OOOR76018
GUIDELINE SERIES
OAQPS NO. 3.0-022
November 15, 1976
RELATIONSHIP BETWEEN AIR QUALITY PLANNING
AND THE STATE AND AREAWIDE WATER QUALITY
MANAGEMENT PROGRAM; ELIGIBLE USES OF
SECTION 208 FUNDS FOR AIR QUALITY ANALYSES
VS. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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UNITED STATES LNVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
NOV 15 1976
OFFICE OF
AIR AND WASTE MANAGEMENT
SUBJECT:
FROM:
TO:
ATTN:
Relationship Between Air Quality Planning and the State and
Areawide Water Quality Management Program; Eligible Uses of
Section 208 Funds for Air Quality Analyses
Andrew W. Breidenbach, Assistant Administr.
for Water and Hazardous Materials
Roger Strelow, Assistant Administrator
for Air and Waste Management
All Regional Administrators
Regional Water Division Directors
Air and Hazardous Materials Division Directors
Environmental Programs Division Director, Region II
REVISED PROGRAM GUIDANCE MEMORANDUM: SAM-8
Purpose
The purposes of this memorandum are: (1) to transmit revised
guidance on Environmental Protection Agency policy on the relationship
between air quality planning and the state and areawide water quality
management (WQM) program, and (2) to identify air quality-related acti-
vities eligible for funding under section 208. This memorandum and
the attached guidance document, "Procedures for Coordination between
Air Quality Planning and the State and Areawide Water Quality Management
Program", revise and expand upon previous guidance signed by John Quarles
on September 22, 1975 (issued as water quality management guidance
SAM-8).
Background
The September 1975 guidance dealt with the coordination of the air
quality maintenance program and the WQM program. Since that time, the
regulations governing both programs have been changed. The attached
guidance has been revised to reflect those changes.
In addition, past guidance has not addressed explicitly an issue of
interest to regional, state, and areawide personnel: the eligible uses
of section 208 funds for air quality analyses. There are various legal
justifications for addressing air quality in WQM programs in both
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designated and nondesignated areas. The most important justification is
found in section 208(b)(2)(E) which requires an assessment of the environ-
mental, social and economic impact of carrying out the plan. In addition, {
the regulations governing the water quality management planning process j
require that WQM plans are coordinated with and describe the relationship j
with plans developed under the Clean Air Act (section 130.34(a)). WQM j
plans must also "be in conformance with all State and local legislation, ';
regulations, or other requirements or plans regarding land use and j
the environment, except for those cases where the plan specifically I
recommends changing such legislation, regulations, or other appropriate ';
requirements" (section I3l.20(f)(1)(i11)). j
As a result of these and other requirements, the effects of the
WQM plan on air quality must be addressed in the plan. This is \
especially important in areas already experiencing serious problems
in attaining air quality standards. The implementation of WQM plans
must not cause a violation or delay the attainment of air quality
standards which are part of the State Implementation Plans (SIPs).
Federal law (31 USC 628) requires that funds appropriated for a
program must be spent for the purposes of that program. Thus, any
air quality activities supported by 208 funding must be directly
related to the purposes of the WQM program. The following guidelines
should be used in determining eligible air quality costs:
1. The activities listed below are examples of eligible uses of /
The list is intended for illustrative \-
purposes only and is not all inclusive. Other activities
related to air quality aspects of WQM programs may also
qualify.
a. Development of common data bases.
b. Development and implementation of common public participa-
tion programs.
c. Development and implementation of common plan adoption and
revision procedures (e.g., joint public hearings).
d. Development of common institutional mechanisms for plan
adoption, implementation and revision.
e. Development of control strategies or measures that will
achieve the objectives of both air quality and WQM
programs .
f. Development of statutes, regulations, or administrative
procedures relating air, water, and land use.
g. Development of common impact assessment methods, procedures.
and criteria.
h. Development of air quality assessments of existing or
projected development to be served by wastewater treatment
facilities.
i. Development of strategies for mitigating any adverse air
quality effects from WQM plans.
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I The costs of any activities not listed above, but necessary to
comply with the legal requirements of section 208, are eligible for
funding when explicitly justified.
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2. The following activities are not eligible for section 208
funding:
a. Development or improvement of air quality monitoring
instruments or procedures,
b. Collection of ambient and source emissions air quality
data, except as needed to calibrate models used in
analyzing WQM plans.
c. Compilation of base year emission inventories, except as
necessary to assist in determining the air quality
effects of WQM plans (e.g., determining emissions for
areas where data adequate for the WQM plan assessment
was not developed as part of the air quality planning
process).
d. Creation of air quality simulation models.
e. Refinement of air quality simulation models; except
as may be necessary to adapt or calibrate an existing
model to better reflect the characteristics of the
geographic area of application.
f. Identification of major contingencies which may alter
the assumptions used in air quality analyses (e.g.,
energy crises, fuel switching due to natural gas
shortages, amendments to the Clean Air Act, etc.)
Because of the variability in air and water quality problems,
availability of air quality data, and availability of funds, it is
not possible to develop a national formula for apportioning costs
between air quality funds and section 208 funds. Where eligible tasks,
such as those listed on the preceding page, are being undertaken, it
is left to the discretion of the Regional Administrator to determine
the share of the funding which is to be provided through the available
sources of funding.
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PROCEDURES j'OR COORDINATION BETWEEN AIR QUALITY MAINTENANCE PLANNING
AND THE STATE AND AREAWIDE WATER QUALITY
MANAGEMENT PROGRAM
I. Background:
A. Description of the Programs
1. Air Quality Maintenance Planning
Under the Clean Air Act Amendments of 1970, the states were required
to cevelop state implementation plans (SIPs) for the attainment and main-
tenance of national ambient air quality standards (NAAQS) for six pollu-
tants: suspended particulate matter, sulfur oxides, carbons monoxide,
hydrocarbons, nitrogen dioxide, and photochemical oxidants. The SIPs were
submitted to EPA for approval in 1972. Most SIPs emphasized the attain-
ment of standards through emission control regulations and did not fully
address the problem of maintaining the standards once attained. As a
result of a 1973 court case brought by the Natural Resources Defense
Council, the Environmental Protection Agency (EPA) disapproved all
SIPs because they lacked effective mechanisms for maintaining standards.
EPA then required that the states identify areas that have a potential
for exceeding any NAAQS within a 10-year period. Based upon information
submitted by the states, EPA published a list of these potential problem
areas which are termed air quality maintenance areas (AQMAs).
The 1970 amendments also required that the NAAQS be attained by 1975,
or by no later than 1977 if extensions are granted to states by the
Administrator of EPA. However, a number of areas did not attain the
NAAQS by 1975 and will not be able to meet them by 1977. Because of this
attainment problem and the need to provide for NAAQS maintenance, EPA
is reviewing all SIPs to determine where revisions may be necessary to
provide for attainment and maintenance of standards.
By July 1, 1976, EPA determined which areas needed SIP revisions
for either attainment or maintenance. This determination was based
on analyses performed by either state or local agencies or by EPA. In
some instances, it was not possible to complete the analysis by July 1, 1976.
The areas for which analyses have not been completed will be listed in
the Federal Register as potentially requiring a plan revision. A final
determination will be made as quickly as possible. The dates by which
attainment or maintenance revisions to the SIP are to be submitted are
no later than July 1, 1977 for achievable emissions limitations and
July 1, 1978 for all other measures.
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The EPA has not limited air quality maintenance planning
requirements only to those areas designated as AQMAs. Maintenance
planning has been more explicitly incorporated into the SIP process
through the addition of new regulations to Part 51 of Title 40, C.F.R.
(These are labeled Subpart D - Maintenance of National Standards). The
Administrator of EPA may now require SIP revisions for maintenance of
NAAQS in any area regardless of whether the area has previously been
designated an AQMA. The AQM planning regulations may be applied not
only to designated AQMAs but to any area where SIP revisions for attain-
ment and maintenance are necessary.
To ensure the continued maintenance of the NAAQS, once attained,
states must provide a procedure for the continual acquisition of in-
formation used in projecting emissions, and assess all areas of the
state at least every five years to determine which areas are in need
of plan revisions.
The air quality analysis required under Subpart D, must include
determinations of the air quality effects of emissions both from existing
sources and from projected growth and development. The time period analyzed
must cover at least 20 years, or if modified by the Administrator, not
less than 10 years. There are three main elements of AQM analysis:
1) projection of emissions for each area and pollutant identified;
2) allocation of emissions according to estimated projections; and
3) calculation of air quality concentrations resulting from the future
emissions pattern.
When the analysis indicates a need for a SIP revision in order to
maintain the NAAQS, the revision takes the form of an AQM plan. The
AQM plan must include control strategies which will ensure that pro-
jected emissions will be compatible with the maintenance of national
standards, for a time period determined by the Administrator, but not
less than three years and in many cases for 10 to 20 years. The plan
must include: 1) data which demonstrates that the control strategies
are adequate to attain and maintain national standards; 2) a description
of the control strategy measures themselves; 3) enforceable rules and
regulations to implement the control strategy; and 4) a discussion
of possible future control strategies and regulations for enforcement.
2. State and Areawide Water Quality Management Program
Under Sections 208 and 303 of the Water Pollution Control Act
Amendments of 1972, the states are directed to establish a continuing
planning process (CPP) through which water quality standards and manage-
ment plans to implement such standards are developed. The CPP is
intended to serve as a guide for water quality decision-making over a
20 year span, at five year intervals. Its specific outputs are the five
year strategy, the annual state program plan, a state/EPA agreement on
timing and level of detail, and the individual state water quality
management (WQM) plans.
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Mate: quality management plans consist of two phases. EPA has
directed the states to focus the first phase* of water quality management
plans on analyses to determine the effluent limitation necessary for
point sources to meet standards. Implementation of effluent limitations
is through the Section 402 Federal/State discharge permit. Another means
of implementing point source effluent limitation for municipalities is
through the construction of publicly owned sewage treatment works
authorized under Title II of the Act.
In the second phase of water quality management development,
the planning objective is to meet the longer term 1983 goals of Section
101(a)(2): "It is the national goal that wherever attainable, an interim
goal of water quality which provides for the protection and propagation
of fish, shellfish, and wildlife and provides for recreation in and on the
water be achieved by July 1, 1983." Water quality management plans form
£ basis for implementing applicable point and nonpoint source controls needed
to achieve the requirements of the Act. These plans consist of the follow-
ing elements:
(I) Planning boundaries
(2) Water quality assessment and segment classification
(3) Inventories and projections
(4) Nonpoint source assessment
(5) Water quality standards
6) Total maximum daily loads
7) Point source load allocations
8) Municipal facilities needs
(9) Industrial facilities needs
(10) Nonpoint source control needs
(11) Residual waste control needs; land disposal needs
(12) Urban and industrisl stormwater needs
(13) Target abatement dates
(14) Regulatory programs
(15) Implementing and operating agencies
(16) Environmental, social, economic impact
*Phase I water quality management plans, which are based primarily on
Section 303 of the Act, were to be submitted to EPA by July 1, 1975,
unless an extension (of up to one year) was granted by the EPA Regional
Administrator.
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Phase II plans must be certified by the governor and submitted
to EPA no later than November 1, 1978. EPA then has 120 days to re-
view the plans and either approve them or return them to the state for
modification. After EPA approval, the state should review, and if
necessary, revise the plans at least annually.
For those areas with complex water pollution problems, the state j
can designate an areawide planning agency for each area to develop the [
plan. These areas are referred to as "designated areas" and they are I
eligible to receive Federal funding under Section 208 of the Act. There •
are presently 176 such designated areas, and most are urban, industrial j
areas, though some are rural or energy development areas. The plans ;
developed must fulfill the requirements of Section 208 and must be approved \
by the state and EPA. The state is responsible for ensuring that the |
water quality management requirements of Section 208 are met in all areas j
of the state that are not designated.
Planning agencies for designated areas have up to one year to initiate !
their planning process and then two years to develop a plan. For existing \
grants, the Regional Adminstrator determines when the process is opera-
tional based on when the agency has sufficient staff to begin plan
development and has initiated major work elements. The agency has two :
years to develop the initial plan. Most plans for designated areas now j
underway will be due between December 1977 and June, 1978. New grantees :
will have two years to develop the plan from the date the detailed work :
plan is approved by EPA. The agencies can receive up to 5 percent of
their grant award to prepare the work plan.
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There are other EPA programs which are closely related to the state •
and areawide water quality management program. Two of these are par- '.
ticularly important. The first of these two programs is the construction :
grant program. Municipalities and public agencies responsible for sewage
treatment can apply for Federal funding to cover 75 percent of the cost
of construction for waste treatment facilities. Facilities, or 201 plans, ,
which are the first step in the construction grant process, consist of
those necessary plans and studies required to evaluate and ultimately
select the best alternative prior to detailed design and construction of '•
publicly owned waste treatment works. The overall objective is to ensure
that treatment works are cost-effective and environmentally sound.
The second program is the National Pollution Discharge Elimination
System which issues discharge permits. These permits, which describe
the limits of the discharge allowed, are required for all point source
discharges. EPA is responsible for issuing the permits, but it can
delegate this responsibility to the state if the state can demonstrate
it has the necessary authority to implement the program and will comply
with the requirements of the Act. By August 1976, twenty eight states
are expected to have approved NPDES programs. In addition, EPA develops
the effluent guidelines, and new source and toxic pollutant discharge
standards which provide the base level of abatement control on which the
permits are issued. Whenever these controls are inadequate to meet
water quality standards, waste allocations (provided by the state)
are applied.
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B. Designation and Timing
1. Designation of Planning Agencies
Under the regulations for WQM planning, when an area is designated
as one with complex pollution problems, an agency must also be designated
as the planning body responsible for that area. Often this designated
agency is a regional planning council or a council of governments (COG).
For other areas of the state, i.e. non-designated areas, a state agency
must be designated, with primary responsibility for the conduct and
coordination of WQM planning. However, this state agency may and is
encouraged to delegate portions of its planning responsibility to other
state, federal, local, or interstate agencies provided that the delegated
agencies remain under the supervision of the state agency. In the case of
either designated or nondesignated areas, an implementation program
must be developed, and the implementing agency or agencies must be identified.
The situation in AQM planning is somewhat different, since there
is no provision requiring the designation of one responsible agency in
designated AQMAs. The state has the initial responsibility for developing
AQM analyses and plans throughout the state although this responsibility
may be assummed by the EPA regional office or delegated to a lower level
of government. For example, the state might decide to do the planning
itself, or it might decide to do it in conjunction with local or regional
agencies. If this is the case, more than one local or regional agency
might be involved for each AQMA. It is recommended that one agency have
lead responsibility, but this is not a requirement. Implementation can
be the responsibility of one or more agencies as in WQM.
Because many air pollution control agencies may not have adequate
expertise in developing and implementing the kinds of measures that may
be needed for air quality maintenance such as land use and transportation
measures, they are required by the regulations to coordinate with other
agencies, such as the WQM agencies and their policy advisory committees,
HUD 701 aoencies, DOT 3-C agencies, Coastal Zone Management agencies
arid A-95 clearinghouses. Finally, the state would have to forward the
AQM plan to the appropriate A-95 clearinghouse for comment prior to sub-
mission.
2. Geographic Boundaries
Most designated AQMAs consist of urban and urbanizing areas, and many
overlay Standard Metropolitan Statistical Areas. Because of this, the
initial boundaries are often defined as coincident with county boundaries,
though in some cases boundaries divide counties. Other AQMAs cover areas
where resource exploitation or industrial development create, or may
potentially create, an air quality problem. If there is an identified
need, maintenance planning will be done for other areas, although they
will not be designated AQMAs. AQM plan revisions are pollutant specific;
that is, an AQMA may be identified based upon potential violation of any
one or several of the pollutants for which standards exist.
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Following the initial determination of the need for SIP revision,
states or EPA must do an in-depth, analysis of the problems posed by each
pollutant in the identified area. This would include an assessment of
growth factors and development patterns and a projection of future air
quality for at least 10 years. It is possible that based on this analysis,
the boundaries would be revised to correspond more closely to the air shed
within which the objectionable pollutants are a problem.
State and areawide WQM planning is not pollutant specific. Areawide
planning is performed whenever the governor of the state (or in some
cases, local officals) determines that an area has or will have substantial
problems in controlling water quality due to high concentrations of 1
population and industry or other conditions. Boundaries for designated
areas are coincident with governmental boundaries in most cases, though
hydrological boundaries also may influence boundary determination. The
designations are proposed either by the state (or states if it is an
interstate area), or by the local jurisdiction themselves. The larger
state planning area may be subdivided into "approved planning areas,"
which may include the entire state or portions of the state as defined
by hydrologic, governmental, or other boundaries.
Thus, in both programs, the state has overall planning responsibility,
although local and regional governments play an important role in the
planning and implementation process.
3. Timing of Designation and Plan Preparation
Under the air quality maintenance program, the state or EPA must
first analyze each AQMA to determine the extent of existing and poten-
tial air pollution problems and to evaluate whether an AQM plan is
actually needed as a revision to the SIP. In some areas, a plan may
not be required in the near future. In any case, by July 1, 1976 or
shortly thereafter the Regional Administrators must identify all attain-
ment and maintenance SIP revisions that will be necessary as well as
just maintenance revisions. It is the RA's responsibility to set a
submittal date for the AQM plan which will be contingent upon the lead
time needed for effective maintenance. For example, if the air quality
analysis reveals maintenance problems within 10 years and to solve the
problem requires an action 7 years in advance, then the necessary
action must be in the first maintenance revision. It does not matter
how many years the revision covers, the necessary lead time from action
to prevention of air quality standards violation must be considered.
The shortest time period a revision could cover, however, would probably be
three years since less would be impractical. However for those revisions
necessary for attainment, the Administrator is requiring that all achievable
emissions limitations be submitted by July 1, 1977, and all other measures
needed must be submitted not later than July 1, 1978.
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The AOM analysis must cover a 20 year period, or at least 10 years
if modified by EPA, Th>> time period covered by the AQM plan is determined
by EPA, and may be less than the 20 year analysis period. In such a case,
however, possible future strategies for maintaining air quality for the
longer period must be discussed in the plan.
By May 1977 all SIPs must provide for a procedure for the continual
acquisition of information used in projecting emissions. Using this data,
all areas of the state shall be assessed at least every five years to
determine if any areas are in need of plan revision. Of course, if the
original plan insures maintenance for a period of less than five years for
son^e AQMAs 3 these must be reassessed more frequently.
Planning agencies for designated WQM areas have up to one year to
initiate their planning process and then two years to develop a plan.
Per existing grants, the Regional Administrator determines when the process
is operational based on when the agency has sufficient staff to begin plan
development and has initiated major work elements. The agency then has
two years to develop the initial plan. Most plans for designated areas
now underway will be due between December, 1977 and June, 1978. New grantees
will have two years to develop the plan from the date the detailed work
plan is approved by EPA. The agencies can receive up to 5 percent of
their grant award to prepare the work plan. In any event, all initial
WQM plans must be submitted to EPA by November 1, 1978. EPA may either
approve, or disapprove a plan. Once approved, the state WQM plan (in-
cluding the areawide plan(s)) must be reviewed and if necessary revised at
least annually.
C. Interrelationships
One difference between the AQM and WQM planning programs is that
monies have been appropriated specifically for the state and areawide
WQM program, while AQM planning is part of the SIP and is funded out
of existing state grants. The money allocated to the state through
Program Support Grants (Section 105 of the Clean Air Act), together
with the matched state or local funds, must be apportioned among a
number of other air quality programs which are part of the SIP (e.g.
Stationary Source Review, New Source Performance Standards, Transporta-
tion Control Measures), along with other general functions (enforcement,
engineering, technical services, and management).
Nevertheless, WQM planning and air quality planning are interrelated,
both in terms of their impact and in terms of their similarities of
approach. Both are concerned with maintaining environmental quality;
both utilize a state and areawide approach in which areas of potential or
existing problems are identified and a unified plan is developed. However,
when a program is designed to control pollution in just one medium, it
can result in environmental deterioration in another. While the goal of
both air quality planning and WQM is to improve the quality of the environ-
ment, the single medium focus of separate programs may result in conflict
with the attainment and maintenance of standards in the other medium.
At the same time, if care is taken to coordinate their development, the plans
produced through these two programs can be mutually supportive.
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1. Intermedia Tradeoffs
An obvious example of the intermedia conflict is the use of control
technologies and equipment which are employed to reduce emissions to one
medium while transferring the pollution problem to another medium. Lime/
.limestone scrubbers, one means for reducing S0? emissions, produce a
liquid sludge which must be disposed of. Conversely, sewage treatment
plants may try to dispose of sludge through incineration, thus increasing
air quality problems. Such problems can also affect energy production ,
considerations. A fossil-fueled electric generator may be undesirable ,
because of air quality limitations, but an alternative nuclear generating
plant may be unable to meet thermal pollution standards.
2. Community Growth
Potential conflicts are also apparent when examing the issue
of community growth -- where it should occur, how it should be dis-
tributed and how much should be allowed. The two programs will view
these questions from different perspectives, which in some areas may
result in different answers. For example, the location of waste treat- j
ment plants and sewer interceptors can act as an inducement to growth |
and guide growth toward the serviced areas. These areas planned for I
expanded sewerage service may have existing air quality problems which I
increased growth would simply exacerbate. In Ocean County, New Jersey,
for instance, the combination of the expansion of the Garden State i
Parkway and a proposed new large treatment plant would have permitted |
a rapidly accelerating growth rate and resulting air pollution problems i
from increased commuting. Citizen objections finally resulted in a re- I
duction in the scale of the plant. In the Washington, D.C. metropolitan \
area, a large interceptor was run out to serve the Dulles International
Airport through land which was largely undeveloped. The combined
attraction of both the airport and the available sewer service has put
severe pressure on the local communities to accommodate greater develop-
ment and thus more pollution.
In addition to conflicts over the amount of growth, the two programs
may consciously attempt to guide growth toward different distributions. i
In designing an AQM plan, for example, the planning agency may want to j
utilize measures to change emission densities. However, wasteload alloca- !
tions consistent with maintaining water quality may necessitate a different •
land use configuration which would not correspond to the air quality zones. j
For example, the location of additional heavy industry within a particular
area may lower the quality of the receiving water below standards, though i
due to favorable meteorological conditions, it is a desirable location ;
in terms of air quality maintenance.
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On a large scale, the two programs may favor different general
growth patterns. In one area, for example, substantial in-migration
and a concommitant demand for housing may result from increasing job
opportunities. New housing construction to meet the increased demand
might occur primarily in the urban fringe where excess treatment capa-
city exists. Indirect sources, such as shopping centers, would accompany
the residential construction, and as a result, air quality standards
might not be attained or maintained. In addition, adequate mass transit
irny not be available, and the inevitable increase of motor vehicle use
could cause substantial air quality problems. Thus, the development pattern
best suited to meet the requirements of a water quality plan may conflict
with the needs for air quality maintenance planning.
3. Reinforcement
Thus far, only possible conflicts between the two programs have
been mentioned. However, they should be designed to be consistent with
one another so that their policies can be reinforcing, thus providing
further inducement for communities to take regulatory action. Waste-
water treatment and collection facilities, for example, can be designed
to serve those areas lacking significant air quality attainment and
maintenance problems, thus directing growth away from problem areas. In
doing so, however, consideration must be given to preventing deterioration
of air arc water quality. If land use policies and controls are consistent,
growth can be regulated so that it does not result in violations of either
water or air quality standards. Therefore, it is important that agencies
developing plans under the two programs coordinate closely with each other
to assure that their plans will achieve national objectives for both media
and that they are compatible and complementary. The plans will thus more
likely reinforce each other as they are implemented.
I]. Procedures for Coordination
A. Introduction
Various state, regional and local agencies may be involved in either
AOM or WQM planning; some agencies may be involved in both. State and
regional agencies are responsible for the WQM program; state designated,
and delegated agencies are responsible for the AQM program. The general
parameters for coordination of these two "sets" of agencies are detailed
in the respective program regulations. In keeping with these regulations,
this section will outline a number of procedures which could facilitate
AQM-WQM coordination and describe their integration into the planning
process.
Both the WQM and AQM planning processes have certain requirements for
intergovernmental cooperation and coordination. In the WQM area, one
mechanism for coordination 'between local, state, interstate, and federal
units of government is the policy advisory committee. This committee is
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made up of representatives from interested agencies and chief elected
officials of local governments, and advises the responsible planning and
implementing agencies on broad policy matters relating to the WQM plan,
includng fiscal, economic, and social impacts. Furthermore, the state
planning process must assure the coordination of water quality management
plans with other resource and developmental planning, including state and
local land use and development programs and federally-assisted planning
and management programs (specifically including the SIP).
The regulations for AQM planning do not require the formation or
utlization of a policy advisory committee, but they do include a more
detailed description of the areas and purposes of coordination. Organi- -\
zations or agencies with the responsibility for the development of AQM
plans must ensure the continuous involvement of locally elected officials,
state and local air pollution control agencies, and agencies within the
AQMA responsible for local planning including the agencies and policy
advisory committees responsible for WQM planning. Coordination with
other planning programs substantially affecting or affected by air quality
management is to be facilitated by the use of common data bases; coordi-
nation of work programs; use of similar policy advisory bodies; use of
compatible public participation and information programs; incorporation
of air quality as a factor in other planning programs; and determinations
of consistency between programs.
In addition, the AQM plan must describe the program relationships
between air quality management and state, regional, and local programs
for land use management; transportation and parking management; water
quality management; solid waste management; and other forms of environ-
mental management affecting or affected by air quality management
(40 CFR 51.58).
B. Planning Agency Designation/Delegation
Because the state is ultimately responsible for both AQM and WQM
planning, the need for program coordination at the state level is
imperative. In many cases, however, the state will delegate or share
planning responsibility with local or regional agencies, such as regional
planning commissions or counsels of governments (COGs). For the most
part, the state designation or delegation process for WQM planning
agencies will be completed prior to the AQM delegations.
Given this situation, coordination would be facilitated if the state
delegated or shared responsibility for AQM planning with the same agency
involved with WQM planning, provided that agency has responsibility for
comprehensive planning and is capable of preparing such a plan. The
development of AQM plans in many areas involves measures, such as land use
controls, which many air pollution control agencies have neither the
expertise to develop nor the authority to implement. Thus, in addition
to facilitating coordination., it may be more politically acceptable
to have an agency responsible for general comprehensive planning closely
involved in the development of the AQM plan. Of course, the feasibility
of having the same agency develop both plans would depend on the boundaries
of the two areas. If there is little overlap, or if the state chooses not to
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delegate its planning responsibility, there may be no local or regional
•planning agency with the authority to conduct both WQM and AQM planning
in a given geographic area.
I If the same agency does not have responsibility for both WQM and
AQM planning, coordination would still have to occur, and to assure that
it does, the responsible planning agencies should draw up letters of
agreement between them to cover such items as integration of work plans,
I and consistency of data and control strategies.
C- Geographic Boundaries
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From the earlier discussion, it should be apparent that in many
cases AQM and WQM planning areas will not coincide, despite the general
state oversight of both programs. For example, part of a metropolitan
a'^ea may fall within a WQM planning area, while another part may be in-
cluded in an AQMA. However, if there is a considerable overlap between
the two planning areas, it would be preferable if they could be the same.
During the AQM analysis, the states or those delegated by them should
consider incorporating existing WQM planning areas into the AQMA when this
appears to be a practical alternative. Conversely, future designations
and boundary determinations for approved WQM planning areas should give
consideration to refining geographic boundary lines so as to increase
consistency with an existing AQMA.
D Work Programs
The WQM and AQM plans have a slightly different planning sequence,
but essentially follow a similar process. The following generalized
planning tasks apply to either AQM or WQM planning:
1. Inventory of existing and potential emissions or
discharges and characterization of possible problems.
2. Data collection and projection of population, employment,
and land use over the planning period.
3. Projection of waste loads or emissions over the planning
period.
4. Determination of effects on air or water quality.
5. Determination of necessary emission or waste load
reductions.
6. Development of alternative strategies of waste load or
emission reduction ,to achieve and maintain standards.
7. Evaluation of strategies and selection of preferred alterna-
tive.
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Although they may be on somewhat different time schedules, it is
important that whenever possible, WQM and AQM agencies coordinate
on the development of their work programs to better integrate the
tasks to be accomplished. In fact, it should be possible where there
is no great discrepancy in timing, to use a common format for the two t
.work programs. Since the AQM planning effort will have limited funding, J
the WQM agency could gather the data and develop projections of population,
employment and land use which could then be utilized by the AQM agency.
Some tasks, such as the citizen participation effort, could be done jointly,
perhaps reducing the staff requirements and the time-consuming nature ; •
of such programs. In any case, the work program must specify how ^
coordination will occur throughout the planning process.
The following sections deal with procedures for coordination in the
development of projections, evaluation of alternative strategies, environ-
mental analysis, reporting, and representation. The exact means of
implementing these procedures shou'icl be developed in the work plan.
E. G r a n t C o nd i t i o n i n g
Grant conditions can be used to specify and give assurance that
sufficient attention will be given to coordination needs. Those responsible
for administering the AQM program within the regional offices can make
use of conditions on Section 105 program grants. If grants have already
been given out, the refinement of work programs may provide an additional
means of ensuring coordination. Similarly, conditions can be included in
the WQM grant. An example, of WQM grant conditions is included on the
following page. In addition, contracts or agreements between the WQM
and AQM planning agencies can be used to clarify responsibilities for
coordination.
F. Data
Both programs require the projection of future pollution levels.
To do this, they must correlate predictions of the concentrations and
components of growth to the resulting emissions. WQM covers a twenty
year span at five year intervals; an AQM analysis must cover a 10-20 year
period while the AQM plan must address a 20 year period. If the two
plans are to be consistent, they must develop consistent projections
for demographic factors such as population and household type, and for
economic growth and land use. To ensure such consistency, a common
classification system is needed for land use and economic factors
so that data will be compiled using a similar format. The planning
agencies should integrate their data requirements before gathering
data, so that the information obtained for the one plan is transferable
to the other. AQM plans can use the data already collected in areas
where WQM planning is already underway. In other areas, the two programs
should divide the effort of obtaining data, which, when collected, can be
integrated into a common data base.
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Air and Water Quality Planning Coordination
The Project Control Program shall, at a minimum, establish
procedures to integrate the air quality maintenance planning (AQMP)
and water quality management planning (WQMP) activities for the area
by written agreement(s). These agreements shall insure that:
A. The identified air quality maintenance planning agency(s) has
reviewed and commented on the project control program prior
to its submittal to EPA.
B. Periodic reporting and output review procedures for both the
AQMP and WQMP programs are established between the identified
air quality maintenance planning agency(s) and the identified
water quality management planning agency.
C. The designated air quality maintenance planning agency(s) participate
as member(s) of the Planning Advisory Committee, established
pursuant to 40 CFR 130.16.
D. There is an equivalent degree of participation (as B. above) by
the water quality management planning agency (grantee) in the
air quality maintenance planning activities for the area.
E. A coordinated search (involving the responsible air quality planning
agencies) of the existing economic, demographic, land use, and other
base!1ne data and data formats is accomplished prior to the develop-
ment of the data base for the WQMP and AQMP programs.
F. Development of new economic, demographic, land use and other baseline
data is applicable with respect to content, format, and timing of
both the WQMP and AQMP programs.
6. Consistent economic, demographic, and land use projections are
utilized in both the WQMP and AQMP programs.
H. Development of the air quality portions of the environmental assess-
ment required by 40 CFR 6.512(a) and the air quality analyses in
response to 40 CFR 131.11(p) is in a format appropriate for direct
input into the air quality maintenance planning process.
I. Where possible, the coordinated scheduling of intermediate WQMP
program outputs and information requirements with the outputs and
information requirements of the AQMP program.
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Since most AQM planning agencies have limited resources, primary
reliance should be placed on WQM agencies for population, land use,
economic and water quality data when this is compatible with the time
schedule for AQM planning. The inventory and projection of air quality
emissions remain the responsibility of the AQM agency.
The viability of coordinating data collection and projection depends
of course on the timing of the two planning efforts. If one is done much
earlier than the other, more recent or comprehensive data may become
available by the time the second planning effort is underway. If this
is the case, there may be adequate reason for modifying projections.
However, if it cannot be demonstrated that the difference in projections
is due to the availability of more complete data, projections for the
two plans should be the same. This approach should also be taken when
AQM or WQM plans are revised so that consistency is maintained.
Another problem develops when the two planning areas overlap but
are not identical. In this case the projections in the overlapping
area should be the same and those for the adjacent areas should not
conflict. That is, the growth rates for the entire area should be
consistent.
Prediction of pollution levels will be based in part on population
projections. These predictions will affect the selection of alterna-
tive implementation strategies, which could in turn, necessitate modi-
fication of the projections. This iterative process of revising pro-
jections must also be coordinated so that potential growth areas are
not conflicting.
6. Representation
Periodic consultation between AQM and WQM planning agencies will
help ensure that both plans are consistent. It is important therefore,
that representatives of the planning agencies responsible for each
program should be included in any advisory group which might be created,
to ensure periodic consultation between the two agencies. AQM planning
guidelines discuss the necessary involvement and interrelationship of
various governmental organizations in the development of an AQM plan.
They assume that, in most cases, a number of agencies will be intimately
involved in the plan's development. Whatever method is chosen to
ensure coordination, a representative of the WQM planning agency should
be included in such efforts. WQM guidelines similarily provide coordi-
nation by means of policy advisory committees, and representatives of
an AQM agency should be included in its membership. In addition, the
staffs of the two planning agencies should develop a close working
relationship. For example, each planning agency could designate one
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person to serve as liaison between them, to help ensure that necessary
coordination is carried out in a timely fashion. This would help in
identifying possible conflicts and resolving them informally as they
arise.
H• Evaluation of Alternative Strategies
Many of the control strategies available for use in either an
AOM or a WQM plan have a potential impact on the other medium. This
ic- especially true for control strategies relating to land use. In the
Ccise of air quality maintenance, nine of the 18 measures discussed in
Control Strategies (Volume III of the AQM guideline series), are cate-
gorized as land use measures. Emission allocation procedures, for
instance, would limit the emission of pollutants based on the regional
lend use/transportation plan. The maximum emissions allowable, consistent
with standards, would be allocated to planning subareas, and land use
ard transportation plans would be revised so that these prescribed
emissions limits would not be exceeded. Transportation controls help
reduce emissions from motor vehicles by either reducing the pollutant
emission rate per vehicle mile of travel (VMT) or by reducing the total
number of VMT. Measures to reduce VMT have the greatest impact on land
use, and can include such things as street closings or traffic free zones,
parking supply management, restricted road building, improved mass transit,
and control of urban development. Other control strategies which affect
land use include transfer of emission source location, indirect source
review, emission charges, and regional development planning.
All of these control strategies can indirectly affect water quality.
Emission limits set for various subareas would effectively control
certain types of development producing those emissions, while possibly
encouraging them to locate elsewhere. An optimum location decision in
teons of maintaining air quality may not be desirable in terms of hand-
ling water pollution discharges. Restricting the development of road
networks in one area may lead to development where the transportation
infrastructure was already in existence - thus causing higher pollution
loads in already developed areas.
As pointed out earlier, it is not only the control strategies which
directly affect land use and thus water quality, but also the technolo-
gically and operationally oriented strategies, that is, emission control
measures. These include such things as new source performance standards,
fuel conversion, combination of emission sources, stack height regulations
and control of fugitive dust sources. Combination of emission sources may
cause a concentration of water pollution discharges. The use of tall stacks
may reduce ground level concentrations but could result in contaminated
precipitation such as the "acid rains" observed in Sweden. One control
strategy for fugutive dust consists of watering which could cause runoff
problems.
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However, not all interaction between WQM and AQM need result in
conflict. For example both plans should favor better management of
construction activities. Measures such as minimal exposure periods for
active construction areas, or ultilization of staged grading, seeding
and sodding procedures would reduce both runoff and fugitive dust problems.
Street cleaning techniques can be useful as a means of reducing resuspen-
sion of particulate matter and also as a means of reducing peak pollutant
loads from stormwater runoff. More generally, the objectives of both
programs would be served by limited urban development in certain areas
or controlled density. Transportation control plans which restrict
road construction to such areas, and facility planning which avoids
routing and an interceptor to undeveloped areas could both be used as
reinforcing strategies.
It is thus critical for the successful implementation of the WQM
and AQM plans to take advantage of complementary strategies by evaluating
the effectiveness of various alternatives to determine their impact on
each medium.
The planning agencies responsible for the two programs must
make sure that they inform one another about alternatives being
considered and offer one another an opportunity to review and comment
on alternatives. Such comments should be considered during the evaluation
process so that alternatives for one medium could not be selected that
would conflict with implementation of the plans for the other medium.
This review and comment should be undertaken by the planning staffs and
the advisory groups to the planning agencies.
WQM agencies will have an additional opportunity in preparing
the environmental assessment to assure that no conflict exists with
AQM strategies. Each alternative WQM plan will be evaluated to assess
its impact on air quality. Not only the direct impact on air quality
should be assessed but also the indirect effects on growth inducement
or distribution. Information developed for the environmental assessment
can be utilized in the AQM plan. The WQM agency should discuss with
the AQM planning agency the potential of transferability when designing
the environmental assessment.
I. Reporting
In order to keep the planning agencies posted on the current develop-
ment of both plans, there should be some type of periodic or milepost
reporting between them. The state should be responsible for ensuring
that the reporting is carried out. This could take place quarterly or
at the beginning and completion of some subtask (e.g., data collection,
projections, analysis of water and air quality, etc.). Informal contacts
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would, of course, be more frequent. Periodic or milepost reporting,
however, would provide formal documentation of the communication which
had taken place.
In addition, a report should be periodically sent to the EPA regional
office. The report should describe how representatives of each program
are involved in an advisory capacity, any meetings which have been held
between the t\
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