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

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                                       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

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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

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                        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

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                           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

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        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.

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      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

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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

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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

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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

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       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

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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




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         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

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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

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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

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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




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    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

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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

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      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

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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

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       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

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 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

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 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

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     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

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     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

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     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

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    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

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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

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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

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                                  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

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