of directing limited funds
first to projects which have the greatest impact on water quality, this
should not be viewed as a weakening of EPA's commitment to achievement
of secondary treatment everywhere.  EPA feels strongly that technology
based treatment standards must remain a key element of the national
municipal treatment program and that all communities must achieve this
goal.  Given limited funding for all desired projects, however, it is
preferable to fund those secondary treatment projects which result in
fishable/swimmable waters, or which significantly improve water quality,
prior to funding secondary treatment projects with  limited water quality
impacts.  Eventually, all secondary treatment projects should be constructed,
as they are the foundation for the national water pollution control  program
under the Clean Water Act.

     The proposed program management goals raise the question of whether
EPA might recommend "sunset" of the program after the achievement of the
fishable/swimmable goal.  In response to this, EPA's position is that there
should be a sunset to the construction grants program.  The challenge is
to identify a realistic date for sunset.  It will depend on the economy,
the rate at which progress is made toward program goals, and the potential
availability of alternative funding at the Federal, State or local level to
complete the program.  So, while EPA believes there should be a sunset to
the program, the agency also believes strongly in the need for the program
to be completed, i.e., that all required BPWTT projects should be constructed.
While continuing to support the federal grant program as a major source of
funding for achieving this goal, EPA also proposes, in the draft strategy
that States maximize the use of limited federal funds by reducing the
federal share of project costs, eliminating or restricting the eligibility
of certain types of projects, and developing state financed loan programs.
Yet another option which merits careful consideration is the eventual
substitution of a federal loan program for the present grant program, as
discussed in the Funding Strategy paper.

     EPA believes that the successful achievement of these two program
management goals is essential if the goals of the Clean Water Act are to
be realized.  The Agency, therefore, recommends that these two goals be
the dominant guideposts for both management of the national Construction
Grants Program and for state management of the program over the next
decade.  EPA intends to maintain its focus as well as the focus of the
states on these goals by using progress toward these goals as the primary
basis for evaluating each state's performance in administering the program.
Relationship of Goals tn the National Municipal Policy & Strategy (NMPS)

     These proposed program management goals have some implications for
implementation of the National Municipal Policy and Strategy (NMPS),
which directs EPA enforcement towards major municipal dischargers and
establishes a system of coordination between those enforcement efforts
and the Construction Grants Program.  A major goal of the NMPS is to
assure that grant funding is available to major municipalities with
projects necessary to meet enforceable requirements of the Act.

     The proposed program management goals for the 1990 construction
grants strategy emphasizes the funding of projects with substantial
water quality impacts, whether or not they are major municipal projects.
In most cases, major projects will have a significant impact on water
quality, but for some major projects, this will not be the case.  It is
likely, therefore, that the priorities established for some major projects
with minimal water quality impacts will not be emphasized under the 1990
Strategy as strongly as they were under the Municipal Policy and Strategy.
This is not to say these large municipalities will go unfunded.  On the
contrary, in order to meet the BPWTT program management goal, the major
municipality will be involved in planning, design and construction
over many years, because of the magnitude of the projects.  Thus the 1990
Strategy could result in a more extended schedule for these major projects,
but it is likely that planning, design and construction activities will be
underway at a significant rate over these next 10 years.  It is EPA's intent
to continue to utilize the National Municipal Policy and Strategy to track

the progress of the major projects and, where appropriate, take enforcement
actions.  The 1990 Strategy may lead to the extension of the compliance
schedules for some of these projects, but the NMPS will continue to be used
as a prime mechanism for keeping these projects moving ahead in accordance
with the revised compliance schedules and should be developed jointly with
the State strategies.

1990 GOALS

     To achieve the two goals identified in the previous section the
preliminary draft 1990 Strategy has seven major themes for change or
redirection of the program.  These often cut across the specific areas
of funding, compliance, and so on, to provide a common underpinning for
the program's redirection at this time.  These seven major themes are:

     •    Maintenance of minimum, technology-based treatment standards,
          but greater emphasis on water quality impacts of projects
          as a basis for priority-setting and decision-making;

     •    Expanded state responsibilities, through legislative and
          regulatory changes, to the point that virtually all
          project-related activities will be delegated to states,
          and EPA will concentrate on achievements of national
          objectives through the state-administered program;

     •    Streamlining the grants process to make it more flexible,
          faster, and less burdensome;

     0    Establishment of a simplified grants process for small grantees;

     •    Emphasis on future need for POTW self-sufficiency, to
          sustain compliance on a long-term basis;

     •    Increased management attention to compliance of municipal
          treatment facilities; and

     •    Continued encouragement of innovative and alternative

     Each of these major themes is discussed in the following sections.

Emphasis on Water Quality  Impacts in Setting Priorities

     In this preliminary draft 1990 Strategy, EPA is proposing to reaffirm
the basic water quality orientation of the Clean Water Act.  The draft
recommends explicitly that decisions and priorities under the Construction
Grants  Program should accord significant weight to the potential water
quality impacts of proposed projects.

     Implementation of this emphasis on water quality-based priorities
is described later in the detailed recommendations related to planning.
In order to emphasize this commitment and to be able to evaluate states'
progress in this area, EPA has established two programs goals:

     •    By early 1983, all States should have categorized their
          construction grants projects according to water quality
          impact and completed their State Strategy outlining the
          ways they will achieve the two program management goals.

     •    Annually, in the EPA review of state programs, states will
          demonstrate that they are funding projects in accordance with
          their state strategy and maintaining adequate programs to
          achieve the two program management goals.

Management:  Federal, State, and Local Roles

     Another central theme to the 1990 Strategy is a commitment to full
and rapid delegation of the Construction Grants Program to the states.
This extends the current policy to include delegation of activities
previously considered nondelegable, such as payments to grantees and
deciding most disputes, grant offers, appeals, and protests.

     This element of the preliminary draft strategy is also a direct
response to numerous recommendations made to the Agency by representatives
of public, local and state governments, and others during the strategy
development process.  The rationale for this recommendation is twofold.
First, it was felt that the states have more knowledge of local and
regional circumstances, are better able to follow-up local implementation
within the state, and are doing much of this already.  Second, full
delegation will allow EPA to focus limited resources on the national,
programmatic aspects of the Construction Grants Program, and to perform
a valuable function in policy-setting, long-range planning, management
oversight, and technical and management assistance.  It will also allow
EPA to focus on the most critical areas of national interest in
environmental and fiscal areas.

     It has been acknowledged by many that states have differing levels
of experience, resources, and readiness to assume full delegation of the
program.  Accordingly, delegation may be slower and may require more
assistance in some states than in others.  Nonetheless, EPA has been
urged not to delay, but rather to delegate rapidly and to assist states
which request assistance in making the transition.  Consequently, the
following goals are incorporated into the 1990 Strategy:

     •    By the beginning of FY 1983, all States will have agreed to
          accept delegation of all  activities (including those currently
          non-delegable), with assumption of the program no later than
          2 years after the signed agreement.

     •    By the beginning of 1983, a management evaluation system will
          be in place so that EPA can oversee state performance to
          ensure that national objectives are met.


     For various reasons, including congressional mandate, many require-
ments have been added to the construction grants program.  The result is
now a maze of paperwork and specific requirements that frustrates local
communities and helps stretch the time for completion of a moderately
sized treatment facility to an average of seven to eleven years.  There
are literally dozens of specific requirements, ranging from giving
adequate technical considerations to alternative waste treatment
techniques, such as land application, to ensuring that minority
businesses are included at appropriate levels.

     Some improvements can be made within the current construction grants
process.  Delegation of the program to the states will help ease these
problems by eliminating dual state and federal reviews and by placing
program responsibility at a level of government which is closer to local
communities.  Likewise, within the present program structure, time
requirements can be shortened by improved time management, including
scheduling more activities in parallel, combining some review and
approval steps, and establishing time targets for reviews and approvals.

     These are important steps in easing the administrative burden and
shortening the time it takes a community to get through the grants
process, but EPA intends to go one step further.  The Agency is proposing
a basic shift in its grant regulations, from specifying procedural
requirements to focusing instead on results and giving grantees more
flexibility in how to achieve them.

     The combination of these changes—delegation to the states,
improving time management and providing more local flexibility in how to
meet program requirements—should result in significant streamlining of
the program.  EPA is establishing the following goal for these efforts:

     •    On average, a greater than 25 percent reduction will be
          achieved in the time required to complete the grants process,
          from the initial Step 1 application through project closeout
          without sacrificing project quality or achievement of national

Small Community Grants Process

     In its meetings with various organizations and the public in
developing the preliminary draft 1990 Strategy, EPA has heard an almost
universal plea for a greatly simplified grants process for small
communities.  The experience of state and local officials and others
in the field indicates that the needs of small and large communities
are usually quite different, as are their technical and managerial
resources to deal with the grants process.  The general feeling has
been that many of the requirements which are appropriate for medium
to large communities are not needed for most small communities.
Examples might include intensive waste surveys, complex procurement
requirements, and the evaluation of very sophisticated treatment
processes.  Many  people  have also felt that the paperwork required
of small communities could be greatly simplified.

     The present grants process already does provide flexibility in some
of these areas but it is not fully utilized in practice.  For example, a
number of small communities are currently able to complete the grants
process in just a few years for simple projects, but for most small
communities the process takes much longer.  Furthermore, widespread
experience indicates that small communities generally find themselves
complying with requirements and filling out administrative forms which
they feel are not relevant to their waste treatment and disposal

     As a result, EPA is proposing, as an element of the 1990 Strategy,
that each state be encouraged to develop a simplified grant process for
small grantees.  States will be encouraged to develop separate management
procedures and requirements to assist small communities and to facilitate
their compliance with program requirements.  EPA will allow states
considerable flexibility in this regard and will also provide states
with tools to be used in this effort.  For example, generic facilities
plans for use by small grantees will be developed.  Also, EPA will
encourage funding of third party managers to assist grantees in managing
their projects.  The accompanying goal of the strategy in this area is:

     •    By January 1983, the states electing to establish a separate grants
          process for small communities will have established processes
          that reduce the overall time required to complete projects by
          50 percent.

Muni c i pal Self-Suffi ci ency

     The ultimate success of the Construction Grants Program rests not
with the federal government, nor even with the states, but with the local
communities.  It is the municipalities which bear the responsibility for
operating the treatment plants effectively, maintaining their systems in
good working order, replacing capital equipment over time, and expanding
their systems where necessary.  The municipalities also have the
accompanying managerial responsibilities for hiring and supervising
qualified staff, planning and overseeing various activities, and
maintaining a sound financial position to support these activities.
Currently, grantees are required to develop financial plans which
identify how they will fund construction of a proposed facility and its
subsequent operations and maintenance.  In general, however, grantees do
not develop financial or management plans aimed at meeting their
long-term needs.

     The need for a sound financial position is an especially critical
point.  In these times of increasing pressure to hold down government
costs, municipal sewage districts will continue to operate with tight
budgets.  Yet an adequate budget is crucial for communities to
successfully carry out those local responsibilities.  In that sense the
financial position of the sewage district may be the "acid test" of
whether the facilities will be operated, staffed, maintained and expanded
as necessary so that they achieve the long-run water quality objectives
for which they were constructed.

     EPA will assist POTWs  to achieve self-sufficiency by allowing
funding for the development of a long-term financial and management
plan for each municipality.  The purpose of this plan will be to identify
the long-term financial needs of the municipality, in terms of the
operation, maintenance, and expansion of its wastewater facilities and
the means by which those needs can be satisfied.  In addition, the plan
should provide a management element to insure that any necessary expansions
or modifications are initiated in sufficient time to insure compliance with
effluent requirements.

     As a result, the following goals are established in this area:

     •    All grantees will have developed long-term management and
          financial plans prior to completion of their grant project, or
          otherwise demonstrated to the satisfaction of the state that
          they have adequate plans and resources to become self-sufficient
          and to maintain continuous long-term compliance with effluent

     t    States will be required to include in their state strategy to
          meet program management goals a program to ensure that POTWs
          are self-sufficient, that they remain in compliance, and that
          they initiate plans for needed expansions in ample time to
          maintain continuous compliance.

Management Attention on Compliance

     One major thrust of the preliminary draft 1990 Strategy is to meet
the challenge that too many treatment plants are operating out of
compliance with their discharge permits.  The problem is not just that
many plants are in "technical" violation of their permits, but also
the analyses that estimate 30 to 50 percent are seriously out of

     Several detailed actions are recommended later in the Compliance
section of the next chapter to focus significant management attention at
all levels of government on compliance as a major goal of the Construction
Grants Program.  In order to accomplish this commitment, the Strategy
includes recommendations in three areas.  One is improving the availa-
bility, use and quality of current monitoring data.  That includes
expanding the concepts of "compliance" and "noncompliance" to
differentiate better between instances of serious versus minor
noncompliance.  Another area of recommendations is related to assuring
the compliance of new facilities which are yet to be completed.  The
third area is shaping a strong diagnostic assistance, and enforcement
program to substantially reduce the incidence of serious noncompliance
at existing facilities.  A strong enforcement program will be an
important element of the 1990 Strategy for achieving compliance at
both major and minor facilities.  An important long-term aspect of
this approach is also encouraging the financial self-sufficiency
of treatment works, as described above, to ensure that communities
are able to maintain their systems in good condition and operation
in the long run.

     To this end,  the following goals are incorporated into the draft
1990 Strategy:

     •    The percentage of communities with serious noncompliance
          problems will be steadily reduced in all states from the
          present levels estimated to be 30 to 50 percent, to less
          than 5 percent by 1990, and strong enforcement action
          will be taken against those communities remaining out of

     t    Each state will establish intermediate goals related to
          reduction of the percentage of communities with serious
          noncompliance problems, in conjunction with its state

Innovative and Alternative Technology

     The Clean Water Act includes significant emphasis on the role which
innovative and alternative technology should play in the Construction
Grants Program.  Congress envisioned that innovative and alternative
technology would be significantly more cost-effective than conventional
processes in many situations, and that it could offer superior
environmental benefits, such as reducing water usage by increasing
water reuse.

     The 1990 Strategy proposes not only to continue the current
innovative and alternative technologies program, but to strengthen
it in several ways.

     First, innovative technology will be further encouraged through
the direct sponsorship of selected pilot projects.  These will be
geared to demonstrate the technical and financial viability of emerging
innovative technologies in order to reduce the risks to localities,
and speed up acceptance.

     Second, the 1990 Strategy also includes recommendations to make the
present higher funding percentage for innovative projects fully applicable
whenever over one-half of a project can be considered innovative.  The
draft 1990 Strategy proposes a recommendation to Congress that a 1 percent
set aside be made permanent for innovative projects to remove present

     Third, EPA intends to encourage and assist states in the development
of small systems offices which will promote the use of innovative and
alternative technologies in small communities.  These offices will also
disseminate technical information to these communities and their

     To emphasize this commitment to innovative and alternative
technology, the draft 1990 Strategy includes the following goal:

     •    Each state will be encouraged to develop specific targets
          in its state strategy for the numbers of innovative and
          alternative projects which it will attempt to fund throughout
          the next four years.

                                    27 .


     This chapter presents the preliminary draft 1990 Strategy's major
recommendations for changes in three basic aspects of the Construction
Grants Program.  The first, the planning process, provides  priorities and
the overall context for the Program.  The second focuses on the
administrative elements:  funding; operations of the grants process; and
activities designed to ensure compliance of facilities with their  permits
The third area describes realigned management roles for federal,  state,
and local governments in the revised Construction Grants Program.

     The changes listed here represent  only the highlights  of  the  1990
recommendations in each study area.  This description characterizes the
major issues dealt with in each area and the key changes suggested.
Further elaboration of the issues, rationale, options, and  detailed
recommendations can be found in the full Strategy Document  available for
each of the five topics under separate  cover.

     The water quality planning process  has  significant  impacts  on  the
Construction Grants Program.  This process  is  an  important  first  step  in
the construction grants process,  since  it  provides  the  perspective  of
problems, solutions, and results, and thereby  focuses  attention  on  the
most important water quality  problems.   A  small  investment  in  planning,
compared to the costs of installing  and  operating controls,  can  save
money by solving problems early.

     Planning efforts become  even more  important  when  the  limited funding
confronting the Construction  Grants  Program  is  considered.   In this
situation, the evaluation of  the  attainability  of water  quality
standards, the need for advanced waste  treatment  facilities, and  the
definition of minimum technology-based  standards  are critical.

     The major areas of the planning process discussed  in  the  1990  effort
centered on emphasizing water quality impacts  in  setting project
priorities and evaluation of  some water  quality  standards  to achieve
program objectives.  Each of  these areas and the  resulting
recommendations are discussed in the sections  that  follow.
Water Quality Impacts Will Receive a Greater
Emphasis in the Planning Process

     Extensive discussion supporting an  increased  emphasis  on  water
quality impacts when evaluating project  priorities  occurred  throughout
the 1990 process.  However, there was  also  a  strong feeling  that  1990
recommendations should not require extensive  new planning  efforts.   The

changes outlined below recognize the  validity  of  these  two points  as well
as the reality of limited funds and a continued commitment to  minimum
technology-based standards.

     1.   Planning efforts under the  1990 Strategy will  make maximum use
of existing data, plans, and programs but will re-direct resources to
address the most critical water quality  problems.  Many States and EPA
Regions have strong water quality-oriented  programs  which  use  existing
data effectively in directing their construction  grants programs.   Also,
the portions of the State WQM plans which deal with  municipal  point
sources are the most complete parts of those plans.   However,  despite the
amount of information available, in some States and  Regions the links
between water quality data, problem assessments,  plans, and actions have
been severed, making their programs less effective.   EPA will  work with
the States to develop overall planning and  management approaches directed
toward meeting the fishable/swimmable goals and to set  priorities  tied to
problem assessments for WQS reviews, monitoring,  waste  load allocations,
nonpoint source planning, evaluation, and other activities. The States
should concentrate data gathering  and analysis on streams  where States
are considering extensive capital  investments, such  as  AST/AWT plants, or
where problems (e.g., toxics) aren't  clearly identified.

     2.   Water quality impacts will  be  emphasized in setting  project
priorities and in developing state strategies.  There are  several
potential ways of emphasizing water quality impacts  in  implementing
a priority system.  EPA could develop uniform  national  priority ranking
criteria based on water quality and require each  state  to  utilize  these
criteria in developing its annual  construction grants priority list.
Another possible method would be to improve existing water quality
monitoring data to provide a better foundation for the  establishment of
priorities.  A third option would  be  to  utilize existing water quality
management plans as the basis for  priorities.  All these approaches have
merit, but at the same time, they  have limitations.

     The recommended approach offers yet another  alternative.   It  does
not involve the development of national  uniform priority criteria.
Rather, it places responsibility on each state for developing  a strategy
to meet program management goals.  The state strategy will categorize all
projects within the state into one of three broad classifications  of
water quality impact and will include a  schedule  for the eventual
completion of all POTWs within the state.

     The strategy will be reviewed and approved by EPA.  The state
strategy will result in a shift away  from the  concept of carefully
ranking the projects to receive grant funding  each year and toward a
concept of scheduling project completions based on priorities  and,
specifically, water quality impacts.  The priority list will  remain the
vehicle for determining which projects are  funded in a  given year, but
the list must be consistent with the  schedule  of  POTW completions
detailed in the state strategy.  Due  to  planning  and construction  time
constraints, etc., the annual fundable priority list may show  projects of
lower classification with high priority.  This may be necessary to get
large or complex projects started  so  that they can be completed on

     Ranking projects or establishing  priorities  in this way is not a
departure from technology-based  goals;  it  is  a  method to determine which
of the BPWTT projects to build before  others.   Priority rankings will be
established for all projects within  the state,  but  those with the
greatest impact on water quality will  be  built  first, thus insuring the
maximum environmental result from limited  resources as quickly as

     Another aspect of the  recommended  approach is  that it focuses the
gathering of additional water quality  data  on  site-specific problems
where a determination has been made  that  additional data will be needed
to make a rational priority or funding  decision.  The recommendation
recognizes that existing data will be  adequate  for  decisions on most
projects but not on all.  It provides  for  additional  data collection and
analyses only where needed, and  allows  other  projects to proceed through
the grants process without  delay.  Thus,  the  strategy will be used as a
management tool to prioritize standards evaluations,  waste load
allocations, and additional water  monitoring  data needs, as well as
assisting in scheduling the various  project  phases  of the construction
grants process.  The strategy will also indicate to communities the long
range likelihood of federal funding  for  their  local projects and assist
them in decisions to develop alternative  funding options.

     The specific aspects of the recommended  approach for implementing a
priority system which emphasizes  water  quality  impacts are listed below:

     t    In the state strategy,  states  will  identify all projects or
          parts of projects that  are necessary  to comply with the water
          quality and BPWTT objectives  described in Chapter II and
          classify each project  as follows:

          —Necessary for achievement  of, or  significant progress toward,
            fishable/swimmable waters,  protection of  outstanding natural
            resource waters, or  protection  of  public  health.

          --Necessary only  to meet minimum  treatment  standards (i.e.,

          --Not necessary to meet  the  enforceable requirements of the

          The state strategies should  also  set  forth  in broad terms the
          methods that the  state will use to meet the program objectives.
          For example, the  state  may plan to  lower  the federal  share of
          eligible project  costs,  eliminate some eligibilities or
          implement a state loan  program  in order to  support more
          projects, or it may plan to review attainability on certain
          critical stream segments (e.g., those covered by blanket
          standards or where AWT  projects are planned).   Methods such as
          these should be enumerated in the strategy.   The state strategy
          is not meant to be an  elaborate or voluminous report  requiring
          extensive new analyses.  It should be straightforward and
          concise based on available data, professional  judgment,  and,
          infrequently,  on new analyses.

     •   In the state strategy, states will  Include  a  master schedule
         for all projects in the  first two  categories  above, which would
         complete the Construction Grants  Program.   The strategy will
         also include schedules for completion  of projects  categorized
         as not necessary to meet the enforceable requirements of the
         Act.  Consideration by the states  of these  lowest  priority
         projects (which may not  receive federal  funding)  is necessary
         because the states must  manage the complete municipal
         wastewater treatment  program, not  just those  projects funded by
         federal grants.  The  schedules will  be based  on national funding
         levels.  The strategy will be continually updated  as additional
         progress is made toward  program goals.  States will also develop
         strategies for program completion  under the assumption that
         annual funding is not constrained.

          States will  place the time schedules  derived  above  in  the NPDES
          permits for  each project.   This schedule will  thus  become an
          enforceable element of the permit.  The schedule will  also
          become a condition of the grant thus  obligating those  involved
          to hold to the schedule.  Time schedules for  major  dischargers
          will  be tracked through MMS.

     States will administer the Construction Grants  Program  to maintain
the master schedule designed to achieve program objectives.   The  annual
state priority list should be consistent with this schedule  and  the state
should closely track projects to maintain them  on schedule.   The  state
will be evaluated on its performance against  its  plan  in annual  reviews
with EPA (see Management Recommendations for details).

     3.   Nonpoint source and  industrial point  source  pollution  must  be
evaluated when assessing the priority of a  project.  Meeting  the  goals of
fishable and swimmable waters  involves much  more  than  just the
construction of POTWs--nonpoint sources and  industrial  point  sources  can
affect the attainability of water quality standards.   The existence or
likelihood of significant progress in these  areas must  be considered  when
evaluating the priority of a municipal discharge  project.  Many site-
specific problems involve tradeoffs among these sources.  The compliance
efforts of industrial point sources are relatively far  along (they must
meet a 1984 BAT goal); nonpoint source control  efforts,  on the other
hand, are not as far along.

     Efforts dealing with the  issue of nonpoint source control include
the continuing national EPA effort that focuses on building  a technical
base of knowledge appropriate  for support of  state planning  in the
nonpoint source area (through  the present Water Quality Management
Strategy and outside the 1990  effort).  In  addition, the facility
planning process will be expanded where necessary, to  include an
evaluation of the tradeoffs between different pollutant  sources  as they

  affect municipal discharge requirements  for  advanced wastewater treatment
  systems.   Where complex analyses are required, they  will  generally be
  performed  i/-"^" other  funding programs.

      4.      iTient water quality  emphasis  by improving fiscal, financial,
 and instit   i'ona7 aspects of planning.  The abilities of communities,
 counties,      ^e states to fully implement  the plans and realize their
 goals  de1         '-^'cantly on fiscal, financial, and  institutional
 factor?                « often  given  little attention,  while  major  effort
 is di>                   i-cal  aspects  such  as water  quality monitoring  and
eval-                       ''ant  specification.

standards and the determination of attainability.  States  should  include
attainability determinations in the present required cycle relating  to
review and revision of water quality standards.

     2.   Modify the technical definition of "secondary treatment" to
allow other biological treatments such as trickling filters where they
are suitable^  The current definition of secondary treatment  requires the
           I) of highly efficient and often costly and complex treatment
                                       pities that have an existing  form
                                                              5 not  quite

affect municipal discharge requirements  for  advanced  wastewater  treatment
systems.  Where complex analyses are  required,  they will  generally be
performed under other funding programs.

     4.   Augment water quality emphasis by  improving fiscal,  financial,
and institutional aspects of planning.   The  abilities of  communities,
counties, and the states to fully  implement  the plans and realize their
goals depend significantly on fiscal, financial,  and  institutional
factors.  Yet these are often given  little attention, while  major effort
is directed toward technical aspects  such as water quality monitoring and
evaluation and treatment plant specification.

     The states should focus on the  problems and  capabilities  of their
local management agencies, especially for capital  budgeting  and  long-
term operation and maintenance of  septic systems,  POTWs,  sewers,  and
nonpoint source controls.  This municipal self-sufficiency is  necessary
to long-term success of the program  and  is also discussed under  the
Compliance Recommendations.  In addition, where economic  reasons are a
major barrier in attaining standards, the state should examine options
for innovative financing or such ideas  as a  change in the service area to
improve financing capability or to reduce per  capita  cost impacts.
Selected Revisions of Standards
for Achievement of Water Quality

      Four efforts in the standards  area  are  recommended..  These changes
provide the flexibility needed at the  local  level  to  achieve water
quality goals in a timely and cost-effective  manner.   Each  is discussed
in detail in the following paragraphs.

     1.   Emphasize the "attainability" of water  quality standards.
While the law establishes an interim goal of  achieving fishable/swimmable
waters where attainable, EPA and the states  have  not  given  much
consideration to the concept of "attainability" in the development of
water quality standards or in the establishment of construction grants
priorities.  In several states, many streams  were classified for uses
which are simply not attainable, often due to natural  background
conditions or a lack of adequate treatment technology.  As  a result,  some
advanced waste treatment projects which will  not  significantly impact
water quality have been given priority and been funded.   The
reassessments of stream uses are necessary to avoid building costly AWT
or CSO systems that will not impact  water quality.  It is recommended
that these reassessments be based on the  Water Quality Standards Strategy
which EPA developed and circulated extensively for public comment several
months ago.

     The preliminary draft proposes  emphasizing the concept of
attainability in the development or  reevaluation  of water quality
standards.  To assist states in evaluating attainability as they develop
and update water quality standards,  EPA will  prepare  guidance for the
states.  This guidance will deal with  the technical,  environmental, and
economic factors that should be considered in the development of

standards and the determination of attainability.  States  should include
attainability determinations in the present  required  cycle relating to
review and revision of water quality standards.

     2.   Modify the technical definition of "secondary  treatment"  to
allow other biological treatments such as trickling filters  where they
are suitable.  The current definition of secondary treatment  requires the
construction of highly efficient and often costly and complex treatment
processes.  There are a number of communities  that have  an existing form
of biological treatment, such as a trickling filter,  which does  not quite
meet the current definition of secondary treatment.   Many  of these
existing facilities are also simpler and less  costly  to  operate  than the
more efficient forms of secondary treatment.   The question arises as to
whether EPA should allow a lower level of secondary treatment than
acceptable under the current definition if it  can be  demonstrated that a
lower level of secondary treatment will not  adversely affect water

     EPA has examined this issue and has concluded that  a  lower  level of
secondary treatment would, in many cases, result in considerable cost
savings both nationally and locally without  adversely affecting  water
quality.  EPA has also evaluated two different approaches  for allowing a
lower level of secondary treatment.  The alternatives evaluated  include
allowing a case-by-case waiver similar to the  approach allowed for
discharges to deep ocean waters and establishing a second, lower level of
secondary treatment to be allowed under certain circumstances.

     As a result of these analyses, EPA will  soon open the issue of the
definition of secondary treatment to public  consideration, through  an
Advance Notice of Proposed Rulemaking.  The  definition could possibly be
broadened to take into account local factors,  presense or  absence of
toxic pollutants, and treatment works performance requirements.   EPA
would maintain a technology-based requirement  of biological  treatment,
while attempting to trim the costs of "treatment for  treatment's sake."

     3.   Develop a strategy for controlling pollution from combined
sewer overflows and urban storm runoff.  The problems of combined sewer
overflows  (CSO) and urban storm runoff  (USR) are accompanied by  great
uncertainty regarding their severity and control.  The solutions to these
problems involve the difficult task of  accounting for high-flow  (i.e, wet
weather) conditions in setting water quality standards and writing  and
enforcing NPDES permits.  EPA will work with the States  and local
agencies to develop a CSO and USR control strategy by the  end of FY 83
and continue to build its data base on  problems and controls.

     4.   Phase toxics criteria into water quality standards. While
concern about toxics has grown considerably  over the  past  several years,
many unknowns exist regarding their pathways,  fates,  and environmental
effects.   In addition, toxics monitoring is  extremely expensive.  Strong
tools, however, are available  for assessing  conventional pollutant
treatment  impacts.  Because of this, EPA proposes that states continue to
focus efforts on conventional pollutants over  the  near term, but
gradually  phase toxics into water quality standards and  effluent
requirements as information providing the basis to do so becomes

     Some tools and information do exist for assessing toxics problems.
These should be used in areas where toxics are a significant issue and
where the impact on toxics control should be considered  in determining
project priorities.  As a result, some POTWs that would  receive low
priority on the basis of conventional pollutant control  impacts would
receive high priority upon consideration of toxic pollutant control
impacts.  Furthermore, recent sampling and analysis have shown that
secondary treatment can provide effective removal of some toxic
pollutants.  Therefore, the continued application of technology based
standards requiring secondary treatment to meet the BPWTT goal will  also
contribute significantly to eliminating toxics.

     EPA has developed ambient criteria for some toxic pollutants and
will define the state of the art  in toxics control.  In  addition, EPA
will issue effluent guidelines covering toxic pollutants.  States should
incorporate toxics into state standards and monitoring programs as
information becomes available from EPA.

     Three of the major areas addressed in the 1990 Strategy development
process deal with administrative aspects of the program.  Those  three
are described in the sections which follow and include  funding,
operations of the grants process, and the activities  related to  ensuring
compliance of POTWs with their permits.

     The $119 billion preliminary estimate of needs from the  1980  Needs
Survey is much greater than the funding likely to be authorized  and
appropriated by Congress by 1990.  In light of that fact,  it  is  crucial
that projects be selected strategically to achieve further progress
toward the goals of the Act.  Moreover, funding mechanisms and
eligibilities should also reinforce the objectives of the  program.

     EPA deems it inappropriate to include in the present  draft
strategy specific recommendations related to funding, since the
new administration will almost immediately be addressing program
funding in light of current national economic conditions.  The
Funding Strategy staff paper (Task I of the draft 1990 Stategy)
which discusses specific recommendations and their implications
for the program, is available for review and comment.  Essentially,
those recommendations are that:  (1) while basic funding mechanisms
should not be altered substantially, states should be strongly
encouraged to implement measures such as state loan programs  and
reduction of the federal share to maximize the benefits from  federal
funds; and (2) priorities for project funding should be based on
potential water quality impacts as well as requirements for secondary

      Because one of the  objectives  in developing the 1990 strategy
has  been  to identify all  ways  in which  the Construction  Grants
Program could  be made more effective, many of the  recommendations  in
other areas of the  preliminary draft could result  in reducing
the  estimates  for federal  funds needed  to complete  the program.
The  chart below outlines  the potential  impacts  of  those  recommendations
on the needs reported in  the 1980 Needs  Survey.
                               Table III-I

         I. Secondary
1980  NEEDS*

$ 28.8
         il. Advanced

         IIIA. I/I
$  5.6

$  2.5
         HIB. Rehabil-     $  5.6

         IVA. Collectors    $ 18.4
         IVB. Interceptors  $ 20.8
         V.  CSO (Recrea-    $ 36.5
             tlonal Uses)

             (Fish &      $ 23.0
         *Preliminary estimates

Could be reduced by $840 million
to $4.6 billion over a ten-year
period by including trickling
filters In definition of second-
ary; further reductions possible
if other processes included; use
of Industrial Cost Exclusion
(ICE) could save $5.9 billion
in Categories I and II.

Could be reduced by attainability

Could be reduced by modifying
cost-benefit evaluations.

Could be reduced by restrictive
definitions of eligible projects

Could be further reduced as full
effect of PRM 78-9 restricting
collectors is felt. Could also be
reduced by greater use of alter-
native systems.

Could be reduced by restricting
eligible projects to those neede
for integrity of entire system;
use of ICE could save $1 billion

Could be reduced by focus on
attainable uses.

Change to this water quality
objective could save
approximately 13.5 billion.

Operations—An Efficient and Effective  Grants  Program

     The Construction Grants process  includes  a complex set of
requirements relating to planning,  design,  and construction that
currently takes from seven to  eleven  years  to  complete for  a moderately
sized plant.  Besides the preparation of  applications for  each Step,
there are multiple  reviews throughout the  process  and requirements to
comply with over 50 other federal  laws  in  completing  the process.

     The grants program  is generally  one  of the largest financial and
administrative programs  that many  municipalities,  especially small ones,
will ever undertake.  While the  program is  divided into only three main
Steps, each Step has a significant  number  of requirements  which can be
complex and time-consuming.  For example,  in Step  1  (Planning) grantees
are required to analyze  innovative  and  alternative treatment processes
and techniques that reclaim and  reuse wastewater,  evaluate  potential
opportunities for recreation,  open  space  and access to bodies of water,
and conduct an assessment of the primary  energy requirements for each
considered treatment system.   All  of  this  is in addition to meeting basic
technical and economic requirements and waiting for the state and EPA to
review the facilities plan.  Clearly, there is a plethora  of activities
and actions required of  grantees.   Step 2  is also  complex  because a
complete plant design plan must  be  developed and approved  (by the state
and/or EPA).  Step 3 involves  actual  construction  of  the POTW and the
time needed here can be  significant depending  on the  type  of facility
being constructed.

     The grants process  is long  and involved and few  municipalities have
had experience which is  directly relevant  to helping  them  through it.
Nearly every evaluation  of the Construction Grants Program has identified
similar issues as problems for grantees.   To summarize these issues, the
complexity of the grants process,  the changing of  regulations while
grantees are in the process, and the  length of time required to complete
it all- reduce the program's potential effectiveness.   These problems are
compounded by the fact that despite the program's  reviews,  plants coming
on line are not consistently in  compliance.

     Many small systems  share  other types  of problems in their dealings
with the construction grants process, such  as  a lack  of management
resources, a lack of financial planning,  and use of accounting systems
that differ from those required  by  EPA.  The current  grants process, with
its significant time delays and  increased  costs, has  caused financial
problems for small municipalities which,  typically, are the least able to
afford such costs.

     The issues described above  cover the  broad areas of shortening the
process time, lightening the administrative load,  and improving or
maintaining project quality (building POTWs that meet NPDES requirements)
in the grants process.   Discussions have  led to a  wide variety of
suggested actions.  These include  optimizing the present grants process,
altering the process to  eliminate duplicative  requirements, and the use
of generic plans to expedite the facility  planning process  for small

     EPA has formulated a series of  recommendations  to  address many of
the problems discussed above.   In general, EPA will  simplify the grants
process by Devaluating the current  process  to reduce the administrative
burden and time needed for grantees  to complete  it.   In addition,  full
delegation of the grants program will aid  in eliminating some problems
such as duplicative reviews.  The combination of  these  actions will
substantially reduce the process time (by  at least 25 percent), simplify
the administrative process, and maintain the quality of facilities.   Some
specific actions which will be  taken are:

     1.   The time needed to move through  the grants process will  be
reduced by at least 25 percent.  Full delegation  of  the grants program
will aid in eliminating many time-consuming  duplicative state and EPA
reviews.  EPA will develop aids and  recommend procedures that will reduce
the time in the grants process.  These tools will  then  be made available
for use by the states.

     Types of time-saving measures will  include  development of model
Critical Path Method (CPM) charts, such  as ones  produced by the state of
California, which offer broadly applicable optimization techniques for
concurrent processing of several grants  requirements.   Other tracking
methods which will help keep projects moving efficiently through the
process will also be developed  and made  available to states by EPA.   In
addition, EPA will continue its efforts  in the  area  of  critical path
analysis of the grants process  to determine  the  areas where regulatory or
legislative changes might have  the greatest  impact  on  the time involved
in the process.

     As an added measure to reduce the time  required in the grants
process, states and grantees will be encouraged  to  develop contracted
time schedules as part of the application  for each  of the three steps in
the grants process.  In this way the mutually agreed-upon schedule will
provide a realistic time target to which both  parties  will adhere.

     2.   The grants process will be simplified  and  streamlined.  EPA
will take several steps to simplify  and  streamline  the  grants process
thereby easing the administrative, technical, and management requirements
and burden on grantees.

     •    Simplification of A/E procurement  regulations through
          conformance with OMB  Attachment  0, continuing inter-agency
          review of Attachement 0,  issuing bid  qualifications procedures
          and issuing flexible  guidelines  for  reasonable profits.

     •    Simplification of the eligibility  of  grantees' administrative,
          legal, and fiscal costs by amending regulations to allow an
          option for lump  sum payment  for  those  costs based on cost
          curves developed from examination  of  typical  historical cost

      •   Revision of the  regulations  to remove  unnecessarily
          prescriptive requirements  and  replace  them with responsiblity
          for the states to ensure that  the  functions are carried out
          properly.  This will  be carried  out in connection with full
          delegation and will  be  designed  to provide states maximum
          flexibility in implementing  the  program as efficiently as


     •    Implementation of certification.  Ongoing  pilot  certification
          projects will be used to provide future  guidance for  regional,
          state, and grantee personnel.  Qualified grantees,  having a
          history of successful administration  of  construction  grants,
          will be certified by the states to  proceed with  many  activities
          in the process without further state  review.

     •    Request legislative changes  needed  to modify  current  procedures
          to allow grantees to proceed with design prior to formal
          approval of the Facilities Plan.  Eligible costs incurred would
          be reimbursed at the time the Step  2  grant is  awarded.

     t    Examination  of the consolidation  of procedures for complying
          with  other applicable federal  requirements.  EPA, acknowledging
          the need for  consolidation  of  the  requirements for compliance
          with  the more than 50 federal  requirements impacting
          construction  grants  projects,  will  work  with  other federal
          agencies to  determine the  feasibility of consolidating some of
          these  requirements and will  cooperate in pursuing any
          legislative  changes  needed  for effective implementation.

     •    Special consideration of NEPA.  The requirements of the
          National Environmental Policy  Act  (NEPA),  because of their
          integral relation to EPA's  environmental objectives,  will
          receive special  attention  regarding delegation.   A process for
          allowing full delegation of  EPA's NEPA responsibilities will be
          developed consistent with the  need  to acknowledge that certain
          projects due  to  special environmental, international, or
          interstate concerns, are of  particular federal  concern, require
          federal assistance to assure program integrity and achievement
          of EPA's national environmental objective.

     3.   The grants process will be  greatly  simplified for small
grantees.  Many  small,  rural communities have similar background
conditions and  constraints  in  such areas as  suitability for on-lot
disposal, demographic  characteristics,  and quality of existing
facilities.  An  abbreviated planning  process  and set of generic facility
plans is being  developed by EPA for use  by the  states to greatly simplify
the Step 1 facility-planning process  for communities of less than 10,000.
This will ensure that  all  requirements  can be met  by small grantees
without undue complexity.  These communities  will  be screened and all,
except those communities which the states feel  have  special
complications,  will be  able to use the  simplified  process  and generic
plans for their  own facilities.  The  generic  plans will  be a means of
taking advantage of these  common conditions by  offering cost-effective,
appropriate solutions  for  small communities developing  facility plans.

     EPA and states choosing to do so  will modify  the program to assist
small communities with the administration of  the revised grants process.
This will take the form of funding third-party  management.  Third-party
management will   offer communities the  option  of using state or  private
consultants to  aid them through the grants process.   This  will  expedite
the application  process and help to ensure that communities build
functional plants suited to their needs.  Other actions  will  also be
taken to aid facilities, such as encouraging  preapplication conferences
and intermediate state  reviews to help ensure that small  systems are "on
target" with their plans and understand what  to expect  throughout the
steps of the process.


     4.   The  Agency will  continue to clarify policy guidance in areas
 having  significant  effects on the grants process.  These areas include
 infiltration/inflow  problems,  innovative and  alternative projects, and
 integrated waste management.   EPA will  modify the infiltration/inflow
 (I/I) program to make  it  more  cost  effective  and  accurate and  to  reduce
 the time  needed to  complete  it.  The  agency will  also  encourage states to
 assist  applicants in the  development  of effective sewer  maintenance
 programs  in conjunction with  planning and  designing wastewater  treatment

     Legislative changes  to  the  innovative and  alternative (I/A)  program
 will be recommended  by the Agency  in  order  to encourage  greater use of
 innovative technology.  The  strategy  recommends confining the  use of
 set-aside funds to  innovative  projects  but  continuing  to fund  both
 innovative and alternative at  a  higher  rate than  conventional  projects.
 There are also recommendations to  simplify administration of the  funding.
 The set-aside would  be a  mandatory  minimum level  of one  percent with a
 national  pool established  to  which  unobligated  set-aside monies (not to
 exceed  one percent)  would  revert.

     In light of the recent  burgeoning of waste disposal problems being
 faced by  public officials  at  all  levels of government, EPA is  developing
 a new and more comprehensive  multi-media/multi-waste approach  to  those
 problems.  Integrated Waste Management, the umbrella term being used to
 describe  this approach,  involves  agency initiatives and  pilot  projects in
 a variety of  areas.  Of  particular  concern in this area  to the 1990
 Strategy  are  the problems  being  faced by present  and future operators of
 POTWs.  Treatment of greater  volumes  of wastewater at  higher levels is
 producing greatly increased  volumes of sludge for which  beneficial or
 acceptable disposal  methods  must  be found. At  the same  time the  options
 available for sludge disposal  are  being severely curtailed by
 restrictions  on incineration  and  ocean dumping, the presence of toxics in
 sludge  and the public  concern with  sitting issues.  The  pretreatment
 program is designed to solve  major  parts of this  problem by removing
 toxics  from sludge  so  that it can  be  used beneficially in such ways as
 soil reclamation.   The mandated  development  of local pretreatment
 programs  is being funded  through the  construction grants program as are
 several pilot projects intended  to  demonstrate the feasibility of an
 integrated approach to local  waste  management problems.   These activities
 are described in more  detail  in  the Operations Strategy.
Compliance--The Integrity of the Program

     The  present  level  of  performance of grant-funded POTWs is not
 satisfactory.   Numerous studies of municipal wastewater treatment plants
 throughout  the  country  have estimated that 30 to 50 percent of existing
 facilities  may  be seriously out of compliance for several months a year.

     POTWs  represent  a  major public investment of public funds in
 pollution abatement  that is not producing the anticipated results.
 Making  sure the plants  and other  facilities funded under the Construction
 Grants  Program  work  as  they were  designed to work—that they are in
 compliance--is  critical to achieving the objectives of the Act.  Unless
 facilities  funded through  this program are operating in compliance with

requirements, the public funds  expended  for  this  program will  not  have
accomplished their intended purpose—to  clean  up  the  nation's  waters.

     EPA's proposed strategy to  bring  existing POTWs  into compliance and
to ensure that future facilities are in  compliance will  contain  three
elements.  First, the major thrust  of  the  compliance  program will  be an
aggressive enforcement effort.   The existence  of  violations  of the
technology-based requirements of the Clean Water  Act  will  indicate the
need for potential enforcement  actions.  Facilities which are  in serious
noncompliance, and especially those which  are  recalcitrant  in  their
efforts to comply with the Act,  will be  targeted  for  strict  enforcement.

     Second, the management of  POTW compliance data will  be  improved to
better determine the significance of compliance violations.  This
information will provide additional input  to ongoing  enforcement actions.
The information will also aid in funneling advisory and  direct assistance
to facilities which have the worst  problems.

     Third, the preliminary compliance strategy encourages  the concept of
municipal self-sufficiency for  operating and maintaining POTWs.   The
enforcement program and data systems have  as their ultimate  aim
municipalities taking full responsibility  for  meeting NPDES  requirements
on a consistent basis, as required  by  the  Clean Water Act.   As can be
seen in the discussion below, states will  be the  primary vehicles  for
direct interface with POTWs in  the  areas of  technical  assistance and
assuring long-term municipal self-sufficiency. EPA will  offer guidance
at a national level and maintain an aggressive enforcement  program in
conjunction with those states which have been  delegated  authority to
manage the NPDES program within  their  jurisdiction.
Compliance Data

     In order to make  better  evaluations  of  the  significance  of
noncompliance or the means to bring  about a  return  to  compliance,  there
must be better coordination of  compliance data that is currently
available.  Information obtained  from  self-monitoring  reports,  compliance
inspection Reports, Quarterly Noncompliance  Report, 0  & M  Reports, Grants
and Needs Reports, and other  compliance-monitoring  studies must be
processed more rapidly and communicated more accurately.  Greater  use of
this information should be made during compliance evaluations  and
enforcement follow-up.  In order  to  facilitate the  use of  this
information, the Agency will  emphasize and support  the following

     1.   A common database of  compliance and grant information designed
around the specific needs of  the  Agency and  the  states will  be  developed.
The basic data elements of such an  information pool are outlined in the
Municipal Management System (MMS) guidance document.   The  data  currently
maintained in various  permit  and  grant systems can  be  integrated using
the NEEDS cross-reference index.  This capability exists and  is available
to all users.  This database  is to  be  augmented  by  information  from state
pollution control agencies as determined  in  Agency/State MMS  working

agreements.  Under MMS operating  procedures,  the  exact  types  of
compliance data necessary to coordinate the evaluation  of  and return to
compliance will be identified  as  to their  priority  and  recipient.   The
Agency will continue with its  efforts to develop  and  bring on line  an
automated violation detection  system  (PCS-II)  so  that  self-monitoring
information can be rapidly processed  and supplied to  the common database.
This will enable State agencies to monitor trends and degrees of
noncompliance more accurately.  It will also  make it  easier for the
agency to measure the effectiveness of various types  of responses.   Based
on State/EPA agreements, certain  types of  compliance  inspection
information will also be supplied to  the data  base.   The intent is  to use
the vast amount of such information already available.

     2.   Means to assess compliance-monitoring information more rapidly
and to provide continuous quality assurance of the  data will  be
established.The Agency has initiated the DMR Quality  Assurance Program
specifically to address the quality of DMR data and provide follow-up
compliance inspections where problems are  detected.   In addition,  EPA has
developed a quality control inspection procedure. This  will be used to
assess a permittee's sampling  and analytical  work and  to upgrade
performance where necessary.   Corrective measures can  be supplied  to the
permittee immediately along with  copies to the State  agency serving the
POTW.  These efforts, in conjunction with  PCS  II, will  lead to higher
quality monitoring data.  This will also make  permit  limits and
self-reported data more accessible to EPA  and  State users  who must  manage
the return to compliance.  EPA and State permit and enforcement
authorities will use this information in the  developoment  of  MMS
procedures which streamline traditional compliance-review  activities
across interdependent programs.   Compliance data  necessary to assess
discharge performance or plant operation will  be  produce more rapidly,
achieve wider distribution, and be prepared in a  more  reviewable format.
MMS operating procedures will  insure  expeditious  handling  and follow-up.
Compliance for Future Facilities

     It is expected that the entire compliance  program will  help to
ensure the integrity not only of existing  POTWs but  also  of  future
facilities.  As lessons are learned from close  examination of  the
compliance problems of existing POTWs, appropriate changes will  be
incorporated in the planning, design,  and  construction of new  facilities.
Over time, as current problems are corrected and  plants are  brought  into
compliance, steps will be taken to prevent  compliance  problems in the

     The actions which EPA is proposing to  ensure the  integrity of future
facilities can be summarized as the following elements:

     •    Refinement in characterization of influent.

     •    Extension of the start-up program.

     •    Use of a systems approach in the  grants program.

     •    Addressing  the  problems  of  high  flow conditions.

In addition to these  measures, the  implementation  of  pretreatment
programs already  required will assist  in ensuring  compliance at plants
affected by industrial wastes.   One of  the  major causes  of  noncompliance
at some plants is that the  actual  influent  is  not  consistent with that
for which the plant was designed,  and  part  of  that problem  often stems
from industrial sources.  This can  interfere with  a plant's operation,
including reuse,  recycling  or disposal  of  sludges.  Effective
implementation of the pretreatment  program will, by itself, make POTWs
easier to operate and more  reliable.

     The following recommendations  describe tools  which  will be made
available to states as mechanisms  to  help  ensure a high  rate of
compliance for future facilities.   They are:

     1.   Municipalities will be encouraged to more thoroughly evaluate
the characteristics of their influent  to ensure that  treatment facilities
are matched to the influents and properly  sized to accommodate the volume
flow.  This will  obviate  many influent  and  treatment  design problems.
More specifically, grantees will be encouraged to  increase  analyses and
influent monitoring in Step 1 and  Step  2.   There will  be an emphasis on
reliability and operability by focusing on  the importance of considering
influent constituents and volume flow  in the design of POTWs.

     2.   The start-up program will be  extended to ensure that POTWs are
able to meet NPDES specifications  prior to  local municipalities assuming
full responsibility for their operation.EPA's intent will  be to ensure
the operability of POTWs  such that  they will be in compliance before they
come into service.  The concern  about  operability  at  start-up will
include examination of staffing, training  of personnel,  and initiating
operations to provide grantees with a  stable,  competent  operating
organization.  More specifically,  this  will include examination of items
such as:  plant specific training  manuals,  preventive  maintenance
programs, training programs for  operations  and maintenance  personnel, and
review of the adequacy of user change  rates.   In cases where it is  clear
that a POTW will  not  meet NPDES  requirements,  the  project will not be
closed out until corrective actions have been  taken.   While it is not the
intent of EPA to  fund necessary  corrective  steps,  in  exceptional cases,
where it is apparent that a POTW will  not  be capable  of  achieving
compliance at design  loading and is in  need of additional funding to
expedite corrective action, some limited funding may  be  considered.
However, it is expected that in  the vast majority  of  cases,  corrective
action for start-up will be a local responsibility.

     3.   A systems approach will be encouraged in the Construction
Grants Process.  In order to provide a  smooth  and  orderly transition
through the planning, design, construction, and start-up of a POTW and
service, use of a project manager will  be encouraged.  The  manager will
be an agent of the grantees, most  probably  a private  contractor, whose
job it will be to direct and coordinate the activities of all
participants through  the three Steps of the Construction Grants Program.
The manager will take administrative oversight responsibility so that
potential compliance  problems, which might  otherwise  remain unseen  due to

the complexity of the grants process, will be  quickly  identified  and
addressed by the municipalities.  In this way  the managers will aid  in
the prevention of POTWs coming  into service that have  compliance  problems
from their first day of operation.

     4.   EPA wi11 exami ne and  recommend methods to prevent  noncompli ance
due to high flow condition's^High flow conditions, especially  during  wet
weather, can cause considerable problems for POTWs in  their  ability  to
treat the additional volume of  water, thereby  causing  the facility to  be
out of compliance.  A significant effort in reducing high flow  volume
conditions will be undertaken through modification of  the infiltration/
inflow (I/I) program.  Excessive I/I is a well-documented,  serious
compliance problem for some POTWs and the current I/I  program has  not
been effective in controlling the resulting problems.

     Types of actions which are being examined  include:

     t    Allowing funding and  development of  an acceptable  sewer
          maintenance program as part of the Step 1 process, and

     t    Initiation of a joint effort with offices within EPA  (OWPO  and
          ORD) to develop new approaches and technical procedures  for

     Over time, as the I/I program is reviewed and amended,  interim
guidelines will be issued by EPA as a bridge between the current and  a
revised program.  Final I/I guidelines will be  developed using  several
avenues to collect information, such as public  participation and
initiation of a program to further evaluate the effectiveness of  both  the
technical and administrative aspects of the I/I program.

     The outcome of these efforts will be the  development of final
guidance for I/I which will be  comprehensive in nature covering areas
such as:  technical change, funding, and enforcement.
Compliance at Existing Facilities

     Improvement of compliance rates  in existing  facilities  is
necessarily a complex and time-consuming process.   No  one  individual
action will be sufficient to bring all noncomplying POTWs  into
compliance.  Therefore, EPA will institute a compliance  strategy  for
existing POTWs which comprises three  principle  elements:

     •    Identifying solutions to compliance problems through  diagnostic

     *    Developing a technical assistance  program for  use  where needed

     •    Developing an aggressive enforcement  program.

Each element is examined below.

      1.   Diagnostics  will  be utilized where states feel they are
appropriate  to  determine problems causing noncompliance!The
lilterrelationship of  the many facets of operating a POTW indicates
a  need  for a.comprehensive diagnostics program for some facilities
which are out of compliance.  Diagnostics will include examination
of plants' design characteristics, influent constituents, management
systems,  financial  condition, and operating and maintenance activities.

      Depending  upon individual  circumstances, diagnostic reviews could
be performed by qualified private-sector firms, state personnel, or other
qualified groups.  Since diagnostics will be a vital component of
determining  the types of compliance problems facing certain POTWs,
they will be 201  funding eligible with each state deciding which specific
POTWs will require diagnostics.  Details of the mechanism for funding
diagnostics  will  have to be worked out, since the diagnostics must be
completed on a  more expedited schedule than the regular grant process would
      A  POTW  as  a  complex system witti  any number  of potential  problem
areas.  As a result,  Lhe diagnostic  analysis  may  occur  on  any  level  of
detail  as required  by  the  particular  circumstances.   In  many  cases,  the
causes  of noncompl iance  will  be readily  apparent  and  only  a very  limited
diagnostic review will be  performed.   These  facilities  will then
immediately  commence with  corrective  actions.  However,  for facilities
with  more complex compliance problems,  a full, comprehensive  diagnostic
analysis might  be appropriate.  For  example,  in  a  complex  situation,  as  a
first step,  a POTW's  operating  procedures  and design  would be  reviewed.
Areas examined  in detail to  determine  a  possible  relationship  with
noncompl iance would include  the compatibility of the  design with  influent
conditions,  operator training and  level  of  skill,  operating procedures
for  dealing  with  changing  influent  conditions,  and maintenance
procedures.  Identification  of  the  primary  causes  of  noncompliance would
be followed  by  an examination of  management  and  financial  procedures  that
may  have contributed to  noncompliance.   Areas such as adequacy of user
charges and  maintenance  expenses  would  also  be examined.

      The diagnostics will  set forth  the  changes  needed  in  all  areas  to
achieve compliance.   In  order to  make  full  use of  the findings from
diagnostics,  a  composite correction  program  (CCP)  will  also be developed
which identifies  deficiencies contributing  to noncompliance.   Facilities
will  then make  necessary agreements with  states  to take  the appropriate
steps necessary to  rectify the  problems  detailed  in  the  CCPs.  These
plans will be enforceable  agreements  committing  communities to specific
actions and  dates.

      The  need to  address the  complex  interrelationships  of a  plant's
operations and  financial states can  be highlighted through an  example:  a
rate  structure  that is inadequate  to  cover  operating  and maintenance
costs could  lead  to the  hiring of  a  skeletal  staff of plant operators
with  limited experience.  That  staff  might  not be  able  to  adequately
respond to changes  in  influent conditions, which could  adversely  affect a
plant's operations, putting  it  out  of  compliance.  This  emphasizes the
the need for a comprehensive approach to diagnostics.

      2.   Technical assistance will be offered by  states in accordance
with the needs specified in the CCPs.  Technical assistance could take
many  forms,  depending  on the  individual  needs  of  a facility as detailed

in the CCPs.  Specific types of assistance will  be determined  through
discussions between states and municipalities.   However,  some  categories
of assistance which will be offered will  include:

     •    General — such as,, tracking of equipment failures  leading  to
          published reliability analyses  for  use by grantees,

     •    Financial—such as, aid in establishing user charge  systems
          which will provide adequate  revenue to ensure the  financial
          integrity of the facility,

     •    Technical and operational—such as, advanced operator  training
          programs to familiarize operators with the full capability of
          equipment and treatment systems, and

     •    Management—such as, aiding  facilities in determination  of the
          appropriate staffing levels  for technical and nontechnical

     In addition to direct technical assistance  offered by  states  for  use
in meeting CCPs, EPA will encourage facilities to use innovative
management techniques such as:

     •    "Circuit rider" programs—Groups of communities will  hire
          experts to assist in specific elements of the grants  process
          such  as planning, design and  construction, and  operation.  In
          this way, several communities will  share the cost  and  benefits
          of one group of experts.

     •    Financial Guidance Documents--Issued and compiled by EPA, these
          will contain typical financial  data to be used  as  benchmarks by
          local systems and states.

     •    Model Financial Management Systems—These documents  would
          describe typical information  systems that local systems  can  use
          as models in establishing their own financial management

     In very special cases, the Construction  Grants Program may  even
provide some limited funding of capital-related  needs.  This will  be  a
"fast track" mechanism for the exceptional case  which the Agency believes
requires expeditious action based on recommendations in the CCP.
Eligibility for this type of funding will be  determined on  a case-by-case
basis.  However, it will be extremely  limited and, for example,  will  not
be available for correcting noncompliance caused by deficient  operations,
new industrial  flows, or capacity expansion.

     3.   Implementation of CCPs will  be  the  objective of aggressive
enforcement action by states and EPA.   Since  CCPs contain specific
activities necessary to bring individual  noncomplying municipalities  into
compliance along with a timetable for  such activities, they are  the
logical basis for enforcement action.   Communities which  are recalcitrant
in their efforts to achieve compliance will face serious  consequences
including court action,  sewer bans, compulsory third-party  management,

and absorption  of  inflated costs of necessary construction due to serious
delays by POTWs  in  implementing CCPs.   In order to implement a
comprehensive enforcement  program,  EPA will  request from Congress
additional authority  to  issue  administrative orders imposing sewer bans
and other sanctions  in the cases of recalcitrant, non-performing
communities.  This  authority will  be utilized in serious cases of
recalcitrant communities.   In  addition,  industrial dischargers to POTWs
will also face  strong enforcement  action if  they fail  to resolutely
implement agreed-to  pretreatment programs.  In this way both
municipalities  operating POTWs and  industrial  dischargers to POTWs will
have strong and  explicit incentives to cooperatively and expeditiously
bring facilities into compliance.   A result  of this type of enforcement
program will be  a  broadening  of the scope of the Municipal Management
System whereby  environmental concerns  and not only the size of the
facility will be the  focus of  enforcement efforts.  This more
comprehensive enforcement  coverage  will  help to ensure the success of a
national effort  to  raise compliance rates for all sized facilities.

     The  preliminary  draft  1990  Management Strategy proposes a
significant departure from  the current  management plan.  It present a new
perspective for the Agency  and the  delegated states, as each assumes new
responsibilities.  The Strategy  responds  to the already changing nature
of program management (i.e.,  delegation), and the movement toward state
management of the  program.  At the  same time, it responds to the need to
protect national interests  and ensure that national objectives are met
through systematic monitoring of state  program performance.  The Strategy
represents a realistic image  of  this  changing nature in the program and
of EPA's  role in managing the transition  while ensuring that national
goals are satisfied.

     The  preliminary  draft  1990  Strategy  proposes major changes in the
range of  activities delegated to states and in the  federal  role
anticipated after  delegation.  The  state  will take  over the day-to-day
operational concerns  of the program while EPA will  concentrate its
efforts on the oversight of state performance and on technical
development (e.g., training,  R&D).  States will  be  held accountable for
the achievement of national program objectives and  for the maintenance of
program integrity  and will  have  a role  in policy development at the
national  level.  In posing  these changes, EPA recognizes that the system
will  be improved, but  not perfected.

     The  strategy  proposes  a  more comprehensive form of delegation than
is now in effect.  It  also proposes an  oversight role that  is keyed to
state performance  based on  program  objectives rather than the present
procedure-oriented review.  Additional  changes to technical  assistance
are also warranted to  support the management  and technical  needs of state

     The major element of discussion in the  management  area  has  centered
on the state and federal roles under delegation.  The resulting
reconmendations are detailed in the sections that follow.
The State Will Be the Primary Local Program Manager

     The key issue here concerns the appropriate  role  of  a  federal  agency
in meeting national program objectives.  Under the current  concept  of
delegation, EPA transfers the responsibility  for  certain  project-level
processing activities to the states but retains responsibility  for  a
number of project-level decisions, such as the environmental  sign-off on
projects, the issuance of grant awards, the processing  of bid protests,
payments and other activities.  The proposed  roles in  the 1990  strategy
transfer virtually all these responsibilities to  the states.

There are three key recommendations in this area.

     1.   Delegation to the states will be comprehensive  and  expedited.
Under this concept, delegated states will be  responsible  for  managing
individual grant projects and for managing the grants  program within
their states.  The states will be given considerable flexibilty in  terms
of how they choose to administer the program, and will  be held
accountable for the achievement of the program objectives identified  in
Chapter II.  EPA will delegate all operational responsibilities related
to individual projects, including bid  protest resolution, minority
business enterprises, National Environmental  Policy Act determinations
and actions, final resolution of audit exceptions, and  other  currently
nondelegable activities.  In addition, EPA will delegate  grant  offers,
payments, and other fiscal responsibilities that  have  been  traditionally
the responsibility of the federal government.  States  accepting
delegation will have to accept responsibilities for all activities.
Partial delegation will not be possible.  EPA's goal is to  have signed
delegation agreements with all states  by 1983 and full  delegation  in  all
states by 1985.

     EPA also has a continuing responsibility to  assure that
environmental integrity is an integral part of the delegated  program.  In
order to fulfill this responsibility,  EPA must retain  the flexibility
necessary to provide assistance to these states on a project-specific
basis when appropriate to assure attainment of our national  objectives.
EPA will develop specific guidelines with state participation for  EPA's
involvement in projects.  It is anticipated that  such  projects  will
involve special issues of an environmental, interstate  or international
nature which are of such significant national concern  that  they
constitute an overriding federal interest.

     2.   States will be involved in negotiating  the next Corps of
Engineers agreement including determination of their respective roles.
In order to be consistent with the concept of delegation  and  the need for
a single manager, the Corps and the states will be encouraged to -develop
a relationship in which the Corps will be responsible  to  the  state  for
the parts of Steps 2 and 3 that the Corps currently manages.. At a

minimum, states will have  a  role  in  the  next  Corps  agreement

     3.   The administrative grant mechanism  will be  reoriented to allow
states to fully administer the grant.The  existing federal categorical
grant made' by EPA to municipalities  is inconsistent with  the  thrust of
the preliminary draft 1990 Strategy.  Categorical grants  direct to the
states would be consistent but offer many  potential adverse  impacts
(applicability of federal  laws to localities,  enabling  legislation at the
state level, etc.).  The recommended option is a grant  provided to the
municipalities but approved  and awarded  by  the states.  Since the  states
will be making the grants  to municipalities under this  proposal,  some EPA
regulations may be amended to cover  the  EPA-state relationship.
The Federal Role Under Delegation Will Be Directed
Toward Oversight and Assistance

     The two recommendations  relating  to the  federal  role  under
delegation concern a proposed oversight framework and  the  nature  of
assistance to the states.

     1.   State-managed programs will  be evaluated  by  EPA  based on
performance rather than procedures.  After  initial  demonstration  that  a
state is following suggested  program requirements,  and has developed
approved procedures, continued state conformance with  program
requirements will be generally presumed.  Ongoing EPA  evaluation  of state
performance will focus on the adequacy of each  state's progress toward
the program objectives described in Chapter II  and  other indicators that
provide an early indication of tiate management toward objectives.   In
addition, specialized monitoring of a  limited scope and for a short
duration will  be performed.   State progress toward  1990 program
objectives is  to be evaluated annually.  The  specific  elements  of the
proposed program to oversee and evaluate delegated  state performance is
as follows:

    •     State progress toward program objectives  is  to be evaluated

          --States will initially develop an  overall strategy (see
            Planning recommendations for details) to achieve  the  basic
            program objectives.  The state  strategy will include  a
            schedule for the funding and completion  of all  projects
            deemed necessary to achieve the objectives and  will be
            negotiated with and certified by EPA.

          — States will annually submit a report to  the appropriate EPA
            regional  office identifying their progress toward the program
            objectives over the past year and describing their  planned
            progress  for the coming year.  These documents  will be
            reviewed and approved by EPA in conjunction with  the
            state-EPA agreement process.

— Evaluation will focus on  state  progress  toward  achievement of
  goals and the fiscal and  managerial  integrity of the state

— In evaluating state performance,  the EPA regional  office will
  utilize direct measures of performance such  as  the number and
  population of communities meeting BPWTT  versus  the total
  number of communities and their population;  the number and
  miles of waterways not meeting  fishable/swi rumble goals;  and
  the percentage of projects not meeting scheduled completion

--In conjunction with the monitoring  program,  EPA will maintain
  a system of incentives and sanctions to  ensure  that, once
  each state has accepted full  delegation,  its performance is
  sustained and national interests  are protected.  An effective
  system rewards good performance;  thus, the emphasis in the
  EPA system will be placed on  the  positive and incentive side
  of management.  States with well  managed programs will be
  noted to Congress and used as examples.

— If, during the course of  an evaluation,  EPA  finds a state's
  performance is lacking in an  area,  it will work directly  with
  the state to provide technical or management assistance.   In
  severe cases, or where state  performance deteriorates, EPA
  will request legislative  adjustments for the following two

     (1)  To withold the 2  percent  205(g)  monies  for use by EPA
          to administer the program itself through contract,
          other third parties,  or with in-house staff.

     (2)  To terminate or suspend construction grants program
          assistance to projects  in the state  until  the state
          performance meets national  standards.

  These sanctions will apply only in  cases of  severe
  performance problems and  will be  based on uniform criteria
  known to the states in advance.   This specific  criteria will
  be developed in conjunction with  the state and  other

During the first year after full delegation to a  state, the EPA
regional office will monitor state  procedures  to  ensure (1)
that the state has understood and implemented  the federal
program requirements and (2) that only high quality projects
capable of compliance with  permit requirements are likely to be

Every three to five years,  EPA  will evaluate state procedures
relating to the fiscal integrity the  grants program.  It is
proposed that this evaluation be performed by  an  independent
management/accounting firm  for  the  purpose of  assuring that
each state is making every  effort to  protect the  fiscal
integrity of the program.

     •    EPA will  conduct  periodic  program evaluations in selected areas
          of interest  or  concern.  The  purpose  of  these evaluations will
          be to  determine the  effectiveness of  particular aspects of the
          program  and  to  recommend program improvements where
          appropriate.  Examples  would  be  NEPA  compliance, evaluations of
          the effectiveness  of the infiltration/inflow program,  the
          public participation process,  and the minority business

     •    EPA regions  will  conduct limited-term monitoring of state
          operations and/or  procedures  under the following

          --If serious  questions  arise  regarding a state's progress
            toward  program  objectives.

          --If significant  new program  requirements or performance
            objectives  are  developed  by  EPA.

          --If a state  significantly  changes its procedures or the
            conduct of  its  program.

      2.   EPA will  develop  a national program for  specialized technical
and managerial assistance to delegated  states.   Assistance is needed in
several areas, as  delegation and  EPA's  changing role create a greater
dependency on the  technical  abilities of state  and local  personnel.  The
program will focus  on  technical and  managerial  areas.   This assistance
will  be provided to states  desiring  it  through  the technology transfer
program and/or through  direct, individualized assistance.   In general,
technical assistance will include the identification and transfer of
information on new  and  improved technology and  innovative information;
the identification  of knowledge gaps  and negotiations  for specific
research and development  to  support the  program, as well  as integrated
training programs for state  agencies  in  technically complex program areas
and with new initiatives.   The technical areas  currently targeted for EPA
technical assistance include:

     •    Management systems for  the  grants process.

     t    Operations and  management of treatment works.

     •    Innovative and  alternative  technology.

     t    Pretreatment  and sludge management.

     •    Water conservation and  energy  efficiency.

     t    Financial management.

      it is anticipated  that  this  expertise will  be located in one or
perhaps several EPA offices  throughout the country,  with  the EPA regions
serving as the link between  these offices  and the  states.   The states
will  be the vehicle for providing assistance  to  the  localities.

                               APPENDIX A


Proposed 1990 Strategy for Municipal Wastewater Treatment  (1/81)

1.  Task I      Funding Strategy (1/81)
2.  Task II:    Management Strategy (1/81)
3.  Task III:   Operations Strategy (1/81)
4.  Task IV:    Compliance Strategy (1/81)
5.  Task V:     Planning Strategy (1/81)
1.  Workshop Notebook  (11/80)
2.  Draft Funding Strategy  (11/80)
3.  Draft Management Strategy (11/80)
4.  Draft Operations Strategy  (11/80)
5.  Draft Compliance Strategy (11/80)
6.  Draft Planning Strategy  (11/80)

      1.  First Concept Paper (2/80)
      2.  Second Concept Paper (6/80)
 II. Management Strategy

     1.  Roles of EPA (6/80)
     2.  Third Party Management Options for
         Small Communities (9//0)
     3.  State Resources Under 205(g)
     4.  Technical Support Centers  (8/80)
     5.  National  Program Management  (9/80)
     6.  Grantee Marketing  (8/80)

                          APPENDIX A CONTINUED
      jerat1ons Strategy

     1.   Background and Problem Definition Paper on Grants Process
     2.   Small  Alternative Wastewater Systems Strategy  (5/80)
     3.   Streamlining Option Papers
         a.  Overview of Option Papers on
             Streamlining (7/80)
         b.  Certification (7/80)
         c.  Simplification of A/E Procurement
             Procedures  (7/80)
         d.  Economic Incentives  for POTW Compliance
             with Enforceable Schedules  (7/00)
         e.  Procedures for Reviewing the Profit Element of
             Architectural/Engineering Contracts  (7/80)
         f.  Regional Authority for Deviation to
             Title II Regulations  (7/80)
         g.  Peer Review  (7/80)
         h.  Simplifying Eligibility of Grantee
             Administration, Legal, and Fiscal Costs  (7/80)
         i.  Extended Use of Steps 2 and 3 Grant Awards  (7/80)
         j.   Implementation of Attachment 0 to OMB
              Circular A-102 of the Construction Grants
              Program  (7/80)
         k.   Advance Work on Step 2 (7/80)
     4.   Facility Planning Process (9/80)
     5.   Integrated Waste Management  (9/80)
     6.   Innovative and Alternative Program  (9/80)
     7.   Quality Assurance (9/80)
     8.   Inflow/Infiltration (9/80)
     9.   Other Federal Laws (9//8)
    10.   Generic Plans for Small  Communities  (9/80)
IV.  Compli ance Strategy

    1.  Background and Problem Definition Paper on
        Compliance (7/80)
    2.  Quality of New Treatment  Facilities  (10/00)
    3.  Improving POTW Compliance by Correcting
        Influent Problems  (10/80)
    4.  Improving Performance of POTWs Through Construction
        Grants Program (9//0)
    5.  Improving Compliance at Existing Municipal
        Treatment Facilities  (9/80)
    6.  Financial Management  (9/80)
    7.  Enforcement Aspects of Compliance (11/80)
    8.  Compliance--Existing Plants

                         APPENDIX A CONTINUED
V.  Planning Strategy

    1.  Water Quality Standards Strategy  (9/80)
    2.  Policy Statement Water Quality Standards
        Attainability and Upgrading  (9/80)
    3.  Water Monitoring Strategy (9/80)
    4.  Background Paper on Planning  (10/80)

                               APPENDIX  B




Circuit Riders
Col lectors
- Architectural and Engineering

- Alternative Justifiable Expenditures  is  a  method  of
  allocating the costs of a multiple-purpose  project
  to the individual project purposes.

- Advanced Secondary Treatment and Advanced  Wastewater
  Treatment are required where treatment more
  stringent than secondary treatment is needed.   These
  treatments greatly reduce levels of effluent  and  are
  useful for removing pollutants such as phosphorus,
  ammonia, nitrates, or organic and other  substances.

- Best Available Technology is defined  as  a  wastewater
  treatment method for toxic and conventional
  pollutants that most effectively and  economically
  achieves the effluent standard set for a particular

- Best Practicable Wastewater Treatment Technology  is
  a designation given to the minimum secondary  level
  of treatment or whatever higher level of treatment
  is needed at a specific POTW to achieve  the water
  quality  standards there.  The water quality
  standards include a consideration of  the technical,
  economic and environmental feasibility of  reaching
  them.  At present, BPWTT requires secondary
  treatment as a minimum for treatment  and discharge
  of conventional and toxic pollutants.

- Construction Grants Program

- Circuit  riders are government-sponsored  technical
  staff who would be available to a number of
  treatment plants within a region to aid  in  the
  management of a facility or help in the  correction
  of an operational or compliance problem.

- Collectors are the part of the sewer  system designed
  to transport wastewater from individual   buildings to
  the main interceptor sewerage lines.  New  collectors
  are necessary to correct violations caused  by raw
  discharges and the seepage of waters  from  septic

- Critical  Path Method is a method of operations
  analysis designed to optimize the time spent  on and
  the costs of any process or operation.  This  method
  could be used on the Construction Grants Program  to
  eliminate redundancies in the process and  expedite
  the processing of individual  steps.

                              APPENDIX  B CONTINUED

Combined Sewer Overflows are sewer  system designs
that allow for the bypassing, during high flow
periods, of untreated wastes directly  into
surrounding bodies of water.  Monies directed to
this category are for the purpose of preventing or
controlling this periodic bypassing.
CWA                - The Clean Water Act  (P.L. 92-500)  passed  in  1972  is
                     the major legislative authorization  for many  of
                     EPA's water quality  initiatives,  including the
                     Construction Grants  Program.   It  was  amended  again
                     in 1977.

DMR                - Discharge Monitoring Report  is  a  quarterly report
                     filed by all treatment plants to  the  state or other
                     authority giving the results of effluent  quality
                     tests performed during the testing period.   The DMR
                     is the method through which  compliance with  NPDES
                     permits is ascertained.

GAO                - General Accounting Office

GICS               - The Grants Information and Control System is  an
                     agencywide computer-oriented management system that
                     contains general purpose information  on all  EPA
                     grant programs, whether the  program  is administered
                     through EPA headquarters or  through  the Regions.

Hydraulic Overload - Hydraulic overload refers to the  state of a
                     treatment facility when incoming  flows of wastewater
                     are too large in volume to be  adequately  handled  and
                     treated by the facility.  This  state  may  be  due to
                     infiltration problems, especially after rain  storms
                     or excessive domestic flows, to cite  two  possible

I/A                - Innovative or Alternative.   Innovative project
                     designs are those that incorporate new technologies
                     in the treatment process.  Alternative project
                     designs, on the other hand,  step  away from the
                     conventional treatment methods  for wastewater and
                     utilize site-specific characteristics which  produce
                     new methods of waste treatment; usually alternative
                     projects are most feasible in  low density areas.
                     These two types of designs are  provided with  funding
                     for 85 percent of their eligible  project  costs by
                     the Construction Grants Program.

ICR                - Industrial Cost Recovery refers to the plan  each
                     facility must develop during the  application
                     process, through which industries served  by  the
                     facility must repay  their fair  share  of the
                     project's capital costs (part  of  which goes  to the
                     U.S. Treasury).  However, the  clause  was  postponed
                     by Congress in the 1977 Amendments to the Clean
                     Wat*-*- Act.


                             APPENDIX B CONTINUED
Land Treatment

Needs Categories
Needs Survey
- Infiltration/Inflow.   Infiltration  is  ground  water
  entering a sewer system through defective  sewer
  pipes, joints, connections, or manhole walls.
  Inflow is caused by cross connections  from storm
  sewers and combined sewers, manhole  covers, and
  yards, cellars, and foundation drains.  Because  of
  I/I problems, flow greater than the  capacity  of  the
  treatment plant can result in wastes bypassing the
  treatment process.

- Interceptors are the part of the  sewer  system
  designed to transport  bulk wastewater  from the
  collector system to the treatment plant.
  Transmission pumping stations are also part of the
  interceptor system.

- Interagency Personnel Agreements  loan  EPA  experts to
  the state or local levels for one or two years in
  order to provide training of personnel  and expertise
  in needed areas.

- Integrated Waste Management.  The planning, design,
  and construction of facilities for the  treatment and
  disposal/utilization of all wastes  (e.g.,  municipal
  solid wastes, hazardous wastes, radioactive waste).

- The application of treated wastewater  to land
  surfaces for ultimate disposal  either with  or
  without the use of this waste for irrigation

- Millions of gallons per day

- Needs Categories are the seven major types  of
  projects funded by the Construction Grants  Program.
  They are:  (I) Secondary Treatment;  (II) Advanced
  Secondary Treatment/Advanced Wastewater Treatment;
  (IIIA) Infiltration/Inflow; (IIIB) Rehabilitation;
  (IVA) Collectors; (IVB) Interceptors;  and  (V) CSOs.

- The 1978 Needs Survey is a detailed estimate of the
  costs of construction of all  needed  publicly  owned
  treatment works in all  of the states.   This survey
  was completed in order to provide a basis  for the
  Congressional  allotment of funds to the Construction
  Grants Program.

- The National  Environmental  Policy Act dictates that
  federal  agencies must take into consideration the
  environmental  affects of any proposed  actions when
  making decisions.   Its  most conspicuous requirement
  is the preparation of an Environmental   Impact
  Statement for projects  with a potential to cause
  significant  environmental  impact.

                            APPENDIX B CONTINUED
Non-Point Source


Replacement and
- Non-point source programs are attempts to control
  pollutants from areawide sources, such as runoff
  from agricultural and forest lands, runoff from
  mining and construction, and storm runoff from urban

- The National Pollutant Discharge Elimination System
  is a national  permit program designed to control the
  discharge of pollutants into waterways from all
  specific point sources including industrial and
  municipal treatment facilities and commercial
  activities.  It is administered by EPA or an EPA-
  approved state .agency.  The permits are enforceable
  and must be renewed at least every five years.

- Operations and Maintenance

- The status of projects that have begun the
  Construction Grants Process but have not yet
  completed it is often referred to as "in the

- Pipes are those project types relating more to the
  delivery of wastewater to the treatment plant than
  to the actual  treating of the wastewater.  Specific
  categories in the "pipes" class are (IIIB)
  Rehabilitation, (IVA) Collectors, and (IVB)

- Program Operations Memorandum and Program
  Requirements Memorandum state EPA's interpretation
  of portions of the CWA and EPA's related policy

- Pub! icly owned treatment works is the general term
  used to refer to all treatment facilities funded
  under the Construction Grants Program.
  Replacement and Rehabilitation  is the  project
  category name for the correction of structural
  problems in existing sewer systems.
  Secondary treatment is the treatment of  wastewater
  by biological methods after primary treatment by

  A set-aside  is the mechanism for  specifying  the
  particular amount of money to  be  used  for  a
  particular type of project, such  as I/A  or rural.

                             APPENDIX B CONTINUED
Sludge Management  - Sludge management  is  the  management  of the disposal
                     of solid waste  products from a  wastewater treatment
Step 1
Step 2
Step 3
Step 4
User charges
Standard Metropolitan Statistical Areas  are  defined
by the U.S. Department of Commerce either  as  one
city of 50,000 or more inhabitants or  as  a city with
at least 25,000 inhabitants which, together  with
contiguous places, has a combined population  of
50,000 inhabitants and is for all general  purposes
considered a single economic and social  community.

Step 1 of the Construction Grants Program  initiates
the planning and engineering of  a POTW.  Often Step
1 is a combination of what has come to be  known as a
pre-Step 1 and Step 1.  Pre-Step 1 planning  includes
expected costs, work schedules,  and project
compatability with regional plans.  Step 1 itself
produces a facility plan which defines the problem,
examines alternative solutions,  and selects  one
solution for implementation.

Step 2 of CGP develops the detailed plans  for the
treatment plants based on the facilities plan
produced in Step 1.  Both technical and
administrative requirements must be addressed in  the
plans along with cost estimates  from which bids for
construction can be judged.

Step 3 of CGP is the combination of Step 3 and
post-Step 3.  In Step 3 the plant is actually
constructed and put into operation.  Post-Step 3
involves the final  project  reviews, reports, and
financial audits.

Step 4 is the combination of Steps 2 and 3 of the
Construction Grants Program.  Step 4 grants  are
awarded to facilities whose total project  cost will
not amount to over $2 million.

Stormwater is water that flows over hard surfaces,
such as roads and parking lots,  and into municipal
drainage systems as a result of  rainfall or  other

Total Maximum Daily Loads are the greatest amounts
of pollutants that an individual facility  may
discharge into a body of water on a daily  basis.
This level  is defined in each facility's NPDES

User charges are the rates whereby users of  the
treatment facility are charged for the service so

                            APPENDIX  B  CONTINUED

                     that  all  operating and maintenance as well as any
                     capital  repayment  costs of the facility are
                     collected from the system's users.  User charges are
                     usually  based  on metered water usage.

WLA                - Waste Load Allocations allocate pollutant loads that
                     may be imposed on  a  water body by individual
                     dischargers  and  also help identify point source
                     permit conditions.

WQM                - Water Quality  Management is the attempt to control
                     and manage all factors that affect the quality of a
                     body  of  water.  Included in this is the control of
                     both  point and non-point sources of pollutants.

WQS                - Water Quality  Standards are legal designations of
                     the desired  use  for  a  given water body and of the
                     water quality  criteria appropriate for that use.

                                APPENDIX  C
                 Meetings, Briefings, and Work Sessions
Environmental and Rural Interests, State and
Local Government, and Economic Interest
Monthly Briefings
1990 Policy Committee Monthly Meetings
1990 EPA Steering Committee Monthly Meetings
Association of Metropolitan Sewerage Agencies,
Sledge Committee Monthly Briefings and Work
Construction Grants Advisory Group
Association of Consulting Engineers Council
Environmental Industry Council
National Utilities Contractors Association
National League of Cities
Local Government Work Session and Policy Meeting
League of Women Voters
National Association of Counties
U.S. Conference of Mayors
Water and Wastewater Equipment Manufacturers
National Food Processors Association
American Society of Civil Engineers
Building and Construction Trades
State of Maryland 201-208 Advisory Committee
Management Advisory Group to EPA's Municipal
Construction Division
Society of the Plastics Industry
American Clean Water Association
National Council of State Legislators




                               APPENDIX  C CONTINUED
1990 National Combined Interest Group                      December
Conference Report-Back
ASIWPCA Mid-Winter Meeting                                 January
National Society of Professional Engineers                 September
American Society of Civil Engineers                        October
White House Rural Policy Conference                        October
Water Pollution Control Federation                         October
1990 National Strategy Workshop                            November

                                     APPENDIX  D
                  1990 National Construction Grants Strategy Workshop
                                   November 16-22, 1980
J. Stanley Alexander
National Conference of Black Mayors
Washington, D.C.

Fred Burton
Bluefield City Manager
West Virginia

Warren L. Carter
State Water Control Board

Frank Cervi
National Assn. Development Org.

Edith Chase
League of Women Voters

Ray Chavez
New Mexico Water D&S Corporation
New Mexico

Lee H. dayman
Metropolitan Washington Council
  of Governments

Maurice Dorton
Dept of the Metropolitan Council

Andy Ellicott
Water Pollution Control Federation
Washington, D.C.

Paul Freese
Camp, Dresser, McKee, Inc.

Joseph Frisella
Frisella Engineering
Rhode Island

Steve Garman
Pensacola City Manager
Louis Gilde
Campbell Soup, Inc.
New Jersey

James E. Gutman
State Water Quality Advisory Comm.

Mark Hammer
University of Nebraska
Fred Harper
Orange County
Sanitation District
Ted Heemstra
Citizens Advisory Streams
Pollution Control Board
Andrew Howarth
Rural Community
  assistance Program
Eric Kaston
New York City Dept. of
  Environmental Protection
New York

William Katz
Milwaukee Metropolitan Sewage District
Paul B. Kelman
Atlanta Regional
Lane Kendig
Lake County Planning
D. J. Kirk
Ruth Kretschmer
Supervisor DuPage County

                                    APPENDIX D CONTINUED

                   1990 National  Construction Grants Strategy Workshop
                                     November 16-22, 1980
Tex LaRosa
Dept.  of Water Resources

Susan  Lofgren
League of Women Voters

W. J.  McKee
National Society of
  Professional Engineers
Washington, D. C.

Tess McNulty
League of Women Voters

Bob Nicholson
Zimpro, Inc.

Jack Odgaard
Nebraska Water Resources Assoc.

Tarn R. Osborne
Virginia Water Project

Ervin S. Queen
Appalachian Water & Sewer
  Development Association
West Virginia

William Reinhard
State Office of  the Comptroller

John Scheaffer
Scheaffer  & Roll in

James P.  Schafer
Havens  &  Emerson, Inc.
Wayne Schmidt
Michigan United Conservation Clubs

Dale Twachmann
Institute of Water Resources

Larry Walker
Larry Walker Associates
Barbara Webber
Natural Resources
John B. Wells, Jr.
Water Resources Assistance Corp.

Clyde Wilber III
Greeley & Hansen
Washington, D.C.

Betty Woodruff
League of Women Voters

Kenneth Bartal
States Conference on Water Quality

Susan Boyd
Concern, Inc.
Washington, D. C.

Ron Buckhalt
National Utility Contractors Assn.
Washington, D. C.

Gould Charshee, Jr.
Regional Planning Council
 Fred Cooper
 Mississippi  Institute
                                                                      for  Small  Towns

                                     APPENDIX  D CONTINUED

                    1990 National  Construction Grants Strategy Workshop
                                      November 16-22, 1980
Glen Enrich
County of Fairfax Public Works

I. B. Ellis
W.S. Dickey Co.

Senator Fred Finlinson
Utah State Senate

John Flynn
International Union of
  Operating Engineers
Washington, D.C.

Patrick C. Glisson
DeKalb County Office of Finance

Edward Graham
Washington Surburban Sanitary Comm.

Audrey Jackson
League of Women Voters

Lynn Judd
University of Wisconsin

Charles Kaiser, Jr.
Metropolitan St. Louis Sewage District

Charles Kamasaki
National Council of La Raza

Austan Librach
Washington Metropolitan Council
  of Governments
Washington, D.C.
Robert McGarry
Washington Suburban Sanitary Comm.
Peggy McNeil!
Mercer Company Soil
New Jersey
Patricia M. Nesbitt
Environmental Consultant

E. J. Newbould
National Clay Pipe Institute
Washington, D. C.

Bob 01t
Union Carbide Corporation
New York

Neal Potter
Councilman for Montgomery County

Clem Rastatter
The Conservation Foundation
Washington, D. C.

Merilyn Reeves
League of Women Voters

Robert Robinson
Michigan Township Assoc.

Samuel H. Sage
Sierra Club
New York

Frederick Schauffler
New England Interstate Water
  Pollution Control Commission

                                      APPENDIX  D  CONTINUED

                  1990 National  Construction Grants Strategy  Workshop
                                    November 16-22, 1980
 Garrett  Sloan
 Miami Water Sewer Authority

 Joel Smith
 Oklahoma Wildlife Federation

 Raymond  J.  Smit
 National  Society of
    Professional  Engineers

 John Wander
 Peat, Marwick,  and Mitchel, Inc.
 Washington,  D.  C.

 Joe Waters
 Heart of Georgia Planning and
    Development  Commission

 Laurence Weatherholts
 National  Utilities Contractors Asso.

 Calvin  E. Weber
 Westchester County Dept of Health
 New York

 John J.  Wright
 Greater  Birmingham Association of
    Home  Builders

 L. Carl  Yates
 McGoodwin,  Williams & Yates, Inc.
•U.S. GOVERNMENT PRINTING OFFICE: 1981-0-7ZO-016/:>985               68