GUIDELINES FOR
AREAWIDE WASTE TREATMENT
MANAGEMENT PLANNING
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
AUGUST 1975
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GUIDELINES
for
AREAWIDE WASTE TREATMENT MANAGEMENT PLANNING
SECTION 208
FEDERAL WATER POLLUTION CONTROL ACT
AMENDMENTS OF 1972
Environmental Protection Agency
Washington, D.C. 20460
August 1975
U. 3- -
QJJS8A,
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AUG 7 1975
FOREWORD
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.
\dministrator
U. S. Environmental Protection Agency
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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
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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
Glossary
Bibliography
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CHAPTER 1
INTRODUCTION
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.
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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.
1-2
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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
process.
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.
1-4
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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.
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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.
1-6
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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
locally.
1-7
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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
program.
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
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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
plan:
. 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.
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CHAPTER 2
RELATIONSHIP WITH OTHER PROGRAMS
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
alternatives.
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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
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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
Administrator.
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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
regulations.
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.
2-4
C.
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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
strategies;
3. Assessment of 208 plan implementation on air quality,
especially the primary and secondary effects of treatment
facilities;
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
pollutants.
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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
plan.
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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:
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. 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
3-2
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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
abatement.
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 goalsmeeting 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.
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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
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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).
3-5
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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
3-6
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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
investigated.
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
specified.
3-7
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(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
Quality
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:
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. 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
monitoring.
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
input.
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.
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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.
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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.
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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
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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.
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. 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
controlled.
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 3.3.0.8),
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).
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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
sources.
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;
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. 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
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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
feasible?
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.
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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.
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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
management.
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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
combined.
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)
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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.
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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.
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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.
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TABLE
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
Implement)
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-
val.
(c) The identification of required
'urban storm water runoff ccntrol sys-
tems;
(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
options
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)
(c)(l)
an analysis of the magnitude of existing and anticipa-
ted urban Stormwater problems including those resulting
from combined sewer overflows
(c)U)
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
(d)
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
Major
References
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).
3-24
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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,
etc.)
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
(e}(l)
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-
ing
- 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
(e)(2)
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) ).
(e)(3)
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 }
Major
References
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.
3-25
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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
Major
References
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)
3.4-
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
intrusion]
i
Residual "Waste
Management
~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
sources.
(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
sources;
(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
sources;
(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
quality;
(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,
i
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
pollutants
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
3-26
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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,
"[continued)
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
References
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 ager.cy(s) 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
3-27
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CHAPTER 4
DETAILED CONSIDERATIONS FOR LAND USE
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
plan.
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
standards.
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
revisions.
4-2
-------
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.
4-3
-------
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
quality;
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
4-4
-------
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-
tified.
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
ordinances.
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.
4-5
-------
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
o
4-6
-------
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
quality?
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.
4-7
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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.
4-8
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CHAPTER 5
DETAILED CONSIDERATIONS FOR POINT SOURCES
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.
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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
systems.
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.
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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
meters.
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.
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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
system.
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-
loading.
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).
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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
presented.
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
following:
(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.
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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
techniques;
(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.
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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
practicable;
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.
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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.
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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
facility;
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.)
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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).
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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 .
year).
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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.
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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
systems.
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-
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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
systems;
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.
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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-
water.
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.
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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
initiated.
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
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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-
niques.
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;
o
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
components;
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.
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CHAPTER 6
DETAILED CONSIDERATIONS FOR NONPOINT SOURCE MANAGEMENT
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
System.
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
include:
"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;"
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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
6-2
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"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
Programs
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
Areas
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.
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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.
D.
Distinguish Planning Approach for Existing and New Nonpoint
Sources
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.
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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)
where:
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
pollutant
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
load.
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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.
6-6
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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
practices.
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.
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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
6-8
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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
Campaign";
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
chemicals.
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)
6-9
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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:
6-10
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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-
tion
d. Legal/institutional controls to prevent construction
and thus avoid flood damage in flood plains
e. Structural alternatives - levees, floodways, retarding
basins.
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
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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:
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1. Land and Subsurface Disposal of Liquid Waste
a. Pollution from wells, waste, brine, radioactive gas
storage
(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
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(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
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(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
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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.
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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.
6-17
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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.
6-18
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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.
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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 should.be 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-
tives.
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.
6-20
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CHAPTER 7
MANAGEMENT RESPONSIBILITIES AND INSTITUTIONAL ARRANGEMENTS
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
operations.
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.
7-2
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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-
tation.
B. Statutory Requirements
The Act requires that a 208 regulatory program include the
following:
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.
7-3
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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
purposes.
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;
7-4
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--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
operations;
--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
staffing.
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.
7-5
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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.
7-6
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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
below.
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, stormwater.management, 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.
7-7
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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
discharged.
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
revenue?
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:
7-9
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7-10
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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
7-11
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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
required.
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.
7-~T2
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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.
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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.
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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
indebtedness.
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
treatment).
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.
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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
follows:
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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
required.
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
requirements.
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.
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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.
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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
period.
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.
C-G
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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
cost.
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.
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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.
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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.
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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:
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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.
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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-
making."
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3.
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
participation.
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.
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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
alternatives.
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.
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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.
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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
plan;
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
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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
appropriate.
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.
10-6
-------
10-7
DESIGN OF ALTERNATIVES ^MS AND
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10-8
PLAN REVISION RECOMMENDATIONS
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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.
10-9
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ORGANIZATIONAL STRUCTURE
Advisory Committee*
208 Planning Staff
Citizen Participation
Working Group
208 Management
Agency
I
**
Effluent
Limitations
Water Standards
Attainment
Nonpoint
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.
10-10
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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.
10-11
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CHAPTER 11
ENVIRONMENTAL, SOCIAL AND ECONOMIC IMPACT EVALUATION
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
recommendations.
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;
11-2
-------
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.
11-3
-------
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:
11-4
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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
implementation.
11-5
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CHAPTER 12
COMPARISON OF ALTERNATIVES AND SELECTION OF PLAN
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-
cations.
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.
12-2
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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.
12-3
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TABLE 12.1
COSTS AND EFFECTS OF ALTERNATIVE AREAWIDE PLANS
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
area.
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
monitoring
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
12-4
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TABLE 12.1 (cont)
COSTS AND EFFECTS OF ALTERNATIVE AREAWIDE PLANS
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
projections)
12-5
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TABLE 12.1 (cont)
COSTS AND EFFECTS OF ALTERNATIVE AREAWIDE PLANS
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
activities
(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
12-6
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PLAN ELEMENTS
1.
2.
3.
TOTAL COST $_
IMPACTS
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
sites).
DESCRIPTION
Economic
1.
2.
3.
Social
1.
2.
3.
Environmental
1.
2.
3.
IMPLEMENTATION
(Institutional and financial issues.)
12-7
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TABLE 12.3
ALTERNATIVE LEAST COST PLAN MODIFICATIONS
Plan Elements
1.
2.
3.
Least
Cost
Alternative
Alternative
A
Impacts
Cost
Increase
Alternative
B
Impacts
Cost
Increase
12-8
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CHAPTER 13
REPORTS
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 sectionsa condensed
report on outputs and a full report on the planning processas discussed
below.
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
report.
13-2
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CHAPTER 14
PLAN SUBMITTAL, REVIEW AND APPROVAL
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.
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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;
14-2
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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
agency(s)).
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,
14-3
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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.
14-4
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GLOSSARY
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
maintenance.
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)
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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.
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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
for.
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
502(7)).
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).
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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,...in 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.
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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
consideration.
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 nature...in 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)).
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BIBLIOGRAPHY
NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
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.
U.S_. GOVERNMENT PRINTING OFFICE (GPO)
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.
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EPA REGULATIONS
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
revision)
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)
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EPA PROGRAM GUIDANCE
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.
20460.
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.
WATER QUALITY MANAGEMENT PLANNING
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.
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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.
URBAN PLANNING AND LAND USE
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,
1969.
U.S. Council on Environmental Quality. The Quiet Revolution in Land
Use Control. Fred Bosselman and David CallielTGPO, stock noT 4111-0006,
$2.75.
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,
$2.60.
POINT SOURCE
U.S. Environmental Protection Agency. De sign Criteria for Mechanical,
Electric, Fluid Systems and Component Reliability. Washington, D.C.
NTIS PB-227-558/4";
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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
Offices.
NON-POINT SOURCE
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-
227-229/2.
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.
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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).
DIRECT RESOURCES COST AND FINANCING ARRANGEMENTS
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).
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PUBLIC PARTICIPATION
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"
ENVIRONMENTAL IMPACT
U.S. Geological Survey. A Procedure for Evaluating Environmental
Impact, Circular no. 645. Luna B. Leopold, ejz.al^ 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.
ALTERNATIVE TREATMENT TECHNIQUES, RESIDUAL WASTE MANAGEMENT,
POPULATION PROJECTIONS
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.
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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
assignment).
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.
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