905-R-78-114
Public Participation in 201 Projects

A Review in Regions I, III, V, VI and IX
Facility Requirements Branch
June 1978

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                           TABLE OF CONTENTS
                                                           Page
I.   Recommendations and Conclusions	1
II.  Region I 	5
III. Region III  	12
IV.  Region V 	15
V.   Region VI	28
VI.  Region IX  	35
VII. Special Commitment of Region  V
     to Public  Participation  ~  Ms. Annette Nussbaum  	41

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                     RECOMMENDATIONS AND CONCLUSIONS
     The result of a survey of public participation in five regions
indicates that a strong commitment by EPA regional  personnel,  the water
division director, and the regional administrator in each region exists
towards public participation.   EPA personnel  are far ahead of  most
grantees and States in encouraging public participation in the 201
program.

     It has been found in all  regions that public participation in 201
projects often provides for:

     1.  A better public facility plan;

     2.  A less costly project;

     3.  Improvements in the environmental  quality of the project;

     4.  A review of more alternatives,  especially small  systems and
         land application;

     5.  A better job by the consulting  engineer;

     6.  A more detailed facility plan;

     7.  A better review of environmental  impacts.

     The development of citizen participation has been an evolutionary
process for both the grantee and EPA. The first 201 projects  had virtually
no public participation, except for the  public hearing that was required
at the end of a facility plan.  At that  time  objections were noted and
the project proceeded.  While this process  is still  evident in many
communities, EPA is no longer allowing communities  to disregard opposition
to a project or public scrutiny.  All regions are now requiring the
grantees to openly discuss costs of projects  and have the public involved
prior to the time when decisions are made.  Some regions  require applicants
to discuss public participation in the initial  Plan of Study and show
when the public can participate in facilities planning.  All regions
agree that the regulations governing public participation should either
be amended or clarified through a PRM to require:

     1.  A public participation plan in  the Plan of Study or a plan
         for public participation at about the ten percent completion
         phase;

     2.  Public meetings or workshops soon  after a Step 1 grant has
         been made;

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     3.  Public participation in the planning  process  before an  altenative
         has been chosen;

     4.  Better advertisement than a legal  notice,  containing information
         on anticipated costs and proposed  workshops,  meetings,
         hearings, agendas and availability of reports.

     As experience with 201 projects progressed,  public  participation
was found to be an extremely useful tool  in assessing, at an early date,
whether the project was controversial.  This enabled many regions  to
make an early decision on whether an environmental  impact statement was
necessary, and often saved time in getting  a project underway as the
piggyback method was used.  In some instances, controversies were  arbitrated
through public participation, which allowed the project  to go ahead more
smoothly.  As a result of public participation some projects that  were
controversial at the start did not need an  EIS.

     In several projects where the boundary of 208  and 201 projects were
similar, the public participation program was  merged effectively.   This
works only in limited areas and for limited projects.

     Regions interpret eligibility for  public,participation differently,
and it would help all regions if eligibility for public  participation
was clarified.  It is recommended that  a  policy statement be issued
which would indicate that public participation is eligible for EPA
funding through Step 3.  Special mention  should include  newspaper,
advertizing, newsletters, radio, and other  advertising;  staffing citizen
advisory committees, and a grantee's public relations  staff.

     Public participation should be continued  beyond Step 1 so that an
effective forum for public input exists.  A project may  indicate no
opposition through the Step 1 and Step  2  processes, then generate opposition
when the Step 3 construction project is awarded.   At that time,  the
region will have to decide whether an Environmental Impact Statement
should be written and if Step 1 should  be revised—a long and costly
delay.  Other experiences indicate that in  building the  treatment
works, there should be public participation when it is necessary to
phase wastewater treatment works and inform the public about construction,
Street closures, and other effects of the 201  program.

     The addition of a public involvement professional at the regional
leyel to assist project'officers, applicants and their engineers in the
201 program is deemed an absolute necessity.  Region V has such a
person; their experience with the staff position of a  public involvement
professional i;s extremely- favorable.

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     A public involvement professional has expertise in the use of the
communications media and public participation, and that person has the
knowledge which provides for an effective two-way forum to discuss
controversies, alternatives, environmental issues, costs and other
construction grant program issues.  Such a person needs experience and
training in working with the communications media and should have some
knowledge in dealing with civic action programs.  Such a person should
also train project officers in public participation.

     A major shortcoming of the 201 program is the inability of project
officers to meet with the grantees and to attend  public meetings. There
is a vast amount of misrepresentation of EPA programs by local engineers,
local officials, consulting engineers, and city attorneys at public
hearings, due to misunderstanding of EPA programs.  For example, in an
Indiana project, a city attorney moderated a public hearing and stated
that EPA was not interested in costs, then threw  out all questions on
costs as irrelevant.  In a public hearing in another Indiana project a
local engineer refused to discuss small  systems,  stating that only a
treatment facility and long interceptor sewers would be permitted by EPA
and the State.  In Illinois there were a number of engineers that told
small communities that they had to have a sewage  treatment plant with
collection sewers in order to comply with EPA regulations.  In that case
the State had to put a moratorium on acceptance of small systems for
placement on the priority list.  Some public participation functions may
be delegated to States, which may require EPA to  establish public participation
strategies on its 201 program.

     Travel money for EPA staff would be an investment that would pay
extensive dividends both tn catching problems early and in making EPA
policy known to potential grantees regarding small systems, costs, and
environmental considerations.  In the case of Region V, there is a fear
that if travel for water division staff continues at the present rate,
there will be no travel money after July.

     There is a need for a national public relations program to tie
together regional and local programs with a unifying theme.  Such a
program would help stimulate participation on the local level through
public information on EPA's public participation  programs.  A comparable
program is Interior's "Smokey the Bear"  fire prevention program.  EPA
would let the nation know that it is trying to clean the nation's water
and that individuals can do something withtn their communities to bring
this about through public participation in the 201 program.

     The dollar commitment tn public participation is not necessarily a
measure gf good public participation.  Some communities used minimal
funds, but had good public participation, while others used large sums
a,nd had poor public participation.  The resourcefulness of the involved
offtcta,ls and engineers plays a much greater role than dollars committed.

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                    PUBLIC PARTICIPATION SURVEY SUMMARY
Communities Surveyed

     Region I                               11
     Region III                               6
     Region V                               30
     Region VI                                4
     Region IX                              10.

  Total Number of Projects                  61

Public Participation Effort Made            26

Effect of Public Participation

     No Effect                              15
     Increased Total Cost                     1
     Decreased Total Cost                   16
     Improved Environmental  Quality         17
     Hurt Environmental  Quality               0
     Relocated Sewage Treatment Plant         4
     Relocated Sewers                         3

Public Hearing

     Publicized Beyond Legal Requirements    27
     Issues Raised                          23

          Effect
            No Effect                       18
            Changes suggested, changes       19
               made
            Changes suggested, no changes      3
               made

Assistance to Public

     Staff                                  15
     Consultant                             17

     Note:  A project may have had more than one answer.   For example,
            a project may have, through public participation, decreased
            total costs, improved environmental  quality,  relocated STP,
            relocated sewers, had consultant assistance.

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                                 REGION  I


      Public participation  review in Region I consisted of reading
 Region I's Step 1  report of  several random sample  201 projects recently
 completed.  Further  information  was given by Gerald Potamis and Sharon
 Francis,  who directs two public  participation professionals in Region I's
 Public Participation Office.  The Region I Step 1  Task Force consists
 of EPA staff as well  as  outside  citizens, consultants, and municipal and
 State officials.  This Task  Force reviewed the adequacy of facility
 planning  and developed recommendations  for ways to improve public participation
 and consider alternative systems.  The  following review of State projects
 is based  on the Task Force working papers.

 Connecticut

      The  cities of Putnam  and Shelton were reviewed by Group I.  In
 Putnam there was evidence  of a public hearing which was well summarized
 and showed that issues were raised by the public,  but gave no detail of
 the consultant's or  community's  response to these  issues.  In Shelton
 there were about 20  public meetings with the consultant which included
 preparations for a referendum.   The Shelton referendum passed by 80
 percent of the  vote.

 Massachusetts

      The  cities of Gardner and Mansfield were reviewed by Group I.
 There was no mention of  public participation in Gardner in the facility
 plan; however,  a public  meeting  was held and separate transcripts were
 submitted of the public  hearing.  No controversies appeared at the
 public hearing.

      In Mansfield  there  was a public hearing, but  no transcript was
 submitted.

 New Hampshire

      The  cities of Ossippe, Salem, Stratford, and  Concord were examined
_by Group,  I.

      Several  meetings took place prior  to the public hearing to which
 the public was  invited in  Ossipee.  The proposed plan was not the one
 that the  public preferred; however, it was the most cost-effective
 solution.

      In Concord a  public hearing was attended by about 50 people.  Some
 modifications were made  in the facility plan due to public participation.
 It was speculated  that earlier citizen  involvement would have brought
 about better results.

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     Only the required public hearing was held in Salem.   Based on the
review of the plan and project file,  there was ample opportunity for
public participation.

Rhode Island

     The Town of Tiverton had one public hearing  on the facility plan,
as provided in the regulations.  The  minutes  of the meeting  showed that
some lively discussion took place regarding costs.   Land  use issues were
raised.  It was speculated that public participation at an earlier date
would have been helpful to resolve various issues raised  at  the public
hearing.

Vermont

     A public hearing was held in Hyde Park but an incomplete transcript
of the meeting was submitted with the facility plan.  As  a result, it
was difficult to determine the result of public participation in this
201 project.

     Public participation has definitely shaped the facility plan of
Stowe.  Unfortunately, the public oarticipation was a result of town
meetings and subsequent bond votes, rather than the built-in public
participation program.  The public rejected several plans, after the
fact.  Early involvement by the public, before decisions  of  alternatives
were made, would have been helpful.

Region I Comments

     Due to the fact that no visit was made to Region I,  comments
were made on the basis of phone conversations with Gerald Potamis and on
"Progress Report on Public Participation of EPA Water Programs for New
England," by Sharon Francis and Barry Jordan.  Other comments were received
from Sharon Francis and Lester Sutton.  As part of the work  of the Step 1
Task Force, a regional policy statement and manual  for applicants on  public
participation techniques have been drafted.  A copy of the draft policy
is enclosed.  Region I's public participation review resulted from the
effort of two sub-groups formed out of a larger regional  Task Force to develop
a regional policy which, when put into effect, would produce the most
cost-effective and environmentally sound solution to water quality problems and
wastewater related public health problems. The results of one of the
sub-groups indicated that a majority  of the facility plans reviewed were
done well.  The sub-group also reported that  in many cases the projects
had a long history of public involvement.  The sub-group  recommended
that as a minimum, preparers of facility plans provide a  summary of all
public participation efforts (not just a summary of transcript of the
formal hearing) to include significant comments,  Questions and responses
or dispostion of major issues.

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     Another sub-group prepared a draft regional  policy statement on
public participation (see enclosure)  and a draft public participation
manual for grantees.

     Region I is commited to public participation and has hired Barry
Jordan and. Sharon Francis as special  public participation consultant to
serve the 208 and 201 programs, respectively.   An effort to educate, and
assist officials and engineers in implementing  the public participation
program is now going on.  Region I has had special workshops with project
officers and consulting engineers on methods to improve public participation
in the 201 program.

     The review of Group I's projects indicates that public participation
will provide a better 201 project and may, as  in the case of Stowe,
Vermont, preclude doing several plans before obtaining public acceptance.

     There is some frustration in Region I with public participation
when opportunities exist and consultants and other officials make great
efforts to get the public involved.  Few people seem to come to meetings,
leaving a small vocal minority with greater influence on public projects
than their numbers would ordinarily allow.

     Some innovative techniques that have been  used in Region I:

          a.  A consultant developed a monthly  newsletter that was
              sent to the public.

          b.  A community put the public hearing  on cable TV.

          c.  A radio talk show was used to publicize the project and
              answer quanswer questions.

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                                        Consensus  Draft
                                        November  1,  1977
REGIONAL POLICY STATEMENT
ON PUBLIC PARTICIPATION
IN WASTEWATER TREATMENT
FACILITY PLANNING
BACKGROUND

The Federal Water Pollution Control  Act Amendments  of  1972  call  for
mandatory public participation in all  phases  of  the multi-billion  dollar
clean up of the nation's waters.   Congress  declared in the  law:

     "Public participation in the development, revision and enforcement
     of any regulation, standard, effluent  limitation, plan or program
     under this Act shall be provided  for,  encouraged, and  assisted..."
     (Section lOle)

Our experience in New England has shown that  an  interested  public, given
adequate encouragement and opportunity, makes important contributions to
the planning of treatment facilities.   And  yet,  this aspect of facility
planning has not been given as much  attention as experience or the
statute seem to call for.

Pollution abatement should be carried  out with sensitivity  to  the  unique
conditions in each community.  The public must be satisfied that long-
range community goals are being served, that  the areas to be sewered
should be sewered, that the method of  treatment  chosen is cost-effective
and environmentally sound, that reserve capacity in any facility is
allocated in an equitable manner, and  that  adequate provision  is made
for operation and maintenance of  treatment  facilities.

Public participation means consultation with  the public.  It means a
dialogue between government and citizens about decisions that may  affect
peoples' lives and reshape their  communities. It is not enough  to
inform the public of decisions already made.

A commitment to public involvement can reduce the likelihood of  court
actions and last minute demands for  Environmental  Impact Statements
which may seriously delay important  projects. It may  also  improve the
chances of a favorable vote on a  bond  issue when the time for  construction
approaches because public participation helps the engineer  to  produce an
acceptable plan.

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PURPOSE

The purpose of this policy statement is to assist applicants for wastewater
treatment facilities planning grants in their interpretation of EPA
statutes and regulations calling for participation by the public.

Regulations to implement Section Idle of the Water Pollution Control Act
Amendments of 1972 on public participation were published in the FEDERAL
REGISTER, August 23, 1973 (40 CFR, Part 105), and are incorporated in
the Construction Grant Regulations, published February, 1974 (40 CFR 35.917-
5).  Their "intent...is to foster a spirit of openess and sense of
mutual trust between the public and the State and Federal agencies in
efforts to restore and maintain the integrity of the nation's waters."

According to the regulations, public participation programs are to cover
"each of" the following activities, as they apply to wastewater treatment
facility planning: "informational materials," "assistance to public,"
"consultation," "notification," and "access to information."

POLICY

The policy, adopted by EPA for the New England States, requires certain
minimum steps to involve the public in plan development for the following
categories of Step 1 facility plans:

    -"first time" projects,

    -significant expansion of the area to be sewered by an existing
     facility,

    -significant expansion of a treatment plant site or reconstruction
     on a new site in a residential, commercial  or industrial  area,
                                             ">•
    -multi-community projects.

If your community is not certain that these requirements apply, EPA will
make a determination prior to the Step 1 grant award.

Applicants should develop public participation tasks as part of the Plan
of Study for their project.  The tasks should assign responsibilities,
identify principal activities, and be fully integrated into the schedule
of technical study elements.  Applicants are encouraged to consult with
interested citizens and members of relevant boards or committees in
developing the Plan of Study.

Techniques and processes for public participation will vary from one
community to the next.  Applicants may consult with EPA's "Manual on
Public Participation" and select from a full range of methods  and models
in shaping a public participation program suited to the character and
needs of their community.  EPA recognizes the importance of flexibility
in developing appropriate public participation measures, and therefore,
only a few basic elements are specifically required.  The regional
policy stresses the following elements:

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1.   Educational  Material  for Public and  News  Media

     The consultant should provide timely fact sheets  and  summaries  in
     non-technical  language during the planning period in  support of
     items 2 and  3  below,  and at other times as appropriate for informing
     the public about project developments.  These should  explain the
     need for pollution abatement, the alternative methods for  achievement,
     their environmental,  financial, social and economic implications
     and other matters of  interest to the community.   These should be
     systematically distributed to a mailing list which includes public
     officials, interest groups, other interested or affected citizens,
     and the news media.  Copies of each  place should  also be available
     for use at a conveniently located depository, along with other
     documents, meeting summaries, maps and reports on the plan.

2.   Public Meetings or Workshops

     Because sewers and treatment plants  may affect a  community's economy
     and environment in many ways, it is  important that their implications
     be discussed among the full range of interests in the community.

     At least two public meetings or workshops should  be held,  the first
     early in planning to  review and discuss community goals and wastewater
     treatment needs, and  the second, later when planners  are identifying
     alternative solutions to be analyzed. The purpose of these sessions
     is for the consultant to share his professional experience with
     citizens and listen to their advice  based on knowledge of  local
     conditions.   Strong advance publicity and personal contact with
     public officials and  citizen leaders should be conducted to assure
     adequate attendance.   The personal invitation list should  include
     representatives of the selectmen or  council, sewer commission,
     board of health, planning board, regional planning commission,  208
     planning agency, conservation commission, industrial  development
     commission,  finance committee and citizens representing environmental,
     sports, civic, business and church groups and other local  organizations,
     as well as those who might be affected by proposed construction.
     State and Federal EPA official's should also be invited.

3.   Public Hearing

     A public hearing, also well publicized  in advance, should  be held
     after all the alternatives have been analyzed. The purpose of  the
     hearing is to record community preferences for consideration in
     selection of the final plan.  The consultant may  recommend a preferred
     alternative and still assure the community that  he will seriously
     consider other oninions expressed at the  hearing.
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These minimum requirements for projects in the affected categories
may be modified by the Regional Administrator if the applicants and
their consultants can demonstrate that other measures are more
appropriate and effective.

Completed facility plans should include summaries of public participation,
information distributed, meetings held, public comments, and the
effect they had on the plans.  The States and EPA will  review the
summaries and may order further efforts if public participation has
not been adequate.
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                                 REGION  III
      Direct discussions  were held  with  the water  division director,  the
branch chiefs,  project officer and  EIS project  officers  regarding
public participation.   People that  were  contacted  directly include:

     Greene Jones             William Bulman
     Robert Blanco            Barbara D1Angelo
     Joe Galda                 Stuart Kerzner
     Lee Murphy               Ken Christiansen
     Robert Blaszcak          Joe Parisi
     Ken Anderson             Rochelle Volin

     Region Ill's water division director  asked me to  sit in  on  a
conference in which 208 project officers met with  Ms.  Marcia  Kaplan  to
discuss public  participation.  In this conference  sonie of the trials  and
tribulations that project officers  found with public participation were
aired.  I felt, from this meeting,  that  the staff  was  committed  to
public participation in the 208 program, but were  frustrated  with
public response.  The disaggregation of  public  participation  - such  as
208, 201, HUD program, EPA programs - and  the ability  of the  public  to
take hold of the programs were also brought out.

     I discussed public participation with project officers on specific
201 projects in Region I IT, as follows:

Maryland

     The three Maryland projects reviewed  were  East New  Market - Secretary,
Cambridge, and  Kent-Narrows-Stevensville-Gresonvine,  P.P.

     The East New Market-Secretary  project was  a combined sewer  of two
towns with a combined population of 750  people. The public was  aware of
the project and the wastewater treatment works  generated little  controversy.
TWO, well advertised, public hearings  took place,  which  brought  out  an
Attendance of about 5 percent of the population.   Public participation
dtd not influence the project. The  main  controversy was  whether  there
should be joint or separate sewage  treatment plants.   A  single treatment
plant was chosen.  Comments were asked for; none were  received.

     In Cambridge, with a. population of  50,000, there  was no  public
participation,  though a public hearing was held, there was no response.

     The Kent-Narrows Steyensville-Gresonville, P.P..  with a  population
Of 10,000 had what Region "III considered good  public participation.
Special public meetings took place  prior to the public hearing.  Due to
public input there were relocations in  the sewer line  and elimination of
                                 12

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service to an area which did not require a collection system.   The
controversy in the project involved the local  desires for more  extensive
service.  Reduction in the service area were due to PRM 77-8 and  cost.
The overall project appeared to satisfy the needs and desires of  most
people.

Pennsylvania

     In Pennsylvania, Lynn Township and Rush-Ryan-Delano Joint  Sewer
Authority Projects were reviewed.

     In Lynn Township, a community of 720, a sewage treatment plant and
interceptor sewers were built.   No public participation took place prior
to the public hearing, and minimal legal  notification of the meeting
took place.  As a result, the public did not participate in Step  1
planning.

     Rush-Ryan-Delano Joint Sewer Authority, with a service population
of 3500, had a planned public participation program.   Meetings  were held
in each town before the public hearing and the news media was involved
in publicizing the program.  As a result of public participation  there
was improvement in the environmental quality of the project.

Virginia

     The City of Chincoteague,  with a population of 5300, developed a
treatment plant and sewer plan.  A plan to involve the citizens was
established prior to the development of the facility plan.  Public
meetings were planned and held which were well  advertised and publicized.
As a result of the public participation,  a project that was estimated to
cost some $6,000,000 was not butH.  The reason for the no action alternative
was due to the fact that this project was near a National Park  where
sewers would have had a major impact on wetlands.

West Virginia

     The Lake Floyd Public Service District project,  which sewers a
population of 1300 people, had public participation only at the required
hearing.  The public participation had no effect on the project.

     In Virginia and West Virginia the region  has informally delegated
pufaltc participation to the State and a State  representative is at every
meeting.

     The regign assumes public participation to be an eligible  cost and
feel? that regulations shpuld require early public participation.

     A case-by-case review of public participation plans should be left
to the discretion of the region.
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     Where applicable,  208 and  201  public  participation  should  be coordinated.

     The region brought up the  fact that lack  of  public  participation
often creates problems.  For example,  a  facility  plan may  be approved
after a public hearing  has been held.  The applicant receives its design
(Step 2) grant.  When construction  money is allocated (Step 3)  and
construction begins* a  major controversy may take place, requiring  the
region to go back and prepare an EIS.  This holds up a project  and  could
require the redoing of  Steps 1  and  2.

      When a project is planned, there may be  controversy  for one or
more elements.  Better  public participation may,  at the  least,  point out
the controversy so that an EIS  would be  done early and not hold up  a
project. Public participation through the  construction phase is desirable.

     When major efforts were made to involve the  public, both in 201 and
208 programs, project officers  were often  disappointed by  the lack  of
public response.
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                                 REGION V

     In Region V» due to the number of large populated  states  involved,
an average of five communities per state were examined.   In  addition I
met with staff persons, including Ms.  Annette Nussbaum, with whom  I was
so impressed that an entire chapter is devoted to  Ms. Nussbaum's public-
participation efforts.   Others I  met with  in Region V were:

     Charles Sutfin
     Charles Orzehoskie
     Robert Goltz
     Cynthia Wakat
     Doug Hall (State of Minnesota - telephone)
     William Benjey
     Michael Mikulka
     John Piccininni
     Al Kraus
     Gene Wojcik
     Ron Drainer (State of Illinois -  telephone)
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                            PROJECTS REVEWED
 1.   Minnesota
       Beinidji
       Moorehead
       Annandale
       Green Lake  Sanitary District
       Orno Long Lake Interceptor
2.  Wisonsin
       Delfield-Heartland
       Sun Prairie
       Heart of the Valley
       Hurley, Wisconsin  -  Iron Wood, Michigan
       Lancaster
3.  Ohio
       Indian Lakes
       Columbus
       Springfield
       Plain City
       New Concord
4.  Michigan
       Bay City
       Bear Lake
       Ecorse Creek
       Lincoln Twp
       NW Ottowa Facilities Plan
       Central Branch County
5.  Illinois
       Ogden
       Rankiu
       Mar ting ton
       Rockford
 6.   Indiana
       Stueben Lakes
       New Palestine
       Marshall & Bloomingdale
       Laporte
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Mi nnesota

     The City of Beinidji, population of 11,480,  developed a Step 1
facilities plan for a $6,000,000 sewage treatment plant.   The project
was begun in 1970-1971 and EPA became involved around 1975-1976.

     The consultant went ahead with the facility  plan and proposed a
land application sewage treatment system.  This was proposed at the
required public hearing where enormous controversy took place,  requiring
EPA to do an EIS, which is now underway.  Several  hundred people  attended
the required public hearing, where they objected  to land  treatment.   As
a result of the public hearing and public reaction, the consultant came
up with a treatment discharge program, and EPA asked for  further  review,
because the land application was most cost effective.

     This project is a clear indication where public participation would
have indicated controversy and where public input would have affected a
choice of alternatives.  Due to the lack of public participation  the
project was held up and the facility plan had to  be redone after  it had
been completed.

     The City of Moosehead held three separate public hearings  for a
$9,000,000 treatment plant.  In addition, there were meetings with
special interest groups prior to making choices on alternatives.   All
meetings were well advertised and publicized.

     As a result of the public participation the  sewage treatment plant
was located in a different part of the service area than  originally
Anticipated by the engineer.  Step 1 is not yet completed, and  it is not
possible to determine the effect on the environment or on costs that
were due to citizen involvement.

     The Town of Annandale, population 1600, required a $724,000  sewage
treatment plant.  There was no plan for citizen participation.  As a
result, 20 to 30 people showed up at the public hearing.

     In thts project the engineer decided to use  a stabilization  pond.
public participation changed the engineer's design (with  the active
encouragement of the State of Minnesota and EPA)  from a stabilization
pond to land application.  The end result was a less costly system which
also was less environmentally damaging.

     Earlier citizen participation might have speeded up  the Step 1
process.

     The Sreen Uke Sanitary District sewers two  communities, New London
and Sptcer, with a service population of 3000. The two communities  have
separate treatment systems; a lake near these communities has homes
sewered by septtc tanks.  Within the towns phosphorous removal  is a
problem.
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     Prior to the required public hearing  there was  no public participation.
At the public hearing controversy appeared,  which required  EPA to  prepare
an EIS.  The controversy was primarily due to costs.   In  this project
early citizen participation would have surfaced the  controversy sooner.

     Orono-Long Lake Interceptor is located  in the Twin Cities Area.
The City of St. Paul holds a public hearing  once a year on  its capital
improvement program, which it (St. Paul)  considered  adequate to meet  the
required public participation objectives.   The State of Minnesota
required the City to notify affected land  owners and hold  hearings.  As
a result of public participation and State involvement, the project was
removed from wetlands and a program for easements rather  than outright
purchase was used, which enabled the landowners to use the  surface area.
     An existing sewage treatment plant sewers the Town of Ely,  which
was built by EPA as a research and development demonstration program.
Due to the high operating cost of this project, the town plans to
abandon the plant.  Public discussion is now underway whether the town
should take over this plant or develop a new plant with lower operating
costs.

     There ts an excellent relation between EPA and the State of Minnesota.

Wisconsin

     The City of Lancaster proposed sewage treatment plant improvements
at tts existing site for its 10,000 inhabitants.  At the regular hearing,
that was not well advertised, complaints and 15 letters were received.
As a result, EPA required a second public hearing.  EPA agreed to the
proposed project after the second public hearing.

     A Hurley, Wisconsin and Iron Wood, Michigan lift station and force
main for $200,000 with respective populations of 2300 and 8000 was
proposed.  The required public hearing was held.  This project was
simple a.nd non-controversial .  Additional citizen involvement would have
hacTno effect tn this project.

     The Heart of the Valley- project sewers several counties and a
population of 300,000.  A new sewage treatment plant and interceptors
costtng $19,000,000 wa,s proposed.  Good newspaper coverage of the project
a,nd consultant presentations before civic groups took place prior to
choices being made on the alternatives.  Citizen interest was passive.
                                    18

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     The project was in a river bed which was not adequately brought out
at the first public hearing.  A second public hearing was held and every
property owner along the river front was notified.   Eighty percent of
the river front property owners were at the second  hearing.   They all
wanted the project.

     Sun Prairie, a community of about 20,000, had  public participation
both before and after its public hearing.  In this  $7,000,000 sewage
treatment plant and interceptor sewer project, public participation
caused some changes in the public facility plan and some changes  in the
details that the facility plan dealt with.  A better facility plan did
come about due to public participation, but no changes in the alternative
occurred.  Due to the publfc participation some issues were raised and
discussed.  The Regional Planning Commission participated in meetings
with the public and helped to explain the program.

     Due to the public interest, meetings were held after the public
hearing. The facility plan looked at several alternatives, including
regionalization and land application, but settled on advanced water
treatment prior to discharge into a river.

     The Delefield-Heartland sewage treatment plant and interceptors
which sewer about 30,000 people, costing about $12,000,000,  was developed
without citizen participation, but became a political issue.   The first
facility plan was submitted when elections were about to take place.
The election issue centered around the wastewater treatment facility.
A,s a result, new officials were elected.

     The new officials fired the engineer and hired another  engineer to
redo the project.  Two additional public hearings took place besides the
original public hearing.

     The news media were involved.  Some citizens asked for  an EIS.

     The State of Wisconsin provides excellent cooperation and coordination
On EPA projects.

Ohio

     Indian Lake is a resort community whose seasonal population  varies
from about 10,000 to 93,000.  A 23 million dollar sewage treatment plant
a,nd interceptor sewer project was planned for this  community without any
public participation.

     Lack of public information about the project led to "investigative
reporting" by the Iqcal newspaper.  As a result,  just prior  to the
public heartng, the local newspaper came out with a headline and  story
staging that sewers could cost $50 per month to local residents.   As a
result of the newspaper articles, about 900 people  showed up at the
public hearing, including a representative of the Sate of Ohio.   The
                                   19

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State officials added fuel  to the controversy by threatening  to "close
down the community" if the wastewater treatment facilities were not
built.  The County Commissioner, who moderated the public hearing,
failed to answer any questions.  The public hearing lasted from about
7:00 PM to 1:00 AM.

     After the public hearing about 120 letters were sent to  EPA's
regional office objecting to the project.  A later petition was submitted.
EPA Ohio was confused with U.S. EPA by local  residents,  which was  reflected
in the letters.

     Lack of public participation and the objections filed caused  U.S.
EPA to send the project back to the State of  Ohio to take a look at
possible alternatives.

     No decision has yet been made on whether EPA will  do an  EIS.   The
applicant held two additional public hearings and plans  no further
public participation.

     Columbus, a city with a population approaching one million, prepared
a facility plan costing between 60 and 80 million dollars. At the
present time EPA is doing an EIS primarily because there was  poor  public
participation.  Citizens complained to EPA that they were not well
enough informed prior to the choice of alternatives to  provide public
input.

     There is likely to be increased cost to  the project due  to citizen
participation, since the cost escalation of construction will occur
while the EIS is being written.

     This project is an example of poor public participation  in a  major
city.

     In Springfield, a,$12,000,000 project award was made, which is
being held up due to a law suit against Summit County.   There is speculation
tn the regional office that the law suit might not have occurred if
public participation would have been better handled. A citizen group
was formed to oppose the. project due to costs.

     Plains City- planned to butld a $4,700,000 oxidation ditch for its
2400 people.  No public participation took place until  the required
public hearing.  It is speculated that public participation would  have
been responsible for a better project by looking at alternatives.

     New Concord held the minimum required public hearing for its  sewage
treatment plant a,nd interceptor sewers, which together  cost about  \h
mtllton dollars.  The 2800 people in the town were not involved.  Even
the public hearing consisted merely of public officials and the consulting
engineer.
                                20

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     It was speculated by EPA that public participation would have
brought about a better project.

Michigan

     Bay City is a community of 200,000 where a $60,000,000 sewage
treatment plant and sewers were proposed.  The consultant was very
familiar with the community, which helped him to develop a coordinated
public participation program at the outset.  Not only did the consultant
do an excellent public relations job, but he coordinated with county
officials.  As a result, the people were well informed.

     One of the things the consultant did was to talk to industries at
an early date.  As a result, Dow Chemical Company donated 75 acres for
a sewage treatment plant, of which 50 acres will be used as a park.

     Public meetings were held before the decision on alternatives took
place.  Costs were fully explained and publicized.

     As a result of citizen participation there was a definite decrease
in costs and improved environmental quality.  One hundred and fifty
people attended a well advertised meeting.  Issues were raised at the
public hearing that affected the final plan.

     Bear Lake's facilities plan calls for an expenditure of $5.5 million
for a sewage treatment plant and sewers.  The consultant mailed questionnaires
to the entire community before starting the project.  Only 15% of the
populace received the questionnaires.  The tourists to Bear Lake generally
failed to participate, but wrote to EPA to voice their objections.

     A property owners association was formed to oppose the project,  due
to costs, which caused public participation.   As a result, extra public
meetings were held during the summer.

     About 100 people attended the public hearing, after which two more
hearings were held.

     It was felt by EPA that public participation could have been handled
better by the applicant.

     Ecorse Creek is in populous Wayne County.  A sewer separation
project, serving almost 400,000 people, was proposed with public participation.

     As a result of public participation and  EPA policy, which forced
many changes and which delayed the project, the cost was decreased  from
an originally estimated $175 million to $60 million, sewer lines were
relocated, which improved both the environmental quality and the social
conditions.  Between 200 and 300 people attended the public hearing.
                               21

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     Lincoln Township, population 10,000,  planned  to  develop  collection
sewers, a force main, and a pump station costing $8.5 million dollars.

     The consultant sent out 2600 questionnaires and  received 1600
replies.  These questionaires and a public meeting  allowed  local  participation
to occur before a decision on alternatives was made.

     The consultant made about 300 telephone calls  the day  before the
public hearing asking people to attend the public  hearing.  As a  result
of the open policy of the consultant,  strong support  for  the  project
took place.

     In addition to the public participation, the  consultant  coordinated
his project with the regional planning agency, which  submitted an
early, favorable A95 support statement.

     The facility plan was completed in a  very short  time period  -  about
6 months.  Public participation helped speed the project.

     The Northwest Ottowa Facilities plan  for sewers  serving  13,800
people in Ottowa County, is estimated  to cost $17,500,000.  This  area  is
in desperate need of sewers and is high on the State's priority list.

     Several township meetings were planned  prior  to  the  public hearing
to involve citizens prior to decisions on  alternatives.  However,  there
was poor citizen participation at these meetings.

     The Lake Michigan Federation petitioned EPA to provide changes.
The citizen participation resulted in  lower  costs  for the project and
improved environmental quality as some sewers were not built  on sand
dunes.

     Central Branch County's facility  plan requires 4n all  new system
for its people, costing $12 million.  Almost 250 people attended  the
public hearing.  After the public hearing  the facility plan had to  be
revised.  Land application with spray  irrigation on leased  land is  now
being proposed.  A new public hearing  for  a  decreased cost  and an
improved environmental quality project is  to be held.

Illinois

     The City of Ogden proposes a collection system with  sewage treatment
facilities for its 543 people.  The State of Illinois sees  no demonstrated
need at this time.

     Public participation did not exist on this project except for  the
required public hearing.  This project is  not expected to go  ahead.
                               22

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     In the Town of Ranken, population 727, a sewage treatment plant and
collection sewers were proposed.  No public participation, except the
public hearing took place.  The State of Illinois has returned the
project to the community so it could evaluate using the existing treatment
system.

     In Martington, population 300, a clustered septic tank system was
deemed adequate and was proposed by the consultant.  Public participation
included special meetings with citizen and public meetings with citizen
groups. The consultant had to sell this system to the community and
compared the user costs of $13 per month to the next lowest cost of $17
per month.

     As a result of public participation this lower cost system was
approved by the communtty and by the State.

     The City of Rockford, with a population exceeding 100,000, had made
an effort to involve Its citizens in public participation in various
sewer projects by scheduling different public hearings in neighborhoods.
Very few people attended the hearings.  An apathetic community did not
affect the project.

     In the State of Illinois there were many consulting engineers that
convinced very small communities that they needed sewers and treatment
facilities to meet EPA requirements.  As a result there were a very
disproportionate number of small projects submitted for State prioritizing.
The State issued a moratorium for small community systems until a
review of applications could be made.  This is an example of outright
misrepresentation of EPA by local engineers.

     The State of Illinois requests (not requires) communities to use
larger ads to publicize public hearings.  It also encourages communities
to have early public meetings.

     Urger communities in Illinois are not finding the public concerned
with the HOI program, according to State officials.

Indiana

     Steuben Lakes is a resort community whose population varies from
6000 permanent residents to 22,000 seasonal residents.  A 2 MGD STP and
sewers costing $14 million is proposed.  An EIS by EPA is now underway.

     The consultant scheduled one meeting with each Lake Council and
eventually met with public groups on a weekly basis, getting good public
response.

     The resulting citizen participation increased the total project
cost and hurt the" environmental quality through relocation of sewer
Itnes.  About 80 people attended the public hearing.
                                23

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     New Palestine is located about 6 miles from Indianapolis with a
population of 863.

     New Palestine is an example of poor public participation and shows
the need for EPA attendance at public hearings.  The public hearing was
moderated by the city attorney.  At this public hearing all questions
relating to costs were deemed inappropriate and, hence, were not answered.

     The New Palestine project dates back to 1972 when a P.L. 660 grant
was made to the applicant.  litigation occurred as EPA was sued to
prepare an EIS.  EPA requested the town to prepare an environmental
assessment.  As a result EPA issued a negative declaration in March,
1977.

     The town is trying to build a sewage system that will induce development.
Those opposed to the extensive sewering are anxious to preserve agriculture
in the County.  A conflict occurs regarding future land use development
which affects this project. Some conflict of interest questions have
also been raised.  Better public participation would have surfaced these
conflicts sooner.

     LaPorte's sewage treatment plant, costing $6,000,000, is to serve
the city of 18,000.  Two meetings were held prior to the decision on the
alternatives at which time people living downstream from the treatment
plant were very concerned.

     As a result of public participation the cost was decreased and
environment improved.  Of the 50 people attending the final public
hearing,  40 came from outside the sewage service area, living downstream
from the discharge point.

     Marshall and Bloomingdale are two small communities with populations
of 365 a.nd 391 respectively.  These communities were several miles
a,pa,rt.  A proposed connecting sewer and sewage treatment plant were
proposed by the consulting engineer, costing $2,000,000.  No public
participation took place until the required public hearings.  Twenty-two
citizens attended a public hearing in Marshall and nine citizens attended
a, public hearing tn frloomingdale.

     The engineer stated that the two communities were presently in
violation of the law and that the proposed system (no alternatives) he
designed would be the only system which would bring about compliance
W;ith the eixtsting law.

     Bloomtngdale rejected the proposed plan due to costs.

     This project had virtually no public participation.
                                 24

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Public Participation Comments -  Region V Staff

     EPA should establish new regulations on public participation which
would:  •

     a) require meetings soon after grant has been made;

     b) require meetings before alternatives are chosen;

     c) require publication of user costs;

     d) require better advertisements, including large advertisement in
        paper - not just legal ad - public service announcements on
        radio, etc.;

     e) there must be a method to enable the communities to meet public
        participation requirement if the community does not start public
        participation early (catch up).

     The regional staff believes that coordination b.etween 201 project
public participation and 208 project public participation should be done
wherever applicable.  Some staff feel that the broadest coordination
should take place.  Most staff are reluctant to broaden public participation
of 201 programs beyond the 208 program, feeling that 201 projects would
get lost among other projects.

     More fteld work by EPA staff is needed.  Project officers should be
more visible and accessible.  One project officer felt that all  government
employees were vtewed in small communities as "the bad guys".

     EPA employees should, it is generally felt:

     a) hear problems in communities first hand;

     b) forestall engineers from "pulling the wool" over public's eyes;

          l\ Examples:

               a) Ctty Attorney in an Indiana city who moderated
                  the public hearing stated that EPA is not interested
                  in costs. He then determined all questions on  cost
                  were irrelevant and not to be discussed.  This is not
                  untypical in Region V.

              • b) In an other Indiana city, the enineer did not  prepare
                  alternative solutions, implying that the community
                  ha,d to build thts system (one he designed) to  conform
                  wiNth existing Federal laws.  More detailed analysis of
                  non-conventional systems should have been made.
                                 25

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               c)  In Illinois,  before emphasis  on small  treatment
                  systems became popular,  engineers  visited  small
                •  communities throughout the State claiming  that the
                  community had to have a  sewage collection  system  and
                  treatment plant or they  would violate  the  law.

     Better facility plans occur when the  public participates  in a  201
planning program in the following ways:

     A) Allows public to know about project and its  scope before final
        decisions are made;

     B) Generally puts the engineer in a position where  he must think
        things through, and by being responsible to  public scrutiny,
        he will do a better job;

     C) Enables the project to have input  by people  who  are  affected,
        such as those living downstream of the  discharge point, at  an
        early time.  This often brings out controversy before  there is  a
        commitment to any specific solution and may  result in  an early
        EIS decision;

     D) Public participation may have eliminated the need for  an EPA
        EIS in many instances or identify  where early start  up (piggy-
        back) is possible;

     E) Environmental concerns would surface early.

     Region V ts committed to public participation and encourages such
public participation in a, 11 201 projects.   The  region is far ahead  of
local and State officials in its support for public  participation.   In
most instances the best public participation programs came about through
the regional office's direct involvement and suggestions that  early
public participation take place.  Project officers often had to prod
local agencies and consultants to start the public participation programs
early-

     The dollar commitment in public participation is not necessarily  a
    ure of good public participation.  Some communities  used minimal
funds, but had good public participation,  while others used  large sums
a,nd ha,d poor public participation. . The resourcefulness  of the involved
Officials and engineers plays a much greater role than dollars committed.

     At the present time there is extensive staff travel. At  the rate
of existing staff travel, the present travel budget  in the water division
will be depleted by July.  Yet it is important not only  to make EPA
visible in 201 projects, but also to visit State agencies, especially
with new delegation provisions of the Cleveland-Wright ammendments, and
visits to Corps of Engineers offices.
                                   26

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     Many problems could be solved if EPA and the State met with the
applicant and engineer early.

     It is desirable to advertise costs in the required notice of public
hearing.  The advertisements should be more than tiny legal  notices.

     One suggestion, that a minimum number of people should  attend a
public hearing, was made.  The project officer thought that  EPA should
establish a quorum requirement.

     PRM 77-8 requires that engineer be educated.  Some engineers don't
know how to design alternate systems - critical  in small  communities.

     The 208 public participation experience in  Region V has prompted
many project offices to ask for similar 201 assistance in public participation,
The use of a trained person who can direct the use of spot announcements,
movies, and advertising to make people aware that they can partake in
public policy is deemed a necessity.

     Care needs to be taken so that interested people living outside the
immediate service area, such as downstream residents, are as informed  of
the public participation opportunities as the people within  the 201
project area.

     Establish new regulations requiring early public participation, but
leave maximum implementation discretion to regions.
                                  27

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                             REGION VI

     I visited Region VI and among the  staff I  met were the following:

     Ned Burleson
     Hendon Crane
     Joe Haney
     Richard Harper
     Bob Hillery
     Dave Neligan
     Gene Wossum

Texas

     San Antonio began a citizen participation  plan early.   The consultant
included citizen participation as one element in his Plan of Study and
participated in meetings and workshops.

     In San Antonio two consultants were hired; one to do the facility
plan without the environmental impacts  and one  to do an environmental
impact statement - piggyback.  The estimated total  costs were $36,000,000
for a sewage treatment plant and $100,000,000 for sewers.

     In the early stages of the project EPA and the grantee met and
determined that a broad-based citizens  advisory committee should be
formed which consisted of members from  following:

     Federal /Military Impact                 I  Representative
     Spanish-American Community for          1  Representative
       Economic Development
     The Business Community                  Several Representatives
     Aquifer protection                      1  Representative
     Mayor of a Small Community              1  Representative
     Ctty Council                            1  Representative
     San Antonio Redevelopment Authority     1  Representative

     The advisory commtttee meets monthly, at which time both consultants
bring progress reports and EPA and the  State are present.  In addition,
San Antonto hired a publtc relations man who spends about 80 percent  of his
time on the 201 project.

      A local brewery sponsored a bus tour for  the advisory committee so
that members could see existing and proposed facilities from the ground.
         advisory committee sponsored workshops for special  interest
groups to broaden public involvement.  When the consultant was ready to
do sewer smoke tests, special flyers were distributed to residents
warning of the tests and explaining to the public that manholes would
emit smoke.  This publtc awareness resulted in good public relations,
and po unnecessary- fire calls.
                                   28

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     The advisory committee recommended a solution that was not the most
cost-effective and might increase the total  cost; it also established a
priority system in which sewer construction  for interceptors and collectors
was phased to meet anticipated revenues over a period of time.

     The Citizen Advisory Committee is expected to function through the
construction period.  It will notify people  of construction progress and
traffic impedments due to construction.

     Citizen participation may have held up  the project by one  or two
months, but it probably justified its existence by surfacing public
concerns at an early date and having no major controversies at  the end
of Step 1.

     By contrast, in Houston there was little public participation in
the 201 planning.  The public was aware of the need to sewer the city
and provide new sewage treatment facilities.

Oklahoma

     Bartlesville proposed $4 million expenditures on a treatment plant
and $5 million on sewers in its Step 1 program.

     Public meetings were planned and held prior to the decisions on
alternatives.  Newspapers and radio provided excellent coverage before
the public hearing.

     A citizens advisory committee, made up  of engineers, was appointed.
Both public and private meetings were scheduled with the advisory committee.

     As a result of the controversy, which was in large part due to the
location of the sewage treatment plant, many petitions were received by
EPA» both for and against the project.  The  Regional  Administrator went
to Ba,rtlesvllle to personally conduct a public hearing before accepting
Step I.

     A bond election for sewers was approved with a 9:1 majority.  Later
three councflmen who were opposed to the facility plan were defeated in
thetr bid for re-election.

     The Tulsa Regional Metropolitan Utility Authority is developing a
plan for an $80,000,000 wastewater treatment facility consisting of a
          plant and sewer lines.
     In thts project public participation did not take place  until  after
major decisions were made on alternatives.  At the public hearing  there
emerged controversy over the discharge location into a local  creek.
                             29

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     Citizen group involvement took place after the public hearing  and
after a special meetings with EPA staff.   EPA organized  an ad  hoc committee
which looked into alternatives,  one of which was an outfall  sewer to  the
Arkansas River.

     Citizen involvement will affect the  project by decreasing the  cost
of the project and improving the environmental  quality.   Earlier  citizen
involvement would surely have saved time.

New Mexico

     A steering committee, meeting monthly with citizens and special
interest groups, was organized in Alberquerque for its $25,000,000
wastewater treatment project.  Citizen participation took place early,
and steering committee meetings  had as many as  100 people attend  monthly
meetings.

     Partially as a result of public participation, an EIS was piggy-
backed, which saved time.        .  ,

     Public participation improved the environmental quality of the
project, but had no effect on costs.  The facility plan  was  responsive
to citizen scrutiny, and changes were made due to citizen participation.

     Forty-five people attended  the public hearing for the facility
plan.

Region VI Public Participation

     Region VI considers each community to contain unique conditions  to
which ft tries to be sensitive.   The region is fully committed to
public participation and believes that when the public is involved  in
facility planning, everyone benefits.

     Region VI requires a plan for public participation  in the plan of
study.  As a minimum, the plan must encompass preparation and  distribution
gf a fact sheet about the project, news releases to the  press  and a
public hearing before the final  plan is selected.  A draft regional
policy statement for Region VI is attached.

     It is suggested by Region VI that Headquarters issue guidance  on
eligible funding for public participation.  For example, is a  community
eligible for reimbursement for their public relations employees'  time
spent directly- on public participation?  Can the tour of existing plants
and proposed STP sites by' an advisory group be an eligible cost?

     The regional staff often finds it frustrating to promote  citizen
participation  and find few who attend public meetings and hearings.
                               30

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     REGION VI POLICY STATEMENT ON PUBLIC PARTICIPATION

             IN STEP I FACILITY PLANNING GRANTS
     EPA's commitment to public participation in planning wastewater
treatment facilities arises from our concern that Federal requirements
for pollution abatement be carried out with sensitivity to the unique
conditions in each community.

     The national construction grants program is vital  to clean water
goals.  The primary goal of the program is to improve the water quality
in our rivers and lakes.

     To accomplish this, Congress has provided, and is  expected to
continue to provide, billions of dollars for the Federal  portion of the
costs of building municipal wastewater treatment facilities.   Millions
of those tax dollars are being spent in communities throughout Region
VI.

     The community is where the action is.  When the public becomes
interested and involved in planning treatment facilities, everyone
benefi ts.

     The public has a right to be assured that long-range community
goals are being served and that the plan adopted is cost-effective and
environmentally sound.  Public participation means consultation with the
public.  It means a dialogue between government officials and  citizens
about decisions that may affect peoples' lives and the  shape of their
communities.  It means informing the public about alternatives and
options and making sure that public responses are incorporated into
final project decisions.

     Early and effective public involvement is the way  to avoid time-
consuming last minute court actions and demands for further environmental
studies.

     Adequate public participation increases the probability that the
completed facility plans will have sufficient support throughout the
community to be implemented as expeditiously as possible.

     Public participation is required under section lOle  of the Federal
Water Pollution Control  Act which states:  "Public participation in the
development, revision, and enforcement of any regulation, standard,
effluent limitation, plan, or program under this act shall  be  provided
for, encouraged, and assisted..."
                                 31

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     In line with this requirement, it is EPA policy that the public
must be involved at the earliest possible time in the development of all
Step I facility plans.  It is therefore Region VI policy that:

    *A plan of public participation must be outlined in the Plan of
     Study and summarized in the completed facility plan.  As a  minimum,
     the plan must encompass preparation and distribution of a fact
     sheet about the project, news releases to the media, and a  public
     hearing before final selection of the plan.

    *In situations where there is substantial indication that the project
     may be controversial, an Environmental Impact Statement, if needed,
     will be prepared concurrently with the plan  development and the
     public will be so advised.

    *In controversial situations, a citizens advisory committee  should
     be established at the beginning of the planning process.

     Development of an effective plan of public involvement, for each
Step I grant project, will help  assure maximum efficiency in the expenditure
of tax dollars allocated to your community through the U.S. Environmental
Protection Agency.
Adlene Harrison
Regional Administrator
                                 32

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     RECOMMENDED STEPS TO ENCOURAGE PUBLIC PARTICIPATION

     Identify the individuals and groups in the community most likely  to
be affected and/or concerned about the project.  Compile  a mailing  list
of individuals and community groups, such as agriculture, business,
industry, consumer, women, environmental, labor, minorities,  urban,
youth and public interest.

     Identify the issues of public concern to be addressed in the course
of plan development.  These should be included in a  fact  sheet in laymen's
terms about the project given wide distribution as early  as possible.
Public involvement activities should begin 60-90 days  before  any public
hearings are scheduled.

     Distribute a news release announcing the project  ot  all  local media
plus the general mailing list.  Participation of local  officials in  the
pre-application conference might be used as a "news  peg"  to make the
announcement.  News releases should be issued at each major step in  the
plan development process.

     Schedule and publicize at least one informal  public  meeting/workshop
to discuss the issues identified above.   Names of those attending should
be added to the mailing list.  Follow-up public meetings  should be
scheduled as necessary.

     Form an advisory committee representing a cross section  of the
community to spearhead the public participation program.

     A field trip to the proposed site or sites might  be  undertaken
especially in controversial situations.

     Schedule and publicize the required public hearing before a decision
on the facilty plan is made.
                                33

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                                REGION IX

     In Region IX,  I  discussed public participation with  regional  staff.
Among the people-I  talked with were:

          Richard Coddington
          Mark Zuckerman
          Fred Krieger
          Bill Helphingstine
          Loraine Pearson
          Doris Lee
          Mark Brucker
          Val  Danos
          Chirs Carroll

     The following  projects were examined:

California

     Central Contra Costa
     Los Angeles Wastewater Facilities Plan
     Orange County Sanitation District
     East Bay Discharge Authority
     Los Angeles County - Joint Outfall System  Facilities Plan

Arizona
     Globe
     Pheonix
Nevada
     Clark County Sanitary District
     Las Vegas
     Dayton
     Sun Valley
                               35

-------
 California

     The Central  Contra Costa facility  plan  involved  citizens  prior  to
the decision on alternatives  for  its  $50 million  sewage  treatment  plant
through a series  of community workshops.  This  project considered  the
need to provide for growth, which became a major  issue.  The area  is
struggling with air quality,  unemployment and costs.  There also was a
question regarding the use of solid refuse in the treatment plant  as
fuel.

     The facility plan and EIS have been completed.   One hundred and
fifty people attended the public  hearing, which was well advertised with
an eight page Sunday supplement in the  local newspaper.  There is  no
indication that public participation  had an  effect on the  project.

     The City of  Los Angeles  developed  a facility plan with piggyback
EIS for its $300  million wastewater treatment facilities.  Through its
community action planning staff the City of  Los Angeles  involved the
public and obtained public participation. An eight page supplement  to
the Los Angeles newpapers was produced  for distribution  to the public
for EIS meetings  and citizen  comment.

     There appear to be no major  effects due to citizen  participation as
citizen turnout was exceedingly light for public  meetings, public
hearings and workshops.  In  any case, there  was ample opportunity  for
citizens to participate in the decision making  process.

     The Orange County Sanitation District selected a task force from
different locations and interested citizens  in  the county  who  acted  as
a citizen advisory committee  and  developed workshops  throughout the
proposed service area.  Their main concentration  was  on  the EIS that was
piggybacked with the facility plan.

     Numerous press releases  were issued by  regional  staff on  the  EIS to
all medta.  An eight page special Sunday supplement was  placed in  local
newspapers inviting comments.  Five workshops were held, bringing  out
about 200 people to each workshop.

     There were some improvements in  the final  facility  plan due to  the
workshops and citizen participation."" It is  difficult to determine how
the cost of the public participation  could be justified, based on
attendance,        .•1-

     In Los Angeles County a  joint outfall system facility plan was
proposed, together with an EIS that was piggybacked.  A  plan for citizen
participation was developed  prior to  beginning  the facility plan,  which
included a citizens committee to  be formed with many  workshops.
                                36

-------
     Public participation did take place.   In addition,  an  eight page
Sunday supplement was put into newspapers.   A slick summary of  the EIS
was mailed to each household prior to the  public hearing.

Arizona

     The City of Globe developed a facility plan for a required treatment
system with the Town of Miami in 1972.  Globe received a grant  for Steps
1, 2, and 3, and were given out simultaneously.   Construction for a
$500,000 interceptor was completed in 1972 before construction  halted
due to local controversy.  In 1975, Region IX made a decision to do an
EIS to resolve local controversy before proceeding with the project.
The EIS process had an active public participation program  and  a final
EIS was issued in April, 1976.  In essence, it refuted the  earlier
project concept of a regional treatment system,  and recommended two
separate treatment systems.  The $500,000  inteceptor, already built,  was
not to be utilized.

     It is evident that an effective public participation program in
1972 may have demonstrated that controversy existed and an  EIS  done
earlier or the controversy might have been resolved and an  EIS  might not
have been necessary.

     An early, effective citizen participation program might have saved
as much as $500,000 tn facility planning,  design and false  construction.


Diagramatic Sketch of Project as Proposed in Globe
                         _

                                  """
       fop - 7ooo
                                   37

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     The City of Pheonix developed its facility plan,  with an estimated
cost of $50 million, for a wastewater treatment plant and sewers with an
EIS piggybacked.

     Three citizens advisory committees were organized and many workshops
took place.  In this case the 208 mechanism for public participation was
used in the 201 project and close coordination between 201 and 208
planning took place.

     Meetings in Pheonix were well advertised.  The results from the
advisory group are becoming very helpful; it reviews the content,
presentations, conclusions and other aspects of the facility plan.  Some
improvements in environmental quality of the project are evident.

     The chairman of one of the advisory groups works for the State of
Arizona and is given time off to be active on the advisory committee. As
a result, the chairman spends considerable time on the project.

     The three committees meet two to three times per month, each.

     Meetings of the advisory committee take up about half a day per
month.  EPA attends few meetings and the EIS and facility planning
consultants are paid to attend meetings.  In addition, 208 staff serve
the committee.

     The project is still underway and no final public hearings have
been held.  In this project, the regional EPA staff met with the city
a,nd insisted on public workshops.  The city chose the 201-208 advisory
committee as the tool for citizen participation.

Nevada

     The Clark County Sanitary District and the Toryabe National Forest
got together to develop a facility plan in an area that has many second
homes and is primarily a, seasonal community.  Concern with possible
septic tank failures prompted the joint study.

     A citizen participation plan was developed in which public meetings
took place tn December and flyers went out through the 208 agency.

     The first public workshop had four people in attendance; 50 persons
showed up for the second.

     In, this community public participation was deemed a failure, since
few showed up and few commented on the proposed plan.

     A non-structural solution is being proposed.  The final public
hearing has not yet been held.
                                   38

-------
     The Town of Dayton, population 800, had no public participation
plan prior to developing its facility plan.  However, controversy forced
citizen participation which resulted in a number of workshops for the
$600,000 sewage treatment plant and sewer project.  Questionaires were
completed at the second workshop and the residents have taken an active
role in the facility plan.  As a result of public participation, some
changes were made.

     In Sun Valley, population 900, there were a number of public meetings
held even though there was little planning for such meetings when
the facility plan was started.  The community was involved through
the citizen participation process prior to the decisions on alternatives.

     The district encouraged public participation through the use of a
monthly newsletter.

Region IX Comments on Cittzen Participation

     Region IX is committed to public participation and is willing to
pay for it.  Furthermore, Regfon IX takes the position that public
participation should go on throughout the grant program — through
Step 3 — until the total program is implemented.

     Community public relations programs which explain the effects of
construction such as street closures, traffic rerouting, and the like
should be eligible cost items.  Where large communities have existing
staff for public relations, these communities can handle public relations
adequately.

     In Region IX it is generally felt that public participation:

     a) provides for better projects;

     b) builds public support where lack of public support could delay
        or derail a project;

     c) provides liason with the community;

     d) should be started early in the planning process and be continued
        through Step 3;

     e) expounds the communication link between the State, the grantee,
        the consultant a,nd EPA.

     Require a publtc participation plan in the first phase of the
facility plan.
                                  39

-------
     Leave the mechanics used for public participation such  as  advisory
group, task force, workshops and the like up to  the grantee,  State and
region.  Minimum,guidelines should be issued from Headquarters.

     Small and medium sized communities need assistance from  someone
other than the engineer in implementing public participation, possibly
the EPA project officer.  In some instances, a public participation
consultant may be hired.  Large communities have their own public relations
staff.

     A policy statement on public participation  and changes  to  the
public participation regulations are needed which would specify minimum
criteria.
                                   40

-------
SPECIAL COMMITMENT OF REGION V TO PUBLIC PARTICIPATION « MS.  ANNETTE NUSSBAUM
     Region V hired Ms. Annette Nussbaum in its water division specifically
to help implement the public participation requirements of the 208
programs, which had previously been floundering.  Ms. Nussbaum comes
from a background, unique in EPA, which includes newspaper work,  radio,
television, advertising and theater.  As a result Ms. Nussbaum knows how
public participation can be promoted, knows how to program public meetings
in order to obtain the maximum public participation, and is capable of
channeling citizen participation into constructive actions that give
credit to the Agency.  Every EPA project officer that I talked with, who
was involved in the 208 program, had high praise for Ms. Nussbaum's
work.

     Among the things Ms. Nussbaum has done are:

     1. Preparation of EPA display material that can be used in State
        Fairs, regional meetings, and other public gatherings.  Several
        of the display packages - which consisted of questions and a
        choice of three answers - (where a light comes on when the
        correct answer is chosen) have been worn out by the public.
        While the display machine was being used, EPA brochures and
        public material were picked up.  Previous similar booths  were
        passed by.

     2. Records for radio spot announcements were made to advise
        people to, "come, come on in...the water's going to be fine...if
        you help on planning for clean water".

     3. Newspaper advertisements that address specific issues  exceedingly
        wellv

     4. Special handouts for 208 agency use at public meetings or prior
        to public meetings.

     5. A brochure that explains PL 92-500 in the language that a citizen
        can understand.

     6. Region V bulletins.

     7. Films that dramatise the benefits of clean water — fishable
        and swimable — in layman's terms.

     8. Provides special assistance to 208 project officers and occasional
        assistance to 201 project officers in providing for public
        participation.
                                  41

-------
     The uniqueness of Ms.  Nussbaum is that she occupies a position on
the staff within the water  division.  Her success in the 208 program has
been recognized by the entire region, and there is some talk about
coordinating all.public relations activities through the regional
public affairs officer — expanding the program to clean air, 201  and
other EPA activities. The water division is opposed to this policy
because they fear that it would take away their staff and thereby  dissipate
Ms. Nussbaum's effectiveness.  The Municipal Construction Division
should support the water division in Region V.

     The expansion of Ms. Nussbaum's activities into the 201 program
through additions in her staff is highly recommended.  A professional
public relations person like Ms. Nussbaum can help direct public partici-
pation expenditures and programs, further.

     Ms. Nussbaum is an example of the value of a public relations pro-
fessional in the regional office water division.  A similar position
should be established in other regions and the present position should
be expanded, with additional staff, as applicable, to work on 201  public
participation programs.

     Region VI, by contrast, uses their Office of Public Awareness to
assist in public participation programs.

     It has been demonstrated in the previous analysis of 201 projects
that the consulting engineer is generally not qualified to handle  public
participation, and often opposed to public involvement.  Regional  project
officers have been in the forefront in promoting public participation,
and they need the assistance of a professional  in order to aid them in a
field that is becoming increasingly important.
                                  42

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Population in Thousands
Cost in Million Dollars
STP (s); Severs (i); Both (*)
Environmental Impact Statement

i'Jeet With Special Interest Groups
Flyers
Use of (levs Media in Planning

Public Meetings j
Other
Innovations
Citizens Involved Before Decision on Alternative
Meeting Advertised
Minutes or Summaries
Costs Explained
Costs Publicized . :
Evidence Public Particip. Affsct&d Plan
Explained Environmental Effects

Ho Effect 7

Increased Total Cost

Decreased Total Cost
Improved Environmental Quality
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Relocated Sevagc Treatment Plant

Relocated Severs
Publicized Beyond Legal Advertising
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Issues Raised Affecting Plan


Response: fio Effect
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1 Response: Changes Suggested, Changes Made
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Response: Changes Suggested, Ho Changes Made
Staff Assistance to Citizen Groups

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Consultant Assistance to Citizen Groups
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COM.IUNITY








Population in Thousands




Cost in Million Dollars




STP (s); Sewers (i); Both (/t)




Environmental Impact Statement




Meet With Special Interest Groups




Flyers




Use of ilevs Media in Planning




Public Meetings




Other




Innovations




Citizens Involved Before Decision --n Alternative




Meeting Advertised




Minutes, or Summaries




Costs Explained




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Evidence Public Particip. Affected  Plan




Explained Environmental Effects




Ho  Effect




Increased Total Cost




Decreased Total Cost




Improved Environmental Quality




Hurt  Environmental  Quality




Relocated  Sewage  Treatment  Plaut




Relocated  Severs




Publicized Beyond Legal Advertising




Attendance  at Public  Hearing




Issues Raised Affecting Plan




 Response:   Mo Effect




 Response:'  Changes  Suggested, Changes Mude




 Response:   Changes  Suggested, Ho Changes Hade




 Staff Assistance to Citizen Group:;




 Consultant Assistance to Citizen Groups




 Other





                                          48

-------