I.     INTRODUCTION                                     1

II.    MAJOR THEMES FOR FY 1977                         2

             A.   Follow-through on Current             2


             B.   Additional Program highlights.        8

             C.   Major Objectives and Concerns.       14

             D.   Legislation.                         18

III.   PRIORITIES FOR FY 1977.                         20

             A.   Priorities Among Program Areas.      23

             B.   Priorities Within State and

                    Regional Program Areas.            25

             C.   Regional Priorities.                 29


             A.   General Phasing.                     32

             B.   Phasing in Specific Program Areas.   3b

V.     CONCLUSION.                                     43


     The t\ iy"/7 edition of the Water  Quality  Program  Overview
has Deen prepared tor particular use  and  review  by  State
and local government officials, and for  the  information of
the public. It is intended to be helpful  as  States  and Regions
plar  their operating programs, and for the use of States,
local governments, and interested citizens in  the development
of water quality management p]ans under  the  Federal Water
Pollution Control Act  (P.L.  "2-500).   This  document reflects
the final decisions on the Feueral Government's  FY  1S>7? budget.

     Ihe Overview describes the basic national water quality
program; supplemental program modules provide  more  detailed
descriptions in specific subject areas.  Ihe  Overview and program
mooules are three-hole punched so tnat revised pages can
oe distributed and incorporated during the course of the
year if necessary to maintain currency.

     The national program's directions have  not  changed
from last year.  However, some substantive changes  have been
made.  Also, the Overview discussion  has been  broadened to
include several new areas of program activity.

     The principal emphasis of the Water Quality Program Over-
view is in the implementation of the Federal Water  Pollution
Control Act, tor which LPA has the major Federal responsibility;
and the term "the Act" means the fWPC'A unless  otherwise indi-
cated.   EPA's role under the harine Protection,  Research, and
Sanctuaries Act in regulating ocean dumping  is also included.
Programs directed to the protection of public  water supplies
are not addressed, although a module discusses areas of the
Sate Drinking Water Act which are related to the FWPCA.

     Persons using the Overview are reminded that this paper,
while bastd on law, is not the law, nor is  it  a  regulation
mandated by the law.  It is a description of program policy
Lor use by government agencies implementing  the  Act and by
other interested persons.

     Ihe Cverview is written under the aegis of  the Water
Planning Livision in EPA headquarters, but  it  reflects the  work
of individuals within all EPA headquarters program  areas and

tne participation of LPA's Regional Offices,  the States,  ana
interested public groups and citizens.   These contributions
are appreciated.

     Comments on the Overview and program modules are welcomed
at any time.  Th


     Summarized in this hater Quality Program Overview are
near-term and long-range views on the control of water
pollution.  Sections II and 111 chart LPA's goals tor
Fiscal Year ly?7.  Section IV puts these goals in
the broader perspective of the next decade.

     Sections II and III, in the form of themes and priori-
ties, describe EPA's near-tern  concerns.  These generally
will be the highlights of the FY 1977 national program.
It will be evident, however, that not all of. the program
elements required for comprehensive water quality management
can be given top priority in the next year.

     The desired end result of the national program is the
improvement and maintenance of water quality. Data on  ambient
conditions appear in EPA's annual report to Congress,  the
National Vvater Quality Inventory, pursuant to section  305 ot
the Federal Water Pollution Control Act, and, more summarily,
in LPA's annual Clean Water Report to Congress pursuant to
section 516(a) .

     rihis Overview is supplemented by individual program
modules, which provide more detailed descriptions ot parti-
cular programs.   Modules are available in the following

           The Basis for Effluent Limitations.
           Permits, Compliance Monitoring and Enforcement.
           Municipal Construction and Operation.
           Program Management and Water Monitoring.
           Diffuse and Intermittent Sources.
           Distinct Water Body Programs.
           Research and Development.
           Associated Program Areas.

1 1 .    MAJOR THEMES FOR FY  1977
     Ihe tollowing major themes represent  the  locus  ten  li:;*.\il
Year 1977.  These are nationally important elements  that should
be common to every State and Regional  Otfice program etiort.
They combine retained emphases of past years,  new program
highlights, and adjustments to program objectives. The  effect
of these themes is to establish priorities among program areas,
which are summarized in Part III, below.    Vvhile these
major themes apply nationwide, it is recognized that States,
Regions, and individual planning agencies  may  need to estab-
lish additional priorities that address individual areas of
local and Regional concern. These efforts  are  encouraged.

A .   follow-through on Current Accomplishments .

     Ihe award of construction grants and  issuance of permits
have been primary objectives since the enactment in  October,
1972, of the Federal Water Pollution Control Act Amendments.
During the past year, program resources have continued  to
emphasize the expeditious obligation of construction grant funas.
The permit program, in contrast, has witnessed a recent major
shift to compliance monitoring and enforcement of the issued
permits.  In addition, State and areawide  water quality manage-
ment plans are being developed for many areas  of the country.
Approved plans should be a major guiding factor in Phase II
activities and should enhance the effectiveness of the  overall
national water quality management effort.

     Ihese and other progams are achieving a  stage of full
operation.  Therefore, EPA is becoming increasingly  concerned
with the accomplishment of program objectives  and achievement
of the Act's initial requirements, along with  the advancement  of
programs to achieve subsequent milestones.

     Since these  three areas — construction grants, enforcement/
permits, ana, oi  growing significance, management — have received
primai y agency emphasis to date, their accomplishments  and
further prospects are particularly important  in defining EPA's
water quality program.  These areas are discussed in this

                              A continuing emphasis on
construction grant obligations will be accompanied in
FY 1977 by increased attention to the quality of  grant
management, as described unaer Program Priorities
(Part III, at pages 23 and 25-26, below).   Delegation to
States of major portions of grant-associated responsi-
bilities will also be a continuing major program  objective
Municipal facilities' operational performance will be an
important and distinct concern.  (See page 8, below).

     It is planned that $9.7 billion will  be obligated
for new grants in tY 1977.  A major tederal, State and
local effort in sound program management — from pre-
application through to completion of each  project —
will be required to obligate this sum effectively and
on time. Meaningful delegation of municipal facility
activities to the States will be a critical element
in this effort.  It Congress enacts EPA-backed legisla-
tion providing construction grant funds for State program
administration, substantial, needed resources will
become available to support the States' involvement.
This subject is further considered in Section C.
(Pages 14-16, below.)

     Individual grant tetms must be developed in
coordination with State and Regional water quality
management plans as well as existing facilities plans
to determine cost-effective solutions to achieving
water quality goals.  Grant terms must also be
coordinated with the associated permits, which will
be an important element j.n securing progress in
individual projects.  The FY 1977 priority list
development should emphasize the need tor  good grant/
permit coordination as well as grant/plans

     tor active projects, resources should be applied
to assure expeditious progress and completion of
construction.  hanagemen : of large projects will
receive particular attention:  given the major sums
and impacts associated w th these projects, their
progress will be a major factor in the overall success
of State and regional programs.

           Program.   The National  Pollutant  Discharge
Elimination System consists of compliance monitoring/
enforcement and permitting.  It exemplifies  a  fundamental
philosophical goal—a State/Federal  partnership
carrying out a major facet of water  quality  manage-
ment,  increased participation by  all  States is
the principal goal in FY 1977.

     Compliance monitoring and enforcement.—The NPDES
program initially emphasized the issuance of permits,
since virtually no Federal permits limiting  the dis-
charge of pollutants to water existed  prior  to the
establishment of the program.  With  the issuance
of the bulk of first-round permits,  emphasis shifted
to compliance monitoring and enforcement, focussing
on compliance with construction requirements and schedules
set forth in the permits.  In FY 1977  and beyond,
the enforcement program will concentrate on  achievement
of the effluent limitations required by permits.  The
enforcement program's priorities are described below.
(Part III, pages 23 and 26-27.)

     EPA expects the majority of major industrial
dischargers to complete their construction schedules
and have all necessary equipment operational during
FY 1977.  By the middle of the fiscal  year,  inspections
for priority dischargers with operating equipment
will include sampling to determine compliance with
final effluent limitations and inspection of residuals
disposal procedures and areas.  Given the greater
complexity of this type of inspection, a system of
priorities should be employed, and a sound information
system will become increasingly important.

     Where enforcement actions are needed, they should
be quick and appropriate to the nature of the violation.
As in the past, program effectiveness should be achieved
through the maintenance of reasonable enforcement priorities
and the use of informal enforcement measures where appro-
priate (e.g. , for the less significant violations)
and/or municipal operational and training assistance
wherever possible.  For municipal  sources, enforcement
should emphasize strict compliance with realistic
construction schedules and with effluent limitations
based on operations and maintenance conditions.

     Permits.—For the Permit program the  latter  half
of FY~~T5T7~wi 11 begin a new crest period of  activity,
as initial permits expire and require reissuance.
In preparation for this period, States and EPA must
complete the process of putting enforceable  initial
permits into effect.  Resolution of major  discharger
adjudicatory hearing requests will be a priority

     EPA's early municipal permits strategy  was designed
to allow re-examination of POTW requirements as the
deadline for Phase I compliance neared.  Hence, virtually
all municipal permits—some 20,000 including about  4,000
majors—must be reissued over the next several years,
and a reoriented municipal permit program will be a
primary concern.  The program will be based  on new
legislative or administrative policies regarding  the
statutory compliance data; funding and construction
realities; operation and staffing requirements; residuals
disposal; and the revision and implementation of  a
pretreatment strategy.

     New permits will also be needed for certain  feedlots  and
irrigated agricultural activities, as provided in revised
EPA regulations; mining; new sources (including NEPA
reviews for the Federal portion); industrial reissuances;
and other sources including energy-related permits  (coal
and uranium mining; oil exploration and production).
Permit revisions to take account of toxic pollutant
limitations requirements are also likely.

     Thus, the FY 1977 workload, while not at the peak
levels of 1974 and 1975, will be sizeable.  Delegation
of NPDES programs to States, which should total 33
States by the end of fiscal year 1977, should cut EPA's
direct permit responsibilities to approximately
30 percent of the total effort, but supervision of
State programs will continue to demand a considerable
EPA effort.

     Timely and efficient preparation for  Phase II  is
critical to both EPA and States.  Significant policy
decisions must be made, such as for section 301(c)
(economic relief from BAT) and section 302 (water quality

related effluent limitations).   Increasingly,  permits
will be coordinated with State  and  areawide  plans;  these
may include effluent limitations which,  when approved,
must be reflected in the permits.  The permits
issued during the 1977-1979 period  will  be a principal
determinant of the status of water  quality  in  the

•     Water Quality Management  System.  Designated
planning agencies and,In nondesignated areas, States
conduct detailed water quality  management planning
called for primarily by sections 208  and 303 of the
Act.  This activity is directed toward development
of implementable plans to achieve the Act's  national
goal of water quality, wherever attainable,  that will
support aquatic life and water  contact recreation.
Pursuant to court decision, initial Phase II water
quality management plans must be completed  by  November
1978.  Some of the areawide plans by  designated
agencies should reach initial approval during  FY 1977.

     The goal of the water qua]ity management  process  is
to establish the institutional  framework for State
and local government decision-making  for water quality
management on a continuing basis.  To this  end, key
elements of the planning process are: public involvement;
coordination of resource management with water quality
management; assessment of alternatives;  assignment  of
institutional responsibilities and capabilities;
development and implementation of specific  area programs;
and provision of long-range support for the  process.

     Planning will analyze the  water  quality problems
of the area, identify sources of pollution  and, after
consideration of alternatives,  define coordinated
solutions, including responses to municipal  waste
management needs, target permit conditions,  and non-
point source controls.  The law requires that  permits
and construction grants be consistent with  appropriate
portions of approved plans; nonpoint source  programs
must also include means for implementation.  These
factors underline the importance of sound data and
analysis and timely plan completions.

     Interim and final plan outputs should identify
and address principal water quality management needs  in
accordance with a State/EPA agreement on the timing and
level of detail of the plans.   Determination of non-
point source management needs  must be a major and
integral feature. (See pages 8-9,  below.)   Also, water
quality standards reviews will be  an important early
output  (See pages 10-11, below.)  Other planning
activities are defined by the  revised regulations
(40 C.F.R. Parts 130-131), which provide for flexi-
bility in the development of workable plans.

     Effective State/areawide  communication is essential
during the planning period, to assure development
of plans which will satisfy the State's responsibilities
and needs.  Development of interim plan outputs will
encourage early communication.  At the same time,
EPA and States must continue to recognize that plan
implementation will often be heavily dependent on
local government action. Existing institutions will
be enlisted wherever possible.

     Plans will consider the social, institutional,
economic, and physical t'ade-offs among the alterna-
tive means of addressing existing and potential problems.
Continuing involvement o,. the public and other affected
parties in plan development, including the difficult
judgments to be made, is critical.  A citizen
constituency should be developed to secure ongoing
public support.

     By involving all related  programs and their managers
in a coordinated immediate and long-range approach to
water quality management, plans will assure that  the
activities are carried out in a complementary fashion
to achieve specific, mutually recognized goals.

B.    Additional Program Highlights.

     While municipal facilities management,  permits  and
compliance, and water quality planning  and management continue
to receive principal attention in the national  water quality
program, numerous associated or support areas are also
essential components of the national program.   Various
activities are highlighted in this  section and  described  at
further length in program modules which supplement
this Overview.

     •    Municipal Operations.  Efficient and  reliable
     performance of municipal wastewater treatment facilities
     is the goal of the national municipal operations
     program.  Its achievement calls for a coordinated
     Federal, State, and local partnership.  The States
     and, ultimately, individual localities  have the
     primary responsibilities for wastewater facilities
     operation; Federal overview is necessary to assure
     achievement of statutory goals.

          The program involves interrelationships in a
     broad spectrum of program activities, including permits,
     monitoring, enforcement, planning, grants, manpower
     planning and training, and operational  assistance.
     Direct Federal action, critical  in the  near term,
     should essentially phase out by 1982.

          During FY 77, emphasis will be on  EPA and  State
     operations program evaluations and information  gathering
     along lines identified in guidance developed during  FY
     1976.  This will establish a sound basis for final
     decisions on program changes and specific  actions  to
     be taken during FY 1978 and beyond, when the major
     program-related and resource impacts will  occur.

          Manpower planning and training to  support  to  the
     municipal operations program will  be also  reviewed
     during FY 1977.  This task will emphasize  assessment
     of State and local manpower and training needs  and
     evaluation of existing State programs.

     •    Nonpoint Source Program.  Widespread  imple-
     ment aFronoT~¥TFeTFrv^~norTpo int. source  control  programs

is one of the most important unmet needs confronting
national water quality management.  In the absence  of
adequate nonpoint source programs for  areas having
problems, the Act's water quality goals will not be

     Full scale operation of nonpoint  source planning
and management programs is a major element in State and
designated agency planning under the FWPC Act.   In
FY 1977, a program to assess and manage nonpoint sources
should be operating in all States, including those
which have not previously initiated a  program.   State
and areawide planning processes provide an opportunity
to define specific requirements, including regulatory
programs.  Resources newly available to States under
section 208 will help support this activity.

     The extent of implementation will depend on the
status of existing programs as well as on the new planning
Existing and new nonpoint source efforts should take
advantage of current laws, institutions, and control
programs such as those operated by the U.S. Department
of Agriculture and county soil and water conservation
districts.  Implementation should proceed promptly
where efforts are under way, and all approved plans
should result in some level of specific implementing

     Both the sources of nonpoint pollution and the
means for abatement vary greatly according to local
conditions.  Hence, the States and designated agencies
under the planning process are best suited to address
their unique problems, and local levels of government
will often play a critical role in implementation.
EPA encourages an approach which relies not on after-
the-fact treatment but on employing best preventative
management practices, to be defined for the specific
geographic areas and types of sources.

•     Water Monitoring.  The primary responsibility
for water monitoring lies with State and local govern-
ments, and with pollutant dischargers.  EPA regional
offices provide support through technical guidance  and
management and through field activities needed in

certain regional and national  priority  programs.   A
policy statement on environmental  monitoring,
developed during FY 1976,  defines  EPA's monitoring
goals and objectives.  Each region will prepare a
regional monitoring strategy in accordance with the
national policy statement  and  specific  guidance.

     Quality assurance, to guarantee a  strong  data base
for the national water quality strategy and implementing
programs, is a critical program objective and  a first
level national water program priority.   Good quality
control should result in reliable  data  being produced.

•    Toxic Substances.  Control of substances  with
toxic properties is necessary to safeguard human health
and ecosystem integrity.  In FY 1977, EPA will launch
a major effort to establish appropriate controls on
identified toxic substances. Toxic effluent standards
for a number of industrial categories will be  published
pursuant to section 307(a) of the  Act during the year,
and studies for the inclusion of additional parameters
in effluent guidelines will also be undertaken.

     States and regional offices will re-examine existing
NPDES permits of known or  possible dischargers of  toxic
and other identified substances in the  industrial
categories for which standards are promulgated.

     Permit terms will be  modified as necessary.
Examination of municipal facility performance  will
also be required, to review toxic  industrial discharges
to the facility and to check on the facility's
residuals sludge disposal  program where toxic
pollutants are present in  the sludge.

•     Water Quality Standards and  Antidegradation.
Review of existing water quality standards will
be a priority activity during FY 1977.   State  and
areawide planning provides the forum for the necessary
reviews.  Standards must reflect the FWPC Act's
interim water quality goal where attainable.  At a
minimum, existing designated and actual uses will  be
maintained, except in limited situations, and  State
mechanisms for implementing antidegradation policies

will be established.   LPA intends that the  need  tor
addressing toxic or hazardous pollutants should  receive
special considerations in the standards review.   Tho
State's standards reviews and any icvinions should  br
completed by January 1, 1977, to be available lor
the reissuance of expiring permits and other
control measures.

•    State Programs.  EPA will continue to  provide
financial support for State programs which  provide
a State water quality management strategy,  an orderly
annual program and periodic evaluations and reports
to EPA.  Reporting is conducted pursuant to the  Formal
Planning and  Reporting System, an integrated reporting
system for the regions and States.  Decentralization
will remain a major emphasis permeating all aspects
of the Federal/State partnership.  EPA will continue
to seek solutions for the ever-present problem of
adequate State program funding.

•    Effluent Guidelines.  Effluent guidelines will
be reviewed during FY 1977 in accordance with a  priori-
tization of industrial categories developed during  the
winter of 1975-1976.  The reviews will be a coordinated
examination of all control requirements for the
category, including best available treatment regula-
tions, pretreatment standards and new source performance
standards.  Where necessary, promulgated limitations
may be altered.

*    Discharge °£ Dredged or Fill Material.  By the end
of FY 1977, coverage of the Corps of Engineers'  permit
program for discharges of dredged or fill materials
will have expanded to match essentially EPA's juris-
diction over all "navigable waters," and all sources
discharging dredged or fill material to such waters
will be required to obtain a section 404(a) permit.
A system of general permits will eliminate the need for
individual permits for minor discharge sources.
EPA's role will be substantial.  After improving
the section 404(b) guidelines, the agency will
conduct permit application reviews, including field
site inspections; provide advanced identification of
potential disposal areas; exercise its power to

prohibit proposed disposal  sites  where  the  discharge
would have an unacceptable  adverse environmental
effect; and supply enforcement coordination and assis-
tance in important cases.

•    Oil and Hazardous Materials.  The  elimination of
spills is the primary long-term objective of EPA's
oil and hazardous spill control program.   FY 1977
should include a fully operational oil  pollution
prevention and control program emphasizing  continued
response to major oil spills, and medium  and minor spills
as required.  A hazardous  substances response capa-
bility should be initiated  following promulgation of
implementing regulations,  using new field methods and
techniques for responding  to hazardous  substance
spills.  This will necessitate major revision in
FY 1977 of the National Contingency Plan  and of
regional, sub-regional, and State plans.

*    Clean Lakes.  With additional funding becoming
available ($15 million for  FY 1976), the  clean lakes
program will expand substantially and emphasize
improvements in State restoration proposals and
implementation of approved programs.

•    Ocean Disposal.  All  permitting under the Marine
Protection, Research and Sanctuaries Act  must be  con-
sistent with the International Convention on the
Prevention of Marine Pollution by the Dumping of
Wastes and Other Matters (effective August 1975).

     The number of applications for Marine Protection
Act permits may increase during FY 1977,  because  such
permits are required for the df>positing of off-shore
oil drilling mud.  EPA expects to issue a general permit
for these cases, to be implemented by the regions
pursuant to guidance.  The number of ocean incinera-
tion permit applications may al.so increase.  If new
"burn sites" are to be designated, EPA will need  to
conduct additional baseline suiveys of potential
disposal sites.  Additional moritoring will also  be
required, to determine any air or marine  effects  of the

     Finally, EPA will place considerable emphasis
during FY 1977 on encouraging permittees  to seek
alternatives to ocean disposal.

•    Marine Sanitation.   The marine sanitation program
will proceed on the basis of revised regulations
published January 29, 1976.   States continue to have  the
authority to establish "no discharge" areas, subject
to approval by the Administrator; regional ofiices
will be increasingly involved in evaluation of State

•    Research and Development.  Reserch and Development
programs for water will give priority attention to
health and ecological effects, in support of the
Agency's efforts to control harmful or dangerous
substances in water.  Significant efforts will also
be directed to the industrial processes effort, in
support of EPA's effluent limitations development and
reviews, and to the identification of improved
management techniques for the reduction of nonpoint
source pollution.

•    Ground Water.  Efforts will continue toward  imple-
mentation of a coordinated Federal and State program
for the protection of ground water resources, employing
the permitting and other authorities of both the
Federal Water Pollution Control Act and the Safe
Drinking Water Act.

•    Small Business Loans.  EPA will review loan  assis-
tance applications to determine the necessity and
adequacy of the proposed construction.  States are
encouraged to assume or participate in program responsi-
bilities.  The demand for loans is expected to increase
with the introduction of pretreatment requirements.
Reviews should be expeditious, so as not to impede
discharger compliance.

•    Federal Activities.  Environmental reviews will  be
increasingly integrated into early construction grant
planning; section 208 areawide planning may help  pro-
vide analyses for these reviews, if resources permit.
They will also be conducted for new source NPDES  permits,
municipal facility construction grant awards and  selec-
tion of ocean dumping sites.  EPA retains responsibility
for monitoring all Federal facilities' NPDES compliance.

     Ihe lis-t of  polluting  industrial  facilities  ineligible
     for certain  Federal contracts,  grants  and  loans  pur-
     suant to E.G.  11738 will  be  in  effect.

c-   Major Objectives and Concerns.

     A number of  objectives and concerns  cut across
individual water  quality programs.   The extent  to which
particular programs are affected by  these broader issues varies
with the program and the subject;  however,  they generally
constitute areas  of importance to the  overall national

     •    Program Decentralization.   Decentralization of
     the operational functions of t le  water pollution
     control program remains a high  management  priority.
     Expected resource limitations in  FY  1977 are
     likely to restrict i-he capacit/ of States  to assume
     the responsibility ior further  delegations of
     major program functions (e.g. ,  NPDES)  or subfunctions
     (e.g. , plans and specifications review), unless
     legislation embodying the Cleveland-Wright concept
     (below) is passed.  However, informal  delegations
     (e^g. , drafting or certifying permits) should
     continue to be possible.

          Additionally, much can be  done  to reduce or
     eliminate duplication of effor ; between States  and
     Regional offices.  For example, in cases where
     Regional offices are reviewing  every permit  issued
     and every plan and specification, even where these
     functions have been delegated,  consideration should
     be given to spot-checking only  a  certain percentage
     of the State's work.  Regional  office  resources
     which become available through  elimination of
     duplication should be assigned  to other priority

          The annual development, by States and Regional
     Administrators, of State and regional  strategies and
     programs should specifically indicate  the  extent of
     the responsibilities and authorities that  the States
     and EPA accept in each program  area  and the  Federal
     support that will be provided.   This will  provide  a
     mutual understanding of the extent of  State  involve-
     ment agreed to by the region and State.

     Regions should assure that States are  provided
with real program authorities,  not merely work
assignments, and that they may  exercise their
authorities with a reasonable degree of independence,
subject to appropriate output reporting and program
evaluation.  To this end, it is highly important that
regions work to assure that every State has the basic
management capability that is essential for the proper
administration of an expanded water quality management

     Many States have already assumed administration
of the NPDES permit system.  Further efforts toward
increased State responsibility  should be emphasized
in the areas of:  construction  grant administration;
municipal facilities operations evaluation and
assistance; enforcement (which  States assume as to
State-issued permits when they  receive NPDES authority);
compliance monitoring (for which States, local govern-
ments and pollutant sources have the primary responsi-
bility); and small business loan applications.
Effective execution of these responsibilities will
be stressed.

     By the end of FY 77, EPA hopes that for each of
the significant operational areas (other than the ocean
disposal permit program under the Marine Protection
Act and the oil and hazardous substances programs,
which are not delegable to the States) a majority of
the States will have assumed the fundamental responsi-
bility for the conduct of the program.  This goal,
of course, is Dependent on the States' willingness
and capability, which may depend in turn on their
receiving sufficient funding resources.

     Thus, budget constraints at the the State and
the Federal levels may limit decentralization goals
in FY 1977.  However, enactment of pending legislation
that would make a portion of Federal construction
grant monies available to States for their administra-
tive costs in that program (the Cleveland-Wright concept)
would help ansv er State resource needs not only in
that program bi t in other areas of State water quality
management to \ hich State-generated and section 106  funds
may be redirected within a State water pollution control
agency.  In addressing resource needs for manpower
development and training, the Federal/State vocational

and post-secondary education systems  should  be  used  to
the maximum extent possible.

•    Public Participation.   Effective public participation
in water quality management is an important  aspect
of Federal, State and local activities.   EPA encourages
States and local agencies to develop  mechanisms
for workable community involvement.   For  example, State
or local advisory committees are to be established for
each 208 planning area.   These committees should  include
appropriate local elected officials and representatives
of Federal, State and local agencies  as well as other
individuals and groups.   In this way, the views and
suggestions of all interested persons can be taken into
account in the plan's formulation before  major  decisions
are cast.  The potential major impact of  these  plans
makes this ongoing involvement critical to program

     The FWPC Act calls for public participation  in
essentially all programs under the Act.   EPA has  promul-
gated regulations to implement this directive.  While
program exigencies have at times overshadowed this
activity in the past, increasing attention to in-
volving the public must be integral to every program's

     Constructive participation can benefit  all parties.
It will help assure decisions which reflect  the
community's concerns, and it will also enhance  the
public's appreciation of the factors  leading to those
decisions.  An openly developed, responsive  water
quality management program should enjoy the  public
acceptance and support which is critical  to  its success.

•    Outstanding Issues.  As EPA and  the  States attempt
to implement the FWPC Act, complex issues continue
to arise.  Major policy areas yet to  be resolved  include
the application and procedures of the economic
capability and cost-benefit provisions of sections
301(c) and 302, delineation of a sound pretreatment
program, an appropriate national control  program  for
all toxic substances, and issues regarding funding
for State activities.

     Meeting the deadlines that confront EPA,  States,
localities, and private parties will require ongoing
attention.  Particularly where activities are inter-
dependent (e.g., terms of permits based on completed
waste load allocations based in turn on revised water
quality standards), the initial effort must be timely
in order for the subsequent event to proceed on

•    Examining program results.  FY 1977 will mark
the fifth year of operation under the 1972 Amendments
to the FWPC Act.  The progress to date and remaining
problems are documented and analyzed in numerous EPA
reports, the State water quality reports under
section 305(b), the report of the National Commission
on Water Quality and in private analyses.

     If any consensus is to be found, it is one of
a mixed accomplishment.  Trends observed in some water
quality parameters in some waters indicate that
substantial progress is occurring, and priority programs
are beginning to show results as pollution abatement
facilities begin operation and important regional
analyses are completed in preparation for further
water quality management decisions.  At the same time,
however, in some cases the Act's near-term deadlines
will be missed, and draft National Commission on
Water Quality reports predict that delay in achievement
of the 1977 requirements may lead to delays in the
achievement of the 1983 requirements as well.  Con-
tinuing inadequate performance and other operational
problems in many municipal treatment facilities
will also seriously hinder attainment of water quality
goals.  Furthermore, the costs and impacts of meeting
statutory requirements are in many cases significant,
and local impacts can at times be severe.

     These factors may be taken into account by Congress,
which maintains a continuing review of the implementation
of the national water quality program.  EPA's  legis-
lative program and reports of the National Commission
on Water Quality will receive particular attention.

D.    Legislation.

     The 1972 Amendments to the Federal Water Pollution
Control Act create a comprehensive water quality protection
program cased on technology-based effluent limitations coupled,
where necessary, with water quality based controls.   Experience
with implementation of the Act has affirmed the basic soundness
of this overall approach.  Nonetheless, given the stringency
and complexity of the Act's multiple mandates, a series of
adjustments inevitably becomes necessary.

     Several amendments were proposed or supported by EPA
last year (FY 1976 Overview, pp. 6-7).  If enacted,  they
will authorize certain municipal aci valorem tax systems
(section 204(b)(l)), revise section J07(a) procedural re-
quirements, change the State water quality reports under
section 305(b) from annual to biennial, and provide support
for State construction grants administration (see Program
Decentralization, Part 3, above).  Later in 1975, EPA
also proposed an amendment to allow judicial review of
effluent guidelines directly in the U.S. Court of Appeals.

     In January 1976 EPA transmitted to Congress addi-
tional proposals to bring the total Federal share of eli-
gible construction grant needs within reasonable reach of
Federal budgetary resources and to provide needed flexi-
bility in municipal facilities compliance requirements.
These proposals would:

     •    Reduce funding percentages for combined
     sewer  overflows from 75% to 60% and eliminate
     eligibility for most storm sewers, major sewer
     rehabilitation or replacement, and new collection

     •    Eliminate the eligibility of reserve capacity
     for future growth.

     •    Limit Federal funding of treatment levels
     more stringent than secondary to the amount shown
     essential to achieve the objectives of approved
     water  quality standards or ocean discharge guide-

     •    Allow case-by-case extensions of municipal
     facilities' compliance requirements to up to July 1,

    -EPA reviews possible additional  areas  for  legislative
action on a continuing basis.   Information  developed  in
the next 305(b) water quality  report  and recommendations
of the National Study Commission pursuant to section  315
of the Act will receive particular  attention.

     That issues are under consideration does not mean that
EPA will necessarily conclude  that  legislation  is needed.
The Agency conducts an environmental  impact review in
connection with its legislative proposals and certain pro-
posals introduced by others.  These comments help deter-
mine the need for and effect of the possible amendments.

III.    PRIORITIES fOR F¥  197 7_
       NOTE:   National,  Regional,  and  State  water
       quality program priorities  are highlighted                    i
       here to provide overall  program  perspective.
       Detailed Regional  and  State  priorities
       are established in EPA annual Regional
       Operating Guidance.

     The following priorities among and within  program areas         *
for FY 1977 form a general  framework  in assigning  national
program resources.  (See  Table  I,  pages 21-22,  below.)
Individual Regional Office  and  State Agency priorities will
differ somewhat because of  localized pollution  control problems,
varying resources and capabilities, and because certain national-     -
level programs may not require  equally  large-scale efforts
in all Regions or States.  Specific agreements  on  program
priorities, outputs, and  resource  allocations will be  made
in the preparation of Regional  Office and  State Agency
FY 1977 program plans.

     The results of the annual  program  planning process should
be consistent with, but need not mirror, national  priorities.
The most important element  in any  water pollution  control
program is that it be balanced.  Resources should  not  be
exhausted on selected program areas,  leaving  other priority
areas without coverage; neither should  they be  spread  so             «
thinly as to negate program effectiveness.                        ""*

     Achieving the necessary balance  year-by-year  as well as
over the long run requires hard priority decisions.  For
some EPA program areas, States, and designated  agencies,
money is not available at desired  levels to carry  out                 4
effectively all the program efforts and responsibilities under
the Act.  In other instances, jt is taking time to bring
additional personnel and resources to bear.  Near-term
requirements will not all be Achieved by all  parties all
at the same time.  However, the Agency  believes that
through a proper emphasis on priorities and an  effective,            9
decentralized management system, goals  in  critical program
areas can be achieved within a  reasonable  period.

     EPA is aware of the pressures on State revenues and
the States' difficulties in funding their  programs at  desirable
levels.  State assumption of greater  program  responsibility           f
may therefore be heavily dependent on additional Federal funds,

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                            i    S



such as those that might become available under  proposed
legislation.  Nevertheless, the States as full  partners
in a national water quality management and broader  environ-
mental protection program must take responsibility  for
assuring that needed priorities are maintained  relative  to
other concerns of State and local government.   The  annual
State program planning process, carried out in  conjunction
with EPA Regional Office program planning, requires pro-
vision for citizen participation in making these decisions.

A-   Priorities Among Program Areas.

     1•   Priorities for State and Regional Actions.

     The major program priorities for State and  Regional
action during FY 1977, summarizing the Operating Guidance
and outlined in Table I, are:

     •    Construction Grants.  Highest priority in FY  1977
     is to complete development of sound program management
     procedures at the EPA Headquarters, Regional Office
     and State levels, in conjunction with increased shifting
     to the States wherever possible. Only through  effec-
     tive management of the program at all levels will
     timely, cost-effective and environmentally  sound use
     of municipal construction grant funds be assured.
     Early starts on environmental assessments  by potential
     grant applicants are emphasized.

     •    Permits, Compliance Monitoring and Enforcement.
     The NPDES program for major dischargers,  including
     Federal facilities, as the FWPC Act's principal pro-
     vision for assuring implementation of high-impact
     point source control requirements, continues to be  a
     first level water quality program priority. Monitoring
     and enforcement of final effluent limitations  is an
     increasingly important component.

          EPA program priorities emphasize continued enhancement
     of the State role in all program aspects,  along with
     implementation of an Enforcement Management System.
     EPA responsibilities in relation to Federal facilities
     compliance are stressed, however.  The need for Environ-
     mental Impact Statements or negative declarations
     on all new source permits is also highlighted.  National
     priorities, which implicitly include the program
     priorities, are set forth at pp. 26-27, below.

     •    State and  Areawide  Water Quality Management Planning.
     FY 1977 priority I  is  given^both  tHe State ancTaTeawiae
     water quality management program  under section 208,
     including completion of  current efforts, water quality
     standards reviews,  and implementation of plan outputs.

     •    Monitor ing. Aspects of water monitoring that
     support other programs share the  priorities  of those
     programs.  Development of State monitoring programs
     as detailed in  Appendix  A of the  State program
     regulations (40 C.F.R. Part  35) is given a stronger
     priority in FY  1977, particularly as necessary to
     support other first priority activities with reliable
     stream and/or effluent data  and analysis, and to
     document water  quality improvements.

     Second level  FY 1977 priority  is  assigned to:  municipal
operations and manpower  planning/training activities; oil and
hazardous spill response and  contingency planning programs;
non-NPDES water enforcement;  Federal interagency  coordination
in support of the  water  quality management program; ocean site
EIS preparation and  ocean disposal  permits;  implementation
of EPA's responsibilities regarding permits  for the discharge
of dredged or fill materials; and State or Federal reviews
of applications for  small business  loan assistance.  Related
aspects of water quality monitoring ace included.

     Third level FY  1977 priorities for State/Regional pro-
grams relate to minor discharger  permitting, compliance
monitoring, and enforcement;  oil  and hazardous spill
prevention and control program activities; certain technical
studies and support  activities (e^g.,  dealing with Marine
Sanitation Device Standards and aquaculture  projects),  the
Clean Lakes Program; and advising dischargers of  the availa-
bility of SBA loans.

     It is expected  that the principal national water quality
program priority activities for States and regions—municipal
facilities management, compliance monitoring, enforcement  and
permitting, and water quality management  planning—will  generally
receive State priorities and share  in  the available funding
in proportions commensurate with  their national and Regional
importance.  However, individual  Regional Offices, States  and
areawide planning agencies  will determine  the specific  FY  1977

balance of program priorities and funding levels  required  in
each State and among its localities.

     2.   Additional National Program Priorities.

     In addition to the Regional/State priorities identified
above, EPA headquarters will focus special attention on the
following areas:

     •    TOXJ.C and Related Substances.  A strengthened
     program to control pollutants Raving toxic character-
     istics is a new first priority at the national
     level, to expand EPA's effort in protecting  human
     health and ecosystem integrity.   For FY 1977,
     emphasis will be on promulgating and beginning to
     implement toxic pollutant discharge standards  for
     industrial categories.  Studies and analyses leading
     toward inclusion of other substances with toxic
     characteristics into selected effluent limitations
     guidelines will commence.

     •    Research and Development.  First level  national
     water program priority will include research and
     development activities in the area of human  health
     and ecological effects.  Industrial process  and
     nonpoint source management technologies are  second
     priorities.  Activities concerning the ecological
     effects of pollutants associated with energy systems
     and monitoring and technical support efforts,  while
     lower in priority, are also considered important
     aspects of the program.

B-   Priorities within State and Regional Program Areas.

     •    In construction grants/ activities related to
     sound, effective management include State develop-
     ment of project priority lists and project schedules,
     with active Regional Office and State efforts  to
     be sure that lists and schedules are used to manage
     the program more effectively.  To this end,  resources
     should oe concentrated on pre-application assistance
     and post-grant award activities to assure that
     work begins promptly and schedules are maintained.
     This will include close coordination of the  grants
     program and permits, compliance monitoring and
     enforcement activities.  Emphasis will be given

to larger projects of high potential  impact.   Sound
environmental assessment will also be stressed.

     The coordination of planning activities  under
sections 106, 201, and 208, as well as priority  list
development and the Needs Survey, should be high
management priorities.  Full State partnership in
program administration will be encouraged.  Work on
the FY 1976 needs survey must be concluded  by February
1977, and initial work on the FY 1978 needs survey,
for submission to Congress early in 1979, must commence.

•    Permits, Compliance Monitoring and Enforcement.
One of the most important program goals for FY 19?7  is to
promote increasing State participation in the NPDES
program by all States and to develop further  the
capabilities of the States to carry out their program
responsibilities in a manner consistent with  the
requirements of the FWPCA.

     Every effort must be made to respond appropriately
and expeditiously to all violations.  Implementation
of a streamlined Enforcement Management System will
provide improved guidance and assistance to the
Regions and States as well as more effective  management
of the national compliance and enforcement  program.

     Assuring the completion of facilities  by major
industrial dischargers to meet BPT and WQS  will be
water enforcement's other primary national  priority.
This will include the resolution of all pending
adjudicatory hearing requests by major dischargers
and strengthened compliance monitoring.  Also among
the highest priorities is the compliance of major
municipal facilities with permit conditions,
especially as permits are made fully consistent
with State project priorities and the funding capa-
bilities of the Municipal Construction Program.

     Non-NPDES compliance and enforcement,  concentrating
on oil spills, spill prevention, and Ocean Dumping Act
enforcement, are of second priority emphasis.  Minor
discharger compliance ranks third priority.

     Highest permit issuance priority during  FY 1977
is directed to reissuing expiring major municipal

and other permits consistently with new Municipal
Construction program policies, pretreatment
requirements, and with approved plans developed
by the States and areawide agencies under section  208.

     EPA issuance of permits for discharge from  oil  and
gas operations on the Outer Continental Shelf will
be an increasing activity as the Department  of the
Interior continues its accelerated leasing program.
Third priority is assigned to issuance, reissuance,
or modification of minor discharger NPDES permits.

•    State and Areawide Water Quality Management.  The
highest priority in the water quality management process
is the completion of initial State and areawide  programs,
particularly those which have been under way for some
time.  Specific priorit es are to be established
by the individual State and areawide agencies on the
basis of particular water quality objectives, problems
that can be solved by the water quality management process,
and the institutional setting. Nonpoint as well  as point
source controls will be included to the extent appro-

     Both States and designated agencies must employ
adequate business management and other fiscal manage-
ment procedures.  Within designated areas, special
emphasis will be given to establishing a decision-making
framework within existing institutions.  Effective
EPA and State review of plans and overall program
analyses will be required.

•    Monitoring.  EPA and State Monitoring activities
in support of other programs carry the priorities
associated with those programs.  Within the monitoring
program, quality assurance efforts have highest emphasis.
Quality assurance includes continued evaluations of
State laboratories by performance checks; more detailed
review of the States' monitoring strategies, in-
cluding a first effort to define the States' rationales
for monitoring on a basin-by-basin basis; and correction
of identified deficiencies.  The State's monitoring
strategy, quality assurance efforts, and data transfer

agreements are components of  the  section  106  regula-
tions (40 C.F.R. Part 35, Appendix A),  and  an
approved State Monitoring strategy is considered
essentia-1 for State Program grant approval.   Imple-
mentation of Appendix A will  be coordinated through
State and Regional Office monitoring strategies and
EPA Office of Research and Development  quality
assurance procedures.

     Other significant FY 1977 monitoring program
activities are operation of the National  Water
Quality Surveillance System (NWQSS) and publication
of analysis of NWQSS data; preparation  of improved
section 305(b) reports; and improving the management
and operation of STORET, including clean-up of data.
The State Water Quality Inventory (§305{b)) report
to Congress will have special significance since
Congress may be reviewing the entire FWPCA in
the 1977-78 session.

     Throughout all monitoring priorities during
FY 1977, consideration will be given, where applicable,
to monitoring raw drinking water quality  as well as
general ambient water quality, to help assure coordina-
tion between Water Quality and Water Supply
program activities.

•    Municipal Treatment Facility Operations and Training,
Highest priority will be given to increasing the
level of State operations and maintenance (O&M) related
activities, particularly to evaluate and  document
operating problems of existing facilities. Emphasis
is also given to evaluating current operations and
training related programs against expanded Federal
objectives  and  to examining needs  in the area of State
and local statutes and ordinances. State and local
municipal operations program planning and budgeting
procedures  should also be reviewed and, if necessary,

     Sharing  high priority will be an effort to en-
courage  the States to assess treatment facility
personnel needs, adopting recently tested EPA metho-
dologies .

     •    Oil  and  Hazardous  Substance  Spill  Prevention
     and  Control.   Highest priority  in FY  19*71  is  assigned
     to response actions  relating  to oil and hazardous
     substances spills and contingency planning.   Spill
     prevention through the  preparation ot  plans  receive.".
     lower priority for FY 1977,  though elimination  ot
     spills remains the primary long-term  objective  ot
     the EPA program.   The development of  a hazardous
     substances spill  response capability  and a hazardous
     substances spill  prevention program will be  initiated
     in FY 1977. Both  have high priority.

     •    Permits  for  the Discharge  of Dredged  or  Fill
     Materials^Program priority will be  given to assuring
     that the issuance of general permits  is well  under
     way and that  review of  individual permits  and Corps
     projects is well  established.  EPA will concentrate
     on improving  the  quality of the system to  protect
     wetlands and  other sensitive areas, for example by
     carrying out  capacity surveys,  emphasizing sound
     pre-permit planning, and promoting public  education
     to help move  development pressures away from wet-
     lands .

     •    Ocean^Dumping.  Priority is  given to  preparation
     of ocean site EIS's and review  of applications  and
     issuance of ocean dumping permits. Both ocean
     incineration  and  depositing of  drilling mud  by  off-
     shore oil operations are expected to  require increased
     permitting and monitoring in FY 1977.

     •    Small Business Administration Loans.  The  small
     business loan program will concentrate on performing
     technical reviews of applications for  subsequent
     determination by  the Small Business Administration
     for financial eligibility.  Assumption by States
     of this responsibility  will be  emphasized. Promo-
     tion of the program is  a lower  priority.  No major
     commitments of manpower should  be needed for the SBA

3.    Regional Priorities.

     States and regions may  need to  establish additional
priorities that address local geographic or other problems
unique to their area.   The following activities have been
identified by Regional offices as receiving focus in 1977:

Region I.

     The lakes of New England constitute a  signifi-
cant economic and environmental resource.  The  New
England States in cooperation with local governments
and regional EPA staff will be developing the
framework for sound lake restoration and preserva-
tion efforts, including through the use of  section  314
of the Act.

     Combined sewer overflows constitute a  significant
deterrent to reclamation of water uses in many
major river basins in New England.  The control of
combined sewer overflows will constitute an important
regional priority for facilities grants and permit

     The effective operation and maintenance of
wastewater treatment facilities is the cornerstone
of the regional water pollution control effort.
Federal/State programs providing technical  assistance
and guidance to local communities will be intensified.

     Sludge and septage disposal constitute an
increasingly complex problem in the region.  Efforts
to find  appropriate solutions will be encouraged,
particularly through research and demonstration

     The foundation of a national clean water program
is action by local governments and private industries.
Efforts  will be made to increase local and private
understanding of their responsibilities under the Act
through  education programs developed in cooperation
with the States.  In addition special efforts will
be made  to encourage and support river constituencies
throughout the region.

     Increased emphasis will be given to development
of industrial pretreatment programs by local govern-
ments, including an adequate information base and
required regulatory programs.

Region II.

     Ocean disposal of pollutants is a significant  area
of concern in Region II and will continue to be the

subject of  a large regional  program.

Region Ijl.

     Region III will give special  priority to  the  Chesapeake Bay
Study and to issues related  to waste  water treatment  in  the
Washington, D.C. area. Furthermore,  the national NPDES priority
emphasis on major sources will be  supplemented with attention  to
the problem of coal mine drainage  from both active and abandoned
"minor" sources, given the significant cumulative  effect of  this
pollution.  Minor coal mine dischargers will share  priority NPDES
attention;  also, abandoned mine drainage will  receive equal
priority with urban area nonpoint  sources in Phase II planning,
including Statewide 208 funding.

Region IV.

     The expanded program under 5"WPCA section  404, discharge of
dredged or fill material, will receive a high  level of attention
in Region IV, especially with regard  to Corps  of Engineers pro-
jects and construction grants. The region's geographic character-
istics (extensive coast line, etc.)  will give  rise to a  large
number of 404 situations.

Region V.

     Region V will emphasize the Great Lakes Initiative  program,
the focus of agency activities on  the Great Lakes  undertaken to
recognize the high priority  of this unique national water resource,
and in response to the U.S./Canadian  Great Lakes Water Quality
Agreement of 1972.

     In addition to the ongoing regionwide programs in support of
these high priority national and international responsibilities,
the Regional program for FY  1977 will emphasize:

     •  Funding and technical support for study of the Upper Great
Lakes under the aegis of the International Joint Commission.

     •  Funding and technical support for study of pollution from
basin land use under the aegis of  the International Joint Commission

     •  Funding and technical support for International  Joint  Com-
mission Water Quality Board  activities, and, as appropriate, for
Great Lakes Research Advisory Board.

     •  Supplementation of Great Lakes Water Quality  Surveillance


     This section relates the  various  program  activities
discussed in this paper to the time  requirements of the
Act.  This sequencing is summarized  by the  flow chart on
page 33.  The final objective  in the sequence  is to
achieve the Act's 1983 water quality goals.

A.    General Phasing.

     The Act targets two dates,  July 1977 and  July 1983,  to
serve as major mileposts.  There must  be achieved by each
date a national base level of  technological control. In
addition, by 1983 the Act provides as  a goal for the achieve
ment, where attainable, of a general level  of  water quality
in the country that will protect aquatic life  and allow
water contact recreation. In 1977, applicable  State water
quality standards are to be met. EPA has determined that,
generally, these water quality standards should provide  for
recreation on the water and protection of aquatic life.

     The period 1973-1977 is generally referred to as
Phase I of the Act's implementation, and 1978-1983 as
Phase II.  The distinctions between Phase  I and  II are
sometimes blurred, especially  in programs which are not
geared to the cycle set by the issuance of  permits.  These
include areas of research, enforcement, ambient
monitoring, and prevention of  and response  to  unique or
accidental spills.

     •    Phase I has emphasized the issuance  of permits
     and the award of needed construction grants.  These
     two activities will be a  major factor  in  efforts  to
     achieve the 1983 goals:  for some sources,  achieving
     the 1977 requirements will be all that is necessary
     for 1983.  Most of the pollution  problems addressed
     in this phase have been well identified and,  compared
     to many of the problems which will remain,  are
     readily correctable.  Much of the Phase I effort
     proceeds from the work of the States  and  the
     Federal Government in past years.

     •    Phase II will be a period when goals become
     more controversial, solutions more subtle and  the
     alternatives for abatement more conflicting.   It
     will demand a better understanding of  the cause-
     effect and cost-benefit relationships  between

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     objectives and results.   This  will  be  the period
     for implementing most of the programs  for controlling
     nonpoint sources and the more  difficult  point
     sources of pollution, including toxic  pollutants.
     A solid start toward addressing these  problems  has
     already begun during Phase I.

     Work toward installation of best practicable  technology
and secondary treatment in accordance with  permits and
construction grants is proceeding.   While it  is  recognized
that for some sources, particularly municipal plants, achieve-
ment will be delayed past the Phase I statutory  deadline,  this
slippage in timing should not be allowed to obscure  the
real accomplishments that will be occurring.

     Indeed, it has been suggested  by the Staff  Draft
Report of the National Commission on Water  Quality (November,
1975) that compliance with Phase I  effluent limitations  may
frequently result in water quality  conforming to the 1983
interim water quality goal, or produce conditions  where  the
non-attainment of the water quality objectives  is  due more
to nonpoint source pollution or combined or storm  sewers
than to inadequate traditional point source controls. Based
on this suggestion—which may be subject to a number of
questions, including the extent to  which toxic pollutants
are adequately controlled by Phase  I technology—it  has
been further suggested that, in the absence of a Oirect
water quality justification, the installation of the higher
technology levels or alternative control techniques  of Phase  II
may in some cases amount to costly  expenditures  with little
corresponding benefit.

     Such a finding, if verified, might argue for  certain
refinements of priorities. Thus, point source control  resources
might be concentrated, in these situations, on  evident areas
of need—the geographic areas having known current water
quality problems or anticipated growth which  may result  in
such problems and the specific parameters,  wherever
occurring, that pose a particular threat to human  health
or aquatic ecosystem integrity--and a strengthened nation-
wide nonpoint source control program might be given  a high
level of attention.

     At the same time, the complexity of these questions
argues for caution.  The lack of scientific certainty
clouds the definition of "good" water quality;  an  ongoing

research program will  provide continuing  reassessments
of current information.   Further,  if  shifts  occur  in
the public's expectations and desires as  to  the  uses of
the nation's waters, these should  also be taken  into account.

     The fundamental issues which  are coming to  the  toie  as
the close of the first phase of activity  under the 1972
amendments is reached merit the attention of EPA,  the
Congress, and the public.  EPA will continue to  review  the
mix of program priorities in the light of the problems
likely to be present in the early 1980's  and beyond.
Specific program emphases may shift should analyses  indicate
that changes are warranted, hut in any case, EPA's Phase  II
program sequencing will cont nue to seek  the orderly
coordination of water quality management  activities  to
implement the FWPC Act and related laws and  to reflect  an
abiding concern for the protection of human  health and
aquatic ecosystems.

     The Act contains the further  goal of no discharge  of
pollutants by 1985.  EPA foresees that universal achievement
of the "no discharge of pollutants" goal  by  1985 may not  be
feasible or environmentally desirable, given the possible
impacts of such a goal on energy use and  on  the  non-water
environment.  Indeed, for the 1983 ambient water quality
goal as well, the present interpretation  of  the  legislative
caveat "where attainable" recognizes that prohibitive
background conditions could result in a failure  to meet
the 1983 "fishable/swimmable" goal in some waters.  However,
EPA does not intend that correctable point or nonpoint  source
pollution be the prevailing reason for any nonachievement.

B*   Phasing in Specific Program Areas.

     Water Quality Analysis and Setting of Standards.—During
Phase I, State water quality analysis and planning has
concentrated on classifying segments as to water quality,
analyzing the problems, and targeting solutions.  Attention
has focussed on the "water quality limited"  segments—those
in which compliance with the Act's technology-based  effluent
limitations guidelines and standards is not  sufficient  to
achieve water quality standards.  In the  latter  portion of
Ph^se I (fiscal years 1976-1977),  the State  effort is
bef|ng assisted by designated planning agencies.

     In the Phase II program,  water  quality analysis  and
segment classification will reflect  the 1963 water  quality         _^
goals, as embodied in water quality  standards which define          _
those goals or in the water quality  criteria published under
section 304(a), and the impact of second phase technology-
based requirements.  The classifications will take  into
account nonpoint source impacts.

     Water quality standards for Phase II will reflect             4
attainable water quality, including  the 1983 goal where
attainable.,  Standards will at a minimum reflect all
actual and designated uses except where background  or
irreversible man-induced conditions  preclude a
designated use or substantial and widespread socio-economic
disruptions would result from implementing the standard.             4
All existing beneficial uses will be protected.

     The State and designated agency planning activity
determines the total maximum daily load of pollutants
which may be added to the segment without violating
standards, and allocates the load among present and future          J
sources of pollution.  Increasingly, alternative solutions
for meeting the total load limit, and the social,
economic, and environmental effects  of these solutions,
will be considered.

     Achievement of Phase II water quality standards  may
require stringent point source effluent limitations and/or
nonpoint source controls.  Where needed point source
limitations exceed technology-based  or water quality
standards-based limits, section 302  may be involved prior
to their imposition.  Conversely, if the 1983 technological
limitations and basic nonpoint source control should  be
sufficient to reach planning goals,  base level technological
limits will be employed in writing permits.

     Permits, Compliance Monitoring  and Enforcement.—Permits
have been issued as rapidly as possible during Phase  I to
set compliance with the 1977 requirements.  By law, no
permit term exceeds five years.  Upon expiration, a second
round of permit issuances will occur to set compliance
with the 1983 requirements.  This will be a major activity
during Fl 1977-79.  Increasing State participation will
occur, but substantial Federal involvement and assistance
will continue to be necessary.

     For industrial point sources,  the tirst  round ot
permits was based on effluent regulations describing oost
practicable technology tor many major industrial  cateooi ic?,
or on the basis of water quality analyses in  water quality
limited segments.  Additional data and more complete,  and
in some cases revised, effluent guidelines will be available
tor the second phase of permit issuance.  Completion ot
areawide planning will contribute importantly to second
round permit terms.

     Permit issuance in Phase II is likely to become increas-
ingly complex.  For Phase I, the point source effluent
requirements of section 301(b)(l) were absolute.   For
Phase II, on the other hand, the Act reflects an apprecia-
tion that greater uncertainties surround the  more stringent
waste treatment mandates of section 301(b)(2).  Accordingly,
section 301(c) provides for modification of BAT require-
ments, within certain limits, on economic grounds; and
section 302 provides that the Administrator may impose water
quality based effluent limitations, again subject to
certain statutory conditions, where he determines that
discharges consistent with base level Phase II effluent
limitations would interfere with water uses.   A major
task facing EPA is to assure that the flexibility provided by
these provisions will be exercised, with appropriate
State involvement, to issue Phase II permits  that impose
reasonable, just, and sufficient effluent limitations.

     Compliance monitoring and enforcement will be a major
focus of the permit program during Phase II,  to assure that
the permits' potential for water quality improvement will
be realized.  As the number of permits issued and hence
enforced by the States increases, EPA will focus on the
severe violations which present more complex  enforcement

     Municipal Facilities.—In the municipal  field, a massive
program of Federal financial assistance is provided to
communities to help meet the terms of permits.

     During Phase I, grant awards have haa to be both expedi-
tious and effective. Awards in this Phase continue to be con-
centrated on projects which truat current flows,  such as
treatment plants or alternative techniques, rather than
adding new flows, for example through collection sewers not
required to eliminate existing health hazards.  To achieve

immediate water quality improvement,  permits  tor  existing
tacilities emphasise actions to achieve  optimum operations
and maintenance with minimal capital  investment.

     Abatement of pollution trom combined and storm sewers
will be necessary in some areas to meet  the 1983  water
quality goals and, in some cases, water  quality standards.
A variety of potential abatement methods exists,  including
the use of best management practices  and non-structural

     The costs and benefits of abating or controlling
combined and storm sewers vary significant in accordance
with the specific source and the methods used.  In many
instances, the capital costs of traditional structural
remedies are so high as to make widespread use of that
alternative an untenable solution.  Therefore,  any
Federal grant decision will be mada only after  detailed
case-by-case study and long-range planning.  The  planning,
which will normally oe conducted under section 208 of  the
FfoPC Act, will have to explore fully the alternative control
technologies and the resulting levels of control, to select
the most cost-effective approach.  Where a pollution
control project has multiple purposes, funding will be
limited to the water pollution control elements of the

     Under a proposed legislative amendment,  construction
grant funding for separate stormwater controls would be
suspended.  (See Legislation, pages lb-iy, above.)  Reliance
would instead be placed on non-structural solutions, which
would be developed through water quality management plans.

     As most municipal plants achieve the minimum techno-
logical standards that are required,  some facilities,
oecause of growth or water quality requirements,  will
have to employ higher levels of treatment.  They  will under-
take increasingly important studies, often in conjunction
with areawide planning under section 20b, to  achieve a
cost-etfective solution to their problems.  On this basis,
they will select between major alternatives,  including:
(1)  the type of treatment:  recycling,  land  disposal,  or
surface water disposal;   (2)  the increase in capacity
versus correction of infiltration/inflow; ana  (3)  the
problem to be addressed—whether to respond to combined
sewer overflows or to develop higher plant efficiency.

     The Federal funding program will continue to be
oriented towards the correction of existing problems,  and
not toward a perpetuating level of assistance,  hith  the
completion of the construction necessary to meet the
1*63 water quality requirements, State and local
governments should move closer to an era ot tinancial
self-sufficiency.  LPA supports the identification ana
provision of long-term funding authorizations so that
effective planning and phasing of the construction of
activities can be undertaken.

     Completion of facility planning will be emphasized
during the next several years so that construction of
treatment works can proceed expeditiously.  These plans
will be incorporated as promptly as possible into
planning which will take place at the areawide level.
However, areawide planning is not intended as a substitute
for all the elements of a facility plan, and facility plans
will remain a precondition to the award of a Step 2 or
3 grant.

     Maintenance by States and regions of a good mix of
Steps 1, 2 and 3 grants will assure a steady flow of
projects from initial planning through to completion
of construction.  Steps 2 and 3 will become an increasing
portion of total current projects.  Assumption by States
of additional grants administration responsibilities will
enhance their level of involvement in the construction
grants program.

     As treatment facilities are completed, LPA and the
States will emphasize effective plant operation and main-
tenance.  This will be an important program, employing
a coordinated approach that includes technical support,
operator training, and compliance and enforcement.  The
ultimate responsibility of local level plant management
will be recognized.  This effort will become an increasingly
significant determinant of success in the municipal
treatment area.

     hater Quality ManagementPlanning.—In Phase I,  States
have developed and Begun to implement a coordinated
program ot State water quality management.  Components
of the program are:  the State strategy, which covers a
multi-year period; the annual State program, which

identifies specific program outputs  and  resource  needs
each year; and State water quality management  plans,
conducted in each of the identified  planning units  of
the State. . The State water quality  reports under section
305(b) contribute information tor these  components.

     In Phase II, the State, as a part of its  program
management system, will assure that  an appropriate  level
of planning will be conducted throughout the State.
States and areawide planning authorities will  update
current planning on an ongoing basis, consistent with
local priorities, to provide a coordinated plan directing
water quality management decisions.

     The areawide waste treatment management planning
effort pursuant to section 208 will  strengthen the
institutional basis for water quality management, including
both point and nonpoint sources. The program was initiated
in 1974.  host initial planning agency designations
were made during fiscal year 1975, although additional
designations are expected.  Initial  plans should be com-
pleted no later than November, 1978.

     The primary importance of areawide planning will  be
realized when plans are carried out  during Phase II.  These
plans, including near-term outputs,  will be a  major
vehicle for program management.  By law, they  coordinate
permit requirements, construction grant needs, and  nonpoint
source programs and identify technical,  institutional
and funding problems and solutions.   They will consider
the social, economic, and environmental consequences of
alternative proposals.  As applicable and to the extent
that they do not do so initially, plans will be related
over time to ground water, water supply, air quality,  and
residual waste management.  Thus, section 208  areawide
plan outputs will  influence actions in a variety of other
programs, and plan implementation will result  in coordinated
environmental management.

     Nonpoint Sources.--As the abatement of point sources
is achieved, nonpoint source pollution control will
be an increasing water program focus.  During  Phase II,
NPS control will become a major program emphasis, to be
implemented through the water quality management system.

     Preparation for nonpoint source management is  occurring

in Phase I,  curing FY  1975-77.   LPA is  expanding  its  intoima-
tion and guidance on nonpoint source control  methods  and
techniques and is undertaking cooperative pilot  projects
with the States.  States and designated agencies are  dovelopino
control strategies, including regulatory programs.   b'oi
States with good existing programs, this primarily  ituvlvo;--
building on past activities.

     A 1975 court order requires NPDES coverage  of  all
point sources, including a number of sources—e__.g. ,  certain
agricultural and silvicultural flows—not of  the tradi-
tional municipal/industrial effluent outfall  type.
Regulations for these categories will be promulgated during
calendar year 1976, and EPA and State permitting activities
will be consistent with these regulations.

     It is generally recognized that many types  of  nonpoint
sources are not amenable to an effluent limitations  approach.
In developing individual solutions, States and designated
agencies will identify best management practices for  these
sources, relying not only on '-heir own experience and EPA
guidance but also on the considerable expertise  of  other
Federal agencies responsible :or particular geographic
areas or types of activities.

     Toxic Pollutants.—During Phase II major attention will
be paid to toxic poTTutants.  The exotic pollutants,  such
as refractory organics and heavy metals, remain  a complex
problem, but a lack of perfect knowledge should  not  result
in a failure to establish needed limitations  on  discharges
of identified toxicants.  A coordinated effort of research
into toxic pollutant treatment technologies and  management
systems, health and ecosystem effects, and fates in  the
environment will be coupled with existing knowledge  and
use of the Act's various regulatory provisions to produce
an integrated Federal water-borne toxicants policy.

     During 1976-1983, technology-based effluent guidelines
limitations will be the principal mechanism for  controlling
substances which display toxic properties.  The  effluent
guidelines for all principal categories of industrial
sources will be revised, and these substances will  be in-
cluded in the guidelines on a routine basis.

     Where effluent guidelines prove inadequate  in con-
trolling a given substance and sufficient data are available,

the substance will be designated a toxic pollutant pursuant
to section 307(a).  Toxic effluent standards for the
pollutant will then be developed for industrial categories
which account for the discharge,  in addition, section
311 of the Act will be employed during Phase II to regulate
substances which pose a toxic hazard from industrial  sources
which handle or transport such substances.

     Increasingly, State water quality standards will include
limits on toxic substances.  This will improve the mechanism
for obtaining environmental data by which to review the
results of existing programs and develop new responses as


      Successful implementation of the water quality program,
including both the FWPC Act and the Marine Protection,  Research
and Sanctuaries Act, is a complex undertaking of enormous
nationwide impact. Cooperation and communication must exist
at all levels—within EPA's own organization, both headquarters
and Regional; with other Federal agencies having interests as
diverse as the Forest Service and the Nuclear Regulatory
Commission; with States, communities, other governmental
institutions, and with water quality planning and management
agencies.  Special attention must be given to informing
and involving members of the public, be they individual
dischargers, environmental groups, or private citizens.  The
theme of open dialogue will continue to be a major element
throughout LPA's water quality activities.