OCR error (C:\Conversion\JobRoot\00000CE7\tiff\20013MNA.tif): Unspecified error
-------
WQM FRAMEWORK MANUAL
U.S. Environmental Protection Agency
Water Planning Division
Program Evaluation Division
-------
Table of Contents
CHAPTER TITLE PAGE
INTRODUCTION 1
1 PROBLEM ASSESSMENT 7
2 STRATEGIES 19
3 WQM PORTION OF THE STATE/EPA AGREEMENT 37
4 WORK PROGRAMS 49
5 ASSISTANCE IN THE IMPLEMENTATION OF WQM PLANS
& EXECUTION OF WORK PROGRAMS 77
6 EVALUATION OF PROGRESS 91
7 IMPLEMENTATION INFORMATION SYSTEM (RESERVED) ....
APPENDICES
PUBLIC PARTICIPATION WORK PROGRAMS
n
-------
Introduction
Water Quality Management Program
Since 1973 the Water Quality Management (WQM) Program has been an
evolving one. It started as three separate programs under Sections 106,
208, and 303(e) of the 1972 Federal Water Pollution Control Act amend-
ments. In 1975 the planning under Sections 208 and 303(e) was combined
and in May, 1979 regulations were published, formalizing the integration
of Sections 106, 208 and 303(e) into the WQM Program.
The Water Quality Management Program is one of several programs that
contribute to the achievement of the water quality goals of the Clean
Water Act including, "protection and propagation of fish, shellfish
and wildlife and provision of recreation in and on the water by 1983
wherever attainable..." The relationship of the water quality manage-
ment program to the problem solving process is described in Chapter 4
of the Supplemental Water Quality Management Program Guidance for FY 1981
(June, 1980).
The certified and approved Water Quality Management Plan (authorized
under Section 208) forms the basis of the Water Quality Management
Program. The plan is a key aspect of the management process, and is
intertwined throughout the process. Information from the initial WQM
plans supplemented as appropriate with additional information from
monitoring, intensive surveys, etc. serve to identify additional
planning requirements. The institutional and financial components of
the plans lay the groundwork for implementation of plan recommendations.
Evaluation of the implementation of the WQM plan may lead to the
identification of weaknesses in the program, the need for additional
208 planning to strengthen the program and to recertification of the
plan. Areas which need to be strengthened should be incorporated into
the annual update of the State's five year problem solving strategy,
the State/EPA Agreement and the work programs. The work programs define
-------
activities necessary to develop the control programs to solve water
quality problems, carryout other WQM activities such as plan revisions,
monitoring, enforcement, permitting, management of the construction
grants and nonpoint source control programs and evaluation of the
performance of management agencies.
A comprehensive WQM plan directs a State action program that effectively
controls pollution problems from both point and nonpoint sources. The
WQM Plan should identify control needs and any conditions to be included
in NPDES permits; should identify the regulatory and other programs to
implement the controls and the financing of control programs; should
identify the management agency(s) with adequate authority and capability
to implement the plan's programs; and should assess the environmental,
social and economic impacts for the following program elements:
• Total maximum daily loads and wasteload
allocations;
• Dredge and fill programs;
• Nonpoint source control needs;
• Municipal and industrial needs;
• Urban storm water needs;
• Residual waste control needs;
• Water quality standards revisions; and
• Water conservation practices
Once certified and approved according to the process described in
40 CFR 35.1523, the plan becomes the official State program to solve
the priority geographical and categorical water pollutant problems. As
part of the certification process the State assures that the plan will
be implemented and appropriate sections will be used for setting
permit conditions, nonpoint source controls, schedules of compliance
and requirements for municipal waste water treatment systems. In
addition, Federal properties and facilities are required to be in com-
pliance with State, interstate and local substanstative and procedural
requirements included in certified and approved water quality management
plans.
The initial plans submitted during the three year planning period were
not comprehensive because the plans did not include programs to control
both point and nonpoint sources. In the first phase (FY 73-75), area-
wide agencies concentrated on cost-effective municipal treatment
processes. During this period, States conducted basin planning under
Section 303(e) of the Act using their own or 106 program funds. The
-------
basin plans were used to set effluent limits, develop water quality
standards and rank municipal waste water construction treatment needs.
Following promulgation of the "130/131" regulations and opening 208
funding to States in 1975, 303(e) basin planning was to be integrated
with 208 WQM planning.
Many States opted to take over the planning for the control of nonpoint
source pollutant problems but did not integrate their 303(e) basin
plans with the nonpoint source program elements and develop a com-
prehensive water quality management plan. A few States have updated
their basin plans as the point source element of their WQM plan. The
plan will be taken through the certification and approval process
which raises the status of the 303(e) basin plans and makes them an
official part of the State's WQM program.
However, the primary gap in most of the WQM plans was the absence of
control programs for nonpoint source pollutant problems. Therefore,
EPA is directing 208 funds toward problem solving projects designed
to identify cost-effective controls for nonpoint source problems.
At the same time, EPA is emphasizing the importance of moving beyond
planning to the implementation of control programs. To be eligible for
208 funding in FY 80 and beyond, grantees are to define with the
Regional Office the implementation which is to occur over the next
year in order to be eligible for 208 funding the following fiscal
year (for "Significant Implementation Agreements," see 40 CFR
35.1533-3(b)).
As solutions to specific pollution control problems are defined and
programs to control the pollutant problems developed, the WQM plan
should be updated and taken through a similar certification and
approval process as the initial plan. This is not necessarily an annual
requirement but is required as plan revisions occur and should be
included in State/EPA Agreements and State and areawide work programs.
In addition, the framework for State management of the WQM Program,
the Continuing Planning Process (CPP) description, should be revised
to reflect changes in State and Federal laws, State organization,
procedures and processes for developing and implementing solutions
to water quality problems.
In FY 81 and beyond, State and areawide agencies will move from non-
point source planning into management of nonpoint surce control
programs. At the same time, EPA will shift its emphasis from
individual grant programs (e.g., 208) into a consolidated process
which combines all aspects of the overall problem-solving process.
The WQM program has made much progress in cleaning up the nation's
water and, in FY 81-83, will continue to fill gaps in 208 plans,
build an information base, and move to implementation of controls.
With adequate funding (at $50M per year), EPA anticipates completion
-------
of the 208 grant program in FY 83. Without adequate funding, EPA
will request reauthorization of 208 funding to complete WQM planning.
To ensure WQM activities continue after FY 83, EPA has begun to develop
recommendations for a restructured WQM program, in conjunction with
the upcoming 1990 construction grants strategy.
WQM Framework
The WQM Framework provides a systematic approach for managing the WQM
program on an annualized basis. The Framework prescribes an assertive,
style of management by which Regional Offices assist States exercise
their responsibility of coordinating local political action to transform
areawide plans into comprehensive water quality management programs.
The Framework provides the management structure to promote vigorous
implementation of WQM plans. Although the configuration of the WQM
program varies in Regional Offices because of different organizational
alignments, the Framework is flexible enough to allow each Regional
Office to adopt the principles of the Framework and still meet its own
unique requirements.
The WQM Framework builds the foundation for an integrated WQM program
from the separate sections of the Clean Water Act (106, 208, 303(e))
and includes both the regulatory requirements and the demands of good
process management for the WQM Program as a whole. The elements of
the WQM Framework include:
• Assessment of the water quality problems to
be used to select the WQM program priorities
and activities.
• Development of Strategies in which goals,
objectives and priorities are set and a cohesive
sequence of activities are defined to develop
and implement solutions to the water quality
problems.
• Development of the WQM portion of the SEA to
document the mutual commitment of EPA and the
State to solve priority environmental problems,
based on water quality problem assessments
and strategies.
• Development of work programs to identify and
manage priority tasks to solve the water quality
problems.
• Assistance by Regional Offices in the implementation
of WQM plans and execution of work programs as
the key to make the WQM process work - the
development and implementation of WQM plans,
effective and efficient administration of
operational control programs and the improvement
in water quality.
-------
• Evaluation of progress to keep management, planning
and implementation moving in the right direction.
Figure I shows a timeline of the activities included in the WQM Framework.
Purpose of the Manual
The WQM Framework Manual serves as an introduction to the Water
Quality Management Program and as a guide to improve the management of
the WQM Program. The Manual is written for Regional Office personnel
directly or indirectly involved in the program. It describes the operation
and effective management of the program. The loose-leaf format allows
Regional Offices to supplement chapters and appendices with procedures
and forms specific to the Region.
Each Chapter of the Manual discusses the activities required to manage
the WQM program and suggest ways to carry out the activities. There
is also a description of the products to be completed and the criteria for
judging the quality of the products. The appendices which correspond
to each chapter provide examples of the tools to manage the framework
element or includes analyses of innovative features of these tools.
Finally the Manual defines what is expected of the Regional Office in
managing the WQM Program. It will be used as a basis of the WQM Pro-
gram Review of the Regional Office.
Chapter 1; describes the problem assessment and
its use as the basis of WQM program activities.
Chapter 2: discusses how strategies are developed
to plan State and Regional program activities.
Chapter 3; lists the activities in the preparation
of the WQM portion of the State/EPA Agreement.
Chapter 4; focuses on the work program as an
essential tool in the management of WQM program
activities.
Chapter 5; explores the technical and managerial
assistance to be provided or arranged for State
and local agencies to carryout their work programs
or implement the WQM plans.
Chapter 6; discusses the various types of evaluations
which establish the feedback look to keep planning,
implementation and management moving in the right
direction.
Chapter 7; defines goals and objectives of an
implementation information system to be piloted in
FY 1981 for agriculture.
Appendices
-------
Figure 1
WQM FRAMEWORK
2 Year Time Line
.1
PROBLEM ASSESSMENT
Monitoring Strategy Guidance Issued
State 5-Year Strategy
Headquarters Modification* to FY 82 305(b)
Report Guidance
305(b) Reports
Assist States prepare FY 80 305(b) Reports i
.J 80 305(b) Reports Due
Regional Overview of the WQ Problems Prepared
STRATEGIES
HQ's Draft WQM 5-Year Strategy
HQ's WQM 5-Year Strategy Issued
Draft R.O. Source Control/Funding Strategy
R.O. Source Control/Funding Strategy Issued
5-Year Strategy
Assist States prepare 5-Year Strategy
Sts • 5-Year Strategy Finalised
WQM PORTJON OF SEAs
Annual Agency Guidance Issued
Work with States to develop a SEA
Public Meetings Held
SEAs Signed
WORK PROGRAMS ,
fl*o
Agency Appropriation
WPD Work Program Published
States Provide Framwork for Areawlde 208
Work Programs
Assist Grantees Develop Work Programs
Draft Work Programs Due
208 Project Proposals forwarded to HQ
for Revitv
States have A5 days to comment on Areawii
208 Project Proposals
R.O. 45 days to comment on State Work
106 Work Programs Approved/IOC Funds
Obligated
208 Work PcoErafflB Finalized/208 Funds.
Obligated
ASS1STARCF
Draft R.O. Assistance Work PUn
Finalist R.O. Anslstance Work Plan
Implement R.Q. Assistance Work Plan
V /AUJATIOtI
Quarterly Report on Grantee Arti'Itlrs
Pvnl.i.tlon of the Im,,l—.-.t of W1 M .nc
v'JFMA!lJJAS T 0 K D J
1 I
K A M J J A S
-------
Chapter 1
Problem Assessment
INTRODUCTION
How should the task of managing the 106 and 208 grant programs and
the WQM process be approached? Start by asking some questions. What
are the water quality problems? How serious are the problems? Where
are the problems? What are the causes of the problems? A water
quality problem assessment should answer these questions. It is the
first step of the WQM process.
The purpose of the water quality problem assessment is to direct the
WQM program activities. Whatever document is used as the "problem
assessment" it should be used by all Regional personnel. Those
working with States on Five Year Strategies, State/EPA Agreements and
work programs or individuals preparing Regional source control and
funding strategies need a common starting point. A major criterion
for evaluating the activities funded under WQM Program grants is
whether the activities relate to solving either categorical pollutant
problems or severe water quality problems in particular geographical
areas that have been identified in the problem assessment.
A problem assessment identifies, evaluates and prioritizes the water
quality problems. The difference between water quality data and a
problem assessment is the analysis and evaluation of the data that
is in an assessment. The problem assessment should include infor-
mation on whether streams meet or will meet State water quality
standards, goals or their designated uses and the appropriateness of
existing standards and stream classifications. Particularly important
is the assessment of toxics problems and nonpoint sources of pollution
and a determination of the relative projected pollutant loadings
attributable to nonpoint sources versus point sources. The assess-
ment should also discuss current and projected pollutant abatement
schedules as an element in the determination of future problems.
-------
One of the most useful parts of an assessment is the ranking or
prioritization of stream segments especially if the type, location
and severity of the contributing sources of the pollutants are identified,
Prioritization of stream segments or pollutant sources is done to
focus limited resources on solving the most critical water quality
problems first. Ranking the priority stream segments and classification
of lakes simplifies the development of State Five Year Strategies
discussed in the following Chapter. There are many different meth-
odologies for ranking water quality problems. Whatever methodology
is used, Section 303(d) of the Clean Water Act requires priorities
for control actions to take into account the severity of the pollution
and the uses of the water impaired. This requirement may be met by
including such factors as frequency and severity of violations and
the severity of the pollutant problem in terms of population impacted,
need for protecting the quality of the water for drinking, fishing,
recreation, etc. It is recommended that the metholdology used, be
brought before the public for review and comment.
An assessment should also contain an evaluation of the effectiveness
of existing pollution control programs and recommendations for future
modifications to those programs. As implementation of WQM plans,
nonpoint source control and clean lakes programs proceed, this
section of a problem assessment becomes more important. WQM Project
Officers should direct States to evaluate nonpoint source control
as well as point source control programs.
The 305(b) Report (if prepared according to the March, 1979 guidance)
should be used to document the State's water quality problems. It
should include the problem assessment of the State and areawide WQM
Plans. State/EPA Agreements and work programs include an assessment
of the water quality problems as do Regional and/or State environ-
mental profiles. These should be based on and consistent with the
305(b) Report.
The data collection and assessment activities that are eligible for
106 and 208 grants are identified in this Chapter. The Chapter also
discusses the activities that WQM Coordinators and/or Project Officers
should become involved with to ensure the assessments are sufficiently
detailed to serve as a basis for the preparation of State Five Year
Strategies, State/EPA Agreements and work programs or program plans.
Guidance is provided on judging the adequacy of water quality problem
assessments as the basis of WQM Program activities. Exhibit 1-1 is
a matrix showing the roles and responsibilities of Regional Office
personnel for the problem assessment activities. Exhibit 1-2 shows
Regional Office activities in relationship to State and Headquarters
activities.
-------
DOCUMENT CITATIONS
Basic Water Monitoring Program, Revised May, 1978 (EPA 440/9-76-025)
40 CFR 35.1511.1, and 35.1537(d)
Guidance for State 305(b) Report Preparation, March 8, 1979
208 Project Selection Criteria for FY 81. Information Memorandum:
INFO 80-69
POLICY SUMMARY
This section provides a summary of the current policy on funding data
collection and assessment activities out of 106 and 208 grants.
Each State is required by Section 106 of the Clean Water Act to con-
duct monitoring activities for surface and ground waters. The components
of a State ambient water monitoring program are described in the
Basic Water Monitoring Program (BWMP) revised in May, 1978.
A critical criterion for determining the eligibility of assessment
activities for funding is whether the proposed activities build on
existing information. There may be data available that have been
collected through State sponsored special studies and intensive
surveys, or by EPA and other Federal agencies such as the U.S. Geo-
logical Survey, Fish and Wildlife Service, other agencies in the
Department of the Interior, agencies in the Department of Agriculture,
TVA, Bonneville Power Administration or by interstate commissions
etc.. There may never be enough data for some, but limited resources
require a Project Officer to take a hard look before funding additional
data collection activities for the assessment of water quality problems.
Headquarters guidance stresses the need for improved toxics monitoring
capability. There has not been enough emphasis on the identification
of toxics and their transport, fate and impact on our water ways to
control local "hot spots,"
Except where otherwise determined by the Regional Administrator, State
water quality assessment activities are funded primarily by Section
106 grants. Limited amounds of 208 grant funds may be used for
monitoring and sampling if tied to specific 208 projects that lead to
the implementation of controls.
Water quality assessments for water quality standards revision or for
Clean Lakes studies are not eligible for 208 grants. Financial
assistance equal to 70 percent of the cost, up to a maximum of
$100,000, is available under Section 314 of the Act for each State to
classify its publicly-owned fresh water lakes according to trophic
condition and need for restoration or protection.
-------
WQM ASSESSMENT ACTIVITIES
Although the preparation of a problem assessment is primarily a State
activity, EPA does have a role in problem assessments including
monitoring, evaluation and prioritization of toxic problems, supporting
intensive surveys, defining priority data requirements, assisting
States improve the quality of the 305(b) Reports and monitoring
strategies, and providing information from special studies such as
National Urban Runoff Program, groundwater and agriculture monitoring
and evaluation projects.
The 305(b) Report is the primary reporting mechanism for the State
water quality problem assessment. If inadequate as a problem assess-
ment (particularly for toxic and nonpoint source problems), it should
be improved to meet the March, 1979 guidelines.
Although WQM plans, State Five Year Strategies, State/EPA Agreements,
Regional and/or Environmental profiles may contain adequate problem
assessment, States should integrate the various problem assessments
and review data from all relevant sources such as approved WQM plans,
303(e) Basin Plans, Clean Lakes Assessments, Open Dump Inventories
and Surface Impoundment Assessments and incorporate them into a single
water quality problem assessment that can be used as a basis of the
State's WQM program activities. The 305(b) Report is the logical
source to document the water quality problem assessment activities
as the Report is mandated biannually and its preparation is funded
by the 106 grant program. The 106 program plans (see Chapter 4)
should be carefully reviewed to determine whether the State has
included activities that will lead to the improvement of their 305(b)
Report and the State's monitoring program.
Timing
State 305(b) Reports are due to Headquarters April 1 of even numbered
years. Recommendations for modifications in the State's monitoring
strategy and supplemental problem assessment activities need to be
made early in the fiscal year for States to use in preparing the
annual update of their Five Year Strategy, State/EPA Agreements and
work programs for the following fiscal year. Priority Federal data
requirements to be included in the monitoring strategy should be
forwarded to States by February 1.
Coordination with S&A Division on Monitoring Strategies and 305(b) Reports
The most likely areas WQM Coordinators and Project Officers will
need to work with the S&A Division, the Waste Load Allocation (WLA)
Coordinators and the States to improve the State's monitoring strategy
is the identification and assessment of toxics and nonpoint source
pollutant problems.
10
-------
Priority Federal data requirements, suggestions for intensive surveys
and other improvements in the State's monitoring strategy should be
agreed to in the Regional Office and communicated no later than
February 1 to enable the State to adjust its monitoring strategy
for the following fiscal year.
The lead responsibility for working with the States on monitoring
strategy is not critical. It may be the Water Division, the S&A
Division or the activities may be coordinated through a water media
task force. However, it is critical that WQM Coordinators and Project
Officers be knowledgeable of the monitoring activities and get involved
in setting priorities. Are the locations of the Federal as well as the
State's water monitoring stations, the requirements of the Basic Water
Monitoring Program (BWMP), the schedule for compliance surveys, haz-
ardous waste sites investigations, intensive surveys known? Has the
State completed its classification of publicly-owned fresh water lakes?
Intensive surveys are particularly important for construction grants,
toxics and nonpoint source pollutant control. Nonpoint source
intensive surveys do not receive priority ranking in comparison with
intensive surveys for new facilities or permits although nonpoint
source pollutants may be included in wasteload allocation studies.
Priority data needs and recommendations for the location of intensive
survey(s) should be communicated to the S&A Division and/or the water
media task force. Some States require assistance in the design and
conduct of intensive surveys. Work with the S&A Division to ensure
States improve their capability to conduct intensive surveys.
The S&A Division should be involved in the development and review
of 208 funded assessment activities, particularly for quality assurance
controls. They should also be involved in the review of completed
assessments. It may be necessary to resolve inconsistencies among
the various problem assessments. For example, if an areawide WQM
plan identifies nutrients as a major factor in the water quality
problems of particular stream segments and identifies agriculture as
the source, but the State 305(b) Report does not recognize agriculture
as the cause of the nonpoint source pollutant problem, the reasons
for the inconsistency should be identified. In some cases the problem(s)
may be political — the importance of a particular industry such as
agriculture, mining, etc. in the State or in an area. The State's
monitoring strategy should include data that will determine the
cause, the source, the severity and relative impact of any particular
pollutant source on the water quality. The State monitoring strategy
is a key element in setting State priorities. The 106 program
plans should identify activities to improve the 305(b) Report as a
water quality problem assessment. There may also be a need to work
with the S&A Division and the States to improve the analysis in the
Report by providing examples of methodologies to make point versus
nonpoint source impact analyses.
11
-------
Preparation of a Regional Overview of Water Quality Problems
Some Regions have found it useful to summarize the problem assess-
ments of their States and provide an overview of the priority problems.
The Regional Overview of the water quality problems should include
elements other than water quality data. Regional perceptions of the
major water quality management problems should be based on Regional
evaluations of the effectiveness of control programs, institutions,
etc. The Overview is a valuable tool to use in the preparation of
the Regional environmental profile to make the water quality portion
of the profile a more useful document. The Overview is also an
essential component of the Regional source control and funding
strategies. It provides the justification for allocating limited
resources to priority problems.
GUIDELINES FOR JUDGING THE ADEQUACY OF A PROBLEM ASSESSMENT
This section lists criteria to determine the adequacy of the water
quality problem assessment as a guide for WQM program activities.
To assist the reader, Figure 1 should be used in conjunction with
this section to determine what needs to be done if there are
deficiencies found in the assessment.
You will want to determine if the water quality problem assessment:
• Includes information from other assessments including 303(e)
Basin Plans, WQM Plans, Clean Lakes classification, Open
Dump Inventories, Surface Impoundments Assessments, special
studies, intensive surveys.
• Contains data adequate to determine the full range of
pollutant problems including the data elements identified in
the Basic Water Monitoring Program, guidance on priority
Federal data requirements, toxics.
• Identifies the nature and severity of water quality problems
for each segment.
• Compares the water quality of each segment to the State's
water quality standards/goals for that segment and identifies
the uses impaired.
• Identifies groundwater problems and the probable cause(s).
• Identifies the source(s) of the pollutant problems.
• Identifies nonpoint pollutant sources and estimates the
relative loadings of nonpoint source pollutants to point
source pollutants.
• Identifies the priority of the segments based on the severity
of the pollution and the uses of the water impaired including
the population impacted and the need for protecting the
quality of the water for drinking, recreation, fish, etc.
12
-------
»
o
a. co
It rf
CO B
H- rt
oo re
3 9
< B
H- 3
re oo
S It
H- »
3
OQ 3
re
pi O
it
en co
rt co
pi 01
rf 11
re^
Co rt
O
eo 3-
0) PI
a <
CO It
i B
S o — I
n S
•O PJ
)-• O
o it e
re rt >
HI re H
H- M PI
o *<
SB 7>
a. o
n re 03
re c H
rt
o) re ;>
§ Tl M
P O CO
°" fjj ^
o* re M
H
3 B »
O 01
it re
Pu CO
», i
3 re
sg
re
0 3
rt o
re rt
o>
p re
o
rt HI
H- re
O B
B co
0) H-
a1
H- H-
3 re
D
i-1 *!
e P-
O- rt
re s-
O. H-
3
h- re
o
00 Hi
01 B
a B
re
12. ~
I-* O
pi Hi
•
2.0
c! CD
n t— '
re CD
en
rt
tu
3
o*
^
03
"
1
O W >^ * > !>T3>H-:>!>S>.OHCOH n H- > O
oeo c H- n F) n R o. R H ,3 R HI o. re co o s H n
3 rtrtre reoititreiDcoit (too 3nre B
rtltC3" a" 3 — -OBBrt rtH' HI
KHil id 'UH^'QrfOQrtQ.toHrfreEJ' BCO rt
oHirooH H>reOH-iiorereoH-3it H-O.H
Mre rtH- H-BH-HiOXcoOocTHirril BltEJ* *e
n H- 3d o oeoSH-pH-H-Br-'H- re ,o.re H
13 rr & n n n rtresoooitreoo _o. ~^*-o H o
.""5 ^j"° Si"^ rr 4 ~° "i 9- "'^ ••* 3
H*OO rev o^ B h1* 4 i ' 4 re v i
H 3' rt core re33 r
.^ *_* to -<. QJ rr
3^ - B rta 01 rtj . pi A rr- B^. H
•^ — H< rf en f — .0 Hf — CO CO^ ' B* CO* 8
to-re ocore 01 3
Srecococo corto reioo.n c
H- OQ H* n
co re H-3ti3g HiB3eo>
COCOH»COO COHl'O ftps Or*(t CO CO
O.COO ltH*O 'OH'X^J HiO3 U B CO
(tO(lB3 rtltH- tlHiltB Brf S3 rt> ID
1 rt -- DO
o re i » oo
cr s re H"<
>-" O CO
@H- O o rt
re M HI o
CO cr
m fe rt
?>
en co fli
re H* rt
co co re
01 rt
S CD ^
re a 1
CD rt
rr O
O 1
p.
H* 3
rt
OQ n
n o
tu OQ
rr if
re to
a
w
3 H 03
•" rt > B g
^O rt g
H- O
S W B
oo n re s
re tO &*
».co <
rt H
c
i w 11 re
ft 3 •"
re B re M
OQ 0 3
"< 3 rt
1 n
-------
• Identifies and ranks categorical pollutant problems as well
as identifies geographical areas where problems are concentrated.
• Identifies and ranks pollutant problems or segments consistent
with other analyses or problem assessments such as WQM plans,
Five Year Strategies, State/EPA Agreements Headquarters
ranking of toxic "hot spots."
• Identifies future water quality problems.
• Evaluates the effectiveness of existing control programs.
14
-------
h- '
(D
OQ
H-
O
Pi
I— *
o
HI
n
re
o
H
00
{5
N
rf
O
3
1-1
M
00
re
3
CO
a
H-
Ftl
re
V*
rt
3"
ro
Ft
re
Ftl
o
FI
re
(—•
JP
(a
&*
n
re
CO
T3
O
3
CO
H-
a-
rf
re
CO
s
3
O
rf
re
n
F-l
rt
0)
""
rf
Pi
ft
| S. O | 50
F* O rt re
CO 3 ft CO
H- -a
o a t— o
3 F* Hi 3
Ft CO
ro f?» F*
o o-
rf 01 r*
O CO t-'
n F*
Oi rt
"O ^
•o
1
0
Ft
01
rf
ft
SI £ cnlo
re 0,3 o S if
rt ^3 3 1 3 > 1
n cn
rt 33 •« I 0
n ft . . M
o o O O Cn so
03". « C Q
n • 3 •« 1 >
0. • CO <
H- cn -•
O FH Ft O 0>
Ft O. CTv 3
co 1 H- n
• 3 if re
PS B
S! 3 rr M B>
P < O 0
> F* tt 00 S»
Ft CO 3
C*) O ^d to
§i 3^
tt rt (-(. ga
o. 3 re H-
F* rt O a
SB rt
B M
rf O
o cn HI
tt O Ht
» re o
3 (t
rt Ft
H. a
CO
rf
9)
o o
O G rt re ho re
O cn y rt o 3*
PS o re n >— rt
f
**i ^d ^
e ft o FI
cn a. so o
O ft > 30
M Ft . fj.
f fa QJ
r- S! S
H a
<> rt O
> ro n> HI
• ft ft Hi
3 H-
PS o cn o
OF* C (I
> re -a o
F-- 1
' 1 > ro
3 £
n
ro 3
o
r1 3
re H-
rt rt
rf o
re «
1 H-
3
00
Cn
trategy
00
01
F*
3
CO
rt
*
*
1
H
§
3C
H
1
C/j
TRATEGY
S >
3 CO
3 CO
-1* F4*
-t co
3 rt
1
-"• r1*
3 3
0
n
> o
ordin
rft v1
-^ rt
t H-
o 3
00
01
3
o.
M
3
rt
ft
00
n
pi
rr
F*
3
00
*
*
ro
F*
ro
t-1
re
rt
H
ro
11
s.
rf
3"
cn
rt
01
rt
ro
00
ro
3
O
*
*
cn
cn
M
cn
O
M
W
o
PS
Pi
s
Tj
1
M
H
O
yo
M
a
n
cn
?a
o
PS
o
F<
> "13
ro rt
re ro
3 -0
0 P>
< i
re
01
3
a.
cn
re
3
a.
o
C
idance
f
ro
rf
rt
re
n
rt
O
cn
rt
Eu
rt
re
*
*
*
g'g
3 co
H. n
rt C
O CO
1 CO
H-
3 pa
oo rt
00
cn H-
onal
trate
oo cn
X C
00
s; oo
H- ft
rt co
31 rr
F*
cn o
rf 3
01 CO
rr
re HI
O
> 1
00
re
3
n
\
*
333
re re re
01 re re
3 O. rf
co re
a* £
O F*
Hi ^^ rt
M 3*
3 3
re rt cn
ro re i?1
rt 3 >
H* CO
3 H- pi
ro < 3
re a.
Er cn o
etermin
urveys)
ese Nee
a. re
CO 01
3 3
O, o
3
hrj H'
0 rt
CO O
CO Fl
H* H*
CT 3
MOO
re
*
\
> w
n re
rt r>
H- O
< d
H- ro
rt
re pi
co g
H-
F*
01
F<
(-*•
rt
cn
rt
pi
rt
re
O
3
FJ«
rt
O
H
H-
3
00
*
\
I
H-
fD
^
P
T3
•a
H
O
X)
l_l.
01
rt
re
F)
o
a-
^
CO
n
(D
cn
CO
g
ro
fl
rt
cn
*
\
*
o
pl
pi
I
i
h- 1
H
O
M
O
STRATEG
*!
O
f-<
o
^
o
i
s\\\
1
1
1
«l
H
2
*
o
a
b 3
m
cn H s;
IP*
O >TJ O
Fq O 3
o pa pa
PI >
cn 3
> >*j o
W f
cn
c
a
E
2
CO
:s.
z
CO
t—
W
cn
PS
"0
o
a
o
O H
PS M
n 3
M
CH O
PS
W
i
pa
O
•z
o
w
cn
§
s
cn
CO
S
15
-------
if?
^ ^
fD €
rl 3
r^
D D*
2
Assessment of Re
alitv Problems t
0 09
P-
n o
1 B
D
t n
t p.
D O
n 11
p-
rt
v^
e
5 *
*
00
D 0
-»oa
H. o
^ H*
•< P-
ate all States P
Problems and Pri
O 1
i p-
p- o
rt 1
* P*
1 rt
D *-<
^
p>
rt
(D
n
I
i *
*
c/>
5
§
V
hf
P-
N
e State Problems
*
oa
E>
CO
H
CO
H
CO
TATE AGENCY DEVE
f
§
LO
O
Ui
s~^
cT
W
w
^d
o
co O
rt p.
B> en
rt o
(D C
CO
> CO
TO
Sw
0
O Ln
cr
•a
o
rt
(D
"8
f\
Pi
rt
P-
O
3
^1
P-
rt
•y
*
*
O P*
n co
O
U> c
O CO
O1 CO
/••v
Information and
b) Report
;>
P>
P-I
CO
p-
tt>
^
0)
It
CX
CO
CO
> <
"b \
^
*
*
£
(-(
<*
Co
r^
a.
305(b) Report Gu
p-
ex
3
ID
If
O
CO
rt
(D
rt
(D
*
*
§i?
a. <
^ it
ID
CXTO
It
0 3
o- n
o x
B rt
It O
"i?
pa co
ID O
CO M
0 <
M (t
c
Si?
O TO
3 h*»
CO O
3
CO
*
*
co a
rt n>
1 HI
CO H-
rt 3
ID (t
TO
X M
Regions Concerns
5j
rt
3-
c?
D
p.
rt
O
p.
3
TO
*
X-
^X
SSxys
\ \ \.
\\v\
s\\N
\\\
«
i^
w
\v
xV
ACTIVITY
O
o
hd£
b 3
•
CD
co H S
H M.O
> 0 2
3*
o^o
2 ^ ti
M S S
o w pa
CA §
I> ^d O
C^ PJ *~3
PI O ffi
2 P3 W
o pa pa
M ^
Pi F"
CO
"a
H
H
O
CO
M
CO
o
Z
CO
^
c-1
PI
CO
P)
8
z
o
§
O 0
i
i
55
pa
1
M
s
93
M
W
M
H
1
H
M
., 16
-------
EXHIBIT 1-2
SUMMARY: PROBLEM ASSESSMENT ACTIVITIES
g
C/3
3
u
o
PS
PM
Q
O
M
O
H
M
1
0
s
a
1S
SM
o>
ss
u
0
w —
H
cno
MM
MH
MpS
>3
Md,
HW
OoJ
0
MDZ
WMH
<3 S M
JE;HJQ
o w
§
ZH
0<
Mod
HO
<^M
SMZ
PSQM
OS
OOP
OHUp
owz
HQ
ZK
§«•
• E3P-4
UW
OPu
o
gen
ZH
4t «H 4»
01 «H: e«H
(-1 4J 4J O-H *0 iJ *•"
CO-H-H •• O i-i CU m 4-1
O O O cC rfl Ci-t OoS
^ d T3 0 3 C ^-0
3S'wt»;ovio"oe!
> -H >p 01 tO*J rt t< 4!
h o w 3
P4(4-< CO CO • • •
1 CO
co o at
0) P-H
4J P.O
co ac
4J en co a)
t« 4) CO
•H e to
-CJ 0
« C M^t
O 00 14
00 4-J-u
tUt-H d 41
o
4J O C! Ot
CO £,£> V-i
< CO O P,
(0
1 a>
•H 4J 1-1
T3-H OJ
M > 4J
O-H 4J CO 4J
O 4J *J > C
O O «) W
C & C 4)
•HM-i -H U
O *O^i ^i
4-» -H C OWO
•H OX O 1* CSS
< CO 3
*J
8.
CD
^^
m
o
en
0
£
au
OJ 00
' O) 4-1 C
pi CO CO*H
/-x a* o eo
••^ OOH-H 00
in el en c o
O O cd O ^
V
r-l r-( CO O
1 aj «JJJ C cu
O P O O (Ot- 3 cu c
o u ocatv-* 4J to4J^^c3n^c
OOCiJC OliH 3 OO1) COSJCJ^CJ W
0) O —sV-^lt, dtnOrH4.J(-itJC3r-CH^-1-f
13 C -H -H E^-' O-, O ffi 4J ,'ii -H -i -< «4-' iH T1 VJ CJ O cC -H
>'Ura>oUot-'i- -H CO — * 4> 1j
4)-HT3 OUO C '2
*-t co X encoM «
CU CO C
6
O
>H M
CJ
O <0
CO CO
C CU
tfl C"O
•H O>
CO flJP4
OJ 4J
B) O4J
4J <0
CO (O-H CD
41 M 41
cn a o o
•H C 1- C
CO 41 CXOJ
|
g* en cu
a en >
T-1J2 C*J | OJ -H
aia!(J KrHC
-r4 m to -H !-< 4J a c
•4-I4J "O- 3CQJ-H
TD O C W CO P-Cn O &.
d QJCcne Ecn-
g-HWp.cn oiptn-HflJ
O4J<1) 0)d-HO4J-O>
0* J-i W O* CO P- O E CJ 4J 3
piOQtO££>J O4~i-H g into
& ffSp
eo 4J t^ o
CO 3 CO 004J
4J ^ J- O-H
•^5 C fl) 4J i-i C
OJ _j yj CO P. O
w e co o E
O CO M CO )-JtM
P. 4J O (0 0) O O
41 m u-i «H >H s
pi en co >,?*,
x-v OJ-P C B) CU
& VJ-H aj « 3 4J
>^ at > co a.) cr co
inji cu n)<: at )-i
cno^QJcnaK «
^
0
. !, CS
at en M o C
w C P. o
ts cu eo o
JD aj V) co
O tJ C PvH
P.OJ 01 X
3 C n o
4) XC 4J
•H 4-1 o m
iJrH-H CU 4J tO
> 3 C-H 4J O
O crpj <4-i co ,-(
. ««
cti c P a c
^ QJ O > CO
a, cj M « en to 4J
4J&--H c en c:
cc 3 o at J-i to 3 c 3 U
oa,"3 W-HCT ^
V-i
SDIJdO 1VNOI03H
VI
9
•• tn t«
X 4)
•H 0 ,J
3d EO
o
at oo in
4-»< O
cd v-/
C-H
-H Cfl -^ MX" *
*O CJ C5 C/l 4J
0
o . « . .
to
CO 4-1
I aj d
nH^H CU
•a cj 6
j-i d co
O 4) CO
o boa?
cj nj to
•**. «
Crd CO
O 4-»
•H-H 00
4-j is d
CC -H
i-j d i-1
&OO <0
OI-H PH
4-) 4-1 01
d « ^
M C P.
*
>, to *
00 4-i 4J "It
a; c u cn g n a
01 *j<—* a> co at a> cu 01 a> CO-H coo*X
•H env_x nj a) UtoCeflefldO 4J
•^•H iJ u-1 C CC E W C-H ^ 4J
P.)J 4> OJ >O (0 CO 3 4) CO CO 60O
f-i 4-) r3 (j W>H CM co 41 13 en cu -H-H eo
CJ-HP-Ofl'r—iE aJC-HC*-'> *O^!
O E P-i OS t--< DV^ S(J O4J P. E (0 CO HC
1 | ^t | o cnat
3 -^ CO o-^. >>o
i-i 4J o 4>*u a> c
CJ 13 t-Bj
CrH -.-H *fl O d >-.-H 60 (0 d 3 CO
OQ)t/l entdej cat/i CJCO-H-H o* ^
J-i CO
„ «^8SS
17
-------
Chapter 2
Strategies
INTRODUCTION
Long term strategies are an essential component of the WQM program.
A strategy outlines the approach to be used to solve priority water
quality problems. It defines not only what needs to be done but also
how it will be done.
The development of a strategy is a culmination of a process which
focuses on defining what is to be accomplished each year to solve the
water quality problems. Goals, objectives and priorities are set
and a cohesive sequence of activities are outlined that maximize
the use of resources to develop and implement programs to solve the
water quality problems.
Strategies take time, imagination and discipline to complete. However
once completed, strategies expedite the processes necessary to solve
priority WQM problems. A strategy shows that an agency is in control,
knows what needs to be done and how it will get done. There is no
more effective document than a strategy in selling the WQM program
to top management and legislators.
Every year, in January, Headquarters publishes its WQM Five Year
Strategy to assist Regions, States, and areawide agencies and the
participating public with program planning. The Strategy is the
document that directs the development of WPD's work program, sets
program and budget priorities and justifies to Congress, OMB, and the
public that the WQM program has direction, is developing solutions
to complex water quality problems, and is solving the problem.
19
-------
Regional Offices should prepare nonpoint source control and funding
strategies to set priorities for the funding of activities and to
ensure effective control programs are developed, implemented, and
administered. The content of these strategies is discussed later in
the Chapter.
States are to prepare and annually update (usually by March) a
strategy for controlling water pollution problems from point and non-
point sources. Strategies are to emphasize solving particular
pollutant problems in specific geographic locations. They are also
to address how the programs are to be managed. Activities funded
with 208, 106 and 314 grants — such as planning, implementation,
monitoring, permitting, enforcement, and administration — should be
explained in terms of how these activities contribute to the solutions
of priority water quality problems. The purpose of the State Five
Year Strategy is to direct the preparation of work programs and
program plans.
The Strategy Chapter lists the documents and policies which should
be consulted, the content of a State Five Year Strategy, Regional
Office involvement in the development of State Five Year Strategies,
and the development of Regional Office nonpoint source control and
funding strategies.
Exhibit 2-1 presents in matrix form the activities of the Regional
Office in the development of State Five Year Strategies and Regional
nonpoint source control and funding strategies. Exhibit 2-2 shows
the relationship of Regional Office activities to those of Head-
quarters and the States.
DOCUMENT CITATIONS
40 CFR 35.1511-2
Supplemental Water Quality Management Program Guidance for FY 81,
June, 1980
National Urban Runoff Program, November, 1978
Agriculture Nonpoint Source Strategy, October, 1979
Water Quality Mangement Ground Water Stragegy, April, 1980 (Draft)
POLICY SUMMARY
The policy summary for State Five Year Strategies is excerpted from
40 CFR 35.1511-2.
20
-------
§35.1511-2 SUte strategy.
(a) General. The Slate shall prepare
and annually update as an activity
under its work program a strategy for
controlling water pollution problems
from point and nonpomt sources. The
strategy delineates priority water
quality problems (in relation to the
seriousness of pollution) and activities
to control these problems in a five-year
time frame. The strategy shall address
the problems, solutions and priorities in
certified and approved WQM plans;
other problems identified in the
assessment process; and needs
identified during management agency
performance evaluation. The strategy
may be used to recommend revisions in
WQM plans, and may be used to
establish priorities for plan revision
activities of areawide agencies. The
strategy shall include:
(1) Coals for a five-year period, and
estmated costs of activities to control
priority water quality problems;
(2) An identification of governmental
entities expected to be responsible for
conducting the activities; and
(3) A summary of anticipated Federal
and other funds for the strategy period.
(b) Role of areawide agencies. Since
the State strategy is used in the Regional
Administrator's review and approval of
the areawide agency's work program
(see 5 35.1513-7). the State shall involve
each affected areawide agency in
development of the strategy, and shall
consider priorities suggested by the
areawide agency. The State shall
forward a summary of areawide
participation and State response to
comments received from areawide
-agencies to EPA with the strategy.
(c) Submission, Each year, the
strategy should be submitted to the
Regional Administrator for review and
comment in time to provide guidance in
work program development and
assistance in negotiating the State/EPA
Agreement. ^~
(d) Integrated strategy. An integrated
strategy covering more than one EPA
program submitted under the State/EPA
Agreement may be used, if the Regional
Administrator determines the integrated
strategy meets the requirements of this
section.
FIVE YEAR STRATEGY CONTENT
The content and format of a Five Year Strategy will vary depending on
whether the Regional Administrator and/or the State wants to develop
a comprehensive, integrated strategy and include the drinking water
and solid waste programs in addition to the 208, 106, 201, 205(g)
and 314 grant programs. At a minimum, State Five Year Strategies
are to include:
• An assessment and prioritization of the State's
Water Quality problems:
- The assessment should be consistent with the
problem assessment described in the previous
chapter. The methodology used to select the
priorities is critical. The selection of
priorities should result from a number of
different considerations including: the rank-
ing of stream segments and/or categorical
pollutant problems based on the severity of
violations; severity of the pollutant impact
on public health and the environment; class-
ification of publicly-owned fresh water lakes
accorded to trophic condition; recommendations
of certified and approved WQM Plans (including
21
-------
those of areawide agencies); evaluations of
operational programs and management agencies'
performance; concerns expressed by the public
and local governments; Headquarters annual
program guidance; and the legislative mandates
of the Clean Water Act.
- The priorities should be identified as speci-
fically as possible. For example, the priority
pollutant problems may be identified in terms of
a stream segment, lake, geographical area or
for categorical pollutant problems (agriculture,
urban runoff) where the impacts may be localized
but occur in several areas of the State, the
areas should be ennumerated to the extent possible.
• Goals and objectives of the Five Year Strategy:
The goals of the State Stragegy are to be compatible
with the goals of the Clean Water Act and include the
achievement of water quality standards or designated
uses wherever attainable. The objectives should be
more specific. What is the State to accomplish over
the next five years — develop a state cost share
program? Reduce agriculture nonpoint soure pollutant
loadings to the stream by 60 percent? Eliminate toxic
discharges to the stream? The objectives set out what
the State is to accomplish and therefore direct pro-
gram grant activities. Without clearly defined
objectives set forth in a five year strategy, work
program activities lack purpose or direction.
• A discussion of the program activities:
- How are the problems to be solved? What
approach is to be taken and why? This is
an essential component of the strategy.
The approach is the link between the
objectives and the program activities. Is
the approach to include revision of the
water quality standards, development of
regulatory or voluntary control programs
or, an evaluation of existing control
programs? The question you will need to
ask is whether the approach is logical and
appropriate given the nature and extent of
the problem.
- Program activities should relate directly
to the priority problems and be discussed
along program lines. For example, how will
planning, permitting, enforcement, and
22
-------
administration relate to urban runoff,
agriculture or industrial point source
problems? This is also applicable to
geographical priorities. Major sources
of the pollutant problems (agricultural,
urban runoff, etc.) may be identified for
the particular stream segment, publicly-
owned fresh water lake or geographical area;
the approach is defined and then program
activities are tied to the development, imple-
mentation, administration of any number of
control programs necessary to solve the water
quality problems in that stream segment, lake
or geographic area.
The existence of or the need for additional
programs and control measures and how the
various control measures and programs will
be used together is another component of
the strategy. Control programs for point
and nonpoint sources include administration
and enforcement of the NPDES and 404 programs,
pretreatment programs, administration of the
construction grants program, facilities
operation and maintenance, training, agri-
culture cost share programs, construction,
permitting and on-site disposal inspection
and licensing programs are but a few of
the programs States may use or develop to
control priority problems. Proposed or
existing control measures should be des-
cribed in connection with the control
programs in the strategy and may include
BMPs, Regional facility planning, permits,
emergency response programs, Clean Lakes
projects, user charges and other techniques
and/or programs.
The planning section of the Strategy should
address those problems not covered in the
initial WQM plans or, based upon an
evaluation of the implementation of the WQM
plan other problems which are identified.
The big question is whether additional
planning is really needed or whether all the
necessary controls are available and only
administrative procedures need to be
developed? If additional planning is
essential, the Strategy should propose pro-
jects for funding and show how the Infor-
mation from the projects will be used to
23
-------
develop comprehensive control programs. Up-
dated WQM plans will need to be taken
through the certification and approval
process.
- The Strategy should identify the agencies
responsible for completing the activities
or carrying out the program. It is important
for State strategies to incorporate the
priorities of areawide agencies and identify
areawide agency activities in terms of con-
trolling a categorical and/or geographical
pollutant problem. Many programs require
the cooperation of State, county, municipal,
or Federal agencies. For example, an area-
wide planning agency may conduct monitoring
and develop controls for on-site disposal
programs; the State develops legislation to
regulate on-site disposal systems; country
governments enforce the program; and State
and counties cooperatively develop methods
of financing the control programs. Other
examples are Clean Lakes projects where
municipal treatment requirements and NPDES
permits must be in place and nonpoint source
controls (BMPs) identified consistent with
the WQM plan prior to receiving section
314 phase I or phase II awards. To assist
land owners implement the BMPs USDA cost
share and technical assistance programs need
to be focused on priority watersheds or lakes.
- The Strategy should identify the cost of the
activities and the year the costs and activities
will occur. Cost information should include
the amounts to be obtained from 106, 201,
205(g), 208 and 314 grants as well as State,
local and other Federal sources. Most States
find the matrix format the simplist, most
easily understood way of presenting the infor-
mation.
- Where possible, alternative approaches and
different levels of effort should be identified
and analyzed in terms of the impact on resources,
and the timing of anticipated results.
Public Participation
The public participation requirements for the Five
Year Strategy can be met by combining the public
participation activities of the Five Year Stragegy
24
-------
with those of the State/EPA Agreements and work
programs. It is important to remember that the
public advisory groups required under 40 CFR
35.1507 of our regulations should be involved in
the early stages of developing the strategies.
REGIONAL OFFICE INVOLVEMENT IN THE DEVELOPMENT OF
STATE FIVE YEAR STRATEGIES
This section of the Chapter describes the timing and activities of the
Regional Office in the development of State Five Year Strategies and
how the Regional Office should review the strategies.
The amount of time, direction and assistance Regional Offices need to
provide States in the development of a Five Year Strategy will depend
on a number of factors including:
• whether States have previously developed strategies in con-
junction with both 106 and 208 grant programs;
• the quality of previous State strategies;
• whether new program initiatives are necessitated by changes
in program emphasis (e.g., completion of control programs
for agriculture and initiation of urban runoff program
planning; or initiation of a toxic monitoring program);
• whether Regional source control and/or funding strategies
have been developed and are accepted by the States; and
• whether the Regional Administrator requires State WQM Strategies
integrated with drinking water and solid waste strategies;
the number of State agencies involved; and their relationship
to one another.
Timing
Annual State Five Year Strategies are to be used as a basis of 208
work programs and 106 programs plans. Depending on Regional Office
policy, the State Five Year Strategy may be included or referenced
in the State/EPA Agreement. Five Year Strategies should therefore
be completed no later than the end of the second quarter of the fiscal
year (March, 1980 for FY 1981).
Prepare Guidance Letter
Based on a review of State water quality problem assessments, the
Regional Overview of the priority water quality mangement problems
and/or the Regional nonpoint source control strategy, there may be
elements that the Region wants included in all State strategies such
as the development of State agriculture cost share programs, con-
struction runoff regulatory programs or toxic monitoring programs.
25
-------
To save time and energy and frustrations later on, early in the
process, Regional suggestions for the development of the strategy
should be discussed with the State. Even for States that have not
yet developed a WQM Strategy, it is not as formidable a project as
might be expected. All States participated in the Needs Survey.
Without much additional effort the State can develop an initial WQM
Strategy. Other States found the Needs Survey so valuable that they
are designing their Five Year Strategy around the Needs Survey.
Following the initial discussions on the Strategy, a guidance letter
should be sent to the State outlining Regional Office expectations
for the Five Year Strategy including the priority problems to be
addressed. The Region's procedural guidance such as formatting,
the timing of draft and final submittals, and review procedures, etc.,
should be included in the guidance letter.
Assist States Prepare Strategy
An area Project Officer should be actively involved in assiting a
State develop its Strategy is in seeking commitments from and defining
the roles of other Federal agencies. Another area Project Officers
may need to assist is in reconciling areawide and State priorities.
Regulations require States to incorporate the priorities of areawide
agencies into their Five Year Strategy and to the extent possible
this should be done.
Review of State Five Year Strategies
Figure 2-1 (page 26) outlines the questions Project Officers should
think about in reviewing a State's Five Year Strategy. Without
getting bogged down in too much detail, remember the purpose of a
Five Year Strategy is to provide a framework for solving priority
water quality problems and show how the pieces fit together. If
after reading the Strategy you think the State is in control, knows
where it is going and has outlined a logical approach and sequence
of activities to solve the priority water quality problems, it probably
is a good strategy.
The State Five Year Strategy should come as no surprise to the Project
Officer. However, there may be areas of the Strategy which need to
be strengthened. The Project Officer and the State need to work
together to revise and strengthen the document. The strategy should
be reviewed by appropriate Regional Office personnel. It is the
State's "best shot" and should be factored into the program plans of
the Regional Office.
Some Regions incorporate the strategy into the State/EPA Agreements;
others, reference the document. Whichever approach is used, the State
Five Year Strategy is to direct the development of WQM work programs
and program plans.
26
-------
en 60
p cd
M cd C
cd cu cd
4»4 a
>< cu
oo -d o
CU G CU G C-
>iH o cd cd
i-HJ a 4J
(^ cd cd ,
O C 60
0 0 >-, tu
T-l 00 4J
cu 4-1 cu cd
CJ CO 4-1 H
p 4J cd 4-1
3 >>-kj P CO
O 00 0)4-1
en cu exen cu
4J !«! to
co cd o) P 1-1
v l-i cd >
1
CJ
T »-i
J. >
§
cu
3 B
S &
CM
w
5g
£
M
C,
H
fn
O4J C
^
i
c
4
C
1
4
CJ
1
C
(
<
•r
[1
4.
K.
C
:
C
"3
^ 3
•a. -a
> co 4 .
S cd ^
k
^
Q
UH
to >-,
C 00
O CU
1-1 4J
4J Cd
cd P
4-> 4J
oco
0)
^ cd
01 CU
>-l
or
0- 60
J-* C
CU 1-1
CO 4J _
CJ 5* —
to cu c-
CU rH T3 C-
i-H CO
O CU
COiH
CU CJ
P C
CU
O4-1
4-1 CO
•H
0) CO
co C
•H O
> u
c
4
a
c
c.
a
c.
t
c:
a
C
ft
)
>
1
i
4 CO
5 CU
)iH
3 00
CU
> 4-1
1 cd
CU 4-1
T
1-
K
^
C
t
p.
ri
a
^
t
Cl
) CO
<
•rH
> O
4J
k
f
'5
ik
>
6
a
4.
CI
4-
r~
c
(.
4-
c
-, c
0 c.
J
i a
c.
1-
r
)
)
)
1
cn o >*
CO 00
0
cu
CO O 11^
IS
a
p
i
i e-
i CO
P 4-1 C
J Cl IH C
c
I 4
p
4J
to
0
o e
4J CO CO CU O rH CX 1-
1 -H CO T3 .C iH Cd 8 4.
_. H M OI DC.
O O I-l r-l C
>> 1-1 14-1 -a cj c
) p
J cx T:
> 0
1-
>-
> a >-. cd -H a. 4J M-I
J 00 O,i-
d oiocococdoi4-
* > r-l 0) CU
1 4-1 t> 4J 4-1 Ct
O O i-l i-l C,
-i CU fi I-l l-i i-
T
T
c_
_J
^»
60
cu
4-1
cd
p
4J
en^
01
co
•H
^
S
CO
e -a
en rV
•H H x>
5 C -H ^
3 cd 3
•H
4-1
CJ
cd
O
CU 1
4J 4
^
cd
s^
1
in
>-,
30 P
V 0
T)
-1 •
J CX
cd en X >-,
d cu oo
•^
u cu
•O CO O 4J
p .H erf cd
o
> p
O 0) O 4-1
cj «! t-ien
' ^ ^^ ^
, % >
a
o
1 O 4J Cd CJ
J CU Cd CO CU iH JB
H a X a
3 4J 1-
) rH r-
J
H 4-1
3 T<
3 3
CJ M-l 0) > 4-1
O tO iH 1-
4-1 0) Cl M-l 4-
4-1 C
rH T.
) eu i-
< p
CC
0
1—
01 oi Gc"
I *d T3 CU CO
> cd -He" CJ 3 3 4J C
«" e
co a
e v
3 4J C 60
; cu tu T
4 C T34J C
c« o e
!•« C c
CU iH T
JC" iH-H
3 >-, C04J
HP e cd
j T-14J o ooo cop-cd o .-H cd cd-H . cd O4J
-1 VO~VB "» M T rl^rH ""rCU " *1-l CU ' *O> 00 ^CU CO"^4J *CO 4J » 4J i-l"r 60 * 60 £5 Cl
cv. C^ CX
u • cd oo'" f f ci
> to Jf 0) rH i-H
-1 i-H CUiH » N 0
H Cd K 4-1 4-> 4-1 V
•H 4-
C3 i-
O^_i-
4 Gy td 0) CO «
)4J_ 11) Q
\) 3^ XD
1—4-13- lHlH>- 4Jp'~4-)Cd S >"lH >-Or!'"4JC">.4JCO'"6bj<
•H >i-H iH O, iHrH P O- O 4J O O CdOO Cd CUCU
)C" > T-
H iH 4-
>
a T-
t
rH 1-
> CX OTJ fl 3
4 MH CU 0) O 1-
T3 ti ^^ 1
iH 4JCN 4.
-i eu 4J
j co cdO
o CD T-I cd cd a> tu 4J o cd 4-10 4->x a 4-1 oo cd co coed HEX!
J 60 X w 2 B XrH O cd P o M OO" 1-1 P cd >, (UP
-1 4-1 O 4-l.Q cd 60 0)4-1 cflS O P >->3 CO CO CX COf
d CUiHCU 0) O CUO C OIO.CUP U CUvO 0) to 4J
•4 P co p p p a
r
3 P O r
i cx o <
P C
ex c
o c:
CJ C
3 O £ 0) p cd Cl
3 0 oo e
1 0 QrH C
3 01 CO-rl
r*
o
M
2
H
w
*2
M
p
*s
t" H
Cu
w
FH
o*
' w
5
T
4-1 CO
G G
01 O
CO 4-1
co cd
cu 3
CO T-l
co cd
W CO
CU "P
rH CO CU
r° C O
o cd c
PT-H o
4-1
CU
cu
cu
S5
27
-------
REGIONAL NFS SOURCE CONTROL AND FUNDING STRATEGIES
A Regional NFS source control and funding strategy is the primary
management tool for Regional Offices to focus limited grant funds
and personnel on solving the most significant problems in those areas
where water quality is most adversely affected. Regional agriculture
NFS control strategies are required, but, other nonpoint source
pollutant problems such as groundwater, on-site systems, etc., would
benefit from the development of Regional strategies and the identi-
fication of a cohesive sequence of activities that lead to the
implementation of control programs. Preparation of funding strategies
in conjunction with NFS control strategies will maximize the use of
limited resources and provide the rationale necessary to make the
difficult funding decisions.
The content and format of the strategy will vary depending on the
type of strategy (agriculture, groundwater, on-site disposal, urban
runoff) and the magnitude of the effort necessary to develop operational
control programs.
Define the Pollutant Source and Scope of the Strategy
The first step in the development of a strategy is to define the
problem. The Regional overview of the priority water quality manage-
ment problems is a start. Is agriculture, for example, the major
source of the Region's nonpoint source pollutant problems? What is
the magnitude and extent of the problem? What are the beneficial
uses precluded because of the pollutants? What are the pollutants-
sediment, nutrients (fertilizers, animal wastes), pesticides?
The next step is a survey of the State programs to determine what is
required to have fully operational programs implemented. The questions
that should be asked are:
• Do the State programs address all or only part of the
pollutant problems (e.g., sediment, when water quality data
indicate that nutrient and potentially pesticides are also
contributing to the water quality problems)?
• Do the States have a strategy and a logical sequence of
activities identified which will lead to fully operational
control programs?
• Have the States and/or Regional Offices evaluated the
operational control programs, management agencies, BMPs?
• What type of control programs are in place or proposed —
regulatory or nonregulatory?
• Are, or should national controls, e.g., TSCA be used to
control the problem.
• Are the States' approaches (such as a nonregulatory programs)
working?
28
-------
• Are there backup legal authorities if the nonregulatory
approach fails to ensure compliance?
• Are the BMPs identified in the WQM plan being applied?
• Are there adequate information/education/technical assistance
programs?
• Have financial management aspects been considered? What
arrangements are available, or have been made, to support
the management/administration of the programs (i.e., State
financing for conservation district staff)? Do the States
have, or are they working toward developing cost share
programs of their own?
• Are other appropriate agencies, Federal/State/local/private
programs acting on the priority problem areas? Is there
technical assistance support?
• Are there candidates for prototype projects (FMAP, ground-
water, RCWP, silviculture, agriculture, monitoring and
evaluation, or Clean Lakes projects)?
• Are there critical elements necessary for fully operational
control programs common to all the States in the Regions?
An important factor to keep in mind when surveying a State program is
the political and institutional climate. The manner in which a non-
point source control program was developed is a significant factor
in developing a favorable climate and the support needed to implement
the control program and apply the best management practices. Early
and continued involvement of key publics — which depending on the
situation could be viewed as farmers, interest groups, local officials,
State legislators and State and Federal personnel — frequently
determines the success of the program. Even though all the pieces
may be in place, without the support of key publics the program will
not be implemented. A critical element of the Regional Strategy may
be the development of the support necessary to ensure the implement-
ation of the control programs.
Draft the Strategy
Once the survey has been completed and the information analyzed, the
requirements for fully operational control programs can be determined.
This is the starting point of a strategy, defining what needs to be
done. Then how it will be done and how much it will cost can be
determined.
29
-------
Involve other program offices, State, local and Federal agencies
Impacted by the strategy in its development. No one individual
develops and implements a strategy. The best way to have those
affected by the strategy buy into and support the strategy is to
have them define their roles in the strategy.
Some other concepts to keep in mind in developing the source control
and funding strategy are:
• Problem identification has a low priority. Most States
identified at least the general sources of their nonpoint
source water quality problems in their initial WQM plans. A
variety of planning techniques were used to identify those
problems, ranging from sophisticated land use models to field
examination. In many States the information developed was
sufficient to identify the critical problem areas. Further
problem identification studies and the development of pri-
ority listings for every area in the State with agriculture
problems are not necessary since implementation resources
are likely to be only sufficient to initiate control programs
in a few of the highest priority problem areas. For other
categories of nonpoint source pollutant problems such as
urban runoff (except for the NURP projects) silviculture,
mining, construction, etc. use good judgment.
• The initial planning process resulted in the development of
numerous BMP handbooks and substantial amounts of information
material such as brochures, slide shows, movies, etc. 208
funds should not be used to produce similar material which
would duplicate what has been produced previously. Funding
for material of this type should be limited to innovative
approaches for which handbooks and other informational or
educational material have not been developed.
• Technical and management assistance requirements of the
States and the activities of the Regional Office in meeting
those needs should be identified in the strategy. Regional
Project Officers are the key to assisting States in imple-
menting their NPS control programs. The umbrella and
individual agreements between EPA and Federal agencies should
be used by Project Officers to focus Federal resources on
State priorities. Agencies in the U.S. Department of Agri-
culture, U.S. Department of Interior and the Tennessee Valley
Authority can effectively assist States with NPS control
programs.
• The strategy should identify ways to develop better commun-
ication among State water quality agencies, designated manage-
ment agencies, and Federal agencies. Methods of improving
communication including work shops and advisory groups will
be discussed in greater detail in Chapter 5.
30
-------
• Training assistance is another key element necessary for
designated management agencies to accelerate the implement-
ation of controls (BMPs). The type, number and participation
in training work shops should be identified.
• Prototype projects are being used to excelerate implementation
of control programs in areas with the most critical water
quality problems. Regional strategies should identify the
potential for prototype projects. Since financing is often
the critical factor determining whether technical solutions
are implemented, fiscal management analyses should be a top
priority of the Strategy. Through the Financial Management
Assistance Program (FMAP) technical assistance is available
from Headquarter's expert consultants. The 208 planning
agency or the designated management agency does not
necessarily have to be selected as an FMAP prototype project
to receive technical assistance. On a selected basis within
existing resource constraints, technical assistance may be made
available. Headquarter's FMAP Project Officers should be
consulted for ideas and suggestions. The case studies and
FMAP tools should also be consulted for ideas on innovative
approaches other agencies have used.
The USDA cost share programs and Title V Regional Development
Commission funds are two examples of other Federal financial
resources available to assist in the implementation of non-
point source programs. These and others should be sought out.
• The Strategy should identify the support other divisions,
offices, and EPA organizational elements will provide whether
in the form of grant assistance (106, 201, 208, 314, RCRA),
contract funds, laboratory assistance for monitoring and
evaluation, or Headquarters' technical assistance.
• The Strategy should identify the mechanisms that will be used
to transfer the information and approaches developed to other
States and agencies. Workshops or Regionwide forums on
particular problems are frequently used. Regional Offices
may also wish to consider using State and/or areawide agency
personnel as consultants to other State or local agencies
with similar problems. Be innovative.
Review and Finalize Strategy
Don't hide the Strategy. Make sure it is widely distributed not only
within the Regional Office but to State and areawide agencies, Head-
quarters, other Federal agencies and State Policy Advisory Committees.
The more interests involved, the more support there will be to imple-
ment the strategy within the Regional Office and in the States.
31
-------
H
M
CO
u
h-f
H
S
o
PS
S!
1
to
w
C5 j>r>
M
a o
M Id
R 0
0
_0
Pi
en
Cd
cc
CO
z
o
cu
CO
S
CO
z
O
g-t
M
CO
O
Pi
en
-t
o
w
H
p§
£H
en
cc!
W
W
PREPARE STATE FIV
LETTER
\
•K
Review Guidance
\
•K
O
* «
S
x-x
ll
o
*4-l
CU
CJ
fi
CO
•^3
•H
3
0
M-l
O
ements
C Develop Common El
ill States
*
,B
4-1
1-1
S
CO
B
0
•H
4-1
to
4J
CJ
CU
O.
w
CO
B
Discuss Suggestio
States
*
0
* •
3
I-i
cu
4-1
4-1
CO
01
Guidanc
•o
B
cu
en
B
to
01
I-i
CO
a
CO
jj
P-I
0
£-4
CO
CO CO
4J CO
B
01 ,-!
e to
3 1-1
t-< M
W QJ
Oi
0) CO
B B
0 "^
{j
CU I-l
4-1 O
B
o td
Work with States
quiring Technical
*
c
•H
CO
0
B
4-1
CO
•H
to
(0
CO
Provid
Coordinate and/or
Development of St
CQ
W
3
H
co
w
1
REVIEW DRAFT STAT
•K
B
O
•H
CO
•H
CU
X
00
CO
4J
cd
4J
en
l-i
o
•o
cu
cu
cu
ti
•H
CU
4J
CU
O
t
t
0
01
o
H
I-l
14
D
1
X
0
Pi
(J
01
4=
0
a
z
o
S
*ti
lj
2
-i
o
i
o
>•
4J
r-
•H
^
i-
CO
B
O
a
CO
^
p;
>
^|
CO
|
PI
i
ex
ex
3
en
u
cu
4J
CO
S
^T
w
^
PS
A
i—<
o
CM
CO
•H
CO
i-l
eg
PI
-
W
Q
en
D
<
O
en
to
CO
1-1
4-1
01
•H
O
en
i-H
CO
4J
B
0)
jj
o
•H
>
B
1
M-l
U-l
CO
CO
t
J3
O
Ol
H
S
g
W
8
M
CO
p
o
4J
CO
B
•H
•O
I-i
O
O
CJ
^
-J
*
CO
I..I
o
4J
A
C
•H
*O
h
o
o
CJ
W 0
2U iJ
g 01
0)
m
1
&
1
32
-------
TJCO
i-t C
O i"t
u* ^
M fB
§^
CO CO
rt
rt
hJO)
i-l
O CO
•O rt
O i-l
CO (U
(B rt
O.fB
TO
COH-
O fD
C
rt rt
H-O
O
3 0
CO (B
rt
a>
H-
CB
*
o opd
3 a- It
rt <
cr pro
(BBS
^t Mpd
3 fD
COXKW
rt C H-
pi rto
rt 3
(B Hipi
» 1 I-1
CO O
9 O
i-t S!fB
0 OH
O* 2 ^
M. H-
fB (B
3 H^£
CO l-l
0 0
fl>'
rt.O
Ot)
HlH
HlO
H-CT
r> M
fD fB
H3
CO CO
\
*
r
O fB
0 Hi
•O H»
fB 3
O
HlHj
0
rt M
i-t C
pi rt
rt pi
fD 3
TO rt
X
cn
o
e
I-t
o
(B
Hi
O
l-t
C/3
rt
i-l
PI
rt
IB
TO
X
&>
*
TiO
O *^d
MH
M
coo
HM
go
^ £*•*
K!CO
o
o
M
O
O
z
H
O
f
j^
O
VNV
V \ \\
^\ \ \
\v\\
T3 O
l-l 0
O i-t
•OX)
l-< O
H-i-t
CD 111
rt rt
fD (B
CO
rt
i-l
PI
rt
fB
H-
3
rt
O
W
t*J
^.
J)>
CO
*r
«
0 *
,
CO CO
CO
Z H*
fB CO
O rt
fB
CO H-
co 3
(u
X fB
H-
CO
H-
3
TO
C/3
rt
i-t
^1
rt
fB
TO
X
H-
Hi
ff
<^
H-
CO
P-
O
3
*
coS
rt fB
l-l fB
Pi rt
rt
(B S
TO H*
X rt
rt 03
P-rt
MP1
Mrt
fB
WCO
^
H-H-
CO Hi
rt
^d
l-t
O
0*
M
fB
0
CO
5]
p*
rt
3"
X-
J
H-
CD
Si
P0
fB
(X
l-t
PI
Hi
rt
fB
Cu
C/3
rt
i-t
Pi
rt
fB
TO
K-
\
\
\
a
W
M
O
Z
C/3
H
^
h-3
C/5
)-J
ro
5
w
o
M
M
CO
as
fB fB
3fB
rtrt
CO
"SL
Ort
O 3*
O
3 rt
fB Pi
3 rt
rtfB
gpi
(B 3
(B D-
rt
H*pd
3 (B
OQ >n O
o PJ H
wos:
Z M W
a pd pa
w F
CO
CO
M
O
O
H
Z
O
<
o
W
o
CH
£
3
M
i
fe
po
"d
o
CO
I-H
H
0
CO
s
CO
"d
O
CO
hH
f
H
I— i
M
O
o
i
H
M
M
CO
X
X
K)
I
H
33
-------
H
I
H W
O
o
z
H
O
O
Pu
W
55
s
CO
CO
Z
o
a-
CO
3
W
z
o
H
M
CO
O
a,
en
d S
w w z
M Q W
H W O
c^ P^ ^C
5 OT
W O H
t™ ^^ r*-i
o £ o
S§l
c-*
ttt
32 0
Cs P-.
Q
Q
C
1— (
M
H
^
^^
\\\
v\v
\\ \
*
13
& Q)
HI*
O
.. 0)
Mcd
0) 4J
4-icn
CO
u 4-J9
OJ-HO
Q iS<
B
W
<-
M
£H
CO
jgj
O
(-^
o
3
w
J^
55
H
Q
Z
12
w
^
[£
s
\
V
\
o
* «
3
^>
do
-.
4-1 O
cd C
l-i (
CO ^
l-i cd
cd H
STJ
o
-------
EXHIBIT 2-2
SUMttARY: SISATKGY DEVELOPMENT ACTIVITIES
fti
o
Q
!5 -
O
H
y
jj
s
rt
3
~*
ID
Q
Q
a
p
OS
CM
O
O
4
-4
2g
-IM
-•>
3
H
trt
QM
U M
US
§u
2H
U]
siSss
M O
M§^
p<> Cd
oow
SB
M
IS
Sw
iss
OCrf
OO0
U
H a .-J
te Bl ->!
W 3 >
X H U
-3 M
Q
S§
O Pi
fe
e°«
iss
M W
Q i-J t3
£3 P3 W
o w 2
a
M 1>
rt B
c a.
0 0
•HMM
W) O O1
O! P >
p; 4J oi
d-o
c o
•H O X>
60
4-1 OI OI
CO O 4-1
•H P rt
Cfl 3 M
CO O 4J
< CO M
U CO
3M 1 co
y rt e
c tort'a
01 cd
CUM CO*
COO) QJiJ
rt-o *J C
o» rt 01
M CO OI
oi rt *-> P>
P a co s
3 > TO co
•H rt 2
i-li-l O CO
OOO O O/O-H
•HO- O rt CU
C 3 P iJ *->
•H CO O CO rt
U CO 0) O 4J
o c • rt-<->
oi OM OM
C g 4-1 Q> 1-1 rt
•H O
4-1 G * W OI-H
W g O CU fXGO
i < '
U) M
tx, d O
01 CUCN O
£. 3 coo
4-> 01 .CM
O-H 4-1 rt CO
> -H « o
i-i ax
at coo
P CO O MH (0
a
XO M
COP rt
oi u
rt o J3
pa M
4-1 « O
pp: co rt C
rt ai o
Q^vHM 0 X
>J rt GO rt OO
C oi c; co a)
u-l O *-> O O 4J
o-_rt 4-1 rt o +J
. . .
GO M
CU O X
W p p 00
rt 4J rt ' oi
P C CU AJ
4J o X rt
CO 00 4J
O rt fi. -H
60>H 0) rt (0
4) 0)Mi-< P CU OI
CiiA O n) &0 d> O>*
C C CU O.C
13 JJ -Q T-l rt "O
•H rt*H4-lp<3-r-(S
otn oct: MCI] tors
£ ....
SHHiHvnbavaH
OI GO
O t 1 0>
PIC a « 4J
o P- rt o cu to rt
<4-< <9 U M P 1) V4
CO 01 tCi-4 U
13 COM p> 4J tO
cu to ora c P cu
c cu rt >i M o 4->
*O X 4-l*r-< «
c > 4J ai P p-w
ep-H 4Jrt *-> oi o> o
O.P r)^ {r4Ji34J
01 Q," *J4J QJ C-r4i C
4J-d O P WtO f^M 3-H
CJ C h O
O t4
§rt co
(fl O w c oi
•H P bO CO j2 C tO rt OQP^
JU 4J i'J CO 4-> 01 4J
o o a rt « p; co
C 00 4->
CO CO 4J O* 3
GO CJ O> W S
C O-H P T3
•H -H 4J 4J C CUT3
4J M-i-H CO O 4J C
rt *w > T-I rt rt
Cl OT-* p 4J P
•H i-J rt 0) MP
"O 0 O 01 P CD OI
p rt rt >-* o 4-* AJ
o >-< co e rt cu
O •• t04-i iA -H tH 3 4J
O GOO O -O CO
C *H CL4J 4J * OOC 3
M AJ P i) <; o*"r-i
rt P O 4-1 • 4J ^ "O
u P 01 oto pi rt d-H
CO GO£ P- pvHM
^C
CO
OI
•H
01
4J
C/l
rt
01
m
o>
rt
•
0)
00
4J
(d
4-> M
CO O
M 4-1
O C CO
P O 0)
4J U -H
C GO
O CO OI
O U -W
•H rt
P.J O «J
. .
CO |
CO CU >it5
•• CU > CCQ
CvH -H OJ W
O 4-J 4J *J
CU P O-H P f£
CJ O W 4J 4-1 Q5
C T-t tO-H CO U
rt P m c pi
•H -O 01 -
C C V< ^H
T3 -H^i-H CU »
•H 4J GOU 00
> rt O oi C o
Q'Z 4->OiM CN
£ • • •
30I.iJO 'IVNOI33H
i
T-t
4J 00
O 0)
rt 4-i
rt
CO P P
iJ O 4J
1 C<4-l CO
*J P rt
•H^ O 0>
IS?4
o 3in
CJ CO
C
£T3-H
•H c:
rt rt co
4J OI
O O 4J
GO
C 01
tO P -H 4J
Of rt ^ co
tH OiU ® C S
O 4JM X p
rt >m 0*0-0
O UiH -H -4J O
0- oi rt OI-H co
PX4J T3 »4-> S
S T)«. 0) OI rt -O
W-H W-H X -M-H XG
p oi<4-i oo rt P eort
C C1--H-H OI *•< G-CU
^-Hoy4-)4J ftoo*-ip
rtPpcrt cuprtcu
43 P- OCKJ 4J C O.4-I rt
O rt rt-H to M rt co 3
.
c
0 X
S 00
e v
O 4J
cj rt
i 13 4J
in CW
cu rt
o tj rt
c o cu
O»4-<>4
GO
OI
0) -H 0*
13 4-1 4J
3 P 4-1
rt oco
01 -H
P P C
< ao
X
GO
0)
rt c
P 0
-u a.
to en
0)
rt
01 O
^-1 T-t CO
M W CO
3 CU P
o) a-c rt
4-1 C-H 2
t/j ra to w
1
•u c at
CO X
cu t;"-i-i x
"O P 01 O 00
•H O 4J 4)
3 m rt c u
rt P o rt
p p tO J_) U
rt •• o rt co
« 3 p p
o) 41 o rt oo 01
*O-H 6 O O> 4J
•H o rt>-i 4J rt
O oi bm i-i 3 co
P GO
fr. flJ *
S3S^SvS
35
-------
Chapter 3
WQM Portion of the State/EPA Agreement
INTRODUCTION
The State/EPA Agreement documents the mutual commitment of EPA and
the State to solve priority environmental problems. The State/EPA
Agreement (SEA) process forces top management in the Regional Office
and in the State to select and agree on which priority environmental
problems to address; to make the decisions and commitments necessary
to solve the priority problems; and to evaluate how well the decisions
and commitments are being carried out. The purpose is to ensure that
EPA grant funds produce tangible results by maximizing the use of a
variety of grant programs to solve priority environmental problems
that separate grant programs can not handle alone. The State/EPA
Agreement is an administrative mechanism to give EPA additional
flexibility to integrate the grant programs and coordinate the
delivery of services to the States.
The State/EPA Agreement is also a vehicle States find valuable to
integrate and coordinate programs and activities kof different agencies,
and/or organizational elements within a single agency, and to focus
their programs on solving priority environmental problems.
No subject is more sensitive with States than whether State/EPA
Agreements are just another "vehicle" for imposing EPA's require-
ments on the States. The Agreement should be a result of a true
negotiation between the States and the Regional Office* Commitments
are not just for the States to make. Regional Offices must be
willing to state, in specific terms, what they will do to help
achieve the Agreement's objectives.
37
-------
All EPA programs are covered by the State/EPA Agreement, which means
that potentially additional resources and program authorities can be
used to solve priority WQM problems that 208 or 106 funds can not do
alone, such as the use of Clean Lakes projects to assist in the con-
trol of nonpoint source pollutants or the use of RCRA or SDWA funds
to attack groundwater problems. That is why it is essential for
WQM Coordinators and Project Officers to become actively involved in
the process and agressively seek wyas to incorporate WQM priorities
into the State/EPA Agreement.
Because there is so much guidance on the activities, timing and
priorities in the SEA process, this Chapter discusses only those
aspects of the SEA process of particular importance to the WQM
program. The Documents section lists the most recent documents and
only those that directly relate to the WQM Program. The Policy
section includes policies related to the SEA process in general.
The content and suggested format of the Agreement are outlined and
the time frame for the preparation of the SEA is provided in this
Chapter. The activities of Project Officers are included in the
text of the Chapter but are set forth in greater detail in Exhibit
3-1. Exhibit 3-2 shows the relationship of the Regional Office
activities to State and Headquarters activities.
DOCUMENT CITATIONS
40 CFR 1507 funding for the State's WQM work program.
FY 80 State/EPA Agreement Guidance, February, 1979.
Annual Report State/EPA Agreement, October, 1979.
EPA Operating Year Guidance (FY 81), February, 1980.
Handbook for FY 81 State/EPA Agreements, February, 1980.
State/EPA Agreements — Administrator's Policy Statement for FY
81, February 28, 1980.
Supplemental Water Quality Management Guidance for FY 81, June,
1980.
POLICY
General SEA Guidance
• Regional Administrators are to continue to
make State/EPA Agreements a high personal
priority.
38
-------
• Regional Administrators should stay personally
Involved in negotiating the Agreements and
make sure States receive any help EPA can give
them.
• State/EPA Agreements are to focus on those
issues which need top-level policy attention.
• For FY 81 and beyond it is EPA policy that all
EPA programs be considered for negotiation in
SEA's. Where possible, States and EPA should
integrate activities to solve pressing environ-
mental problems — problems which do not respect
the boundary lines of EPA legislation or
programs.
• State/EPA Agreement priorities and policy level
commitments are to drive grant negotiations.
Agreements are to include a section showing how
specific grant activities contribute to achieving
State/EPA priorities.
• Agreements are to reflect national priorities to
the maximum extent possible.
CONTENT OF A STATE/EPA AGREEMENT
The key to SEA success is flexibility and accommodation of individual
State environmental problems and resource capabilities. Keeping this
in mind, the Regions and States have flexibility in designing
an appropriate format for how priorities, work plans, grants, summaries,
and signature pages are incorporated or appended. Regardless of what
format is used, the Agreement should deal with a manageable number of
priorities and should be streamlined so that it is useful to top
EPA and State managers.
The Agreements must have some uniformity of content to enhance their
use as management tools. With this in mind, Agreements should include
the following:
o An executive summary (if the SEA is longer than 25
pages).
o A clear identification of priority problems —
Priority problems are to be based on problem
assessment and multi-year strategies. The WQM
problem assessessment process and the State
Five-Year Strategy will provide a clear identi-
fication of the priority problem.
39
-------
• Annual grant work plans, which may be
appended — Once priority problems are
selected, steps need to be taken to make
sure that commitments are actually ful-
filled. This is done by using the State/
EPA Agreement priorities and policy level
commitments to "drive" grant negotiations,
and by tracking how well the Regional
Office and State are doing together in
meeting the commitments made in the Agree-
ments. Grant work plans should be consistent
with SEA priorities and implement the policy
level commitments.
• Documentation of tasks and resources needed
to meet SEA priority commitments — Agree-
ments are to include a section showing how
specific grant activities contribute to
achieving State/EPA priorities. This will
help meet both the management and coordin-
ation goals of SEA by making sure that
grant awards and cooperative agreements
provide the resources needed to meet State/
EPA Agreement commitments.
• A description of public involvement — Although
the States and EPA have principal responsi-
bility for negotiating the Agreements, the
involvement of the public and other interested
parties is important to the development and
implementation of the SEA. Federal regulations
require EPA and the States to (1) notify
the public about the goals and scope of the
Agreement; (2) provide information to help
people participate in the Agreement process;
and (3) schedule ample opportunities for
participation. Specific procedural require-
ments for public involvement, including
those for public meetings or hearings, are
contained in the public participation
regulations (40 CFR 25). In addition to the
general public, EPA and the States should
work closely with regional planning and
implementing agencies, as well as interstate
agencies and local governments to agree on
cooperative strategies, priorities, and
responsibilities.
• A procedure for management tracking — A
general criticism of State/EPA Agreements by
both States and EPA is that many commitments
40
-------
in the Agreement are so loosely worded that
tracking progress (verification of specific,
measured steps toward the stated objectives)
is difficult. To help improve SEA tracking,
Regions may wish to (1) give each program
office a check list of SEA tasks and output
dates for which it is responsible (this should
assist in tracking commitments at all manage-
ment levels; (2) use the SEAs as the basis
for State/EPA mid-year reviews where commit-
ments by EPA and the State are evaluated;
and (3) assign State and Regional project
officers to each priority. In addition,
priority commitments made in the SEAs should
be tied to managers' performance agreements.
In all aspects of the SEA process, top manage-
ment must support and be held accountable for
implementation and evaluation of meeting of
the SEA commitments. Where commitments are
not being met, the Regions and States must
take corrective actions.
WQM COORDINATORS & PROJECT OFFICERS INVOLVEMENT IN THE SEA PROCESS
Work programs and program plans are developed at approximately the
same time as the SEAs. No 106 or 208 grants may be awarded until
there is a signed EPA Agreement. Therefore, it is essential to get
the State/EPA Agreement signed by October 1.
Timing
The following is a general calendar for FY 1981 SEA development. It
is similar to the schedules in several Regions.
ACTIVITY RESPONSIBLE PARTY
October Award FY 80 grants Regions
November Initiative review of FY 80 SEAs HQs/Regions/States
to determine strengths and
weaknesses
December Prepare FY 81 SEA schedules and Regions/States
"scope of work" for development
of SEA
Review environmental problem Regions/States
assessments
41
-------
MONTH
1980
January
February
March
April
May
June
July
August
September
ACTIVITY
Begin FY 81 SEA priorities
planning
Prioritize problems based on
problem assessments and State
5 Year Strategies
Prepare program priorities for
SEA negotiation based on Agency
Operating Guidance
Begin SEA priority negotiations
Issue public notice Re: SEA
development
Public meetings/workshops/
questionnaires for SEA
priorities
Mid-year review of FY 80 SEA
Complete SEA negotiations for
draft FY 81 SEA
Distribute FY 81 SEA draft
for review
Prepare summaries for public
Solicit public comments on
SEA draft
Final SEA negotiations
Complete FY 81 SEA, reflecting
public comments
Prepare public responsiveness
summaries and distribute as
appropriate
Sign FY 81 SEAs
RESPONSIBLE PARTY
Regions/States
Regions/States
Regions
Regions/States
Regions and/or States
States/Regions/locals
Regions/States
Regions/States
Regions/States
Regions or States
Regions and/or States
Regions/States
Regions/States
Regions/States
Regions/States
42
-------
Develop Regional Position on SEA Priorities
State problem assessments, the prioritization of the State's water
quality problems, the State Five-Year Strategy, and national and
Regional priorities are the primary tools needed to select and
negotiate the WQM priorities for the State/EPA Agreements within the
Regional Office and with the States. What really are the problems
— not just those activities being addressed by the WQM program?
Are there groundwater, toxics, acid rain problems which impact a
number of program areas? Are there 208 planning activities which
could support the SEA priority problems? What about 106 program
priorities? Are there State WQM problems which track national
priorities that the State would be willing to address? Are there
WQM related problems which should be included as a SEA priority?
What other program authorities need to be and can be focused on a
particular WQM problem?
Unless Project Officers take the initiative to propose priorities
for the SEA, prepare the analyses and justification, suggest approaches
and coordinate with other program offices, no one else will and the
WQM problems will not be addressed in the Agreement. Since all
States have critical water quality programs which the 208 and 106
programs can effectively impact, the State/EPA Agreement should have
a WQM element which is either supported by other program authorities
or supports Regional Office SEA priorities. The attention of top
management should be sought out — not avoided. With the support
of the Regional Administrator, programs may move more quickly to
completion, stumbling blocks within the Regional Office may be
removed, and a sudden willingness to cooperate may be noted where
previously the typical response was "I'll get around to it" - next
month, next year, or, never.
Assist States Draft WQM Portion of SEA
Regional Office priorities should not come as a "surprise" to the
States as the SEA negotiations begin. Whether by formal letter or
staff discussions the priorities of the Regional Office should be
discussed with the State. The expanded SEA process requires more
coordination to ensure all appropriate State agencies are involved
in the negotiations and to the extent possible, ensure State agency
jealousies do not hamper the negotiation process.
An important component of the Agreement is the commitment that the
State and EPA make to meet the goals and objectives of the Agreement.
EPA in some cases has been justifiably criticized for not making
commitments other than awarding a grant. The WQM Coordinator and/or
Project Officer should suggest areas of technical and managerial
assistance that (s)he can provide or arrange for the State. This
will be discussed later in Chapter 5 of the Manual.
43
-------
A major Agency priority for the State/EPA Agreement is to strengthen
the State/EPA Agreement as a management tool. In FY 81 a management
evaluation and tracking system is to be included as an integral part
of the SEA process and incorporated into the text of the Agreement.
Some Regions use the SEA as the basis of the mid-year review and
some States are using the SEA process as a tool to better manage
their own programs — even those that are not funded by EPA.
Review and Complete Draft WQM Portion of SEA
The review of the State's SEA draft should focus on the proposed
WQM related priorities and whether they are justified based upon the
problem assessment and Five-Year Strategy. Do the State's priorities
reflect national and regional priorities, the priorities of the area-
wide agencies, if appropriate, or those identified in certified and
approved WQM plans?
It is important to keep on top of the SEA negotiations and the
priorities to be included in the Agreements as work programs and SEAs
are developed on approximately the same time schedule. Since Agree-
ments drive grant negotiations, the SEAs must show how specific grant
activities contribute to achieving State/EPA Agreement objectives.
Assist States With Public Involvement Activities
Public involvement efforts have been disappointing in many Regions
and States. How do you get people excited, educated and willing
to become involved? The case study section of the Handbook for FY 81
State/EPA Agreements describes several successful approaches. Four
principles prevail:
i
• Obtain early public involvement; To maximize
public participation and meaningful input,
the public should be involved early and
continuously in SEA development process.
• Use target groups: Target groups have an
established membership which can be used
to funnel information and feedback to and
from State and EPA officials.
• Use Regional and interstate agencies;
Regional planning and implementing agencies,
as well as interstate agencies, can be
used to serve as prime contact points with
local interest groups. These agencies
carry out activities which encourage public
participation, such as establishing
advisory groups and conducting meetings,
hearings and workshops in conjunction with
the State and EPA.
44
-------
• Consolidate/coordinate public participation
activities; Wherever possible, the States
and Regions should combine the public parti-
cipation requirements of the programs (such
as water quality management and solid waste
management) covered by the Agreement.
Possible areas for consolidation and coordi-
nation include advisory committees, public
information programs, and public hearings or
meetings.
Even though the Region's SEA Coordinator has primary responsibility
for the Regional Office's participation in public meeting(s) on the
Agreement, the WQM Project Officers should, if possible, attend the
meeting(s) with their State counter-parts. The willingness of the
Project Officer to participate stimulates cooperation and the feeling
of "we're in this together."
In addition to the general public, project officers and States should
work closely with Regional planning and implementing agencies as
well as interstate agencies and local governments to agree on mutual
priorities and cooperative responsibilities.
Finalize Agreement
Recommended changes in the Agreement based on public comment on the
draft should be accommodated to the extent possible.
As the Agreement is finalized so too are the program plans, work
programs and the commitments EPA has agreed to in the SEA. As in the
case of the Regional Office, those negotiating the Agreement for the
State may not be in the same organizational unit as those developing
the State 106 program plan or the 208 project proposals or the 314
application. In the rush, it is too easy to forget to keep everyone
informed of what is happening or what has changed. Therefore, it is
recommended that a "For the Record" memorandum be prepared by the SEA
Coordinator following each SEA negotiating session and be distributed
to all participants in the meeting as well as to those preparing the
program plans, project proposals for grant funding and implementation
assistance work plans. Then, maybe all State and EPA commitments
will be documented and not lost or forgotten in the maze of paper.
45
-------
I
n
u
g
B
H
g
en
z
RESPO
CO
§
M
H
M
S
z1
K
"
€
02
5J
o!
9
^ a
pq
e
1
u
g
0
z
CO
a H
et 2 o
w u z
F^ W O
£ eo
ill
O PM O
S3 *
tw H
H CO
B
£ O
5 cu
o
0
s
H
^
g
^
v\\\N
\^vx\ >
\\j\\
<
W
cn
PS
O
cn
W
H
I—I
OS
O
H
tA
CU
|
S
£>
Q
«
01
O
C
CO
•0
•H
s
3
01
•H
>
«s
«
JS
CO
B
O
4J
CO
4->
U
I
X
w
•0
e
C8
CO
B
O
•H
4J
CO
CU
00
oo
3
cn
CO
eo n
3 cu
O4J
co a
•H4J
ocn
\
\
*
CO
Vi
00
O CO
£ 3
o
Vi U
CU-H
jj
O O W
4-1 C
« 0
Vl CO-HI
0 VI4J
u CU a
C4J U
•HO 0)
•a ex
o w
O to
o u-a
01 C
< U CD
cnu-i co
14-1 C
4J 1-1
•H 4-1 4-»
S 0 CO
01 01
CU 0 00
CU Vi 3
SCucn
*
a)
4->
CO
4J
cn
_£.
4J
•H
3
CO
o
0
z
o
ce!
O
CU
S
H
<^
O
W
H
U
y
O
O
g
M
X
ww
Sen
«
* 'o
sT
4J
UH
ct!
P
CU
•H
01
Pi
1
to
CJ
o
•H
UH
U-l
O
1
oc
0
Vi
CM
Vi
01
0
„;
p"
l-l
o
1
*k
iH
a
o.
a
CO
0)
4J
a
3
J"
p2
CJ
PS
»— I
O
cs
CO
•H
rH
CO
0)
O
B
a
iH
rH
•H
01
e
3
CO
1
^
o|en
Q)
4J
(0
•H
Vl
U
4J
01
CO
n
V
o
•H
U-l
O
jj
O
01
1-1
o
oo
o
(S
•a
o
1
B
•
O
Cu
£
g
i
CD
V
u
V
w
a
01
•o
01
tx
0)
.e
0
CO
o
co
B
•H
•O
o
£
•
ey
ij
o
•I
^
a
w
2:
H
a
in
^
^
<
M
B
U
CO
•H
4J
B
0)
•H
U
CO
H
U
B
I
Vi
•H
B
U
1
U-l
w
eo
^
o
W
8
B
Vi
o
w
CO
B
t>
Vi
J
J
B
Vl
O
S
1-1
•o
o
o
u
CO U
CU 4J
z cu
ta<
p
>
4J
1-
r—
1-
M
, a
co
CO
CD
*H t0
CO
B
O
•H
D.
CO OJ
11
>
4-1
«
^ -H
Vi U
B iJ
Q Vi
Z Cu
W
3 i
J*
CO
Cu
V
\
^4
o
4J
u
01
•H
c
B
O
•H
<0
•H
•H
a
i
M
10
B
e
a
•H
iH
Q
Vl
CO
n
S
3
1
01
jD
CO
(U
u
o
aj
£
§
CO
01
•H
4J
1-1
tH
•H
•H
CO
e
o
a.
eo
01
•o
co
o
t-i
CO
§
01
o
01
Vi
s
*•*
It
-------
e^>
O C co
o e'en
S I-1*-1-
3 P-cn
ft O rt
3
rt *dOT
pi rt
*^H PJ
5 rt rt
~-O
n^i M
P pi
SSrt 3
(D P-
n> o MI
rt 3 O
H*"""*^"^
3 pd
FQ (D (?*
^
§*(??
CO £ ^
C rt
Mjt*P-
rto O
CO rt p-
P-X)
< fl>
PTt
rt
W CO
>co
p.
p-cn
3 rt
OOT
O rt
3 P>
i_i. rt
§ ">
O O
rtO
P-O
O i-t
3 O.
p.
£1 3
|-i* ^3
rt rt
P* (B
M^
O
OB
OT3
O M
N (B
O-rt
S"
W C3
rt ^
O P>
r< Mi
rt
^
**
O
*
\
\
O* ^^
O O fl>
O H (B
B P-
(B 3
3 09
rt 50
£ 0)
n P-cn
(B rto
CO 3*M
C CO
rt
oa>
O rt
o n>
h^
Cuo
p-l-l
3
B) 50
rt (B
OTO
1 P-
O
P> 3
cn
O
530
(B 3
O O
(B fB
CO i-(
CO 3
B> cn
,3
*
\
1
j
1
\
rt co
O C
o-
coS
rt p-
fl) rt
rt
(B o
o
pi |
3 3
CL(B
3
Ort
P-cn
CO
0 H
C 3-
CO l-(
CO O
C
g(W
P- 3*
rt
^W
CO ^
rt
B) O
rt O
(B O
i-t
a.
p-
3
rt
O
^
^
,*!
0 *
*
\
\
^
>^
1-5
)— 4
hH
3
a
o
p"§
"»
CO
> 0*3
S3?
o hb o
Tl o 3
Si"
w g
> "1 O
O M H
W O PC
Z M Pi
O 50 pO
M >
M f
p
hH
H
M
O
z
S RESP(»
"•4
CO
3
M
i 0
o
O
g
•^1 ^
W M
3
W-l
5 o
pa
i
I
1
H
M
n
CO
S
o
M
i
CO
M
47
-------
EXHIBIT 3-2
SUMMARY: SEA ACTIVITIES
1
o
Q
O
M
CM
W
Pn
CO
o
fr
Q
£
1
^
PQ
tn
M
H
M
M
-
0
^
H
CO
aw
Zwl
J
< J
< 3-
< W
§H
OJ
w
1 X
ZH
MO CO
W
HCJ
ZMZ
O3W
M O
Z W •-]
Q bJ S
OOW
U>frj
Z
o
ZH
S3
HO
pdCiM
oed
cio 5
p
w
H
A ED
-i Q >J
a w
J > Q
CO
H CJ
• z s
S <
""i Pi
o e2
Q CU
O
=1 to
s Z: H
< 0 Z
•J H X
S a c<
< T3 CX
-H 0
O t-i
J-J 03
Pn 6
.
00
r-<
tti
C
fe.
'
4)
O
cd
•XJ
y
o
4)
O
•• c ^
en ctj 03
d "X3 0) tu tn
O *rH U>< 4)
•H 3 d *H
4» -C C 41 3
OS E -H T-t O AJ
41 t-iO tC O
•C M (JT3 OJ
1> °W P."^ S
.
saawvnbovsH
ey tn 0 en 60
o) -H to E d
4J U (-1 OJ Cfl 0>
4-ȣx1 > O O^3 V^ CO
coco o w n o O-H
4-1 d CX)-t M
o) d c d tn cx*j p, ot
d O el) tr. ^ 41 QJ OOU
•H-HG4I ^4-J41 LJd
COPir-l 4)rH O60O-H ft tn
41 OU4l)J41W> -H
Jj-Q > O >• CX4-I O J-J tn
4-iCC'M4)p.COI-'Oen '
• • •
tn
•H 01
-H en
txtn M cu
en 4> 4_)
O -H 4-J
41 flj QJ
•O d ell
OJ U CO
O -I-1 CO 4)
4-> O tJ O
4J 4) >
X RJM to
. .
-n o
W W .H
to ccX
eu to »-H[I] d
d nj C J-i en d S d-H
O OOlCXflJG-H U(J COO
^1 "HP 4Jfi x;d41O. -UtH
ni 4j cxto c cj 01 *H -H eo t-i
pifi, 0)41 13 £ • in it 43i'of^Ips-H-SiH"!xo
f, g tO O CX bO^H O C S d^*H t-i^l
(S 5 W &MS5 0^> 4) 4-i
OPS cO
.
., aa"«™o13M
48
CO
en dl
en oi
en l-i
•H M
4J
C oi
4> O
•d d
M td
"
P
0
tn ' o Q
o tn d o «
d r> -H-H e uj
so 4j tn w ex
4J en nj tn «H
ex -,4J -H fd 00 W
i-1 P T-I tn -Hpri O l-<
4J 60 > ttl-0 rH 60
MiH (CPS OM-lO-H
. .
O 4J
•H d tn
ifl d 6001 41 4-1 K
o CtH ^ >»-J Jj
•H 3 OJQ1-I4I CO O
o u ni ,d *-) o cxu ^
rH 3 +J CO O fi M CO-H &
efl O CJT3 O O O dr-4 O O C
4J 60 eo O) bO-H 604) nXJ 60 COO)
OtS MCS5P«5 rtWWfSK*
W
to
^
d
•H
•a
c
m
4J
M-l
^4
Ct
UJ
CO
4J
»*-<
JJ
41
4J
OJ M
*J O
cn ii-i
* CO
d d
0 O
*H §
0 0 <
J-i OI W
P< M CO
.
sv saaiMmv/saivis
-------
Chapter 4
Execution of Work Programs
Work Programs
INTRODUCTION
Work programs are the most important tool the Project Officer can
use to manage the WQM program. All WQM grants require work programs
as part of the grant application — they assure Federal dollars are
used efficiently and effectively to solve priority water quality
problems.
Quite simply good work programs serve to stimulate a disciplined
approach to managing the work to be accomplished by identifing the
activities necessary to solve priority water quality problems and
providing a mechanism to track whether those activities are being
accomplished. Work programs not only document grant applications
but also serve as a basis for evaluating grantees.
Work programs are to reflect the problem-solving emphasis of the WQM
program. WQM grants are based on actual needs rather than on arbitrary
formulas. The priority problems addressed in the work programs should
be those reflected in the problem assessments, prioritized in the
State's Five Year Strategy and agreed to in the State/EPA Agreement.
Project Officers must know what the agencies are doing and be able to
judge the adequacy and the feasibility of achieving the expected
results in relationship to the nature of the water quality problems,
authority, organization and past performance of the agency(ies)
involved and their resources. Work programs are to stress quantifi-
able objectives and outputs so that EPA, the public and the grantees
themselves can access progress, oversee the accomplishment of the
activities, and thereby manage the program.
49
-------
Work programs should not be overly long, obscuring important
objectives and outputs. There are many types of acceptable work
programs — integrated work programs, non-integrated State subplans,
project level State or areawide work plans. Integrated work programs
for all State and areawide agencies' activities are encouraged under
the State/EPA Agreement.
There are a number of systems management techniques useful in the
development and presentation of work programs. These are outlined
in Chapters 4 and 5 of the draft Work Program Handbook for Water
Quality Management, August, 1980. After review of the draft Hand-
book is completed the most useful techniques will be incorporated into
Appendix 4 to the Manual.
Included in this Chapter is a summary of the documents and policies
to which Project Officers should refer before initiating the work
program development process, and a description of the content of work
programs. The documents, activities and thought processes the Project
Officer needs to go through to assist agencies develop the type of
work programs Project Offices and the grantees themselves need to
manage the WQM program, are outlined in this Chapter. Exhibit 4-1
summarizes the activities necessary in the work program development
process and Exhibit 4-2 shows the relationship of Regional Office
activities to those of Headquarters and the States. Exhibit 4-3
lists the State WQM program fundable activities, Exhibit 4-4, 208
project selection criteria, and Exhibit 4-5 national 106 priorities
for FY 81.
DOCUMENT CITATIONS
Sections 106 and 208 of the Clean Water Act
40 CFR 35.1513; 40 CFR 35.1507; 40 CFR 35.1509; 40 CFR 25
EPA Operating Year Guidance, February, 1980
Water Quality Management Five Year Strategy, January, 1980
WQM Policy Memorandum A-2:" FY 81 & 82 WQM Funding Policy - Section
106 and 208, June, 1980; Amendment, INFO: 80-89, July, 1980
208 Project Selection Criteria for FY 81, INFO: 80-69, May, 1980
Work Plan Guidelines for the Nationwide Urban Runoff Program, July 1976
Work Plan Guidelines for the WQM Advanced Treatment Planning Projects,
June, 1979
WQM Ground Water Strategy, April, 1980 (Draft)
Agriculture Monitoring and Evaluation Projects, April, 1980 (Draft)
Work Program Handbook for Water Quality Management, August, 1980 (Draft)
50
-------
POLICY SUMMARY
• Draft work programs are to be submitted no
later than June 1 of each year. Comments
are to be provided to the grantee within
45 days of receipt of the work program.
• The Regional Administrator shall not
approve a work program unless satisfied
that the applicant has provided adequate
opportunities for interagency involvement
and that the proposed work is in compliance
with applicable requirements of other Federal
programs.
• FY 1981 106 program priorities include:
building WQM capability, conduct priority
waste load allocations, hazardous waste and
toxic monitoring, environmental emergency
response and pretreatment programs, State
compliance and enforcement activities and
protection of sensitive ecosystems.
• The 208 program priorities emphasize the
development of implementable nonpoint
source programs for the highest priority
problems and the establishment of a reason-
able cause-effect technical data base with
a minimum of duplication. This is to be
carried out through problem-solving proto-
type projects. The information obtained will
be transferred nationwide. The highest
priority problems are: agriculture and
silviculture, groundwater and urban runoff.
• Regional Administrator shall not approve an
areawide agency's work program if, based on
the Regional Administrator's review and
advice of the State, the Regional Administrator
determines the work program is incompatible
with the State Strategy, State/EPA Agreement
or EPA guidance.
• After fiscal year 1979 no funds under section
208 of the Act will be available to any
planning agency which developed a certified,
and approved plan, unless a significant
portion of the plan is being implemented.
51
-------
• Prior to grant award, each State or areawide
agency must have an approved, or conditionally
approved, work program which identifies
specific outputs the 208 funds will produce,
including public participation elements.
• The State is primarily responsible for
evaluation of management agency performance
and it shall provide a description of its
evaluation process in its work program.
• All FY 1981 funds are to be obligated by
March 1, 1981 (50% of the funds must be
obligated within 30 days of the advice of
allowance); funds not obligated revert to
Headquarters for redistribution to Regions
with fundable projects. No funds are to
be carried over from one year to the next.
WORK PROGRAM CONTENT
Work programs and program plans both in draft and final (with the
final in greater detail) are to include for each task or program
element:
• Executive Summary; If longer than 25 pages
• Direction of State WQM Program (Summary of the
approach to solving the priority water quality
problems):
- the existing or potential water quality
problems, the severity of the problems, the
beneficial uses impacted, the geographic ex-
tent of the problems, and the source and
adequacy of the data used to define the
problems.
- the criteria used to select priorities and
its status in the WQM plan, State's Five-
Year Strategy, Continuing Planning Process
and SEA.
- previous years work or how the problem was
addressed in previous planning efforts.
- policy framework for incorporating areawide/
local agency priorities into State WQM
program.
52
-------
- anticipated changes and a schedule for
making the necessary changes in the
continuing planning process document and
the WQM plan.
• Program Element/Task Description
objective of the program element: this
should describe the issue or problem to be
solved and reflect the priority of these
problems (WQM plan, Five Year Strategy, SEA
commitment).
work to perform/tasks: show how they will
lead to the achievement of the objectives.
methodology to be employed; what approach
will be used to solve the problem.
outputs: either in terms of units to be
completed or control programs developed,
ordinances or legislation passed, etc.
milestones: key products to be produced,
decisions to be made or actions to be taken
for each output.
future commitments: depending on the program
element or task might include maintenance
of effort, i.e., number of Class II inspections;
or in terms of the development of the develop-
ment of NFS control programs passing of an
ordinance which may lead to future tasks of
obtaining funding for inspectors or the develop-
ment of a Phase II Clean Lakes application.
person years: for each program element and/or
task.
agency(s) responsible: for each program element
or task.
funding source(s): EPA grant, other Federal
sources, State and local funds to be used to
accomplish each program element/task.
estimated costs: allocated to each task in-
cluding any special costs such as laboratory
and equipment and a disbursement schedule.
53
-------
schedule: when each task is to be completed
and their dependency on other tasks.
- assistance required: technical and/or man-
agerial assistance required to complete the
task.
Public Involvement process to be included for each
appropriate task and/or program element as well as
a separate work program element which incorporates
all the public participation items. The element
should include:
- a schedule indicating when key decisions will
be made and what opportunities exist for public
participation in the key decisions.
- major public participation activities and ob-
jectives related to key decision points and
tasks (i.e., sequence of distribution of infor-
mation, workshops and meetings, hearings, etc.)
- the major publics that will be involved.
- budget by category, (i.e., publications and
media campaigns, hearings, work shops, etc.)
- indication that a public participation respon-
siveness summary will be prepared which
describes measures brought before the public
at key decision points, the public response,
and the Agency's response as to how the plan
was affected by significant input.
- description of the membership, meeting schedule,
and general responsibilities of advisory com-
mittees.
- brief description of how the public was involved
in selecting this program element/task and
developing the work plan (in some cases, the
5-Year Strategy development process could be
referenced here to meet this requirement).
Schedule Chart(s); Submit a scheduling chart (PERT,
CPM, or other) which clearly shows the significant
work tasks in sequence and the relationship between
tasks (see draft Work Program Handbook for Water
Quality Management, August, 1980).
54
-------
• Implementing Agencies; For 208 grants, list the
expected implementing agencies for each major plan
output and their involvement in the development of
the program.
• Agency Commitments;
- provide documentation that each agency with a
significant responsibility for producing,
adopting, and implementing the outputs, under-
stands and is committed to its outputs and
schedule, as described in the work plan. This
documentation must be in the form of a written
commitment from the highest appropriate
official (policy) level.
- significant implementation agreements (208
grants).
- information to be included in the quarterly
reports.
- data to be provided for information systems.
- evaluations of management agencies that State
will perform and a description of the process.
• Other Involved Organizations: Identify all
individuals, agencies, organizations, consultants,
etc., other than the grantee and implementing
agencies listed above, whose participation is
necessary to carry out the work plan. Describe
the specific responsibilities for each organization.
• Other Related Programs; Describe other related
programs (e.g., air quality, HUD 701, coastal zone
management, etc.) and the procedures for coordinating
these with the WQM project/task/program.
Timing
State and areawide work programs are developed in tandum with the
State/EPA Agreements. A great deal of coordination and communication
takes place within Regional Offices, within States, between States
and areawides and between the Regional Offices and the States
because the priorities in the State/EPA Agreements are to be re-
flected in the work programs.
The policy framework for the work programs is based on the State's
Five Year Strategy and is to include priorities for areawide agencies'
208 activities. The significant elements of the policy framework
are to be communicated to the areawide agencies no later than April 1.
55
-------
States have 45 days to comment on areawide agencies' work programs
if submitted directly to the Regional Office. Draft work programs
are due to the Regional Office in June and proposed 208 projects
are forwarded to Headquarters in June or July. The activities to be
funded are finalized by September and incorporated or referenced in
the State/EPA Agreement. Without a signed State/EPA Agreement no
grant awards can be made to State and areawide agencies.
Preparation of the Regional Guidance Letter
Expectations for State and areawide programs should be outlined in
a guidance letter to the States no later than April 1. The mid-year
evaluation of the State agency's WQM program is an excellent forum
for the development of ideas for the letter with the State agency.
When finalized, the letter should be discussed with the grantee.
A number of topics need to be addressed in the guidance letter:
• Funding target; Every agency wants to know
its funding target for 106 and 208 grants.
Although the target is not an entitlement or
a commitment on the part of the Regional
Office, it will assist grantees define the
scope of their activities based on the pro-
bability of resources available and the
agencies' needs.
• Ineligible agencies; Letters should go to
those agencies previously funded for which
208 funding is unlikely to occur in the next
fiscal year — for whatever reason. Although
limited resources is the most likely reason,
failure to have a certified and/or approved
208 plan, mismanagement of grants and not
completing agreed to outputs are justifications
for refusing to consider continued funding
for an agency. It is a difficult but necessary
task for Project Officers to recommend that an
agency's funding be terminated. If resources
can be better utilized elsewhere they should
be.
• New initiatives; A key item in the letter is
the identification of new programs and projects
based on national and regional initiatives and
funding priorities. Guidance on new national
initiatives and funding priorities can be
obtained from the items listed in the documents
section above.
56
-------
Initiatives may be based on national priorities,
the Regional Administrator's priorities, State/
EPA Agreement priorities, Regional source con-
trol strategies, State Five Year Strategies,
conditions for approving WQM plans, water
quality problems identified in the States'
problem assessments, the Region's overview of
the assessment or the environmental profile.
• Ideas for possible 208 projects: These may be
found in a review of the conditions approving
WQM plans and an evaluation of the implementation
of WQM plans. Concepts which are compatible
with the current nonpoint source emphasis should
be suggested as possible projects. Headquarters
provides managerial and technical assistance in
the development of work programs for NURP,
groundwater, financial management and for
agriculture monitoring and evaluation Category
1 projects.
• Format: Examples of the format and a discussion
of the level of detail necessary for draft
and final work program submissions should be
provided in the Guidance Letter. It simplifies
the process if grantees know of new require-
ments prior to preparing their draft programs.
The degree of Regional Office program inte-
gration (106, 208, 314, RCRA, SDWA, etc.) will
impact the formating of program submissions.
A common format for all work program sub-
missions and the integration of work programs
is encouraged and is used successfully in
some Regional Offices.
• Procedural Guidance; The Guidance Letter should
also outline the procedures for internal work
program review, the timing of submittals and the
review and approval schedules. It is important
to leave enough time not only for the development
of work programs but also for their review and
revision.
• Quarterly Reports; The letter should identify
the information to be included in the quarterly
reports such as expenditures, summary of acti-
vities against the projected outputs, etc. This
is explained in more detail in Chapter 6.
57
-------
• Information System; Requirements for data in-
puts into a Regional and/or Headquarters Infor-
mation System should be identified (Note: a
pilot test of an Agriculture Implementation
Information System is to be initiated in FY 1981.
• 208 Areawide Agency Funding Policy; If the
Regional Office has not already forwarded its
policy on the funding of areawide agency 208
activities — either directly or through State
agencies — it should be included in the work
program guidance letter to State and areawide
agencies.
• Revisions of Continuing Planning Process Document
and/or the WQM Plan; Required revisions to the
Continuing Planning Process description and or
revisions to theQM Plan should be identified for
inclusion in work programs.
• Significant Implementation Agreement; Each 208
work program is to include WQM plan implement-
ation activities necessary to meet the require-
ments of 40 CFR 35.1533-3(b). This regulation
states that a significant portion of the WQM
plan must be implemented prior to future 208
grant awards. The activities in the agreement
must be completed during the fiscal year in
order for the 208 planning agency to be
eligible for funding the following fiscal year.
Regional Offices should identify those imple-
mentation activiites they expect to be
accomplished over the next fiscal year.
• Evaluation; The letter should reference or out-
line the Region's program review process for
grantees (mid-year evaluations, implementation
reviews, etc.) and the expected evaluations of
management agencies States are to perform.
Review and Revision of Draft Work Programs
There is much for the Project Officer to consider in reviewing draft
work programs and project proposals. Only criteria applicable to
the WQM program in general are listed within the text of this Chapter,
Criteria for funding 208 nonpoint source control projects and 106
program priorities may be found in Exhibit 4-4 and 4-5 respectively.
58
-------
Some general guidelines for the review of draft work programs are!
• Do the programs/projects reflect national
and Regional program priorities and
initiatives?
• Do the programs/projects address the priority
water quality problems addressed in the pro-
blem assessment? Just because there is a
national problem does not mean the States
within the Region have the problem.
• Are the programs/projects consistent with
the State's Five Year Strategy, the State/EPA
Agreement and the Region's control strategies?
• Are the activities and outputs clearly defined?
Do I understand what is going to be accomplished
and when?
• Is there adequate funding to accomplish the
tasks? It is better to fund a few projects
completely than under fund many projects that
will not produce implementable programs.
• Are 'the public participation work elements
tied to the major tasks and decisions in the
work program? Have the public participation
objectives and target publics been clearly
identified? Do the specific public partici-
pation mechanisms (newsletters, public
meetings, ad hoc advisors, etc.) relate back
to the identified objectives? Is the budget
adequate to implement the public partici-
pation work elements? Is there a separate
public participation work program?
• Do the 208 projects address removing the
conditions to the approval of WQM plans?
• Are 208 projects limited to solving nonpoint
source control problems? Point source
control activities are ineligible as 208
projects in FY 80 and FY 81.
• Do the 208 projects fit Category 1, 2, and 3
criteria? Are there projects targeted for
208 funding which are ineligible but have
merit and could be funded from other sources,
such as 201 or 314?
59
-------
• Are the outputs of the 208 projects part of
an overall implementation plan? Will they
lead to operational NFS control programs?
This is a must. The intent is to assure
that projects lead to decisions on the
establishment of operational control programs
as opposed to studies which involve no
commitment to implement.
• Is data collection proposed which is not
essential to problem solutions and implement-
ation?
• Are integrated approaches to solving multiple
nonpoint source problems proposed? From more
than one funding source (201, 314, RCRA, SDWA,
etc.)?
• Will the projects be initiated in a timely-
fashion? In other words will projects funded
in a particular fiscal year be well under way
in that same fiscal year?
• Are the appropriate agencies identified for
the project activities? A local agency is not
the logical agency to develop State legislative
proposals.
Some of the factors to keep in mind when evaluating the 208 submissions
as a whole for the Region include:
• Are projects duplicative of one another? Is
there one project addressing a particular
problem which is more likely to produce hard
outputs transferable to the other States
within the Region? If so, that one project
should be selected as a prototype for the
Region and the information gained transferred
to the other agencies.
• Are there potential Category 1 projects within
the Region? If so, work with Headquarters
and the State on the proposal.
Grantee performance — past and anticipated is to be used in the
evaluation of work program activities. Some of the things to
remember are:
60
-------
Grantees, other than new designations, must
have certified and approved plans to be
eligible for 208 funds. Partial or con-
ditional approvals meet this criteria.
No Section 208 funds will be available to
any agency with a certified and approved
WQM plan unless a significant portion of
the plan is being implemented. (See CFR
35.1533-3(b) and CFR 1537-4(c)).
Regions should have reached a written agree-
ment with each Grantee as to what implement-
ation outputs were to be achieved prior to
the FY 80 Grant Award. An evaluation of
implementation must be undertaken for each
Grantee and the Implementation Agreement
updated to reflect those implementation
activities to be accomplished during FY 81
before an award of FY 81 Grants can be made.
Grantees must be likely to be successful
in their efforts, and meet the other eligi-
bility criteria in CFR 35.1537-3(b).
There can be no award of a 208 grant where
the Regional Administrator determines that
(1) funding is to compensate for administrative
mismanagement, (2) the proposed work would
be duplicative of another grant agreement,
or (3) other funds are available and more
appropriate to the task.
No projects may be funded if agencies do not
have sufficient management, technical, and
grant-matching ability to perform the pro-
jects. In making such decisions, the Regions
must consider an agency's past performance,
its present staffing and funding, and the
amount of work — possibly large — the agency
must complete under the terms of previous
FY 78, 79, and 80 grant awards.
A determination is to be made that State ex-
penditure of non-Federal funds for recurrent
106 program expenditures will not be less
than such expenditures during the fiscal year
ending June 30, 1971.
61
-------
• Determination that the State has complied
with the provisions of 40 GFR 35.1537-4(d)-(h)
including monitoring requirements, 305(b)
Report preparation, emergency response pro-
grams, adequate level of funding for legal
expenses related to enforcement and any
Federally assumed enforcement actions under
Section 309(a)(2) of the Act, in order to be
eligible for 106 grants.
State and areawide work programs should be reviewed and commented
on by other appropriate program areas and offices in the Regional
Office. This may include the State/EPA Coordinator to assure work
programs are tracking the SEA priorities, enforcement, S&A, con-
struction grants, etc. Work with other program coordinators to see if
projects can be improved. Are there areas which should be better
coordinated within the State? Are there other program activities
which could be utilized to improve the outputs? Are there new
initiatives that should have been included in the State's program
plan? Is the program funding level adequate?
While reviewing the work programs, keep in touch with your State
counter-part on an informal basis. Let the State explain and justify
its activiites. Make sure you fully understand what it is trying
to accomplish. Talk over your concerns — maybe it is just a matter
of phraseology. The trust and rapport built during the negotiations
of work programs and projects may make suggestions for future work
programs and projects more willingly accepted.
208 projects will have to be ranked. The needs are great and the
resources so limited that more projects will probably be submitted
than can be funded. The ranking of 208 projects proposals is much
easier if the Region has prepared a nonpoint source control and
funding strategy that sets forth the Region's priorities. The Strategy
provides the rationale for selecting those projects that will lead to
operational control programs.
Preparation of 208 Project Proposal Summaries for Headquarters Review
The purpose of Headquarters review of proposed 208 projects is to
assure 208 funds are allocated to areas with the greatest need.
Individual projects will not be approved or disapproved. However,
unless the Regional Office can demonstrate their needs based upon
sound project proposals, funds will be reallocated to Regions with
fundable proposals.
In forwarding 208 project proposals to Headquarters, anticipate the
questions that may be raised. For example, do the projects fit into
an overall Regional strategy? How do the projects fit into the State's
6?
-------
Five Year Strategy? Stress outputs and how the projects will lead to
operational control programs and/or removal of conditions to the
208 plan. Is there a mix of projects addressing both national
and Regional priorities? Recommendations for Category I projects
and technical and managerial assistance requirements should be
identified.
If project proposals are submitted to Headquarters by July adequate
time is available for any modifications necessary to incorporate or
reference the work programs in the State/EPA Agreement.
Finalize Work Programs and Make Grant Awards
The more clearly defined the work program outputs, the easier it will
be to manage the program. Overly long and complicated work programs
obscure the objectives and outputs and inhibit program management.
In a well managed program, outputs are tracked, slippages identified
and issues resolved before the program is jeapordized.
Changes may be necessary in State work programs activities when the
appropriation act is passed and the State/EPA Agreement is finalized.
Difficult as changes may be, it is an accepted process familiar to
State agencies. It is important to keep the State agencies abreast
of the potential changes that may be necessary - so no one is
surprised.
As soon as possible after the State/EPA Agreement is signed and advice
of allowances are transferred to the Region, work programs should be
finalized and grant awards made.
The letter accompanying the grant award should clarify the Regional
Office's understanding of any outputs in question, conditions to
the grant and how the work programs will be tracked. This is a key
document in the mid-year evaluations.
Assistance in the Execution of Work Programs
It is important for Project Officers to recognize that the success
of the WQM program may be dependent on the technical and managerial
assistance that the Regional Office provides or assists the grantee
in obtaining. Assistance to State and areawide agencies is a critical
activity for the Program Officer.
During the development of work programs, State and areawide agencies
and the Regional Office should identify the areas of managerial and
technical assistance that may be necessary to assure execution of
the work programs and the commitments made in the State/EPA Agree-
ment. Project Officers or other experts within the Regional Office
63
-------
may be able to provide the grantee the assistance required. Head-
quarters consultants are available for Category 1-208 projects and
for Category 2-208 projects as time and resources allow. Headquarters
project officers should be consulted early to determine whether the
type of assistance can be provided when it is needed. Assistance
may also be obtained from other Federal agencies through interagency
agreements or personal contacts.
The preparation of an assistance work plan will help Project Officers
anticipate, coordinate and schedule the managerial and technical
assistance necessary for State and areawide agencies. A Regional
assistance work plan identifies those activiites of an agency's work
plan that will require either technical or managerial assistance, the
type of assistance needed, when it will be needed and who will
provide it. The next Chapter describes in greater detail Regional
assistance work plans.
64
-------
Ic
1
s:
0)
Pt
m
1-1
o
0|
b
i
o
V*
H-
\
1
^d
D>
f^
n
h*
rt
H-
*
1
^
11
H-
B
11
^
r1
PI
o
PI
z
o
H- CD •«
j* «- -•- f*\ l-rt
PT ^3
n CA
o
o
o
i
Cu
H-
B
rt
0
n
a
w
3r«
fl
>
C?
O
h(
a*
H^
3
B
pt
0
IB
«
ps
o
PJ
|
i«j
(B
rt
=r
CA
Pt
B
H)
1
w
3
[^
0
p.
(B
3
pt
B
I-1
en
rt
H-
(B
3
pt
)-••
CO
B
a
en
O
C
CA
D
M
*
l»4
<2
*>•
«
M
D
t*
^«
H-
CO
H-
O
3
O
z:
,O
•
s
c?
0
11
H-
3
B
Pt
O
i-t
CD
O
pt
=r
ro
*4
(B
a.
(B
l-t
B
H"
^
)0
IB
3
rt
^*
(B
at
I
r~
o
3
a
^
(B
O
pt
O
rl
B
3
*0
•
0
s
CO
1
h^
O
o\
tf*
to
o
00
7
o
IB
rt
pt
O
i-h
H>
I-"
O
(D
11
CO
IB
l-t
rt
•
H*
Pt
n
h*
i-h
0*
B
m
B
•a
XI
i
0
•d
(B
r*
n
CO
•o
o
3
CO
h*
o-
I-1
H*
Pt
^
CA|O
tr>
>
\
CA
C
w
s:
B
pt
IB
p^
CA
e
X)
XI
^
1
0
M
pa
ns
^
O
rt
3*
(B
1
13
0
00
p^
B
B
0
Ml
i-h
)•*
rt
IV
0)
I
HI pa
ht (D
O.O
(B
>cn
XI rt
XI
i pa
O (D
i-l H-
H-IB
ft) 5
rt
IB O
HI
11 S3
O O
OQ 11
11 W
ft)
11
oo
Hi hi
H-ft)
rt B
IB
CO P]
i
(B
rt
CO
*
>M
CO d.
CO ID
w rt
rt H.
ft) HI
ID 13
O
pan
IB CD
B
0>
3
rt
*
pa
(D
(B
«
0
11
Hi
rt
S!
&
11
11
O
OQ
11
g
CO
*
M
PJ
<
p)
s:
i
s
<
H
CO
M
O
Z
o
IT!
0
§
i-3
1
7?
p^
8
£>
3*
CO
^
s\\
^
vsV
v>\\
AVO
m
d .j.
H* CO
Cx.cn
CO CO
rt
3
O
O
o
11
CXt
H-
ft)
rt
H-
3
00
CA
rt
ft)
rt
(D
CO
ft)
p
ex,
ii
ID
ft)
1
*
pa
IB
3
O
IB
r1
n>
rt
rt
a>
l-t
7
"o it-
si-
P8O
(D ID
OQ <
H* (B
O M
3 0
13
O
C rt
H-P"
a. ID
ft)
O ft)
an— u
o
rt i-t
O
O
COO
rt g
ft) a
rt o
fD 3
CO
PI
ft) M
P (B
(D
>3
i-f rt
a o
H-H)
Cx.
(B
CO
*
*
Hpa
IB <
CO 0>
*>*
H-
CO Q
rt C
C H-
co ex,
CO ft)
3
s! o
H-fD
rt.
O
CO ft}
rt
M
O
M
O
Z
£>•
f~*
§
M
O
^
o
w
,_,
Pl
1-3
H
PI
pa
CA
*
^^
^
f^
.J
g
H
^
O
O
p S
CO
H nB
> 0 S
**5 •
o "o o
HO H
M g
> "3 O
O PI H
PI O 33
Z PI W
O pa pa
M >
Pi f
CA
i
pa
«!
*— » »-
f
0
CA
PI
ha
O
O
H
POSIT]
r~i
o
z
CA
pi
CA
hQ
0
z
CA
M
M
3
'
3
pi
1
l-l
§
PI
CA
65
-------
a
w
2
8
CO
td
H
O
i O
fa
W
tt)
O
P
§ i
M J
S H
M g
i— i
1
§
i
u
_!
PS
cn
O
PH
1
2
0
M
H
M
CO
0
fa
CO
iJ W
< M
W W 2
SOU
H W 0
O fa -*
f-H
M
^
M
H
O
^
\
\
\
CO
e
to
00
o
M
>/
t-l
O
EE
u
*W
(9
p
c
o
CD
4-1
C
CU
H
0
u
^Q
3
CU
•H
p>
CU
PS1
\
*
a
to
00
,0
PH
^
^j
O
C
o
CO
4J
C
CU
g
3
O
0
!->{
to
c
o
*r-l
00
CU
CU
nJ
G,
CU
fa
*
CU
•a
1 -H
0 >
0 0
O t-l
a
c
O CU
•H.O
CU O
CO CU
CO O
3 C
o to
CO 4->
•H CO
PiH
CO
O CO
CU iH
CU CO
4-1 TH
C 4-1
CO C
M CU
O 4J
O
JJ
._> ,J4
S
CO
4-1 4-1
CU C
CU CU
X S
*
JJ
o
CU
o
PH
00
O
CN
HI
N
•H
4-1
•H
jj
O
•H
^
PH
T3
C
to to
,-H
a. 03
o co
i-l O
CU (X
> 0
0) >-i
Pfa
•K '"^
en
i-l O-
CO
O O
CX4J
o
t-l CO
fa 4-1
CO
J-J <
D
en i-l
•a c
C o
CO T-l
4J
3 to
•H
^T3
cu ti
f6 CO
O
* •
^»
O
c
cu
toO
O
C VH
OPn
i-l
00 CU
CU.JO
pi
o
»4->
o*
S3 CU
O
cu a
N CO
•H 4J
i— 1 CO
CO-H
C 10
•H CO
fa<;
•K
^»
O
C
cu
op
VH
CU
.fl
4-1
O
T3
(3 to
C04J
C
o-cu
w g
cu
C cu
O M
•H M
60*^
CU
Ptf CU
o
4J c2
e to
0)4-1
§co
•H
U CD
O CO
P
-------
Hi CO
0 C
>-i a-
B
T3 rt
XJ
i-l O
O i-l
pi 3
Met
r
^
o.
£•>
o
o
^
(B
c-1
CD
rt
rt
CD
i-t
It
O
PC
^^
O *
O^d
0 ^
O CD
11
b ro
rt
H-O
3 >-l
|Q pj
3
Ort
O
ar
-.. fo
rt 11
H-P,
O
3 0>
tn 3
O.
O
O
CD
I-l
r1
n>
rt
rt
CD
*
w 2
is
hdfi
I-l p-
O rt
^_t
ro CD
^
0
I-l
7f
^d
i-{
o
I
*
en 09 ?a
rr »-( 0)
Q) ^J ^
3 B H-
CL en ft)
MJ d
3 >
TO 09 CO
CO (D rt
p.pj
5J 3 rt
3 co CD
U rt
co pd
PI CD >
^> OQ ^
H«(D
O P^
3 Si
h4*
00*
O (D
3
3 "3
CD H-
3 3
rt »
CO M
M
^
ao
p i-i
QJ ?7*
CD
I-1T3
0
1
1 *rj
II
or1
COM
N
M
32
O
pc
p^
po
o
o
J>
3
CO
^
2J
O
s
5>
r*
Bd
O
50
^
*g
Pj
^
M
AANAA
vvyvv
.\N\\\
M
o
H
H
<
I— 1
l~^
r<
O
O
.^5
0 3
tn
co H £
H WO
> o 3
^ij 32
"^ '
o TJ o
CO g
> i) O
O PI H
PI O S
Z P3 W
PJ r1
CO
TJ
O
CO
I-l
I-t
O
CO
PI
•Ji
0
CO
M
M
n
s
o
w
o
E> M
^ g
w
i
po
1
§
o
M
O
o
M
M
H
PJ
X
M
03
O
o
Z
H
PI
a
67
-------
EXHIBIT 4-2
SUMMARY: WORK PROGRAM ACTIVITIES
i
j
j
o
.,
j
i
p
H
3
3
iRFORMED
REVIEW
n. lA
<**L
CQ P
3 ^!
5r
ACTIVITIES
PREPARATIOl
ai p
§§H
H |
O O W
(J > tv
GRAM
RDINATION
NTEGRATION
0 0 H
S8-
Q
W 5 (-3
5 M >
O > W
Q 2 -8
Cfl
B§
S
U W
O C»5
tn
0
GUIDANCE ANT
EXPLANATION
REQUIREMENTS
cu
E
CO CO -H
O O AJ CO
CN CN > CO >* « O
p 4-1 p AJ cn
O G O O CU
60 CU CO Ct PS
0) i-j CU •*-> O
AJ O AJ O T3 *-l
O CXO cx to a)
• •
CO
•H
CO
CO
CO rH
nJ
o o
AJ O
CO
AJ T3
C C co
0> CO Ot
G -H
CU OJ CJ
CU AJ C
P rt cy
60 AJ to
•< W to
•
I
o
P AJ
C «J
P X O P
o P e 60
M-l 0 G
& O 6
cn u (8
U -U P
> O
•H u tO C P O
60 «J "U -H O i~t
CU P TJ "O **""
P. O 3 X O
OJ O fi-< CJ -H
•a P -H AJ
> A-
c « c o
tfl C 0) O
60 -H 60 -O
AJ C
CO U P P
a> -H cx
C >^ E 3 cu cu 3
AJ R) O 60
«
§ CO 60 PC C
iS -H C 0 td O
Oj.t4.Hil-, ^H
o cx-c cn x cn
CUCXHH-HESSg
•H p X ^H U AJ
CXCU-HCUCJO PcO
OOAJOtOrH "OOP
P.HCP V vi-
cu to
"a. 60
go
p
0 fX
L
K 1
^-t AJ
3 CO
CU CO
P CO
to
M-I AJ
•H CO
AJ CO ft)
§AJ 3 CU
C cr o
*0 CU OJ C
M 0 Bi «
* "
p
0 1
•AH AJ
CO -H
AJ CO
SCO
rt to
E
•H AJ
1 -H
U CX
O
X P CU
CU CX CJ
o> cx c
•
It §
PC rH
cu cx tn to cx
co ^ -H ex to o ey
AJ P *J CU AJ .C
W O -H S -H AJ
> > O- 0 -O
0) «H ^S C CU AJ
AJ CO AJ CU AJ C
cti -0 O CX 60 CO CU
P -H CO O CO C E
60 S rH 60 OJ
C P P a> -H «3 0
rH tO 60O & *O -H
1
CO
cu
p
CO CO
o
M-I (N
O
cn to
0) ^i cO
•HOP
> c to
CU OJ O
P 60 P
CO CX
CD
AJ O J£
C *G P
AJ -H O
tn & 5
1 to
1 CU 1 1 *o''~ ScCtoIoAJ S O
OP&'H OJ OJOI 3«3P^(
r-i CX^MH p B"*-*^ cx o AJ
P
§
0) CU CU 00
-o E -o o
-H nj -H CN CO
> PS 0>
O •* *W CO » ^f
P CO CU s U
CX CU X P X *H
•o o
tO «rC-H C ^H
0) ;* r-{ p OJ AJ
AJ « o o to o
tn to *
giviHdO^dav
sv saainvaw/saivis
68
-------
EXHIBIT 3
STATE WQM PROGRAM
FUNDABLE ACTIVITIES
Activity*
CONSTRUCTION GRANTS MANAGEMENT
PERMITS (includes NPDES, 404 and
Other State Permit Programs)
Administration
Compliance Evaluation
Enforcement
GENERAL & POINT SOURCE WQM PLANNING
Water Quality Standards
Wasteload Allocations
Municipal Facilities Planning
208 Dredge and Fill Regulatory
Programs
NONPOINT SOURCE PLANNING AND
IMPLEMENTATION
MONITORING
Equipment and Facilities
Ambient and Compliance Monitoring
General/Point Source Intensive
Surveys
MUNICIPAL FACILITIES OPERATIONS &
MAINTENANCE TRAINING
EMERGENCY RESPONSE
PRETREATMENT
314 CLEAN LAKES
OTHER PROGRAM ACTIVITIES
Funding Source
106 to the extent not fundable
under 205(g)
106, 205(g)
106, 205(g)
106, 205(g)
106, 205(g)
106, 208, 205(g)
106
106, 201, 205(g)
106, 201, 205(g)
208, 106, 205(g)
208, 106
106
106
106, 208
106
106, 205(g)
106
106
314
106, 208
*Refinement of elements shown in 40 CFR 35.1513-5(c)(l-18)
69
-------
EXHIBIT 4
208 PROJECT SELECTION CRITERIA FOR FY 81
A. General
1. The major objective of these criteria is to foster development
of 208 projects which produce hard outputs and solve problems
other than those which are construction grants or point source
oriented.
2. All projects must be part of a State WQM Strategy.
3. All projects must have fiscal/financial management components.
4. Each project must include complete public participation in
accordance with the public participation regulations (40 CFR
Part 25) and the WQM regulations (40 CFR 35 Subpart G).
B. Category I Projects
1. NURP: No new projects.
2. Agriculture: Three to five new intensive M&E projects on the
effectiveness of BMPs and water quality impacts.
3. Silviculture: About three new projects which demonstrate inte-
gration of State Forest Resource/208 Planning with training
and implementation.
4. Ground Water: About 10 additional projects in a range of settings
focusing on development of comprehensive, implementation-oriented
management programs with monitoring strategies and legal/
institutional analyses.
5. Financial Management: Up to one additional project per Region
on nonpoint source control financing and institutional arrange-
ments with direct relationship to plan implementation; emphasis
is on the development of tools which can be transferred to other
areawides for use in small flow system management, agriculture,
NFS pollution abatement, urban runoff control, and ground water.
70
-------
Category II Projects
Subject "DO"
Urban Storm
Runoff
Agriculture
Small Systems
develop implementable
programs to solve known
WQ problems with known
practices
set up programs which
give full and early
consideration to finan-
cial and institutional
arrangements and are
self-sustaining
emphasize funding items
to maximize operational
status of WQM plans
refine critical area de-
signations to impacted
water courses as opposed
to entire drainage basins
where priorities have
been established for
implementation, develop
implementable programs
to solve known WQM
problems with known
practices
support on-going RCWP
projects for monitoring
and evaluation
use State Cooperative
Extension Service funds
to match 208 funds
where possible, to assist
with information, education,
testing, integrated
pest management, and manage-
ment-oriented BMPs (See
INFO 80-30)
develop implementable
programs to solve
identified WQ problems
evaluate BMPs
do problem assessments
monitor for toxic
pollutants
— fund RCWP applications
or identification/prior-
itization of potential
RCWP projects
— fund BMP handbooks
fund problem-identifi-
fication studies
use 208 funds to solve
problems which are
eligible for facility
planning grants under
201
71
-------
6.
Subject
Ground Water
"DO"
7.
Construction
Runoff
8. Mining
9. Hydrologic
Modification
10. Residual Waste
refine the effect and
degree of known WQ
problems, and develop
implementable programs
to solve these problems
with known practices
fund comprehensive State
or aquifer-wide ground
water management programs
consistent with the al-
ready established surface
WQM programs
participate in hazardous
waste programs to ensure
ground water protection
fund development of State
legislation and imple-
mentation of local ordi
nances, modification of
existing regulatory
programs, and resolution
of financial issues nec-
essary to develop an
implementable plan for
solving identified WQ
problems
fund development of non-
coal, regulatory programs
to solve identified WQ
problems
fund proposals which focus
on quality/quantity relation-
ships , if they have a
significant impact on WQ
fund proposals which lead
to implementation of re-
gulatory programs to en-
hance or maintain WQ
fund NFS residuals pro-
posals which will lead
to an implementable plan
to solve identified WQ
problems
"DON'T"
— fund aquifer mapping
— fund monitoring and
data collection unless
they clearly lead to
an implementable con-
trol program
attempt to determine
whether a problem
exists
fund ground water modeling
in general (NOTE: This
is a Category II criterion)
fund BMP handbooks
fund development of non-
regulatory programs
fund planning for coal
mining-related WQ pro-
blems
fund general solid waste
planning
72
-------
Subject "DO" "DON'T"
11. Recreation — In identified 208 projects, — fund recreation planning
Open Space identify recreation
opportunities or potential
areas that may result from
the projects by upgrading
WQ through NFS controls
73
-------
EXHIBIT 5
NATIONAL 106 PRIORITIES FOR FY 81
Improve Management of the Construction Grants Program
EPA stresses improved State management of obligations, outlays,
project completion, priority lists, and facility plans. An
additional priority is State assumption of pretreatment authority
and 205(g) funds to minimize the burden on 106 funding from
construction management assistance.
Develop a Framework for Toxics Control
States should place priority on incorporating toxic criteria
in their water quality standards. States with NPDES authority
should control toxic substances by issuing second-round permits
to primary industries, major secondary industries, and major
POTWs, by implementing the pretreatment program and by enforcing
pretreatment regulations.
Build Water Quality Management Capability
States should develop their toxic analytic capability, including
the purchase of laboratory equipment. Quality Assurance
procedures are mandatory in all projects in which participants
gather environmental data. States should also develop operational
control programs for nonpoint source problems with EPA technical
assistance, especially for ground water, agriculture, and urban
runoff, with special attention to the financial management aspects.
Conduct Effective Permit and Enforcement Programs
In addition to permit and enforcement efforts aimed at strengthen-
ing the framework for toxics control, States should simplify the
permit process through the consolidated permit program; process
selection 301(h) marine waivers; issue energy-related permits;
implement the National Municipal Policy and Strategy; conduct
inspections in support of enforcement cases and emergency situations;
and implement Discharge Monitoring Report (DMR) quality assurance
programs.
Conduct Waste Load Allocation/AWT Reviews
Using EPA guidance (see, for example, INFO 79-98), the States
should establish programs for waste load allocations. States
should prepare priority lists of wasteload allocations necessary
to substantiate inadequate AST/AWT effluent limitations in
accordance with WQM policy memorandum B-8 (PRM 79-11).
74
-------
Respond to Major Environmental Emergencies
To receive a section 106 grant, each State must have an emergency
response program consistent with section 504 of the Act, including
a contingency plan, necessary response capability, authority to
establish a contingency fund and a program to prevent emergencies
from occurring. For further guidance, see WQM Policy Memorandum
B-5.
Protect Sensitive Ecosystems
To protect sensitive wetland areas, States should develop their
section 404 dredge and fill programs as resources allow and work
toward assuming 404 program delegation. In the 404 program,
States should focus on the most environmentally sensitive projects,
emphasizing pre-permit applications, planning, and analysis.
States should also operate a Clean Lakes program to protect or
restore publicly-owned fresh water lakes, in accordance with the
314 Clean Lakes section.
75
-------
Chapter 5
Assistance in the Implementation of
WQM Plans and
INTRODUCTION
Regional Offices are evaluated on their ability to make the WQM
process work — the development and implementation of water quality
management plans, effective and efficient administration of operational
control programs and the improvement in water quality. The essential
tools to manage the WQM program have been discussed - strategies, work
programs and SEAs. This Chapter concentrates on the assistance
necessary to assure work program outputs are completed and WQM plans
implemented. A significant portion of the WQM Program Review focuses
on these activities as an important indicator of the ability of the
Regional Office to organize and direct its resources to make the WQM
program work effectively to solve water quality problems.
The specifics of the assistance required depend on the individual
needs of the program or agency and the ability of the State to
identify and arrange for assistance to agencies involved in developing
solutions to the remaining priority water quality problems (for
example 208 nonpoint source control planning activities) and to
agencies involved in the implementation and administration of water
quality management programs.
A case could be made that the discussion of assistance should be
separated into two distinct elements. The first would concentrate
on those activities necessary to assure that the 106/208 work programs
are executed - toxic monitoring, pretreatment, and enforcement
programs carried out and WQM plans developed. There is a direct
relationship between the Agency (grantee) and EPA. The agencies
— primarily State agencies except for areawide agencies carrying
out 208 planning activities — are funded by grants and therefore
must comply with the conditions of the grants.
77
-------
The other part would involve a discussion of the assistance necessary
to assure that planned problem solutions are implemented and evaluated.
Many of the agencies designated to implement portions of the WQM
plans are not grantees of EPA (other Federal agencies, conservation
districts, etc.) and therefore, if failure occurs all EPA can do to
the Agency is de-designate that agency. It can not hold the grant
as hostage to make the agency comply with its letter of commitment to
implement the WQM plan. Even finding out what assistance a particular
implementing agency needs assumes an extensive tracking system
- which does not now exist.
Why then is the Assistance Chapter not broken into two parts or even
two chapters? First, too many similar activities and needs exist
to make a clear distinction between what is needed to develop and
what is needed to implement and administer a water quality management
program. Second, as the initial WQM plans are approved and the 208
planning effort focuses on filling in the gaps, the clear distinction
between planning and implementation gets lost. As FY 1984 approaches
and a restructured WQM program is formulated, planning, implement-
ation and administration will be integrated into a cohesive WQM
program managed by the States. Therefore, the focus of the Assistance
Chapter is on helping the State manage the WQM process whether the
assistance needed is by a State or areawide agency.
Furthermore, Project Officers and WQM Coordinators need to think
about the WQM program as a whole and get actively involved in making
sure the WQM process works whether it relates to planning, imple-
mentation, operation or administration of the component parts of
the WQM Program.
This Chapter therefore, includes examples of the type of assistance
Project Officers should provide or assist States to arrange, sources
of assistance, and the delivery mechanisms. There is also discussion
of a tool — the Regional assistance work plan — to aid in the
planning, organization and coordination of assistance to meet the
priority needs. Exhibit 5-1 shows in a matrix format the activities
of Regional Office personnel and Exhibit 5-2 shows the relationship
of Regional Office and Headquarters in assisting grantees execute
their work programs and agencies implement the WQM plans.
REGIONAL ASSISTANCE WORK PLAN
An assistance work plan (or an assistance element of a overall work
plan) will aid Project Officers plan, organize, coordinate and meet
the priority assistance requirements of the State or Region. The
idea of the work plan is to anticipate as much as possible the
assistance that will be required over the year and to prioritize
the needs. Unforeseen requests for assistance will occur but the
preparation of the work plan should keep these to a minimum and
assure the highest priority needs are met.
78
-------
Timing
Assistance is provided throughout the year. The work plan should
be drafted and finalized simultaneously with the SEAs and work
programs.
Preparation/Content
The content of the Regional assistance work plan follows the logical
process Project Officers would use to provide or arrange for assist-
ance to an agency. Therefore, the plan should include a discussion
of:
• Problems for which assistance will be
needed; Ideas for technical or managerial
assistance come from a variety of sources
including State and local agency requests,
Regional source control and funding
strategies, State Five Year Strategies,
State/EPA Agreements, work programs,
quarterly reports, mid-year evaluations,
implementation reviews and tracking
reports.
• Priorities for Assistance; There are
probably more requirements for assis-
tance than there are resources available
to meet the need. How are priorities
to be set? By the severity of the
pollutant problem? Conditions to the
approval of WQM plans? Court decrees?
Applicability elsewhere in the Region?
State/EPA Agreement commitments? State/
EPA commitments must be honored.
• Approach to be used to meet the particular
assistance need; Will Headquarters'
expert consultants be used for urban
runoff, groundwater or financial manage-
ment problems, waste load allocations/
toxics controls or for their expertise
in silviculture, agriculture or septic
systems? Will Regional Office personnel
be used or are there other State or
local agency personnel who have been
involved with similar problems? Are
workshops more appropriate to enable a
number of agencies to talk about their
their approaches to resolving the
problems? Or, should the approach be
primarily one of information exchange
and the use of prototype summaries?
79
-------
Delivery mechanisms to be used; Sponsoring
workshops, attending public meetings and
forums, participating in public advisory
committee meetings, working on interagency
or intra-agency committees, directing and
coordinating an information exchange on
prototype projects, research on cost-
effective BMPs, economics of control, etc.
are all effective technical and managerial
assistance delivery mechanisms. In many
cases the best approach is sitting down
with the agency and talking out problems.
This is especially valuable in working
out institutional problems and trying to
find ways of better coordinating Regional
Office programs.
Agencies to receive assistance; Which
agencies are to be the recipient(s) of
the assistance? Who will be involved in
workshops or forums on a particular topic?
Sources of assistance; Who will be providing
the assistance - Project Officers, WQM
Coordinators, Water Division Director,
other Regional Office personnel, Head-
quarters consultants, Headquarters
personnel, State, local or other
Federal agency personnel, other experts?
Who is responsible for ensuring the
assistance is provided on a timely
basis? The sources of assistance will
be discussed in greater depth later in
the Chapter.
Timing of assistance; Workshops require
substantial lead time. Regional and
Headquarters personnel and consultants
have other demands which may limit their
availability to assist an agency; how-
ever, the timing of assistance to an
agency may be critical.
Budgetary impact; Budget constraints are
a fact of life. Look for assistance that
is close and free. Will some other
agency absorb the cost? Should the con-
sulting assistance be included as an
eligible grant cost? How many trips do
you need to make? Is there a cheaper
way for you to travel? No matter how
80
-------
difficult a particular pollutant or
source control problem, institutional
or financial issue may be, finding
cheap, innovative ways of providing
assistance to State and local agencies
may be the most challenging part of the
process.
A matrix is a useful method of structuring and organizing the assistance
a number of agencies may require. Categories of assistance for each
program area (agriculture, urban runoff, etc.) might include:
• Agreements on institutional responsibilities
• Review/strengthening State program approaches
• Water monitoring activities
• BMPs/controls for a particular pollutant
or source problem
• Financing BMPs and control programs
• Sanctions/incentives
• Grantee failures
The categories will depend on the strengths and weaknesses of the Region's
agencies, the priority problems to be addressed, and the program to be
developed and/or strengthened.
The other axis of the matrix chould be either the sources of the
assistance or the recipients of the assistance. A cut both ways is
useful. From the matrix the assistance can be categorized and summa-
rized for the work plan; the "type" of assistance to be provided,
who provides what type of assistance to which agency, and the type and
source of assistance each agency is to be provided.
Preparation of the work plan needs to be coordinated through the
Division Directors since various parts of the WQM Program are scattered
throughout the Regional Office as are the personnel who can provide
the assistance. WQM Coordinators and Project Officers will have to
prepare their own work plan for the overall assistance work plan. The
work plan should guide most of their activities and be the basis of
their performance agreements.
The Regional assistance work plan or appropriate portions thereof
should be forwarded to the grantees and agencies receiving assistance
as well as to agencies providing the assistance.
81
-------
TYPES OF TECHNICAL/MANAGERIAL ASSISTANCE
There are many activites — some very simple, others more spectacular
which smooth the WQM process. Some of the activities and approaches
suggested below may be more appropriate to one problem or agency
than another. They are neither mutually exclusive nor all inclusive.
A combination of activities and approaches will have to be developed
to meet a particular agency's needs, based on commitments made in
the State/EPA Agreements, special requests, or just common sense.
Agreements on Institutional Responsibility
The first step for State and areawide agencies in implementing
solutions to water quality problems is developing agreements on
institutional responsibilities. State and areawide WQM plans identify
agencies with the authority and capability to implement all aspects
of the plan, and the Governor designates these agencies as WQM
management agencies. The planning agency and the management agency
develop a long-term agreement detailing the steps each agency will
take to implement the plan, and a schedule for doing so.
Generally, different institutions handle different problems. States,
Cities, special service districts, or interjurisdictional compact
agencies normally handle municipal waste treatment problems, while
soil conservation districts or county governments are more likely
to handle rural nonpoint source problems.
No single entity needs to have all the authorities, resources and
capabilities to carry out the program. A combination of agencies
may meet the requirements. However, as the number of agencies
multiply the coordination linkages become more important. Greater
care must be taken in the development of the management agency
implementation agreements to ensure that the program as developed
and approved is implemented. The prerogatives and jealousies of
competing levels of government will make this task a challenge.
The simpler the structure the easier it will be to work out the
agreements on the roles and responsibilities of the agencies. These
agreements are particularly important because the commitments and
milestones outlined in the agreements should be included in the
Significant Implementation Agreements. They are the criteria for
evaluating whether WQM plans are being implemented.
Review/Strengthen State Program Approaches
Regional Offices are involved in assisting States in the develop-
ment, review and revision of their antidegradation policy and water
quality standards; inclusion of toxics and wet weather flow criteria
in water quality standards revisions; development, review and revision
-------
of wasteland allocations; review of the consistency of 201 grants
to the certified and approved facility portion of a WQM Plan; review
of Clean Lakes applications and review and/or issuance of permits.
Enforcement is generally the responsibility of the permit-issuing
agency, and is a critical part of implementation. As with other
aspects of the process, it is necessary to set enforcement priorities.
As a rule, enforcement aims first at chronic violators, major dis-
chargers, and potential dischargers of toxic substances.
In addition to permit based regulatory programs for point source,
there are other regulatory and non-regulatory approaches for non-
point sources. Such programs are generally State or local initiatives,
and many states and local governments are planning such programs
through the WQM planning process. For EPA to approve a nonpoint
source regulatory program in a WQ M plan, such as a permit, license,
or bond program there must be adequate authority to control the
problem, monitor activities, and enforce the program. The designated
management agency must have adequate expertise, staff, funding, and
authority to run the program.
In the absence of regulatory programs voluntary compliance programs
may work (or already by working) to control pollution. Such pro-
grams usually depend on education, citizen involvement, self-
monitoring and other programs to assist in the implementation of
controls. Clean Lakes projects, in conjunction with USDA cost-
share and technical assistance programs, have effectively stimulated
implementation of agriculture nonpoint source control programs.
For EPA to approve a non-regulatory program in a WQM plan, the
Regional Administrator must determine that there is a reasonable
degree of certainty that it will result in implementation of needed
controls and achievement of water quality goals. Usually a period
of time is given — three to five years — to evaluate whether the
non-regulatory approach will work.
Water Monitoring Activities
Most State water quality monitoring programs are directed toward
point source pollutant problems. Less is known about toxics and
nonpoint source pollutant problems — their transport, fate and
impact on instream and riparian biota. Standards and criteria
generally are applied to low flow conditions while nonpoint source
pollutant problems are primarily connected with storm events and
have their greatest impact in the first flush. This Manual will not
tell you how to design a nonpoint source or toxics monitoring pro-
gram, conduct an intensive survey nor how to make point and nonpoint
source tradeoffs.
83
-------
Some guidance is available and more is being developed. The proto-
type projects in agriculture monitoring and evaluation and urban run-
off will provide valuable information on the design of less costly
monitoring techniques. As information becomes available it should be
facotred into a State's monitoring strategy. In many cases States
could do a better job of identifying and determining the source and
impact of their toxics and nonpoint pollutant problems. Project
Officers should make States more aware of the need for toxics and
nonpoint source pollutant monitoring data and analysis and ensure that
the S&A Division and Headquarters assist States improve their cap-
abilities.
BMPs/Controls
Although cost-effective BMPs exist for some problems, such as con-
struction runoff and failing septic systems, structural and non-
structural BMPs for such problems as urban storm runoff, ground-
water contamination, and agricultural runoff are not fully tested.
For this reason, designated State and areawide WQM planning agencies
are testing BMPs in prototype or pilot projects. Some of the BMPs
being tested are detention basins and street sweeping, irrigation
systems which reclaim waste water and erosion control barriers.
When complete, the prototypes will provide a technological basis
or control which EPA can then transfer to States and areawides
nationwide.
The prototype projects also test the financial, institutional, and
political aspects of controls. State, areawide, and local planners
work with local elected officials and the public on institutional
arrangements, public support, and sources of funding for selected
controls.
Although there are many non-structural solutions to water quality
problems, in some instances construction is appropriate. The 1977
Ammendments to the Clean Water Act provided an incentive for
innovative and alternative treatment works, by raising the Federal
share of the cost of such projects from 75 to 85 percent. Innovative/
alternative projects are those which reuse or reclaim wastewater,
recover nutrients and other pollutants in wastewater or sludge, or
conserve or recover energy.
The Agency needs to emphasize alternatives to building waste treat-
ment plants and has developed a Strategy to improve the performance
of small and alternative wastewater systems to meet the total waste-
water needs, not just specific requirements of the 201 and 208 programs.
Funnelling information on what has worked and what has not worked
and why, is valuable assistance to State and local agencies. What
are the most cost effective BMPs? How did an agency approach a
particular problem? Project Officers should keep abreast of the
prototype projects and disseminate the information obtained from
these projects to State and local agencies within the Region.
84
-------
Financing BMPs and Control Programs
Fiscal management analyses and how the BMPs in the WQM Plan are to
be financed are prevalent problems. BMPs will not be accepted and
may be counterproductive, if they are too burdensome on the person
or entity required to implement them. Little fiscal management
analysis was included in the initial water quality management planning
effort. State and areawide planning agencies need to identify
taxpayers, develop sound plans to defray the costs, and attempt to
motivate community action to implement the plan. Ad hoc requests for
funding, or over-reliance on Federal funding are not suitable long-
term substitutes for effective financial planning.
In response to the need for improved financial planning and analysis
for water quality management at all levels of government, the
Financial Management Assistance Program (FMAP) through expert con-
sultants, assists State and local agencies develop systematic
approaches to financial management and budgeting to implement con-
rols. The consultants assist agencies develop the true costs of
implementing controls in order to set user charges or permit fees.
The case studies of the prototype projects selected for intensive
FMAP assistance should be widely distributed to agencies with similar
problems.
Several States have cost-sharing programs to assist farmers apply
agricultural BMPs, as in Kansas, Illinois, Iowa, Nebraska, Wisconsin,
Minnesota, Ohio, South Dakota, and Washington. These programs should
be studied to assist State personnel develop legislative proposals
or a cost share program where none exist.
Financing the education information and technical assistance necessary
or an agricultural WQM program may also be a problem. USDA agencies
do not always have sufficient field personnel to adequately cover
all the needs. Some States have provided additional funding to
conservation districts to hire staff to provide the technical
assistance. These approaches should be brought to the attention
of State agency personnel especially if continued funding is a
condition of approval of the WQM plan. You may have to collect the
information, and arrange for agencies that have used a particular
approach to talk with your State as well as prepare a draft proposal
for the State to consider, review, modify and potentially adopt as
its own.
Sanctions/Incentives
Where attempts to solve water quality problems have failed, EPA or
a State may wish to apply sanctions. Sanctions may be against a
single discharger, a local or areawide agency, or the State itself.
85
-------
If a municipal or industrial discharger violates its NPDES permit,
the resulting sanction is a fine or withdrawal of a permit. Dis-
chargers may be subject to both civil and criminal penalties for
polluting. (Note that EPA or the States will not usually impose
sanctions aganist municipalites that are too far down the priority
list to receive construction grants to correct their problems).
Here we are more concerned with seeking incentives as alternatives
to sanctions. One example is the "payment in lieu of a fine", where
a discharger/operator faced with a fine may contribute to the
solution of an environmental problem in lieu of, or in addition to,
a fine. Other examples are Small Business Administration (SBA)
loans, accelerated tax write-offs for industrial/commercial
pollution control, awards and honors, and grants from discretionary
funds as rewards for superior performance. EPA's 75 percent Federal-
share construction grants program is an incentive for implementation
of solutions to municipal waste treatment problems, as are Section 314
Clean Lakes grants for lake restoration and USDA's cost-share programs
for agricultural nonpoint source controls.
Failure to carry out elements of a work program which do not con-
stitute a grantee failure (covered below) needs to be identified
through the quarterly report and/or mid-year evaluations and
corrected. Sanctions for failure might include withholding a portion
of the grant or reducing the following year's grant.
If a management agency designated to implement a certified/approved
WQM plan fails to carry out its agreed-upon duties, the State may
withdraw the management agency designated and transfer the authority
to another aency or the State itself. In extreme cases, EPA could
rule an agency not deserving of public trust, which would exclude
it from all federal funding.
Finally, if a Regional Administrator feels a State is not implementing
its certified and approved WQM plan, he or she may rule that the
State's Continuing Planning Process is inadequate and withhold
State assistance or revoke its NPDES delegation, if any.
Grantee Failures
This Chapter assumes that technical and managerial assistance will
be concentrated on issues generic to the pollutant problems or
sources. Nevertheless, there may be occasions where an Agency's
technical and managerial needs will be so great as to question the
capability of the agency to fulfill the obligations of the grant.
If this problem does occur, efforts should be made to assist the
Agency complete as many outputs as possible so as not to threaten
the integrity of the grant. However, the Agency should not be funded
again and the criteria used to evaluate the capability of an Agency
to accept a grant should be tightened.
86
-------
SOURCES OF ASSISTANCE
In addition to Regional Office and Headquarters expertise, the
resources of other Federal agencies and private industry should be
used in developing an assistance package.
Umbrella agreements as well as individual agencies agreements open
the door to the financial and technical resources of the U.S. Department
of Agriculture and U.S. Department of the Interior, Tennessee Valley
authority, U.S. Army Corps of Engineers and Economic Development
Administration. All of these agencies have been involved in and
have supported WQM activities. The most successful examples of
cooperation have been those where the WQM Coordinator or Project
Officer is actively involved with the Federal and State agency,
such as preparing applications for special project funding. Federal
agencies should be encouraged to seek designation as the management
agency for WQM activities on their own lands. Headquarters can
encourage Federal agencies to seek designation but the ground work
must be laid by the Regional Office. Some examples of the WQM
activities in which Federal agencies have participted are listed
in Table 5-1.
The private sector especially large corporations may be willing to
cooperate in special projects if they are made aware of the project
and asked to participate. Mining companies have joined in Category
1 groundwater projects and the forest industry in testing various
BMPs on its lands. More should be done with the construction in-
dustry. Companies are required to widen roads, donate lands for
open space as a condition of development. Why not involve them in
testing different types of sediment basins, different configurations
of basins to minimize O&M costs after the development has been
completed, and the development of alternatives to sediment basins?
87
-------
TABLE 5-1
FEDERAL WQM ASSISTANCE ACTIVITIES
U.S. Department of Agriculture;
Agriculture Conservation and Stabilization Service: ACP fund-
Ing for BMPs; Special ACP Projects; Model Implementation
Program (MIP); Rural Clean Water Program (RCWP).
Extension Service: Integrated Pest Management (IPM) program
technical assistance in the development and implementation
of BMPs.
Forest Service: Technical assistance in planning for a
silviculture element of a WQM plan, and in the implement-
ation of BMPs; development of BMP handbooks; training; and
designation as the management agency responsible for BMPs
on national forest lands.
Soil Conservation Service: Technical assistance in the develop-
ment and implementation of WQM plans; technical assistance
in ACP special projects, Model Implementation and Rural Clean
Water Program projects.
U.S. Department of the Interior;
- Bureau of Land Management: Delegation as the planning agency
for sane of BLM lands; coordination and assistance in the
preparation of 1JQM plans; development of BMP handbooks;
inclusion of BMPs as a condition of leases; designation as
the management agency for BLM lands; water quality monitoring
and participation in STORE!.
- Bureau of Mines: Coordination and Information on mining
activities Including economic analyses.
- Fisih and Wildlife Service: Instream flow and water quality
recjoirements for acquatic and riparian biota; assistance to
States to develop State operated 404 programs.
Geological Survey: General monitoring and data collection
for both surface and ground waters; acqulfer mapping;
technical assistance for urban runoff data collection,
anatlyses, and modeling, etc.
Heritage Conservation and Recreation Service: Recreation
benefits of Improved water quality; urban recreational
initiatives including requirements under section 201(g)(6)
of CWA and use of State Outdoor Recreation Plans.
- National Park Service: Innovative waste treatment
facilities for isolated park areas; coordination of /irk
planning activities with the development of WQM plans.
Water and Power Resources Services (Bureau of Reclamation):
Irrigation scheduling; Improving water delivery efficiencies;
retrofitting dans to improve water quality below dams (DO
levels; supersaturation problems); modification of
operations at dams to relieve surface and ground water
problems .
Tennessee Valley Authority; Technical assistance in rural and
urban nonpoint source control; designation as the management
agency for TVA dams, reservoirs and lands; development and test-
ing of cost effective BMPs to control water quality problems
(DO) below TVA dams; inclusion of BMPS as a condition of a lease.
U.S. Anay Corps of Engineers; Contract with EPA to oversee the
design and inspection of the construction phase of waste water
treatment plants; evaluating the impact of their dam operations
on down stream water quality; urban studies.
Economic Development Administration; Title V EDA funds have been
used to supplement ACP funds in special projects.
88
-------
It Z
n t)
n w
•
o
o
S.
^te
3
B
rr
O
1
B
PS
^
f*
O
1
0.
p.
3
B
rr
O
a
8
P!
l<
1
f
rt
It
ft
O
^
^
B
O
3
3 o
Z 1
H a
n jo
v •
' ?
en
rt rt
B O
rt, O
B.
1 H-
3
n B
3 rr
< 0
h* 1
n a
o
§
it
3
rr
B
H"
CO
r»
A
3
rr
H«
a
rr
B
O
G rr
en —
a re
> n
V
C (t
en c.
D It
t~H 1
- B
M
•-5
> n
- it
3
M 0
O r»
> It
- B
1
.°'\
a i
PI
'S
*3 t Z
1 B n D
rl
0 rr
H> H-
< n
H. H- V
a -a
r* B
O rr
3 It
i
e >-
1
It B<
O
rr B
O CO
rt
»
•a ••
•o
1
o
•e
B
rr
It
^
a
X
i
<
90
t
I
3
0
3
B
A
f
-t
M.
rr
<
SIS10
2J I 5^
•« i
•
O CO
• ^ c
B <
It
1 H-
H' H*
O B
O
B- (t
S3 PI
O
06 >
3
hfl jj
0 ><
<_>. B
It M
n a
rr
o
H>
P-
n
it
n
B
It SJ
rr O
O i—
• •"
O
£»
V
D
rr
ro
n
en
c
13
•o
?
1
O
35
•O
>
O
rr
it
n
iO
)S
1
t
S
O
>-ri
i-r,
O
It
a
Respond
Grantee
rr
O
equest for Assistance
o
a
*
Initiate
Based on
Year Eva
Agency E
< M
pi c pa >•
C rr ow
papoz
OH
M M
n>
CO
PROVIDE OR ARRANGE A
NFORESEEN ASSISTANCE
1°
t-H
0
fr]
P3
\\\
\\ \
ro oih-(
CX01O
i-l 01 H-
pi pro.
Mpiro
>o >
OS (fO
ro TJ
3 T)^
O MO
H-P1T3
rt 3 ^
01 H-
rr pi
O rt
ro
O
1 "d
PI O
3 4
rt rr
ro H-
ft O
PI 01
3
0,0
O
rods
1 H-
o
M
^
» *
O
*
a a ro
0 H-
• wro
ro o
HOPl
i-hi-l 3
O-O 0.
3°>
pprove Region Assista
ate Appropriate Plan
ance Agreement
MS
MO
rt ro
ft *^a
3 M
rt PI
CD J3
?*
O
„.
Coordina
and Meet
Assistan
n HTT
ro 3 ro
OS
rr 01 Pi
nd Participate in Dis
to Define and Negoti
o Grantee
01 O
rre
ro 01
01
H-
o
3
01
£-
sA
*
L
\
\
\
o
ro
rr
ro
H-
3
ro
en
o
C
o
01
o
Hi
01
H-
01
rt
pi
3
O
ro
*
Identify
ments Du
Work Pro
OS H
n H-PI
» a a
3crs a.
Prioritize Assistanc
Development of Stral
is and SEA's
ro it
OS
H-pa
(B (D
v C
^
i
»
1 PREPARE
m
o
:ONAL ASSISTANCE PLAN
\\\
\\\\
\ \ \
k \ \ \
\\\
K^
l\\\
^
1
\\\\
\v\\
n
§
ACTIVITY
o
o
o s
B
en H f
t-3 W O
> n z
"3 Si
ij .
o *s o
S'2 w
en S
III
h-t P
PI r
en
POSIT]
3
Z
en
M
••B
O
Z
en
M
BJ
PJ
J0~t
t~3 N"J
poco H;
rt
N3
£2 -T]
H3 •*]
PBO.K
H
p-i
M
1 o
H *"3
pOl ><
0.
H ~2j
parr,*
i
I
s
HI
M
ft
en
M
en
H
in
-------
EXHIBIT 5-2
SUMMARY: ASSISTANCE ACTIVITIES
W
0
3
EH
C/3
M
C/2
cn
•0
O
z
M
p
M
>
0
PH
PH
«D
O
z
H
z
M
S
PH
H
EH
H
P
Z
M
P
H
§
O
C"H
PS
H
PH
W
«
8
w
w
M
EH
M
>
M
EH
0
<
P
fe
•<5
iJ W
<
W MH
O Zc/)
2ww
SH«»!
1 (A
Z W
Mg
P OCA)
z w
< pa i-i
Po
ZMZ
OtiW
H q
EHH<:
W
Oi-JP
OOW
CJ>PH
z
o
M
StI
°*5
MCrf
HO
<:w
SZH
MO O C
CO-H V4 0)
p 6ocx B
Bpd c co 60
O4J CO
•a o o e
e 4-1 co cu 01 vi co
to oi-i-i cu f-i cu B
OI 01 O IH 3J-1 O)
rH O 4J )J 34-1 cOiH O
CO C C O- 4J,H:2 CO C
O CO CO i-H 3 -H CO
1-14J tJ 01 3 OT3 O 4-1
c coo P. O-H e c to
4T.-H >*H-H > 3 CO-H
O COT3 4-lS (Jr-l O (3 CO
cu to c op OO-H VJ-H co
HcOc04JZ 43
cu e
P 3
73 CU
C 0
cO C C
CO O
H4J-H
CO CO 4J
O-H CO
•H to e
C CO (H
43 CO O
O >4-l
CU4-1 C
4J q!-H
CU 01
oi B oi oo
T3 OIT3 d
•H 60^-1 CO
> CO >43
O C O 0
t-> to )-i X
PH BPn CU
• •
I
•H T3
to co c
e cu co
O -H
O, CO 4-1 CO
CO OI-H v
0) 43 > OH CO
P O-H g 0
co 4-1 pq co
i-H O O Vl
CO Vi CO in 00
CO. O 0
O CX60 M CO
•H CO C 60 O-O)
4J to -H (3 >
3 CU 0 P -Hi-t-H
4-l-H CO O O O4J
•H4-1M4JCOC ^C
4-l-H OOHv CO 4J 01
COrH O CPn C CO
(3-H n OS-H o p
M43pHj£tt>Pt< CJM
• • • • • •
s^aiHvnbavaH
CX CO CO
O 0) -
^-1 C043 P-, |
0) 0) O SO
> -H CO « M
CU 1-1*4 O CX
t) CO-H M MH
PM O. Oi-H
0) O-H D.OOtO O CO
4-1 •• -H43 CO C CU 60»J 0)
CO OI 4-l-H -H-H C 4J >
4-l>3C00V44-l -HP -H
CO O 4J P CO O-H CJ O 4J
U-HO>-liJ> COCOtOp
4-1 CX 4-1 CX 60-H -H » CO B CU
C00 (OCOOp4JpjpIOCOO
•H-H C 0) >-l O CJ g-H p |H a
CO M M PH S CO CO PL, CO 6CK-I
CO I-l
O 0 1 II II 1
.
1
01
^ 00
O CO
P (Up
C OI 4-1 CO
•H 00 CO 6
CO CO P
4-1 60CO
43 iH -H CO
O CO CO
VH 0) CO
CO 0) T3 01
OI T3 -H
OI 01 CO O CO
4-1 14-1 CU p CU
P 4-1 CU-H
CO 01 OI CU CO OOO
)J O 4-1 O 4-1 CO P
O P CO PCO OI
CO P CO i-H 00
4J 4-1 -H 4J 4-1 CO CO
CO CO T3 10 CO |J
-H-H IJ-H-H CU 4J
CO CO O CO COT) P
CD tO O CO CO 01 OI
< to O CO-
O CO 1
01 C -H
P-H O 0)
T3 -H 4-1 Ol
CU IJ 4-1 i-l CO 00
O O M CO CO p p
p o to exp -H co
tO O CXO O T3 43
4-1 43-H M CJ
0) (-i M CO 4-1 OX
•H O O CO O 0)
CO \,i! P O
CO CU T3 I-i P
COT3 d O 01 0) T3 O
•H CO ? 4-1 0 d-H
X> tO d CO 4-1
4-1 O 4-1 p (3 CO CO
•H IJ O-H-H 4J 4-1 g
4-1 eX 3 T3 CO O H
d T3 CU U-H 0) O
ona p 4J o co pm
T3P OcOOtO-HP
H CO O PO CO P-H
• • • •
^
iJ
01
o
p
CO
4J
CO
•H
CO
CO
CO
•H
CO
d
o
•H d
00 CO
Oli-l
cri cx
30I.MO 1VNOI03H
01
o
0) P
O CO
P4-1
CO CO
4J-H
CO CO
•H CO
CO CO
CO
CO CU
4J
4-1 CO
CO-H
0) 4-1
3 0
croo
cu cu
PiZ
• •
0)
o
01 d
o to
d 4J
CO CO
4-l-H
CO CO
•H CO
10 CO
CO
CO 0)
4-1
4-1 CO
CO-H
01 4J
3 0
croo
01 O>
rtZ
• •
OI
o
01 p
O CO
C4-1
to co
4J-H
CO CO
•H CO
CO CO
CO
CO CU
4-1
4-1 CO
CO -H
01 4J
3 O
CT60
01 01
PiZ
• •
aiviHdouddV sv
saaiMvasv/saivis
90
-------
Chapter 6
Evaluation of Progress
INTRODUCTION
Evaluation is a key element of the management of the WQM program.
Evaluation establishes the feedback loop in the WQM problem-solving
process to keep management, planning and implementation moving in
the right direction. Regions must evaluate: (1) progress against
work programs ({106 and 208 WQM activities); (2) progress in imple-
menting WQM plans (and designated management agencies, if appropriate)
and significant implementation agreements; (3) the adequacy of the
WQM plan and State Continuing Planning Process; (4) the consistency
of State actions (permits, construction grants, etc.) with WQM plans
and problem assessments, State strategies, and State/EPA Agreements;
(5) internal Regional performance and the support of Headquarters
for the WQM program. State and areawide agencies must evaluate
similar elements. Theoretically, evaluation is the comparison of
actual performance or status against clearly stated goals, objectives,
output measures and cost limits. Thus, evaluation depends on an
understanding of what is required and desirable.
Evaluation activities weave through the problem-solving process,
and break down into the following general areas: evaluation of out-
puts, water quality trends, institutional aspects, and internal
performance.
This Chapter discusses the elements to be evaluated and the tools to
manage the evaluation activities, such as the quarterly report, mid-
year evaluation and the WQM program review. Exhibit 6-1 shows
91
-------
Regional Office evaluation activities for each of the elements to
be evaluated and Exhibit 6-2 shows the relationship of Regional
Office activities to Headquarters and State evaluations.
DOCUMENT CITATIONS
AO CFR 35.1513-8
40 CFR 35.1521, 1523, 1525, 1527
Supplemental Water Quality Management Program Guidance for FY 81,
June, 1980.
POLICY SUMMARY
• Each year the Water Planning Division is to conduct a program
review of the Region's management of the WQM Program. The
Report documenting the program review will be forwarded
to the Regional Administrator from the Assistant Adminstrator
for Water and Waste Management.
• At an appropriate mid-point in the program year, EPA (Regional
Office) shall conduct an evaluation meeting with each State
and areawide agency to review and evaluate the program
accomplishments and to discuss work projected for the coming
year.
• EPA (Regional Office) shall prepare a written report of each
evaluation, forward a copy to the grantee (and the State where
the grantee is an interstate or areawide agency) and notify the
public of the availability of the report.
WQM EVALUATION ACTIVITIES
Evaluating Outputs
There is a distinction between "review" for day-to-day management
purposes and the "evaluation" of WQM management activities. Permits,
construction grants, WQM plans, facility plans, Clean Lakes
applications and other plans (such as State Implementation Plans
for air quality) are reviewed to ensure they are consistent with
each other and with all relevant laws and regulations. There are
different ways of reviewing outputs. The construction grant pro-
gram uses the Corps of Engineers to conduct inspections at con-
struction sites, to evaluate plans and specifications and to monitor
construction progress which eases the burden on EPA. Program
activities are reviewed so outputs are consistent not only with
the Clean Water Act, but also with Presidential directives and other
major environmental legislation.* Many laws have built in consistency
requirements, such as the requirements of sections 176(c) and 316
*For example: Clean Air Act, Safe Drinking Water Act, Resource Con-
servation and Recovery Act, Toxic Substances Control Act, National
Environmental Policy Act, Wild and Scenic Rivers Act.
92
-------
of the Clean Air Act and sections 208(d) and (e) of the Clean Water
Act. These are essential activities for program management pur-
poses. Evaluation, however, is the determination of whether a pre-
determined standard has been met.
Regions are required to meet annually with the States and areawide
agencies to determine how all parties have performed against the
commitments they made in their work plans and State/EPA Agreements.
These reviews focus on completion of quantifiable outputs, and lead
to midcourse corrections or adjustments to subsequent years' work
plans. The mid-year evaluation must include a review of the agency's
compliance with its public participation work program and the
requirements of 40 CFR Part 25, especially 25.12(a)(2). In con-
junction with mid-year evaluations, Regional Offices may wish to
conduct an implementation review site visits to determine how well
WQM plans are being implemented and commitments in the Significant
Implementation Agreements are being met. There is also a need to
look at whether the program designed in the 208 planning process is
adequate to control the problems for which it was prepared or whether
additional 208 planning efforts are needed to prepare a fully
operational control program. Identified weaknesses should be incor-
porated into a State's Five Year Strategy, the State/EPA Agreement
and work programs in order to resolve the problems.
Quarterly reports are effective tools to monitor progress through-
out the year and to prepare for mid-year evaluations. The timing,
content and format of the quarterly reports should be determined
during the development of the work program and incorporated into the
work program. The Quarterly Report should contain:
• Expenditures to date
• Summary of project or program activities
against the projected outputs (for example,
Class II inspections completed, permits
issued, BMPs, tested, etc.)
• Identification of the causes of the variances
and the impact of the problems on completing
the projected outputs
• Summary of the technical or management assistance
provided
• Identification of technical or management
assistance required
• Changes in roles, responsibilities, authorities,
resources of the agency which may impact
progress
93
-------
• Progress of designated management agencies in
meeting their projected outputs agreed to in
the management agency letter of commitment
• Progress in meeting the commitments agreed to
in the Significant Implementation Agreement
(part of 208 work program)
Using the quarterly reports, Project Officers should prepare for mid-
year reviews by working with State and areawide agencies on the
timing and procedures for the evaluation, scheduling slippages, and
the reasons for them, prior to the meeting.
Documenting the mid-year evaluations is a report prepared ,by the
Regional Office and sent to the grantee (and the State where the
grantee is an interstate or areawide agency). The objective of the
Report should be to assist grantees improve their management of the
program or project. The Report should be written in such a way as
to identify the issue, identify the affect or impact of the issue
(e.g., problem created), and identify potential solutions to the
problem or issue (its preparation might be considered a self-evalua-
tion. The Division Director, Headquarters and others will evaluate
these as well as the performance reported on).
The problems, issues and solutions identified in the mid-year
evaluations are to be factored into the design of the strategies,
State/EPA Agreements, work programs and assistance plans for the
following year. If an approach is not leading to the implementation
of a control program or the solution to a problem, it needs to be
changed.
Project Officers should work with their States to ensure that States
have an internal process or procedure to evaluate their WQM pro-
gram activities. Given the WQM program's emphasis on implementation
of controls for specific problems, evaluation of designated manage-
ment agencies is a key component of a State's evaluation system.
Management agency evaluation is a State responsibility and should
be included in work programs. Management agency evaluations start
with a comparison of management agency letters of commitment to
actual progress or outputs.
Evaluating WQM in Terms of Water Quality Trends
The ultimate test of any environmental program is whether it meets
its overall objectives of environmental protection. For water
programs, this means protecting or improving water quality in such
a way that problems aren't simply transferred to other media — the
air and the land.
94
-------
Through monitoring and other observations, EPA, the States, area-
wide agencies, local agencies, and the public continuously evaluate
water quality. Is water quality improving, staying the same, or
going downhill? Are numerical criteria being met? Are designated
stream uses justified — or are they too optimistic or pessimistic?
Is stream biology healthy? Is ground water being protected from
overdrafting and contamination? Are residuals properly disposed
of, recycled, or reused? And finally, where problems exist, what is
causing them?
Because pollution is a dynamic problem trend analysis is a key part
of evaluation. One key variable in trend analysis is population and
economic growth or decline. It is possible that, in some instances,
population and economic growth could cancel out improvements in
water quality achieved through the problem-solving process.
State, areawide, and local agencies should evaluate the impacts
of population/economic growth on domestic waste generation, in-
dustrial waste generation, sediment production and transport,
pollution from nutrients and pesticides, ground cover, land use,
water demand and withdrawals, and any other factors. The build-up
of toxic pollutants in the environment and in aquatic life, partic-
ularly fish and shellfish, is a trend which should be monitored.
Conclusions reached should be documented in the State's 305(b) Report.
Conclusions from water quality monitoring should be factored into
the "problem assessment" and priorities for WQM activities in such
a way that evaluation of WQM against improvements in water quality
can be made. Headquarters will be looking for such provisions in
work plans and State strategies as well as in mid-year evaluation
reports.
Evaluating Institutional Aspects
When assessing the causes of water pollution and developing and
implementing solutions to the problems, it is some times impossible
to separate the technical problems from the related institutional
and political problems. Thus EPA and agencies must evaluate the
institutional aspects of the WQM programs and the framework for
managing the WQM program. Mid-year reviews of State and areawide
agencies are an excellent forum for evaluating and if necessary
recommending solutions to institutional problems.
Two areas on which the Region may wish to focus are the Continuing
Planning Process description and the designated management agencies.
WQM regulations 40 CFR 35.1509 and 40 CFR 35.1521-3(c) and 40 CFR
35.1527 provide guidance and criteria for evaluating the adequacy
and effectiveness of the Continuing Planning Process and the
designated management agencies.
Does the Continuing Planning Process (CPP) description reflect
changes in State or Federal laws, State organization, procedures
or framework for managing the WQM program? Is there sufficient
95
-------
authority to control the pollutant sources? Is there adequate fiscal/
financial expertise. Are salary scales, staffing and training pro-
grams adequate? Is the monitoring and enforcement programs
satisfactory? Are activities coordinated? Do the responsible
agencies understand the laws and regulations? Is EPA guidance
appropriate? Is the agency encouraging and providing for public
participation? Is the public involvement broad-based and does the
public support the agency's actions?
Questions such as these set the tone for institutional evaluations.
Depending on the answers, the agencies involved should revise the
Continuing Planning Process description and take corrective action
in the areas of management, planning, legislation, and training.
Progress should be tracked to ensure that the corrective actions are
implemented.
Evaluating Internal Performance
Although regulations do not require it, each State and areawide agency
should conduct an internal review to determine where to raise skills,
improve efficiency or change the distribution of resources.
Regional Offices also need to conduct internal program reviews. How
well is the program being managed? To ensure that EPA's management
of the WQM program effectively supports the activities of the State
and areawide agencies, Headquarters has recently initiated a WQM
program review. The review will cover progress toward implementation
of WQM plans, development of operational nonpoint source control
programs, and improved management of the 106 grants. It will provide
a qualitative evaluation of the effectiveness of Headquarters and
Regional Office management, identify problems and issues, recommend
alternative solutions, and disseminate information on problems,
issues, and solutions to other Regions.
Evaluation is not an end. The recommended improvements must be
implemented, programs and priorities adjusted, products improved,
control programs perfected. Evaluation as a process is incomplete
unless factored into each step of WQM process and WQM Framework.
problem-
Assessment
Evaluating
Progress
Implement
Work Programs
WQM pi a
develop
Stratigies
Make A
Commitment
(SEA)
Prepare
•Work Programs
96
-------
Ic
i
ff
rf
ft
n
O
p-
p.
B
O
3
01
O
1
e
p-
p-
B
p-
O
3
0
n
o
rt
o
n
I
B
h|
rr
O
H* *
•o
B
rt
(C
p-
rti
B
B
B
•O
•O
1
O
*
•«
3
1
•«
?d
!B
O
M
9
3
B
h*
0"
h*
•*
n
•<
£
n
PI
§
•e
It Z
rt fa
O CA
'§
O.
p-
a
B
rt
O
B
«
^i
p
H
rc
o
«
M
rt
B
frti
|
re
3
PI
ri
i
a.
^
3
B
rf
O
1
*
B
pi
It
3
rt
B
cn
r>
it
a
rt
p-
B
B
C
CA
O
"
C
CA
M
H
>
V
PI
O
w
O
^
f>
•£
•
§
h|
0.
H*
3
B
rf
O
B
O
rf
-f
It
h|
"fl
It
B.
It
hi
B
^
X>
re
B
n
h*
re
a
I
1
hfl
O
s
a
1
O
ff%
to
0
oo
o
re
o
rt
0
HI
o
re
i
B
B
rt
(C
sr>
\
n
^
it
p-
M
B
3
O
It
tf
S
B
B
P-
B
O
1
O
h-
^
O
re
rt
o
•
ro
0
H^
»
73
n
^»
w
^
D
rt
re
1^
en
C
•a
•o
h-«
^
rf
3-
It
1
"a
h|
0
tn
i
B
g
o
H
0
It
B
1
f?p-
1X9 «
P-0
O 6
am
u
•D
It SO
MIC
oo
3 rt
It
O.M
rt
OB
B C
a P>
rtrt
13
•O
O
hi
B
rt
*
\
\
\
g»°
T3 rt
O B
hlP.
rta
a
B
o a
a a.
HSO
r-l It
3 P-
ait
a «
B?
rtp.
=rrr
It 0
X 1
p>
(S3
It 09
0
(t-O
O
< rt
P-
B a
o-o.
M
It
If
*
3
ALUATE
S
\\
tt
y\
Vs
Vs
vv
\v
\\N
\V
1
o
scuss
pQ
1
S
rt
a1
1C 13
a CA-O
rf O hi
MO
B'C'O
rtM
C'O'B'
rtS rt
C a 1C
1C rtB
o re
£ re
OB h|
rt B
re rt
a rf 1C
a-re
1C
rt
H0
•3 o.
B It
O rt
It It
a
*
"" a
termin
Output
B re
$.Q
re
h|
B Hi
30
re <
B
p-
?§
o"n
o re
o a
a
rt«
i re
B rt
ss
o re
1 3
B
h-1
B
a
*
\
"§?
MP-
O C
»•§
B«rt
s. Quarter
Managemen
ft M
-------
^ro-
•o
v H
__ c^O*
C?
Z
M
M
H
T)
v H
v H
SO
M
CO
O
CO
Cd
Z
O
M
H
M
CO
O
O-i
CO
i-3 W
«£ M
at K to
Sd td Z
sou
H td O
C5 P** ^C
5 ^
W 0 M
ll£
o ft< o
x u «c
0-td H
!» H W
CO
^
•
X 0
o- •
? PM
o
Q
f4
C-l
H
M
H
^^
•K
Jj
o 6
CU CO
tJ l-i >-i
p-H «)
CUO O CO
H t-t C "60
)J CO CO CU
O ^> UfA
H cd
C S M4J
•P 4J C
u coco 0)
•O co B
4J 3 CU 3
C co 3 o
Oi-l 4-1Q
p co
CO OW
x) X co
(Ur-l C
CO CB OT3
cd C-H c
pa< 4J co
CO
£-{
o
td
p*
CO
! "]
^
trt
o
1-1
H
o
E-i
I-l
E-i
CO
Z
M
w
PH
j EVALUA
•K
4-1 CO
4J C 4-1
C CU >-l
CD e o
§OJ o.
60 CU
00 CO (A
CO C
c 5 x
J£- J"1
•K CU
•4-1 I-.1
co C VJ
e cu co
O B 3
4-1 -H
cd S'O
3 I C
H O CO
(du
> CO
fi3 W-l C
0 0
M i-l
CO CO 4-1
CU P CO
^i
?S,JW
U XX
CU CJ O
•H C C
> 4-1
C-HI-I
CO 4-1 IS
CO
COM CO
CO M
co a) &o
•O.C 0
H 4-1 M
PH
•60
CO CJC
C-HO1
•H P
4-1 CO
(U*O Ed -W
4-1 i O
01 1 O
f^ p^ ^3 Q
^HT3S •
S C 1>
CO C4J
CU i-l CO
e « 1-1
•H e cu M
E
-------
(t Z
rr >e
o co
o
o
o
11
a.
IA
3
B
rt
O
ID
<*
p3
^
C?
O
o.
3
P
rt
O
r^
D
n
o
p]
Is
§
i_3
(t
0
p-
CO
rt
X
l-tl
Hi
1
PJ
3
p.
o
g
(t
3
rr
B
CO
n
H-
(t
3
rt
Is*
rt
CD
e
CO
a
j"
c
CO
D
M
*
»_£
<5
>
M
O
1
C
u
n
i
O
^
H-
CD
O
3
O
r|
^
•
jQ
t
!9
It
3
0
a
a
1
0|\
*O 1
' "«
1 Dl
O rr
H- 1—
< n
H^ H*
H- B
O rt
3 (t
a H-
f* Ml
It C?*
0
rt 0)
O a
B
•o
•o
o
•o
rr
n
il?1
•« i
•
O en
• c
» i
CO <
It
1 H*
1— H-
O B
5j* 3
O
Cf* (t
S3 tf
O
00 >
3
1-5) jo
O v<
' *- CO
(t h^
0 CD
rt
O
l-Ti
O
It
H
a
It ro
rr O
n i—
• i.
O
^
"
^
D
rt
It
11
CO
c
•o
•o
^
»
1
1
g
1
•<
Jg
(t
CO
•o
o
3
^1.
cr
H-
I-1
h*
1<
o
l
o
M
JO
13
|^
O
rr
sr
n
n
i?
o
ao
1
g
O
It
r*
n
a
I
r1
0
z
o
(t B*
TOT!
H-t-1
O It
3 S
B ID
MS
rt
3 PC
o.ro
o o
i-t S
Wit
SO-
o
0
TJH'
i e
0 rt
TO H-
<1 0
B 3
S 01
POO
(t 3
H* hH
(t 3
S rt
01 ft
i
s
» *
o
*
*
O >P1
01 B
aSH-M
Ow g
SSrrS
B rt
4 n
O (t 50
09 It
il WTO
B 3 H-
B O.O
3
n> C M
i-^O S3
it oo
S H 3
rt
HO
O rt
(t H-
OQ rt
H-H-
O (t
3 01
01
B
B 3
01 O.
BO
H »
rt B>
S
'o
\
\
It It
1-hH-
O (t
3 S
II
(t H-
O
>3
09 B
H
It S3
(to
9 3
(t
3 IT)
rt (t
01 11
01
0
3
3
ft
o
OS
01
01
o
i-h
f
- *
o
*•>
(t H-
< 01
H-rt
(t
C CO
rr
COB
rt rt
(U (t
rt 01
It
B
HOI
3
rr >
It T3
11 -O
3 H
B O
hi
P1H-
< B
B rt
MID
H.
rt3
H-
O T)
3 It
l-h
O
3
H-
3
TO
7
> *
0
*
9
1
H3
m
z
H
50
^i
>T)
O
£
n
M
^
H
^4
M
H
1-4
a
o
p 3
o
> o s
O "8 O
•^ !» H
"] O S3
M O FJ
CV58 »8
PI S
CO 3
lii
2! PS W
O ?o ?o
M?
POSITIO
z
CO
RESPON
CO
B)
PS 01^
rt
-ObJ
i-l
OW "
D.
O*-
H »
(on-
3"
n
S
I
M
M
I-J
OS
s
I
99
-------
•H
*H
5
4J
4»
M
.ng Progres
4-1
nj
3
S
W
"^
h
c/i
C-J
1
-H
•H
•s
H
100
STAT". S / ARE AWIDES AS
APPROPRIATE
HIU XO
3 < OJ C
rt B 3 B
re MB rt
3 COO rt
B re to
OJ rt B rt
HH-re H
O 3 vj
re 3 rt
< CO ft
B P re
M OOXt
C re o
B 3 rt
rt O rt
H- v; CD
O
3
HSre 3
3 H-
0 H-C
00 3 rt
S °
B rt rt
B re o
O ol
fS S"
H- 00
O
re
j^ B O-H-CO O
5 10 re B o re
E~ re coxt Hit
I 3 H-MC re
3 ooo re rf rt
» H-3 B H-B
M re 01 re o H-
„. 01 it 3 3 3
B re it co re
5 B O.B
2 3 rt H-XJ
0 O.B H-3 rt
O BO O
H- H-3 3 So1
re 3 B SM
» -h
0 0
IB rt
REGIONAL OFFICE
MS
3 H-
It CL
re I
3 re
B B
Hrt
re re
B B
MM
It rt
H-H-
0 0
re en 2 re So
< It H-«1 B C
B B Q-f" 3 B
Mrt 1 H» rt
C revj cioo rt
B re P re re
rt H-B rt B rt
H-3 rt H-re H
o rt o 3 v;
3 re re 3 it
rt < 01 rt
3 B B re
B H OQXt
MC re o
B 3 rt
It O It
H- VJ 01
o
3
•
B B H-O
300 3 re
o-re o rt
3 rt re
H-O re rt
It 01 H-
re o H-3
ooo 3 re
rt O 00
B rt a
rt p* en re
H-H- it rt
O 3 B Zf
3 B rt O
rt re P.
H- CO
0
3 Hi
0
rt
•
HlH-B O H-O.H
re B 3 o 3 re o.
cuo o-o r> rt re
re H rt rt re 3
rt re pdo-re rt it
B 8 re H-OJ 3 H-
nre oo 3 co H- H,
3 H-» re avj
B rt O rt re
OOP 3 H M, XI
re rt O m CO rt
3 H-B 3 'Q,O O
003 fj MO"
H-3 O.S Sj C H
01 H- H- It PL H- 3
3 3 cr o co
< B 3
O X] OOO 01 B
HOrt re 3
< SB 3 rf &
H- 3 O O
0 rtv;
oo re
re
01
i i i >
01
X) X) B MXIXI H B HI OCD
OrtSreooreSrtrtoi
O* Hi B 3 0*00 3 rt re rf
HOOOrtMrtrt xirt
re rt re H-reBH- n-rt BO
B B 3 HiBSH> B o H-fi
33 B rt rt re 3
O(t(?» OBOB rt
re its < S S re
B o H-O. re re re
oo o < B B rt co
re rt H-O re B &••
3 rt rto 3 3 O
o re vj rt rt B p-
vj o rt oo co
it re re
0 1
rr
HEADQUARTERS
•
(D CD
H* M*
(0 O
S3 O
isd —H
45 2
ri M
O
00
I-J
2
n co£??d III iil^
rt O OtD O
i^ C 200 (5 £££: WUi^i-i
BJ i-( H.-i-
CO 0 CD O HKIQ MO CO rt
rt0- OQ rtpiW
i-im(B,a3(-5H flOirt
O »-i en O <^ PS OiCOO)
1— i < "-<(uS rtfDOi
H* J— * 03 CD CO *•
C OQ W
fi 01 ^9
rt ID
OH* P
i-h o rf
J
OQT3 H-O
»1 H ^ (B
03 O O rf
rtOQ H {tl
H-H (p H
0 P3 » g
p 0 GO h"
H-3
o 3 ro
i-WJQ
hh B
O rt rr
H-O
H*O O.
tf p OJ
(D H>
1 O
i-t
,
OH* &•!-»
O3 [D &.
OO rt fD
ni-i ro 3
&0> 3 rt
p.(U B H*
3co H- *-h
03(D P ^<
rt fl>
h^-r) X)
O(D CO l-t
3&* O O
ft) MO*
* C H-
0) rt rD
i_i H.g
o n
(U 3
DQ OJ 01
fD 3
d rt &>
o o
^
9 H- >
01 B co
3 ••O CO
Oi i-j H-
OQ O OS
§^ rt
n>
fD ?d
3 T3 fD
rt '•I OQ
O H-
00 O
H 3
03 CO
rt
o
^ a
eo
c
M 2
D H
cn
III
ill
t-1 e H
c w
il
o
. „
ROGRAM
:OORDINATIO
JTO INTEGRA
M
§
50 H O
j> ^ h-<
MJCff'
M
CftOM
Sf
m
HS
M S
X !^
S o
ope
JO
cn 3>
HO
en
H
jt-
c;
Cd£l>
ACTIVITIES
EVIEW
g
CO
IT)
PI
pa
0
1
a
DURING
1-3
PI
O
K
13
g
T)
E^
!>
1^
H
O
z
o
o
PS
-------
Appendices
-------
APPENDIX
WQM PUBLIC PARTICIPATION WORK PROGRAMS
This appendix provides guidance on public participation work programs.
Work programs are the primary means for WQM agencies to outline,
organize, and manage public participation activities. The material
that follows includes background on public participation work program
requiremnts, some basic information on what makes a good work program,
and a few examples of effective public participation work program
elements. This is not intended as a strict set of guidelines for
producing public participation work programs.
Good water quality planning often requires more than just professional
or technical competence. A State or community's economic, social,
and political environment must also be considered. This requires
active public involvement in all stages of the planning process.
Public participation is not always easy, and it does not guarantee
that a program's goals will be met. Experience has shown, however,
that if public support is needed to implement a pollution control
program, citizens must be involved in the planning and decision-
making .
Work Program Requirements
Public Participation Work Programs are required both by EPA's Office
of Water and Waste Management's public participation regulations
(40 CFR Part 25, "Public Participation in Programs under the Resource
Conservation and Recovery Act, the Safe Drinking Water Act and the
Clean Water Act") and by the WQM program regulations (40 CFR Part
35.1507, "Grants for Water Quality Planning, Management, and Imple-
mentation"). For WQM grants, a requirement for separable public
participation work programs complements requirements that public
participation activities be integrated into and coordinated with
technical program activities.
A public participation work program has several functions. It
describes the various public participation activities proposed for a
given project. It links these activities to the project's schedule,
particularly major decision points. It gives citizens a better under-
standing of what to expect from the project. Lastly, it provides a
mechanism for managers to consider program implementation needs.
Because work programs are public information documents, they should
be made easily available.
Work programs must be of sufficient scope and detail to indicate the
adequacy of proposed public participation activities. They must also
be a working guide for carrying out the activities. For example,
rather than simply mentioning that "consultation" shall take place
at a specific point, the work program should indicate which consultation
techniques will be used, each activity's purpose and target audience,
planned publicity, descriptions of information tools (fact sheets,
newsletters, etc.), and approximate completion dates.
102
-------
Specifically, the WQM regulations require that public participation
work programs contain the following information:
• a schedule indicating when key decisions will be made and
what opportunities exist for public participation in the key
decisions.
• major public participation activities and objectives related
to key decision points and tasks (i.e., sequence of distri-
bution of information, workshops and meetings, hearings, etc.)
• the major publics that will be involved
• budget by category, (i.e., publications and media campaigns,
hearings, work shops, etc.), including resources available
to the advisory committee
• indication that a public participation responsiveness summary
will be prepared which describes measures brought before the
public at key decision points, the public response, and the
Agency's response as to how the plan was affected by significant
input
• description of the membership, meeting schedule, and general
responsibilities of advisory committee
• training of advisory committee
WQM agencies can be flexible in developing work programs, because the
detail needed to effectively manage public participation will vary.
Work programs are not static documents; they grow and change with
time and project phases. The key is adaptability. Planners must
adjust work programs to fit changing situations. While there are
basic requirements for public participation work programs, the overall
goal is that agencies and their advisory groups remain sensitive to
public needs and strive towards common sense public participation
programs.
Budgets and Schedules
Budgets and schedules are particularly critical elements of public
participation work programs. The public participation budget requires
WQM agencies to show the costs and resources associated with each
activity, including those of advisory groups. This commits specific
resources to specific activities and provides a mechanism for evaluators
(including the public) to assess whether those resources are adequate.
There are many ways to present public participation budgets. Exhibit 1
shows one good format.
103
-------
Work programs also require a schedule indicating when key decisions
will be made, what opportunities exist for public participation in
these decisions, and when responsiveness summaries will be prepared.
Schedules allow people to plan ahead. WQM agencies need to know
at what point they should begin to solicit public input and develop
information materials. Interested citizens should know when their
input is required so they can be properly prepared. Exhibits 2 and
3 together show one good way to prepare public participation schedules.
Appropriate Public Participation Activities
Choosing public participation activities which are appropriate for a
particular project in a particular State or community situation may
well be the most difficult aspect of developing good public partici-
pation work programs. It is also the most logical place to start.
The following step-by-step approach has been shown to be effective.
• Key Decisions — Each agency, in coordination with its
advisory group and interested and affected publics, should
identify the key program decisions to be made in the planning
period. These might include recommending a new septic system
management program to a town council, selecting management
agencies responsible for implementing a control program, or
applying for a Rural Clean Water Program grant.
• Outputs — For each decision, outputs such as draft or final
reports, data findings, or recommendations should be
identified.
• Public Participation Objectives — Based on the decision to be
made and the identified outputs, one or more public participation
objectives can be developed. A public participation objective
might be to inform the general public of the nature and scope
of the issue or to solicit public input on recommended control
programs.
• Target Publics — The next step is to target specific people
or groups for information and/or involvement. Target publics
could include the general public, business associations, public
interest groups, or elected officials. In determining these
targets publics, several questions should be asked. Who
are the decision-makers involved? Is voter approval required
to implement the project or project recommendations? How
much public consensus is needed? What groups can provide
additional expertise?
• Specific Public Participation Techniques — There are many
different public participation techniques. Some, such as fact
sheets, newsletters, and seminars, provide information to the
public. Others, such as public meetings, surveys, and advisory
groups, are consultation techniques which facilitiate the
flow of information from the public to the agency. The
choice of appropriate techniques for any particular situation
104
-------
is based directly on the public participation objectives and
target publics previously identified. Other factors which
may influence the appropriateness of individual techniques
are the time and money involved, available personnel, and the
receptiveness of the State or local community to certain
techniques.
One example of how this planning process has been used is shown by
Exhibit 4, a Nationwide Urban Runoff Program (NURP) Public Partici-
pation Planning Matrix. Note that the public participation techniques
or tools at the top of the chart are basically informational. This
corresponds to the fact that decisions made at the beginning of the
NURP program require little public consultation. An emphasis on
information materials is more appropriate at this stage. Later on,
decisions relate to implementing a control program and require
public input. At this point, consultation techniques are added to the
basic program.
105
-------
$9, 620. 00
1,218.00
2,418.00
Exhibit 1
Public Participation Budget
1. Staff Time and Overhead
a. Direct Salaries:
Public Participation Coordinator
92. 5 days @ $104
Technical Staff
18 days @ $67.68
Support Staff
56. 5 days @ $42. 80
b. Benefits and Overhead:
0. 73 of Direct Salaries
Total
2. Travel
a. 4 Roundtrips, New Orleans to Dallas @ $130 each
b. Per Diem: 4 @ $30
Total
3. Advisory Group
a. Reimbursement of out-of-pocket expenses;
20 members, 6 meetings
b. Training
Total
4. Mailings
CAC meeting notices: 120 letters
Public meeting notices: 500 letters
Public hearing notice: 125 letters
Miscellaneous: Reports to EPA,
news releases, etc. = 100 letters
Total @ $0. 15 each, 845 letters
5. Printing/Copying
4. Phone Calls: Long Distance
5. Advertisements In Newspapers for
Public Meetings and Hearings
6. Miscellaneous
$13,256.00
Total Project Cost: $348, 850
9, 677.00
$22,933.00
520 00
120.00
$640.00
970.00
400.00
$1,370.00
$127.00
$420.00
$50.00
$400.00
$100.00
TOTAL $26,040.00
This sample budget combines infor-
mation from a number of sources.
106
-------
CM
W
CU
rH
3
T3
0)
f|
0
CO
(U
g
•H
EH
O
CO
H
£H
U
<
2
O
H
EH
rij
04
H
U
H
EH
Pi
rij
04
U
H
l_3
0
D
04
0*J
O
fa
U
D
Q
W
EC
U
CO
04
'O
(U
4.)
(U
Cn
)H
id
EH
0)
Cn
rrj
G
id
O
rtj
EH 0
•
G
MH Id
O r-l
04
CJ
0
0)
>
•H
4J
0
Q)
•n
Xt
O
00
g *
M fa
o
4-1 CU
C £
•H 4-»
O MH
EH 0
o
CO
m
H
5*1
rH
3
^
%.
^i ^i
rH rH 4J
C -rrl-H
(DOG
N CO 3
•H g
•P T3 g
•H G O
O (d O
X! rH G
CQ m o
•H SH -H
M 3 -P
id -P rd
D4H >
3 M
rH O (!)
id -H CO
O rH G
O Cn O
rH Id O
o
111 »«J
O rH
0) 3
n^J Pi PJ
c o
(d O .K
CQ 0)
>i 0) CO
•H x;
G -P
3
f!4-| G
o lCO
id H
3
£3
(d
^
1
O CU
•H rH
Cn 3
0) 4-1
3
•o o
C -rl
en
rH fd
id
o to
O rH
rH (tj
o
C3 «H
ril UH
EH 0
UrH
«; m
04 G
J5
O
O
•H -
rH 0)
XI rH
3 id
a
CO
'O •
CD 04
•P 2
co m
(U
!H rH
a) id
^ i ti
C 3
•rH 4J
rH
0) 3
X! 0
•P -H
^1
5 en
O id
x:
CO 4-)
id
O JZ
EH S
1
M
0)
4J
•H
rH
rH
id
•d •
G 0
rH
>iXl
•P 3
•H a.
c
3T3
g 0)
5 -P
O CO
o
G-H
•rH £ CO
-
rH CO 04
0) CU 2
CU-P «
0-rl
rl CQ .C
04 4VJ
•P-H
•d to ^ •
GO) -P
(d 4VJ 0) 3
G 0
- O O X!
M EH --H
rd 'OS
> 0)
>i G -H OJ
(U O co £
J2 -H -H 4->
-P -P > O
rH
00
C">
rH
^
id
3
rH
XI
0)
O
•rH
rH
(")
3
TJ
0)
CQ
0)
0)
4-1
g
•H
»
O
EH
>.
U
rtj
04
CO
U) d)
T3 3
•^ o*
rH -H
CQ G
r;
G 0
0 0)
•rl 4J
4->
Id MH
rH O
rH
id G
•P O
CQ-r|
G to
•H CQ
3
04 O
2 co
CQ -H
MH
O t3
C
co id
3
4J J TJ
m o a)
4J XI CO
co co 3
rH
oo
Cf\
rH
>.
CU
C
3
1-3
O
•rH
rH
Q
3
p.
•a
(U
4J
to
CU
M
0)
G
•H
<.
O
(<£
EH
-
U
<:
04
MH
O
CO
4J
rH
3
CO
a
r-|
rH
id
•H
4J
•r|
C
•H •
73
MH 0)
~O -P
O
G 0)
O rH
•H rH
CO O
CO O
3
u id
CQ 4->
•H id
D T3
H
00
a\
•H
>,
rH
3
^
CO -P
H -H
id c
•H * 3
0 >i g
•H 4-> g
<*H -rl O
UH G O
O 3
§1—1
id
(d O G
GOO
0 -H
•rl rH -P
en id id
0) rH 0)
rH 3 rH
•P 0
•* rH 0)
3 rH
rH O
Id -rl QJ
O rH ^
o en id
H (d H
i
CO
3
O
CQ
•rl
"d
•d
£j
id
id
4J
id
'd
MH co
O -P
rH
G 3
OJ CO
•rf 0)
•P JH
id
•P M-l
G 0
to G
0) O
M -rl
04 CO
00
CA
!_|
>H
0)
•i
0)
4J
04
(U
CO
,
G
O
•H
•P
id
0)
o
0)
rl
>« co
CU
•H -rl
id -P
3 C
4J 3
•H i
3 g
o o
•H U
rH
Id
G CQ
CU 0
CQ 04
0) CO
M -rH
p,rrl
<-d
Q G
i-^ id
c
O
k;
O
•H •
CO rH
CQ O
H3 cj
0 -P
to G
•H O
Q 0
rl
• O
CQ 4->
W O
0) CU
c >
•H
m cu
•P >
G-H
O -P
o id
c
ll t.
•H CU
CU 4J
x; -H
4-) id
Cn
G
•H
4-1
0)
a)
4J
•H
>
•H
4-)
O
2
U
<£
04
^x
(U
Cn O
G C
•H 0)
4J TJ
0) -H
0) >
2 0
M
O 04
•H
rH 0)
XI v
3 id
04 ^
^_,
CM
CU
o
c
I (U
TJ
04 -H
•H >
H O
EH M
04
T3
rH (1)
a> ^
•rH Id
n
107
G
•H
•P
CD
0)
S
U
<
04
Cn
G
•H
4->
0)
0)
U
<
04
Cn
C
-H
4J
-------
3) Newsletter Article
CO
A fto
X 3*H-
H- H, CO
CO 0 CO
rt e A
H-tO 3
3 3-H-
VQ 3
ft 0)
§3" ft
A H-
H- 0
HC 3
H«ft
3 H-O
ifl HHi
H-
HUH
H-O) 3
tt ft Hi
ft H-O
• o n
3 3
0)
0 ft
Hi H-
0
0) 3
3
2) Public Hearing
Oi 3 13 M
3 ft) H O
O< 3 O H
Q.< H-
CD ft) H-O
0> ft 0i H-
ft H- A ft
o o a
iQ C H
A tr1 a.
• rs
A fl> 3
9 3
13 Cu A
HI 9
0 13 ft
< > to
H-h
a o
A H 3
9 A
O O IT1
A O 0)
3 X
1 A
8
3
rt
if
O
M
CO
3
A
A
a
A
a
•
13 3
A A
CO 9
rt 0.
H-01
0 ft
H- H-
0.0
A 9
« to
to rr
0 0
H-
H H
A
§01
&
a.
0)
H>vQ
A A
iQ 3
H-O
C0><
H
0) O
ft 3
H-
<
A
1) PAC Meeting
HI D
H- H-
3 to
01 O
H C
to
h to
A H-
10 O
C 3
H
•rt o
10 Hi
0 4*>
Hi H
o
to
ft S
C A
a A
•< rt
• H-
3
iQ
50 (0
A
O 0>
O 3
3 a
1
ft 00
if 3* >f
O A
H* 3 H
W H- A
• O iQ
0) H-
HCO
CO H1
0)
01 ft
3 H-
a<
A
CO
tt
HS
A
A If
Hf to
O
CO Hi
H-O
o n
3
0)
OlQ
O tf
3 H-
1 1
0) t3 T3
sec
D. CT ft
M
3 H-C
A 0 H-
A H-
O.13 H
A
Hi H CT
O 0 A
If A
13 to
H-ft O
3 H- M
O O H-
if 3 0
A H-
0> O rt
to Hi A
A 0i
0i ft
3-01
8 A to
3 n ft
ft A O
If to
O C rt
H M 3"
to ft A
to
0) Public Meetings
ft 0, >-3
3* H- 3*
A W h
O A
F C A
01 10
X CO ^
A H- W
3 -'
•flvQ
O rt A
< y A
H- A ft
0i H-
A Hi 3
3 H-vQ
O 3 to
A 01
M SI
tO H-
ft H M
C A H-
0i CO
*< c cr
• H A
rt
to 3-
H A
3 O M
1 Hi 0i
13
HI
O
<
H-
0J
A
O
-A
H
A
to
e
H*
ft
CO
*
9) Workshops
>o o w
H 3 s:
01 O
O A O
rt Hi
H- Hi £
O A H-
A 0 H-
to rt H*
H-
cr < 13
0» A HI
CO A
A CO to
0i O A
H- 3
O H ft
3
O U>
rt O
3" 3 £
A to O
A H
t-1 n x
01 < CO
9T 0) 3*
A ft O
H-13
O to
3
00
***^
13
>
O
if
A
rt
H-
3
iQ
> »O W
0 CU X.
ft vQ 2
H- A £
< H-
H- NJ rt
£
CO O
H- 0)
O ft
3 0)
O13
HI if
A
If CO
A A
O
cr
LJ.
A
0-
ft
H-
A
CO 3
C rt
M 01
rt rt
to H-
0
0>
3
o.
a
H-
to
o
d
to
1
9
rt
fl)
to
ft
fl)
a
•o
en
9
Sf
h
(D
to
«T
a
o
to
en rt >
ft H-lQ
0) 0 If
rt 3
~ 0>
H-
O
Hi
Hi A
O
o
0»
H
H-
O
C
O
O
ft
c
O _
H- O § M
0) 3 3
H 0) H- »»
to H- rt
H-M
0> A A
3 to O
Di« M
A
0)
I
ft >
H-lQ
O H{
3 H-
0) O
H C
H«
O ft
O C
C H*
H- 8i
ftn
A A
CO O
H
A
0*
13
H-H3
O >
3
at
H
A
(0
ft
A
ft
H-
O
M
fl)
(D
H
X
01
fl)
•0
ft
A
I-
(D
M
H
V0
o
Is)
C
I-
VD
00
to
C
3
(D
vo
00
13
if
H-
H1
vo
CO
NJ
s?
o
n>
CO
H-
I
CA
O
3*
fl)
a
c
M
(D
108
-------
CO
rH
3
JS
O
co
CU
g
•H
EH
m
4-1
•H
•H
•a
w
co
CO
co
en
4-1
•H
•H
•s
w
co
CO
co
en
•H
X
w
CO
CO
CO
to
u
ca
o
o
•H
Q)
•P
0)
Oi
M
m
3
04
0)
4J
01
CO
M
0)
4J
c
•H
•§
04
(1)
4J
m
0)
M
0)
4J
C
•H
(U
4J
O
CO
•l-»
»
4-1
•H
rH
gg
in
rH
cu
O O •
MH >i
O "O
•H W 3
A G CO
3-H
O< JH CO
id u
co to c
JS A CO
T3 -H
g§§
O r-l
«W CO CU
C Cn
•H C CU
•H X
O -P (0
E-" CO iJ
CO
0)
a
(j
o
CO
i-> U-l
O O
CO
4J
CO
CU
_r;
W
4J
O
(0
b
CO
CO
CO
G
CO
> CO
•H CU
CO -H
C M
O (0
cu g
CO g
CU 3
Ctt CO
CO
(U
o
•H
JJ
O
2
cd
<-\
P-i
CO ^
-------
Exhibit 3
FY80 PUBLIC PARTICIPATION SCHEMATIC
1980
Hews Release for Field
Trip
Fact sneeu
Public Meeting Notice
Woikshop No Lice
Workshop Notice
PUD -Lie wee ting INOUXOCJ
Responsiveness Summary
Public Hearing Notice
i
i
o
A
S
N
^1981
J. < «
F
*
A
M
j
0
1982
J
F
A
M
J, .<
S^ r>
•j
0
N
PAC Meeting
Public Meeting
Field Trip-BMP
Installation
PAC Meeting
PAC Meeting
Public Meeting
Workshop-Pesticides
and Alternative
PAC Meeting
Workshop-Effect Soil
Conservation Methods
Series of Public Meet-
ings
PAC Meeting
Public Hearing
Summary
*Proposed starting date, will be.adjusted as necessary.
110
-------
s
i
1
t/1
fr-
1
I—
e.
as
o.
M
— 1
S
a.
2
i
5
e:
2
V)
UJ
£
3
s
V)
i
*>
s
V)
U
v»
«
V)
V
2
VI
v> X
4) O
•^ C
k. 01
!<**
1 ^ S £
V) <—4l
E OK •»->
n e at
Hli
i
JJ
, 1
1 t
HP
>, >, >, 10
U U U t-
c
•5
ll
»
•- c»
Stjs
ft) O. £"
f- +» S
"» "G P-
•*• ic
PI
^
te
o
Q. IB
v *e
I "
~
OJ 3
U M-
*J «- t/>
1/1 t- -o c
3 1C =0
> 1 .£ £
O i/> t- — «. C
A 4-> cn*— j Q
ID u-o £ r: s
30 •— •
O. (A u n
^- •« N- at
I lil»
A •»- i- a. at
IB > *J C
*- V "O •»-
V) -O N OJ *J
-^- c u dj
41 « TO+J
1 £="!—
to >: —
, , £1.
x * D 4-> at *
OI-— ••*- C -C W
—
Vt i- «
* § i
1 T. S
^ •*-" C
o c ai
t i 2
n
^
a. «
cr>
> •*
o -*-1
"S n
1^
10 -ii
to a- _
1
•0
Jo
S
^ *
U x c s-
U "O (D **-
0 3 E
•*- +J JK
VI **- o c *o w
t- C O •" (U O
•C C -r- C 0) —
O »»~ Ol O
U > C O -t-1 l/>
ai *j *j (.J o
*- w *J *J 'g. C
IO -J !/1 O *•—
.— en u^ wi
ID C OJ •—
> i- C VI
UJ T3 ft) >,
3 03 ^
O. «— *-^ -0
flD C trt *H
•»- o
£
•
a
w *
a- c
(U ^,,^ —
O >N I
•o "^ ^ K
w !Q "" o
tj •— (/i
3 (/)
O. re
(U ->
O "-
J3 ••-
T3 C3
^ U
qj J
3 41
(/I UJ
Q. C
Oi f O
tJ t- C
C -M O C
0 * -- -0
i- UJ l/l ^~
•M O.-^- O
i, tj OJ *J
•«— -o c
a Q. a. a.
C i- 4l O C
3 O 1. — '3
O (*
4- 4-)
*•- C
^ 01
e £
sll
„ =
^
re
TJ in
a; •*- at
ID cv. „_ Q;
4-> C *J t~
O o -^ oi ro
1J <*- OJ
r; G
c
o —
•f Q.
CJ C O
CJ - *J
t--) u CL
31 O
t S S
03 .5
si
3
C
E
QJ
_g £
ai -c c
OJ w ^
•^ Cl O
U C 1-
f- w- a.
T— 3 >E
^ C —
3 —
0. *J C
. .- 0-2
*J t/> U CU
iln
1 ^
- o t: — ai
in -r- O • » •— E
C i— 3 01 O- O
re 3 *j c i-
E O-.- (O t- Q-
— O) 4-> j; a- E
w c n
0 — 3E
—
•D -O
1 0 C
O — re
U AJ
at ~- at
O O jD f^-
i- a. TO a"
O " **- J3
^1 s s
0
c
o
3
~;
Q.
=•'
in
------- |