CY COOPERATION
COMPREHENSIVE
URBAN PLANNING
iND AIR QUALITY
MAINTENANCE
IE1NTAL PROTECTION AGENCY
Air and Water Programs
uality Planning and Standards
;le Park, North Carolina 27711
-------
-------
EPA-450/3-74-027
INTERAGENCY COOPERATION
IN COMPREHENSIVE URBAN PLANNING
AND AIR QUALITY MAINTENANCE
A Study Conducted by the Research Staffs of
Argonne National Laboratory
Energy and Environmental Studies Division
9700 South Cass Avenue
Argonne, Illinois 60439
and
American Society of Planning Officials
1313 East Sixtieth Street
Chicago, Illinois 60637
Interagency Agreement No . EPA-IAG-0159 (D)
EPA Project Officer: John Robson
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
March 1974
-------
The APTD (Air Pollution Technical Data) series of reports is issued by
the Office of Air Quality Planning and Standards, Office of Air and Water
Programs, Environmental Protection Agency, to report technical data of
interest to a limited number of readers. Copies of APTD reports are
available free of charge to Federal employees, current contractors and
grantees, and non-profit organizations - as supplies permit - from the
Air Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711 or may be obtained, for a
nominal cost, from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22151.
This report was furnished to the Environmental Protection Agency as a joint
study conducted by the research staffs of the Argonne National Laboratory,
Energy and Environmental Studies Division, Argonne, Illinois, and the
American Society of Planning Officials, Chicago, Illinois, in fulfillment
of EPA-IAG-0159 (D). ASPO research reports are not reviewed for approval
by the Board of Directors or by the membership of the society. The
contents of this report are reproduced herein as received from the contractor.
The opinions, findings, and conclusions expressed are those of the authors
and not necessarily those of the Environmental Protection Agency. Mention
of company or product names is not to be considered as an endorsement by
the Environmental Protection Agency.
Publication No. EPA-450/3-74-027
ii
-------
TABLE OF CONTENTS
Page
List of Tables iv
Summary v
1. Introduction 1
2. Questionnaire 2
3. Participation in Air Quality Management 4
4. Relationships with Air Pollution Control
Agencies 9
5. Planning Attitudes Regarding Air Quality
Management 14
6. Summary and Conclusions 21
iii
-------
LIST OF TABLES
Table Page
1 Jurisdictional Distribution of Agencies 3
Responding to Questionnaire
2 The Incorporation of Specific Air Quality 5
Considerations Into the Planning Process
3 How Agencies Incorporate Specific Air Quality 7
Considerations Into the Planning Process
4 Agencies Using Performance Standard Zoning 9
5 Organizational Relationships Between Planning 11
Agencies and the State on Local Designated
Air Pollution Control Agency (APCA)
6 Planning Agencies Giving Direct Assistance to 13
Activities Associated with Air Quality
Management
7 Attitudes Regarding the Relationship Between 15
Comprehensive Planning and Air Quality
Control
8 Planning Agencies Use of EPA Sources of 21
Information on Air Quality Management
IV
-------
INTERAGENCY COOPERATION IN COMPREHENSIVE URBAN PLANNING
AND AIR QUALITY MAINTENANCE
Summary
This is a study of the interagency relationships among state and
local air pollution control agencies and comprehensive planning agencies.
The study was conducted as a joint effort of Argonne National Laboratory,
Energy and Environmental Studies Division (ANL/EESD) and the American
Society of Planning Officials (ASPO) for the United States Environmental
Protection Agency, Office of Air Quality Planning and Standards, Land Use
Planning Branch. Staff from EESD and the ASPO research team developed a
questionnaire that explored the potential for planning agencies and air
pollution control agencies working together to achieve air quality goals.
This questionnaire was then submitted to the 900 public planning agencies
subscribing to the Planning Advisory Service of ASPO. The results of this
survey indicate that the record of interagency relationships has not been
good, although there are indications of the potential for planning agencies
to participate in and contribute to air quality programs.
Contributors:
Allen S. Kennedy, Project Manager
Frank Seal, Assistant Director for
Research
Richard Spicer
Charles Thurow
William Toner
Argonne National Laboratory
Energy and Environmental Studies
Division
American Society of Planning
Officials
ASPO, Research Associate*
ASPO, Research Associate
ASPO, Research Associate
* Now with Southern California Association of Governments, Los Angeles.
-------
-------
INTERAGENCY COOPERATION IN COMPREHENSIVE URBAN PLANNING
AND AIR QUALITY MAINTENANCE
Introduction
New state and local agencies have been created to monitor and
regulate air quality as a result of increased public concern for
environmental problems. Greater refinement in knowledge about air quality
has led planners to recognize that it must be dealt with on many levels.
Decisions often involve work done by local and regional planners; for
example, decisions that encourage an individual to live in one locale
and work in another, or that influence the location of a highway, have
a direct bearing on air quality. Similarly, a peculiar concentration
of emissions sources may create pollution pockets of particular local
significance, or the presence of a sanitarium or of a large elderly
population can require special local considerations for air pollution
control. In the face of such overlapping needs and problems, it is
clear that air quality cannot be achieved by having one agency set
standards and another blindly implement them; rather, there must be vital
interaction that will mesh air quality considerations into the planning
process. For effective coordination of effort, planning agencies must
not only make air pollution control a part of their work program but also
develop working relations with air pollution control agencies.
Planning activities are often hard to define and patterns vary
depending on place, problems and personalities involved; however, it is
important to assess how well planning agencies are functioning in terms
of investigating the accomplishments of their own work programs and of
the types of interaction they have had with state or local air pollution
control agencies. To evaluate these functions for this study, a general
1
-------
information questionnaire survey of urban and regional planning agen-
cies was used.
The Questionnaire
To determine what urban and regional planners are doing in support
of air quality control, a questionnaire was sent to various planning
agencies in May, 1973. This questionnaire was designed to obtain
information in three basic areas: first, to what extent are planning
agencies involved in air quality control; second, what kind of working
relationships do they have with air pollution control agencies; and
finally, what are the agencies' attitudes toward increasing their role
in air quality control.
The questionnaire canvassed the entire range of city, county, and
multi-jurisdictional planning agencies. It was sent to approximately
900 public planning agencies that subscribe to the Planning Advisory
Service of the American Society of Planning Officials. Three hundred
and twenty agencies returned questionnaires that were acceptable for
tabulation. These were categorized by jurisdictional population and
by jurisdictional types — municipal, county, multi-jurisdictional, or
state. Little significant variation was found between different popu-
lation and jurisdictional groups; consequently, the results are dis-
cussed in terms of the totals for all responding agencies. Because the
questionnaires were mailed as a general canvass of planning agencies,
the returns tend to weight the results in favor of the agencies with
larger staffs and greater interest in air quality. The data probably
overstates the extent to which urban planners are involved in air quality
control. In addition, Table 1 shows the distribution of returns by
-------
jurisdictional categories. The sample is clearly biased toward the
metropolitan areas with 234 (73%) coming back from agencies in SMSA's.
The questionnaire was not administered personally, but instead it
was simply mailed to the agencies. As could be expected, not all
agencies answered every question. Consequently, the results were
totaled in terms of those answering each question.
Table 1. JURISDICTIONAL DISTRIBUTION OF AGENCIES
RESPONDING TO QUESTIONNAIRE
Metropolitan
Number of
Agencies
Nonmetropolitan
Number of
Agencies
Central city planning
agency in SMSA 62
Municipal (city, town,
township, village, etc.)
planning agency (not 88
central city) in SMSA
County planning agency
in SMSA 38
City-county planning
agency in SMSA 19
Regional planning
agency or council of
Municipal (city, town,
township, village, etc.) 26
planning agency nc?t in
SMSA
County planning agency
not in SMSA 15
City-county planning
agency not in SMSA 10
Regional planning
agency or council of
governments not in SMSA 11
States
governments in SMSA 27 State planning agency
22
Other
Other
2
Total
320
-------
Participation in Air Quality Management
As Table 2 indicates, planning agencies' participation in air
quality control is not uniform. The record is best in environmental
planning and preparing, or reviewing, environmental impact statements.
Fifty-four percent of the agencies doing environmental planning and 61
percent of those handling environmental impact statements make air
quality a specific consideration in their work.
The figures seem to indicate that the environmental imract state-
ment process has done more to involve planning agencies in air quality
considerations than the A-95 review. It is difficult, however, to .make
a clear separation between these two review processes. As agencies
develop their capacity to handle work on air quality through these review
procedures, they may use it more in other work.
Planning agencies generally have not developed air quality programs.
In the important area of land-use planning, only 36 percent of the
agencies responsible for such planning consider air quality as an expli-
cit component, and in the area of transportation planning only 33 percent
of the agencies say they explicitly consider air quality. These figures
are important because planning traditionally has had its greatest impact
in land use and transportation, and, as previously mentioned, these two
activities have important causal links to air quality. Therefore, it is
in these areas that planning could make a significant contribution to the
task of controlling air pollution; or, on the other hand, it could cause
significant problems through neglect.
There are hopeful signs. Of those agencies that do deal with air
quality when doing land-use and transportation planning, a majority of
-------
Table 2 . THE INCORPORATION OF SPECIFIC AIR QUALITY
CONSIDERATIONS INTO THE PLANNING PROCESS
Planning Activities
Agencies having
primary respon-
sibility for
activity(n=320)
Agencies incorpo-
rating specific
air quality con-
siderations into
activity
Percentage
incorporating
air quality
Land-use plan
Transportation plan
Environmental plan
Housing plan
Redevelopment (e.g.,
urban renewal)
Health plan
Open space/recre-
tion plan
Capital improvement
A-95 review process
Zoning (land use)
Planned unit develop-
ment regulations
Subdivision regulations
Building codes
Housing codes
Emission density zone
(limits by sources/poll-
utant /area/time)
Air zoning & smokeless
zones(e.g., prohibiting
industrial polluters )
Utility extension policies
Review or preparation of
environmental impact
statements
307
224
179
212
108
28
200
189
106
234
235
216
68
72
109
73
97
38
26
11
58
29
48
97
52
29
26
23
36
33
54
18
24
39
29
15
45
41
22
13
38
32
28
87
205
21
35
16
125
75
73
18
61
-------
them incorporate it as a fundamental part of the planning process. (See
Table 3.) Seventy-two (66%) of the agencies which incorporate air
quality into their land-use plans make it one of the specified goals of
the plans. Forty-five (62%) of those doing transportation planning have
it listed as one of their goals. This means that when agencies do become
concerned with air quality, they make this interest an integral part of
their planning process and goals. The figures also mean that these
agencies see air quality as a problem that they can influence.
The same pattern follows for the other functional areas within
planning — housing, redevelopment, health, open space, and capital
improvement. All of these areas potentially have important interfaces
with air quality control because air quality may influence the plan or
the plan, air quality. In housing, for example, the poor air quality
of various areas may be one cause of declining property values, whereas
the location of residential areas may affect air quality due to traffic
congestion. Few agencies deal with these interfaces. As with land-use
and transportation planning, however, when an agency does incorporate
air quality into its plans, it tends to make it a specified goal. For
example, 28 out of the 38 planning agencies incorporating air quality
into their housing plans included it in their goal structures.
Table 2 and Table 3 also give some information on whether
agencies use specific implementaion devices. There is little indication
in this data of any attempt to strengthen implementation strategy so that
an agency could be more effective with air pollution control. For example
one of the strong tools for directing growth patterns, and therefore
controlling some aspects of air quality, is the extension of public
utilities such as sewer and water. Few agencies (16) have responsibility
6
-------
Table 3 . HOW AGENCIES INCORPORATE SPECIFIC AIR QUALITY CONSIDERATIONS
INTO THE PLANNING PROCESS
(Numbers of Agencies)
By incorporating the
By asking state desig- air quality standard
As a As a nated air pollution con- of the state designated
specified section trol agency for review air pollution control
Planning Activity goal of of and comment agency
Land use plan
Transportation- plan
Environmental plan
Housing plan
Redevelopment
Health plan
Open space/recreation plan
Capital improvement plan
A-95 review process
Zoning (land use)
Planned unit development
requirements
Subdivision requirements
Building codes
Housing codes
Emission density zoning
72
45
57
28
10
11
34
17
24
42
25
14
4
5
5
15
12
22
7
8
4
8
6
10
41
16
11
5
5
13
20
13
25
9
3
4
11
7
21
16
11
9
2
3
9
15
10
19
4
5
2
8
4
10
21
13
9
6
4
7
Air zoning and smokeless
zones 7 24 12 7
Utility extension policies 8 6 11 5
Review or preparation
of EIS 42 49 56 24
-------
in this area and only eight of them make air quality one of the criteria
that is used in setting policy. Likewise, very few agencies have the
option of using some of the techniques specifically designed to deal
with pollution loading and air quality: only 28 have emission density
zoning and 48 have air zoning and smokeless zones.
Zoning remains the primary method by which planning agencies attempt
to influence air quality. It is logical that this technique would get
the most use because separation of incompatible uses is likely to improve
air quality for at least some areas. But even so, only 41 percent of the
agencies make air quality a specific consideration in their zoning work.
Probably the most sophisticated way of including air quality in the
zoning process is through performance standard zoning. In performance
standard zoning, rates of emission per land unit or maximum allowable
emission from a given stack are set for a district along with measurement
and enforcement procedures„ Under these circumstances, it is feasible
for the clean steel plant to locate in a zone in which a dirty one could
not. The survey showed that over half (55%) of those agencies doing zoning
work use performance standard zoning. (See Table 4). Naturally, most of
these (73%) include air quality standards.
In asking the agencies how they rank these standards with state and
federal standards — whether they are more or less stringent — a surprising
number did not know. It is unlikely that this is simple ignorance of state
and federal standards, but instead a combination of factors. Indeed, they
may not have compared them, specifically. But they may also be using what
has been described as "primitive" performance standard zoning in which the
standards are worded in subjective terms, such as "no obnoxious odors or
smoke," instead of in specific measurable standards. In either case, it
8
-------
is clear that the problem of incorporating state and federal standards
into local zoning has not been solved. Better measurement techniques or
better air basin models may make this kind of zoning more feasible.
Table 4 . AGENCIES USING PERFORMANCE STANDARD ZONING
Number of Agencies
(n=320) Percent
Ye s No No
Is your agency responsible
for administering a zoning
ordinance?
210
If yes, does the ordinance
employ performance standards 116
If yes, do the performance
standards cover air quality
85
107
94
31
66
55
73
More Less
Stringent Stringent The Same
Don't Know
If yes, how do those air
quality performance stand-
ards compare to state
standards? 8
If yes, how do those air
quality performance stand-
ards compare to federal
standards?
11
24
10
68
Relationships with Air Pollution Control Agencies
The second objective of the survey was to discover the kinds of
relationships that exist between planning agencies and air pollution
control agencies. These relationships are important because they can
provide a flow of information that will lead to better coordina-
tion. Coordination can make the operations of both agencies more
-------
efficient by minimizing the number working at cross purposes. In
addition, if these two groups have strong working relationships they
will be able to give each other needed support. Both agencies, for
example, are often in the position of making adjustments to the private
market system in order to guarantee some larger social good. They may
find themselves having to play the role of environmental advocates.
One agency spokesperson, in answer to the question of how air pollution
control agencies could contribute to comprehensive planning, said:
"They could back us up when the political heat is on." This, of course,
is only the most dramatic form of cooperation. Local planning agencies
in particular have a perspective on the local area that can give posi-
tive imputs into the entire process of air quality management.
The record of developing these relationships, however, is as incon-
sistent as the record of directly integrating air quality management into
planning programs. As shown in Table 5, only 41 percent of the planning
agencies have either a formal or an informal process for working with
their respective air pollution control agencies. Approximately 50
more agencies have had some staff interaction -- although they do not
have any on-going contact. The majority of those who do, have telephone
relationships. When asked to describe the process of working together,
most respondants described it as informal — "we phone them up wh&n the
city has a question." There are some, however, who share data and also
some who send their materials to the air pollution control agency for
review and comment.
This general picture is supported by the questions about more
formal interagency relationships. Only nine agencies have staff members
who serve in some capacity in a state or local designated air pollution
10
-------
Table 5 . ORGANIZATIONAL RELATIONSHIPS BETWEEN PLANNING AGENCIES
AND THE STATE OR LOCAL DESIGNATED AIR POLLUTION CONTROL AGENCY (APCA)
Number of
agencies Percent
(n=320) Yes
Organizational Relationship Yes No
Does your agency and the state or local
designated air pollution control agency
have a formal or informal process for
working together, resolving differences,
sharing information, consulting with one
another, and so forth on policy, programs
regulations, standards, and controls per-
taining to air quality? 129 182 41
A staff member of your agency serves on
the board, commission, or committee of
a state or local designated air pollution
control agency (APCA) . 9 294 2
Your agency has a technical advisory com-
mittee on air pollution control. 15 295 4
A state or local designated APCA staff
member serves on a board, commission, or
a committee of your agency. 17 290 5
The state or local designated APCA has a
technical advisory committee on compre-
hensive land use planning. 22 170 11
A staff member of your agency has met
with a staff member of the state or local
designated APCA: 180 106 63
Frequently 30
Occasionally 90
Seldom 60
Never 106
The state or local designated APCA has used
data from your office • 81 128 38
The state or local designated APCA- has
sought your agency's advice on how land
use and transportation planning can be
used in an air quality improvement
program. 35 240 12
Your agency and APCA mail to one another
notices of commission and hearing committee
meetings, public hearing, etc. 71 230 23
11
-------
control agency; there are only 17 cases of the reverse arrange-
ment. It is probably indicative of general inaction on the part of both
types of agencies that practically none of them has used an advisory
committee arrangement as a coordinating mechanism. The two sets of
agencies have done the most in sharing data and in keeping each other
informed of hearings and commission meetings. But even so, the record
indicates that more could be done.
Further improvement is needed in the areas of exchanging information
and coordinating air quality activities among both types of agencies.
In this particular case, there seems to be a distinct pattern of the
planning agencies going to air pollution control agencies for
advice and counsel, but little of the reverse. In only 35 cases have
air pollution control agencies approached planning agencies for sugges-
tions on how the land-use and transportation plans could be used to
improve air quality. This pattern is particularly evident when one
looks at the specific activities associated with air quality management
as shown in Table 6 . Planning agencies have some input through their
traditional stronghold of land-use controls, but they have very little
role elsewhere. Even in areas where they would be able to review and
evaluate work in order to check it for relevance to local conditions,
they do not. For example, in the first item -- air quality effects and
damages -- they could give important feedback on the air control agency's
work, but evidently they do not have that opportunity.
Planning agencies were asked to describe their achievements pertain-
ing to air quality management activities. Of those answering the question,
most said they had made none. Although absolute conclusions should not
be drawn from this type of question, it does suggest that no immediate,
12
-------
Table 6:. PLANNING AGENCIES GIVING DIRECT ASSISTANCE TO ACTIVITIES
ASSOCIATED WITH AIR QUALITY MANAGEMENT
Number of
agencies Percent If Yes. Qualify
(n=230) Yes Provide Advise/ Prepare Evaluate/ Other
Activities Yes No Data Propose Review
Air quality effects
and damages 10 285 3 43 1 6
Air quality
standards 21 275 7 87 2 71
Point source con-
trol regulations 15 280 5683 8
Area source emis-
sion control
regulations 16 282 5 6 A 2 8
Mobile source
emission con-
trol regulations 8 287 2 57 1 7
Land use controls
(e.g., prevent or
modify construc-
tion) 107 194 35 42 53 28 53 5
Transportation
controls (e.g.,
auto free zones.
parking bans) 38 258 12 17 22 6 18
Public facility
control 35 237 12 13 21 7 17
Source permit
system 15 283 5 74 2 6
Source
surveillance 11 283 3 522 3
Air quality
monitoring 9 286 3 71 2 4
Episode control
programs 6 286 2431 3
Air quality data
and reports 16 281 5 10 2 5 14
Emission data
and reports 12 273 4743 11
13
-------
concrete accomplishments are vivid in the respondent's memory. If
there are results, they have been nebulous, rather than direct and
tangible. In part this may be due to the fact that the relationships
are relatively new and still in a formative stage; however, there may
be little incentive to develop stronger relationships if those in the
past have not received the reinforcement of positive accomplishment.
Planning Attitudes Regarding Air Quality Management
The third and final goal of the survey was to ascertain the planning
agencies' attitudes toward air quality management; that is, whether or
not they should be involved, and what they feel the possible stumbling
blocks have been in the past. These attitudes and opinions are sum-
marized in Table 7 . This section of the survey is important because
it gives some indication of the potential for involving planning agencies
in air quality management.
Planners overwhelmingly support the idea that they should be involved
in air quality management and believe they can make significant contri-
butions to the program. Four-fifths of the responding agencies believe
that considerations of air quality lie within their realm of responsi-
bility. They reject the idea that the multijurisdictional nature of
pollution problems makes it difficult for them to contribute to air
pollution control. Although planners understand the emphasis in published
research on a regional, air basin level approach to air quality manage-
ment, they also see a potential for effective work within a single
political jurisdiction.
This positive attitude about planners" potential contributions to
air quality management runs throughout the rest of the questionnaire.
Fewer respondents feel that their agencies presently have a lot to offer
14
-------
TABLE 7. ATTITUDES REGARDING THE RELATIONSHIP BETWEEN COMPREHENSIVE
PLANNING AND AIR QUALITY CONTROL
Strongly
Agree
Tend to
Agree
Tend to
Disagree
Strongly
Disagree
Not
Applicable
or No
Opinion
Any consideration of
air quality is beyond the
basic function of our
agency even if legal
authority, funds, staff,
and other resources were
available for such
considerations. 16
The air pollution
problem exceeds our
agency's political
boundaries and there-
fore this agency can
make no contribution to
air pollution control. 9
The majority of the
planning commission
wants our agency to
contribute to air
pollution control
activities 23
The majority of the
governing body wants
our agency to contri-
bute to air pollution
control 28
This agency has much
to offer a state or
local designated air
pollution control
agency 42
Air pollution control
should not be handled
exclusively by the
state or local desig-
nated air pollution
control agency 75
46
116
136
41
115
123
28
99
36
32
125
92
41
21
117
124
78
22
51
124
65
28
19
15
-------
TABLE 7 (continued). ATTITUDES REGARDING THE RELATIONSHIP BETWEEN COMPREHENSIVE
PLANNING AND AIR QUALITY CONTROL
Strongly
Agree
Tend to
Agree
Tend to
Disagree
Strongly
Disagree
Not
Applicable
or No
Opinion
Effective coordination
with the state or local
designated air pollution
control agency is worth
the cost in time and
money to this agency 80
Even though this agency
has much other responsi-
bilities, it should be
involved effectively in
air pollution control 75
Our agency has tried to
work with state or local
air pollution control
agencies, but they have
not been very cooperative 6
Lack of statutory autho-
rity has prevented this
agency from participating
in air pollution control
activities 31
We are interested in
working on air pollution
control activities, but
other issues have higher
priority 48
We do not have any staff
qualified to work on air
pollution control
activities 100
The relationship between
our activities and air
quality is so poorly
understood that we can't
make a contribution 13
168
35
49
169
36
29
29
80
57
132
90
96
36
82
183
35
13
27
130
60
17
15
63
145
62
37
16
-------
TABLE 7 (Continued). ATTITUDES REGARDING THE RELATIONSHIP BETWEEN COMPREHENSIVE
PLANNING AND AIR QUALITY CONTROL
Strongly
Agree
Tend to
Agree
Tend to
Disagree
Strongly
Disagree
Not
Applicable
or No
Opinion
Air pollution control
agencies do not under-
stand the comprehensive
planning process 19
It would be politically
impossible for us to
make a contribution to
air quality control
programs 14
Our agency would be
interested in using
a quantitative model
to evaluate its compre-
hensive land use and
transportation plan
alternatives for their
impact on air quality 90
Air pollution control
agency should have
authority to veto any
proposed major land use
development whose emissions
would make difficult the
maintenance of clean air 85
77
81
31
131
125
25
112
57
25
67
11
34
107
46
50
22
to state or local air pollution control agencies, but the positive
response is still over half. When asked to balance staff and budget
considerations with output on air quality management, 78
percent believed that effective coordination with air pollution control
agencies is worth the time and money involved. Even with other respon-
sibilities, the same percentage agreed that they should put their
resources behind air pollution control.
17
-------
Planners' interest is tempered by their awareness of the specific
problems involved. There is some doubt, for example, on the support that
they recieve from their commissions and from governing bodies. Only
35 oercent of the agencies feel that they have the support of
the majority of their planning commissions for contributing to air pollu-
tion control activities. A significant number -- 125 -- did not know if
they had support or not. The same pattern holds true for the governing
bodies. Clearly there is still no general political consensus behind air
pollution control, and the agencies are often left in a political limbo
without clear indicators from public policy. This political uncertainty
probably contributes to the even spread in the responses to the need for
statutory authority before embarking on air quality work. On the other
hand, these same responses do not indicate political shyness or timidity.
Over three-fifths (62%) of the agencies do think it is politically feas-
ible to make a contribution in this area. If they are in doubt about the
political situation, at least they are willing to brave it.
As might be expected, the chief limitations that the agencies see
are in terms of staff and information. Although they are interested in
air pollution control, other work has already established itself as having
higher priority. As the rest of the questionnaire supports, the air
quality programs in planning agencies are still in their formative stages
and it is logical that the longer established work programs tend to push
the new to the background. Furthermore, the agencies feel that they need
specialization in their staff if they are going to increase their efforts
in air pollution control. Two hundred and thirty of the total 320
agencies believe that they do not have staff qualified to work on air
quality; a hundred of those feel a specialized staff is particularly
important.
18
-------
This desire for specialized staff reflects the types of programs
that agencies would like to develop. As Table 7 indicates, there is
general interest in using a quantitative model to evaluate comprehensive
land use and transportation plan alternatives for their impact on air
quality. A similar concern for quantitative skills dominates planning
agencies' desires for relationships with air pollution control agencies.
Most of the respondents think of these agencies as sources of "technical
assistance and guidance," or "objective criteria by which to judge
alternatives," or "data on the comparative effects of different land uses
upon the region's atmospheric conditions." There is a clear pattern of
concern for what could be called an objective, or technical, approach to
air pollution.
In part this response is the logical outgrowth of the political
situation described earlier. If the planners are working in a politically
hazy area, then it is particularly important for them fco be technically
clear and precise. Furthermore, the emphsis on staff trained in air
quality work and the desire for more technical information are expressions
of a general uneasiness when moving into a new area of work. Air quality
in particular, seems to create insecurities in terms of methodology.
One agency representative pointed directly to an information lag that
the agencies feel:
Air pollution control is achieving a degree of technical ad-
vancement at a pace which makes it difficult for city agencies
to remain abreast without a degree of coordination which is not
present in this area. We need dialogue, correspondence, etc.
to keep aware of what can be done in this area — without~re~ly-
ing, totally, on a larger agency.
Probably some of the desire for quantitative modeling and for more
specialized staff is an expression of this information lag.
19
-------
This lag may be due in part to the simple dissemination of inform-
ation. In the process of the questionnaire, planning agencies were asked
about their use of particular information sources developed by the
Environmental Protection Agency and air pollution control agencies.
The results shown in Table 8 indicate that the majority of agencies
have not used these sources. Part of the difficulty may be in preparing
materials that are specifically useful to the planning agencies --
particularly those without large, specialized staffs. Many of the remarks
made about the role of pollution control agencies could be translated
as: Help us apply these air quality programs to the specific conditions
we face at this moment.
Positive linkages in the flow of communication can help build the
strong relationships that are desirable between the two types of agencies.
Air pollution control agencies can assist in developing technical services,
and, in a complementary fashion, planning agencies can aid by providing
important data. Air quality analysis is only one kind of support they
can give to each other; cooperative arrangements should expand into other
areas relating to implementation and enforcement of air quality control
via the planning and decision-making processes.
20
-------
Table 8 . PLANNING AGENCIES USE OF EPA SOURCES OF INFORMATION
ON AIR QUALITY MANAGEMENT
Information Source
Number of agencies
have used the
source (n=320)
EPA publications on air pollution damages
EPA publications on air pollution control
and costs
EPA state implementation plans
EPA guidelines and/or procedure manuals
EPA air quality data
EPA emission inventory data
EPA publications on emission factors
EPA atmospheric dispersion factors
EPA training programs
EPA key work literature search
60
47
59
78
63
35
36
13
16
Summary and Conclusions
The record for planning agencies integrating air quality manage-
ment into their program has not been good. Few agencies specifically
consider air quality in the vital areas of land-use pla'nning and trans-
portation planning, and even fewer consider it in other functional areas •
such as housing,open space, or redevelopment. In addition, most agencies
lack primary responsibility for developing utility extension policies
or zoning tools such as emission density zoning and air zoning, which
they could use to influence air quality through their planning programs.
21
-------
It is significant that those agencies that have dealt with air quality
in their work have integrated it into their entire work program. Air
quality has generally tended to become one of the specific goals of the
planning agency's activities.
The record on interagency relationships between planning and air
pollution control is equally weak. Whereas nearly half of the planning
agencies have some formal or informal contact with their respective
pollution control agencies, most relationships are informal and tend
to remain at an exchange of information level. There is little indica-
tion of extensive cooperation between both groups.
In spite of this record, there are indications of the potential for
planning agencies to contribute to air quality programs. A large per-
centage of the planning agencies want to be involved and are willing to
commit staff and budget to this work. What is needed in order to realize
this potential is the availability of technical advice and consultation
that will allow the agencies to begin building their capabilities in
this area. A role for planning agencies should be specified and set
forth in guideline form.
In conclusion, the record of interagency cooperation between planning
agencies and air pollution control agencies documented by this survey
should not come as a surprize. No strong incentives have been forth-
coming from the EPA for State and local air pollution control agencies
to use the planning community as a resource. Air pollution control guide-
lines have suggested that transportation and land use controls be con-
sidered in the development of implementation plans, but no specific
22
-------
guidelines on how this should be accomplished have been published. The
EPA has published information and quantitative methods of air pollution
analysis, but the record shows lack of general use of this information by
the planning community. Again, the absence of precise definitions of roles
and responsibilities have created a lack of incentive on the part of
planning agencies to make air pollution impact analyses an integral part
of the planning process. Perhaps the most recent issues of complex sources
and long-term maintenance of air quality standards will provide the impetus
for defining roles for the planning community in air quality control.
Unless guidelines are forthcoming to direct state and local air pollution
control agencies to integrate the planning community into their control
plans and programs, it is unlikely that the record of inter-agency cooperation
to achieve quality goals will significantly improve in the future.
23
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO.
EPA-450/3-74-027
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Interagency Cooperation in Comprehensive Urban Planning
and Air Quality Maintenance
5. REPORT DATE
March 1974
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Allen S. Kennedy, Frank Beal, Richard Spicer, Charles
Thurow, William Toner
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Argonne National Laboratory
Energy and Environmental Studies Division
9700 South Cass Ave.
Argonne, Illinois 60439
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
EPA-IAG-0159(D)
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Prepared in cooperation with: American Society of Planning Officials, 1313 East
60th Street, Chicago, Illinois 60637
16. ABSTRACT
This is a study of the interagency relationships among state and local air
pollution control agencies and comprehensive planning agencies. The study was
conducted as a joint effort of the Argonne National Laboratory, Energy and Environmen-
tal Studies Division, and the American Society of Planning Officials for the United
States Environmental Protection Agency, Office of Air Quality Planning and Standards,
Land Use Planning Branch. Staff from EESD and the ASPO research team developed a
questionnaire that explored the potential for planning agencies and air pollution
control agencies working together to achieve air quality goals. This questionnaire
was then submitted to the 900 public planning agencies subscribing to the Planning
Advisory Service of ASPO. The results of this survey indicate that the record of
interagency relationships has not been good, although there are indications of the
potential for planning agencies to participate in and contribute to air quality
programs.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Land use
Planning and zoning
Local government
Questionnaires
Air Pollution Control Agencies
13. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
28
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
24
------- |