OOOK88002
CD420
.G281
kvEPA
          United States
          Environmental Protection
          Agency
Office of Water
Regulations and Standards
Nonpoint Sources Branch
Washington, DC 20460
August 1988
          Creating Successful
          Nonpoint Source
          Programs:

          The Innovative Touch



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                             Contents
Concepts Behind Creative Programs	1
Unusual Alliances Can Get Creative Results	2
    Oystermen and Farmers Unite to Save Tillamook Bay  	2
    City Aids Farmers in Fighting Pollution  	3
Funding Often Must Be Creative, Too   	4
    Loans Replace  Grants for Cost Sharing  	4
    Community Forms Utility District to Fund Stormwater Control   	4
    Industry Funds  Enforcement Program	5
The Program That Plans for Results Can Show Results	6
    Monitoring Provides the Needed Connection  	6
    Programs Can Pay Multiple Dividends	7
Target Your Most Productive Program  	8
    Local Interest Leads to Willingness to Assume Problem Ownership  ....  8
    Pennsylvania Focuses on Nutrient Management	8
    Maryland Protects Critical Area  	9
Explore Modern Technologies	10
    Virginia Locates Key Farmers with Computer System  	10
    Minnesota Assessed Ground-water Sensitivity	10
Self-regulation May Be Easier to Sell  	11
    Dairy Farmers Fine Association Member  	11
    Illinois Farmers Write Farm Plans  	11
    Idaho's Foresters Believe in Effective Enforcement	11
Recast the Problem Creatively	12
    When is a Nonpoint Source a Point Source?	12
Bibliography  	12

             Cover: an innovative way of controlling erosion on steep
                slopes—vegetation can be planted in open blocks.
      This report has been reviewed by the U.S. Environmental Protection
      Agency and approved for publication. Approval does not signify that
      the contents reflect the views and policies of the U.S. Environmental
      Protection Agency. The listing of trade names or programs does not
      imply any endorsement by the Agency.  This document was prepared
      by Claire M. Gesalman, Amy L. Marasco, and Maggi Elliott of Roy F.
      Weston, Inc. under EPA contract 68-03-3450. Design by JT&A, Inc.
      The EPA Task Manager was Jim Meek, Nonpoint Sources Branch.

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       Concepts Behind Creative Programs

Innovation has always been necessary in the nonpoint source management field.
Resources have been chronically limited; standard  methods of monitoring and
problem identification show only part of the  picture; results can be hard to
demonstrate. And yet, program managers and staff have found ways to solve the
problems and get the programs moving.
   Solving problems often depends on leaving no stone unturned — letting no idea
go unconsidered. Even ideas that seem impossible can work.
   By reviewing the circumstances and approaches of several innovative programs,
we can distill certain concepts and characteristics that seem to be key to then- success
and creativity. These concepts are presented in the pages that follow with the goal of
helping managers of newer state and local programs save time, money, and energy in
solving their own problems, as well as giving a boost to  programs that may be in need
of a new direction or approach. Following each program description is the telephone
number of the responsible department or agency.
           Documenting New Program Approaches
   The examples included here are a
   starting point for an effort to gather
   new examples of creative programs.
   EPA and states are moving into a
   new phase of the nonpoint source
   control  effort  with  the initiatives
   created by the 1987 Water Quality
   Act,  and new approaches will be
   needed to solve the current genera-
   tion of problems. This information
   transfer is vital to our ability to meet
   the goals Congress has set.
      There is no need to write a 30-
   page report. Just list the points that
   are key to understanding what you
   are doing and how it is succeeding.
   Some of the  questions that  you
   should consider are:
    •Who's been involved? (lead and
      support roles, coordination,
      institutional issues, etc.) And
      who's been missed? Who
      should be involved?
  • What problems have you
   encountered and how did you
   overcome them?
  • How did you define the program
   scope or identify the specific
   problem to be studied or attacked?
  • What sources and amounts of
   funds were considered, located,
   developed, chosen? (Why and
   how?)
  • What factors do you consider as
   key to the success of the program?
  • What have been the results to
   date?
  • How has progress been assessed?
  • What would you do differently the
   next time?
   Send information on your program
 or a program you think is innovative or
 creative to EPA's Nonpoint Sources
 Branch at WH-585, 401 M St.,  SW,
 Washington, DC 20460. Or call us at
 (202) 382-7085.
U.S. Environmental  Protection Agency
                                     Region  b, Library  (FL-12J)
                                   1 77 West Jackson Boulevard, 12th Floor
                                     Chicago, IL  60604-3590

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 Unusual Alliances Can Get Creative Results

It's simple and often very productive to go directly to the source of
the  problem,  using  time-honored  cooperative mechanisms  like
USDA's Soil Conservation Service network. Incentives and enforce-
ment clearly work, but continually using the same network can mean
business as usual and missed opportunities for creativity.
  Involvement by outside interests can provide a spark. Perhaps the
best way to obtain such involvement is to appeal to the self-interest of
those who are part of or affected by the problem: Develop a sense of
ownership of the problem. People who feel responsible are easy to
mobilize; they're energetic and tenacious about problem solving.
Who is adversely affected by nonpoint source (NPS) pollution in your
program area? Are they aware of the problem and its economic con-
sequences for them? For example:
Oystermen and Farmers
Unite to Save Tillamook Bay

When oystermen in Oregon's Tillamook
Bay saw their livelihood threatened by
large-scale NPS pollution, they united
to tackle the problem. Fishermen aided
state agencies and  local citizens, who
began to track down the source of fecal
contamination in their shellfish beds.
Dairy cattle were  identified as the
culprits:  19,000 of  them on 118  dairy
farms.
  The oystermen approached the Til-
lamook Creamery Association for help.
Together, these  two interest groups
sought solutions. By 1980, an EPA grant
had yielded a plan for abatement of
agricultural  NPS  pollution. In  1981,
USDA funded a Rural Clean Water
Project that cost shared best manage-
ment practices (BMPs). Farmers began
a massive reform of their waste han-
dling practices.  By  1985, sampling in
streams feeding Tillamook Bay showed
that fecal bacteria levels were down 15-
50 percent in various areas. Further im-
provements are expected.
  "While  credit belongs  to  several
government agencies for getting things
started, it  has  been  the  Tillamook
Creamery Association  and  individual
dairymen who have actually been get-
ting things done," said EPA's Region 10
Administrator.
  Local pride in Tillamook oysters and
Tillamook cheese may have had some-
thing to do with it, too. These oystermen
and  dairymen  have  shown  an en-
lightened  understanding of the  inter-
dependence of interests necessary to an
area's economic health.
Oregon Department of Environmental
Quality- (503) 229-6035

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City Aids Farmers in
Fighting Pollution

Springfield,  Illinois  is  another place
where  people  concerned  about NFS
pollution tackled the problem from out-
side the traditional network of coopera-
tion. Lake Springfield was filling in with
sediment, threatening even the normal
water supply needs of the City in times
of drought.  The citizens were worried
about the future of the lake as a water
supply, as well as a fishery.
   Representing the City's self-interest,
the water department went right to the
source of the  problem:  local farming
practices. A $10,000 grant from the City
of Springfield  bought the  county soil
and water conservation district a no-till
planter. Farmers began  to  use it and
demonstrate the benefits of preventive
soil conservation measures.
   The City went on to cost share other
BMPs for NFS pollution control. The
program was run without federal cost-
share money and was  administered by
the county soil and water conservation
district. Projections indicate that these
preventive methods will save about 20
percent of  the price  tag  of dredging
uncon-
   Soybeans in no-till wheat straw.
   Photo by Soil Conservation Service.

trolled  sedimentation  over  the  next
decade.
   The cooperative relationship among
City government, the  soil and water
conservation district, and local farmers
has  proved highly effective both in
Springfield and  in  other  areas of Il-
linois.
City of Springfield- (217) 786-4093

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      Funding Often Must Be Creative, Too
The traditional funding source for NFS programs has been appropria-
tions for both program administration and incentives or cost sharing.
Clearly, the need has grown far faster than the political  will to ap-
propriate  general  revenues for these  programs, so  nontraditional
sources of funding are  needed.  Some of the  programs that  have
developed a new approach to funding include:
Loans Replace Grants for
Cost Sharing
State revolving loan funds (SRFs) are
now being established to  replace the
wastewater construction grant program.
Under  SRFs, states may also provide
financial assistance to nonpoint source,
groundwater, and estuary activities. In
addition  to  SRFs,  some  states  have
other loan programs that may be avail-
able for nonpoint source  activities.
Many people are not aware that this
funding  method can  be used  for
leveraging  state  money  in  other
programs. In contrast  to the cost-shar-
ing approach other states are applying
to NFS pollution control, Utah has in-
itiated   the   Agricultural   Resource
Development Loan Fund. The program
has grown from $250,000 in 1976 to
$14.4  million in 1988. Once interest-
free, the loans are still affordable at only
3  percent.   Furthermore,  repayment
does not begin until the improved land
is ready for use. These features remove
many of the  financial  barriers that can
discourage  individuals  from  making
abatement improvements.
   The program's success is due in large
part to Utah's soil  conservation  dis-
tricts, which process  applications, ap-
prove plans,  and monitor projects. The
conservation districts make sure the
BMPs  are  practical  and reasonable.
Loan payments and interest replenish
the state fund. Administrative fees are
divided among the various state and
local agencies involved in the program.
Utah Department of Agriculture— (801)
533-5918
Community Forms Utility
District to Fund Stormwater
Control
Bellevue, Washington needed to im-
prove its management of stormwater as
the City grew. Residents saw the salmon
dying and pristine  areas disappearing
and wanted to preserve local streams as
viable natural environments. Grassroots
support was easy  to garner because
many residents had moved to Bellevue
for its natural beauty and accessibility to
recreation. Local involvement was key
to obtaining  approval of a comprehen-
sive  stormwater management plan to
aid in improving water quality (an ad-
visory  vote  was  held  before  sale of
revenue bonds).
   Funding for the drainage program is
based on the "polluter pays" principle;
all developed property has some imper-
vious surface, so  everyone contributes.
Other  funding sources include permit
fees, buy-in  charges, developer exten-
sions,  and  late-comer  agreements.
These last two items result in system ex-

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pansion  at  no charge  to the utility.
Funding is  stable because  the utility
does not have to  compete with other
public services for budget appropria-
tions.
   The program centers on source con-
trols, such as oil-water separators where
spills are  likely,  vegetation  clearing
limits, and  public  education. Public
education is designed to develop a feel-
ing of "ownership" of the problem and
show how individuals can be part of the
solution; common problems and practi-
cal solutions are emphasized.
Bellevue, WA Storm and Surface Water
Utility- (206) 451-4476


Industry  Funds Enforcement
Program

In an interesting twist on the "polluter
pays" principle, Idaho's forest products
industry lobbied the state legislature to
have themselves taxed to support five
forestry agency positions to enforce the
State Forest Products Act, which regu-
lates erosion control by forestry opera-
tions. Forestry, like many industries, has
had a negative public image and is often
subject to calls for  stricter regulation
and stiffer penalties for violations. Now,
Idaho foresters pay  five cents per  acre
into a fund for staffing in the Depart-
ment of Lands.  The  program is  ex-
pected to generate about $150,000 per
year. The increased staffing level will
allow the agency to increase its inspec-
tion and enforcement activity, as well as
improve its  educational efforts. For ex-
ample,  a series of  15  workshops for
forest operators has been held around
the state. Careful homework before the
legislation was introduced ensured  its
passage with little opposition.
Idaho Department of Lands— (208)
334-3280
Sides and ditches of logging road seeded
   to control erosion. Photo by Soil
        Conservation Service.

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       The Program that Plans for Results
                    Can Show Results

Successful NFS programs are efficient and cost effective. They use
available  resources and expertise and build on the experiences of
others. In addition, they consider the long-term costs and benefits of
the program—it may be necessary to spend a little in the near term to
gain a lot in the long term.
  The most effective demonstration projects focus on demonstrating
clear results, rather than just showing how to  implement a project.
This is something that requires a  talent for detailed foresight and
skillful planning. Simply stated, a program needs reliable feedback:
              • What's working, and what isn't?
              • Is the strategy cost effective?
              • Who's being convinced?
              • Is water quality improving?
              • How could the next project be improved?
  It can be difficult to answer these questions, but it is possible, even
with large, complex projects.
 Monitoring Provides the
 Needed Connection

 Iowa's   Big   Spring  Demonstration
 Project was planned carefully to show
 results.  Nitrates  and pesticides  are
 creeping into  ground water in  Iowa,
 where 80 percent of the citizens depend
 on  it for  drinking water. Big Spring
 Basin had experienced ground-water
 contamination from these sources, so it
 was  an  excellent  choice  for  a
 demonstration project. Almost all of the
 basin's ground water  discharges at Big
 Spring, so chemicals that leach into the
 ground water eventually show up there.
 Furthermore,  the background  data
 needed to reveal water quality changes
are  already  available; intensive water
monitoring has been conducted in the
basin since 1981.
  Finally, Big Spring Basin is a perfect
test ground for abating NFS pollution
from  agriculture.   There   are   no
municipal  or  industrial  wastewater
sources that could confuse monitoring
results.
  Big Spring provides a huge, relatively
undisturbed laboratory for making NFS
tests. Project personnel are educating
farmers   on  ground-water  quality
problems and the use of fertilizers and
pesticides and good agricultural prac-
tices. BMPs are being installed and dis-
played on experimental farm plots. And
ground-water   results   are  being

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monitored. Early data show a relation-
ship between fertilizer nitrogen applied
in the Big  Spring Basin  and  nitrate
levels in the ground water there. Nitrate
level declined in response to the reduc-
tion in fertilizer use associated with the
Payment-in-Kind (PIK)  program, for
example. It will be a few years, however,
before  clear  relationships  can  be
defined, since year-to-year variation can
mask long-term trends. The excellent
planning choices made in targeting Big
Spring Basin will  assure  that  these
results will be possible.
Iowa Department of Natural Resources,
Geological Survey Bureau — (319)
335-1575
Programs Can Pay Multiple
Dividends

In Queen  Anne's County,  Maryland,
state officials constructed an artificial
marsh at a local high school. In develop-
ing this project, they not only built  a
control mechanism to solve a problem,
but also provided a teaching tool. Stu-
dents and teachers learned about NFS
pollution  and  the   natural cleansing
power of wetlands while doing part of
the planting. Thus, Maryland cut costs
of   creating   the   wetland   while
demonstrating the efficacy of coopera-
tive efforts and effectiveness of natural
systems in reducing NFS pollution.
Maryland Department of the
Environment- (301) 974-2224

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     Target Your Most Productive Problem

The diffuse nature of NFS pollution makes it particularly difficult to
grapple  with:  the problem presents few clear "handholds."  Many
program managers have responded to this  situation by dispersing
abatement funds uniformly across the state or on a first-come, first-
served  basis.  Others,  however,  have  thrown  a  spotlight   on
troublesome areas through an approach popularly called "targeting."
Targeting can make it much easier to show results, because it focuses
control  activities on  a  problem watershed, a specific industry, or a
particular facet of the problem.
Local Interest Leads to
Willingness to Assume
Problem Ownership

Wisconsin carefully  targets areas with
serious NFS problems and provides as-
sistance only where localities want help.
This  skillful,  two-pronged approach
maximizes the efficacy of limited funds.
Wisconsin uses the following criteria to
select target watersheds before commit-
ting resources:
 1. severity of the pollution problems;
 2. the potential for pollution reduction;
 3. willingness of landowners to
    participate in the cleanup effort;
 4. potential benefits as a result of the
    program;
 5. ability of local authorities to carry
    out their roles; and
 6. the willingness and ability of local
    agencies and other governmental
    units to control other sources of
    pollution.
 Federal, state, and local agencies are all
 actively involved in targeting  water-
 sheds. Development of abatement plans
is also a cooperative effort, with respon-
sibilities for action and funding clearly
detailed. The unique feature of this
program is the targeting of watersheds
where communities have convinced the
state that they want to solve their NFS
pollution problems. The  local govern-
ment monitors the projects and  is ac-
countable  to  the   state  for  their
implementation.
Wisconsin Department of Natural
Resources- (608) 266-1956


Pennsylvania Focuses on
Nutrient Management

Pennsylvania targeted its  Susquehanna
River basin as a major focus of agricul-
tural pollution control based on EPA's
study on  Chesapeake Bay pollution.
The Susquehanna contributes  about
half the fresh water flowing into the Bay
and carries with  it 21 percent of the
phosphorus  and  40 percent of the
nitrogen  polluting Bay  waters. The
sources: excessive cropland soil erosion
and a dense livestock population. An
earlier study by the  state showed that
counties  in  the  lower   Susquehanna
basin were responsible for the bulk of

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the pollution,  so the control program
was targeted to those areas. In addition,
nutrient management was identified as
the most productive approach to pollu-
tion control, leading to design of a cost-
sharing program around this concept. A
nutrient  management plan must be in
place before a farm is eligible for BMP
cost-share funds. Assistance to farmers
includes  a  mobile nutrient laboratory,
which helps farmers limit nutrient ap-
plications (including manure)  to the
level needed by crops.
Pennsylvania Bureau of Soil and Water
Conservation-(717)  787-5267


Maryland Protects Critical
Area
Maryland has  created a special zone to
protect the Chesapeake Bay from NFS
pollution. The Critical Area Program is
a means of implementing  NFS efforts
along  shoreline  areas adjacent to the
Bay through controls on development in
a 1000-foot strip. A state and local com-
mission developed program  criteria,
which  are  being used  in  developing
local   protection   programs.   Local
governments assign critical areas under
their  jurisdiction  into  one  of three
categories  and  regulate development
accordingly. In "Limited Development
Areas" the goal is to  preserve existing
forest cover and minimize impervious
surfaces. In  "Resource Conservation
Areas" development is  discouraged in
favor  of agriculture and forestry. Pol-
lutant reduction from existing develop-
ment   is   the  goal   in   "Intensely
Developed Areas." Farmers in the criti-
cal areas   must have  soil and water
management  plans  by  May  13, 1991.
Buffer strips of vegetation up to 100 feet
wide  are   being planted along tidal
waters and streams.
Chesapeake Bay Critical Areas
Commission- (301) 974-2426
         Waste management for cattle operation, with settling basin on right.
                       Photo by Soil Conservation Service.

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            Explore Modern Technologies
Recent advances in computer technology have made new tools avail-
able to program managers. Geographic information systems are new
tools that can be used to define problems and target solutions.  Two
ways they have been used are described below.
Virginia Locates Key
Farmers with Computer
Virginia is now using a computer-based
information  system  to  identify  farm-
land with  a high erosion potential.
VirGIS—  the Virginia Geographic In-
formation System —replaces a manual
approach to the identification and tar-
geting  process. VirGIS  is used as  a
screening  tool  to  identify  potential
problem areas. State and local staff then
visit farms  to verify conditions and
evaluate abatement  techniques.  This
approach identifies the potentially most
serious problem areas and allows staff
to take the program to farmers who
might not  have  requested assistance,
rather than just allocating funds among
farmers who come in voluntarily.
   VirGIS combines  a variety of data
sources: topographic, soil, and surface
water maps, and  soil, watershed, and
elevation  information are  integrated
with  factors for  rainfall,  vegetative
cover, and land use practices. The one-
hectare cell that is the geographic unit
allows targeting of priority areas on in-
dividual farms. In the long term, staff
expect to be able to  use the system to
assist with priority setting and critical
area determination for programs such
as the Conservation Reserve, forestry
management, and assessment  of site
suitability for on-site waste manage-
ment.
Virginia Division of Soil and Water
Conservation-(804) 786-8173
Minnesota Assessed
Ground-water Sensitivity
A key receptor for pollution is ground
water.  However,  the  potential  for
ground-water  contamination  varies
from place to place. In southeastern
Minnesota, karst topography (limestone
caves, sinkholes, etc.) leads to high pol-
lution potential, but available monitor-
ing data  were not organized so that
trends  could  be  identified  easily.
Analysis of local well monitoring data in
conjunction with state well location in-
formation in the Minnesota Land Infor-
mation System has allowed correlation
of test data with aquifer data. Hydro-
geologic  sensitivity maps produced by
the state  show how susceptible various
areas are to ground-water  contamina-
tion. These substantiate the relationship
between  land  use and  ground-water
quality. Results are being used to edu-
cate local officials and  residents and
have led  to development  of ground-
water protection ordinances and the use
of local  water planning legislation to
develop  aquifer  protection plans for
each county.
Minnesota Environmental Quality
Board- (612) 296-0676
                                    10

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       Self-regulation May Be Easier to  Sell
By developing consensus on the need for regulation, the regulated
community may find it easier to comply without complaint. Similarly,
self policing by a regulated group may be more effective than govern-
ment intervention: The penalties may more closely fit the "crime."
Dairy Farmers Fine
Association Member
As part of the effort to clean up Til-
lamook  Bay (described earlier), dairy
association members fined one of their
fellow members for violating required
BMPs. That farmer's  milk  price was
reduced until the violation ceased, and
to help  ensure future  compliance,  the
reduction  was  continued for an addi-
tional six months.

Illinois Farmers Write Farm
Plans
In Illinois,  the Soil Conservation Service
has begun  a program to train farmers to
write their own farm plans. These plans
are the basis for  conservation and
erosion  improvements through  im-
plementation of BMPs and are required
for continued eligibility for federal as-
sistance. Accelerating  development of
the plans will increase the pace of BMP
installation and thus  result in  more
water quality benefits.  In other  areas,
most farm plans  are  developed  by
governmental agencies, which limits  the
number  that can  be developed each
year. Helping farmers  write their own
plans will  also help ensure their im-
plementation, since the  farmers will feel
a greater  degree of responsibility  for
them and the results, as well as feeling
that they are realistic. Farmers also  are
taught  key concepts  about erosion,
which are then related to recommended
control practices. Farmers have always
recognized   their   role   in   land
stewardship, and this understanding of
causes and effects of erosion provides
good reasons for controlling erosion by
reinforcing this feeling.
   The Soil  Conservation Service and
the  Cooperative Extension  Service
together have developed an instructor's
manual,  five  slide  shows,  and  a
videotape  to be used in an  18-hour
course. The material was  tested and
revised over a one-year period and is
now available for distribution. Several
states have already used the materials,
which are designed to be modified easi-
ly to include locally relevant informa-
tion.

Idaho's  Foresters Believe in
Effective Enforcement

As mentioned earlier, Idaho's forest
products industry lobbied for a tax to
support state enforcement of the Forest
Products Act. Clearly, foresters believe
that their interests are served better if
the law is enforced; they are less likely
to receive  adverse publicity and com-
plaints if all  affected  companies know
they must comply. Peer pressure is also
an effective tool to increase compliance;
forestry associations  are  cosponsoring
workshops and  other educational ef-
forts.
                                   11

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            Recast the Problem Creatively

Some innovative program managers have gone to  the heart of the
NFS problem —and transformed it! Such an approach calls for an al-
most forced detachment  from usual ways  of viewing the situation,
coupled with some very creative brainstorming.
When is a Nonpoint Source
a Point Source?

Florida managers decided that it would
be  easier to control some nonpoint
sources if they could be viewed as point
sources, tractable to point source solu-
tions. BMPs provided the inspiration:
stormwater runoff is now being cap-
tured in retention basins or detention
facilities in urban areas across the state.
Developers are required to implement
the concept. To release stormwater to a
surface water  body, developers  must
apply for a state discharge permit. The
applicant must assure the state that the
proposed discharge  will not cause a
violation of water  quality standards.
Performance standards  are  used to
achieve this goal. For example, for a
project occupying less than 100 acres,
the standards require that  the runoff
from the first inch of rainfall or the first
half inch of runoff be captured either in
a retention basin or in a filtering deten-
tion facility.
   Although some problems have sur-
faced in implementing the program,  it
has been widely accepted by the con-
struction industry. In its first four years
of existence,  the Florida  Stormwater
Rule has stimulated the development of
thousands of detention  and retention
systems. Current issues to be addressed
include the potential for ground-water
contamination  and  the  need  for  a
regional or watershed approach to con-
trols in some areas.
Florida Department of Environmental
Regulation -(904) 488-0782
                           Bibliography
 Cooperating for Clean Water (case studies
   and three briefing papers related to agricul-
   tural nonpoint source pollution  control,
   published by the Farmland Project of the
   National Association of State Departments
   of Agriculture Research Foundation), 1986.
 The Model Implementation Program: Lessons
   Learned from  Agricultural Water Quality
   Projects  (prepared by the National Water
   Quality Evaluation Project at North Carolina
   State University and Harbridge House, Inc.)
   February 28, 1983.
Chesapeake Bay Nonpoint  Source Programs,
   U.S.  Environmental  Protection  Agency,
   Region 3, Chesapeake Bay Liaison Office,
   January 1988.
                                    12

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Inv
    For additional copies — contact the

     U.S. Environmental Protection Agency
      Nonpoint Sources Branch (WH-585)
               401 M Street, SW
            Washington, DC 20460
                (202) 382-7085
                 U.S. Environmental Protection Agency
                 Region 5, Library (PL-12J)
                 77 West Jackson Boulevard, 12th Floor
                 Chicago, IL  60604-3590

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United States
Environmental Protection
Agency  WH 585
Washington DC 20460
Official Business
Penalty for Private Use $300
            nonpoint  source W pollution

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