WASHINGTON, D.C. 20460
            AUGUST 1975

             SECTION 208
         AMENDMENTS OF 1972
    Environmental  Protection Agency
       Washington, D.C.   20460
             August 1975
      U.  3- -

                            AUG 7   1975
     The Section 208 areawide planning and management program for
solving water pollution problems is perhaps the most comprehensive
program that the Congress has established to bring about environ-
mental quality.  This program ties together the various federal
water pollution abatement requirements (including municipal, indus-
trial, residual waste, runoff, and ground water pollution abatement)
and places the responsibility for planning and implementing these
provisions with regional  and local agencies.

     The Congress had in  mind a number of guiding principles in
creating the Section 208 Program.  First, the complex technical  and
institutional problems of water quality protection vary so widely
across the Nation that long-term solutions to these problems will
necessarily depend on decentralized management.  Secondly, a close
relationship exists between misuse of resources and generation of
pollutants; therefore, developing efficient abatement strategies
requires a total resources perspective.  Third, much of the authority
and financial commitment needed to resolve water quality problems
rests with local government.  This means that implementation of 208
programs will require new legislation for water quality control  at
the local level, which makes involvement of the public and local
elected officials a prerequisite in creating a successful 208 program.
The fiscal responsibility of local government is especially important,
since providing services  such as sewage treatment and protection of
water supply and water uses and coordinating these services with other
community services are intimately related to the fiscal  viability of
the community.

     While it is not possible for EPA to provide answers to all  the
water quality problems that 208 programs should resolve, these guide-
lines describe the overall factors which should be taken into account
and provide a framework for designated 208 planning agencies to use
in developing their 208 plans ansL-4-ffialementation programs.
                      U. S. Environmental Protection Agency

                             TABLE OF CONTENTS
1.    Introduction
     1.1  Purpose
     1.2  Applicability
     1.3  Objectives of 208 Planning
     1.4  Overview of the 208 Program
     1.5  Program Output Requirements
     1.6  Planning Process Overview
     1,7  Planning Criteria

2.    Programmatic Relationships and Authorities
     2.1  Introduction
     2.2  Relationships Between Section 208 Planning and
          Other FWPCAA Provisions
     2.3  Relationships Between 208 Planning and Other EPA Programs
     2.4  Relationships Between 208 Planning and Other
          Areawide Management Programs

3.    Planning Process
     3.1  Purpose
     3.2  Goals and Policies of the Act and Other
          Water Related Goals of the Planning Area
     3.3  Technical  Planning
     3.4  Management Planning
     3.5  Combined Plan Evaluation and Selection
     3.6  Plan Outputs
     3.7  Plan Submittal, Review, and Approval

4.    Detailed Considerations for Land Use
     4.1  Introduction
     4.2  Pertinent Authorizations and Purpose
     4.3  Incorporating Land Use Considerations
          in the 208 Planning Process

5.    Detailed Considerations for Point Sources
     5.1  Introduction
     5.2  Municipal  Wastewater Facilities
     5.3  Other Point Sources
     5.4  Combined and Storm Sewer Discharges
     5.5  Industrial  Wastewater
     5.6  Development of Alternative Subplans

6.   Detailed Considerations for Nonpoint Source Management
     6.1  Introduction
     6.2  Statutory Requirements and EPA Policy
     6.3  Development of a Nonpoint Source  Planning  Approach
          in Designated Areas
     6.4  Identification and Evaluation of  Existing  Nonpoint Sources
     6.5  Assessment of Nonpoint Source Management Practices
     6.6  Selection of Best Management Practices

 7.    Areawide Institutional  Arrangements
      7.1   Introduction
      7.2   General  Management Program
      7.3   Regulatory Program
      7.4   Waste Management Program
      7.5   Basic Issues in Management  Agency  Designation

 8.    Financial  Arrangements
      8.1   Introduction
      8.2   Requirements of the Act
      8.3   Specific Problem Areas
      8.4   Budget Preparation and Supporting  Documentation

 9.    Direct Resource Costs
      9.1   Introduction
      9.2   Basic Concepts in Identifying  Resource  Costs
      9.3   Specific Cost Questions

10.    Public Participation
      10.1   Introduction
      10.2  Public Participation Program  Development
      10.3  A Model Program for Public Involvement
      10.4  Institutional Alternatives for Representation
            of the General  Public
      10.5  Program Evaluation
      10.6  Advisory Committee

11.    Environmental, Social and Economic  Impact Evaluation
      11.1   Purpose
      11.2  Environmental, Social and  Economic
            Impact Evaluation Process
      11.3  Environmental Effects of the  Selected  Plan

12.    Comparison of Alternatives and Selection  of  Plan
      12.1   Purpose
      12.2  The Plan Selection Process

13.    Reports
      13.1   Purpose
      13.2  Periodic Reports During  Plan  Development
      13.3  Final Report
      13.4  Report on Annual Review  of Plan

14.    Plan Submittal, Review and Approval
      14.1  Introduction
      14.2  Submittal and Review of  Interim Outputs
      14.3  Local Review and Recommendation
      14.4  State Review and Certification of Approval
      14.5  EPA Review and Approval
      14.6 Annual Certification of  Consistency


                             CHAPTER 1

1.1  Purpose

     The Federal  Water Pollution Control  Act Amendments  of 1972 (here-
inafter  referred to as the Act) sets forth requirements for controlling
all types of water pollution.   EPA's overall  approach for dealing  with
these problems and for implementing those requirements of the Act  is
set forth in the Water Quality Strategy Paper.   These guidelines represent
an approach for carrying out Section 208 of the Act,  which provides for
areawide management planning in areas with substantial water quality
control problems due to urban-industrial  concentrations  or other factors.
Regulations on 208 area and agency designations have  been published
(40 CFR, Part 126) as well  as  interim regulations  on  208 planning  grant
applications (40 CFR, Part 35, Subpart F).

1.2  Applicability

     This guideline is intended to assist 208 planning agencies in carrying
out their areawide waste management planning responsibilities within
designated areas.  It applies  also to other agencies — local, state, and
federal--that may be involved  in the planning process for those areas
or in plan review procedures.

1.3  Objectives of the 208 Program

     The overall  objective of  the Act is  to "restore  and maintain  the
chemical, physical, and biological integrity of the Nation's waters"
(Section 101(a)).  To achieve  this objective,"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"
(Section 101(a)(2)).  To enable meeting the Act's  objectives, "it  is the
national policy that areawide  waste treatment management planning  processes
be developed and implemented to assure adequate control  of sources of
pollutants in each State"  (Section 101(a)(5)).

     Thus, the objective of 208 planning  is to  meet the  1983 water quality
goal  by developing a plan  as described in Section  208(b)(2), selecting  a
management agency(s) to implement the plan as specified  in Section 208(c)(2),
and demonstrating that the initial plan will  enable meeting  the 1983 goal
of the Act.   This demonstration is needed in order for the state to certify,
pursuant to Section 208(b)(3), that the 208 plan is consistent with
applicable basin plans.

1.4  Overview of the 208 Program

     Through Section 208 designation,  local  areas  are provided  a  unique
opportunity to meet the 1983 water quality goals  by planning  and  managing
a comprehensive pollution control  program for municipal  and industrial
wastewater, residual  waste,  storm  and  combined sewer runoff,  nonpoint
source pollutants, and land use as it  relates to water quality.   Through
a locally controlled planning agency,  an area can  select a  cost-effective
and institutionally feasible plan  directed to meet the 1983 goals of the
Act.  It should focus on an integrated approach for identifying and con-
trolling the most serious water pollution problems initially  and, over
time, resolving the remaining problems, where feasible.   Particular emphasis
should be placed upon nonstructural  approaches to  pollution control  (fiscal
policy, land management, nonpoint  source preventati-ve measures) rather  than
traditional structural measures normally requiring large investments.  The
management agency and institutional  arrangements  most able  to ensure
implementation of the plan should  also be selected by the area. Periodic
review and updating of the plan and management arrangements would allow
for response to new information and changing conditions.

     Table 1.1 on page 1-3 illustrates how the 208 program  can  develop  the
measures needed to resolve specific technical and institutional problems  of
pollution abatement, and how these measures may be implemented  by a 208
management agency.

1.5  Program Output Requirements

     To summarize the measures needed  to solve both the technical and insti-
tutional problems of water pollution abatement and to implement these
measures, a 208 program should have the following program elements:

      o Municipal and Industrial Treatment Works Program
      o Residual Waste Management Program
      o Urban Stormwater Management Program
      o Nonpoint Source Management Program
      o Regulatory Programs (Including Discharge Permits)  to Implement
          Abatement Measures
      o Management Program -- Management Agency(s) and Institutional
          Arrangements to Suoervise and Finance Plan Implementation

     In addition to these major elements, the interim regulations on
208 plan contents (40 CFR,Part 35, Subpart F) require an environmental
assessment and certain plan recommendations and certifications.

     Table  3.1  found  on  page  3-24 of  this guideline  delineates
specific elements or outputs which may be included in a 208 plan  to
satisfy each  requirement of  the regulation (40 CFR, Part 35, Subpart F).
The table also relates each element to parts of thisguidel ine which contain
an  explanation of the type of analysis and planning considerations that
could  be followed to  produce  the specific elements.



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     The review and approval  of 208 plans  by the  states  and  EPA will  be
based on the finding that the requirements of the 208  regulations
(40 CFR, Part 35, Subpart F)  have been met.   In making their determination
that these requirements of the regulation  have been  met,  the states and
EPA will compare outputs with those required by checking  the list  of
specific elements.  Further detail  on plan review and  approval procedures
is provided in Chapter 14.

1.6  Planning Process Overview

     This guideline incorporates a  series  of planning  steps  which  should
enable evaluation and selection of alternative abatement measures  and
means to implement these measures.   The following is a simplified  summary
of these planning steps, accompanied by some examples  of how the steps
might apply to typical  pollution problems  likely  to  be encountered in
208 planning areas:

     A.  Identify problems in meeting 1983 goals  of  the  Act.  The  pollution
     problems should be identified in terms of their relative impact  on
     water quality.  Similarly, existing institutional problems impeding
     solution of water quality problems should be identified.

          Example:  To meet the 1983 goals of water  suitable for fishing
          and swimming may require high levels of abatement  for municipal
          and industrial point sources as  well as nonpoint sources.   Munici-
          pal and industrial  point sources may present the worst problem
          under low flow stream conditions.   It may  be necessary to provide
          higher than national  base level  treatment  for  these sources in
          order to meet water quality standards.   In the process of
          upgrading treatment for existing municipal sewage  treatment
          plants and constructing new plants, the location of discharge
          points is an important variable  affecting  water quality.  Treat-
          ment plant collection systems also influence where development
          will occur, which affects nonpoint source  runoff.   Finally, the
          design of treatment systems will need to include options for
          utilizing or disposing of the residual  by-product  of the treatment

               Even after the point source problem has been  solved,  it is
          likely that rainfall-related sources of pollution  such as urban
          runoff may cause severe stress on aquatic  life due to the heavy
          metals and toxic substances washed into the  stream.

               In terms of institutional problems, the fragmented  and small
          treatment works authorities in the area would have to join  together
          to upgrade treatment levels to meet the 1983 goals.  In  addition,
          a management agency or agencies  may need to  be designated to
          establish a nonpoint source and  residual waste management program,
          including local adoption of ordinances  to  require  "best  management
          practices" for various nonpoint source  generating  activities.


B.   Identify constraints and priorities.  Both  technical  and management
constraints on meeting 1983 water quality goals  should  be  identified.
Priorities for solving water quality problems  should  be  established.

    Example.  From a technical  standpoint,  there may  be  reaches of
    streams in the area that cannot meet  the 1983  goal.  The goal
    may not be attainable,  if a technological  solution,  for example,
    dredging sludge deposits from a river,  would cause  as  many long
    term water quality problems as allowing the  deposits to be
    naturally flushed out of the river over time.  A management
    constraint may be a lack of financial  capacity to deal with a
    long standing problem such as drainage  from  abandoned  mines.
    Priorities should focus on problems that can be most effectively
    solved within existing  technological  and economic capabilities.
    For example, renovating urban stormwater systems  may be a low
    priority due to the high capital  costs.  On  the other  hand,
    establishing a treatment works program  may be  a very high priority.
    The 208 plan should specify a number  of interim outputs such as
    service areas and treatment levels to provide  an  areawide perspec-
    tive in further facilities planning.

C.   Identify possible solutions to problems. All reasonable regulatory
and management control  methods should be  identified.

    Example.  To meet the high degrees of abatement of  industrial and
    municipal sources,  it may be necessary  to  consider  larger regional
    treatment plants or pretreatment of industrial  wastes  prior to
    discharge to a municipal facility.  However, the  technical solu-
    tion of a large regional treatment plant must  also  be  feasible
    from an institutional  standpoint.   This would  require  preliminary
    analysis of management  agency(s)  and  institutional  arrangements
    for implementing a particular technical solution.   Similarly,
    in the case of nonpoint sources,  the  overall feasibility of
    managing a particular problem should  be investigated before the
    details of possible management practices are developed.  For
    example, if improved street sweeping  is thought to  be  an option
    for mitigating impact of urban stormwater, the practicality of
    changing parking schedules should be  assessed  from  the outset.
    The regulatory measures for establishing "best management practices"
    for other nonpoint sources should also  be  identified.  The
    authority for regulating certain activities  (agricultural practices
    or mining) may not exist at the local  level, and  would therefore not
    be feasible unless enabling legislation were passed.

D.  Develop alternative plans  to  meet statutory  requirements. Alterna-
tive technical  abatement methods  for  municipal and  industrial wastes,
stormwater, nonpoint sources and  residual  waste,  for  both new and
existing sources should be combined into  areawide plans.  Comparable
alternatives for the implementation of the technical  options through
establishing waste management  programs and regulatory programs should
be identified.

     Example.  The technical  alternatives for municipal  and industrial
     wastes might induce options for regional ization of treatment
     for municipal and industrial wastes, separate  systems, or  up-
     grading existing municipal  systems.   Waste  treatment capacities
     of these alternatives should correspond to  the projected land
     development pattern in the area.  The residual  waste disposal
     options would vary depending on the choice  of  treatment systems.
     Alternative management programs  for construction, operation,
     and maintenance of the treatment works would have to be developed
     and include consideration of the financial  arrangements for the
     local  share of construction, the financing  of  operations and
     maintenance, and cost recovery and user charges.  These assess-
     ments  need only be as specific as the degree of detail undertaken
     in the  208 plan, as opposed to further facilities planning.

           Technical alternatives for managing nonpoint sources  might in-
     clude a series of alternative designs for attenuating the  runoff
     from  new urbanized areas, as well as alternative management practices
     for existing nonpoint sources in categories such as agriculture or
     mining.  The management programs for implementing the design  criteria
     for new stormwater and drainage  systems would require proper  enabling
     legislation, an agency capable of supervising the construction of
     new drainage systems, and adequate  incentives  such as tax  advantages
     for adopting the management practices.

 E.   Analyze a1ternative  plans.   The alternatives should be evaluated
 according  to the  criteria of minimizing overall   costs, maintaining
 environmental,  social, and economic values, and  assuring adequate
 management authority,  financial  capacity, and implementation feasibility
 in  meeting water  quality  and carrying out the requirements of Sections
 208(b)(2)  and (c)(2) of  the Act.

     Example.   To meet water quality  goals, the  least cost strategy for
     abating municipal sources may involve a large regional treatment
     plant.  This option  would allow  establishing a  regional approach
     to sludge  utilization through land  application.  Thus, this  option
     would be environmentally and  economically  desirable.  However, the
     option would involve constructing sewer interceptors  through un-
     developed  land, which, unless land  use controls  were  strictly
     applied, could induce further development.  This option would
      involve the  greatest institutional  change,  since it would  require
     creating authority  for regional  financing  of  treatment.


          For existing nonpoint  sources  such as  urban stormwater,
     street sweeping   might  be less  costly  than  attempting to treat
     stormwater.   However, altering  parking regulations to allow
     better sanitation would be  disruptive  to  transportation.  The
     alternative  of separating some  existing combined storm and
     sanitary sewers  could be accomplished  in  the course of upgrading
     treatment plants, and might be  the  least  cost  solution for
     combined sewer overflow.

          Adopting design standards  for  new drainage systems would
     help protect future water quality.  The costs  of these measures
     could be offset  through tax breaks.  The  feasibility of imple-
     menting these design standards  would depend on adequate staffing
     of the agencies  responsible for supervising their enforcement.

F.   Selection of  an areawide plan. The selection should be based
upon systematic  comparison  of the alternatives.

     Example.  Through a process of  public  involvement in the planning
     process, there should be general  familiarity with options for
     meeting water quality goals.  Having identified the least cost
     plan (where  cost includes economic, social  and environmental
     considerations), the units  of government  involved in recommending
     plan approval might also consider compatibility of the various
     alternative  plans with  other community goals.

G.   Plan approval. Plan review  and  approval will be based on whether
the plan demonstrates that 1983  water quality  goals will be met and
that the plan meets the requirement  of Sections  208(b)(2) of the Act.

     Example.  The plan demonstrates that  the combined measures for
     abating point and nonpoint  sources  will be  adequate for meeting
     standards.  However, to the extent  that some of the cause and
     effect relationships between nonpoint  source problems and water
     quality cannot be documented, the approval  of  the plan should be
     contingent on development of plan performance  assessment including
     an ongoing monitoring program.   The management program meets the
     requirements of  the Act for waste treatment and regulatory
     programs. However, some of  the  regulatory measures needed to
     implement the plan are  in the form  of  legislative proposals before
     local  governments in the area.   The plan  approval should be based
     on the assumption that  the  regulatory measures will become law
     within a given time period.  The state should  monitor the
     progress of  implementation  and  recommend  or enact alternative
     measures if  the  original regulatory proposals  are not adopted

     H.   Periodic  updating  of the  plan.  A  specific  procedure should be
     defined for monitoring plan effects and  developing annual  revisions
     to  the plan.

          Example.   The procedure  for  plan  updating  is that  instream
          monitoring will  be carried out by the management agency(s) to
          determine needed  plan  revision.   The state will monitor  progress
          of the management program and recommend  specific actions  needed
          to assure meeting water  quality standards.

     I.   Flexibility and Local  Initiative in  Planning and Implementation.
     A planning process based on the approach outlined above and further elab-
     orated  in these guidelines should achieve the  planning objectives of
     Section 208.   To meet  these objectives,  planning agencies  may  use
     discretion in employing any other logical planning process that
     achieves the  1983 water quality goals  of areawfde waste management
     and produces  a plan consistent with the  output  requirements of the

1.7  Planning Criteria

     As  previously stated,  the objective of 208 planning  is  to  meet the  1983
water quality goals by developing  a plan pursuant  to Sections 208(b)(2) and
(c)(2) of the Act.   The plans will, therefore, be  evaluated  by  States and
EPA in terms of their ability to achieve these objectives in a  given area.
The Act also provides certain criteria for  choosing  among the means for
achieving the 208  objectives.

     The following criteria should be  used  in the  planning process  (see
Chapter 3) and in  plan selection  (see  Chapter 12)  and will be applied by
the states and EPA in plan review  and  approval  (see  Chapter  14):

     A.   Cqsj: Effectiveness

          The Federal Water Pollution  Control Act  specifies  cost-effective-
     ness as the criteria for the  planning  and development of wastewater
     management programs, in joarticular as  those programs relate to
     municipal treatment works and controls of combined sewer overflows
     and storm sewer discharges.

          EPA has  defined cost-effectiveness  analysis as  a systematic
     comparison of alternatives to identify the  solution  which  minimizes
     total costs to society over time  to  reliably  meet  given goals and
     objectives.  Since Section 208(b)(2)(E)  specifies  that  the plan
     should document the economic, social,  and  environmental impact of
     plan  implementation, the local  economic  impact  (in addition to
     resource costs) must be included  in  the total costs  to  society.
     Thus  the total costs to society  to  be  minimized should  include:

           . resource costs
           . economic costs
           . social costs
           . environmental costs


     In the case of 208 planning, effectiveness refers to meeting the
1983 goals of the Act while providing for the highest practical  degree
of technical  reliability in the pollution control  alternative that
is chosen.

B.  Implementation Feasibility

     Explicit criteria for determining adequacy of the management
provisions for carrying out areawide waste treatment management
are not provided in the Act.   This guideline sets  forth the
following criteria further elaborated in Chapter 3, for1evaluating
implementation feasibility of the management provisions of a .208

     .  adequate legal authority
     .  adequate financial  capacity
     .  practicability
     .  managerial capacity
     .  public accountability

C.  Pub!ic Acceptance

     Since the success of a 208 plan depends on its acceptance
by affected units of government, the acceptability of the plan
to the general public and elected officials in a 208 area should
also be regarded as a basic planning criterion.  The application of
this  criterion  in the planning process is further discussed
in Chapter 3.

                               CHAPTER 2

2.1  Introduction
     This chapter summarizes the relationships  between  planning  activities
pursued under Section 208 of the FWPCAA and (a)  water pollution  control
measures authorized by other sections of the Act;  (b) EPA programs  de-
signed to protect other environmental  media (e.g.,  air)  and  to promote
environmentally sound practices (e.g., solid waste  disposal); and  (c)
other areawide management programs.

2.2  Relationships Between Section 208 Planning  and Other FWPCA  Provisions

     A.  Relationship Between 208 and 3Q3(e) Basin  Plans

         303(e) basin plans constitute the overall  framework within
     which 208 plans are developed for specific  portions of  a basin
     with complex pollution control  problems.  Basin plans:  1) provide
     water quality standards and goals; 2) define  critical water quality
     conditions; 3) provide waste load constraints; and 4) may help
     delineate 208 area boundaries.   The results of 208 planning will
     constitute an integral  part of these basin  plans.   208  plans must
     be consistent with basin plans,  and should  be  annually  certified
     as so by the governor.

     B.  Relationship Between 208 and 201  Facilities Plans

         ° 201  Facilities Planning

              Facilities planning consists of the  plans  and  studies prerequi-
         site to the award of grant assistance  for  detailed  design  and
         construction of publicly-owned treatment  works.  In the absence
         of a completed and approved 208 plan,  the  facilities plan  must
         encompass the following features:

              1.  Description of the planning area.

              2.  Selection of service areas.

              3.  Selection of overall treatment systems, including
              location, capacity and configuration  of all facilities,
              treatment levels, and preliminary  identification of  type
              of treatment and method  of disposal  of residual wastes.

              4.  Analysis supporting the selection in  2 and 3 based on
              identification, evaluation and cost-effectiveness  comparison of

     5.  Preliminary designs and studies  related to  the  selected
     wastewater treatment systems,  including sewer evaluation
     surveys, detailed surface and  subsurface investigations  of
     sites for proposed facilities  preliminary designs and detailed
     cost-effectiveness studies of  individual proposed facilities,
     an environmental  assessment, and other requirements set  forth
     in Section 35.917-1  of the Title II  regulations.

° 208 Areawide Planning

     Areawide planning sets forth a comprehensive management  pro-
gram for collection and treatment of wastes and control  of pollution
from all point and nonpoint sources.  Control measures for abating
these sources utilize a combination of traditional structural
measures together with land use or  land management practices  and
regulatory programs.  These measures are  implemented by  the areawide
management agency or agencies.  An  initial  areawide  plan is
developed over a prescribed planning period and, thereafter,
updated and approved annually.

     The portion of the 208 plan devoted  to future construction
of publicly-owned treatment works  should  select and  describe
planning and service areas and treatment  systems, and  provide
supporting analysis for the selection. The 208 planning require-
ments, therefore, overlap with the  201 planning requirements
described in points 1-4 in the previous section.

o Area Coverage^

     An areawide plan covers a large area with complex water  quality
problems, generally an entire metropolitan area.  A  facilities plan
focuses on a complete system or systems of municipal  treatment
works extending over a geographic  area large enough  to consider
adequately the cost-effectiveness of alternatives.   An areawide
planning area generally includes more than one facilities planning
area, depending on hydrologic and  geographic conditions.

o Coordination and Funding

     The agency's policy on relationships between 201  and 208 planning
in the same area during the period  before final approval of a 208
plan is as follows:

     1.  New 201 facilities plans will be started and carried out
     as provided in the state priority list.

     2.  The scope and funding of  201 facilities planning will be
     sufficient to collect data and conduct all analyses necessary
     for expeditious completion of  the 201  plan.

     3.  Facilities and areawide planning will be coordinated
     closely to avoid unnecessary  fragmentation and  duplication,
     potential conflicts and excessive planning costs.   Data


     and analytical work will be shared, but completion of 201
     plans should not be dependent on the 208 planning process.

     4.   Facilities plans that are completed and approved will
     continue through the Step 2 and 3 stages after timely
     review and comment by the 208 planning agency.

o Interim 208 Outputs

     Interim outputs are necessary to promote the desired
areawide consistency and compatibility in subsequent facilities
planning.  The following interim outputs must be completed within
nine (9) months unless the EPA Regional Administrator grants time
extensions upon the recommendation of the 208 planning agency and
the state.

        Service area delineation for municipal wastewater
        treatment systems throughout the designated area

        Existing population and land use and projected
        population and land use for the twenty (20) year
        planning period

        Projected waste loads and flows generated for each
        service area corresponding to the existing and projected
        population and land use

        Revision (if any) of the waste load allocations

     Interim outputs need to be emphasized in the planning
process to ensure that activities and decisions on the part
of an areawide agency are directed at timely inputs to other
planning and construction programs.  The areawide planning
agency will need to place high priority and sufficient effort
on providing these and other needed interim outputs according
to the schedule included in the approved work plan.  Guidance
on developing these outputs is contained in Chapters 3 and 5
of this guideline.

     Upon completion of the interim outputs, the 208 planning
agency shall submit them to the state for review and approval
and transmittal to the EPA Regional Administrator for con-
currence as fulfilling partial requirements of 208 planning.
In some instances, further areawide planning may reveal that
the interim outputs should be modified.  Such modifications and
associated justifications should be promptly brought to the
attention of the state and affected facilities planning agencies.
(This should occur in the normal process of having close and
continuing coordination between states, areawide and facilities
planning agencies).  The state shall determine the feasibility
and practicality of incorporating these modifications in the
facilities planning and obtaining concurrence of the Regional


           After interim outputs  are developed  and  approved  by  the
      state and EPA for a 208 planning  area,  the  relationship between
      201  and 208 planning in that area will  be the same as  that
      described under the section on "coordination  and  funding" above
      except that:

           ].  New facilities planning  will  be  consistent  with  the
           approved interim outputs of  the  208  plan.

           2.  The scope and funding of new 201 planning should not
           extend to developing a justification for the interim
           outputs.  This justification already will  be available
           from the 208 planning  process.

      o Approved 208 Plan

           The following policy on program  relationships should be
      carried out after the areawide plan has been  completed and
      approved  and the agency or agencies  identified to construct,
      operate and maintain the municipal wastewater treatment
      facilties required by the plan:

           1.  All  facilities plans underway at the time of  approval
           will be completed by the agency  which  received  the Step 1
           grant.  The planning effort  will  continue as before  approval
           unless the analysis in the approved  208  plan clearly
           justifies a change in  required treatment levels or alterna-
           tive approach on the basis of lower  costs or major changes
           in environmental impact.

           2.  The scope and funding of new facilities  planning will
           be sufficient to supplement  the  data and analysis in the
           208 plan to the extent necessary to  provide  a complete
           facilities plan as required  by Section 35.917 of  the Title  II

           3.  New grants for 201 plans will  be made only  to the manage-
           ment agencies designated in  the  approved 208 plan.   New
           facilities planning will be  consistent with  the approved
           208 plan.

    Relationship Between 208 Plans and  402  Permit Program

     The 402 National Pollutant  Discharge Elimination System Permit
Program is designed to ensure that pollutant dischargers will not
exceed prescribed levels.  The permit system provides an essential
tool for implementation of the 208 plans within the framework of
the 303(e) basin plans.  No permits may be  issued for point  sources
which are in conflict with approved 208 plans since they automatically
become part of the overall 303(e) basin plans.  The 208 planning agency
should assess current permit requirements and,  when needed to achieve  the
1983 goals, recommend appropriate conditions for  future permit  issuance.


2.3  Relationships  Between  208  Planning and Other EPA Programs

     A.   Relationship Between 208  Planning and Air Quality Programs

          Sections  107,  108, 109 and  110 of the Clean Air Act provide
     for the establishment  of ambient air quality standards, the parti-
     tioning of the Nation  into Air Quality Control Regions, and the
     preparation of implementation plans to show how the attainment
     and maintenance of  the standards in each region will be accomplished.
     To  simplify planning for the  maintenance of standards, many air
     quality control  regions are also partitioned into Air Quality
     Maintenance Areas pursuant to 40 CFR 51.12(f).  States are respon-
     sible through  State Implementation Plans (SIPs) for the attainment
     and maintenance of  the air quality standards.

          During the 208 planning  process, planners should acquire a
     general  familiarity with the  requirements of the applicable SIP
     in  the Air Quality  Control Region(s) in which the 208 area is
     located.   If any portion of a 208 area is located within an Air
     Quality Maintenance Area,  planners should coordinate their
     activities with the Air Quality  Maintenance Area Plan development
     and implementation  process.   This coordination should include:

          1.   Use of a consistent  data base, especially growth projections;

          2.   Promotion  of  complementary air and water quality management

          3.   Assessment of 208 plan  implementation on air quality,
              especially the primary  and secondary effects of treatment

          4.   Review by  the appropriate agency(s) to ensure that 208 plans
              are consistent with  applicable portions of the State Imple-
              mentation  Plans.  It would be advisable to arrange periodic
              reviews rather than  relying on a single review at the end
              of the planning process.

          Planners  should also  review the applicable state procedures
     for implementing and enforcing Section 111 (Standards of Performance
     or  New Stationary Sources) and Section 112 (National Emission
     Standards for  Hazardous Air Pollutants) of the Clean Air Act to
     ensure compatibility with  208 planning.  These standards may be
     important because of their impact on decisions, for example, concerning
     sludge incineration and the   location of facilities generating air

     B.   Relationship Between  208  and  Solid  Waste  Programs

          Section 208(b)  calls  for regulatory  programs over all dischargers
     as  well  as processes to control disposition of  residual waste and
     disposal  of pollutants on  land or in  subsurface excavations.  Thus
     solid waste and sludge disposal regulation is needed in a  208 program.
     Further information  on regulatory programs is contained in Chapter 7.
     Information on sludge utilization or  disposal is contained in
     Chapter 5.

          In developing  programs for dealing with  water  pollution,from
     solid waste and residual  disposal,  state  plans  for  solid waste manage-
     ment should be examined for recommended organizational and technologi-
     cal  solutions pertaining  to the 208 area.  Local agencies  having primary
     responsibility for  regulating and implementing  solid waste management
     controls should be  identified. The effects of  the  control program
     should be considered and  appropriate  measures taken in cooperation
     with local agencies  to ensure compatibility between the water quality
     management provisions of  208  planning and solid waste management within
     the area.

2.4  Relationship Between 208  Planning and Other Areawide^ Management Programs

     The land use aspects of 208 planning  provide  a  direct linkage with
other areawide planning  efforts within the area including those supported
under the HUD 701, water and sewer, and flood  insurance  and disaster pro-
grams, DOT transportation plans and NOAA coastal zone management  plans.
208 planning should be viewed  as providing the water quality component
of the comprehensive plan for  the  area.  Other area  planning activities
should be considered to  ensure  that their  impact on  water quality is
incorporated into the 208 planning process and that  208  plans are consistent
with these activities.  This will  facilitate the development of a coordinative
relationship between 208 agencies  and  related  agencies which should be carried
over into the 208 implementation phase.

     Special  attention should  be given to  related  plans  which are being
developed concurrently with  the 208 plan.  It  is likely, for example, that
many areas will be preparing  land  use  elements under the HUD 701  program
and/or coastal zone management plans.   These types of plans will  be of
particular importance since they will  be examining issues related to
development, land use, and water quality.  The 208 planning agency  should
establish procedures to  ensure that such plans are consistent with  the  208

                               CHAPTER 3

                            PLANNING PROCESS
3.1  Purpose

     The purpose of the planning process is to systematically  evaluate
alternative means of achieving water quality goals  and to  formulate  a
plan that can be implemented by a 208 management agency.   The  planning
process must integrate technical needs for pollution  abatement and
management arrangements capable of implementing the abatement  measures,
and provide for public participation in plan development.

     The technical  planning portion of the planning process  involves
identifying the priority water quality problems of  the area, recognizing
any constraints in dealing with the problems,  and developing alternatives
to achieve water quality goals.  The alternative plans may then be
evaluated according to the planning criteria discussed in  Chapter 1.

     Management planning, which concerns selection  of a management agency
or agencies and development of appropriate institutional arrangements
for plan implementation, should be conducted concurrently  and  in coordina-
tion with technical planning.   Management planning  should  identify water
quality management problems, and analyze the capability of existing  agencies
and arrangements to carry out the regulatory and management  requirements
of Section 208.  Institutional  problems, lack  of authority,  or lack of
financial capacity for meeting Section 208 requirements should be
identified.  Alternative means to acquire proper authority,  financial
capacity and effective institutional  arrangements for plan implementation
should be developed.  Finally,  alternative management agency(s)  and
institutional arrangements should be evaluated and  a  single  alternative
selected according to criteria discussed in this chapter.

     Developing alternative technical  and management  plans and selection
of an areawide waste treatment management plan require public  participation
throughout the planning process.  Public participation requirements and
means for ensuring adequate participation at each stage in the planning
process are discussed in Chapter 10.

3.2  Goals and Policies of the Act and Other Mater-Related Goals of  the
     Planning Area

     To complement the 1983 water quality goals of  the Act,  provisions
of Title II of the Act provide for additional  aspects of water quality
protection such as:

          .   Water conservation and resource utilization  through
             wastewater reuse or recycling;

             Management of  residual  waste;

          .   Multiple use of wastewater treatment  systems and
             associated land?; for such  purposes  as water  supply,
             recreation, aesthetics,  and fish and  wildlife habitat;

             Protection of ground water quality

Any other water-related goal si of the  208 planning  area, such as provision
of adequate water supply and programs for land or  water resource  management
should be identified for consideration  in development  of  the plans.   These
related goals should be recognized in the planning process and should be
incorporated into the plan  to the extent that their achievement would not
reduce the cost-effectiveness of the  water quality management measures.

     Finally, the results of the planning process  should  be compatible
with other plans for the 208 area, such as those discussed in Chapter 2.

3.3  Technical  Planning

     A.  Purpose

          The purpose of technical planning is to  develop a coordinated
     water quality management strategy  for areas that  may not be  able to
     meet 1983  water quality goals through application of base level
     technology.  The strategy may be a combination of (1) municipal
     wastewater treatment systems, (2)  industrial  wastewater pretreatment
     or treatment, (3) residual waste management,  (4)  urban stormwater
     management, and (5) nonpoint source management.   Implementation
     of these abatement measures is to  be achieved through regulatory
     measures such as local  ordinances, capital  construction of wastewater
     treatment facilities,  arid improved management of  stormwater  systems.

          Since technical planning will  be shaped  by the  particular
     problems of an area, the procedures in this guideline are offered
     primarily as an organizational  framework for  planning.  Emphasis
     accorded each part of the framework"will  be largely  a matter of
     planning judgment.  In developing  a water planning management
     strategy,  however, particular attention should be paid to pollution
     controls other than traditional, capital  intensive structural methods.

          The technical planning process should  be designed so as to  place
     the greatest emphasis  on water quality problems that are solvable
     with existing technology and sources of funding.  The water  quality
     problems that should receive the greatest priority initially are
     municipal  and industrial point source problems, and   nonpoint source
     problems that can be dealt with  through better management practices
     and future stormwater systems that can be better  designed.   Lower

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and Other Related Water
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priority should be placed on nonpoint source and stormwater problems
that require large capital investments for their solution.   For each
type of water quality problem, however, priority attention  should be
placed on regulatory approaches which will help prevent problems
from occurring and thereby lessen the need for remedial  pollution

     The technical planning approach in this guideline is  based on
the Section 303(e) basin planning methodology; a number of  cross-
references are made to the basin planning guidelines  to provide
detail on common procedures.  However, since existing basin planning
is concerned with short-term goals—meeting existing  water  quality
standards and effluent limitations required by July 1, 1977--H is
necessary to expand the scope and detail  of the 303(e) basin planning
methodology to reflect revision to water quality standards, effluent
limitations required by July 1, 1983, nonpoint source planning  and
controls, regional approaches to sewage treatment,  sludge  disposal,
and ground water pollution.

B.  Flow Chart

     Many of the steps shown in the flow chart correspond  to similar
planning steps undertaken as part of the Section 303(e)  basin plans.
The following text elaborates on the meaning of the flow chart  and
discusses aspects of the Section 303(e) planning methodology which
may require greater emphasis in developing a 208 plan.

C.  Inputs

     1.   Information from 303(e) Basin Plans and Facilities Plans

         Available information from 303(e) basin plans and  facilities
     plans provide the basic inputs for 208 planning.   In cases in
     which data necessary for developing an adequate  208 plan are
     not available in the 303(e) basin plan, additional  data should
     be obtained.

         Facilities plans under Title II  of the Act,  or preceding
     facility plans under 18 CFR and Sec.  3(c) of the Water Quality
     Act of 1965, should be coordinated with 208 planning as stated
     in Chapter 2.

     2.   Information from NPDES Permits

         Information on discharges into navigable water available
     through the National  Pollutant Discharge Elimination System
     (NPDES) should be consulted.   Terms and conditions  of  any
     permits already issued to dischargers should be  accounted  for
     in formulating pollution control  strategies for  the second
     round of permits.


 3.   Related Water Management  Information

     Much of the information necessary  for  developing an effective
 208 plan may be available  from related water management programs
 and studies.  Those which  may be especially useful  include:

     .   Basin Studies Under the Water  Resources Planning Act

        Urban Studies of the U.S. Army  Corps of Engineers

        Flood Plain Information Studies of  the  U.S.  Geological
        Survey and the U.S. Army Corps  of Engineers

     .   State and Local  Water  Supply Studies and Data

 4.   Goals Other than Water Quality

     While the 208 plan is  concerned with water quality, selection
 of the final plan nay affect  other community goals.  It is there-
 fore important to establish an understanding of community goals
 and plans,  especially with respect to  housing,  economic develop-
 ment,  transportation, education,  recreation, other  environmental
 goals, etc.  The relationship between  these goals and water
 quality and other environmental  goals  should be understood from
 the outset of the planning process.   Public participation in  the
 planning process is an effective way  of defining the relationship
 between community goals.

 5.   Technical Information

     A  bibliography of technical  studies related to  the various
 parts  of this guideline is provided at the end of this document.

Specification of Standards

 1.   Identify Water Quality Problems and Specify Standards for the
     Planning Period

     Since the objective of 208 planning is to  achieve  the 1983
 water  quality goals of the Act, an assessment  should be made  of
 existing and projected water  quality  problems  which must  be  solved
 to meet those goals.  Water quality standards  which correspond
 to the goals should then be specified. It is  the responsibility
 of the states to sst standards and EPA to  review and approve
 standards.   However, the 208  agencies  can  develop proposals  for
 water  quality standards revision.

     a.  Problem Assessment
          An initial  assessment of water quality conditions
     should be made on the basis of existing data and  a
     general familiarity with the planning area.   Knowledge  of


    industries, waste treatment,  nonpoint source  pollution
    generation, land use, and receiving  water quality  will
    aid in this evaluation.   This evaluation  should  not  be
    limited to well-documented conditions for which  extensive
    data exist, nor only to  existing  conditions,  but also
    should consider trends and future activities  which would
    affect water quality.

    b.  Specification of Standards

         Water quality standards  must be reviewed by the states
    at least once during each three-year period beginning with
    the passage of the Act.   Upon review of  standards, recom-
    mendation for their revision  may  be  considered and adopted.
    The 303(e) basin plans will  then  be  revised accordingly
    during the next basin plan review.

         Since 208 planning  is concerned with pollution  control
    over a 20-year planning  period, control  levels should be
    based on the water quality standards applying over the
    planning period.  In order to develop 208 plans, it  is
    necessary to make assumptions concerning  the  standards
    that would be adequate to meet the 1983 water quality
    goals.  Any such assumptions  should  be made only after
    consultation with the state and should be made explicit
    in the plan.

2.   Construct an Inventory of Existing and Potential Discharges
    and Pollutant Sources

    a.  Point Sources

         Discharge inventories provided  in relevant  basin
    plans should be  reviewed and  compared with information
    provided by the  National  Pollutant Discharge  Elimination
    System (NPDES) in order  to identify  and locate all signifi-
    cant dischargers.   Special  attention should be given to
    adequacy of information  on storm  and combined sewer
    discharges as well  as any point source discharges  to
    ground water.  If necessary,  additional monitoring should
    be undertaken to update  information  already available.

    b.  Nonpoint Sources

         It is not anticipated that a complete nonpoint  source
    inventory can be constructed  at this stage in the  planning
    process.   However,  any nonpoint source information available
    should be assembled as an aid in  identifying  monitoring
    and modelling needs.   Further nonpoint source identification
    should be carried out through monitoring  and  use of  generalized
    prediction techniques (see Chapter 6).


3.  Prioritize Planning and Choose Design Conditions
    and Techniques for Water Quality Analysis

    Further analysis of water quality problems  and  establishment
of priorities require both an identification of conditions  causing
introduction of pollutants into surface and ground  water and  a
description of the physical, chemical,  and biological  processes
which determine the resultant water quality.

    Surface waters may be classified as flowing streams,  tidal
rivers, estuaries, coastal zones,  lakes,  and reservoirs.  Ground
water represents a separate category.  Since each classification
has unique characteristics, the transport and  behavior of pollu-
tants should be understood in the  context of each type of water
body.  Within each classification, variation in the action  of
pollutants may be caused by such factors  as topography,  geology,
hydrology, and meteorology.

    In addition to classifying water bodies, sources  of pollution
can be classified as follows:

         . continuous or seasonal  point source
           (example:  industrial source discharging
           continuously or on a seasonal  basis)

         . intermittent point source
           (example:  storm and combined sewer
           discharge after rainfall)

         . nonpoini; source
           (example:  runoff from  agriculture,  silvi-
           culture, construction,  and mining)

    a.  prioritize Further Planning

         Priorities for planning should be established so that
    further analysis will focus on those pollution  problems that
    can be most effectively solved by intensive management  or
    with existing technology, and  sources of funding.  At this
    point in the planning process, the level of detail of analysis
    for the different water bodies and sources  of pollutions  should
    be established.,  Prioritization should serve as a guide in
    selecting the sophistication of analytic techniques, need for
    additional data collection, and need to consider  pollution
    control methods and management alternatives to  implement the
    controls.  In general, the level of detail  of analysis  should
    correspond to i;he information needed to resolve pollution
    problems.  High priority problems that can be resolved  with
    existing resources should be analyzed in  sufficient detail
    to enable cost-effectiveness comparison of reasonable alterna-
    tives for resolving the problems.  Controls that  cannot be


    immediately applied due to lack of availability  of funds
    (treatment of stormwater,  remedial  nonpoint source controls,
    etc.) should be assessed in more general  terms.   The  nature
    and extent of such problems, their impact on water quality,
    and the rough costs of remedial  controls  should  be assessed.
    However, any techniques that can be used  to better manage
    existing stormwater and nonpoint source  problems without
    requiring large capital expenditures should be carefully

b.  Choice of Design Conditions

    Design conditions are those stream flow  conditions which
serve as the basis for determining if water  quality  standards
can be met.

    A range of flow, temperature, meteorological, and seasonal
conditions should be considered in choosing  design conditions.
In general, for point sources, continuous  discharges present
the worst pollution under low  flow,  dry weather conditions.
For nonpoint sources transported in runoff,  worst conditions
will  be rainfall-related and may occur under  high flow conditions.

    Traditional  stream analysis often makes  use of a low
flow-high temperature design condition (e.g.,  once in 10
year, 7 day low flow).  This flow condition may be appropriate
for a steady-state stream analysis involving  constant rates of
point source pollutant discharge.  However,  choice of design
flow conditions for point source analysis  should take account
of such factors as ice cover and seasonal  point source discharge
which may cause more severe stress on life in the stream  than
occurs at low flow.

    Wet weather flow conditions may be appropriate for analysis
of nonpoint and such intermittent point source discharges  as
storm sewers.  Such factors as intensity and  duration of  rainfall,
time since previous rainfall,  pollutant accumulation rates, and
stream flow previous to rainfall should be considered in  selecting
design conditions for nonpoint source analysis.

    (1)  Dry Weather Conditions

         An analysis of the severity of pollution problems
    associated with dry weather conditions should be conducted.
    Dry weather flow conditions which are  critical for main-
    taining biological life in the waters  should be  noted; a
    design condition for dry weather should  be chosen; and its
    average duration and frequency of occurrence should be

         (2)  Wet Weathe^ Conditions

              A design  condition  for wet weather  flow conditions
         should be  chosen  for  purposes of waste loads generated under
         given wet  weather  conditions.  The  flow  condition should be
         specified  in terms of rainfall intensity,  duration, and
         antecedent conditions specified  (e.g., 1/2 inch rain per
         hour, for  two  hours,  after two weeks of  dry weather).

     c.   Select an  Analytic Model  to Relate  Source  Loads to Water

         Selection  of an analytic  model for  predicting  in-stream
     water quality  from source load information will be influenced
     by the type of sources and conditions of water quality for
     which predictions  are  undertaken.  A number  of analytical
     techniques exist for  a wide  spectrum of conditions.  The best
     technique is the one  which can sufficiently  relate the resultant
     water quality  to its  causes  in the simplest  manner.  Because of
     the 208 planning time  constraint, any proposed analysis should
     be based on currently  available algorithms,  techniques, and
     models.  The properties of different analytic  models are
     discussed in Sec.  3D3(e)  guidelines.

         Any analysis of the relationships of nonpoint  or wet weather
     sources to water quality  should focus on estimating a single gross
     allotment (target abatement  level) for  all nonpoint sources con-
     tributing to a given  water quality segment and estimating the nature
     and magnitude  of the  loads associated with each category of
     nonpoint sources.   Since  the  208  regulatory  and management program
     for nonpoint source problems  is based on establishing Best Manage-
     ment Practices (see Chapter  6) from  target abatement levels and
     relative loads and since  the  time available  for plan development
     is limited, complicated receiving water modeling to establish the
     cause-effect relationships between specific  nonpoint sources and
     receiving water quality will  not  be  appropriate.

4.  Data Collection

     a.  Existing Data

         Existing data should  be  evaluated in terms of  its adequacy
     for solving priority  water quality problems  through application
     of the simplest ana'ytic  techniques  possfble.   Since the initial
     planning period is short, every effort  should  be made to make
     use of existing data  before  additional  data  collection is considered.

         All relevant existing data should be gathered  and summarized,
     by type of measurement, frequency, time period, and location.
     Several types  of data may be required depending on the analysis:


          .  Hydro logic
          .  Hydraulic
          .  Meteorologic
          .  Point Source
          .  Nonpoint Source
          .  Surface and Ground Water Quality

          If water quality problems  are  characterized  by  relatively
     slow changes over time,  as in  the case of eutrophication and
     salt water intrusion, they may  require long-term  data.  Other
     problems, such as dissolved oxygen  depletion,  which  may change
     in severity over very short periods of time, will  require  large
     amounts of data over a short time period.  Finally, the data
     inventory should be used to define  calibration and verification
     periods, as well  as the  need for additional  surveillance and

     b.  Surveillance and Monitoring

          Due to the emphasis of 208 planning  on  nonpoint sources,
     and due to the adoption  of critical  water quality conditions
     that encompass a range of stream flow conditions,  it is quite
     possible that existing data provided in Section 303(e) basin
     plans will be insufficient to  enable prediction of whether
     segments will meet standards under  the assumed design conditions.
     However, in the case of  nonpoint sources,  only data  necessary to
     establish Best Management Practices are needed (see  Chapter 6).
     But it will likely be important to  establish a continuing
     monitoring  program (as  discussed in Chapter 6.4)  to assess
     the effectiveness of Best Management Practice  implementation
     in achieving and maintaining water  quality goals.

          In the case of developing  a nonpoint source  monitoring
     program, it is important to determine priorities  for nonpoint
     source detection.  Various approaches for analyzing  the extent
     of the nonpoint source problem  are  discussed in Chapter 6.

5.   Calibration and Verification

     Calibration and verification are essential steps  in  the develop-
ment of a valid predictive model, capable of describing water quality
under the varying conditions  of stream flow, temperature, and waste

     The data inventory should provide information  useful  for cali-
bration and verification purposes.   The  data collected through  the
monitoring and surveillance program  should supplement  and strengthen
the data base.

     The calibration procedure should determine  the  value of  the
coefficients in the analytical  model.   These  values  should  then
be used to simulate a previous condition,  event, or  time period,
which is independent from the  conditions  used for  calibration.

     The interpretation of analyses  conducted for  various conditions
will  depend in part on the results of the  verification  and  degree
of confidence which exists in  the  simulation  of  proposed alternatives.

6.  Projections

     To plan waste treatment and pollution control over a 20-year
period requires assumptions about  population, employment, and  land
use.   Based upon those assumptions and estimates of  the wasteload
generation characteristics of  different activities,  future  pollution
control  needs can be projected.

     a.   Population, Employment, and Land  Use Over the
         Planning Period

          Estimates of the existing  population,  employment, and
     land use in the basin should  be assembled as  a  basis for
     assessing existing patterns of  the generation of pollutants
     and as a basis for projecting the amount and  spatial distri-
     bution of future waste!oads.  These  projections should cover
     the next 20 years in five-year  increments.  Particular emphasis
     should be placed on the effect  that  implementation of  the 208
     plan, local growth policies,  plans for attainment  and  maintenance
     of air quality, and other regional plans for  transportation,
     solid waste management, water supply, or public investment may
     have on historical trends of population, employment, and  land use.

          Population data are  available from  the Bureau of  Economic
     Analysis (U. S. Department of Commerce). They  should  be  updated
     with the most recent demographic and  economic projections
     developed by the Bureau of Economic  Analysis  (U. S. Department
     of Commerce) and the Economic Research Service  (U. S,  Department
     of Agriculture) and with  projections  used as  a  basis for  state
     planning for air quality  management.   In general,  the  SERIES E
     projections developed by  BEA  or comparable  projections developed
     by the state should be used as  overall growth projections for the
     planning area.  The use of any  projections  that deviate  signifi-
     cantly from BEA should be justified.   BEA projections  are available
     for states, BEA economic  regions, Water  Resource Council  Regions,
     and for Standard Metropolitan Statistical Areas, all of which
     generally include more than a single county.  If it is necessary
     to disaggregate BEA projections, the assumptions made  in  the
     disaggregation process should be made explicit. Historical  trends
     of county population and  employment  data are  available upon  request
     from BEA.

          Sources of information on  existing  and projected  land  use
     (shown at a level of detail adequate for relating  land use  to
     water quality analysis) are discussed in Chapter 4.


     b.  Determine Waste Loads Over the Planning  Period

          By using data on existing population, employment  and
     land use, as well  as monitoring information,  a  materials
     balance for each significant pollutant should be  constructed
     to relate instream water quality to pollution generation and
     transport where possible.  In the case of nonpoint  sources,
     a materials balance may be based on average  factors for
     wasteload generation per unit of area  or  unit of  activity,
     or upon data gathered through intensive monitoring, depending
     on the nature of the problem.   (Refer  to  Chapter  6).

          By utilizing the baseline projections and  factors of
     wasteload generation per unit ot area  or  unit of  activity,
     future waste loads may be projected for increments  of  five
     years, covering land areas and sources such  as  residential,
     commercial, industrial, and nonpoint sources.   Disaggregation
     into more specific land areas and source  categories should
     be undertaken to cover each category for  which  controls
     alternatives are considered.

          These wasteload estimates and projections  may  be  related
     to the land use plan for the area so as to show existing and
     projected wasteload generation for different land uses  (see
     Chapter 4).

7.   Segment Analysis

     Basin plans provide a system for classifying  waters according
to whether base level effluent limitations  required  under the Act
will be sufficient to meet the water quality standard  in a  particular
segment of a stream.  Where this is the case the  segment is classified
as "effluent limited";  where higher levels  of  abatement  are needed  to
meet the water quality standard, the segment is classified  as "water
quality limited."

     It is expected that most stream segments  in  urban industrial
areas undertaking 208 planning will  be classified water  quality limited
at the present time.  However, the following factors may influence
whether this classification will  be appropriate in the future:
(1) the stringency of the standards adopted to meet  1983 water
quality goals; (2)  the change from effluent limitations representing
Best Practicable Treatment for point sources and  secondary  treatment
for municipal  treatment works to effluent limitations  representing
Best Available Technology for point sources and Best Practicable Waste
Treatment Technology; and (3) the wasteload increases  projected for
the area.  Based on an assessment of these  factors,  208  planning
should determine in which segments effluent limitations  are sufficient
to meet standards and in which segments higher degrees of abatement
would be necessary to meet standards.


a.  Effluent Limitations Segment Analysis

     In any segments classified as  effluent limited,  appli-
cation of Best Practicable Treatment is  required  of all  point
sources, other than publicly-owned  treatment works, by
July 1, 1977, by which time publicly-owned  treatment  works
are required to apply effluent limitations  based  on secondary
treatment.  By July 1, 1983,  point  sources  other  than publicly-
owned treatment wor
     It should also be noted that the total  maximum daily
load to a stream segment is the sum of all  individual
discharges.  In some cases, the total  maximum daily load
(consistent with meeting water quality standards)  can  be
determined without specifying the location  and amount  of
each individual discharge to the segment.   In other cases,
due to the characteristics of the water body and the
reaction and decay of pollutants in the water, the
total maximum daily load must be defined as  the sum of
individual discharges at given points in the segment.

     Total maximum daily load calculations  should  be
differentiated according to stream flow conditions.  For
each pollutant, a maximum allowable daily load should  be
specified for (1) dry weather conditions and (2) wet
weather conditions.

     In calculating the maximum allowable daily load of
pollutants, a gross allotment between point  sources and
nonpoint sources should be determined for each design
flow condition.  The allotment for intermittent point
and nonpoint sources should be used to determine target
abatement levels for various categories of  nonpoint
sources. (See Chapter 6.)

(2)  Select eligible sets of wasteload reduction
     consistent with options

     The wasteload allocation procedure involves calcula-
tion of the waste reduction needed from each continuous
point source discharger to meet the water quality  standard.
Eligible sets of wasteload allocations should be chosen
from the abatement options for continuous point sources.
(See Chapter 3.3.D.8.)

     Refer to 303(e) guidelines for a basic  explanation
of wasteload allocation procedure.  The following  are
special considerations for determining wasteload alloca-
tions in complex urban industrial  areas:

     .  The number of alternative sets of wasteload
        allocations should be sufficient for thorough
        comparison of alternative means of achieving
        water quality standards according to the criteria
        of cost-effectiveness.

     .  In general,  continuous  point source  wasteload
       allocation will  be based on the low  flow  condition.
       Nonpoint source  and intermittent point  source  target
       abatement levels will  be based on the incremental
       load resulting from rainfall-related flow conditions
       from nonpoint sources,  when point sources have been

     Calculations of wasteload reduction for intermittent
point and nonpoint sources should be made in order  to
determine how best to meet target wasteload reductions
for these sources.   Methods for predicting  wasteloads
from these sources are  discussed in Chapter 6.   The purpose
of these calculations is to choose the Best Management
Practices for intermittent point and nonpoint  source
categories from the available  options (see  Chapter,
rather than to assign a quantitative load reduction to
individual dischargers.  Thus, the calculations  should
be made for categories  of sources and should be  based on
best estimates of loading from these sources.

(3)  Test sets of wasteload reductions to determine whether
they enable meeting standards

     The analytic model discussed earlier in this chapter
should be used to determine whether wasteload  allocations
for continuous point sources enable meeting standards.   For
a discussion of the tolerance  level  to be used in that  pre-
diction, refer to Section 303(e) guidelines.   The choice of
a tolerance level and the rationale for that choice should
be explicitly stated.

     It is not necessary and probably not feasible  to
attempt to model the receiving water impact of these  load
reductions, as this may require highly sophisticated
analytic modeling and more extensive data requirements
than can be met during the 208 planning period.   It is
only necessary to determine whether the predicted load
reductions for intermittent point and nonpoint sources
enable meeting the single^ gross allotment or target
abatement level for these sources.

     Because some proportion of wasteloads  may be reserved
to allow for future growth in  the area, it  is  important
that the wasteload allocation  process be undertaken in  close
coordination with agencies possessing land  use planning and
control authority.  Management of new wasteload discharges
in the area should be carried out through the  regulatory
program for implementing the plan (see Chapter 7).

8.  Determine Alternative Subplans of Treatment,  Control  and  Flow
    Reduction Consistent with Eligible Wasteload  Reductions

     Wasteload reduction sets should be prepared  in  conjunction with
detailed development of alternative controls  for  point  and nonpoint

     ChaptersS and 6 provide a framework for  developing pollution
control  options for point and nonpoint sources.   The alternatives
that are presented as the result of detailed  planning for point and
nonpoint sources are referred to as subplans.

     In order to develop subplans it is helpful to examine the
patterns of existing and projected wasteloads  by  display on land
use maps.  Alternatives for point and nonpoint source control, and
means to implement these controls may be developed through an
examination of alternative land use and land management practices.
(See Chapter 4.)

     Subplans may be broken into three major  types according  to
the category of sources and design conditions  to  which  they apply.

     a.   Continuous or Seasonal  Point Source  Subplans

          Continuous point sources are municipal  treatment works
     and industrial point sources.  Some industrial  point sources
     may discharge on a seasonal  basis.   Detail on preparing  this
     subplan is provided in Chapter 5.

     b.   Intermittent Point Source Subplans

          Intermittent point sources are wet weather related  point
     sources such as storm and combined sewer  overflows.  Details
     on preparing this subplan is provided in  Chapter 5.

     c.   Nonpoint Source Subplans

          Nonpoint sources are primarily wet weather related.
     Detail on preparing this subplan is provided in Chapter  6.

Each subplan  should furnish information on the following:

     .  Wasteload characteristics of each alternative expressed in
        appropriate units;

     .  Total cost of each alternative expressed  as  its present
        value or average equivalent value of  capital  and operating
        costs for the overall alternative and  subsystem components;

     .  Information on the reliability of each alternative and
        subsystem included in each alternative;


          .   Significant  environmental effects of each alternative
             consistent with NEPA procedures, including a specific
             statement on future development impact;

             Contribution of each alternative to other water-related
             goals of the planning area.

     9.    Screen  Subplans to Select Leading Alternative Subplans
          Consistent with Eligible Wasteload Reductions

          Control options under each  subplan are numerous.  Thus, the
     number  of  possible subplans may  be so great as to impede considera-
     tion of logical alternatives.  Since the only subplans that are
     viable  are those which the management agency(s) can implement,
     it  is important at this stage to  integrate the results of management
     planning with those  of technical  planning.

    10.   Combine  Subplans into Alternative Plans Consistent with
         Eligible Wasteload Reductions

          At this step, viab'e subplans should be combined into alterna-
     tive areawide technical plans for final evaluation and selection.
     This is not  meant to preclude reconsidering options previously
     screened out, but merely to provide a convenient form of organizing
     a vast  number of potential control alternatives into a reasonable
     number  to  evaluate.

3.4  Management Planning

     A.   Purpose

          The key implementation and  enforcement provisions of Section 208
     are delineated  in Section 208(b)(2)(C) and (c)(2) of the Act.  The
     Act requires that authority to carry out the above provisions be
     vested  in  a  designated agency or agencies within a 208 area.  The
     purpose of management planning is to select a management agency or
     agencies and to  develop appropriate institutional arrangements
     through which the plan can be implemented.  Institutional arrange-
     ments for  areawide waste treatment management are the formal
     structure  of affected state and local units of government for
     planning and implementing an areawide water quality management plan.

          The Act clearly specifies the responsibilities and functions
     of the  management agency(s).  The criteria that should be used to
     determine  whether the management agency(s) can properly carry out
     these responsibilities are:

                      adequate legal  authority
                    .  adequate financial capacity

     The Act does not, however, stipulate what institutional  arrange-
ments should be utilized to enable plan implementation.   Criteria
for evaluating the adequacy of the management agency(s)  and institu-
tional arrangements should be:

          .   Practicability -- To what extent do  institutional
             arrangements rely on existing water  quality management
             agencies?  Are the institutional  arrangements  politically

             Managerial  Capacity -- To what extent do institutional
             arrangements provide for program oversight  including
             procedures  for resolving conflicts and cooperating  with
             other areawide planning activities?

             Public Accountability -- To what extent do  institutional
             arrangements provide for a decision-making  process
             accountable to the area electorate?

     1.   Functions of Management Agency(s)

          To ensure plan implementation, the management  agency(s)
     and the supporting  institutional"  arrangements need to carry
     out the following functions:

          a.  General  Management Program

               One of the most important functions of the 208 manage-
          ment agency(s) is to provide general  direction for the
          implementation of the plan.  The management responsibilities
          involved in directing plan implementation should  include:

               (1)  program supervision and coordination, e.g.,
               ensuring   that the 208 program is  being implemented,
               that the  program is being coordinated with other
               programs  in the area, and that the performance of
               the program is being continually assessed;

               (2)  continuous planning, e.g.,  updating  the areawide
               plan and  implementation mechanisms as required by
               changing  conditions;

               (3)  fiscal  management,  e.g., assuring that  adequate
               resources are provided to implement the regulatory
               and waste management programs as well  as  to  finance
               the administration and continuous  planning functions
               of the management agency(s).

          Further detail  on the managerial  functions of  208 agencies
     is  provided in Chapter 7.

     b.   Regulatory Program

          Authority to  carry out the  regulatory  program mandated
     in  Section 208(b)(2(C) is  required.   In  addition  to  authority
     to  regulate existing  and new pollution sources, administra-
     tive procedures and agencies responsible for  implementing
     the regulation need to be  specified.  The regulatory  program
     should be the vehicle for  enforcing  the  abatement measures
     that have been developed through the  technical  planning
     process.   In addition to direct  regulation, appropriate
     tax policies should be developed to  complement  the regulatory
     program.   Further  detail on designing a  regulatory program
     is  provided in Chapter 7.

     c.   Waste Treatment Program

          The  legal  authority and financial capacity needed for
     operating, maintaining, and constructing waste  treatment
     works and otherwise carry  out a  plan  is  described in Section
     208(c)(2) of the Act.  A waste treatment program  includes
     all the capital construction responsibilities to  carry out
     a 208 plan, such as publically owned  treatment  works as
     well as all other  public sector  programs for  abating
     pollution including residual  waste management,  stormwater
     management, and nonpoint source  management.   Detail  on the
     waste treatment program is provided  in Chapter  7.

2.   Institutional Arrangements Capable of Implementing the Plan

     The great variety  of local  institutions, practices,  and
experience dictates that a pragmatic  strategy be followed in
formulating institutional  arrangements.   The  arrangements may
be comprised of one or  more agencies, which may  be existing
or newly created and local, regional, or  statewide in  jurisdic-
tion, and may  also rely on intergovernmental  agreements.  Although
care should be taken to ensure  that the institutional  arrangements
fit the  local  situation, excessive fragmentation of  authority
and responsibility should be avoided. Optional  approaches are
discussed in Chapter 7.

     The greater the number of agencies involved in  implementing
the plan, the  greater the need  to coordinate  between the
agencies.  The role of  various  levels of  government, the  A-95
review process, and the state is discussed in Chapter  7.

     The complexity of  institutional  arrangements  should  not
prevent  a clear delineation of the decision-making process
used to   implement the plan.  In particular,  there  should  be
an explicit arrangement for ensuring  overall  supervision  and
enforcement of the management plan.  Requirements  for  public
participation  in  EPA programs and means  for  providing  public
participation  in  208 planning are discussed  in Chanter in.
                          3 -  18

B.  Management Analysis

     The initial step in the management planning process
should be an analysis of the area's experience in water quality
management.  The purpose of this analysis will be to
evaluate the capability within the area to meet the man-
agement requirements of Section 208 and to develop an under-
standing of what is needed to satisfy these requirements.
Some of the analysis will have been accomplished in the
designation and grant application stages.  During the
planning process, this preliminary assessment should be
reviewed and, where necessary, expanded to assure it^
accuracy and thoroughness.  The following analyses should
be provided:

     1.  An assessment of the specific legal  authority required
     under Subsection 208(c)(2) and 208(b)(2)(C) to carry
     out the regulatory and waste management programs and
     an approach for acquiring such authority,  The approach
     should delineate what enabling or supplemental legisla-
     tion would be necessary, the type of contractual
     agreements that might be employed, and the possibility
     for adapting to existing laws.  In instances where
     existing laws might be broadly interpreted as furnishing
     the required authority, but where such interpretation
     may be subject to dispute, it would be best to seek
     specific statutory sanction.

     2.  An evaluation of existing financial  arrangements
     to determine what changes will be necessary to provide
     affected agencies with the capacity to meet financial
     needs and obligations for carrying out general manage-
     ment responsibilities, the regulatory program and
     waste management program.

     3.  An assessment of the potential of existing institutions
     in the area to perform the required functions.  An overall
     assessment should be made of the area's  potential  for regional
     water quality management.  This evaluation should seek to
     assess the effectiveness of regional management to date and
     the strength of the area's traditions and commitment to regional
     approaches.  The evaluation should incorporate an appraisal  of
     the relationships between federally funded regional  planning
     authorities and regional  or local  water  quality management agen-
     cies such as transportation, land disposal  of wastes, land use
     planning, and water supply where such agency activities affect
     water quality.   The purpose of the evaluation is to help ensure
     that implementation plans are constructed on a realistic founda-
     tion  which reflects the area's experience in regionalized


     C.   Development of Alternative  Management  Plans

         Upon  completion of  the management analysis,  alternative manage-
     ment plans  reflecting the results  of this  analysis  should  be de-
     veloped.   In most cases, only a limited  number of alternatives will
     be  appropriate.   Close  coordination with the  technical  planning com-
     ponent of the  planning  process  will be necessary throughout this
     stage to  ensure that the management alternatives developed are con-
     sistent with alternative technical plans.  As an initial step in  the
     formulation of management alternatives,  the broad options  available
     should be reviewed and  assessed.   Careful  consideration should be
     given to  the advantages and  constraints  of these options in rela-
     tion to the designated  areas.   Once developed, the  implementation
     alternatives should be  screened in terms of their feasibility
     according to the criteria discussed previously.  An overall assess-
     ment of the implementation feasibility of  the alternatives for
     management agency(s) and institutional arrangements should be
     based on  all the criteria discussed.

3.5  Combined  Plan  Evaluation and Selection

     A.   Combine Alternative Technical  Plans  that  Meet Standards with
         Alternative Management Plan Corresponding to Technical Plans'

         Technical  and management planning  should  yield  a series of
     technical plans for which an alternative management plan to imple-
     ment the  technical plan has  been presented.   At  this step, the
     alternative technical  plans  and management plans should be simply

         For each alternative technical and management plan  that are
     combined  into  alternative areawide plans,  sufficient detail concern-
     ing the schedule of actions  to  be undertaken  should be  provided  to
     enable accurate evaluation  of the plan  in  terms  of  meeting 1983
     water quality  goals.

     B.   Compile Information on Alternative Areawide  Plans

         The following information on the plans should be assembled
     for comparison of alternatives:

         1. Contribution to Water Quality and  Other  Related Water
            Management Goals of  the Area.   (Information from
            Chapters 4, 5 and 6)

         2. Technical Reliability  (Information from  Chapters 5 and 6)

         3. Monetary Costs  (Information from Chapters 5 and 6;
            methodology for cost evaluation  provided in Chapter 9)

    4.  Environmental  Effects (Information from Chapters  5 and
        6; methodology for environmental  evaluation provided in
        Chapter 11)
    5.  Economic and Social  Effects (Methodology for evaluation
        of economic and social  effects provided in Chapter 11)

    6.  Implementation Feasibility (Information from Chapters 7
        and 8)

    7.  Public Acceptability (guidance on means to assure public
        involvement in the planning process provided in Chapter 10)

    Much of the above information will have been developed in the
planning process; that which has not should be compiled in order to
be able to proceed to final  plan selection.  Information may be con-
veniently assembled on tables like those presented in Chapter 12.

    The format and procedures provided in Chapters 11 and 12 for
compiling information on alternative plans are specifically
designed to fulfill the need for the applicant to prepare an
environmental  assessment on  the 208 plan.

C.  Compare Alternative Plans and Select Final  Plan

    1.  Effects of Alternative  Plans

        Comparison of alternatives and selection of a final  plan
    should be  the product of public deliberation over the merits
    of the various plans under  consideration.   A discussion of means
    to involve the public in the overall planning process is
    provided in Chapter 10.   Suggested procedures for public
    involvement in selection of the final plan are provided in
    Chapter 12.

    2.  Vary Alternatives if Necessary for Final Selection

        To achieve the most desirable overall  plan, a variant
    or composite of plans originally proposed could be considered.

     D.   Develop Detailed  Description  of  Plan  Features

          In the process of  screening,  evaluating, and selecting plans,
     features of the  plan  may  not  have  been developed in sufficient
     detail.  At this  step,  the  timing  and detail of the plan should be
     finalized.   A critical  path chart  may be  a  useful format for
     depicting the sequence  of plan  implementation.

     E.   Include Provisions  for  Performance Assessment, Plan Revision,
          and Updating

          The 208 plan, which  covers a  20-year period, should be updated
     as  necessary,  and must  be certified  annually by the governor.
     Procedures  for performance  assessment and updating both technical
     and management features of  the  plan  are to  be specified in the
     initial plan submittal.

3.6  ^lan Outputs

     1 •   Technical  and Management  Outputs

          The major technical  and  management elements of a 208 areawide
     waste treatment management  plan have been summarized in Chapter 1.5.
     Table 3.1  found on page 3-24  of this chapter delineates specific
     elements or outputs which  may    be  included in a 208 plan to satisfy
     each requirement  of the regulation (40 CFR, Part 35, Subpart F).
     The table also relates  each element  to parts of this guideline which
     contain an  explanation  of the type of analysis and planning considera-
     tions that  could  be followed  to produce the specific elements.

          The review and approval  of 208  plans by the states and EPA will
     be  based on the finding that  the  requirements of the 208 regulations
     (40 CFR, Part 35, Subpart F)  have  been met.  In making their determina-
     tion that these requirements  of the  regulation have been met, the
     states and  EPA will compare outputs  with  those required by checking
     the list of specific  elements.  Further detail on plan review and
     approval procedures is  provided in Chapter  14.

          The timing  for implementation of the plan should be shown in
     conjunction with  the  plan contents.

     2.   Provisions for Performance Assessment,  Plan Revision, and Updating

          The provisions for performance  assessment, plan revision, and
     updating should describe  procedures  for assessing the progress of
     plan implementation and for modifying specific plan elements, and
     where possible,  provide alternatives in the event that an original
     course of action  proves infeasible or inadvisable in light of
     changed condi tions.


     Since procedures for revision and updating cannot provide for
all possible contingencies,  it is not intended that specific
alternatives to the initial  plan be investigated in detail.   On
the other hand, alternatives that have been investigated in  formu-
lating the initial plan may be cited as generalized contingency
measures to be further investigated in the event of plan revision.

3.  Reports  (Also see Chapter 13).

     a.  Condensed Report on Outputs

         A condensed report on the plan should cover all  the  plan
     elements, relating them to an implementation schedule.

     b.  Full  Report on the Planning Process

         Certain provisions of the interim grant regulations
     (40 CFR 35 Subpart F) require documentation of how the  planning
     process was conducted and how plan alternatives and environ-
     mental impact were assessed.  For example, §1064-1  (1)  and
     §1064-1 (o) necessitate a demonstration of the adequacy  of
     the plan to meet water quality objectives; §1064-1 (m-n)
     require documentation on alternative management arrangements
     for implementing the plan, as well as information on the
     environmental, social and economic impact of alternatives.

         A report documenting how the plan was developed and  its
     likely impact is therefore needed to satisfy these and  other
     requirements of the regulation.  For purposes of clarity,  the
     report on the planning process should be systematic and  deal
     with each step of the process.   The format of the report
     could follow the outline of the planning process presented
     in this guideline.  Various sections of the report could then
     be referred to as meeting the requirements of the regulation
     discussed above.  The documentation of the environmental
     impact ofalternative plans called for in 3.5.B. of this
     chapter should satisfy the NEPA requirements for an environ-
     mental assessment of 208 plans as required in 40 CFR Part 6.

3.7  Plan Submittal,  Review, and Approval

     The procedures for local  government review and recommendation,
state review and approval, and EPA review and approval  of completed
208 plans are  described in Chapter 14.   These procedures  take  place
after a completed 208 plan,  including  reports on plan outputs  and
planning process,  has been completed.   The review and approval
process may result in recommendations  for change in the  plan or report.

Major Elements
of a 208 Plan
I . Municipal and Indus-
trial treatment Works Pro-
of needs and priorities,
elements of planning, and
management agency(s) to
II. Urban Stormwater
Management Program

I. Municipal and Indus-
trial Treatment Works
Program (continued)
Plan Contents Specified in
Interim Gr,ant Regulat ons
(a) An identification of i.he antici-
pated municipal and industrial treat-
ment works construction nec.essary to
meet the requirements of I tie II of
the Act within the designaled planning
area over a twenty year period.
(b) Those portions, of facilities
planning in compliance with
§35.917-l(a)-{i) the costs of which
are allowable under §35-1062 for
those facilities for which Step 2 or
Step 3 grant assistance is expected to
be awarded during the five-year period
following the section 208 plan appro-
(c) The identification of required
'urban storm water runoff ccntrol sys-
(d) The establishment of construction
priorities for treatment wcrks for the
five-year period following the year of
plan approval and a proposed schedule
of completion of major treatment works
over the twenty-year period following
submission of the plan;
Elements which might be in a Plan to Satisfy
Each Requirement of the Regulation
(a){l ) facilities planning:
definition of service areas
lenQtns, and flo^s of sewage collection systems,
except those at or below the trunk line size
location, capacity, type, and level of treatment,
(corresponding to waste load allocations) and pre-
liminary identification of residual waste disposal
preliminary schedules and cost estimates of needed
construction ana economic, social , and environmental
impact information (also required under (n) below)
a)(2) industrial and private domestic wastewater
for private domestic wastewater treatment plants'
•• an identification of service areas and collection
systems, except those at or below trunk line size
for industrial waste treatment and domestic wastewater
treatment pi ants
•• an identification of location of treatment plants,
capacity, type, level of treatment (corresponding
to waste load allocations), preliminary identifi-
Crition of residual waste disposal options, and
schedule of discharge to receiving waters or to
municipal treatment plants
•• a preliminary cost estimate for treatment levels
needed to meet applicable effluent limitation re-
quirements of the Act, or to neet water quality
standards, and economic, social, and environmental
in, pact information regarding such treatment (also
required unde- (n) below)
(bj • refer to statement of relationship between facilities
planning and areawide planning. (Ch 2)
an analysis of the magnitude of existing and anticipa-
ted urban Stormwater problems including those resulting
from combined sewer overflows
a specification of measjres to be undertaken either to
Detter nanage existing sto>-m and comoined sewer systems
and prevent entry of pollutants to such systems, or to
provide for storage and treatment of such runoff
specification of performance criteria for new construc-
tion of urban stnrmwater systems, so as to minimize any
ston.iwater problems
preliminary schedules for facilities construction,
based on facilities planning described in (a) above
• documentation of the priority of the proposed facili-
ties on the State Priority List
in Guidelines
Ch 3.3
Ch 4.
Ch 5.2
Ch 5.2
Ch 5.3
Ch 5.5
Ch 5.6
Ch 2.
Ch 5.4
Ch 4.
Ch 6.4
Ch 5.4
Ch 6.5
Ch 6.2
Ch 6.5

NOTE:     The elements  of  a  208  alan described in this table may be categorized as proposed  actions
         (pollution  control measures, institutional and financial  arrangements}  or  analyses
         used to develop  or justify the proposed actions.  The proposed actions  should  be
         summarized  in a  condensed report on outputs  of the selected plan (see  Chapter 13.31
         and the analyses,  demoistrations of water quality impact, adequacy of regulatory
         measures, and environmental assessment should be included in a full  report on  the
         planning process (see  Chapter 13.3).

        TACLE  3 1
Major Elements
of a 208 Plan
III .Regulatory Program
(for (1) existing sources
(2) new sources and (3)
pretreatment, including
implementation mechanisms
such as permits, ordin-
ances, land use controls,

Plan Contents Specified In
Interim Grant Regulations
(e) The establishment of a regulatory
program to:
(1) Provide that waste treatment man-
agement shall be on an areawide basis
and provide identification and evalu-
ation of and control or treatment for
all point and nonpoint sources of
pollution, including inplace or accum-
ulated pollution sources, as shall be
required under guidelines published by
the Administrator pursuant to sections
208 and 304(e) of the Act. (Special
regulatory consideration , including
land use controls, is required for
sources further specified under para-
graphs (g) through (1) of this section

(e)(2) Regulate the location, modifi-
cation, and construction of any faci-
lities within such area which may
result in any discharge in such area
including as appropriate, regulation
of any future increase in waste loads
and sources , and
(e)(3) Assure that any industrial or
connercial wastes discharged into any
publicly c.vned treatment works in such
area must meet applicable pretreatment
requirements established in the plan.

Elements which might be in a Plan to Satisfy
Each Requirement of the Regulation
demonstration that management agency(s) recommended to
impl ement plan have authority and capability specified
in <>2G3(c)(2) to provide waste treatment management on
an areawide basis
demonstration that planning process has 7 dent i n ed aid
evaluated all sources of pollution in the area ana de-
veloped appropriate control alternatives for existing
and potential forms of pollution, including waste load
reduction levels consistent with meeting and maintain-
ing 1983 water quality goals (also required under (0)
below) .
- For each category of pollutant sources identified in
the planning process {including nonpoint source
categories in (g)-(l) ), identification of corres-
ponding controls included in the initial plan
•• demonstration that an adequate regulatory program for
each category of pollutant sources identified in the
planning process is included in the plan, by document-
- condi ti ons and si tua ti ons in whi ch regul atlon
applies, including abatement requirements
- parties affected by regulation
- timing of regulation, notice, and hearings
- legal form of regulation e g , activity permits,
land use controls, zom ng , bui 3 ding codes ,
licensing of pollutant generating activities,
conservation plans, etc
- legal authority for regulation, adequacy of exist-
law or proposed new regulation
- agencies responsible for inlementing regulation,
agency staffing anr* funding for programs
- methods of enforcement and compliance monitoring
For each category of pollutant sources identified in
the planning process, including nonpoint source cate-
gories in (g-1), identification of controls proposed
for projected ne*v sources from each category
demonstration that an adequate regulatory program for
category of new pollutant sources projected in the
pi an , is i ncl uded in the plan (same documentati on as
(e)(l) ).
demonstration that pretreatment requi regents of
|307 of the Act will be met
demonstration tnat implementation of §307 requi regents
and other requirements proposed in the plan will allow
proper functioning of facilities proposed in (a) and
wasteload reductions documented in (e)(l)
demonstration that an adequate regulatory program
exists for implementing ^307 and other pretreatment
requirements (same documentation as (e)iU }

in Guidelines
!Ch 3.4
|Ch 7,8
Ch 3.3, 3.5
Ch 4.
Ch 7.
Ch 3.3, 3.5
Ch 4.
Ch 7.
Ch 7.3
Ch 5.
Ch 3.3
Ch 5.
Ch 7.


     Major  Elements
     of a 208  Plan
Plan Contents Specified in
Interim Grant Regulations
                                                                           TABLE  3
                                                                               Elements  which might be in a Plan to Satisfy
                                                                               Each  Requirement of the Regulation
                                                                                                                                  in Guidelmes
VI.  Management Program
to Implement(I-y"("includ-
ing legal  authority and
financial  arrangements)
                          Tf)The  identi fi cat ion  )f those'
                          agencies  necessary  to  (1) construct,
                          operate,  and maintain  all facilities
                          required  by the  plan,  and (2) other-
                          wise  carry out  the  plan,
                                          identification of management aocncy(^)  to exercise
                                          responsibi]ity or supervisi on over cons truetion,
                                          operation,  and maintenance of facilities  identified
                                          in (a)
                                                                                                  Ch  7
                                                                          identification of management agency(s) to exerci se
                                                                          responsioi1ity o^r all otner elements of the plan
IV.  Ngnpo i n t _Source
Management Program (in-
cluding planning and
controls for agriculture,
silviculture, mining, con-
struction,  hydrologic
modification, salt water
    Residual "Waste
                          ~fg)  A~~process "to  (1)  identify, if
                          appropriate  agricultural y and silvi-
                          culturally related nonpo'nt  sources of
                          pollution, including  runoff  from man-
                          ure  cisposal  areas, and  land used for
                          livestock and crop production, and  (2)
                          set  forth procedures  and methods (in-
                          cluding  land  use requirements) to
                          control  to the extent  feasible such

                           (h) A process to  (1)  ideitify,  if
                           appropriate, mine-related  sources
                           of pollution including n^w,  current*
                           and abandoned surface and  under-
                           ground mine  runoff, and  2)  set
                           forth procedures and  metnods (in-
                           cluding land use requir Clients)  to
                           control to the extent feasible  such

                           (1) A process to (1)  idertify
                           construction activity related
                           sources of pollution, anc  (2) set
                           forth procedures and  methods {in-
                           cluding land use requirenents)  to
                           control to the extent feasible  such
                            (j) A process to (1) identify, if
                            appropriate, salt water intrusion
                            into rivers, lakes and estuaries
                            resulting from reductior of fresh
                            water flow from any cause, in-
                            cluding  irrigation, obstruction,
                            groundwater extract!on end diver-
                            sion, and (2} set forth procedures
                            and methods to control such intru-
                            sion to  the extent feasible where
                            such procedures and metrods are
                            otherwise a part of the waste
                            treatment management plan,
                             (TT'A process  to  control  the  dis-
                             position  of  all  residual  waste
                             generated m such area  cr imported
                             into  such area which  could  affect
                             eithe" surface or grouncwater

                           (1) A process to control   ,he disposal
                           of pollutants on land or  n subsurface
                           excavations within such area to pro-
                           tect ground and surface wnter quality,
                                          demonstration that the planning process  adequately
                                          identifies  each of the specific nonpomt source cate-
                                          gories in the ,irea in terms  of relative  magnitude,
                                          extent,  and  occurrence of pol1utant loads
                                                                                                                                 Tfi  JTT
                                                                                                                                 Ch  4.
                                                                                                                                 Ch  6.
                                          demonstration of compatfbiTi ty "betwe~eT~po~lTut^nt
                                          reduction levels established  for any nonpomt  source
                                          category and  b,ism  plans
                                          identification of control  measures  for each nonpomt
                                          source category that  are needed to  control  existing
                                          nonpomt sources so as to meet target reduction of
                                          identification of control  measures  for e^ch nonpomt
                                          source category needed to  prevent increase pollution
                                          from nonpomt source generating activities
                                          for each nonpomt source category,  identification of
                                          corresponding regulatory program under (e)(l)  for
                                          existing sources and (e)(2)  for new sources
                                                                                                  Ch  3.3
                                                                                                  Ch  6.
                                                                                                  Ch   6.1
                                          provisions for utilization or disposal of residual
                                          wastes from municipal industrial and private facilit-
                                          ies should be included in (a)
                                                                          identification  of all  existing  and proposed  residual
                                                                          waste,  land, and  subsurface  disposal  sites in area
                                                                          demonstration that the planning process  includes  anfCh373
                                                                          anal/sis  of wasteloads generated from residual  waste   |Ch  4.
                                                                          disposal  sites
                                                                          identification 3! control  measures needed for existing
                                                                          residual  waste, land, and  subsurface disposal sites,    j
                                                                          identification Df control  measures for new residual
                                                                          waste, land, and subsurface disposal  sites, needed
                                                                          to regulate futjre increases in wasteloads from such
                                                                          si tes
                                                                                                                                 |Ch  6.
                                                                          for each control  measure above, identification of
                                                                          corresponding regulatory program under (e)(l) for
                                                                          existing source1;  and (ej(2) for new sources

     Major Elements
     of a 208 Plan
      Plan Contents Specified in
      Interim Grant Regulations
                                                JLAU L_E_ \ J	 _       	

                                                    Elements  which mignt be in a Plan to Satisfy
                                                    Each Requirement of the Regulation
VI.  Management Program
tolmplement I-_V,
j  (m) The  identification of all major   j  (m)
i  alternative measures,  including       |
'  enforcei  cut activities,  f i nanci ng,
j  lind i'se and otner develcoment        j
|  controls and regulatory  actions,      |_
  administrative and management author- j"
  ities and practices necessary to carry,
  out each of the alternatives, and     j
  selection of the recommended system,  I
VII. Environmental Assess_-_
ment of I-VI
VTl I.Recommendations and
Certif 1i caTi ons TCPisis-
tency with basin plans,
public participation,
plan recommendation)
                                                 identification  of  each  major alternative (including
                                                 alternative  Sub-plan  elements)  to the im tial  pi an
                                                 developed  in tne  planmnq process
1  Major
 in Guidel me

iCh  35
                                                                          for each niajor alternative  identified,  identification   ;Ch   3.4
                                                                          of ai.tnority and financial  requirements  needed 01       (Cn   7.
                                                                          the part of i 'ananement  to  inulernent the       j Ch   8.
                                                                          pirn -sp^ci^icd!1/ the authority  c,tlinea  m «j?G3(c)    | Ch  12.
                                                                          (i} of tne Act, as ..'ell as  author!ty u\er  ]at.A use      !
                                                                          a.ia develoonent and regulation or nor.pcnnt source       ,
                                                                          pOl 1 lit! Q'i
 (n) Tne period of rime necessary to
 carry out the" plan and major alterna-
 tives, the costs of carrying out the
 plan an:J . ajor alternatives within
 such ti.iip , and eco'ion i c, social and
 environmental impacts of carrying out
 the plan and , ajor alternatives
 w 11 m •  s j c h i v e,
  Co") Certification of  tne consistency  T
  of  the plan with plans  prepared or  in |
  prepars',on inJer sections  209 and    j
  303 of tne Act   '4Any 201 plan devel- j
  oped  in the area or any epplication   j
  for a Step 1 grant for  such plan  re-  I
  ceived prior to tne approval of tne   f
[  208 plan snail require  review and     \
\  comments by tne designated  208
  agency which snail  be transmitted to
  the State agency processing the Title
  II grant applications.  After the
  section 208 plan has been approved,
  all 201 plans for the area  t^at may
  previously nave been developed shall
  be brought into conformance with the
  208 plan.)
                                                                          environmental assessment of the initial plan, and
                                                                          major alternatives developed in the planning process
                                                                          including identification of
                                                                           - p^an schedule
                                                                           - effectiveness in meeting ivater quality goals
                                                                           - direct costs
                                                                           - socia ^ econoii i c , envi ronriieita!  i rrpact
                                                water quality analysis as specified in Cn  3 3,
                                                sufficient to demonstrate tnan plan will enable
                                                n.eetmg 1983 goals and standards adopted oy State
                                                                          certification by tne State that 208 plan is compatible TCn  3.3
                                                                          with existing or proposed basin plans and revisions     j
                                                                          thereof                                                 j
                                                                          interim 208 outputs as  specified in Ch.  2 of guide! ine$~[Ch  2.
                           (p) Certification and description of   (p)
                           public participation, in the planning;
                           process and adoption of the plan, in	
                           accordance with Part 105 of this      [
                          I Chapter and                           i
                                                see Part 1C5 regs
                                                document hoy, public participation r,<,s beer, carried
                                                out in accordance with Part 105 regulations
                           Tq) Recommendations  by governing      j
                           bodies of local  governments having    [
                          I responsibility for,  or which would be i
                           directly affected by,  implementation
                           of the plan and  having jurisd^tion
                          j in tne planning  area as to State
                          j certification ;nd -iPA  approval  of
                           tne pi in   In tne event that a  local
                           unit of goverrvient fails to provide
                           a recommendation within 30 days of
                           receiving such a request from the
                           planning agency  it snail be consid-
                          I ered that the plan has be'en favorably
                          | recommended by that  unit of local
                          ! government
                                                self explanatory

                             CHAPTER 4

4.1  Introduction

     Since water quality is one of a series of economic, social, and
environmental objectives which may be considered when making land use
decisions, the 208 planning agency must be fully aware of planning and
implementation programs designed to achieve these and other objectives
of the 208 area.  Of particular importance are planning efforts'which
may be ongoing during the development of the 208 plan.  This could in-
clude land use, coastal zone management, and air quality maintenance
planning.  The 208 planning agency must work closely with agencies
responsible for other planning and implementation programs to ensure
that plans are compatible and that the implementation of other plans
and programs does not have an adverse impact on carrying out the 208

     This chapter discusses how land use plans, projections, and
controls should be assessed, revised if necessary, and utilized to
help attain water quality objectives.  A detailed consideration of
land use is important for two reasons:  (1) land use plans can serve
as bases from which point and nonpoint source controls can be develop-
ed and evaluated; and (2) possible changes in future development
patterns can be explored as a means of reducing investment in point
and nonpoint source control.  Because of the strong relationships with
point and nonpoint source subplans, the land use analyses described in
this chapter should be done in close conjunction with these subplans.
4.2  Pertinent Authorizations and Purpose

     Section 201 (c) authorizes, to the extent practicable, the "control
or treatment of all point and nonpoint sources of pollution .  .  .  ."
This implies a need for considering land use controls and land manage-
ment practices as a means for nonpoint source control.

     Section 208(b)(2)('C)(ii)  provides  that  the  areawide  waste treatment
management plan include "the establishment of a regulatory program to
regulate the location, modification, and construction of any facilities
within such area which may result in any discharge in such area  .  .  . ."
This provides authority for the 208 management agency(s)  to regulate
location of new pollutant dischargers by determining the location  of
municipal treatment facilities, by seeking control of other pollutant
sources, and by seeking appropriate changes  in land use plans  and
controls from the agencies possessing land use jurisdiction in the
208 area.  The term "facilities" in the above citation  includes  any
controllable source of pollutants, the regulation of which contributes
to attaining water quality standards.

     More explicit authority for the 208 plan to consider land use
in the 208 area is provided in Section 208(b)(2)(F-H)  which states
that the plan will set forth procedures and methods  including  "land
use requirements" to control to the extent feasible  certain nonpoint
sources of pollution.   The term "land use requirements"  in Section
208(b)(2)(F-H) includes those land use controls (legally permitted
uses) and those land management regulations (regulation  of activities
conducted on land) which contribute to the attainment  of water quality
4.3  Incorporating Land Use Considerations in the 208 Planning Process

     A.   Introduction

          This section identifies various methods of land use control
     which the local  governments and the management agency(s) in the
     208 area can utilize to regulate pollution.   This will  enable the
     208 area to make tradeoffs between structural  solutions (e.g.,
     treatment facilities) and nonstructural  solutions (e.g., alterna-
     tive land uses), thus increasing the flexibility in the choice of
     methods to achieve water quality standards.

          Throughout the process of incorporating land use considera-
     tions into the 208 plan, primary reliance should be placed on
     utilizing existing lard use plans, projections, and controls,
     although it will be necessary in some cases  to identify necessary
     revisions to incorporate changes responsive  to water quality
     objectives.  Since it is unlikely that the 208 planning agency
     will have the authority to enact or implement changes in land
     use controls, it is essential that the planning agency work
     closely with those government agencies possessing legal author-
     ity for land use planning and control.  This will be necessary
     to assure that the management agency(s)  has   the authority to
     implement the plan.

          It is also possible that some jurisdictions within the 208
     area will not have land use plans, projections, and/or controls.
     In this case, the 208 agency should work with the appropriate
     jurisdictions to gather enough information about the area so
     that current and future development patterns, densities, and
     policies can be identified.  If it is determined that revisions
     in these patterns, densities, and policies are necessary to
     achieve water quality standards in a cost-effective manner, the
     208 planning agency must work closely with the appropriate juris-
     dictions possessing legal authority to enact and implement such

     The major outputs of the procedure outlined in this chapter
are land use plans, projections, and an identification of land
use controls and practices necessary to successfully implement
the plans.  These should be of sufficient detail so that nonpoint
source runoff can be evaluated, and so that the location, volume,
and nature of wastewater flows considered can be adequately iden-
tified to formulate system or design parameters for the location,
sizing, and timing of treatment sites and major transmission
systems (interceptors and major trunk lines).  Any specific land
use and development regulations which affect assumptions made
for the above wastewater and land use impact data should be docu-
mented.  In addition, the origin of the wastewater sources, their
location and geographic distribution should be of a comparable
level of detail to accurately relate the origin of flows to
contributing land uses.

     For purposes of displaying land use patterns, a map scale
of 1 inch equals 2000 feet would be generally appropriate.   This
is the scale which the U.S. Geological Survey uses to prepare
topographical maps.  In undeveloped areas, the scale used in
mapping soil associations or soil series may be more appropriate.
Parcels of land use can be depicted for units of 20-40 acres in
densely developed or developing areas, 40-160 acres for moderate-
ly developed land, and 160-640 acres for undeveloped areas.
These suggested scales can vary depending on the type of geographic
area and wasteloads, and the origin of the wasteloads.

B.   Analyze Land Use and Water Quality Relationships

     In recent years a number of studies have been completed
which have examined the relationships between land use and  water
quality.  Although limited in scope, these studies provide  a
basis for understanding the impact of land use on water quality.
A review of these studies and an understanding of land use-
water quality relationships will prove extremely helpful in
identifying specific land use controls which may be necessary
to successfully implement the plan.  Some of these studies  are
included in the bibliography.

C.   Inventory and Projection

     An initial step for incorporating land ase considerations
into the 208 planning process should be a land use inventory
and projection.  Special emphasis should be given to those
geographic areas within the 208 region affecting or affected by
water quality.  The land use projections must be consistent with
the population and employment projections developed in Chapter
3 (3.3.D.6).  In addition, population, employment, and land use
projections should be consistent with those used in other programs,
especially air quality, coastal zone management, and HUD funded
land use elements.  Primary reliance should be placed on utilizing
funds provided under HUD's (701) Comprehensive Planning Assistance
Program to complete the inventory and projection.


     The inventory and projection should be divided into five-
year increments and include industrial, commercial, residential,
agricultural, silvicultural,  recreational  and other land uses
from which pollution may be generated.   The inventory and pro-
jection should be done at the level  of detail discussed in the
introduction to this section.  The projections do not have to
be as detailed for the fifteenth and twentieth year of the
planning period.  This initial projection should be used in
the initial development of point and nonpoint source subplans.

     In addition to the land  uses discussed above, an inventory
and/or projection of other factors may be necessary depending
on specific conditions and problems  in the 208 area.  Those
factors which are likely to be of importance in most 208 areas
are listed below.  Before initiating an inventory and/or pro-
jection, the specific type of data needed and an appropriate
level of detail should be determined:

     1.   Topographic and soil series classifications;

     2.   Bodies of water and related lands that would be bene-
          fically or adversely affected by a change in water

     3.   Water supply, treatment, and distribution systems;

     4.   Existing waste treatment and collection systems, in-
          cluding interim facilities and major urban storm
          drainage facilities;

     5.   Solid waste disposal sites;

     6.   Areas presently served by septic tanks and areas suit-
          able for septic tanks at specified densities;

     7.   Environmentally sensitive areas:

           •  Aquifers and aquifer recharge areas
           •  Marshland and wetlands
             Drainageways and stream buffers
             Flood plains
             Forests and woodlands
             Erodable and/or poorly drained soils
           •  Steep slopes
           •  Shorelands

D.   Display Waste Load Projections

     The waste loads projected in Chapter.3 (3.3.D.6.b) should
be displayed to show their spatial configuration.   The maps used
for the display can be of the level of detail  discussed previous-
ly (1" = 2000').   Rather than using a single map,  it would be
advisable to use a series of maps so that point sources, nonpoint
sources, and different pollutant parameters can be clearly iden-

E.   Analyze Alternative Land Use Controls and Practices

     Land use controls and practices should be analyzed to
determine those which would be most cost efficient in reducing
pollutant loadings.  The analysis should be done in conjunction
with the development of alternative point and nonpoint source
subplans to ensure consistency between the proposed controls
and the subplans.   In addition, the analysis should also be
based on the specific water quality problems in the 208 area.
For example, if sediment is a primary problem, special consider-
ation should be given to controls such as grading  regulations,
construction ordinances, and sediment and soil erosion control

     Land use controls and practices are used to achieve a
variety of objectives.  In addition, the following should be
considered when conducting the analysis:

     1.   Implementation capability.  Careful  consideration
     should be given to the feasibility of land use controls
     and their relationship to existing and proposed institutional
     and financial arrangements.

     2.   Consistency with other programs.  To the extent that it
     is practical, the land use controls should be consistent with
     other programs, policies, and plans such as those related to
     transportation, water supply, capital improvements, air
     quality, etc.

     3.   Public acceptance.  Since controls that  are unaccepta-
     ble to the public are unlikely to be implemented, it is
     essential that serious consideration be given to the public's
     viewpoint.  Appropriate public participation  measures are
     discussed in Chapter 10.

     Land use controls and practices should be reviewed and
analyzed as early as possible in the planning process to ensure
their feasibility in plan implementation especially with respect
to nonpoint source control.   When evaluating land use controls and
practices for the area, the  planning agency must be cognizant of
the general authority and requirements for land use provided
under state and local environmental, conservation, and land use
planning programs.  Additionally, the agency should survey
existing state enabl'ng laws relating to land use and identify
necessary or desirable statutory changes.   This will help ensure
that the 208 plan can be implemented with  proper legal authority.
Institutional structures for implementing  the controls are fully
discussed in Chapter 7.

     Following is a list of  major land use controls and practices
that should be considered as possible measures for implementing
pollution control in a 208 area.  Other ordinances, regulations,
and policies which may have  a direct or indirect impact on water
quality should also be assessed.

     0 Zoning
     0 Flood plain zoning and regulations
     0 Environmental performance zoning
     0 Subdivision regulations
     o Planned unit development regulations
     o Buffer zones
     0 Conservation and scenic easements
     0 Density bonuses
     ° Housing codes
     ° Building codes
     ° Construction permits
     ° Development permits
     ° Transferable development rights
     ° Hillside development  regulations
     ° Drainage regulations
     ° Grading regulations
     9 Soil erosion and sediment control ordinances
     0 Sol-id waste control ordinances
       Septic tank ordinances
     0 Taxation policies
     0 Public works policies
     0 Public investment policies
     0 Land conservation policies
     0 Discharge permits

F.   Display Waste Loadings for Each Subplan

     The waste loadings for each subplan (Chapter 3.3.D.8) should
be displayed to show their alternative spatial  configuration.   A
list of the land use controls and practices needed to implement
a given subplan should accompany the display.   The list as well
as the display can be used in the environmental  assessment and
plan selection process.

G.   Final Refinements

     After the various subplans have been developed, furtjier
refinements should be considered and evaluated according to the
criteria for the suitability of the land use controls discussed
in Section 3 of this chapter as well as that of cost-effectiveness
discussed in Chapter 1.  The following questions may prove useful
in suggesting some final refinements:

     1.   Is this the optimum development pattern for water

     2.   Could the number and magnitude of discharges be re-
     duced if the development pattern was changed?

     3.   Will the location of discharges have an adverse impact
     on water quality?

     4.   Will the timing of discharges have an adverse impact
     on water quality?

     5.   Would the implementation of additional land use
     controls reduce overall investments?

     While this final refinement may occur at various places in
the planning process, it is preferable to do it at the point
where subplans are combined into alternative areawide plans
consistent with wasteload reductions  (Chapter 3.3.D.10).  While
the planning agency, should exercise discretion if it feels that
the final refinement would more appropriately be conducted at
some other point in the planning process, it should be noted that
the final refinement will be of little value if done prior to  the
combination of subplans.

H.   Outputs

     The following information should be provided for each of
the combined alternative plans (Chapter 3.3.D.10):

     1.   A brief narrative description of the proposed land
     use controls and practices and the water quality problem(s)
     they will  help alleviate;

     2.   Tables showing population and economic projections
     for the fifth, tenth, fifteenth, and twentieth year of
     the planning period disaggregated to the sub-municipal or
     equivalent level:,

     3.   Working maps displaying the waste loadings for both
     point and nonpoirit sources;

     4.   Working maps depicting growth, densities, and type of
     development disaggregated by subareas for the fifth, tenth,
     fifteenth, and twentieth year of the planning period;

     5.   A demonstration that the facilities subplans and land
     use projections are consistent;

     6.   A demonstration that the existing and proposed land
     use controls will be consistent with and reinforce the land
     use projections and the facilities subplans.

                                  CHAPTER 5

5.1  Introduction

     Chapter 3 presents a framework for systematic evaluation and selection
of pollution control strategies for all sources of pollutants.  This chapter
describes detailed planning consideration for establishing alternative sub-
plans for controlling point sources of pollution.   The point sources con-
sidered in this chapter are discharges from municipal treatment plants,
combined sewer overflows, separate storm sewer discharges, and industrial
waste effluents.  Disposal of residual wastes, particularly wastewater
sludge, and wastewater reuse are also discussed.

     The various point source problems and controls are presented separately
in the following sections of this chapter, with combined sewer overflows and
storm sewer discharges grouped together because of their intermittent flow
characteristics.  Balanced consideration of measures other than the tradition-
al capital intensive approaches of  point  source  control  is  also stressed.
Alternatives considered should encompass all applicable structural and
management measures for preventing, abating, reducing,storing, treating,
separating, recycling, reclaiming and disposing of municipal and industrial
wastewater and storm water discharges.  The concluding section describes
ways of combining the control options for these sources into alternative
subplans for point source controls.

5.2  Municipal  Wastewater Facilities

     A.   Introduction

          Planning of municipal facilities within  an area will provide for
     (1) cost-effective, environmentally sound, and implementable treatment
     works to meet the present needs of the area and (2) a general program
     to phase facilities development to meet future needs as projected in
     an overall land use plan.  Balanced evaluation of nonpoint source
     abatement and prevention measures as well as  point source measures
     should precede final selection of the treatment works.  Treatment
     works must meet the applicable requirements of^Sections 201(g), 301,
     and  302 of the Act.  As a minimum, facilities "plans must provide
     for application, by 1983, of the best practicable waste treatment
     technology (BPWTT).  Where necessary to meet  wasteload allocation
     constraints consistent with water quality standards, plans must
     provide for measures to further reduce pollutants.  The determina-
     tion of BPWTT, or measures providing for higher treatment levels if
     needed, is based upon evaluation of technologies included under each

of the following waste management techniques:

     a.   treatment (biological  or physical-chemical)  and
          discharge to receiving waters;

     b.   treatment and reuse;

     c.   land application or land utilization.

     Comparison of the above techniques and  determination of BPWTT for
a specific case should .include considerations  for management of nutri-
ents in wastewater and sludges,  development  of integrated (solid, liq-
uid, and thermal) waste facilities, and enhancement of recreation and
open space opportunities.

     This section covers major aspects of the  municipal  wastewater
facilities planning presented in the EPA document entitled "Guidance
for Facilities Planning";  more detailed information on facilities
planning is contained in that document.  In  208 planning areas, spe-
cial attention should be given to the disposal of sludge from the
municipal wastewater system.  The problem of sludge disposal will
likely become more acute in large urban/industrial areas as waste
treatment levels increase and development pressures persist.

B.   Inventory Existing Conditions and Determine Existing Flows

     The existing waste treatment systems must be accurately assessed
to establish a basis for planning any systems  modifications.  Where
available, the Section 303 Basin Plans will  provide essential informa-
tion on municipal point sources, waste loads,  wastewater flows, and
water quality within the planning area.  Data from permits would be
an additional source of information.  At the start of the areawide
planning, this data should be reviewed and supplemented as necessary.
The assessment of each existing waste treatment system should include
a performance evaluation of the treatment plant, including operating
problems and personnel, and sampling and maintenance program.  Data on
current performance of many treatment facilities will  be available from
State water quality agencies as a result of  their programs involving
operations and maintenance visits and consultations.   An infiltration/
inflow analysis should also be made in accordance with EPA Guidance
for Sewer System Evaluation to determine whether excessive infiltration
or inflow exists and, on a preliminary basis,  costs of any corrective
measures required.  Should the analysis determine the existence of
excessive infiltration/inflow, a more detailed sewer system evaluation
survey should be made to specifically define problems and determine
types and costs of corrective measures.  A 208 planning grant cannot
be used for the detailed sewer evaluation survey; however, grant
assistance may be obtained under a construction grant (40 CFR 35,
Subpart E).  To assure satisfactory management of residual wastes, an
inventory of sludge utilization and disposal should also be conducted.

C.   Estimate Future Waste Loads and Flows

     To provide a basis for planning and preliminary design of facilit-
ies, future variations of waste loads and the flows over the planning
period should be forecast.  As described in Chapter 4, forecasts should
be based upon evaluation of land use plans, economic and demographic
growth trends for the planning area, and any growth constraints imposed
by air quality implementation plans, zoning restrictions or permit
conditions.  The effects of selected flow and waste reduction measures,
including sewer system rehabilitation to correct infiltration/inflow,
should also be reflected in the flow forecasts to permit subsequent
calculation of waste treatment system cost reductions.

     1.   Land Use and Development

          Wastewater load and flow projections should conform to the
     time related development shown on the land use projections that
     are proposed as being compatible with water quality goals. (See
     Chapter 4).   To avoid changes in the growth pattern from that
     projected in the land use plan, schedules of hookups consistent
     with the land use plan should be developed and enforced through
     a regulatory program.  (See Chapter 7).

     2.   Flow and Waste Load Forecasts

          The expected economic and population growth patterns for
     the planning area, as projected in the land use plan, should
     be translated into estimates of wastewater flows and waste loads,
     with a realistic allowance for unpreventable infiltration.  The
     estimated future changes in flows and waste loads from industries
     served by the municipal  system should reflect application of EPA
     pretreatment requirements for existing and new industries plus any
     expected process changes affecting wastewater and treatment re-
     siduals.  Wastewater flow forecasts should also include the
     effects of applying selected combinations of flow and waste
     reduction measures within the system and allowance for present
     and anticipated discharges from septic tank pumpages into the

     3.   Sludge Generation Forecasts

          The volumes and composition of sludge which will be gener-
     ated from treatment of wastewater should be estimated.  These
     forecasts should be modified to reflect the different treatment
     levels characteristic of the alternative systems considered.

D.    Develop and Evaluate Alternatives

     Since 208 planning does not necessarily imply a single inter-
connected waste treatment system for an area,  the development of a
facilities system will  involve a systematic comparison  of many sub-
system, as well as system, options.   For each  municipal  wastewater
system, subsystem options should be  identified.   Compatible options
should be combined into preliminary  treatment  systems consistent with
the alternative wasteload allocation sets.

     By using a rough estimation of cost and impact, the components  of
the alternative facility plan should then be screened on the basis
of goal attainment, monetary costs,  and environmental,  social, and
economic effects.   Legal or institutional constraints and implementa-
tion feasibility should also be considered.  Unacceptable alterna-
tives should be rejected; those remaining should be developed into
a limited number of proposals, employing each  of the previously
discussed waste management techniques.  Adequate justification
should be given for eliminating any  of those techniques at any stage.

     The following paragraphs briefly describe major factors to be
be considered and procedures to be applied in  the development and
evaluation of alternative wastewater systems.

     1.   Flow and Haste Reduction Measures

          The Act encourages the use of a variety of methods,where
     cost-effective,for reducing both the volume and amount of waste
     within municipal wastewater systems.  Some of the following
     measures would reduce not only wastewater loads, but water
     supply demands as well:

          a.   Infiltration/inflow reduction by sewer system rehab-
          ilitation and repair,and elimination of roof and founda-
          tion drains.

          b.   Household water conservation measures, such as water
          saving appliances and fixtures.

          c.   Water and wastewater rates that impose costs propor-
          tional to water used and wastewater generated; use of water

          d.   Educating the public on the value of water resources
          and the need  to reduce water consumption.

     2.   Industrial Service

          Municipal waste treatment systems should be planned to serve
     industrial users of the area whenever practicable and cost-effec-
     tive.  Special requirements, issues, and procedures associated
     with industrial use of a municipal  system are covered in section
     5.5.B of this chapter.


3.    Sewers

     a.    System Configuration and Capacity

          Planning of a waste treatment system includes  the com-
     parison of alternative arrangements of interceptors and
     collection pipes, including phased development,  to  assure
     selection of a cost-effective configuration.In newly developing
     portions of the planning area, the capacities  of the system,
     in  particular the larger lateral  and interceptor sewers,
     should generally accomodate not more than the  20-year waste-
     water projection based upon the land use plan.   However,
     choice of interceptor and collection pipe sizes  should
     reflect cost-effective analysis of alternatives  over the
     planning period.  The practice of designing interceptors  for
     long-term projected growth or ultimate development  within
     the service area should be discouraged.   As an  alternative,
     consideration should be given to interim (short-term) treat-
     ment works for outlying areas or to septic tank  units for
     individual or clustered developments in  low density areas.

     b.    Sewer Hookup Schedules

          Since the capacity of the facilities and  design of the
     treatment system is based on flow projections  which conform
     to  a time-related land use plan,  it is necessary to estab-
     lish a schedule for hookups in the system.  A  hookup schedule
     is  important in managing the system over time  in order to
     prevent growth from exceeding the designed capacity of the

          In the event that a violation of an NPDES  permit occurs
     due to overloading of treatment works,the Regional  Adminis-
     trator (or the state if the NPDES program has been delegated
     to a state) may, under authority of Sec.  402(h)  of the Act,  seek
     a court order imposing a ban or restrictions upon sewer connections,
     A series of planning and management actions to  prevent ov-er-
     loading of facilities may be included as special  conditions
     to  permits issued to facilities in danger of imminent over-

          Since the 208 plan is to include a  regulatory  program
     to  regulate location of pollutant discharges in  the area,
     and since the management agency(s) must  possess  authority
     to  refuse to treat wastes from a municipality  or subdivision
     which does not comply with the plan, a schedule  of  hookups
     is  an appropriate management approach for carrying  out this
     regulatory program.  The enforcement of  the schedule through
     the regulatory program may require specific authorizing
     legislation and will  therefore necessitate thorough legal
     analysis. (See Chapter 7).

4.   Waste Management Techniques

     Alternative waste management techniques must be evaluated to
determine the BPWTT for meeting applicable effluent limitations,
including those related to wasteload allocation.   Information
pertinent to this evaluation is contained in an EPA document
entitled "Alternative Waste Management Techniques for Best
Practicable Waste Treatment" (Proposed in March 1974).   Selection
of a waste management technique is closely related to effluent
disposal choices.  Preliminary alternative systems featuring at
least one technique under each of the three categories  (treatment
and discharge, wastewater reuse,  and land application  or land
utilization) should be identified and screened.  A more detailed
proposal should be prepared for each,unless adequate justifica-
tion for eliminating a technique during the screening process is

     Published cost, performance, and other information is avail-
able for many alternative treatment technologies.  Preliminary
screening of these technologies involves comparing costs and rela-
tive treatment capabilities.

     a.   Treatment and Discharge

          Treatment and discharge techniques include the

          (1)  Biological treatment including ponds,  activated
          sludge, trickling filters, processes for nitrifica-
          tion, and denitrification;

          (2)  Physical-chemical treatment including chemical
          flocculation, filtration, activated carbon, break-
          point chlorination, ion exchange, and ammonia stripping.

     b.   Wastewater Reuse

          In comparing waste management techniques and alternative
     systems, wastewater reuse applications should be evaluated as
     a means of contributing to local water management goals.  Such
     applications include:

          (1)  Industrial processes;

          (2)  Groundwater recharge for water supply enhancement
          or preventing salt water intrusion;

          (3)  Surface water supply enhancement;

          (4)  Recreation lakes;

          (5)  Land reclamation.

               Wastewater reuse needs should be identified and
          defined by volume, location, and quality.  These needs
          may influence the location of the treatment facilities,
          the type of process selected, and the degree of treat-
          ment required.

          c.   Land Application

               The application of wastewater effluents on the land
          involves the recycling of most of the organic matter and
          nutrients by biological action in the soil and plant
          growth, generally providing a high degree of pollutant
          removal.  Planning of the land application techniques
          should reflect criteria and other information contained
          in the EPA document on "Alternative Waste Management Tech-
          niques for Best Practicable Waste Treatment".

               Land application techniques include:

               (1)  Spray, ridge and furrow, and flood irrigation

               (2)  Overland flow;

               (3)  Infiltration-percolation;

               (4)  Other approaches such as evaporation, deep well
               injection, and subsurface leach fields.

5.   Residual (Sludge) Management

     Evaluation of alternatives for management of residual wastes should
be closely aligned with the evaluation of each waste management tech-
nique.  Such evaluation includes the evaluation of alternative combina-
tions of sludge processing and utilization techniques for satisfactorily
and economically disposing of quantities of residual wastes.   Care must
be taken to assure that these methods do not appreciably add  to air
quality or water quality problems.

     A variety of sludge processing and utilization techniques are
available including (a) thickening, (b) chemical  conditioning, (c)
chemical stabilization, (d)  aerobic and anaerobic digestion,  (e)  de-
watering, (f) thermal  processing for volume reduction or drying,
(g) composting, and (h) land spreading as  a soil  conditioner.   Sludge
disposal options are limited primarily to  land disposal, land  utili-
zation, and incineration, and must  comply  with the EPA policy  statement
on acceptable methods, based on current knowledge, for the ultimate
disposal of sludges from publicly-owned wastewater treatment  plants.

     Disposal  techniques such as soil  conditioning and land
utilization which realize the nutrient value of sludge as
fertilizer should be given special  attention in adopting a
sludge disposal  program for the area.   Furthermore, consider-
ation should be  given to local  air pollution control  regula-
tions and energy requirements if incineration is an option.

6•    Location of Facilities

     Evaluation  and choice of sites for treatment plants,
interceptors,  transmission lines, outfalls,  pumping plants,
and other major  works should comply with the land use plan.
Factors to be considered in selecting  location include:

     a.   Possible odor and aesthetic  problems;

     b.   Flexibility to convert to possible future reuse
     and additional pollution abatement needs;

     c.   Special protection of potable, shellfish, and
     recreation  waters;

     d.   Avoidance of floodplain and  wetland areas,  if

     e.   Induced growth impacts in flood hazard or environ-
     mentally sensitive areas.

7.    Regionalization

     Regionalization ootions should be evaluated to assure
use of the most  cost-effective facilities systems consistent
with the areawide waste management needs.  Various combina-
tions of treatment plants, interceptors and other works should
be identified; and each should be consistent with a target
wasteload allocation.   The economy of scale associated with
a large treatment plant should be balanced with consideration
of environmental and social impact, especially if the inter-
connected system would tend to induce growth patterns con-
flicting with the land use plan.  The effect of streamflow
depletion due to transport of wastewater to a downstream
plant, and the impact of concentrating wastes from plant
effluents at fewer points should also be considered.

8.   Phased Development

     a.   General

          In examining the cost-effectiveness of a waste treat-
     ment system, two alternatives should be considered:   (1)
     initial provision of sufficient capacity to serve the
     needs of the area as projected over the planning period;
     and (2) phased development of systems and modular
     construction of individual facilities within the system
     to meet future needs.   The phased and modular develop-
     ment option would involve planning for construction  of
     facilities and facilities components at intervals through-
     out the planning period to accommodate projected increases
     of waste loads and flows.  The following factors should
     be included in an assessment of the options: the service
     life of the treatment works;  the incremental  costs;
     and flow and waste load forecasts.

     b.   Reserve and Excess Capacity

          The planning of waste treatment facilities will
     normally provide some excess capacity to allow for daily,
     wet weather, and seasonal flow variations as well as
     projected flow increases.  The system capacity excess
     should be examined from a cost-effective viewpoint,  par-
     ticularly for treatment plants serving areas experiencing
     growth,where phased construction may be more cost-effective
     than initial construction for long-term capacity needs.
     Provision of holding storage at the plant intake should
     also be considered to equalize daily flow variations.

     c.   Phased Development of System

          Phased development of the system is advisable in
     rapidly growing areas, in areas where the projected
     flows are uncertain, or where full initial  development
     of facilities would tend to distort growth from that
     shown in the area land use plan.  The phasing should
     provide sufficient excess capacity at the beginning  of
     each construction phase to accommodate expected flow
     increases during the phase.  Phasing of sewers may
     involve provision of parallel or multiple systems or
     extension of single lines.

d.   Modular Development of Individual  Facilities

     Modular development of individual  facilities is
advisable in areas where high growth rates are project-
ed, where the required degree of treatment must be
upgraded later in the planning period,  or where existing
facilities are to be used initially but phased out later.
Modular development would avoid long-term operating prob-
lems associated with underutilization of certain com-
ponents of the plant.  Where modular development is
used, provisions should be made during  the design of the
initial facilities for future additions.

e.   Interim Facilities

     After the 2C8 plan has been approved, no NPDES
permit issued may be in conflict with that plan.  Since
interim facilities receive permits, they must be consid-
ered in the planning process.  Such facilities are often
used to treat wastes from areas not immediately servicea-
ble by larger, often regional,treatment facilities.
Careful consideration should be given to the way in
which interim facilities will be used,  especially in
high growth areas.  Since such facilities have the poten-
tial for inducing development that may be in conflict with
regional service plans, special attention should be
given to the interim facilities' eventual connection
to the larger system.  Thus, in planning for interim
facilities, particular consideration should be given to:

     1.   Ensuring that the area to be served by the
     interim facility is in conformance with land use
     plans and controls;

     2.   Ensuring, through  the establishment  and  enforcement
     of a schedule of hookups for the life of the facility,
     that the interim facility will not be overloaded;

     3.   Ensuring when the facility is no longer needed,
     that its service area is transferred to a permanent

     4.   Reusing the abandoned facility for some other
     needed function, such as use as a pumping station;

     5.   Ensuring proper operation, maintenance,and
     inspection.  (Trained, certified operators should
     be used.)

           f.   Flexibility and Reliability

               Flexibility and reliability should be considered through-
          out the planning of municipal facilities.  As mentioned in
          previous sections, flexibility factors include possible up-
          grading of water quality objectives, future application of
          new technologies, future application of wastewater reuse,
          modular and phased development of facilities, and temporary
          treatment plants.

               Reliability considerations are important,si nee a
          risk of failure exists in any wastewater system.  With a
          view toward minimizing this risk, the probability, duration,
          and impact of such failures should be considered for each
          system and its components.
5.3  Other Point Sources

     The identification of other point sources within the planning
area, possible control options, and feasible controls should be includ-
ed in point source subplans.  In particular, private wastewater systems
should be evaluated, preferably in conjunction with the municipal  waste-
water facilities.  Information regarding planned capacity of such systems
should be sought from private waste water management agencies.  Planned
capacity should be reviewed for consistency with future waste load
reductions.  Any point sources required to obtain permits should be in-
cluded in point source subplans.
5.4  Combined and Storm Sewer Discharges

     A.   Introduction

          Storm sewer discharges and combined sewer overflows can be
     sources of significant quantities of pollutants.   Since they are
     an integral part of the municipal wastewater collection system,
     untreated overflows from combined sewers pose an added threat to
     public health.

          Various techniques for controlling and treating combined and
     stormwater flows can be incorporated into alternative areawide
     subplans for point sources.  Quite often, these problems can be
     substantially reduced through effective control of the sources
     and/or the runoff before it enters the storm and combined sewer
     systems, as is discussed in Chapter 6.  The most cost-effective
     combination  of controlling the problems at their source or
     controlling the runoff once it enters the stormwater system can be
     made in the later steps of the planning process where alternative
     subplans for point and nonpoint sources are combined into alterna-
     tive areawide plans.  (Chapter 3.3 0.10).

B.    Inventory Existing Conditions

     An inventory of existing storm and combined sewer systems should
be conducted to the extent data is available;  the inventory should
include locations and condition of intake bypasses, pipes,  regulatory
equipment and other features, and an assessment of both the existing
performance of the system and its optimum performance with  intensive
management, operation and maintenance.   Information on flow variations,
design capacities, wastewater constituents, and waste loads is also
needed.  Where flow records are lacking, estimates of overflows and
discharges based upon observations should be correlated with rainfall
amounts.   Wasteload estimates should be based  on pollutant  sampling
and subsequent tests for dissolved oxygen (DO), biochemical oxygen
demand (BOD), ammonia nitrogen (NHs-N), phosphates (P20s),  total
solids (TS), suspended so"ids (SS), toxics, and both total  and fecal
coliform counts.

C.    Estimate Future Waste Loads and Flows

     To provide a basis for planning of control measures, forecasts
should be made of the waste load magnitude, intensity, and  duration
of the problems associated with discharges throughout the planning
period.  Information on existing discharges can provide a convenient
base for the estimates.  Flow volumes and waste loads during storm
periods should be related to the tributary drainage area; the result-
ing information can permit, forecasting of flow volumes and  wasteload
increases resulting from future changes in land use and development.
This information can provide the basis for estimating flows in storm
sewer systems within the planning area.  Adjustments in projections
should be made to account for density changes, reduction in pollutant
discharges due to future protection of environmentally sensitive areas
as reflected in the land use plan, and probable flow and waste reduc-
tion measures.

D.    Develop and Evaluate Alternatives

     The development of alternative areawide control of combined
sewer overflows and storm sewer runoff involves the systematic
comparison of feasible control options, both structural and non-
structural.  Operational strategies should be explored for the
entire system to maximize use of the system capacity.  EPA research
has demonstrated many types of control and treatment techniques for
combined sewer overflows.  Among these, storage options both upstream
from the system or within the systems  appear feasible.  However, this
capacity would generally be limited to the most highly polluted ini-
tial storm runoff from a low-frequency storm event (one chance in one,
to one chance in five of being equalled or exceeded during any single .

     Specific factors to be considered in the development and
evaluation of combined and storm sewer discharge subplan components
are contained in the following paragraphs.   In general, the most
cost-effective solution will  be a mixture of operation/maintenance
and construction techniques.

     1.    Flow and Waste Reduction

          A variety of techniques can be used for reducing flow
     volumes and waste amounts from entering the system.  Consid-
     eration of these techniques should be coordinated with non-
     point source control  options planned for the tributary
     drainage area.  They include:

          a.   Reduce disturbance of land cover and maintain sur-
          face infiltration capacities;

          b.   Control patterns and densities of urban development;

          c.   Reduce nonpoint source runoff through control mea-
          sures for urban and construction activities-,

          d.   Preserve or manage lands that have natural  or
          existing characteristics for retarding or reducing flow
          and surface pollutants;

          e.   Control surface runoff and in-system runoff by use
          of permeable material for paving, flow retardation
          structures, and other means of storing and retarding
          runoff, including planned intermittent shallow flooding
          of parking areas, streets and other surfaces where
          damage would be minimal.

          In 208 planning, emphasis should be placed on use of the
     above techniques as alternatives or supplements to the control
     measures discussed below, as the former are generally far
     more cost-effective and  less environmentally disruptive.

     2.    Alternative Control Techniques

          Alternative control techniques that should be considered
     in  combined sewer overflow and storm sewer discharges can be
     grouped into the following five categories.   Although these
     categories apply primarily to combined sewer overflows, some
     of  them could be appropriate for storm sewer discharges.

               a.    Separatior  of  sewage  and  storm collection  systems
               (generally the most costly and least environmentally
               acceptable approach);

               b.    Operational  control of the existing  system (maxi-
               mum use of the system  storage  by computerized flow
               regulation and subsequent  treatment at  the  plant);

               c.    Storage  at  points within  the system  or at  the
               point of discharge, and subsequent treatment;

               d.    Direct treatment  of overflows (in-line high  rate
               treatment methods) ;

               e.    High level  of  maintenance including  periodic flush-
               ing of sewer  systems.

          3.    Location of Sewer Outlets

               Storm sewer capacities are generally related to the  po-
          tential  damage and public inconvenience associated with rain-
          fall.  These sewers usually have outlets into  nearby waterways
          that can adequately  receive the projected runoff.  Storm
          sewer systems should  be  evaluated together with  the  existing

               The cumulative net  increase in runoff attributed to  these
          systems should be evaluated to  determine the associated effects
          on flood stages in the receiving waters.  More important,  from  a
          water quality viewpoint, the existing waste  loads and anticipated
          future storm sewer discharges should be evaluated and compared
          with the wasteload reduction limits.  Where these limits  would
          be exceeded, an extension or relocation of the outlet sewers  to
          locations where the receiving streams can readily assimilate  the
          wastes may be more cost-effective than developing control  measures.

5.5  Industrial Wastewater

     A.    Introduction

          The overall objective of planning for the control and treat-
     ment of industrial wasteweter is to  provide the most  efficient
     approach for serving the present and future industrial wastewater
     treatment needs of the area.   Treatment techniques  must meet the
     applicable requirements of Section 204,  301, 302, 304, 306, 307,
     and 316 of the Act.  Industries  served by municipal systems must
     comply with pretreatment and  cost recovery requirements.   Direct
     discharge of industrial wastes to receiving waters  must comply, at
     a minimum, with the provisions of the pertinent Effluent  Limita-
     tions Guidelines and New Sources Performance Standards.   Higher
     treatment levels or internal  wasteload reductions will be re-

quired where wasteload allocations dictate more stringent restric-
tions.  Application of higher treatment levels to meet water
quality standards can be mitigated through restricting the loca-
tion of future industrial development to areas where receiving
waters can more readily assimilate the treated wastewater.
Control of industrial location should be incorporated into the
land use plan with recognition of other constraints such as air
quality control.

     The procedures for evaluating industrial waste sources and
problems are basically parallel to those presented in section
5.2 of this chapter for municipal wastewater systems.

     Wastewater flows from all major industrial sources in the
area should be accurately assessed.   Existing information should
be used where available, including information on those industries
that discharge into municipal systems.   To estimate design flows
and wasteload reductions, information is needed on average flow-
rates, flow variations, seasonal variations, wastewater character-
istics and constituents, and mode of disposal.  Particular emphasis
should be given to toxic constituents within the wastes and to
thermal pollutants present.   Forecasts should be made of the
future variations of waste loads and flows over the planning
period and the discharge locations of those wastes.  These fore-
casts should be based upon economic and industrial trends, types
of industries and constituents of associated wastes, location
constraints imposed by the land use plan, and other restrictions
imposed by industrial permits and air quality implementation
plans.  Attention should be  given to estimating waste sludges and
slurries generated by the industries as well as to the influence
that industrial loads will have on treatment plant sludge.  The
effects of user charges, pretreatment, and effluent limitations
guidelines or higher treatment levels on water and wastewater
flows should be incorporated into the projections.

B.   Develop and Evaluate Alternatives

     The development of alternative approaches for treatment of
industrial wastes and the degree of treatment, involves a syste-
matic comparison of the following options:

     a.   Pretreatment and discharge of wastewater to municipal

     b.   Direct treatment by individual industries and discharge
     of wastewater into receiving waters;

     c.   Direct treatment and discharge by groups of industries;

     d.   Reuse of industrial wastewater;

     e.   Land application.

     In conjunction with each of the above options, consideration
should be given to discharge to either water or land and to the
effects of flow and waste reduction on internal recycling and
process changes.   Areawide options should be identified in terms
of meeting wasteload allocation constraints and compared to
provide a rough assessment of costs and impact.  Consideration
should also be given to institutional  constraints and feasibility.

     Specific issues that should be addressed in formulating
alternatives are included in the following paragraphs:

     1.   Flow and Waste Reduction

          The flow and waste reduction as it relates to those
     industries that discharge or will discharge into municipal
     systems should be assessed.  Increasingly stringent techni-
     cal  and financial requirements on industry should lead to
     process changes that use less water and create less waste-

     2.   Minimum Effluent Limitations

          Industrial wastewater treatment must comply with the
     minimum treatment requirements for Best Practicable Control
     Technology (BPT) and Best Available Control Technology (BAT)
     by 1977 and 1983, respectively.  These treatment requirements
     are set forth for the industries cited in Section 306 of the
     Act in a series of EPA documents entitled "Development Docu-
     ment for Effluent Limitations Guidelines and New Source
     Performance Standards for 	Point Source Industry".
     These guidelines contain criteria for each industry for Best
     Practicable Control Technology Currently Available (known
     commonly as BPT) and Best Available Control Technology
     Economically Attainable (known as BAT).  The guidelines also
     provide minimum criteria for New Source Performance Standards
     and New Source Pretreatment Standards.

     3.   Joint vs. Separate Municipal and Industrial Facilities

          Municipal waste treatment systems should be planned to
     serve industrial users of the area whenever practicable and
     cost-effective.  Because of the unusual economy of scale
     associated with larger municipal-industrial facilities, as
     compared to separate municipal and industrial facilities, a
     joint system will often be cost-effective.  In many cases,
     however, it may be more economical to have separate industrial
     treatment facilities because of the characteristics and quan-
     tities of industrial waste, industrial pretreatment require-
     ments, and industrial locations and groupings which facilitate
     joint industrial treatment and/or reuse of industrial waste-
     water.  These considerations are also relevant to the cost
     and effectiveness of sludge disposal options for each alter-
     native facility.


               Industrial use of municipal facilities should be encour-
          aged where total costs would be minimized.  Where industrial
          flow handled by municipal systems is significant, cost of
          separate treatment of industrial wastes versus cost of pre-
          treatment and joint municipal-industrial facilities should
          be compared.  This involves comparing the incremental cost
          of the municipal facilities required to transport, treat, and
          dispose industrial wastes    (and  the costs of corresponding
          pretreatment required) with the cost of separate industrial
          treatment and disposal facilities of those wastes.  In partic-
          ular, the analysis should cover those industries desiring, but
          not receiving,municipal service when facilities planning is

          4.   Pretreatment and Cost Recovery

               Industrial wastes served by municipal systems must comply
          with industrial pretreatment and cost recovery regulations.
          The pretreatment regulations basically require the removal  of
          industrial waste constituents that are not compatible with  the
          municipal wastewater treatment process.  Compatible wastes,
          generally BOD and suspended solids, can be passed to the
          municipal plant for treatment.   The cost recovery regulations
          prescribe that industrial users must bear a proportionate
          share of the cost of operating and maintaining the municipal
          system and must repay of the portion of the federal grant
          attributed to that waste.  Industrial sites should be located
          where receiving waters can more readily assimilate the resid-
          ual wastes and associated nonpoint source runoff.  Such con-
          trol of industrial locations should be incorporated into the
          land use plan and recognize other constraints such as air
          quality control.
5.6  Development of Alternative Subplans

     The alternative subplans for point source controls should corres-
pond to alternative wasteload allocation sets for design conditions for
meeting water quality standards under both dry weather and rainfall
conditions.  At least one subplan should be developed to correspond to
each wasteload allocation set.  Subplans for continuous point sources,
primarily from municipal and industrial treatment works, should satisfy
the wasteload allocation sets for dry weather conditions.   Subplans for
combined and storm sewer flows should correspond to wasteload reduc -
tions for design conditions reflecting rainfall.

     A.   Continuous and Seasonal Point Source Subplans

          Investigation of controls for municipal and industrial waste-
     water may reveal control options that do not correspond to the

target  wasteload reduction sets previously considered.  Addi-
tional wasteload reduction sets should be developed if necessary
to enable consideration of reasonable point source control tech-

B.    Intermittent Point Source Subplans

     Subplans for intermittent point sources such as combined and
storm sewer discharges should correspond to target wasteload
reduction  sets prepared to enable meeting standards under wet wea-
ther conditions.  As discussed in Chapter 3, calculation of treat-
ment levels required to meet standards at wet weather conditions
should be based on point s.ource treatment levels established for
dry weather conditions.  Thus, the additional wasteloads carried
to streams after rain  should be dealt with through load reduction
for intermittent point sources and nonpoint sources

C•    Disposal of Residual Wastes

     Point source subplans. should provide for the disposal of
residual wastes and should conform with an areawide program of
solid waste disposal.

D•    Description of Alternative Subplans

     Following the screening of the system alternatives, the following
information on the alternative subplfas should be presented as an input
to the systematic comparison of areawide pollution control alterna-
tives (refer to Chapter 3.3.D.8).

     0  Wasteload characteristics of each alternative expressed
        in appropriate units for relating to the water quality
        prediction model;
        Total cost of each alternative expressed as its present
        value or average equivalent value of capital and opera-
        ting costs for the; overall alternative and subsystem

        Reliability of each alternative and subsystem included
        in each alternative;

        Significant environmental effects of each"alternative
        consistent with NEiPA procedures, including a specific
        statement on future development impact;

        Contribution of each alternative to other water-related
        objectives of the planning area.

                            CHAPTER 6

6.1  Introduction

     Chapter 3 presents a framework for the systematic  evaluation  of all
sources of pollution and selection of alternative plans for the  area.
The control  plans must identify nonpoint sources,  evaluate  their impact
on water quality, and delineate measures for their control.

     Nonpoint sources, while not defined in the  Act,  are, by inference,
the accumulated pollutants in the stream,  diffuse runoff, seepage,  and
percolation contributing to the degradation of the quality  of surface
and ground waters.  They include the natural  sources  (seeps, springs,
etc.) and millions of small point sources  that presently are not covered
by effluent permits under the National  Pollution Discharge  Elimination

     Provisions for control of nonpoint sources  from  agricultural,  silvi-
cultural, mining, construction and urban/suburban areas must be  included
in the development of a control  plan.   Land and  subsurface  disposal  of
residual wastes,  salt water intrusion,  and hydrographic modification
contributing to water quality degradation  must also be  considered.

6.2  Statutory Requirements and EPA Policy

     A.  Statute

         Sec.  208(b)(2)(c)(i) states that  a 208  plan  shall  include
     establishment of a regulatory program to  "implement the waste
     treatment management requirements  of  Sec.  201(c)," which calls
     for control  of all point and nonpoint sources of pollution.

         Section  208(b)(2)(F-I)  states  that a  plan prepared under  the
     areawide waste treatment management planning  process shall  include:

         "A process to (i) identify, if appropriate,  ...fnonpoint
         sources  of pol lution) . .and (ii) set forth procedures and
         methods  (including land use requirements)  to control  to
         the extent feasible such sources."

     Finally,  Sections 208(b)(2)(J) and (K) provide that a  plan  shall

         "A process to control  the disposition of all residual waste
         generated in such area which  could affect water quality,"  and

         "a  process to control  disposal  of pollutants on land or in
         subsurface excavations within  such area to protect ground  and
         surface  water quality;"

B.  EPA Policy on Implementing  the Statutory  Requirements

     The requirement for a regulatory program over all  point  and  non-
point sources places a clear responsibility on areas  developing 208
plans to establish regulation of nonpoint sources.   It  is  EPA policy
that the type of regulation appropriate for each  nonpoint  source
category should be established  at the state or areawide level  in  the
case of designated 208 areas.

     For each nonpoint source problem category, "Best  Management Practices"
(BMP) should be defined and implemented through appropriate  regulation.
The term "Best Management Practice" refers to a practice or  combination
of practices that is determined by a state after  examination  of alterna-
tive practices to be practicable and most effective in  preventing or
reducing the amount of pollution generated by a nonpoint source to a
level compatible with water quality goals. The "best"  practice for
reducing nonpoint sources in a  given area will depend on the  particular
physical characteristic:; of the watershed (soil,  slope, rainfall, etc.)
as well as the nature o1'" man's  activities that cause  nonpoint source
pollution generation (prevailing forms of construction  activity,  mining,
agriculture, etc.)

     While it is not practical  to try to establish precise cause  and
effect relationships between each nonpoint source generating  activity
and water quality, the degree of control of nonpoint  sources  should  be
based on the degree of water quality protection needed  in  an  area.
Generalized assessments of cost and effectiveness of  control  alternatives
to meet overall targets of nonpoint source pollution reduction should
be the basis for determining the "best" management practice  for nonpoint
sources in the area.  The level of detail of  nonpoint source planning
should be influenced by the availability of information upon which to
base the choice of best management practices.

     Finally, definition of best management practices may  distinguish
between existing nonpoint source problems and potential problems.
Management of existing problems may require fairly detailed  assessment
of the exact nature of existing problems and  appropriate management
techniques.  For examples establishing better management of  existing
urban  runoff problems may entail investigating street cleaning operations>
sanitation services, catchment basin design,  and  stormwater  systems.
(These systems are treated as a point source  problem in this guideline--
see  Chapter  5).

     Before  choosing best management practices for existing  urban
runoff pollution,the cost and effectiveness of the various options
under  existing local conditions should be assessed.  On the  other
hand, more generalized assessment could be made of techniques to
prevent future urban runoff  problems.  The assessment would  be
based  on cost and effectiveness of controls under average  conditions.
The  degree of control over new nonpoint sources should be  such as
to prevent deterioration of water quality due to  introduction of
new  sources.  Thus management practices capable of very high levels
of abatement for new nonpoint  sources may be  the appropriate


     "best management practices."   For example  in  the  case of  urban
     runoff, performance criteria  for construction of  new stormwater
     systems might be established  such that  the natural  rates  of
     runoff in the area would be maintained  through stormwater system
     designs that would attenuate  runoff.

     C.   State Involvement in Establishing Nonpoint Source Regulatory

         EPA is considering how the states can  implement a nonpoint
     source regulatory program as  required by Sec.  208(b)(2)(C)(i) in
     nondesignated areas, or in designated areas,  where, pursuant
     to  Sec. 208(b)(4), the governor certifies  that consistency with
     a statewide regulatory program so requires.   Because of the
     difficulty of undertaking case-by-case  cost-effectiveness
     analysis for particular nonpoint source problems,  it is envisioned
     that states would establish a definition of Best  Management
     Practices for various nonpoint source categories.   EPA would
     provide guidance to the states on how to establish  nonpoint
     regulatory programs, but the  definition of control  requirements
     would be determined at the state level, reflecting  local  condi-
     tions and means of enforcement.   Definition of Best Management
     Practices would establish minimum levels for  nonpoint source
     control. Cost-effectiveness analysis would be appropriate to
     determine the need for higher levels of nonpoint  source pollution
     abatement, particularly in cases where  large  investments  might be
     necessary to remedy a given problem.

6.3  Development of a Nonpoint Source Planning  Approach  in Designated

     A.   Objectives of Nonpoint Source Planning

         Full delineation of the water quality  problems  of an  area
     requires consideration of both point and nonpoint  sources of water
     pollution.  The objective is  to  evaluate both sources of  pollution
     and to integrate a control  program for  significant  nonpoint sources
     into an overall  water quality protection plan.  Nonpoint  source
     controls may be necessary for several reasons:

         1.  Attainment and maintenance of water quality objectives
             mav he impossible using  only the ooint  source controls;

         2.  Inequity may result from imposition of point source
             controls only;

         3.  Nonpoint source controls may be the most  cost-effective.

B.   Problem Identification

    Using available data,  a preliminary assessment of the
magnitude of the nonpoint source problem should be undertaken.
A determination should be made of the categories of nonpoint
source pollution in the area that significantly impair meeting
and maintaining water quality standards.   Potential  problems
as well as existing problems should be assessed.

C.   Priorities for Plaining

    In establishing planning priorities for the technical  planning
process (see Chapter 3), it is important to consider the  priorities
that the states may establish for nonpoint source control.   By
coordination between areawide and statewide nonpoint source
planning, more effective and comprehensive programs for nonpoint
source control can be established.

    As explained in Chapter 3, priorities for planning should
place greatest attention on problems that can be solved with
existing technology and sources of funding.
Distinguish Planning Approach for Existing  and  New  Nonpoint
    For each category of nonpoint sources in the area,  an opera-
tional definition of new and existing sources should be established.
For example, all new st.ormwater systems and hydrographic modifica-
tion after a given date might be considered  as "new".   Normal
changes in the conduct of a given activity such as agriculture
should not be considered as creating a new source.   Rather the
distinction should be based on major changes in topography and
drainage that would tend to cause significant increases in
nonpoint source pollution.  The purpose of the distinction
between new and existing sources is twofold.  First, greater
depth  of planning detail may be appropriate in determining
management practices for existing sources, which vary greatly
in their magnitude and controlability.  Secondly, since it is
not possible to anticipate the magnitude of future nonpoint
s'ource problems, the presumption should be that once existing
sources adopt controls needed to protect water quality, new
sources should be required to adopt the best practices  available
for preventing future increases in pollution.  The best practices
for new sources will in many cases prevent more pollution per
dollar spent than best practices for  existing sources, since
there will be flexibility to prevent problems before they arise,
rather than attempt to control them after the fact.

6.4  Identification and  Evaluation  of  Existing  Nonpoint Sources

     A.   Estimates of Nonpoint Source  Loading

         The first step  toward establishing a definition of the
     best management practices for  nonpoint sources  is  an estimate
     of the existing nonpoint source problem.   This  requires establish-
     ing the extent of the problem  in  the  receiving  waters and then
     determining the origin of the  sources contributing  to the
     problems in the stream.

         1.  Identification of Nonpoint  Source  Problem
             in the Receiving Waters

             The nonpoint sources are  the  sources contributing
         to water quality degradation  where that degradation cannot
         be accounted for by the known point sources.   This applies
         from the largest basin to  the smallest subbasin.  It can be
         expressed as follows:

                   N = (Q+S+D) - (P+I)

                   N = Quantity (mass) of  nonpoint source pollutants
                       in terms of  a given parameter, under a given
                       design flow  condition

                   Q = Quantity of  pollutants in the water leaving the
                       test area

                   S = Quantity of  settlement and precipitation of

                   D = Quantity of  decay of nonconservative pollutants

                   P - Quantity of  pollutants discharged by point
                       sources (assumed  to be constant  under a given
                       design flow  condition)

                   I - Quantity of  pollutants in the water entering
                       the test area

         2.  Identification of the  Origins of Nonpoint  Sources

             Once the total nonpoint source load of  a given pollutant
         under given flow conditions has been established, it is
         necessary to evaluate the  breakdown of sources of this pollutant

     The runoff,  seepage,  and  percolation of  pollutants from
 nonpoint sources is highly dependent on climatic, seasonal,
 and other variable events.  High  rainfall, antecedent rainfalls,
 cropping patterns, street sweeping  schedules,  time of travel of
 runoff, scouring and re-entry of  pollutants, etc., must  be
 considered in the evaluation.   While average conditions  shed
 light on the general situation, an  analysis  based on high
 and/or low runoff periods,  covering specific climatic events
 and seasojiaj periods,  is  more likely to provide  an accurate
 evaluation of the significance of each nonpoint  source.

     Data from sources  such as building inspection offices, soil
 and water conservation districts, and planning agencies, should
 be evaluated to  locate many of the  potential nonpoint sources
 of pollutants.   Soil survey maps, construction records,  urban
 sanitation records, and other such  documents can provide much
 information for  evaluating of the pollution  potential from
 nonpoint sources.  A number of agencies  (USGS, water treatment
 plants, health units,  etc.) maintain water quality records,
 which should provide insight  on the origin of  nonpoint sources.

     In general,  there are two approaches  for tracing the
 origin of nonpoint source loadings:

     (1)  generalized prediction and,

     (2)  monitoring and sampling,

Whichever approach or combination  of approaches is used,  the
objective should  be to determine a materials  balance  for
nonpoint sources  showing loading for each  pollutant to the
streams and origin of the  loads.   This information can be
usefully displayed on the  land use maps that  are  prepared
in conjunction with point  and  nonpoint source planning
(see Chapter 4).   The materials balance can be  broken down
to whatever degree of detail is appropriate,  depending on
the accuracy of the method for estimating  nonpoint source
loading.  In general, sampling and monitoring may be  needed
where problems are so site-specific  that  prediction techniques
cannot be used with confidence; otherwise  prediction  techniques
may  be preferable, especially those that  can be  applied  using
existing information.  However, analysis of nonpoint  source
loading should only be carried out to the  level of detail
needed to choose  best management practices.

     a.  Prediction of Nonpoint Source Loads

         Because  monitoring and sampling  for  nonpoint source
     detection is costly and requires a long  time period  to
     construct an accurate set of  data, it i^ advantageous
     to use nonpoint source load prediction  techniques.

          These techniques enable prediction of nonpoint source  load
          generation and transport based on such measurable watershed
          parameters as soil,  slope,  vegetative cover,  land use,  size
          of drainage area, etc.   While these techniques vary  in  their
          reliability, especially with regard to soluble pollutants  and
          pollutants subject to breakdown in the environment,  they are
          generally adequate for  enabling choice of best management

     Guidance on the applicability of these models  and  the  services
available from federal agencies for utilizing the models is discussed in:

     U.S. Environmental Protection Agency.   Methods for Identifying
     and Eva1uatirva_the JNat ur e _and _Extent of _Npjip_oint__Sources  of
     Ponution,  Report No.  EPA 430/9-73-014.   Washington, D.C. 1973.
     GPO, $2.45.

     Additional  guidance on prediction models and techniques for  non-
point sources is being developed  by EPA and will  be available  in
subsequent guidance.

     b.   Monitoring and Sampling  to Identify Nonpoint Sources

          Monitoring and sampling should be undertaken  in the  short
     term to identify nonpoint source loading in situations where
     more accurate estimates are  needed than can be obtained through
     use of predictive models.  Secondly,  monitoring and sampling
     should be undertaken over a  longer term to  refine  information
     on  nonpoint source loading and to serve as  a management device
     for assessing the progress made  in attaining and maintaining
     water quality through implementation of best management practices.

          In the short term, monitoring may be undertaken,  if  necessary,
     to  estimate a single gross allotment (target abatement level) for
     all  nonpoint sources contributing to  a given water quality segment.
     Also,  monitoring of carefully selected nonpoint sources may be
     undertaken  as necessary to calibrate/verify the analytical tech-
     nique chosen to estimate  the nature and relative magnitude of the
     loads associated with  each nonpoint source  category.   In  particular,
     monitoring  may be needed  to  verify or supplement loading  estimates
     for such sources as  stormwater outfalls,  waste lagoons, septic
     seepage areas,  land fills, spray irrigation areas,  and other
     significant sources that  are  difficult  to estimate through
     predictive  techniques.

          Since  it is not expected that nonpoint source load estimates
     can be verified in the relatively short  timeframe  of initial
     208  plan formulation,  it may be desirable  to  initiate an
     ongoing monitoring program to be carried out in the  plan  imple-
     mentation phase.

                   The  morrtoring and  sampling approach needed for nonpoint
              source  identification  and verification should determine
              a  schedule  of prioritized activities that will enable a
              given degree  of  identification of  individual nonpoint
              sources at  a  given point.   For example, if  the total
              nonpoint  source  load  to  the area is 1/3 of  the total
              pollutant load for a  given  pollutant, the monitoring
              and sampling  activities  should be  aimed at  verifying
              a  given percent  of the nonpoint source load by a given
              date.   Instream  water  quality data which could be related
              to specific nonpoint  source sites  should be evaluated in
              order to  determine whether  a given increment of waste
              detectable  in the stream could be  attributed to a given
              nonpoint  source.  The  sum of the wasteloads that could
              be traced back to contributing sources should be a
              given percent of the  total  nonpoint source  load that is
              chosen  for  the initial monitoring  and sampling coverage.
              If the  individual nonpoint  sources that can be identified
              do not  sum  up to that  given percent of the  total nonpoint
              source  load,  then additional data  should be collected.

6.5  Assessment  of Nonpoint Source  Management Practices

     No single control  method  or set of control  methods will be appro-
priate for all  types  of nonpoint source problems.  Even controls  for
a particular type of source will vary  in  effectiveness according  to
geographic location.  The controls  should be tailored to  local condi-
tions if they are to  be effective.   Thus, a thorough knowledge of
both specific types of  nonpoint sources and local conditions is a
prerequisite to  the design  of  appropriate and effective controls.

     The second  step  in determining  best  management practices for
nonpoint sources is the identification of the technically feasible
structural controls and the practicable nonstructural controls that
are available for particular nonpoint  source problems.  Technically
feasible control alternatives  for  particular types of nonpoint sources
likely to be encountered  ir urban-industrial areas are described  in
this section.  It should  be emphasized that these control alternatives
are cited only as examples, and that other viable alternatives, if
available, should also  be investigated and considered.

     In depth information on the various  control alternatives may be
obtained from the referenced guidance  reports for each type of source.
In general, controls  for  nonpoint  sources consist of either structural
controls or land use and  land  management  controls.  The  implementation
and enforcement of these  nonpoint  source  controls is further discussed
in Chapter 7.

     A.  Urban Stormwater Runoff

         Water pollution  from  urban runoff  is related to  both the
     quantity and quality of the  stormwater  runoff. Rainfall dislodges
     pollutants from street surfaces,  roof  tops, lawns and  other  urban


sources, causing contaminant particles  to  become  suspended  in
solution.  Subsequent runoff transports the  pollutants  across
urban land, into gutters, and eventually deposits the runoff into
receiving waters.  The pollutant concentration   is therefore
greatest at the beginning of a rainfall  event and diminishes
as rainfall continues.

     Almost every conceivable pollutant has  been  identified in
urban runoff.   The most common pollutants  include:  dust, dirt,
pathogens, fertilizers, pesticides,  battery  acid, rubber, grease,
oil, animal and bird droppings, heavy metals, salts, sand,  gravel,
coal, leaves,  paper products, plastics,  glasswares,  and metals.

     The pollutant load in a particular storm runoff depends upon
(1) the amount of material which has accumulated  or  developed on
surfaces since the last storm and (2) the  volume  and velocity of
stormwater.  A direct relationship exists  between the cleanliness
of the urban environment and the pollutants  in  storm water  runoff.

     Measures for controlling the pollution  potential from  urban
storm runoff include:

     1.  Public cooperation in reducing amounts of street litter,
     adoption and enforcement of anti-dumping and anti-1ittering
     ordinances, and public education programs, e.g. "Clean Cities

     2.  Installation of adequate waste receptacles  on  public
     streets,  street sweeping and other programs  for reducing
     the accumulation of pollutants  on  urban streets, roof  drainage
     controls, and use of catch basins  to  retain  the first  flush
     of polluted storm water runoff;

     3.  Reduction in the indiscriminate use of fertilizers and
     pest control chemicals;

     4.  Land drainage modifications for reducing or eliminating
     the runoff of polluted waste waters,  and measures  to minimize
     the impact of runoff water containing snow and  ice control

     5.  Better management of existing  storm drainage systems;
     storage and treatment of runoff waters.  (These and other
     approaches for dealing with urban  runoff once it enters the
     storm drainage system are discussed in  Chapter  5.4).

     More detailed guidance can be obtained  from:

          U. S. Environmental Protection Agency,  Urban  Stormwater
          Management and Technology:  /\n Assessment, Report no.
           6/0/2-74-040. National Environmental  Research Center,
          Cincinnati, 1974.  GPO, NTIS  (awaiting  number assignment)


          Office of Water Resources Research. Practice j_n Detention of
          Stormwater  Runoff  Herbert G. Poertner, American Public Works
          Association, 1974.  NTIS PB-234-554.

          U.  S. Department of Interior, Office of Water Resources.
          Water Resources Protection Measures JJT_ Land Development:
          A  Handbook.  Washington, D.C. 1974.  NTIS PB-236-049.

B.   Construction  Activities

     Construction  activities are major earth-disturbing  opera-
tions required for the development of  highways,  dams,  aqueducts,
housing tracts,  shopping centers, and  other facilities.   They
include stripping  of topsoils,  grading of slopes,  fertilization
and vegetation of  exposed soils, pest  control,  and site  restoration
following construction.

     Construction  related pollution  results from erosion  of bare
soils, careless  spillage of materials, increased storm water runoff,
excessive use of fertilizers,  pesticides, or other materials, and
other generally poor "housekeeping"  practices which permit  pollu-
tants to be transported from the site  area by runoff waters.

     Pollutants  resulting from construction activity consist pri-
marily of sediment,  both mineral and organic, which transport other
pollutants such  as chemicals used to fertilize  and condition soils,
pesticides, petroleum products, and  pathogenic  biological  organisms.

     Effective control of nonpoint sources of pollution  should be
done on a site-by-site basis,  and initiated during the preliminary
stages of a project.   These measures should be  considered during
site planning and  design.  Adequate  control must include  proper
maintenance of the measures installed.  Nonpoint source  control
programs might include:

     1.   Installing structural and  vegetative  measures  which will
     protect environmentally sensitive areas of the site,

     2.   Controlling the velocity and volume of runoff  water to
     prevent erosion and transport of sediments and other pollutants;

     3.   Diverting runoff and trapping sediment;

     4.   Requiring that nonpoint source control be considered in
     construction  contracts as well  as procedures  for the maintenance
     and inspection of measures installed;

     5.   Using stage grading, seeding, and sodding procedures.

More detailed guidance can be obtained from:

          U. S. Environmental Protection Agency.  Comparative Cp_s_ts_ of_
          Erosion and Sediment Control, Construction Activities, Report
          no. EPA 430/9-73-016.   Washington, D.C. 1971:GPO $2.20

          U.  S.  Environmental Protection Agency.   Processes.
          Procedures,  and Methods tp_ Control Pollution
          Resulting from all  Construction Activity,  Report  no.
          EPA 430/9-73-007.   Washington, D.C.  1973   GPO $2.30

C.   Hydrographic Modifications

     The various modifications that may be made within a body of
water  to its banks, or in its drainage area, represent a potential
source of nonpoint pollution.

     Hydrographic modifications such as channelization and urbani-
zation can increase volume and velocity of runoff causing channel
erosion in streams, resulting in sediment pollution.  Dredging
and dredge spoil disposal can introduce sediment, chemical, and
biological pollutants into waters.  Water impoundments can cause
concentration and detention of pollutants of all types.  Controls
are listed below for various categories of hydrographic modification:

     1.   Channelization

          a.   Use of impoundments to control flow rather than en-
          larging channel capacity

          b.   Use of natural contour in design rather than creation
          of new stream alignment

          c.   Use of proper materials and design in channel  construc-

          d.   Legal/institutional controls to prevent construction
          and thus avoid flood damage in flood plains

          e.   Structural alternatives - levees, floodways, retarding

     2.   Water Impoundments

          a.   Pre-impoundment design and site preparation to mitigate
          future eutrophication  problems

          b.   Prevention of poor quality water due to stratification

               (1)  multi-level  outlets
               (2)  aeration of  releases
               (3)  reservoir mixing

          c.    Eutrophication

               (1)   Reduce nutrient inflow to control  plankton and
               epilimnetic forms

               (2)   Vary water levels to control  rooted forms

     3.    Urbanization

          a.    Regulation  of  land  use to control:

               (1)   sources and type  of  pollutants

               (2)   amounb and location  of impervious  surfaces
                    (especially important in  aquifer recharge areas)

          b.    Waste management and environmental sanitation  --  pre-
          vention of waste introduction  in surface  and ground waters

          c.    Public education for waste control

     4.    Dredging  and  Dredge Spoil Disposal

          a.    Spoil  treatment during dredging  operation  -- chemical
          treatment (to aid in dewatering) and disposal  techniques
          (floculation, incineration, filtration, etc.)

          b.    Productive  uses of  spoil:

               (1)   creation  of wildlife habitat  areas

               (2)   agricultural land use

               (3)   land reclamation

     More  detailed  guidance can be obtained from:

          U.  S.  Environmental Protection Agency.  The  Control  of
          Pollution from H/drographic Modifications, Report no.
          EPA 430/9-73-017".   Washington, D.C.  1973.  GPO,  $1.95

D.    Land and Subsurface Disposals of Residual  Waste

     Disposal of residual wastes  on the land  and  in subsurface sites
may result in ground and surface  water pollution  through gradual flow
of liquid pollutants or leaching  of solid pollutants from disposal
sites.  Some of the types of sources  and possible control methods for
land and subsurface disposal  of residual wastes are the following:

1.    Land and Subsurface Disposal  of Liquid Waste

     a.    Pollution from wells,  waste,  brine,  radioactive gas
          (1)   site evaluation

          (2)   waste amenability evaluation

          (3)   construction

          (4)   requisite equipment  and  emergency  procedures

          (5)   monitoring well  and  aquifer response

     b.    Pollution from other  subsurface excavations

          (1)   siting and design of lagoons,  basins  and  pits
          to  avoid  bypassing  natural  protective mechanisms

          (2)   pretreatment,  lining,  barrier  wells,  and  outright
          use  bans

     c.    Septic  tank-percolation field systems

          (1)   abandonment in favor of  sewerage systems

          (2)   require approval  of  installation site and
          installation by competent professionals

          (3)   use  of proper  operating  procedures  and main-
          tenance for such systems

     d.    Sewer leakage

          (1)   modernization  of  sewer construction

          (2)   codes and specifications  as a  state rather than
          local responsibility

          (3)   internal  and external  inspection and  repair
          program at five year  intervals

          (4)   exclusion of the  discharge of  materials damag-
          ing  to  sewers  and/or  ground water

     e.    Tank and  pipeline leakage

          (1)   use  of corrosion-preventing coatings, cathodic
          protection or internal  linings to prevent  corrosion-
          caused  leaks

           (2)  design of storage sites to contain leaked liquids
           before soil adsorption

           (3)  automatic shut-off valves

           (4)  recovering  by pumping  techniques

           (5)  inspections and  pressure testing

 More  detailed  guidance can be obtained from:

     U.  S.  Environmental  Protection  Agency.  Subsurface  Water
     Pollution, /\ Selected  Annotated Bibliography.   Part I  -
     "Subsurface  Waste Injection"; Part  II  - "Saline Water  In-
     trusion";  Part III  -"Percolation from  Subsurface Sources".
     Washington,  D.C.  NTIS,  Part I:   PB-211-340;  Part II;
     PB-211-341;  Part III:  PB-211-342.

     U.S.  Environmental  Protection Agency.   Ground Water Pollution
     from  Subsurface Excavations,Report no.  EPA 430/9-73-012.
     Washington,  D.C.  1973.   GPO. $2.25

2.    Land  and Subsurface Disposal  of Solid  Wastes

     a.    Existing Sites

          (1)  compaction of deposited wastes and covering  with
          at least two feet of compacted  soil; slopes to pro-
          mote  runoff, thereby minimizing  infiltration

          (2)  conversion to a sanitary landfill

          (3)  diversion of surface  runoff  or streams around
          the fill  area

          (4)  establishment of vegetative  cover

          (5)  diversion of groundwater

          (6)  extraction and treatment of  polluted  water

     b.    New Sites

          (1)  diversion of surface  runoff  or streams around
          the fill area

          (2)  operation as a sanitary landfill,  including
          daily application of six-inch (minimum) layers of
          compact cover soil and application of two-foot
          (minimum) leyers of compacted soil as final cover

              (3)  sloping and vegetation of surfaces to promote
              runoff, rather than infiltration

              (4)  construction of an impervious barrier in the
              bottom of the fill area

              (5)  collection and treatment of polluted water

              (6)  judicious consideration of hydrogeological con-
              ditions in site selection

     More  detailed guidance can be obtained from:

          U.  S.  Environmental Protection Agency.  Sanitary Land Fill
          Design and Operation.  Dick Brunner and Daniel Keller,
          Washington, D.C. 1972, NTIS  PB-227-565/9

          U.S.  Department of Health.  Sanitary Land Fill Facts
          Thomas J. Sorg and H. Lanier Hickman, Washington, D.C.
          1970.  NTIS PB-204-403
E.    Agricultural  Activities

     More detailed guidance can be obtained from:

          U.  S.  Environmental  Protection Agency.   Methods  and  Practices
          for Control!ing Water Pollution from  Agricultural  Nonpoint
          Sources. Report no.  EPA 430/9-73-015.  Washington, D.C.  1973.
          GPO, $1.10.
F.  Silvicultural  Activities
    More detailed guidance can be obtained from:

         U. S. Environmental  Protection Agency.   Processes,  Procedures
         and_ Methods tp_ Control  Pollution from Sil vicultural  Activities,
         Report no.  EPA 430/9-73-010.   Washington,  D.C.  1973. GPO,  $1.25

G.   Mining Activities

    More detailed guidance can be obtained from:

         U.S.  Environmental  Protection Agency.   Processes,  Procedures
         and Methods tp_ Control  Pollution from  Mining  Activities,
         Report no.  EPA 430/9-73-011.   Washington D.C.  1973.  GPO,  $3.40
H.   Salt Water Intrusion

    More detailed guidance can be obtained from:

         U.  S. Environmental  Protection Agency.   Identification and
         Control  of Pollution from Salt Water Intrusion.   Washington,
         D.C. 1973.  NTIS PB-227-229/2.

6.6  Selection of Best Management  Practices

     A.   General

          After identifying  instream pollutant loading from nonpoint
     sources and examining technically feasible nonpoint source controls,
     the final step in nonpoint  source planning is selection of best
     management practices for  existing and new nonpoint sources.  This
     selection process should  be based on determining the cost effective-
     ness and implementation feasibility of alternative controls for
     reducing existing and potential loading to a level compatible with
     water quality goals.

          It is recognized that  information on the level of nonpoint
     source reduction  (from  existing sources) needed to meet water
     quality standards may be  difficult to obtain within the period
     of time in which  the initial  208 plan is developed.  If existing
     data are inadequate, a  best estimate of needed nonpoint source load
     reduction should  be established and monitoring of major water
     bodies should be  undertaken as necessary to establish this target
     abatement level.   In establishing this target abatement level,
     waste load allocations  and  load data for point sources on the
     segment should be considered.  Once the overall target abatement
     load is established, analysis  of nonpoint sources should be
     directed at estimating  the  nature and relative magnitude of the
     loads associated  with each  category of nonpoint source generating
     activities.   This relative  load estimation coupled with the target
     abatement level will serve  as a guide in selecting appropriate
     Best Management Practices for each nonpoint source category.  Also,
     it is important to establish a continuing monitoring program, as
     discussed in 6.4  of this  chapter, to assess the effectiveness of
     BMP implementation in achieving and maintaining water quality goals.

          It is also recognized  that information on cost and effectiveness
     of nonpoint source controls is difficult to determine.  In cases in
     which quantitative information cannot be adequately ascertained,
     more flexible procedures  for estimation and later determination
     of cost-effectiveness of  nonpoint source controls are recommended.

     B.   Relationship  with Land  Use Plan

          In determining nonpoint source control measures needed to
     meet water quality standards, any land use measures that reduce
     generation of nonpoint  sources of pollution should be accounted
     for as an element in the  nonpoint source subplan.

C.  Relationship with Management Program^

    Selection of best management practices  should  be  closely
coordinated with the development of a management program  to
implement controls for point and nonpoint sources.  A  management  pro-
gram  should establish the  following legal,  financial, and
technical  support aspects of best management practices (see
Chapter 7 for further discussion):

    1.   Regulatory mechanisms,  including legal  authority
    to  implement and enforce best management practices;

    2.   Fiscal  programs to  provide incentives to adopt best
    management practices;

    3.   Technical assistance and interagency coordination to
    help affected parties comply with regulatory program.

D.  Procedure for Selection of  Best Management Practices  -
    Existing Sources

    1.   Cost and Effectiveness  of Nonpoint  Source

        For each nonpoint source category causing  a water quality
    problem, technically feasible control options  should  be
    presented.   For each option, the cost of the control  and
    the effectiveness of the control in abating different
    pollutants (either at their source, or  their yield to
    receiving waters) should be presented.   Determination
    of nonstructural control costs should be based upon the
    opportunity cost of the control  as discussed in Chapter 9.

        (a)  Representative Data for Cost and Effectiveness

             Since the cost and effectiveness of nonpoint source
        controls depend on  the  exact circumstances in which the
        control is used, cost and effectiveness vary  considerably.
        For purposes of evaluation,  cost data should  represent
        the typical or average  situations.   This will assure
        that the cost and effectiveness of  the control is neither
        overestimated nor underestimated if it is  being considered
        for widespread application.   Naturally, if the control
        is only applicable  in very specific cases, data should
        be representative of that specific  situation.

        (b)  Estimation of  Cost and Effectiveness  Information

             Because the precise cause-effect relationship  between
        application of a given  control and  achievement of a given
        reduction of wastes to  receiving waters is difficult to
        define, calculation of  cost-effectiveness  may require pre-
        liminary estimation.


        Once a particular nonpoint source problem has  been
    identified, the approximate reduction of the source  load
    that could be obtained through a given control  can be
    determined.  Since the cost of the control  can  generally
    be assessed with some degree of accuracy,  the cost-effective-
    ness estimation enables an overall  ordering of  the most
    feasible controls for nonpoint sources.

        Plan revision and updating may be necessary if
    additional monitoring and sampling information  reveal
    the need to consider additional  controls.

2.  Preliminary Screening of Nonpoint Source Control Options

    In order to compare nonpoint source control  options, it
is necessary to reduce the number of possible  options  to
those that are technically feasible, with adequate  documen-
tation of cost and effectiveness.  A reasonable number of
control options for each significant nonpoint  source category
should be presented.

3.  Development of Alternative Subplans for Existing Sources

    Control  options for each nonpoint source category  should
be combined to form alternative subplans.   Each subplan  should
indicate the cost and effectiveness  of possible BMP's  in
meeting the target nonpoint source load reduction levels.

4.  Description of Alternative Subplans for Existing Sources

    The following information should be presented as an  input
to the systematic comparison of areawide pollution  control
alternatives (See Ch. 3.3.D.8):

        .   Wasteload  characteristics of each alternative;

        .   Total  cost of each alternative expressed as its
           present value or average  equivalent value of
           capital  and operating costs  for the overall
           alternative and subsystem components;

           Reliability of each alternative and subsystem
           included in each alternative;

        .   Significant environmental  effects of each alter-
           native consistent with NEPA procedures,  including
           a specific statement of future development  impact;

        .   Contribution of each alternative to other water-
           related objectives of the planning  area.

E.  Procedure for Selection of Best Management  Practices  -
    New Sources

    The process of selecting controls  for  existing and  new
nonpoint sources is essentially the same in  that  cost-effective-
ness and implementation feasibility the criteria  for
choosing controls.   However, for most  new  sources there are
often more options for highly effective management measures
and these higher levels of abatement should  be  considered in
the selection of best management practices  in order to prevent
future pollutant increases.

    The procedure for selecting best management practices for
new sources should be:

    1.  For each nonpoint source category  in which new  sources
    are anticipated, define the level  of abatement of pollutants
    that is needed to prevent new water quality problems.

    2.  Examine the alternative controls and practices  that
    would meet the needed abatement levels under  varying
    conditions encountered in the area.  Representative data
    for cost and effectiveness should  be used.  It may  be
    necessary to estimate the abatement levels  of the alterna-

    3.  Screen the options for best management  techniques for
    new sources and develop alternative subplans  for new
    nonpoint sources;

    4.  Describe the alternative subplans  for new nonpoint
    sources.  The following information should  be presented
    as an input to the systematic comparison of areawide
    pollution control alternatives. (See Chapter  3.3.D.8).

              .  Wasteload characteristics of each alternative,
                 expressed in percent  reduction of wasteloads
                 generated from potential  new nonpoint  sources;

              .  Total cost of each alternative expressed as
                 its present value of  capital and operating
                 costs for the overall alternative and  sub-
                 system components;

              .  Reliability of each alternative  and subsystem
                 included in each alternative;

              .  Significant environmental effects of each  alterna-
                 tive consistent with  NEPA procedures,  including  a
                 specific statement on future development impact;

                 Contribution of each  alternative to other  water-
                 related objectives of the planning area.


                                  CHAPTER 7

7.1  Introduction

     This chapter discusses the general responsibilities of the 208
management agencies, the particular tasks associated with the
regulatory and waste management programs, and issues associated with the
selection of appropriate institutional arrangements.

     Institutional arrangements for areawide waste treatment management
are the formal structure of affected government units responsible for
implementing a 208 plan.  Units of government within this structure must
have adequate authority to carry out the full range of management respon-
sibilities including, particularly, the regulatory and waste
management requirements of the Act.  It is also essential that the
arrangements assure proper management and accountability for program

     Sufficient institutional arrangements and management agency authority
for plan implementation may exist in an area when 208 planning begins.
However, the specific authority required by the Act to be vested in a
designated agency(s) will rarely have been delegated under state law to
any particular governmental entity.  Where sufficient institutional
arrangements and management agency authority do not exist, enabling
legislation should be sought and/or arrangements for plan implementation
should be created by affected levels of government.

     The designated 208 planning agency should take a lead role in for-
mulating institutional arrangements for the area in conjunction with
local governments and state agencies responsible for water pollution
control.  Given the important role of the state in providing data for
formulating certain aspects of the plan, issuing discharge permits,
approving the plan, and maintaining overall responsibility for water
pollution control, it is important to secure the state's involvement in
determining institutional arrangements.

7.2  General Management Program

     The implementation of a 208 plan depends upon the management agency(s)
carrying out a number of related functions for which they should be pre-
pared through adequate authority, resources, and organization.

     A.   Program Supervision and Coordination

          Areawide institutional arrangements must assure that the overall
     program of waste management and regulation of pollutant sources is
     coordinated, the plan implemented, and its performance assessed.  It

     is  essential  that overall  supervision  of the program and  accounta-
     bility for its operation be achieved through the designation  of an
     agency to possess the authority and resources for program oversight.
     The selection of the appropriate unit  to which this  responsibility
     will  be allocated will  require careful  consultation  among all  the
     major institutions affected by the 208 planning process.

          A number of arrangements  can facilitate coordination.   Existing
     agencies such as regional  councils, procedures such  as  the A-95
     review, or mechanisms such as  intergovernmental contracts,  agreements,
     or  memoranda  of understanding  may assist in coordinating  the  compon-
     ents  of the 208 plan.  Since a major part of the management activities
     will  involve  the administration of the regulatory and waste management
     programs, it  is particularly important that the requirements  for
     their operation be carefully considered when allocating responsibil-
     ities for general program management and coordination.

     B.    Continuous Planning

          Because  implementing a program to abate all sources  of water
     pollution will require continual attention to changing  conditions
     and pollution control needs, continuing planning is  an  integral  part
     of  208 program management.  This continuous planning responsibility
     must be allocated within the institutional framework.

     C.    Fiscal Management

          A major responsibility of the 208 management institutions will
     be  obtaining   and budgeting the financial resources  necessary for
     plan implementation.  Among other things, this will  mean  establishing
     financial arrangements to support the  regulatory and waste management
     programs, together with arrangements for the funding of continuing
     planning operations and other  administrative expenses.   Since finan-
     cial  arrangements are a crucial component in an effective management
     strategy, their detailed operation should be clearly established
     prior to plan implementation.

7.3  Regulatory Program

     The regulatory program formulated by the 208 planning agency  should
contain  the following elements:

          1.   The identification of all pollution sources in  the  208 area
          and an indication of which agencies have been designated for
          their regulation.

          2.   An indication thatthe agencies with  regulatory responsibil-
          ity possess the statutory autnority or have initiated legisla-
          tive proposals to obtain  such authority to carry out this
          activity and to utilize the specific forms of regulation called
          for in the program.


     3.   An indication of which form(s) of regulation (land use,
     permits, licenses, pretreatment standards, and associated
     fiscal policies) will be applied to pollution sources.

     4.   A specification of the technical requirements to be
     incorporated into the regulation.

     5.   Provisions that those affected by regulation will have
     adequate notice, rights of appeal, and other legal safeguards
     to encourage full compliance.

A.   Agency Selection

     Many existing agencies with responsibilities in the 208
planning area should be considered  when arranging regulatory res-
ponsibilities for specific pollution sources.   For the regulation
of point sources, these agencies would include local governments
of general jurisdiction, sewage treatment agencies, special district
authorities, and other agencies assigned public works responsibil-
ity.  For nonpoint source regulation, agencies might include soil
conservation districts, water resource control agencies, fish and
game departments, agricultural agencies, or other agencies with
resource use responsibilities.  For an adequate regulatory program
it is essential that all major pollution sources be linked to a
specific agency and regulatory procedures to assure plan implemen-

B.   Statutory Requirements

     The Act requires that a 208 regulatory program include the

     1.   To the extent practicable, provide for waste treatment
     management on an areawide basis and for identification, eval-
     uation, and control or treatment of all point and nonpoint
     pollution sources;

     2.   Regulate the location, modification, and construction
     of any facilities within the area which may result in any
     discharge in such area;

     3.   Assure that industrial or commercial wastes discharged
     into any treatment works in an area meet applicable pretreat-
     ment requirements.

     The regulatory program is also affected by Sec. 208(b)(2)(F-K)
which requires that 208 plans: 1) set forth procedures and methods
(including land use requirements) to control to the extent feasible
nonpoint pollution sources related  to agriculture, silviculture,
mining, and construction; and 2) establish processes to protect
ground and surface water quality through controls on disposition of
residual wastes and on land disposal of pollutants.


     To meet the requirements of the Act, the 208 management agency(s)
will need clear, explicit, and overall authority for their regulatory
activities.  They should riot assume that the authority is implicit
or inherent in existing law.  In some cases, the authority necessary
for some of the regulatory tasks may be present in governmental  en-
tities, or combinations of them, to be included in the 208 institu-
tional arrangements.  In other cases, additional authority may be
necessary to carry out specific regulatory responsibilities.  This
may require a delegation of authority from regional, state, or
federal agencies or new state legislative enactments.

     Thus, in some cases it may be necessary to obtain new authority.
In other cases, it may be possible to acquire necessary regulatory
authority by amending existing legislation.   Instead of enacting new
legislation or amending existing laws, it may be advisable to include
in the institutional arrangements, agencies  which already have the
needed authority but which may not normally  be involved in water
pollution control.  Examples of such agencies would include those
with regulatory power over land use and construction activity.

C.   Regulatory Controls

     The regulatory controls are the specific measures used to regu-
late a pollution source.  There are several  general forms of regula-
tion which may be used individually, or in combination, for regulatory

     1.   Land Use

          Many land use control measures could be used in a regula-
     tory program.  These -nclude:

          --zoning authority, or participation in zoning decisions
            of other agencies;

          --special zoning authority over critical areas such as
            shorelines and flood plains;

          --control of subdivision development to assure that portions
            of land critical to water quality are reserved for uses
            consistent with the 208 plan;

     2.   Permits and Licenses

          It is often possible to create permit requirements and/or
     licenses to accomplish many 208 regulatory objectives:

          --pretreatment permits may be required for effluents
            entering wastewater treatment facilities to assure
            desired water quality;

     --permits for many point sources are already required under
       the National Pollution Discharge Elimination System;

     --permits for other point sources, or licenses for activit-
       ies generating nonpoint pollution, may specify criteria
       for siting, design and performance of facilities and

     --private users of wastewater treatment facilities may be
       required to obtain permits for hookups to public waste-
       water systems.

     The effectiveness of any permit program depends on the
availability of sanctions and adequate staffing.  It is impor-
tant that 208 planning agencies give careful attention to
providing adequate sanctions for the program and to assuring
the availability of resources necessary to implement them.

3.   Standards

     In some cases, 208 management agency(s) may have the
ability to create or to modify water quality standards.  State
and local agencies may, in many instances, be able to set water
quality standards at more stringent levels than the national
standards.  Like the use of permits for regulatory purposes,
the effectiveness of the program depends upon the availability
and use of effective sanctions for noncompliance and adequate

4.   Fiscal Policies

     Various fiscal policies, such as taxation and pricing,
may be used to complement the regulatory program.

     (a)  Pricing Policy

          Pricing policy can be used to reduce the flow of
     wastewater through metering.  In this regard, there are
     two decisions which must be made.   The first, for many
     areas, is whether or not to meter.  Unless there are
     meters, charges cannot be assessed for incremental use,
     and therefore a pricing policy cannot affect flow and
     waste reduction.  Savings from a reduction in water and
     wastewater flow must be balanced against the costs of
     metering.  Relevant savings and costs apply to both the
     water and waste treatment systems.

          If a decision is made to meter, or to meter certain
     classes of users, the second decision is to determine the
     rate levels.  To encourage cost-effective choices on the
     part of users, economic analysis indicates that at the
     margin of use, rates should equal  marginal costs.  Rates
     should reflect the incremental cost attributable to flow,
     the incremental cost of BOD removal, etc.


               In practices  and in current guidelines,  the emphasis
          on developing user charges has been on identifying average
          costs attributable to flow removal  of BOD or  other consti-
          tuents.  While rates  based on such  estimates  are not ideal,
          they have been effective in inducing wastewater flow reduc-
          tion and industrial  process change.

          (b)  Taxation Policy

               Differential  assessment ratios, where legal, can
          serve as an inducement to keep land in a nonurban classi-
          fication for open  space or low density.   Such a policy
          permits owners to  maintain land in  its present use, but
          does not prohibit  its sale for a more intensive use at a
          later date.  The policy therefore tends  to slow down the
          rate of development,  without completely  prohibiting it,
          but gives no assurance that the most environmentally
          sensitive areas are given the most  protection.

D.   Technical Requirements

     To determine whether compliance with a regulatory  program is
being achieved, the program  should include a  specification of the
type of pollutant to be regulated from each pollution source and
the level  of control which is sought.  This regulatory  goal should
be clearly understood by those  responsible for assuring compliance
and those regulated by the program.  A more detailed discussion of
technical  requirements may be found in Chapters 3.3, 5, and 6.

E.   Procedural Requirements

     The regulatory program  should incorporate adequate compliance
procedures and arrangements  to  protect the interests of those
affected by the program.  The procedural arrangements in the program
should include at least the  following:

          1.   A procedure for  giving adequate notice to those
          regulated by the plan concerning when, where, and how
          the regulation will apply to them.

          2.   Information to regulated parties specifying how they
          are expected to conform to the regulatory program.

          3.   A method for hearing and responding to grievances
          among those affected by regulation.

          4.   A notice and  hearing procedure for major regulatory
          decisions made by the management agency(s).

          5.   Provisions for public participation in the adminis-
          tration of the regulatory program.

           In order to devise an effective regulatory program to implement
      208 plans, it may be useful to take an inventory of existing regula-
      tion for each pollutant source category.   Each category may be iden-
      tified together with the agency responsible for its regulation, the
      legal authority for such regulation, the form of regulation, techni-
      cal standards for assuring compliance, and the necessary procedural
      safeguards involved.  Based upon an assessment of the adequacy of
      existing regulation to deal with each pollutant problem, necessary
      modification of existing regulatory approaches can be proposed.  The
      need for additional legislation to establish adequate regulation of
      pollution sources should be assessed as early as possible in the
      planning process so that action may be taken to obtain the necessary
      regulatory authority.
7. 4   Waste .Ma_nagercont Program

      A waste management program consists of all  those activities necessary
to create, operate, finance and enforce the areawide waste treatment management
plan created through the 208 planning process.   It is particularly important
that management agencies obtain the required authority for these tasks  as
described in Section 208(c)(2) of the Act and that they develop effective
management strategies for implementing these responsibilities.   Management
agencies should not rely upon implied powers for their authority but should
obtain explicit authority for their tasks.  It is very likely that some of
the required authority will not be possessed by management agencies when 208
planning begins and will have to be explicitly obtained before the 208  manage-
ment phase begins.  The waste management tasks include all those mentioned

      A.  Securing Comprehensive Authority

          Section 208(c)(2)(A) requires that there be adequate authority
      "to carry out appropriate portions of an areawide waste treatment
      management plan	".  The tasks for which this authority is needed
      are described in Sec. 208(b) and include:  municipal and treatment
      works,, residual waste management,  and nonpoint
      source management.  Usually, this authority will  be distributed among
      several agencies in the 208 area.  An important planning  task is  to
      allocate, and sometimes to consolidate, this authority among those
      units responsible for the management program.   The plan must identify
      agencies necessary to carry out the plan.

          Section 208(c)(2)(B) requires that there be adequate authority
      to "manage effectively waste treatment works and related facilities
      ..." in conformance with the plan.  In this regard, the broad defini-
      tion of "treatment works" set forth in Sec. 212(b) and discussed  in
      Chapter 5 should be kept in mind.  Institutional  arrangements must
      incorporate some means of coordination among the agencies involved
      in administering the plan so that conflicts can be resolved and the
      plan properly enforced.


B.    Operations Management

     The Act requires in Section 208(c)(2)(C) that there be adequate
authority "directly or by contract, to design and construct new
works, and to operate and maintain new and existing works as required
by [the] plan...".  Generally, existing waste treatment agencies al-
ready have this authority.  However, where works are to be located
outside the immediate jurisdiction, or when discharges from outside
the immediate jurisdiction are to be accepted, adequate enabling
legislation to meet this requirement may have to be enacted.  When
approval of a superior agency is required, it should be secured
before a construction grant application is made.  The management
plan should provide sufficient manpower, fiscal  resources, and
administrative expertise to assure that the customary management
tasks associated with such a waste treatment operation are properly

C.    Financing

     The Act requires in Section 208(c)(2)(D) that there shall be
adequate authority "to accept and utilize grants, or other funds
from any source for waste treatment management purposes."  Most
waste treatment agencies have this authority under state law.  Where
such authority does not exist, enabling legislation should be passed.
Some states have arrangements permitting state agencies to redistri-
bute grants among local government units, but the Act requires that
the full federal share of funding for treatment agencies be distri-
buted to the local units.

     Section 208(c)(2)(E-G) deals with other authority required in
relation to financial arrangements.  It should be noted that Sec.
204(b)(l)(A) and (B) require that all user charge arrangements must
assure that each user pay his proportionate share of service costs
and that there be full industrial cost recovery in the program.
Many existing arrangements for assessing user charges are not likely
to meet these tests.  See Chapter 8 for a detailed discussion of
user charges.

     In addition to these specific statutory requirements, the
management agency(s) must be prepared to deal with the customary
fisca-1 responsibilities for program management, including the
raising and transfer of funds internally, and the apportionment
of responsibility for financing operating costs of the program
among the constituent units.

D.    Sanctions

     An effective waste treatment program includes sanctions.
Section 208(c)(2)(H) requires that there be adequate authority
"to refuse to receive any wastes from any municipality or sub-
division thereof, which does not comply with any provisions of

     [the] approved plan...".   This authority, which may be exercised by
     an appropriate state agency, would be used only in extreme cases,
     and only if such measures as negotiations, fines, additional  charges,
     moratoria, and court settlements have proven unsuccessful.

          The Act also requires in Sec. 208(c)(2)(I) that there be ade-
     quate authority "to accept for treatment industrial wastes."   This
     authority also extends to refusal of wastes which do not meet appli-
     cable pretreatment requirements as mentioned in Sec. 208(b)(2)(C)
     (iii).  Other grounds for refusal exist when an industry does not
     comply with the 208 plan or violates applicable state or federal
     discharge laws.

7.5  Basic Issues in Management Agency Designation

     Many issues will have to be resolved to determine the management
agency(s) and institutional arrangements necessary to meet the require-
ments of the Act.  The basic issues are:

               1.   What agency will exercise responsibility for overall
               program supervision and enforcement?

               2.   To what extent will the affected state be involved
               in the areawide institutional arrangements?

               3.   Will implementation responsibility be vested in a
               single agency or diverse agencies?

               4.   If consolidation of responsibilities is undertaken,
               will it be accomplished through unification or inter-
               governmental contracts and agreements?

               5.   What measures will be taken to assure that local
               land use decisions do not adversely affect water quality?

               6.   To what degree will the state delegate some of its
               regulatory or supervisory authority to substate entities
               and general purpose local governments?

               7.   To what degree will agencies be supported from tax

               8.   How much financial assistance can be expected  from
               the state for construction, operation, and other functions?

Below is a chart which suggests where responsibility for major elements
in  the management of the 208 plan might be located:


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s management

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A.    Options in Designation

     The choice of agency or agencies designated to carry out 208
program responsibilities will  probably be influenced by the number
of local governmental  jurisdictions that either operate waste
treatment systems or exercise authority over land use, stormwater
runoff, and nonpoint source controls.  Generally, the options for
designation are:

     1.   Single Planning and Management Agency

          One option is to establish a single planning and manage-
     ment agency with the same geographical  jurisdiction as the
     208 area.   In some situations where a single governmental
     jurisdiction encompassing the entire 208 area already exists,
     it may be assigned both the planning and management respon-
     sibilities.   This would facilitate closer coordination
     between planning and management than would be possible if
     these two responsibilities were assigned to separate agencies,
     and would also achieve greater economies of scale in carrying
     out plan responsibilities.  Where such  an agency is based
     partly on a Council of Governments (COG) or regional planning
     agency which has been designated as a clearing house agency
     under A-95, final approval of specific  projects in the 208
     area can be expedited.  Where A-95 authority is lacking,
     adequate provisions should be made to insure that elected
     officials are included on the planning  agency board so as to
     meet the representation requirements of the Act.

     2.   Single Planning Agency and a Single Management Agency

          Another option is to divide the planning and management
     responsibilities between two separate agencies.  This would
     make day-to-day coordination more difficult, but might
     facilitate approval of specific projects if the planning
     agency has A-95 authority.  A previously established COG
     or regional  planning agency could be utilized as the plan-
     ning agency for 208.  Since such organizations already have
     local elected officials on their boards, the representation
     requirements would automatically be met.  Where separate
     management agencies are involved in waste treatment, consoli-
     dation of such agencies would have to be brought about,
     entailing some loss of local authority.  Economies of scale
     could also be attained as in the first  option above.

     3.   Single Planning Agency and Plural  Management Agencies

          A third option would be a single planning agency and more
     than one management agency.  This would allow those management
     agencies already providing waste treatment service to continue
     with a minimum effect upon their internal administration.   While
     coordination between the planning agency and the management
     agencies would be more difficult, individual government juris-
     dictions could retain their own waste treatment agencies and
     other authority.   This option, therefore, would permit the


     maintenance of existing  institutions  and agencies  to  a  greater
     degree than the other options.   Representation  requirements  of
     the Act could be met by  the planning  agency as  in  the other
     options.   Economies  of scale in plan  implementation,  however,
     would not be likely  due  to fragmentation.   Two  approaches  to
     securing  supervision and enforcement  in  plan implementation
     should be considered:

          a.   A single supervisory  agency with  clear responsibility
          and  resources for overall  management,  coordination,  and
          plan enforcement.

          b.   Apportionment  of some of the responsibilities for
          plan supervision and enforcement among several agencies
          with one given  the  lead role.

     The advantage of fixing  responsibility for  supervision  and
     enforcement of the plan  upon a  single agency is clear account-
     ability and greater  coherence in conflict resolution, plan
     coordination, and overall management  activities.  Dividing
     responsibility for program supervision and  coordination among
     several agencies while designating one as the lead agency  may
     disturb existing agency  powers  and relationships less and
     reduce the difficulties  of formulating a satisfactory manage-
     ment scheme.

B.    Intergovernmental Agreements

     No matter which of the above options  is  chosen, formal  inter-
governmental agreements must  be made.  Adjustments in the  authority
and in services of local, regional or state governments in a 208
area may be effected by different forms of legal agreement and
statutory authorization.

     1.    Contract

          Where a single  agency already encompasses  the entire
     §208 area, other participating  local  units  (county, metro-
     politan government,  or metropolitan special district, etc.)
     of government may contract with it to provide the  services

     2.    Joint Exercise  of Powers

          Where they do not already  exist, consolidated agencies
     may be established jointly by the participating local units
     of government.  Inter!ocal contracts  or agreements may  be
     utilized in such joint exercise of powers.

     3.    Delegation of Responsibility

          Where a new areawide agency is established, the  state may
     transfer functions to it from other local,  regional,  or state
     agencies through appropriate enabling legislation.


C.   A-95 Review

     In accordance with OMB (Office of Management and Budget)
Circular A-95 Revised, dated November 13, 1973, all applicants under
federal programs which provide assistance to state, local, and area-
wide projects and activities planned on a multijurisdictional basis
must notify the appropriate state and areawide planning and devel-
opment clearinghouse for review and comment.  The proposed applica-
tion will be reviewed for its consistency with areawide plans
including comprehensive planning, environmental concerns, water
supply and distribution systems, sewage facilities and waste treat-
ment works, and land use.  In most cases, either a regional planning
agency or COG serves as the regional clearinghouse, and, as mentioned
above, may be utilized as the areawide planning agency under §208.
As part of its review responsibilities, the state should ensure that
any proposed applications are consistent with basin planning under
§303.  On the national level, EPA reviews the annual certification
of state plans.

                                  CHAPTER 8

                           FINANCIAL ARRANGEMENTS
8.1  Introduction

     Financial planning is an integral part of the 208 areawide planning
process.  Financial arrangements necessary for implementing the 208 plan,
and consistent with the capability of the 208  management agency (s), should
be included  in the plan.

     This chapter identifies problems which may arise in complying with
the financial requirements of the Act.  It does not describe methods or
procedures for funding capital construction, for raising revenue, or for
assessing waste treatment charges, since the applicants are best able
to determine financing methods most suitable for their particular prob-
lems and authorized under their enabling legislation.

     These problem areas are divided into three categories:

     A.   Capital construction costs

     B.   Operational costs (revenue)

     C.   Indirect (overhead) coststo be financed

With respect to each of these financing arrangements, pertinent
provisions of the Act and specific problems are set forth below.
Short-term and long-term budgeting and other financial activities
are also discussed.

8.2  Requirements of the Act

     Provisions directly and indirectly affecting financial arrangements
are contained throughout the Act with those specifically affecting 208
areawide waste treatment management set forth in Title II.  To comply
with these various requirements, there should be a unified
approach to planning and budgeting the financial arrangements.

     A.   Capital Construction Costs

          1.   |208(b)(2)(E) requires that the areawide management plan
          include identification of the measures necessary to carry out
          the plan including financing and the costs of carrying out the
          plan within the necessary period of time.  This applies to all
          capital costs associated with point and nonpoint source controls.

     2.    §204(a)(4)  requires that the applicant proposing to con-
     struct treatment works; agree  to pay the non-Federal  costs of
     such work.

     3.    |204(b)(l)(C) provides that the Administrator shall not
     approve any grant for any treatment works unless he shall first
     determine that the applicant has the financial capability to
     insure adequate construction, operation and maintenance of the
     treatment works  throughout the applicant's jurisdiction.

     4.    |208(c)(2)(C) requires that the waste treatment management
     agency(s) have adequate authority directly or by contract to
     design and construct new works and operate and maintain them.

     5.    §208(c)(2)(D) requires that waste treatment management agency(s)
     have adequate authority to accept and utilize grants or other
     funds from any source for waste treatment management purposes.

     6.    |208(c)(2)(F) requires that the waste treatment management
     agency(s) have adequate authority to incur short ^nd long term

     7.    |204(b)(l)(B) provides that the Administrator shall not
     approve any grant for any treatment works unless the applicant
     has made provision for industrial cost recovery (recovery from
     industrial  users of the portion of the Federal share of treat-
     ment works  construction cost attributable to industrial waste

     8.    Section 12 of the Act provides for an Environmental Financing
     Authority under the Secretary of the Treasury.  This Authority is
     established to assure that inability to borrow necessary funds
     on  reasonable terms does not prevent state or local public
     bodies from carrying out waste treatment works construction
     projects eligible for assistance under the Act.  The Authority
     is  authorized to purchase the financial obligations of these
     public bodies to finance the non-Federal share of such construction.

B.   Operational Costs and Assessment of Revenue

     1.    §204(b)(l)(C) provides that the Administrator shall not
     approve any grant for any treatment works unless the applicant
     has financial capability to insure operation and maintenance
     of  the treatment works.

     2.    |208(c)(2)(E) provides that the waste treatment management
     agency(s) must have adequate authority to raise revenues, includ-
     ing the assessment of waste treatment charges, to implement all
     elements of the plan.

          3.   |208(c)(2)(G) provides that the waste treatment manage-
          ment agency(s) must have adequate authority to assure, in
          implementing an areawide waste treatment management plan,
          that each participating community pays its proportionate
          share of the treatment costs.

          4.   |204(b)(l)(A) provides that the Administrator shall not
          approve any grants for any treatment works unless the appli-
          cant has adopted a system of user charges assuring that each
          recipient-of waste treatment services will pay its propor-
          tionate share of the cost of operation and maintenance (in-
          cluding replacement) of any waste treatment services provided
          by the applicant.

     C.    Indirect (overhead) Costs to be Financed

          1.   Continuing planning is an indirect cost to be financed
          by the management agency.  |208(b)(3) requires that the area-
          wide waste treatment management plan shall be certified annu-
          ally by the governor of the state or his designee as being
          consistent with the applicable basin plan.  The interim grant
          regulations (40 CFR Part 35.1054-2(e) ) specify that the
          grant application include "A statement by the applicant that
          the planning process will become financially self-sustaining
          and provide for annual update of the plan once the initial
          plan is developed and approved."

          2.   §208(b)(2)(F)-(K) provide that the areawide management
          plan shall  include processes to identify and/or control
          nonpoint sources of pollution.  Nonpoint source planning is
          an especially important part of continuing planning.

          3.   §201(e) provides that the Administrator shall encourage
          waste treatment management which results in integrating fac-
          ilities for sewage treatment and recycling.  It further pro-
          vides that such integrated facilities shall be designed and
          operated to produce revenues in excess of capital and oper-
          ation and maintenance costs and that such revenues shall be
          used by the designated regional management agency to aid in
          financing other environmental  improvement programs.
8.3  Specific Problem Areas

     A.    Capital  Construction Costs

          Due to the number and variety of methods for financing waste
     treatment management under state and local  laws, each plan should
     include the broad range of financial arrangements available rather
     than follow    any rigid formula.   Some requirements of the Act
     should present few if any difficulties with regard to financial
     arrangements; others are more likely to cause problems.  Financial
     arrangements  which should be relatively easy to provide are as


     1.    Capital  funds may be raised or generated from the general
     fund, particularly if the applicant is a governmental  unit of
     general  jurisdiction.

     2.    Capital  funds may be generated from grants or funds from
     any other source.   In some instances, matching funds may be

     3.    The capacity and ability to contract indicates a  limited
     ability  to generate short-term indebtedness.

     4.   The  capacity to incur short-term indebtedness may  be demon-
     strated  by the ability to issue bond anticipation notes, grant
     anticipation  notes, or to borrow from state agencies.   Such short
     term indebtedness must, of course, comply with constitutional
     limitations on borrowing and with any state or local statutory

     5.    The capacity to incur long-term debt may be demonstrated
     by the capacity to issue general obligation bonds, revenue bonds,
     or the capacity to borrow from  state agencies.  Exercise of this
     capacity to borrow is of course limited in many instances by
     constitutional or statutory provisions.   There must also be com-
     pliance  with   state and local statutory requirements for the
     issuance of bonds or the incurring of such long-term indebtedness.

     Areas in which problems may be encountered in complying with the
Act include the following:

     1.    The industrial coc;t recovery requirements of the  Act are
     specifically covered in 40 CFR  35 Subpart E, of the grant regu-
     lations.  Industrial cost recovery charges may be allocated on
     a systemwide basis provided that the treatment works project for
     which the grant is made is substantially interconnected, with a
     goal to  be completely interconnected physically to all other
     portions of the system.

          Where revenue bonds are used to finance the local share of
     construction  costs, funds designated for bond repayment, should  be
     accounted for separately from those received in compliance with
     industrial cost recovery requirements.  This should avoid any
     problem  in establishing priorities for repayment to revenue bond
     holders  entitled to receive the industrial cost recovery share  of
     total revenues.  In instances where industrial users must make
     long-term commitments for repayment, provision might be made for
     transfer of this commitment, in order to facilitate industrial
     growth and change within the area.  Since it is implied that a
     long-term commitment to repay is in exchange for provision of
     services to treat the user's industrial  wastes, such rights to
     services should be transferable.  Both the commitment  and the
     right to services should be transferable, subject, however, to
     approval by the waste treatment management agency.

     2.   In the event of consolidation of two or more areas or
     agencies, each of which had incurred indebtedness and other
     contractual obligations in supplying waste treatment services,
     a legally acceptable method must be set forth for the consolidated
     agency to assume payment of the debts and obligations.   Personnel
     contracts, retirement benefits, long-term supply contracts, etc.,
     should be paid particular attention.

     3.   In the event of treatment system consolidation, problems
     may arise over the new waste treatment management agency reim-
     bursing the participating agencies for the value of their exist-
     ing facilities and assets.  A fair and uniform method of deter-
     mining the values of these assets and a legally acceptable
     method of handling the transfer should be set forth.

B.   Operational Costs and Revenue Assessments

     1.   User charges.  40 CFR  35 Subpart E, and related guidelines
     provide the basis for establishing user charges.  As set forth
     in these regulations and guidelines, the Act requires that each
     recipient of waste treatment services pay its proportionate share
     of costs of operation and maintenance.  Charges based on property
     values only will not suffice to satisfy this requirement, except
     in cases where such charges have been used historically, the
     change-over would be costly and disruptive, and the goal of pro-
     portionality among user classes can be achieved by such systems.
     Uniform rates on volume among classes of users will suffice if
     the classification reflects the differences in cost of treatment
     among classes of users.

     2.   Participating communities' proportionate shares.  In deter-
     mining each participating community's proportionate share of
     treatment costs, the differentials among communities should be
     explained and justified.  In the event that all participating
     communities are charged on the same basis, justification should be
     given.   The provisions and effects of interlocal agreements and
     contracts to supply waste treatment services should be  reviewed
     and set forth.  The methods of charging users within each of the
     participating communities should be defined.  The user  charge
     requirement cannot be avoided by interlocal agreements  or con-
     tracts to supply waste treatment services.  User charge require-
     ments must be reflected in determining the participating commun-
     ities'  proportionate shares of treatment costs.

C.   Indirect (Overhead) Cost to be Financed

     1.   The amount and source of funds for ongoing planning should
     be set forth in the budget, and should include provision for
     items such as discharge source inventory, monitoring, surveillance,
     and performance evaluation as needed to supplement state support.

          2.    The ongoing planning  process  also  requires  public  partici-
          pation.   The cost of providing  information  and encouraging  public
          participation should be  budgeted.

          3.    To  the extent that  the  areawide  waste  treatment  management
          agency is involved in the  ongoing  identification and  control  of
          nonpoint sources of pollution,  the cost should be budgeted  and
          the source of income indicated.   If performed by state  level
          agencies, this should be noted.
8.4  Budget Preparation and Supporting Documentation

     A.    The plan should include a projection of financial  means to
     provide treatment works necessary to meet the anticipated municipal
     and industrial  waste treatment needs of the area over the 20-year

     B.    A more detailed 5-year projection including capital  improvement
     budgeting and cash flow should be provided.  It should include start-
     up costs, carrying charges during the first years of operation and
     similar nonrecurring costs associated with the implementation of a
     new treatment works or waste treatment management plan.

     C.    The legal  authority of the agency(s) to undertake the financing
     necessary for plan implementation should be described in  an opinion
     letter from the legal counsel for the agency(s).  This opinion letter
     could also be prepared by counsel experts specialized in  the field of
     bond financing.

     D.    The financial capacity of the agency(s) to implement the plan
     should be described in a report prepared by the independent auditor
     for the agency(s).  For example, the extent to which the  agency(s)
     has unused bonding capability should be identified if general obli-
     gation bonds are to be used as a method of financing.

     E.    The method for obtaining budget approval for the 5 year capital
     improvement budget should be described, and should indicate the sche-
     dule for obtaining such approval.

     F.    The relationship of the regulatory program needed to enforce the
     plan (see Chapter 7) to the budget should be described.   For example,
     the use of fiscal and regulatory means to limit and control new
     sources of pollution will influence the amount of new sewage treatment
     capacity needed in an area.  The adequacy of the budget for sewage
     treatment financing is thus dependent on the adequacy of  the area's
     control over location and generation of new pollutant sources.

                                  CHAPTER 9

                            DIRECT RESOURCE COSTS
9.1  Introduction

     The Act requires that areawide plans consider alternative methods
for waste management, that the cost of carrying out alternatives be
identified, as well as their economic, social and environmental impacts,
and, generally, that the choice of alternative be "cost efficient" oV
"cost effective" -- that is, water quality goals should be met at minimum

     As cited in Chapter 1.7, cost-effectiveness analysis is defined as
the systematic comparison of alternatives to identify the solution which
minimizes total costs to society over time and reliably meets given goals
or objectives.  Total costs to society include resource costs plus eco-
nomic, social, and environmental costs.   The analysis involves identifi-
cation and study of the tradeoffs among resource costs, environmental
effects and other economic and social aspects of the alternatives, leading
to selection of the best plan.

     Resource cost (discussed in this chapter) refers to the value of
goods and services used in a given project and  includes  capital cost as well
as operations, maintenance and replacement cost.  Resource cost may
usually be measured in monetary terms; economic, social and environmental
effects, discussed in the next chapter, are more difficult to quantify,
and must be described and evaluated in a more subjective way.

9.2  Basic Concepts in Identifying Resource Costs

     A.   Economic Cost

          In considering the cost of implementing a plan, it is necessary
     to distinguish between outlays and economic cost.   In many instances
     cash outlays adequately represent cost, but sometimes a resource is
     used, with no cash outlay.  The cost in such a case is the value of
     the resource in its best alternative use -- its "opportunity cost."
     For example, acquiring public land for a treatment plant may involve
     no cash outlay, but may have an opportunity cost in terms of foregone
     recreation or commercial use.  If opportunity costs are not considered,
     plan selection will be biased toward those options which do not require
     outlays, despite their other costs.  Moreover, the concept of oppor-
     tunity cost accounts for the cost to the community and nation as a
     whole in evaluating alternative plans, not merely the cost to one party
     or another.

     B.    Price  levels

          Where  costs are  estimated  for  future  periods,  they  should  be
     stated  in terms of base  period  dollars.  Future  costs  should  not
     reflect any expected  overall  increase  in wages and  prices,  unless
     there is reason to expect,  significant  changes in relative prices
     during  the  planning period.   For  example,  due to the present  ener-
     gy  shortage,  long  term prospects  are for higher  energy costs.
     While it is difficult to predict  how much  costs  will rise,  alterna-
     tive  plans  should  be  tested for one effect of higher energy costs.

     C.    Interest rates

          Discounting is a way  to  account for the opportunity cost of
     funds invested in  a project,  in the sense  that the  funds could  also
     have  been used productively in  the  private sector of the economy or
     in  some other public  project.   The  applicable discount rate deter-
     mines the optimal  choice between  capital expenditures  now versus
     higher  operating costs in  the future,  the  optimal amount of reserve
     capacity to build, and so  on.

          In discounting,  the costs  of a plan are stated in terms  of their
     present values.  That is,  future  costs are discounted  at an applicable
     rate  of interest back to some initial  starting date, and added  to the
     initial  capital costs.   Alternatively, the present  values may be
     converted into equivalent  annualized values.  Standard procedures are
     described in  engineering economics  and business  finance  texts.

          The interest  rate to  be  used in evaluating  water-related public
     projects is prescribed by  the Water Resources Council, a Federal
     inter-departmental group,  in  its  "Principles and Standards  for  Plan-
     ning  Water  and Related Land Resources", as amended  by  PL 93-251  (1974).
     The rate specified by the  Council is based on the interest  rate on
     Federal  Securities with  maturities  of  15 years or more.  The rate to
     be  used for each fiscal  year  is determined by the Council on  July 1.
     For fiscal  years 1975 and  1976, the rates  are 5  7/8% and 6  1/8% respectively.

9,3 Specific Cost Questions

     A.    Sunk Costs and Salvage Values

          Sunk costs and salvage values  refer to capital assets  in exist-
     ence  at the beginning or end  of a program.

     For simplicity, investments and cost commitments made prior to
or concurrent with the planning study are regarded as sunk costs and
are not included as a cost for plan evaluation and comparison.   Such
investments and cost commitments include, for example: (1) investments
in existing wastewater treatment facilities and associated lands to
be incorporated into a plan; (2) outstanding bond indebtedness.   How-
ever, if inherited assets were to be disposed of in one alternative
-- for instance, a small treatment plant scrapped and the land  sold --
their sale value would be treated as a credit to that plan.

     Salvage value.  At the end of the planning period, land for
treatment works (including that used as part of the treatment process
or for ultimate disposal or residues)  should be assumed to have a
salvage value equal to its market value at the time of the analysis,
less any costs required to restore the lands to pre-project conditions.
Salvage value of land reclaimed by land treatment of sludge disposal
should be estimated as the value of the reclaimed land.  Rights-of-
way and easements should be assigned a salvage value not greater than
the market value at the time of the analysis.

     Permanent structures should be assumed to have a salvage value
at the end of the planning period if those structures can be expected
to continue fulfilling their planned use.  Salvage value should be
based on the remaining functional life of the structure using a
straight line depreciation over the assumed functional life of  the
structure.  The same approach applies to process and auxiliary  equip-
ment that will have usable value at the end of the planning period.

B.   Capital and Operating Costs

     Elements of total cost include capital construction cost,  annual
operation and maintenance costs, and equipment replacement costs.

     As set out in EPA cost-effectiveness guidelines (40 CFR 35),  capi-
tal costs for facilities include: cost of land, relocation and  right-
of-way and easement acquisition; design engineering field exploration
and engineering services during construction; contractors' costs,
including overhead and profit; administrative and legal services,  in-
cluding cost of bond sales; and startup costs such as operator  train-
ing.  Contingency allowances consistent with the level of complexity
and detail of the cost estimate are also included.

     The capital costs of a plan would include those incurred by both
public agencies and private parties.  These two categories of cost are
utilized in the summary table shown in Chapter 12.  Treatment facilit-
ies built by industrial companies for direct discharges or for  pre-
treatment would be included in private costs.

     Where waste and flow reduction measures are carried out by a
large number of industrial and household dischargers, it is diffi-
cult to estimate the private costs.  Unless the costs have a bearing
on the choice of a cost-effective plan, such estimates are unnecessary.

     Annual operating and maintenance costs for each alternate plan
must be established.  These costs should be adequate to ensure effect-
ive and dependable operation and should include all costs for operating
and maintaining the facilities under study including power, labor,
parts, materials, overhead, chemicals and repair or replacement of
equipment and structures.

     Cost-effectiveness analysis requires establishing a service life
for each component and salvage values for components having service
lives longer than the planning period.  The following service lives
are to be used, unless other periods can be justified:

                     Land                Permanent
                     Structures          30-50 years
                     Process Equipment   15-30 years
                     Auxiliary Equipment 10-15 years

C.   Administrative Costs

     Areawide waste planning and management is likely to include a
number of ongoing costs for activities not always associated with
sewage facilities management.  These activities include monitoring
of streams, monitoring the waste characteristics of major industrial
dischargers, periodic checks of infiltration and
storm and runoff characteristics, collecting and
residential water use, etc.  These functions are
effectiveness of a plan as; the physical units in
may not vary significantly in alternative plans,
eluded in financial projections.  Recovery of costs by direct charges
— e.g., permit fees, monitoring fees, etc. — should be considered
and evaluated.
inflow, records of
analyzing data on
as important to the
place.  The costs
but should be in-
D.   Accuracy of Cost Estimates

     The accuracy of cost estimates for all point and nonpoint ele-
ments of 208 plans should be sufficient to assure the selection of
the most cost-effective solution.  Gross cost estimates ordinarily
suffice for preliminary screening.  Plans selected for detailed
evaluations should be compared on the basis of the following types
of information:

     0 Unit process costs associated with the different wastewater
       and sludge treatment processes considered.  The unit costs
       should be applicable to the locality or region.

     0 Preliminary engineering layouts, quantity estimates, and
       unit costs for the sewer lines and appurtenant works.  Unit
       costs should be representative of the area, based on recent
       comparable projects.

     0 Market value of land or easements required for facilities.

     The above detail of cost estimates should be sufficiently re-
fined to provide a basis for the 5-year financial budget stipulated
in Chapter 9.  Such estimates might be based upon preliminary engin-
eering layouts and designs, taking account of facilities in place.
Should the more refined estimates of the selected system differ
considerably from the previous estimates, the prior evaluations of
alternatives should be revised.  As discussed in Chapter 8, financial
budgets should cover the first five years; therefore, the level of
detail for cost  estimates should be greater for that period.

E.   Present values

     Using the interest rate discussed in  9.2.C, the costs for
construction and operations, by year, should be discounted to the
proposed plan initiation date  to obtain the present value (or,
what is much the same thing, the annualized value) of the plan
alternatives.  An example is given in EPA Guidance for Facilities
Planning, January 1974.

                            CHAPTER 10

                       PUBLIC PARTICIPATION
10.1  Introduction
      A.  Need for Public Involvement

          The success of a 208 plan depends on its  acceptance  by
affected units of local  government.  It is important that the  general
public in the 208 area be actively involved in plan development and
that public participation in the later management phase of the plan
be encouraged.  Due to the complexity of the 208 planning, it  is
necessary to provide a structured program of public involvement to
assure adequate exchange of information and opinion between the public
and the planning agency.

      B.  Legal Requirements

          Public participation is an important element in any  water
resources planning effort.  Section 101(e) of the Act states:

               Public participation in the development, revision,
               and enforcement of any regulation, standard, effluent
               limitation, plan or program established by the
               Administrator (of EPA) or any State  under this  Act
               shall  be provided for, encouraged, and assisted by
               the Administrator and the States.

This means that public participation must be encouraged during the
development of the 208 plan and that adequate provision should be
made in the plan for public participation in the work of the management
agency to implement the plan.

          The Environmental Protection Agency has published regulations
specifying the minimum guidelines for public participation in  water
pollution control efforts.  These regulations (40 CFR 105) require
state agencies to do the following:

     1.  To provide technical  information "at the earliest practi-
         cable times and at places easi ly accessibleto interested
         or affected persons and organizations" and to assist  the
         public in understanding and responding to  water programs.

     2.  To have "standing arrangements for early consultation and
         the exchange of views with interested or affected persons
         and organizations on development or revision of plans,
         programs or other significant actions prior to decision-

To maintain a current list of interested persons and
organizations to be notified, when appropriate or
required by law., concerning agency hearings, rule-making
or other significant actions.
      4.   To develop procedures  to  insure  that  information  and  evi-
          dence concerning  water programs, when submitted by citi-
          zens, will receive proper attention.   In  particular,
          public reporting  of water pollution law violations is  to
          be encouraged.

      5.   To provide "full  and open information on  legal proceedings
          under the Act"  to the  extent consistent with  court require-
          ments and to a  degree  that does  not prejudice the conduct
          of litigation.

      6,   To provide opportunities  for public hearings  on proposed
          regulations where appropriate or required by  law. Public
          hearings should be conducted whenever there is sufficient
          public interest in a matter.  Whenever doubt arises con-
          cerning the degree of  public interest, the question  should
          be resolved in  favor of a hearing or, if  necessary,  by
          providing an alternate opportunity for public participation.
          EPA regulations on procedures for public  hearings should be
          followed if state agency  procedures are less  stringent.
          (See 40 CFR 105.7 for  guidelines concerning public hearings),

      The activities listed represent only the  minimum  steps that local
agencies  should undertake to provide for public involvement.   In many
instances, however, there are alternative  methods for accomplishing this
public involvement.  The  rest of this chapter discusses ways to comply
with these requirements through  a variety  of formal programs of public

10.2  Public Participation  Program  Development

      A.   Relationship with the  Planning Process

          A program for public involvement should be formulated as soon
      after designation of the 208 agency  as possible.   The program, an
      integral part of the  planning process, should outline the specific
      means for public participation at each step  in the process,
      including development, and  modification of the work program.  The
      planning process should be designed  so progression from  one stage
      to  another cannot take place without certain  well-defined inputs
      from the public.

B.  The Major Phases In the Planning Process

    The planning process involves several qeneral phases,
although planners may. define the specific tasks within the
phases  somewhat differently.  The phases are important
because they are the activities around which a program of
public participation should be organized.  The 208 planning
process will 4r>clude the following phases,

    1.  Establishment of Goals and Objectives

    During the first stage of a 208 plan, the planning agency
should establish channels of communication with the public.
Citizen opinion should be sought on the following issues:

     a. The identification of water quality problems and
        priorities for resolving these problems.

     b. The relative importance of water quality goals in
        relation to other community goals.

     c. The role that water quality management can or should
        play in achieving community goals.

     d. The use of land use controls and a regional approach
        to waste treatment to protect water quality.

     e. The use of land disposal and other innovative or contro-
       * versial pollution control technologies.

    2.   Design of Alternatives

    Since water quality planning is but one aspect of community
planning, it is important, particularly in the design of alter-
natives, that the planning agency consider how community goals
may conflict or be compatible with water pollution control

   Citizen views should be solicited on the compatibility of
various water pollution control approaches (municipal and indus-
trial source control, land use and land management control  for
point and nonpoint sources, and control of residual waste)  with
other community goals.

    Citizen views concerning timing,  rate,  and location  of
future development and land uses (particularly  housing,
industrial, commercial, transportation,  open  space,  resource
recovery and recycling) are critical  in  determining  the
suitability of the pollution control  approaches.

    It is also necessary to solicit public  reaction  to possi-
ble management alternatives for implementing  the  plan.
Compatibility of the management alternatives  with the fol-
lowing kinds of areawide planning and implementation agencies
and levels of government may be considered.

    0 regional comprehensive planning agencies
    0 general purpose local governments
    0 sewer districts
    0 air quality control agencies
    0 soil conservation districts
    0 solid waste planning agencies
    0 transportation planning agencies
    0 regional economic development agencies
    0 regional parks and recreation agencies

    3.  Impact Assessment

        Since the evaluation of certain  aspects of the plan
is largely subjective, it is important that those affected
by the plan be involved in assessing its impact.   Special
efforts should be made to obtain the reaction of  those indi-
viduals and institutions that would bear the  responsibility
for financing, construction, operations, monitoring, and
enforcement.  The public should also have the opportunity
to request further study of plan impact.

    4.  Recommendation and Acceptance of the  Final Plan

    During this stage the planning agency should  consider any
reasons why the least-cost plan should not be chosen, such
as the attainment of additional benefits from increased
expenditures, or the minimization of undesirable  social,
economic, and environmental impacts.   Public  comment that
accurately reflects community goals and  preferences  is
therefore needed on plan impact.

    At this stage it Is vital that elected officials who are
responsible for local approval of the recommended plan  are
made aware of public comments and opinions.  This is a major
responsibility of the entire public participation program.

     5.  P1 an Imp!ementation

     The public should be actively involved in the many activities
necessary to implement an areawide plan.   Public  involvement may
be particularly helpful  in  assuring that  the plan is  effectively
implemented and in informing responsible  officials of the plan's
impact in the area.   Public understanding and support for the area
plan may be encouraged through public involvement in  program
implementation.  Among the  phases of implementation where public
involvement may be particularly constructive are  the  following:

     .  the planning of facilities required for plan  implementation
        and the raising of revenue for the facilities;

     .  the creation or modification of water quality standards
        and effluent permits required for pollution sources
        in the area;

        the passage of zoning ordinances  and other measures
        necessary to implement the regulatory aspects of the

        the monitoring of pollution sources and development
        of technical standards for new pollution  sources.

     6.  Plan Revision

     Once an areawide plan  has been selected, the public should
still have the opportunity  to participate in any  periodic up-
dating of the plan.   Information should be available  continually
to permit evaluation of progress made under the plan.

C.  Principles for Public Involvement

     VJhile there are no hard and fast rules for structuring  a
public involvement program, several general principles  should
be kept in mind:

     1.  The program should be an active  program.  Since the
optimum degree of public involvement will usually not occur
spontaneously, simply providing information to those  who
ask for it is not adequate.  An active program is needed to
seek out those who can provide useful inputs, as  well as
those who will be affected  by the plan.

     2.  The program should include adequate provision  for
disseminating information to the public.   One of  the  greatest
inhibitors to active public involvement in planning programs
is lack of readily available information.  To preclude  this
happening in 208 public participation programs, all data and
information available to planners must be easily  accessible  to
the public.   Depositories of documents and data should  be
clearly identified to the public, and should remain open for
use by the public at times  that are generally convenient to


      the average citizen.  Assistance  should be provided in locating
      specific documents  or data  retained  in the depository; repro-
      duction equipment should  be available for use at a moderate
      cost.   Mailing  lists and  publications should also be used if

           3.  The program should be  allocated adequate time and funding
      within the overall  planning effort.  Planning and operating an
      effective program will  probably require the full-time efforts of
      at least one person.  Costs of  the program should be included in
      the planning budget.

           4.  The planning agency  should  designate and identify to the
      public a person or persons  to be  directly responsible for the
      public involvement program.

           5.  Those  electee  officials  and representatives of  state and
      federal agencies who must approve or disapprove the recommended
      final  plan should be  involved in  all significant planning decisions.
      Channels through which  they may be contacted should be clearly
      identified to the public.

           6.  The program should be  responsive to all interested citizens.
      Participation in 208 planning should not be dominated by any one
      interest group  or individual.  This  can best be done by  including
      without exception in mailings,  notifications, etc., all  parties
      who express interest  in the project  or who have been involved in
      community issues related  to water quality planning and management.

10.3  A Model Program for Public  Involvement

      The task of providing for public  participation  in the 208 planning
process is,  ultimately, the job of  matching specific  participation activi-
ties with specific planning tasks.  There  are many ways in which this
matching might occur, depending upon  how planning agencies define their
tasks in detail and which participation activities they choose to emphasize.
The following table (pp.  10-7,  10-8)  lists six categories of public partici-
pation activity which should  accompany  each major phase of the planning
process and matches them with one suggested definition of planning tasks.
Within each category of participation activity will be found one, or
several, suggested alternatives for that activity.

     One useful method by which planning agencies can assure compliance
with the public participation guidelines  is to match  the  public partici-
pation items in the table with their  own definition of planning tasks.
Those responsible for assuring compliance  can  then  "check" a participation
activity as it occurs and be  sure,  finally, that  for  each major planning
task all the major participation  activities have  been assured.


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Kews releases and
news le t tcrs
Data depositories
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Task forces
Staff assistance!

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Public heari r.^s
i nf ormal not. i ce f

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ci tizcn vice's
App't of individual
or agency to rianage
public parLici patior

Public notice
Publication of
final decisions
Public hearings

Full information
when possible
Public hearings

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10. 4  Institutional  Alternatives for Representation of the General  Public

      Institutional  arrangements to implement requirements for public  partici-
pation are a matter of local  discretion,  as long as the provisions  made meet
the criteria of the Act and federal regulations.  However, those arrangements
chosen should:

          1.  Provide clearly defined channels through which citizens  may
          contact decision-makers.

          2.  Define responsibility for actively carrying out public involve-
          ment activities.

           3.    Provide  adequate funding  for  public  participation through-
           out  the planning process.

           4.    Be responsive to all  interested  citizens,  but  not dominated
           by any single interest group.

     Although  a number  of  institutional  arrangements may  meet these re-
quirements, a  formal mechanism  to  ensure full citizen  understanding and
approval  of the selected  plan will  probably  be  necessary, given the scope
and complexity  of areawide water quality management.

     An exemplary arrangement would  be a fully  funded  public  participation
working group,  acting in  partnership with  the 208 planning staff and manage-
ment agency.  At least  one full time staff member   would  be needed to carry
out the tasks of the working group.  Additional funds  should  be made avail-
able to cover the cost  of  printing,  announcements in the  media,and other
incidental expenses.  An  illustration of this type  of  arrangement is pro-
vided on  the following  page.

                     ORGANIZATIONAL  STRUCTURE
                           Advisory Committee*
                           208 Planning  Staff
                           Citizen Participation
                               Working Group
                 208 Management
Water Standards
Source Study
*Composed of non-voting Federal  representatives  (in compliance with
 the 304(j) agreement), State and local  representation and  a  voting
 member of the Citizens Participation Working Group.

**The Working Group may wish to  divide itself along the lines of major
 areas of concern as illustrated.

10.5  Program Evaluation

      An important part of any public involvement program is  a set of
feedback mechanisms to continually monitor the success or failure of the
program.  If feedback indicates ongoing efforts are inadequate,  adjust-
ments should be made as soon as possible, so that the success of the
program will not be jeopardized.  In making an evaluation, information
may be drawn from a variety of sources, including:

      1.  nature of informal contacts initiated by the public;

      2.  attendance at meetings and hearings;

      3.  amount of related public-sponsored activity such as
          meetings, workshops, door-to-door campaigns, etc.;

      4.  amount and nature of media coverage;

      5.  formal surveys.

      In addition to monitoring inputs received from the public  partici-
pation program, an evaluation should also be made of the effect  these
inputs had on subsequent decision-making.  An effective public participa-
tion program should be structured in such a way that the inputs  received
have an influence on later decisions.  Otherwise, the program is inade-
quate, and steps should be taken to correct the deficiency.

10.6  Advisory Committee

      In compliance with Section 304(j) of P.L. 92-500, the Administrator
of the Environmental Protection Agency has entered into an agreement with
the Secretaries of the Departments of Agriculture, Army, and  Interior.
Notice of Final Agreements was published in the Federal Register,  Vol.  38,
No. 225, November 23, 1973.

      As a result of this agreement, the planning agency in each area
designated under Section 208(a)(2) must create an advisory committee,
with representatives of the Departments of Agriculture, Interior,  and
Army invited to participate.  Each Department may or may not  participate
as it deems appropriate.  This requirement provides for coordination of
the programs authorized under other federal laws-vnth 208 planning.

      Pursuant to Section 208(a)(2), grant regulations for Section 208
(40 CFR 35, Subpart F) further state that provisions must be  made  for
inclusion of representatives of the State and the general  public on  an
Areawide Planning Advisory Committee.  The membership may be  further
expanded as considered appropriate by EPA, the State(s), and  the appli-
cant agency.  A special  effort should be made to include representatives
of agencies responsible for other environmental programs being conducted
in the area.

                                 CHAPTER 11


11.1 Purpose

     This chapter provides guidance for integrating environmental, social,
and economic impact evaluation into the 208 planning process.   It is also
intended to meet, in part, the requirements of Sec. 102(2)(c)  of the Na-
tional Environmental Policy Act of 1969 and regulations issued pursuant to
that Act.  While Section 511  of the  FWPCAA can be interpreted  to exempt
Section 208 from the NEPA requirements,  EPA has  decided that these requirements
still apply due to the facilities planning elements of the 208 plan.  The
evaluation will, therefore, serve as the applicant's environmental assess-
ment and will also support the preparation of an Environmental Impact
Statement if required.

     The evaluation must be viewed as an integral part of the  planning
process.  As such, it will be performed throughout the process rather than
after the selection of the 208 plan, with citizens and local  units of
government afforded the opportunity to participate in impact  evaluation
from the beginning of the planning process.  Affected citizens and units of
government will thus be better able to analyze the various alternatives, to
identify specific plan impacts, and to provide meaningful suggestions and
11.2 Environmental, Social  and Economic Impact Evaluation Process

     A.    Inventory Existing Conditions

          The purpose of inventorying existing conditions is twofold:
     (1) to aid in goal and problem identification; and (2) to serve as a
     basis for the analysis and comparison of alternatives.  At a minimum,
     the inventory should encompass the 208 planning area and other areas
     that would be affected by the plan.   For example,  land disposal sites
     for effluent or sludge, other wastewater reuse sites, and the down-
     stream river corridor that would be affected by effective water quality
     management should be included.  The inventory will undoubtedly require
     additions as new problem areas are identified in the planning process.

          Most of the data needed for the inventory will  be readily avail-
     able in existing documents and may have been gathered for use else-
     where in the planning process.  This would be true,  for example,  for
     most of the population, land use, and hydrological data.  Additionally,
     items four through fourteen in the inventory are impact categories
     which may be used in the plan selection process (Chapter 12) to deter-
     mine differences among the plan alternatives.

          Only that data which is relevant to the analysis of alternatives
     or determination of impacts should be included.  Thus, the inventory
     may include but not necessarily be limited to the  following:

 1.    Climate  and  precipitation;

 2.    Topography;

 3.    Geology;

 4.    Hydrology  (surface  and  groundwater):

      a.   water quality
      b.   water quantity
      c.   water quality  and  quantity  problems
      d.   water uses
      e.   water quality  management
      f.   flood hazards;

 5.    Biology:

      a.   rare  and  endangered  species
      b.   fish, shellfish and  wildlife habitats, and  nursery  and
          spawning  areas
      c.   fish, shellfish and  wildlife population
      d.   benthic community  structure

 6.    Air quality;

 7.    Land uses:

      a.    existing  land  uses
      b.    land  use  planning  and  controls
      c.    amount, type,and  intensity  of  growth (The growth data
           should  be of recent  origin.  There is  no necessity  to
           examine growth trends  further  back than  1960).
      d.    soil  types,  permeability,and erodability
      e.    significant  environmentally sensitive  areas;

 8.    Wastewater management  resources:

      a.    energy  (power)
      b.    chemicals
      c,    land  commitment;

 9.    Population levelr>:

      a.    current
      b.    projected (5,  10,  15,  and 20 years);

10.    Economic activity (gross  assessment):

      a.    income  per capita
      b.    agriculture
      c.    mining
      d.    manufacturing
      e.    service;

     11.   Employment trends  including  regional availability of skilled
     manpower for treatment  plant operation and monitoring;

     12.   Other local,  state,  and  federal  projects  having major  inter-
     action with proposed  water  quality  actions;

     13.   Public health;

     14.   Aesthetics:

          a.  recreational accessibility and activities
          b.  unique archeological,  historical, scientific,and
              cultural  areas
          c.  noise pollution.

     The inventory should also include identification of adopted
goals and pertinent constraints.  Goals might typically include:

     1.   Preservation of  high  quality  surface  water;

     2.   Preservation of  coastal or  other wetlands;

     3.   Preservation or  enhancement of  fish,  shellfish  and wildlife;

     4.   Enhancement of municipal  services.

     Examples of constraints include:

     1.   Air quality regulations and implementation plans;

     2.   Local climate, topography,  soils, etc.;

     3.   Restrictions on  flood plain use or other land uses.

B.    Evaluate the Existing Situation

     Based upon the inventory,  a brief analysis of  the existing  situa-
tion should be conducted  to  prioritize pollution  problems and sensitive
impact areas.  This prioritization which will  be  a  primary concern
during the remainder of the  evaluation will require participation of
the public and local government  agencies.

C.    Develop Baseline Projection

     The inventory and  evaluation  of the existing situation will serve
as  inputs into the development of  a  baseline  projection.  Construction
of  a baseline projection  of  relevant environmental,  social, and  econom-
ic  factors (see Table 12.1)  will enable  evaluation  of each alternative.

      The baseline  projections should be quantitative when data are readily
      available.   In other cases,  it should be qualitative.  The baseline
      projection  can be  established by extrapolating present indicator
      trends  over the  planning period.  In making this projection, it should
      be assumed  that  no additional water quality actions will be taken
      other than  those that  have already been approved.

      D.   Screen  Options and Subplans

          Both  point and nonpoint  control options as well as continuous
      point source, intermittent point source, and nonpoint source subplans
      should  be screened according to the factors set forth in Chapters 5
      and 6.   (See  Chapters  5.2.D, 5.6.D, 6.6.)

      E.   Eva 1 uate  Al ternati ves

          After the alternatives have been developed, each of them should
      be evaluated  by  comparing its impact to the baseline projection.
      Special consideration  should be given to those sensitive impact areas
      identified  in the  evaluation of the existing situation.

          A complete environmental assessment of each alternative is not
      necessary,  although the impact of both the structural and nonstructural
      aspects of  the plan should be considered in every  case.  Table 12.1
      contains  a  list  of those environmental, social and economic factors
      believed  to be generally most important.  However, discretion should
      be employed when using this  table.  When there is  no difference among
      alternatives, a  statement to that effect is sufficient.  Similarly, a
      statement will suffice when  an alternative will have no perceptible
      impact on a given  factor.

          Special attention  should be given to long-term impacts, irreversible
      impacts,  and  indirect  impacts such as induced development.  Resource
      and energy  use associated with each alternative should also be high-
      lighted.  The results  should be displayed in a format for use in
      public  meetings  and other forms of public participation.

11.3  Environmental Effects  of the Selected Plan

      The results of the environmental, social,  and economic impact evalua-
tion will be used in the plan selection process (Chapter 12).  Once a plan
has been selected,  a complete description of the impact  that  the  selected
plan will have  on the  area's environment should be completed.  The vast
majority of the data required to do this should be readily available from
the evaluations already  performed. This more detailed evaluation should
describe the impact of the  proposed structural and nonstructural  actions.
Whenever possible,  the impact of each action on each affected environmental,
social, or economic category (see  Table 12.1) should be  described and dis-
played.  However, if more than one action affects a category, the cumulative
impact may be described.  Impad;s  may be categorized as:


      1.   Primary (direct) or secondary (induced);

      2.   Beneficial  or adverse;

      3.   Short or long term;

      4.   Avoidable or unavoidable;

      5.   Reversible or irreversible.

      Included under irreversible impacts should be  an  evaluation  of any
irreversible commitments of resources including energy.   (See §6.304 (c-f)
of 40 CFR  Part 6 for an explanation  of these terms  and examples.)

      While emphasis should be given  to the cumulative  impacts of  all  ele-
ments of the plan, more localized impacts of specific plan  elements, such
as treatment plant locations,  interceptor sewers,  and industrial site
locations, should also be assessed and  highlighted when judged significant.
Greater emphasis should be given to the localized  impacts of individual
projects anticipated to be developed  during the initial  five years  of plan

                                 CHAPTER 12

12.1  Purpose

     This chapter provides guidance on the comparison of alternative plans
leading to the selection of an areawide waste treatment management plan.
The process presented here assumes that each of the alternatives, if im-
plemented, would meet all regulatory requirements and comply with appro-
priate goals and objectives within specified limits of technical  relia-
bility.  Plans are to be compared in terms of the defined criteria of
cost effectiveness as discussed in Chapter 1, feasibility of plan imple-
mentation, and public acceptability.  Emphasis will also be placed upon
drawing together the evaluations already completed so that the alternatives
can be more easily discussed and compared.  Finally, while public parti-
cipation is necessary throughout the planning process, it is essential
that the public be involved to a significant degree during this stage.

12.2 The Plan Selection Process

     A.   Assess Alternative Areawide Plans

          No rigorous analytical method exists which will readily identify
     the best plan for the area.  As discussed in previous chapters, many
     factors should be considered in comparing the alternatives.   While
     some of the factors, in particular cost assessments, can be  quantified,
     others can only be qualitatively assessed based upon professional
     judgement, and the views of the public.  Plan assessment involves  the
     comparison of all key factors deemed pertinent for reliable  decision
     making.  Table 12.1 contains a list of those which are believed to be
     generally most important.  The inputs for that table are to  be devel-
     oped in the technical planning process (Chapter 3.5.B), the  step at
     which alternative plans are evaluated in light of information on
     their cost, technical reliability, environmental, social and economic
     impact, implementation feasibility and public acceptability.  The
     effects of the alternatives should be assessed quantitatively whenever
     possible.  In all other cases a qualitative assessment should be made.

          Representatives from all affected groups should be involved in
     the assessment of the alternative proposals.  In most areas, affected
     groups would include conservation groups, economic interests, local
     elected officials,planning agencies, state departments of health,
     water pollution control, and natural resources, the regional office
     of EPA and the Areawide Planning Advisory Committee.  The plan approval
     and implementation process will be more efficient if the people res-
     ponsible for carrying it out fully understand the issues and contribute
     to the assessment and recommendation of alternatives.

B.   Develop Recommended Plan

     Once the alternative plans have been assessed, the planning
agency should be in a good position to compare the alternatives and
develop a recommended plan.   A logical approach for comparing the
alternatives would be to identify initially that alternative which
will achieve water quality objectives at minimum monetary cost.  This
least cost plan can serve as a base against which the increased costs
and additional effects of other alternatives can be compared.  The
major environmental, social  and economic impacts of this least cost
plan should be listed, including a discussion of the institutional
and financial issues that would be raised if the plan were recommended.
Most of the required impact information should be contained in Table
12.1.  A suggested format for displaying the least cost plan is shown
in Table 12.2.

     The next step should oe the identification of the incremental
monetary cost and incremental impacts of each of the remaining alter-
native plans in relation to the base plan.   Information contained in
Table 12.1 would provide the basis for this incremental evaluation.
Description of alternatives should include the plan elements (such as
construction, zoning, operations, etc.) and measures or statements of
the changes in the impacts of those plan elements.  In addition to
the environmental, social, and economic impact and institutional and
financial issues, additional benefits that could be gained or unde-
sirable situations that could be avoided should be described.  The
alternatives should be described in such a way as to make comparisons
with the additional costs required as direct as possible.  The results
may be summarized in the format of Table 12.3.

     The planning agency should then conduct workshops for the elected
officials who will be reviewing and commenting on the proposed plan to
fully inform them of the consequences of implementing any of the alter-
native areawide plans.  The agency should also take note of their
responses to the alternatives to see if the alternatives can be changed
to improve plan acceptability.  Since these workshops and the public
hearings to follow could very well result in requirements for sub-
stantial changes in the design of plan elements and for further analy-
sis of additional impacts, -the agency should schedule resource expen-
ditures to be able to respond fully to the need for additional modifi-

     At the conclusion of the workshops, the planning agency should
recommend a single plan as the proposed 208 plan.  The plan elements,
costs, impacts, and implementation issues can be summarized in the
format shown in Table 12.2, accompanied by a brief report summarizing
the process followed, the alternatives considered, and the criteria
used to reach a final recommendation.  The report and charts should
be suitable for use at public hearings.

C.   Hold Public Hearings to Present Proposed Plan

     The planning agency should conduct formal public hearings on
the proposed plan and the alternatives considered in its development.
The planning agency should then respond to the issues raised at the
hearings and modify the proposed plan if appropriate (as judged by
the agency).  The planning agency will then submit the proposed plan
to the appropriate local governing bodies for review and recommenda-
tions as specified in Chapter 14.

                            TABLE 12.1


                                                    Alternative Plans

Significant Effects                               P-1    P-2      p-3

1.   Water Quality Goals

     A.   Contribution to goals and
          objectives of the Act.

     B.   Contributions to other water-
          related goals of the planning

2.   Technical Reliability

     A.   Frequency of plant upsets

     B.   Frequency of spills

     C.   Frequency and effects of
          combined sewer overflows

     D.   Nonpoint source control

     E.   Regional availability of
          skilled manpower for treat-
          ment plant operation and

3.   Monetary Costs

     A.   Capital costs including discounted
          deferred costs

          (1)  public
          (2)  private
          (3)  total

     B.   O.M. & R. Costs

          (1)  public
          (2)  private
          (3)  total

     C.   Net revenue  (public)

     D.   Overhead and plan management


                         TABLE 12.1 (cont)


Significant Effects                                 Alternative Plans

     E.    Total average annual costs              P-l      P-2     P-3

          (1)  public
          (2)  private
          (3)  total

4.   Environmental Effects

     A.    Hydrology (surface and groundwater)

          (1)  water quality
          (2)  water quantity
          (3)  water quality and quantity problems
          (4)  water uses
          (5)  flood hazards

     B.    Biology

          (1)  rare and endangered species
          (2)  fish, shellfish and wildlife habitats;  and
               nursery and spawning areas
          (3)  fish, shellfish and wildlife population
          (4)  benthic community structure

     C.    Air quality

     D.    Land

          (1)  change in land uses
          (2)  land use planning and controls
          (3)  amount, type and intensity of
               growth (relate to land use)
          (4)  soil erosion damage
          (5)  significant environmentally
               sensitive areas

     E.    Wastewater management resources

          (1)  energy (power)
          (2)  chemicals
          (3)  land commitment for planned
               features including  sludge disposal  sites

5.   Social and Economic Effects

     A.    Population changes (5, 10, 15, and 20 year

                         TABLE 12.1 (cont)


Significant Effects                                 Alternative Plans

     B.   Changes in economic activity            P-1     P-2     P-3
          where appropriate

          (1)   income per capita
          (2)   agriculture
          (3)   mining
          (4)   manufacturing
          (5)   services

     C.   Dislocation of individuals, businesses,
          or public services

     D.   Impact on other local, state and
          federal projects having major
          interaction with proposed water
          quality actions

     E.   Public health

     F.   Aesthetics

          (1)   recreational accessibility and
          (2)   unique archeological, historical,
               scientific and cultural areas
          (3)   noise pollution

6.   Implementation Feasibility

     A.   Legal authority

     B.   Financial  capacity

     C.   Practicability

     D.   Coordinative capacity

     E.   Public accountability

7.   Public Acceptability

                                 TABLE 12.2
                               LEAST COST PLAN
(A summary list of planning, construction, zoning,
sludge and effluent disposal, operations, moni-
toring actions, etc., indicating their geographic
   (Institutional and  financial  issues.)

               TABLE 12.3


Plan Elements








                               CHAPTER 13


13.1  Purpose

     The planning report should set forth the technical  and management
outputs, the process used to achieve those outputs,  and  the provisions
for plan revision.  Since the format of the report may differ  among  208
areas due to the varying importance of water quality problems  and  control
strategies, a suggested outline for the report is not included in  this
guideline.   The planning agency should work closely  with the state and
EPA regional representatives in deciding  upon the report format.   However,
the final report should be divided into two major sections—a  condensed
report on outputs and a full report on the planning  process—as discussed

13.2  Periodic Reports During Plan Development

     Within 30 days following the end of  each six month  period after the
effective date of the grant, the planning agency is  required by the  grant
regulations to submit for review by EPA a semi-annual report of progress
and expenditures as compared to the scheduling of approved milestones in
the work plan.  In many instances, it would be advisable to submit reports
quarterly.   This will make it easier to track the purposes of  the  program
and identify and solve problems as early  as possible.  In addition,  planning
agencies should schedule periodic meetings with their EPA regional and state
representatives.    In the reports and in the meetings,  any lack of  scheduled
progress and other problems should be fully discussed.

13.3  Final Report

     A.   Condensed Report on Outputs of the Selected Plan

          The condensed report should cover all of the technical and manage-
     ment outputs presented in Chapter 3.5, an implementation  schedule for
     these outputs, and the provisions for performance assessment  and plan
     revision.  Supplementary engineering feasibility data on  the  features
     included in the first stage development of the  municipal  wastewater
     facilities should be appended.

     B.   Full Report on the Planning Process

          A full report on the planning process should discuss the various
     alternatives considered and the reasons for rejecting those not
     included in the selected plan.   The  format for  documenting the  way
     in which the planning was carried out can follow the outline  of the
     planning process utilized in this guideline.  The report  should include
     any analytical studies and supporting information,  demographic  informa-
     tion,  land use maps and studies,  studies on point and nonpoint  source

     control  techniques,  management,  legal,  and  financial  (including  budget)
     studies,  etc.   The complete  environmental assessment  should  be covered
     in a single chapter.   Where  the  report  on the  planning process overlaps
     the condensed  report on outputs,  the  output report  should be  referenced.

13.4  Report on Annual  Review of Plan

     The approved plan must be reviewed, updated, and certified annually.
If substantial  revisions  result,  the  entire  planning report should be
reviewed accordingly.   Relatively minor  revisions resulting from  such an
update could be documented, if practical,  in an  addendum to the initial

                             CHAPTER 14


14.1  Introduction

     Each 208 planning agency must submit its areawide waste treatment
management plan, including recommendations for management agency(s),  to
the appropriate EPA Regional  Administrator within 24 months  after the
award of the planning grant.   This plan must be submitted to EPA through
the governor or state reviewing agency designated by the governor.

14.2  Submittal and Review of Interim Outputs

     Prior to submittal of the selected plan, certain interim outputs
are necessary to guide further facilities planning.   Among these are  the
following interim outputs which are to be completed  to promote consistency
and compatibility in subsequent facilities planning:

     .  Service area delineation for municipal wastewater treatment systems
       throughout the designated area

     .  Existing population and land use and projected population and  land
       use for the twenty (20) year planning period

     .  Projected waste loads  and flows generated for each service area
       corresponding to the existing and projected population and
       land use

     .  Revision (if any) of the waste load allocations

     These interim outputs must be completed within  nine (9) months,  unless
the EPA Regional Administrator grants time extensions upon the recommendation
of the 208 planning agency and the state.  Upon completion of the interim
outputs, the 208 planning agency should submit them  to the state for  review
and approval and transmittal  to the EPA Regional  Administrator for concurrence
as fulfilling partial requirements of 208 planning.

     In some instances, further areawide planning may reveal that the
interim outputs should be modified.  Such modifications and  associated
justifications should be promptly brought to the attention of the state
and affected facilities planning agencies.  (This should occur in the
normal  process of having close and continuing coordination between states,
areawide, and facilities planning agencies).  The state should determine
the feasibility and practicality of incorporating these modifications in
the facilities planning and obtaining concurrence of the Regional  Administrator.

     The planning agency may Identify  additional  interim  outputs,  such
as nonpoint source controls, which they believe  should  be reviewed by the
state and EPA.   The identification and accomplishment of  interim outputs
will  depend primarily upon the ability to complete  tasks  prior  to  selection
of the completed plan, the general acceptance  of the results of those
tasks by the governmental  organizations and agencies involved,  and the
need for the interim outputs to support further  related activities within
the area.  These outputs,  if any,  should be reviewed according  to  the
procedure discussed above.

14.3  Local Review and Recommendation  of the Selected Plan

     Prior to submitting its plan  to EPA through the appropriate governor
or state reviewing agency, the planning agency must provide  the governing
bodies of local governments having responsibility for,  or which would be
directly affected by, implementation of the plan and having  jurisdiction
in the planning area, an opportunity to comment  on  the  plan  and proposed
management agency(s) and make recommendations  for approval or disapproval.
In the event that a local  unit of  government fails  to provide a recommenda-
tion within 30 days of receiving the request,  the planning agency  may
consider that the plan has been favorably recommended by  that unit of
local government.

     The recommendations,  whether  favorable or unfavorable,  are to be
forwarded by the planning agency to the governor in connection  with his
certification of the initial plan.  The local  comments  are also to be
forwarded to the appropriate EPA Regional Administrator when the plan
is submitted to EPA by the state.

14.4  State Review and Certification of Approval

     When the plan is received by  the  governor prior to its  submission
to EPA, the governor or the state  reviewing agency must review  the plan
for the necessary certification of approval required by Section 208(b)(3)
of the Act.  The purpose of the state's review is to determine  whether:

     1.  The plan is in compliance with the provisions  of the state
         program prepared under Section 106 of the Act  and will then
         be accepted as a detailed portion of  the state plan when
         approved by EPA;

     2.  Implementation of the plan will enable meeting the  1983
         goals of the Act;

     3.  The plan is in confomiance with Sections 201,  208,  and 303 of
         the Act;

     4.  The plan is in conformance with the requirements  set  forth  in
         40 CFR 35, Subpart F,  as well  as any other applicable regulations.

     Based on the state's review of the plan and the recommendations
received from the local units of government, the governor   must then
determine whether to approve or disapprove the plan.

     If the governor approves the plan, he must then forward the plan
to the appropriate EPA Regional  Administrator with his  certification
of approval and proposed designation of management agency(s).   The
governor must also forward the recommendations received from the local
units of government.

     If disapproval is necessary, that is, if no certification of
approval can be issued by the governor due to failure of the planning
agency to comply with one or more of the above provisions,  the governor
must notify the appropriate EPA Regional Administrator  and  the planning
agency that the plan is deficient and specify how the plan  is  to be
modified so that it may receive state certification of  approval.

14.5  EPA Review and Approval

     The appropriate EPA Regional Administrator will  be responsible  for
plan approval.   The Regional Administrator's approval of the plan will
be based upon:   (1) the state's certification of approval  and  proposed
designation of management agency(s); and (2) EPA's review of the plan
submission to determine that it fulfills the requirements  stipulated
in subpoints 2, 3, and 4 of section 4 of this chapter.   State  and local
comments and recommendations will also be considered.   (Note:   EPA will
not approve any plan in the absence of proposed designation of management

     Within 120 days after receiving the plan submittal, the Regional
Administrator must:

     1.  Notify the state(s) and the planning agency of approval  of
         the plan and the proposed management agency(s) designation; or

     2.  Notify the state(s) and the planning agency that  the  submittal
         is deficient in one or more respects and specify  the  ways in
         which the submittal must be modified to receive EPA approval.
         EPA must also specify the time period allowed  for  the modifica-
         tions; or

     3.  Notify the state(s) and the planning agency that  the  designation
         of waste treatment management agency(s) cannot be  approved  due
         to failure to meet the requirements set forth  in  Section 208(c)(2)
         of the Act, thereby delaying further consideration of the plan
         until  the deficiencies are remedied.  EPA must also specify the
         time period allowed for correcting the deficiencies,


14.6  Annual  Certification of Consistency

      After the plan has been approved,  it must be  certified  annually  by
the governor or his designee (or governors or their designees where
more than one state is involved) as  being consistent with  applicable
basin plans.   The management agency(s)  should initiate  the annual  certifi-
cation process.  After receiving certification, the plan must be  submitted
to the appropriate EPA Regional  Administrator  for  approval.  If  the
governor fails to certify, notification  should be given to the  appropriate
EPA Regional  Administrator and the management agency(s) explaining the
modifications necessary to receive certification.

The Act - Public Law 92-500.   "This Act may  be  cited  as  the  'Federal
          Water Pollution Control  Act Admendments  of  1972.'"   (Act,
          Section 1).

Base level  technology  - Minimum level  of treatment required  by the Act.

Basin - "The term 'basin1  means the streams,  rivers,  tributaries, and
          lakes and the total  land and surface  water  area  contained  in
          one of the major or  minor basins defined by EPA, or  any other
          basin unit as agreed upon by the State(s) and  the  Regional
          Administrator."   (40 CFR 130.2(1)).

Best Available Technology (BAT) -  "Not later  than  July 1,  1983,  effluent
          limitations  for categories and classes of point  sources, other
          than publicly owned  treatment works,...shall require application
          of the best  available technology economically  achievable for
          such category or class,  which will  result in reasonable further
          progress toward the  national  goal of  eliminating the discharge
          of all pollutants as determined in  accordance  with regulations
          issued by the Administrator pursuant  to  section  304(b)(2)  of
          this Act..."(Act, Section 301(b)(2)(A)).

Best Practicable Control  Technology (BPCT) -  "Not  later  than July 1,
          1977, effluent limitations for point  sources,  other  than
          publicly owned treatment works, shall  require  the  application
          of the best  practicable  control technology  currently available
          as defined by the Administrator pursuant to Section  304(b) of
          this Act..."(Act, Section 301(b)(l)(A)). This  is also  referred
          to as Best Practicable Technology  (BPT).

Best Practicable Waste Treatment Technology  (BPWTT) - "Waste treatment
          management plans and practices shall  provide for the application
          of the best  practicable  waste treatment  technology before  any
          discharge into receiving waters, including  reclaiming  and
          recycling of water and confined disposal  of pollutants so  they
          will not migrate to  cause water or  other environmental pollution...
          (Act, Section 201 (b))-

Capital intensive - Measure requiring initial capital outlays  for its
          development  and relatively little  cost for  operation and

Combined sewer - "A sewer intended to serve  as  a sanitary  sewer and  a
          storm sewer, or as an industrial sewer and  a storm sewer."
          (40 CFR 35.905-2)

Discharge of pollutants  -  "The  term  'discharge of a pollutant1 and the
          term 'discharge  of  pollutants' each means (A) any addition
          of any pollutant to navigable waters from any point source,
          (B) any addition of any  pollutant  to the waters of  the contig-
          uous zone  or  the ocean from any  point source other  than a
          vessel  or  other  floating craft."   (Act, Section 502(12)).

Effluent limitation  -  "The term 'effluent  limitation1 means any
          restriction  established  by a State or the Administrator
          on quantities,  rates, and concentrations of chemical,
          physical,  biological, and other  constituents which  are
          discharged from  point sources into navigable waters, the
          waters of  the contiguous zone, or  the ocean, including
          schedules  of compliance."  (Act, Section 502 (11)).

Effluent limited segments  - "Any segment where it is known that water
          quality is meeting  and will continue to meet applicable water
          quality standards or  where there is adequate demonstration
          that water quality  will  meet applicable water quality standards
          after the  application of the effluent limitations required by
          Sections 301(b)(l)(A) and  301(b)(l)(B) of the Act. "(40 CFR
Facilities planning - Provides "for cost-effective  environmentally sound
          and implementable treatment works  which will meet applicable
          requirements of sections 201(g),  301,  and 302  of the Act."
          (Guidelines for Facilities Planning,  January  1974,  p. 3)

Infiltration - "The water entering a sewer system,  including  sewer
          service connections, from the ground,  through  such  means as,
          but not limited to, defective pipes,  pipe joints, connections,
          and manhole walls.  Infiltration does  not include,  and  is
          distinguished from, inflow."  (40 CFR 35.905-9).

Inflow - "The water discharged into a sewer system, including service
          connections, from such sources as, but not limited  to,  roof
          leaders, cellar, yard and area drains, foundation drains,
          cooling water dischargers, drains from spring  and swampy
          areas, manhole covers, cross connections  from  storm sewers and
          combined sewers, catch basins, storm waters,  surface runoff,
          street wash waters, or drainage.  Inflow  does  not include, and
          is distinguished from, infiltration."   (40 CFR 35.905-11).

Inplace pollution source - Time buildup of pollutant load deposited
          in a receiving water bed and existing as  a load upon that
          receiving water.

Interim Facility - A  temporary treatment facility,  either public  or  private,
          designed for a useful life of usually less than five years,  and
          with a treatment capacity usually less than five million  gallons
          per day.

Land use - The physical  mode of utilization  or  conservation of a  given
          land area at a given  point in  time.

Land use controls - Methods  for regulating the  uses  to which  a given
          land area may be put, including such  things as  zoning,  sub-
          division regulation,  and flood-plain  regulation.

Materials balance - An illustration of the principle of conservation
          of matter; that is, an accounting  may be performed  of all
          transfers of mass  from one point or state  to other  points or
          states, such that  the total  original  mass  is entirely accounted

Maximum daily load - "Each plan shall  include for each water  quality
          segment the total  maximum daily loads of pollutants, including
          thermal loads, allowable for each  specifir criterion being
          violated or expected  to be violated." (40  CFR 131.304 (a)).

Navigable waters - "The term 'navigable  waters'  means the waters  of the
          United States, including the territorial seas."  (Act,  Section

1983 goals - Pertains to goals  outlined  in Section 101 (a) and elsewhere in
          the Act.

1977 goals - Pertains to the July 1, 1977 milestone  set by  the Act,
          particularly  in terms of treatment technology and limitations.

Nonpoint source - Generalized discharge  of waste into a water body which
          cannot be located  as  to a specific source, as outlined  in
          Section 304 (e) of the Act.

Permits - "The Administration may...issue a  permit for the discharge of
          any pollutant, or  combination  of pollutants,...upon condition
          that such discharge will  meet either  all applicable requirements
          under Sections 301, 302,  306,  307, 308, and 403 of  this Act, or
          prior to the taking of necessary implementing actions relating
          to all such requirements, such conditions  as the Administrator
          determines necessary  to carry  out  the provisions of this Act.
          (Act, Section 402  (a)(l)).  "The Administrator  shall authorize
          a state, which he  determines has the  capability of  administering
          a permit program which will  carry  out the  objective of  this Act,
          to issue permits for  discharges into  the navigable  waters within
          the jurisdiction of such state."   (Act, Section 402 (a)(5)).
          The permit program is a part of the National Pollutant  Discharge
          Elimination System (NPDES).

Planning Agency - "The governor...or  governors  shall...designate  the
          208 planning area including its  boundaries,  and  for  each  area
          a single representative  agency to  be  responsible for the
          planning	The agency  shall  be  a  representative organization
          whose membership shall  include but need  not  be limited  to
          elected officials of local  governments,  or their designees,
          having jurisdiction in  the  designated planning area."   (40 CFR
          126.12, 126.11).

Planning period - "The period over which a waste treatment management
          system is evaluated for  cost-effectiveness.   The planning
          period commences with the initial  operation  of the system."
          (40 CFR Part 35, Subpart E, Appendix  A,  d(3)).   In the  case
          of 208 planning, the planning period  is  20 years.  However,
          planning agencies are given two  years to develop an  initial
          208 plan once the planning  process is begun.

Planning process - Strategy for directing  resources, establishing
          priorities,  scheduling  actions,  and reporting programs  toward
          achievement  of program  objectives.

Point source - "The term 'point source1  means any  discernible, confined
          and discrete conveyance, including but not limited to any pipe,
          ditch, channel, tunnel,  conduit, well, discrete  fissure,  con-
          tainer, rolling stock,  concentrated animal feeding operation, or
          vessel or other floating craft,  from which pollutants are or may
          be discharged."  (Act,Section 502(14)).

Pollutant - "The term  'pollutant'  means dredged spoil, solid waste,
          incinerator  residue, sewage,  garbage, sewage sludge, munitions,
          chemical wastes, biological materials, radioactive materials,
          heat, wrecked or discarded  equipment, rock,  sand, cellar  dirt
          and industrial, municipal,  and agricultural  waste discharged
          into water."  (Act,Section  502(6)).

Pretreatment - "The Administrator shall...publish  proposed regulations
          establishing pretreatment standards for  introduction of pollu-
          tants into treatment works...which are publicly  owned for those
          pollutants which are determined notto be susceptible to treatment
          by such treatment works  or  which would interfere with the oper-
          ation of such treatment works."   (Act, Section 307(b)(l)).   "Not
          later than July 1, 1977, the  case of discharge  into  a
          publicly owned treatment works,...shall  require  compliance with
          any applicable pretreatment requirements...under section  307
          of this Act."  (Act,Section 301(b)(l)(A)).

Residual waste - Those solid, liquid, or sludge substances from man's
          activities in the urban, agricultural, mining and industrial
          environment  not discharged  to water after collection and  necess-
          ary treatment.

Secondary treatment - "There shall  be required...for publicly owned
          treatment works in existence on July 1,  1977,  or approved...
          prior to June 30, 1974...effluent limitations  based upon
          secondary treatment as defined by the  Administrator pursuant
          to section 304(d)(l) of this Act."  (Act,Section 301(b)(l)(B)).
          "The Administrator...shall  publish...information, in terms  of
          amounts of constituents  and chemical,  physical,  and biological
          characteristics of pollutants, on the  degree of  effluent
          reduction attainable through the application of  secondary
          treatment."  (Act,Section 304(d)(l)).

State water quality standards - The term "State  Water Quality Standards"
          means those State adopted ^and Federally  approved uses and criter-
          ia that are legally applicable to the  interstate and intrastate
          waters.  The water quality  standards  are incorporated by refer-
          ence in Part 120 of Title 40 of Code  of  Federal  Regulations.

Storm sewer - "A sewer intended to  carry only  storm  waters, surface
          run-off, street wash waters, and drainage."  (40 CFR 35.905-22).

Upstream pollutant source - Source  of pollutant  discharged into the
          receiving waters which is located upstream from  the area of

Waste load allocation - "A waste load allocation for a segment is  the
          assignment of target loads  to point,  and,  if appropriate, to
          nonpoint sources to achieve water quality  standards in the  most
          effective manner."  (Guidelines for  Preparation  of Water
          Quality Management Plans, September,  1974, p.19).

Waste treatment facilities - "Any  devices and  systems used in the
          storage, treatment, recycling and reclamation  of municipal
          sewage or industrial wastes of a liquid addition,
          ...any other method or system for preventing,  abating,
          reducing, storing, treating, separating, or disposing of
          municipal waste, including  waste in  combined storm water
          and sanitary sewer systems."  (Act,  Section 212(2)).   Also
          termed treatment works.

Water quality limited segments - "Any segment where  it is  known that
          water quality does not meet applicable water quality standards,
          and is not expected to meet applicable water quality standards
          even after the application  of the effluent limitations required
          by sections 301(b)(l)(A)  and 301(b)(l)(B)  of the Act."  (40 CFR
          130.11 (d)(l)).


National Technical Information  Service
5285 Port Royal Road
Springfield, Virginia  22161

     The National Technical Information Service  has  available for sale,
both paper and microfiche copies  of  many EPA technical  reports.   Some
reports are, however,  available only in microfiche.   Information on
availability and prices  is given  only by mail  and  can be obtained by
writing to the NTIS and  giving  them  the following  information:

     1.  Title of the  report.
     2.  NTIS accession  number  (usually in the form:  PB-000-000).
     3.  EPA Report no.  (If known, usually in  the  form:  EPA 000/0-00-000)
     4.  Number of copies required.
     5.  Paper copies  or microfiche.

     NTIS will respond by mail  with  a price quote  and availability
statement.  Publications can  then be ordered by  mail  with payment enclosed.


Superintendent of Documents,
U.S. Government Printing Office
Washington, D.C.  20402

     The Government Printing  Office  has available  for sale,  paper
copies of many EPA and other  agency  publications.   Information  on the
availability and price of publications  can be  obtained  by calling the
Publications Information/Order  Desk  at  GPO in  Washington, D.C.   The
desk can be reached at area code  202, 783-3238.  The  following  in-
formation will be needed.

     1.  Title of the  report.
     2.  EPA Report no.  (usually  in  the form:  EPA  000/0-00-000).
     3.  GPO Stock no. (if known).

     The Information/Order Desk can  then check the availability and quote
the price.  If the publication  is available a  check  for  the  amount,
payable to the Superintendent of  Documents,  can  be mailed with  the order
to GPO.  Publications  will be mailed upon receipt  of  the payment.  If
ordering in the Washington, D.C.  area publications can  be picked up in
person at GPO.  When calling  for  information and price  ask the  clerk to
assign a pick-up number.  The publication can  then be picked up in person
at GPO.

     Most of these regulations should be available  in EPA Regional
Offices.  All of these regulations also appear in the Code of Federal
Regulations : 40 Protection of Environment .  This document is published
by the Office of the Federal Register, National Archives and Records
Service, General Services Administration and is revised as of July  1,
1974.  Copies of this document are obtainable from  the Superintendent
of Documents, U.S. Government Printing Office, Washington, B.C.   20402.
Call area code: 202, 783-3238 for information as to availability  and
price .

40 CFR Part 126, Areawide Waste Treatment Management Planning Areas
and Responsible Planning Agencies.  Federal Register, Vol. 38, No.
TT8, Sept. 14,
40 CFR Part 35, Subpart F  , Areawide Waste Treatment Planning Agencies :
Interim Grant Regulations.  Federal~Register , Vol.  39, No.  93, May,  1974.

40 CFR Part 35, Subpart E, Appendix A, Cost Effectiveness Analysis
Guidelines.  Federal Register, Vol. 38,~No7 174, Sept. 10,  1973.

40 CFR Part 35, Subpart E, Grants for Construction  pjf Treatment Works .
Federal Register, Vol. 39, Nc~29,~Feb7  11, 1974~

40 CFR Part 130, Policies  and Procedures for State  Continuning Planning
Process.  Federal Register7~Vol. 39, No. 107,~June  3, 1974.   Cunder

40 CFR Part 6, Preparation of Environmental Impact  Statements : Interim
Regulations.  Federal Register, VolT 39, No. "1387" July 17,  1974~

40 CFR Part 131, Preparation of Water Quality Management Plans.
Federal Register, Vol. 39, No. 107, June 3, 1974. (under revision)

40 CFR Part 105, Public Participation ^n Water  Pollution Control.
Federal Register, Vol. 38, No". 163, August 23,  1973.

40 CFR Part 35, Subpart B, State and Local Assistance .  Federal
Register, Vol. 38, No. 125, "June 29, 1973.   (under  revision)

U.S. Environmental Protection Agency.  Area and Agency
Designation Handbook for Section 208 Areawide Waste Treatment
Management Planning.  Washington, D.C. 1974.  Available upon
request from EPA Regional Offices.

U.S. Environmental Protection Agency.  Guidance for Facilities
Planning.   Washington, D.C. 1974.  Available upon request  from EPA
Regional Offices.

U.S. Environmental Protection Agency.  Guidelines for Areawide
Waste Treatment Management.   Washington, D.C. 1975.  Available
upon request from EPA Regional Offices.

U.S. Environmental Protection Agency.  Guidelines for Preparation
of Water Quality Management Plans.  Washington, D.C. 1974.  Avail-
able upon request from EPA Regional Offices.

U.S. Environmental Protection Agency.  Water Quality Strategy Paper,
Second Edition, A Statement of Policy for Implementing the Require-
ments of the 1972 Federal Water Pollution Control Act Amendments and
Certain Requirements of the 1972 Marine Protection, Research and
Sancuaries Act.  Washington, D.C. 1974.  Available upon request
from U.S.  EPA, Water Planning Division (WH-454), Washington, D.C.

U.S. Environmental Protection agency.  Workplan Handbook for Sec-
tion 208 Areawide Waste Treatment Management Planning.  Washington,
D.C. 1975.  Available upon request from EPA Regional Offices.
     Council of State Governments.  1971 Suggested State
Legislation (1971); 1972 Suggested State Legislation (1972);
1973 Suggested State Legislation (1973); 1974 Suggested State
Legislation (1974); 1975 Suggested State Legislation (1975).
Available from Council of State Governments 1150 17th St.,
N.W. Washington, D.C.  20036.  $5.00 for each volume covering
one year.

Fox, Irving K.  Institutional Design for Water Quality Manage-
ment; A Case Study of the Wisconsin River Basin, Vol. I-IX.
Resources Center, University of Wisconsin, Madison Wisconsin,
1971.  NTIS PB-199-268.

Kneese, Allen V., and Blair T. Bower.  Managing Water Quality.
Baltimore, Maryland: Johns Hopkins Press, 1968.

National Water Commission.  Public Regulation of Water Quality in
the United States, National Water Commission Legal Study No.  18.
Washington, D.C. 1971.  NTIS PB-208-309.

U.S. Department of Interior, Office of Water Resources.  Water
Resources as a Basis for Comprehensive Planning and Development
in the Christina River Basin.   University of Delaware Water
Resources Center,"Washington,  D.C. 1973.  NTIS PB-228-853.

U.S. Environmental Protection Agency.  Problems and Approaches to
Areawide Water Quality Management, Vol.  I-IV.  School of Public and
Environmental affairs, Indiana University, Washington, D.C.,  1973.
NTIS PB-239-808.
Chapin, F. Stuart, Jr.  Urban Land Use Planning.  Urbana, Illnois:
University of Illinois Press, 1965.

McHarg, Ian.  Design With Nature.  Garden City: Natural History Press,

U.S. Council on Environmental Quality.  The Quiet Revolution  in Land
Use Control.  Fred Bosselman and David CallielTGPO,  stock noT 4111-0006,

U.S. Environmental Protection Agency.  Promoting Environmental Quality
Through Urban Planning and Controls.  Socioeconomic Environmental  Studies
SeriesT 1974.  NTIS PB-227"-090/8.

U.S. Environmental Protection Agency.  Stream Quality  Preservation
Through Planned Urban Deve Lopment, Report no. EPA R5-73-019.  Soc-
ioeconomic Environmental Scudies Series, Washington, D.C. 1973.  GPO,
U.S. Environmental Protection Agency.   De sign Criteria  for Mechanical,
Electric, Fluid Systems and Component Reliability.  Washington,  D.C.
NTIS PB-227-558/4";

U.S. Environmental Protection Agency.  Federal Guidelines, Operation
and Maintanence of Wastewater Treatment Facilities.  Washington, B.C.
Available upon request from EPA Regional Offices.

U-s- Environmental Protection Agency.  Guidance  for Sewer System Eval-
uation.  Washington B.C. 1974.  Available upon request  from EPA Regional
Office of Water Resources Research.  Practice in Detention of Storm-
water Runoff.  Herbert G. Poertner, American Public Works Association,
1974. ~NTIS~PB-234-554.

U.S. Department of Health.  Sanitary Land Fill Facts .  Thomas J. Sorg
and H. Lanier Hickman, Washington, D.C. 1970.  NTIS PB-204-403.

U.S. Department of Interior, Office of Water Resources.  Water Resources
Protection Measures In Land Development: A Handbook.  Washington, D.C.
1974.  NTls PB-236-049.

U.S. Environmental Protection Agency.  Comparative Costs o_f Erosion
and Sediment Control, Construction Activities, Report no. EPA 430/9-
         Washington, D.C. 1973.  GPO $2.20.
U.S. Environmental Protection Agency.  Decision Makers Guide in Solid
Waste Management.  Washington, D.C. 1974.  Available upon request  from
0. S .W.M.P. Publications Distribution Center, U.S. Environmental Protec
tion Agency, 5555 Ridge Ave . , Cincinnati, Ohio  45268.

U.S. Environmental Protection Agency.  Ground Water Pollution from
Subsurface Excavations, Report no. EPA 430/9-7 3-012.  Washington,  D.C.
1973.  GPO, $2.25.

U.S. Environmental Protection Agency.  Identification and Control  of
Pollution from Salt Water Intrusion.  Washington, D.C. 1973.  NTIS~PB-

U.S. Environmental Protection Agency.  Methods and Practices for Con-
trolling Water Pollution from Agricultural Nonpoint Sources, Report
no. EPA 430/9-73-015.  Washington, D.C. 1973~!  GPO, $1.10.

U.S. Environmental Protection Agency.  Methods for Identifying and
Evaluating the Nature and Extent of Nonpoint Sources of Pollutants ,
Report no. EPA 430/$P7'3::014"!  Washington, D.C. 1973. GPO, $2.45.

U.S. Environmental Protection Agency.  Processes, Procedures and Methods
~ Contr°l Pollution Resulting from All Construction Activity~Report no.
EPA 430/9-73-007.  Washington, D.C. 1973.  GPO, $2.30~

U.S. Environmental Protection Agency.  Processes, Procedures and Methods
to Control Pollution from Mining Activities, Report no. EPA 430/9-73-011.
Washington, D.C. 1973.  GPO, $3.40.

U.S. Environmental Protection Agency.  Processes, Procedures and Methods
— Control Pollution from Silvicultural Activities, Report no. EPA 430/9-
73-010.Washington, D.C.  T973^GPO, $l7T5~

U.S. Environmental Protection Agency.  Sanitary Land Fill Design and
Operation.  Dick Brunner and Daniel Keller, Washington, D.C. 1972.
NTIS PB-227-565/9.

U.S. Environmental Protection Agency.  Subsurface Water Pollution, A Sel-
ected Annotated Bibliography.  Part I- "Subsurface Waste Injection"; Part
II- "Saline Water Intrusion"; Part III- "Percolation from Subsurface
Sources".  Washington, D.C.  NTIS, Part I: PB-211-340; Part II: PB-211-341;
Part III: PB-211-342.

U.S. Environmental Protection Agency.  The Control of Pollution from
Hydrographic Modifications, Report no. EPA 430/9-73-017.  Washington,
D.C. 1973.GPO, $1.95.

U.S. Environmental Protection Agency.  Urban Stormwater Management and
Technology: An Assessment.Report no. EPA 670/2-74-040.  National
Environmental Research Center, Cincinnati, 1974.  GPO, NTIS,  (awaiting
number assignment).
Grant, Eugene L. and W. Grant Ireson.  Principles of Engineering
Economy, 5th edition.  New York: Ronald Press, 1970.

U.S.Environmental Protection Agency.  Alternative Financing Methods
for Clean Water.  Washington, D.C.   (This report is in preparation and
will be available from EPA Regional  Offices upon completion).

Arnstein, Sherry R.  A Ladder of Public Participation,  "Journal  of
the American Institute of Planners", vol. 35, no. 4.  Washington,D.C.
July, 1969.  Reprints of journals are available  from  Kraus Thomson
Organization Ltd., Route 100, Millwood, N.Y.. 10546,  $3.75 per copy,
State month and year of journal desired.

Burke, Edmund M.  Citizen Participation Strategies, "Journal  of  the
American Institute of Planners".Washington, D.C.  Sept  1968.  Re-
prints of journals are available from Kraus  Thomson Organization Ltd.,
Route 100, Millwood, N.Y.   10546, $3.75 per  copy.   State month and
year of journal desired.

University of Michigan, Ann Arbor.  Public Participation in Water
Resources Planning.  1971.   NTIS PB-204-245"
U.S. Geological Survey.  A Procedure  for Evaluating Environmental
Impact, Circular no. 645.  Luna B. Leopold,^ Washington, D.C.
1971.  Available upon request from U.S. Geological Survey,  National
Center, Reston, Virginia  22092.

U.S. Environmental Protection Agency.  Manual  for Preparation of_
Environmental Impact Statements for Wastewater Treatment Works,
Facilities Plans, and 208 Areawide Waste Treatment Management Plans.
Washington, D.C. 1974.  Available upon request from U.S. EPA, Office
of Federal Activities (A-104), Washington, D.C.  20460.
Federal Water Quality Administration.  A Study of Flow Reduction
and Treatment of Waste from Households.  James R. Bailey,  et.  al,
Washington, D.cT 1969.  NTIS PB-197-599.

U.S. Environmental Protection Agency.  Acceptable Methods for
Utilization or Disposal of Sludges from Publicly Owned Wastewater
Treatment Plants.   Washington, D.C.  (This report is in
preparation and will be available from EPA Regional Offices
upon completion).

U.S. Environmental Protection Agency.  Alternative Waste Manage-
ment Techniques for Best Practicable Waste Treatment, Technical
Information Report.  Washington, D.C. (This report is in
preparation and will be available from EPA Regional Offices
upon completion).

U.S. Environmental Protection Agency.  Evaluation of Land
Application Systems, Technical Bulletin, EPA Report no.
EPA 520/9-75-001.   Wasbington, D.C., March, 1975.  GPO, NTIS
(awaiting number assignment).

U.S. Environmental Protection Agency.  Land Application of
Sewage Effluents and Sludges: Selected Abstracts, Report
no. EPA 660/2-74-042.  National Environmental"Research
Center, Corvallis, Ore. 1974.  GPO,  $2.80, NTIS  (awaiting number

U.S. Environmental Protection Agency.  Proceedings of Joint
Conference  on Recycling Municipal Sludges and Effluents On Land,
Held at University of  Illinois; July 9-13, 1973^Washington,  D.C.
1973.  NTIS PB-227-184 A/S

U.S. Water  Resources Council.  1972  OBERs Projections;
Economic ^^..ivity  Ln the U. S. ; Based on Series E Population,
vol. i-VlT!  Wash ing tori7 bTcT~1974~ GPO, stock~no77 voT.
I,  5245-0013, $3.05; vol.  II, 5245-00014, $2.50; vol.  Ill,
5245-00015, $3.10; vol IV, 5245-00016, $1.90; vol. V,
5245-00017, $2.75; vol. VI,  5245-00018, $2.50; vol. VII,
5245-00019, $2.75.