United States
Environmental Protection
Office of Water
January 1989
v>EPA   Nonpoint Sources
         Agenda for the Future



\,,  ,e

In 1987, Congress  shifted  from  fifteen years of nonpoint
source (NPS) pollution planning and problem identification
(1972-1987) to a new National NPS action program.  In this,
its third mandate for us to do something about NPS pollution,
Congress enacted a statute that:

  4 Requires  States  to  assess their  waters,  and to
    develop NPS management programs to control  and
    reduce specific nonpoint sources of pollution; and

  4 Authorizes Federal loan  and  grant  funds to help
    States and units of local  government, conservation
    districts,   individuals,  farmers,   foresters,   and
    businesses to manage nonpoint sources of pollution.

The Act placed special emphasis on NPS  by moving the
provision from Title II (Grants for Construction of Treatment
Works) into Title III (Standards and Enforcement),  and by
strengthening the basic Declaration of Goals and Policy in
§101 (a) of the Clean Water Act:

    It is  the national policy  that programs for the
    control  of  nonpoint  sources  of  pollution  be
    developed and implemented  in  an expeditious
    manner so as to enable the goals of this Act to be
    met through the control of both point and nonpoint
    sources of pollution.

The law and its legislative history expressed the intent  that
Federal and  State  governments  should  develop   new
institutional arrangements and come up with a better division
of roles and responsibilities  to  get the  job  done.   The
language of the amendments  also  indicates that  Congress
placed high  priority  on  new  and  open decision-making
processes, with the idea that public consensus-building will
lead to creative, practical, and productive approaches to the
NPS pollution problem.

Consistent  with   §319,   States  are   completing  their
assessments  and management programs, which, after EPA
review and approval, will serve as the cornerstone  of the
National NPS program  in  the years to come. This National
NPS  Agenda forms the  framework for the National NPS
program over the next five years, and will be supplemented
by annual EPA work programs  that  provide  additional,
detailed information.
  The Water
  Quality Act of
"The nation behaves well if it
treats the natural resources
as assets which it must turn
over to the next generation
Increased and not Impaired in

Theodore Roosevelt

 The NPS
 Large, Complex,
 and Dynamic
First, let's examine the problem. In our most recent National
Water Quality Inventory:  Report to Congress (1986),  NPS
represented the dominant fraction of the Nation's remaining
surface water  pollution  problem.   The  pie charts below
portray the relative impact of the  nonpoint source pollution
problem in impaired waters.1
"Nonpoint source controls
are everyone's responsibility •
Federal, State, and local
governments, local groups
and organizations, as well as
individual farmers, foresters,
mining and construction

James L Oberstar
US Congressman
EPA Journal,
May 1986
   ©EPA  2
    Combined Sewer
     Natural Causes
I—I Municipal
   Point Sources
Industrial Point
Other/Unknown    E3 Nonpoint Sources
Nonpoint sources such as fertilizers and pesticides, poorly
sited  and maintained septic systems, acid deposition,  and
highway deicing  compounds,  also affect  the  quality of
ground water.

The NPS problem is not just  large.   It  is  also complex,
involving a large number of people and important sectors of
our economy.    The pie charts  below show the relative
amount of assessed waters that are impacted by various
categories of NPS pollution.
                                     Urban Runoff
                                                RIVERS                  LAKES
                                              / 65,000 Miles              8.1 Mlliort Acres

                           Land Disposal
                     Land Disposal 1%Construction'*'
                                                                            ilviculture 1%
                                                    Construction 2%
        REFERENCE America'! Clean Water: The Sates' Evaluation of Progress, 1985
                                                                     Resource Extraction 1%
 1. We do not have comparable data for wetlands impacted by NPS

Finally, the NPS problem is not just large and complQx.  It is
also highly variable in both space and time. The map below
illustrates the regional differences in land use patterns.
     Far Pacific
                                              Urban  *
This map is just a snapshot in time; actual land use patterns
keep changing over time.   For example, while the  1970s
were boom years for agriculture, we  have seen a general
reduction in cropped acreage  in the 1980s.  Production  in
the forest sector remains relatively level, but appears to be
shifting  from the Pacific to the  Southeast.   The current
supply of range and pasture lands appears to be adequate.
Wetlands are  likely  to  experience  significant additional
extirpation   from   agricultural   conversion   and  urban
development.    In  the  mining  sector,  most coal  has
traditionally been mined  from underground in  Appalachia;
the recent  trend is  a shift  to  surface mining production  in
Wyoming and Montana.   Finally,  the  Nation's  coastal
population  continues to climb and predictors forecast  that
75% of us will live within  50 miles of a coast by 1990.  This
will  probably  lead  to  more  development, and increased
stress on wetlands and sensitive coastal water ecosystems.
In short, we  need  to be forward thinking  about the NPS
problem  because, unlike  point sources that are  fixed in one
place, the NPS problem shifts beneath us constantly.

Looking Ahead:
"Nonpolnt source control
demands political or
organizational savvy of a very
high order, plus the courage
to persist and not just throw
up our hands because the
problem Is so large."

Lee M. Thomas,
EPA Administrator
Congress gave the NPS program a four-year lease on life.
The question is:  how can we tackle this complex problem
and achieve real, concrete results in this limeframe?

We need to  recognize from the start that  NPS  problems
differ  greatly from  point  source  probems,  so   we  (the
Federal, State,  and local governments)  must devise  new
solutions and avoid the temptation to force-fit the old ones
that worked so well in the past. For exarrple:

+ Different Problems: Point sources a-e visible,  discrete,
  and easily identifiable. By contrast, nonpoint sources are
  diffuse and often hard to trace to  their sources through
  traditional methods.

4 Different  Political Science:  Point sources are end-of-
  the-pipe discharges" that are easy to regulate with Federal
  and State permits. NPS problems,  on :he other hand, are
  the direct result of our past and  present land use habits,
  so  many  of the solutions lie in finding more  efficient,
  rational ways to manage the land.  Since direct Federal
  regulation  is  not  a  major  factor  in  local land  use
  decisions, State and local  governments often need new
  institutional arrangements  to  deal effectively with  NPS

4 Different  Social  Science:   The traditional regulatory
  solution is "top-down":  Federal and State governments
  impose  specific  requirements on  cities  and industries.
  Since  NPS pollution is  the result of  land   use,  the
  solutions affect the public at large, and tend to be "bottom
  up." This requires an informed public and broad-based
  coalitions to generate support for local or State action.

4 Different Science:  Most NPS pollution to surface water
  stems from storm events, contrasting sharply  with the
  relatively'even, continuous discharges we encounter in
  the point source program. Moreover, the NPS program
  needs water quality standards that  rely on  biological
  criteria,  and  the monitoring  program  needs  different
  emphases, including  biological monitoring and  storm
  event sampling.

This Agenda tries to address these differences, find ways to
tackle them, and achieve concrete resuts in the timeframe
the WQA set out.

The WQA gives States and local governments the front line
responsibilities  for  assessing their  waters and devising
appropriate solutions to their NPS problems.  This Agenda
sets forth a National NPS program aimed at supporting and
reinforcing   States   and  local  governments   at  these
endeavors. The overall goal of this Agenda is:

 To  protect and  restore   designated  uses  of  the
 Nation's waters by providing strong leadership for the
 National  nonpoint  source  program,  and by  helping
 States and  local governments overcome barriers to
 successful implementation of NPS measures.

The barriers to successful implementation can be  viewed as
a series of hurdles that States and  local governments must
jump to get NPS measures in place, including:

  + Convince people  (individually and collectively) that
    there is a problem and a need for action;

  4 Find   successful   solutions-political,  educational,
    institutional, regulatory, and/or technical; and

  4 Provide financial incentives to correct the problem, or
    remove financial incentives to pollute.

Perhaps the biggest hurdle of all is that the words "nonpoint
source" are  linked with the sensitive  words "land use," the
control of which lies largely in the purview of States and local
governments.  EPA's role is to support and reinforce States
and local governments as  they make difficult decisions that
affect  water quality, to improve their knowledge of sound
land  use practices,  and to provide the scientific basis on
which they make these public policy decisions.

This Agenda is oriented  to surface  waters.  Surface and
ground waters, however,  are inter-related, and  efforts  to
manage the two should also be closely linked. In 1984, EPA
issued a Ground-Water Protection  strategy, followed by a
proposed Agricultural Chemicals in Ground Water Strategy
(1987).   These strategies,   as  well as  State  Wellhead
Protection programs, will be implemented as companions to
this Agenda to forge  an  integrated approach to solve the
Nation's complex NPS problems. States may also use their
State  Clean  Water Strategies  (SCWSs)  to  more fully
integrate their surface and ground-water programs.
   The  National
   NPS Agenda
"The nature of our
constitutional system
encourages a healthy
diversity In the public policies
adopted by the people of
several States according to
their own conditions, needs,
and desires.  In the search for
enlightened public policy,
individual States and
communities are free to
experiment with a variety of
approaches to public issues."

Ronald Reagan, President
EO 12612 on Federalism
October 26, 1987

Five Themes for
NPS Action
   ©EPA  6
EPA regards State  NPS Management Programs  as the
cornerstone of the National  NPS program.  To assist and
support States and local governments as they upgrade and
implement their programs, this Agenda proposes that EPA
will channel its energy, resources, and activities into actions
designed to overcome the barriers noted above:

 + Public  Awareness:    Help  Slates  and   local
    governments  raise the level of public  awareness
    about how NPS pollution affects water quality and
    their daily lives.  Provide the information and tools
    they need to educate and inform people about the
    causes and the seriousness of NPS pollution.

 + Successful Solutions:   Provide States and  local
    governments with information on  practical, feasible
    solutions to prevent or control  NPS  pollution--now.
    Solutions  can take many forms:   new  institutional
    arrangements,  best  management practices, and/or
    regulatory or nonregulatory programs.

 4 Financial Forces and Incentives:   Examine the
    economic forces that drive  behavior causing  the
    NPS problem.   Help devise ways to mitigate those
    forces.  Provide financial  incentives that encourage
    people to  install  pollution control practices  or to
    change land management practices.

 + Regulatory Programs:   Help .'States  and  local
    governments improve their capability to develop their
    own regulatory  solutions.   Assist States  in taking
    advantage of  Federal   regulatory  programs  by
    networking existing  EPA authoritias in  a way that
    adds up to support rather than  fragmentation at the
    State and local levels.

 4 Good Science: Develop the "tools" States and local
    governments   need  to  establish  sound  water
    quality-based programs for NPS, particularly water
    quality criteria  and  monitoring  protocols that are
    specifically designed  to  evaluate  NPS controls.
    Improve geographic  management skills, and explore
    the potential for use of the Ecoregion approach.

Each  of these themes is described  oelow,  including the
activities tp implement each over the next five-years.

The  first  barrier we  face  is  lack  of  knowledge  and
understanding.  As  States begin implementing their State
NPS  Management  Programs, they  will  have  to  assist,
encourage, or  require individuals  and  entities to adopt
specific BMPs and  measures to prevent or control NPS
pollution. In order to persuade the public that it needs to act,
people need  to  be  convinced that there is an extremely
important connection between individual activities and land
use practices  and local water quality. The public also needs
to believe that taking certain actions will, in fact,  make a
difference in water quality.  The key is to convince people
that they "own the problem," and that their individual and
collective efforts can make a difference.

Public awareness  does  not just  happen.   It  requires
conscious effort.  To help  raise society's level of awareness
about NPS pollution, EPA will work with  States and local
governments to improve their capacity to convince the public
of the need to change its behavior, and to encourage and
reward good  stewardship of our water resources.  This
requires  communicating   with   citizens  in  ways  they
understand and recognize, targeting the audience carefully,
conveying the message through sources that are perceived
as  "reliable,"  establishing  on-the-ground  contacts  and
interactions, and getting  people  interested and  actively

EPA will initiate a public awareness  program at the  National
level to supply States and local governments with general
information and tools they can use to reach the public-at-
large.   The  materials will  be  designed to help people
recognize  that  there  is   a   problem,   understand   its
seriousness,  and have some fairly clear idea of  what is
causing it.  EPA will seek the support and assistance of
other  Federal  agencies  in preparing   and  distributing
materials, especially USDA, DOT,  DOI/FWS  and USGS,

There  is  a  relatively  limited  market  for  "top-down"
information, however, so  EPA will also support and assist
State  and local "bottom-up"  efforts to  develop public
awareness programs that  give  people  "specifics"   that
characterize their immediate surroundings. In devising such
public awareness campaigns, we will:
The Key to

What is the
0 Information/Education

[Vf Targeting

 4 Explain the NPS problem in ways that help people
    appreciate their water resources, and realize that
    NPS pollution prevents their use arid enjoyment of
    the water;

 + Communicate  the problem  graphically  wherever
    possible  through  GISs,  aerial  photography, and

 4 Use   sophisticated,   state-of-the-art   marketing
    techniques  that include  full,  effective use of  the
    media    (brochures,    videos,    public   service
    announcements, and interactive videos);

 4 Use credible sources of reliable information  to reach
    different,  grass-roots constituencies  such as major
    trade associations, State  management agencies or
    their  associations,   industry,   State   and  local
    organizations  and   their  district  offices,  and
    environmental groups; and

 + Rely on "public affairs" experts wherever possible.

But raising awareness alone is not  sufficient to galvanize
support for  action. Based  on  our e
the targeting and watershed management concepts to purely
"local" water resources.  We will also use these experiences
to learn how to spark people to act in a preventive as well as
a reactive mode.   One form of targeting that EPA strongly
endorses is State  Clean Water Strategies (SCWSs), which
provide a  sound  basis  for  comprehensive watershed
planning and consensus building.

While raising public awareness is vital to our efforts, it is a
"short-term" solution to  a long-term problem.   In the long
term, therefore, we need to  do a better job  of educating
people from an early age.  This will require a collaborative
Federal, State,  and  local effort to  produce  high-quality
educational materials and to train teachers.  EPA will work
with  the States and other interested parties to inventory the
range  of  education  programs  currently available,  and to
identify  the  need  for new and/or improved materials and
training  programs.   EPA will also establish liaison with the
Department of Education, and will work with States to
develop similar contacts.

                      PUBLIC AWARENESS
                     Develop detailed workplan for public
                     awareness program,including materials
                     and media training (OW/OEA/States/
                     Federal Agencies);
                     Implement workplan

                     Identify/use other Federal data bases/
                     mapping capabilities/programs/resources/
                     delivery mechanisms (DOI/FWS and
                     USGS, NOAA, FERC, FEMA, USDA).
                     Develop materials that describe the NFS
                     problem in everyday language (brochures,
                     pamphlets) or depict the problem
                     graphically  (maps/GISs/aerial
                     photography)  (OW/OPTS/OPPE/OEA)

                     Enlist other  Federal programs/resources/
                     delivery systems to communicate with
                     specific audiences (USDA/DOT/FEMA/
                     FERC/BLM) (OW/OFA/OPPE)

                     Develop generic/specific public service
                     announcements/brochures that describe
                     the NPS problems to laymen and what
                     people can do (runoff, land use, mining,
                     etc.) (OW/OEA)

                     Enlist cooperation of private sector parties
                     that are involved in activities that
                     prevent/contribute to NPS (OW/private

                     Investigate existing children's education
                     programs; Develop workplan to
                     produce/upgrade materials as needed
                     Implement workplan to get K-12 curricula in

                     Issue handbooks/brochures on:
                     • Public awareness techniques
                     • Targeting/watershed management
                     • Participatory processes (Boy Scouts/4-H/
                       kitchen meetings, etc.)
                     • Use of filter strips (OPPE/OEA)

Once the public understands the need  to  act, there  are
several  more  barriers  to  overcome in  our quest  for a
successful  solution.   For  example:  What  is the  best
technological, educational, or regulatory "fix" for a particular
problem?  Is  there political willingness  to deal with  the
problem?    Are  the   right   institutional   and  financial
arrangements  in place  to make and carry  out decisions?
Once installed, how will we know whether  the solution is
actually working?  How can we ensure that adverse impacts
to other resources (e.g. ground water) will not occur?

There are a myriad of  success stories waiting to  be told.
The  key  is to  share these experiences among States and
local governments, and  let them build upon ideas that have
succeeded elsewhere.  Moreover, States, local governments
and private parties constantly come up with new, innovative
solutions. We  need fast, reliable ways to communicate all of
this information to a wide audience  of users: States, local
governments,  private   citizens, trade  associations,  and
environmental groups.

To support State and local  efforts to tackle  their particular
NPS problems quickly and efficiently,  EPA will actively solicit
the help of others (both public and private) to set up a variety
of information  networks  to   provide  States  and local
governments with useful, up-to-date information on practical,
feasible solutions to existing problems and ways to prevent
future problems.  For example, EPA will:

  4  Work with the public and  private sectors  to create
     new clearinghouses or information catalogs (or to
     build upon and enlarge existing ones such as the
     Small Flows Clearinghouse), and actively market the
     availability of this  information to  a  wide  range of
     potential users. Most likely topics include information
    that  will help States and local governments:
      Undertake   successful
public    awareness
      Build    viable   institutional   and    financial
      arrangements, and overcome political reticence;

      Select and apply successful technical solutions
      (best management  practices),  and regulatory or
      voluntary schemes (Statewide or local);
                             Old and New

What can States and
local governments do?

gf Build Institutions
0 Install BMPs
0 use Land Conservancy
[jTf Enact

    - Choose  the best delivery system to reach the
      particular audience,  with  special emphasis  on
      recruiting  the   private   sector   to   handle
      "preventive" measures; and

    - Find useful information on land use  practices to
      meet  specific  local  needs,   and  on  land
      conservancy programs and techniques.

 + Work with the public and private sectors to package
    and  deliver high-quality technology  transfer and
    training  workshops  to  help   States  and  local

    - Begin credible local citizen monitoring programs
      to promote local involvement, help identify NPS
      problems, monitor compliance, and evaluate the
      ongoing effectiveness of solutions;

    - Choose  the  right   technical,  educational, and
      regulatory solutions  for different kinds of NPS
      problems (stormwater, construction  runoff, soil
      erosion,  etc.)  with  an  eye  to  'educing the
      potential for tradeoffs to ground water (and other

    - Select and use sound targeting and watershed
      management  methodologies, including sharing
      State experiences with the NEP and  SCWSs  (as
      they become available); and

    - Expand  use  of state-of-the-art decision  aids,
      such   as  EXPERT  systems,   to   design
      site-specific NPS controls, such 35  runoff from
      highways and logging roads.

 4 Use the latest, up-to-date communication techniques
    to get  new ideas into circulation fast,  including
    brochures,  fact sheets,  and  computer   bulletin
    boards.   Again, we  will  make  exlensive  use  of
    public/private partnerships  to   deliver  information
    rapidly and cost-effectively to many different users.

In general, EPA will not be developing "now" BMPs, but will
direct its energies and resources to sharing information  and

experiences with existing  practices and/or new,  creative
approaches developed by others. There are, however, two
areas in which EPA will maintain a special interest.  The first
is  use of  wetlands to  provide an NPS control function.
Wetlands have been shown to  prevent sediment, nutrients,
metals,  and organic contaminants  from entering adjacent
waterbodies.   While we need  to continue monitoring  and
conducting  research to  ensure that  wetlands  are  not
adversely  affected when they are used to buffer sources of
pollution,  it appears that  use  of existing and artificially-
created wetlands can be a cost-effective means of achieving
NPS control.

In   addition,   EPA   believes there are vast,  untapped
opportunities for States and local governments to combine
water quality objectives with other needs of society, such as
flood  protection,  wellhead  protection  for  ground-water
supplies, recreation, public access, and  habitat protection.
Land  conservancy  is an extremely effective way to meet
multiple objectives, and is  rapidly emerging  as a preferred
NPS BMP  in many situations.  Many States, including the
Chesapeake    Bay   States,   Florida,   Massachusetts,
Mississippi, and Rhode  Island,  are moving ahead with their
own land conservancy efforts because they have discovered
that you do not have to go very far up the streambank to see
results in water quality.

EPA  will  join  forces  with  other  public   and  private
organizations  that   actively  promote   land  conservancy,
including  techniques such as greenways,  river corridor
management,   conservation  easements, sale/transfer of
development rights, and use of natural and artificial wetlands
to  achieve  water quality objectives.  While the responsibility
for this kind of planning clearly  belongs to States and local
governments,  we will inventory existing land  conservancy
programs,  and will  actively market the  availability of  this
information, as well as the  merits of securing public access
that serves several  different purposes-one  of which  is to
preserve designated water uses.  This is a major  new
initiative.   It  represents  a significant expansion of EPA's
current  emphasis   on  USDA's   Conservation  Reserve
Program,  which is intended  to   remove  certain fragile
cropland from production and provide water quality benefits.

                                SUCCESSFUL SOLUTIONS
                               Upgrade State NFS Management
                               Programs to include the most effective
                               BMPs, regulatory/nonregulatory solutions
                               for particular problems (OW/OWRS) .

                               Develop detailed workplan for national tech
                               transfer program (OW/States/OFA)

                               Publish useful handbooks:
                               • Work with ULI/ELI to develop case
                                 studies on comprehensive planning for
                                 wetlands (OW/OWP)
                               • Complete urban decision-makers
                                 guide (OW/OWRS)

                               Explore opportunities to highlight NPS
                               issues via cooperative marketing schemes
                               for private sector products (example:
                               homeowners' soil testing kit) (OW/OPPE)

                               Evaluate DOT implementation of EXPERT
                               evaluate broader use of this and other
                               decision aids by Federal/State agencies

                               Investigate public/private cooperative
                               arrangements to establish clearinghouse(s)
                               or to develop catalogs;
                               Implement clearinghouse(s) and market
                               availability (OW/OFA/OPPE/Federal
                               Agencies/private sector)

                               TrainingAech transfer workshops (OW):
                               • BMP matrix project (OW/OPPE)
                               • Citizen monitoring (OW/OWRS, OMEP)
                               • Federal consistency(OW/OWRS,OMEP)
                               • Targeting  (OW/OPPE)
                               • State-of-the-atf decision aids (OW/OFA)
                               • NPDES permitting (feedlot/general
                                 permits) (OW/OWEP)

                               Inventory land conservancy techniques;
                               Market use of land conservancy concepts;
                               help interested States/locals
                               (OW/OPPE/OFA/States/private sector)

                               Share information on what worked/did not
                               work in the  "national laboratory"
                               experiences, i.e. Chesapeake Bay, Great
                               Lakes, NEPs, RCWPs, CLs, NCW pilots,
                               etc. (OW)

                               Study surface/ground water interrelation-
                               ships; assess effect of surface water BMPs
                               on ground water (OW/OWRS, OGWP)
FY    FY
89    90
FY    FY
91    92

Ironically, it is explicit financial incentives to manage land in
a specific way that often cause the NPS problem in the first
place.  Once NPS pollution occurs, it usually takes financial
incentives  to correct it.  Our objective is to deal  with both
sides of the equation: how to remove or reduce the financial
incentives  to pollute in the first place; and how to provide
financial incentives to prevent/correct existing problems.

First, let's examine the financial incentives to correct existing
problems.   Although we do not have exact figures on the
"cost"  to  control  NPS   pollution  nationwide,  we  know
intuitively that the amount is quite large.  We also know that,
given   the  current  financial  picture,  States  and  local
governments will have to fund NPS measures with a mosaic
of sources, including a "mix"  of Federal, State  and local
revenues.   Moreover, since many of the  solutions to NPS
pollution are intimately related to  land use practices, direct
Federal financial assistance may often be inappropriate.

Now, let's  look  at the  Federal funding picture.  The "new"
NPS program was born in the midst of a serious Federal
deficit.  It is one of several important new programs, many of
which  have been  denied funding until  problems  of the
National deficit can be resolved.  In spite of this, however,
Congress  did  several things to  provide  funding for the
fledgling NPS program, including:

  4 Grants to  States under §319(h) of the CWA using
    §205(j)(5)   funds,  which may  be  used for either
    program development or implementation.

  + §201  monies, which represent a  potentially large
    source  of  funding.     Via  the   provisions   of
    §201(g)(1)(B), a State may opt to use up to 20% of
    its  Construction  Grant allotment  for  any NPS
    purposes for which a  grant may  be made under
    §319.  Some States are beginning to take advantage
    of this funding source, and EPA  will  encourage
    others to use these funds for NPS measures.

  4 State   Revolving Funds (SRFs), which are being
    capitalized  by EPA grants under §601.   The  law
    specifically designates implementation  of  a NPS
    Management Program  as  one of two non-sewage
    treatment  purposes  for which  SRF funds may be
    used (estuary plan development and implementation
Financial Forces
and Incentives:
The Money

How can we
pay Mr it?
    is the other), and says that States may make loans
    or  provide   other  financial  assistance  to both
    governmental  and private entities.  Again,  use  of
    SRF   funds  for  NPS   purposes  is  a   State
    determination.  EPA will make States fully aware of
    this option as they create their SRR>, and will work
    with  States and local governments to come up with
    innovative ways to package NPS projects so they
    can qualify for SRF loans or other assistance.

In addition to EPA funds, other  Federal  agencies  make
grants and engage in activities that are closely linked with
NPS control/prevention. Good coordination among EPA, the
States, and Federal agencies at the State and local  levels
can lead to many cooperative "joint" projects to support NPS
prevention  and control efforts (State/State,  Federal/State,
Federal/Federal).    EPA  will  help  find  ways  to  match
State/local needs with those of other Federal  agencies. This
may take the form of Interagency Agreements between EPA
and other Federal agencies, or simply  networking funding
sources  and  program  support to  accomplish  mutually
beneficial objectives.

Realistically, however, Federal funds will  Dover only a small
fraction of the work that needs to be done. Thus much of the
responsibility for  providing financial incentives will fall on the
shoulders of States and local governments.   Many States
and local governments have already taken the lead in finding
self-sufficient  forms  of  financing, and  have discovered
creative new ways to fund NPS controls, as well as  clever
ways  to  tap  into traditional  revenue sojrces.   Examples
include   cost  share   programs,   taxes;  (property/sales/
cigarette),  user   fees, utility  districts   (stormwater/septic
system maintenance), permit/development fees, and many
others.  To assist and support State and  local efforts to
devise their own  financing mechanisms, EPA will establish a
central clearinghouse for innovative State and local funding
ideas, which will cover NPS as well as other water programs
such  as  wetlands, ground  water,  and estuaries.   This
clearinghouse will collect and distribute  information  on all
kinds  of creative financing schemes, with special emphasis
on:   revenue  sources  based  upon  the   principle  that
beneficiaries/polluters  pay; and financing techniques  that
spur private investment in pollution abatement.
 ©EPA   16

Finally, States and local governments should not overlook
numerous  opportunities  to  harness  "free  services" to
accomplish  tasks  that   do  not  require   a   long-term
commitment.  Many organizations are seeking opportunities
to make a contribution, such as Boy Scouts, four-wheel drive
groups,    white   water   canoeists,   4-Hs,    historical
preservationists, and many, many others. In addition, States
and counties  have heavy equipment and labor that can be
channeled  to NPS  projects for  short time periods.   The
notion is that, once a need is identified, a "fix" may not be far
away and may be "free" for the asking.

Financial incentives alone are not the answer. We need to
pay  more  attention  to the  public policy decisions  that
produce  NPS pollution as a by-product. In a  major  new
effort, EPA will step  up  activities designed to  influence
Federal  public  policy  decisions  that drive the  kinds of
behavior that cause NPS pollution.  In the immediate future,
the 1990 Farm Bill represents a prime opportunity for EPA to
engage  in  the debate over  the  Nation's future  agricultural
policy, and to work with USDA to  remove (or at least reduce)
the  government  incentives  that  encourage  continuous
cropping practices and farming of marginal (and other) lands
that produce NPS pollution yet enable the production of food
and  fiber  sufficient  to  meet the needs of the  population.
Other potential targets  of opportunity include  influencing
similar  public  policy   decisions at  IRS, DOT,  FEMA,
DOI/Bureau of  Reclamation,  and DOI/Bureau  of  Land
                                                                       , EPA

                                  ECONOMIC FORCES
                                  AND INCENTIVES
                                  Upgrade financial element in State
                                  Management Programs (OW/OWRS,

                                  Support clearinghouse on innovative
                                  State/local funding (OW/OMPC)

                                  Provide information/technical assistance
                                  on innovative/alternative funding sources

                                  Complete overview report on how to
                                  reduce economic incentives to pollute (in
                                  other than agriculture) (OPPE)

                                  Shape Federal public policy to reduce
                                  incentives to pollute (DOT.BLM, FEMA,
                                  IRS. etc.) (OPPE/OPTS/OW/OFA)

                                  Investigate mechanisms for funding State
                                  NPS programs (OPPE)

                                  Make §319(h) grants with §205(j)(5) funds

                                  Evaluate outcome of demonstration
                                  projects for PS/NPS WLA trading;
                                  Expand, as appropriate (OW/OPPE)

                                  Encourage States to:
                                  • Make §201(g)(1)(B) grants for NPS from
                                    the 20% Governors Discretionary funds
                                  • Establish/use SRFs for NPS
                                    (OW/OMPC, OWRS)

                                  Develop ways to package NPS projects
                                  for SRF loans (OW/OM PC/States)

                                  Investigate opportunities to make use of
                                  Federal funds/resources/programs to
                                  accomplish mutually beneficial objectives
                                  (USDA includes agricultural, silvicultural,
                                  urban runoff; others include DOT,
                                  NOAA/OCRM, BLM, FEMA, etc.)
FY    FY
89    90
91   92
               Farm Bill
©EPA   18

We  have   learned  through  experience  that  voluntary
approaches alone generally are not sufficient to deal with the
NPS problem.  In almost every case,  there is  a need for
some kind of regulatory program as well. The real trick is to
find the best regulatory tool for the particular  problem at
hand, which requires us to take a look at the "sources" and
then pinpoint the right "actor" .to  regulate  that source (the
Federal, State, or local government).
As  noted  earlier, States and local  governments have  the
lion's  share of responsibility for land use controls.  It is not
surprising, therefore, that State  and local NPS regulatory
solutions will-more often than not-be the most  appropriate
ones.  The matrix on the following page is not  a complete
array of regulatory solutions, but it does give some examples
of the broad mix of Federal, State, and local regulatory
authorities  that  are  currently in  use.   It is  intended  to
communicate why it is important to build a  sound regulatory
framework  from  the  bottom up, and to make certain that
each solution fits each specific problem.

One  State  program  is  especially  worthy of  note:   the
Wisconsin "Bad  Actors" law.  This  law is a "response-to-
complaint"  or "permit-by-exception" approach,  which was
initiated largely by farmers who had voluntarily  invested in
BMPs  but  a few  of their  neighbors had  not cooperated.
Under the "due process" clauses of the law, the individual
fa'rmer may  eventually  be treated  as  a  "point source"  if
participation  is not forthcoming.   Clearly,  this is a clever,
viable  alternative  to a purely voluntary  program or  a broad
scale,  heavy-handed regulatory scheme,   It is an excellent
example of a voluntary  program with a regulatory  back-up
that involves full dye process.

EPA will guide and support  States and local governments as
they examine the  wide assortment of regulatory tools at their
disposal, and find the  right regulatory solutions for their
particular problems.  As mentioned earlier, we will set up a
clearinghouse with information on regulatory programs and
land use  practices  already  successfully  implemented  by
others, and will sponsor information transfer workshops. As
States  and   local  governments  discover  other  new
approaches,  we  will  also share that information quickly  so
they may gain from these experiences.
A Vital Part of
the NPS Toolbox
"States, In association with
local entitles such as
watershed districts and
councils of government, have
the front line responsibility
for evaluating the nature and
sources of nonpoint source
pollution and devising
appropriate methods of

Senator Stafford
EPA Journal

Shared Regulatory Responsibility: Examples of Federal, State, and Local Authorities
Clean Water Act
$402 Permits
{404 Conditions
§402 Permits (over
100 animals)

{404 Conditions
{402 Permit*
Log Transfer
{404 Conditions
{402 Storm water
{402(p) Municipal
septnlc storm water
and associated
industrial activity
§404 Condition.
5402 Permit Conditions
{402 Sloimwaler

1985 Farm Bill (FSA)
Cons. Title XII (CRP)

BLM Permits
FS Permits (BMPs)
FHA (erosion control
standards during

Proposed RCRA reg.'s
SMCRA (active
surface mines)

Stale Legislation
(cr field crop - PUPA
fcrAlRuDcff. CA
CWA |2M Rtfnlaar
Suu mptaMatUKm
OmilPmnu ITT. CO.

Erosion control at
construction sites
(16 Stales)

Om Pw™. (Fl«ar Mnta() -
All Slates - CWA
Cooperative State/local
efforts - MD. NE, FL,
NM.VT- Require
ME - Special permits
Other Authorities
Enhance CRP
T x 2000 - WI
«cepfion - WI
Public Health

Forest Practices Act -
Quasi -reg. programs -
Sedimenl/Stonnwaler -
Sediment/Stormwater -

Oenril PUB. NE
(Enforced BMPi)

rairfax, VA
Montgomery Co.,
Ilellevue. WA
King Co., WA

Frolection Districts
lloca Raton, FL
Dillon. CO

Shoreline zoning -

            In  addition, States have a new tool at their disposal:  the
            Federal consistency provision  of the WQA of 1987.  This
            provision invites States to establish processes to ensure that
            Federal projects and activities do not conflict with the State's
            policies, standards,  and activities in its NPS Management
            Program.   If the  State determines a proposed  Federal
            activity or project is not "consistent" with its Management
            Program, the Federal agency must accommodate the State's
            concerns or explain in  a timely  manner why it cannot do so.
            Properly  and   effectively  implemented,  the   Federal
            consistency provision has great potential 1o help States and
            local governments achieve their program goals.

            Also, EPA will encourage and assist States to use their NPS
            Management Programs to get a head start on meeting new
            and  upcoming   EPA  requirements, such  as those for
            Stormwater and  agricultural  chemicals  (pesticides  and
            fertilizers).  To help States weave together various Federal
            requirements  in a meaningful  way,  EPA will place  special
            emphasis on two efforts:

Stormwater: EPA will encourage States to use their
NPS  Management  Programs  to  prepare  local
governments to  comply  with  §402(p)   permitting
requirements.  For example, the  State NPS program
can provide: information that explains the impacts of
stormwater on water quality to convince the public of
the need to act; technical assistance on how to solve
the problem (ranging  from  how  to acquire legal
authority to how to design effective controls);  and
ideas on  how  to  develop State/local institutional
arrangements  and  funding  mechanisms.  Initially,
States would focus on large and medium  size cities
and   discharges  in   critical   watersheds  (FY
1989-1990) as well as discretionary permitting under
§402(p); later  the  focus would  shift to  smaller
discharges   (FY    1991-1993).       Networking
requirements under §319 and §402(p) in this manner
will eliminate much of the confusion that currently
surrounds whether States should treat stormwater as
a point source or a NPS, and will allow both the NPS
and NPDES programs to have a definitive  role doing
what  it does  best  - which  will  speed  up   the
stormwater permitting process.

Agricultural Chemicals:   EPA is  moving  ahead
aggressively to address  problems of  pesticides in
ground  and surface waters.   Using  hydrologic  and
runoff   models,  we   can  predict  surface  water
contamination   due   to   pesticide   runoff  from
agricultural sites. We can then use these predictions
in  risk  assessments to determine  the impacts of
pesticides on aquatic organisms and  their  habitat.
EPA is  also beginning to look  at the problems of
fertilizers in drinking  water, and will deal with  this
problem more aggressively over  the next few years.

At the Federal level, EPA will  explore ways to more
effectively  integrate  NPS  considerations  into  its
existing regulatory network, including CWA, SDWA,
FIFRA,  and TSCA. EPA will also work with States to
enhance their ability to deal  more  effectively with
agricultural  chemical NPS pollution by using their
NPS  Management  Programs to  tailor  prevention
measures to their particular situations.
                                                                    EPA   21

Who Should
In addition, EPA will encourage States to step up their efforts
to prevent NFS pollution problems, rather than responding
as  problems arise.   The WQA  says State  assessment
reports should identify waters that are not expected to attain
or  maintain  their designated  uses  and  water  quality
standards.   To  strengthen  State  efforts; to  protect their
pristine   waters   that  are  threatened   by  encroaching
urbanization  or development, EPA will  explore  ways  for
States to make better use of their antidegradation policies to
fully protect  existing  uses from potential harm from NPS
pollution. If we find there are limitations to this approach, we
will  consider including this finding in our Report to Congress,
along with recommendations for changes.

Finally,  EPA is  but  one  of  approximately  31  Federal
agencies with responsibilities for  water-related  activities.
EPA already coordinates with USDA,  and will continue to
strengthen that relationship.   In  addition, it is  important for
EPA to  develop  a stronger partnership with other Federal
agencies to  achieve  mutually  beneficial  program  goals.
Initially,  we will place special emphasis on strengthening our
alliances with two organizations:  DOI's U.S. Fish and Wildlife
Service  (FWS)  and  NOAA's Coastal Zone  Management
(CZM) program.   We will  improve our links  with FWS to
enhance our mutual  capabilities to deal with impacts on
aquatic  life and habitat, such as Kestersoi National Wildlife
Refuge.  We will also build a stronger working relationship
with CZM to better integrate CWA and CZMA goals  and
objectives into the day-to-day operations of both the national
and State programs.

The  important  points  to   remember  about  the role of
regulation in NPS management are:  1) it is usually used "in
conjunction  with" nonregulatory  measures  (rather than "in
lieu  of");  2) it  is an essential  (but  not  only)  tool  for
guaranteeing the ultimate success of the orogram; and 3) it
must  come from  the right level of government, which-more
often than not~will be State or local, not Federal.  EPA's role
is to  support and assist States and local governments as
they  make  these  difficult  decisions,  to make  sure  that
Federal regulatory requirements are imposed  in a way that
aids  States  in  carrying out  their responsibilities, and to
enforce those requirements once they are in place.

FY    FY   FY   FY    FY
89    90   91   92    93
Improve State implementation of Federal
consistency (OW/OWRS)

Maintain and  improve coordination with

Improve coordination with other Federal
agency programs/authorities (FWS,
NOAA/OCRM, Bureau of Reclamation.

Participate in  EPA rulemakings, as
appropriate (OW/OWRS, OWEP/States)
  RCRA Mining Waste

Explore opportunities to network EPA
authorities/programs (CWA, SDWA,
FIFRA, TSCA); work with States to use
NPS Management Programs to prevent
agricultural chemical NPS pollution

Explore States' use of antidegradation
provisions to protect "threatened waters"
(OW/OGC/OFA); work with States to
implement above

Implement cooperative State §402/319
program for control of storm water;
incorporate BMPs into other permits
§402 Establish application requirements
     Screen initial illicit connections
     Identify funding mechanisms
     Develop/review applications
      Issue permits
      Implement permits
     Other non-ag sources program
§319 Identify municipal agencies
     Identify initial sources
     Acquire legal authorities
     Design/implement urban NPS
   I Largo/medium munlclpalltlM
    Small municipalities

Good Science'        Although we have many best management practices (BMPs)
               /  .           for NPS control,  we still do  not have some of the  basic
B&ttGr D&CiSiQnS      "tools" we need to carry out a water quality-based program
On NFS                  for NPS<  ln order for States to deal effectively with NPS
                             pollution and ensure fair treatment of  NPS and point source
                             discharges, we need to develop criteria to protect the uses
                             contained in  surface water quality  standards (WQS).  We
                             also need to  implement WQS and monitoring protocols that
                             are specifically designed to evaluate how effective our NPS
                             technology-based controls (BMPs)  are in reducing  risks to
                             aquatic habitat and minimizing adverse impacts on ground
                             water, and to determine whether there is a need for more
                             stringent controls and/or regulation to meet WQS and  to
                             attain/maintain beneficial uses.

 "Good science" will          The national  wo-s program  has  traditionally  focused on
  teadto     :    .            numeric (individual chemical) and  narrative criteria as the
      :r  ""'   i     :;:         primary  tools for  determining   whether   point  source
 D  Better brbbitem           discharges are meeting designated uses.   While numeric
    identification             anci narrat've criteria have been very helpful in our campaign
 D  Mechanisms to           to contro' P°'nt sources, we cannot "force-fit" NPS into this
    evaluate whether         familiar mold.  Rather, we may have to adjust the manner in
    NPS controls afe         which we apply existing numeric and narrative  criteria, and
    effective    ;;;           even explore new avenues such  as biological criteria in
 -j  Greater eauKV            order  to evaluate the  effectiveness  of  NPS  controls.
    between boiht/           Consequently,  EPA  needs to  concentrate on providing
    nonboint                 States with sound information that allows them to develop
    dischargers              and aPP'ythese new criteria-

                             The  use  of  biological   criteria  ancl  physical  habitat
                             characteristics offer great promise as tools for addressing
                             NPS impacts.   Many NPS impacts affect  the  aquatic
                             community directly through things  such as sediment, and
                             indirectly through habitat modification. These impacts may
                             also affect terrestrial  wildlife  that depends  on the aquatic
                             community for food,  as well as the physical habitat for
                             shelter.  Use of biological criteria has wide application to all
                             types of waterbodies because these indicators are based on
                             the  "health" of the resident biota as measured by various
                             parameters.  Biological criteria are  particularly useful where
                             physical habitat (rather than water chemistry) is limiting use
                             attainment.    Five  States  (Ohio,  Maine,  Arkansas, and
                             Oregon) have already taken the lead in this area by adopting
                             WQS   that   include   biological   and   physical  habitat


To fill the gaps in our current knowledge, EPA will research
and develop various approaches for establishing WQS that
better address NPS problems (narrative, numeric, sediment,
biological  criteria),  and  will develop  better  assessment
methodologies for NPS  impacts  (chemical, physical, and
biomonitoring).   With respect to WQS, EPA will examine
ways to define in advance what we want to achieve, ways to
express violations of WQS or use impairments, and ways to
quantify load reductions  following implementation  of NPS
prevention  and  control  procedures.    With   respect  to
monitoring,  EPA will  research  and  develop tools  and
techniques  for  apportioning  loads  among  dischargers,
enforcement   mechanisms  (under  the   Water  Quality
Management  regulation),   and  a  "feedback  loop"   of
monitoring  to  evaluate success as well  as the need for
additional controls. There is already a lot of activity  in these
areas,  and EPA  will  work closely  with the  States  to
coordinate and to share information as it becomes available.
We will also work to provide States with the most up-to-date
information possible by their next triennial State WQS review
(1991-1993), with a national goal of having appropriate WQS
adopted in all States by 1993.

We also see  potential for the  use of the Ecoregion and
AgNPS (Agricultural Nonpoint Source) approaches as useful
adjuncts to development  of  national criteria, particularly for
biological criteria. The Ecoregion approach allows States to
determine what  is "attainable" given  their regional aquatic
chemistry and biota,  which  provides a scientific basis for the
State to characterize its stream conditions and then establish
its own regional criteria that are feasible and protective of
aquatic ecosystems.   AgNPS  is a  computer  model that
predicts relative NPS pollution loads within small watersheds
and can be used to help target control resources to areas
with  the greatest potential for success.  In  addition to their
scientific  value,  both  the Ecoregion  and the  AgNPS
approaches are useful to  organize thinking in  ways that
people can understand. EPA will work with States interested
in pursuing either or both of these approaches.

GISs are  also excellent  management tools, although  they
generally cost more to develop and use than Ecoregions and
AgNPS.  A number  of States  are pursuing GISs (Oregon,
Kansas, and California, for  example), and  report that they
are useful to help set priorities and to help identify  streams
that  can be used as "benchmarks" for setting  appropriate
                                                                         EPA   25

                           WQS,   States also  report that GISs have a  positive
                           secondary outcome:  they help weld a  variety of agencies
                           together to accomplish a common  mission.

                           While States  are  in the  process of  developing  more
                           sophisticated problem identification/evaluation tools such as
                           Ecoregions, AgNPS, and GISs, they should not neglect other
                           useful tools that are already available. For example, USGS
                           quadrangle maps  and aerial photography  are  extremely
                           effective, inexpensive  devices for communicating scientific
                           and  land use  data,  especially in public  forums.   States
                           should not overlook the value of using these devices to
                           inventory   sources,   quantify   impacts,   and   conduct
                           before/after  comparisons  in  the  short-term  until  more
                           sophisticated   techniques   can   be   developed    and
©EPA   26


Develop NPS monitoring and evaluation
Issue guidance (OW/OWRS/US FWS)

Develop NPS WLA guidance

Develop citizen monitoring guidance

Issue guidance on applying narrative,
numeric, and biological criteria to WQS
for NPS (OW);
Implement guidance (States/Federal

Develop guidance on WQS for
wetlands/lakes; adopt WQS for
wetlands/lakes (States/EPA)

Target monitoring in NPS-impacted
watersheds ;
Evaluate information g°ained
(States/Federal Agencies)

Improve coordination with FWS/
NOAA/USGS on developing criteria

Revise existing narrative/numeric
criteria for NPS concerns (OW/
US FWS/States)

Develop numeric biocriteria, including
use of Ecoregions (OW/ORD/US FWS)

Adopt fine sediment criteria for selected
waters (States)

Conduct workshops to discuss wildlife
and marine and estuarine criteria;
Develop criteria (OW/US FWS)

Conduct NPS monitoring workshops

Investigate sources of NPS pollution

Conduct case studies to evaluate
biological improvements associated
with filter strips (OPPE)

Conduct research to understand more
about the extent of damages to wildlife
and habitat (OW/OPPE/ORD)

A Vision of the
"We have been persuaded to take
a path somewhat different from
that taken for point sources.
States are given flexibility to
Identify priorities. And based on
commitments made In this
legislative cycle, It Is the
expectation of Congress that this
program will result In a
significant Improvement In water
quality and nationwide reduction
In pollutant loadings from
nonpolnt sources. We will, of
course, revisit this question In
the next legislative cycle on the
Clean Water Act. We will not find
this program adequate If real
Improvement In water quality has
not occurred. We are not so
much Interested In elements of a
State program as we are
concerned with meeting the goals
and objectives of the Clean Water

Senator Durenberger
Senate Debate
October 16, 1986
As noted earlier, Congress gave us a four-year lease on life.
This is  an enormous challenge,  and  Congress  and the
American people are watching and waiting to see if we --
EPA, States and local governments together - can succeed.
It is up  to all of  us to make the §319  program work well.
Otherwise, the next time Congress deals with NPS we may
see the program moved  yet again-this time  from Title  III
(Standards and  Enforcement) to  Title IV  (Permits  and
Licenses) of the Clean Water Act.

We need to set some realistic, yet challenging, goals for the
national NPS program so we can gauge our progress over
time.  In the very near-term, we may be limited to tracking
progress by  counting  how  many  Slates/localities  have
adopted  regulations/ordinances, how many farmers  have
installed  BMPs, or how many new funding sources  have
been established.  By the time the next CWA reauthorization
rolls around, however, we need to be able to make a case in
environmental terms: How/where have we actually improved
the nation's water  quality?   Our  goa   should  cover both
control and prevention  of NPS, and should  deal  with the
nexus between ground water and  surface water.   EPA is
adopting the following environmental goal:

    To prevent further  loss of water uses due to
    NPS pollution.  To  restore and protect critical
    aquatic  resources  (including  habitat)  and to
    meet  WQS  in a  growing  number  of  water

      • Short-term: To prevent further loss of
         water  uses  due  to  NPS,  including
         surface  water impacts  from  ground
         water (five years);

      • Medium-term:  To maintain water uses
         in  water  bodies  impacted by  NPS
         pollution (ten years);

      4 Long-term: To achieve WQS in water
         bodies  previously  impaired  by  NPS
         pollution as  reported  in State  NPS
         assessments (fifteen years).

It has taken a long time and significant efforts to get point
sources under control, so  it is reasonable to expect that
controlling NPS pollution will take equal  or greater efforts
and will not occur immediately. Over the next few years, we
must work together to institutionalize NPS programs, and to
forge an alliance to clean up and protect the Nation's waters
from NPS pollution.  We must also be able to demonstrate
enough progress  in meeting the water quality objectives of
the Act to win the continued support of Congress.
                                                                         EPA   29

EPA Offices
OGC       Office of General Counsel
OPPE      Office of Policy, Planning and Evaluation
OEA       Office of External Affairs
OFA       Office of Federal Activities
OW        Office of Water

           ODW   Office of Drinking Water
           OGWP  Office of Ground Water Protection
           OMEP   Office of Marine and Estuarine
           OMPC   Office of Municipal Pollution Control
           OWEP   Office of Wate r Enforcement and
           OWRS  Office of Water Regulations and
           OWP   Office of Wetlands Protection

OSWER    Office of Solid Waste and Emergency
OPTS      Office of Pesticides and Toxic Substances
ORD       Office of Research and Development
Federal Agencies
©EPA   30
Department of the Interior

BLM    .Bureau of Land Management
USGS   United States Geological purvey
FWS    Fish and WiFdlife Service

Department of Transportation
Environmental Protection Agency
Federal Emergency Management Agency
Federal Energy Regulatory Commission
National Oceanic and Atmospheric

OCRM   Office of Coastal Resource

Tennessee Valley Authority

USDA      United States Department of Agriculture

           FS      Forest Service
           CRP    Conservation Reserve Program
CWA       Clean Water Act
CZMA      Coastal Zone Management Act
CBRA      Coastal Barrier Resources Act
FIFRA      Federal Insecticide, Fungicide, and
           Rodenticide Act
FSA       Food Security Act
RCRA      Resource Conservation and Recovery Act
SDWA      Safe Drinking Water Act
SMCRA    Surface Mining Control and Reclamation Act
TSCA      Toxic Substance Control Act
WQA       Water Quality Act of 1987 (Amendments to the
BMP       Best Management Practice
NCW       Near Coastal Waters
NEP       National Estuary Program
NPS       Nonpoint Source
PS         Point Source
RCWP     Rural Clean Water Program
SCWS     State Clean Water Strategies
SRF       State Revolving Loan Funds
WLA       Wasteload Allocation
WQS       Water Quality Standards
                                                               I* EPA