905R80139


5464                                                              DRAFT


                             GUIDELINES  FOR THE PREPARATION OF
                               AN ENVIRONMENTAL ASSESSMENT

                           An Integral Component  of  the Cost-Effective
                           Analysis Portion of a  Facilities Plan


      A cost-effective analysis can be defined as a  systematic comparison of
      alternative ways of dealing with a wastewater  treatment and disposal problem
      in order to identify the solution which will minimize total costs to society
      over time.  These costs include monetary and environmental as well as other
      non-monetary costs.

      Cost-effectiveness is the central thrust of the Federal Water Pollution
      Control Act Amendments of 1972(PL92-500).   It  is an attempt to integrate all
      important considerations early in the decision-making process and to meet the
      detailed requirements of the law in an efficient manner.

      The cost-effectiveness analysis should be prepared so as to:

           1.  Provide the  rationale    for selecting a particular  course of
               action from among alternatives evaluated.  It is essential that a
               logical decision making process be followed and the factors governing
               selection be spelled out in the analysis.

           2.  Provide a document for evaluation  by  the general public.  In part,
               this means that unnecessary technical detail, technical jargon
               and acronyms should be avoided.

      In accordance with the National Environmental  Policy Act (NEPA), the EPA
      is responsible for preparing environmental  impact statements on facilities
      plans and resultant wastewater treatment projects that significantly affect
      the environment.  To carry out this task, EPA  requires that environmental
      assessments be prepared for all plans and projects prior to submittal.  These
      assessments are to provide data and information needed for EPA to develop the
      required environmental impact statements.   If  prop erly prepared, the facilities
      plan is, in fact, the environmental assessment.

      At the heart of environmental assessment is the need to take a broad view of
      the environment, encompassing physical/chemical, ecological, aesthetic, and
      social factors.  Another key point is the necessity to consider and evaluate
      complete packages of feasible alternatives  for meeting stated water quality
      goals.  Evaluation of alternatives is essential in the planning process to
      identify the most environmentally acceptable plan.  It is not the intent of
      NEPA that alternatives be screened solely on the basis of environmental impact,
      but simply to insure that environmental amenities are given due consideration
      along with technical considerations,  costs,  and public desires.

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It is extremely important to recognize the purpose of the attached guidance.
First of all, it is based on existing regulations and requirements and is
not meant to be v.JLewed as "still another requirement".  We have been asked,
by several states and other groups, to prepare a guidance document for the
use of consultants who are attempting to prepare environmental assessments.
In this document we have elaborated on the regulations and already existing
guidance to indicate the type of document which we feel will satisfy the
regulations.  Secondly, this guidance is of a. general nature and therefore
very comprehensive.  It is definitely unnecessary to address each item for
every facilities plan.  The depth of detail and scope of the assessment will
vary greatly from case to case.  Large complex projects will probably require
more than is contained in this guidance, such as a very detailed consideration
of sludge handling alternatives.  In many cases it will be possible to
perform a much more simplified facilities plan as is pointed out on page 13
of our Guidance for Facilities Planning, January 1974. In any case where there
is some question concerning the scope of the cost-effective analysis and
environmental assessment, please contact your State water pollution control
Agency or the Planning Branch of USEPA.
References:

     1.  Guidance for Facilities Planning - January 1974
           a.  Chapter 4 - Monetary Cost Evaluation - Appendix (present
               worth and annual equival ent cost).
           b.  Chapter 5 - Environmental Evaluation
           c.  Chapter 6 - Plan Selection & Alternatives

     2.  Manual for the Preparation of Environmental Impact Statements - July 1974

     3.  40 CFR Part 6 - Preparation of Environmental Impact Statements - Interim
         Rules and Regulations - January 17, 1973.

     4.  40 CFR Part 6 - Preparation of Environmental Impact Statements - Pro-
         posed Rules and Regulations - July 17, 1974.

     5.  40 CFR Part 35 - Construction Grants for Waste Treatment Works -
         Rules and Regulations - February 11, 1974.

     6.  40 CFR Part 105 - Public Participation in Water Pollution Control -
         Minimum Guidelines - August 23, 1973.

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I.   Background

      A.  Description of the facilities planning area

            1.  Maps showing the planning area and the basis for its
                delineation should be presented.
            2.  Significant topographic and hydrologic characteristics
                of the area should be discussed, including low flow
                information on streams in area.
            3.  All relevant treatment works and other structural
                alternatives should also be specifically located.
            4.  Water quality characteristics of the region, including:

                  a.  Condition of the surface waters and the water
                      quality standards for these waters
                  b.  Septic tank problems
                  c.  Groundwater contamination

       B. Present wastewater collection and treatment system(s)

            1.  History, condition and other characteristics of the collection
                systems, including:

                  a.  Presence and location of bypasses
                  b.  Surcharging problems (including basement backups)
                  c.  Peak flow rates experienced

                  (This section might simply reference the Infiltration/Inflow
                  Analysis and Sewer System Evaluation Survey which has  been
                  done for each community involved, if appropriate, or a
                  summarization of basic information contained in these
                  documents might be presented).

            2.  Basic description of the present treatment plant(s), including:

                  a.  History
                  b.  Present condition
                  c.  Levels of treatment presently obtained
                  d.  Significant industries in the area and the nature
                      and quantity of their wastes.

      C.  Estimates of future wastewater loadings and flows based on population
          projections and industrial wastewater characteristics for industries
          which might be expected to come into the municipal system.

      D.  The conditions contained in the permit issued under the National
          Pollutant Discharge Elimination System and the status of enforcement
          orders, if appropriate.

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       E.   Water quality and  water quantity  objectives  in  the  area  other  than
           solution of  the preceding problems.   Examples of  additional
           objectives and goals  are:

             1.   Streamflow augmentation for enhancing  water supplies
                 downstream,  stream fisheries,  recreation  or aesthetic
                 values.

             2.   Preservation or development of recreation areas, wetlands
                 or attractive open spaces.

             3.   Preservation or enhancement of high quality waters with
                 recreational, fish and wildlife or aesthetic  values.

             4.   Groundwater  recharge for augmenting water supply


             5.   Alleviation  of groundwater  pollution.

             6.   Reuse  of treated wastewater such as recycling of nutrients  in
                 treated wastewater.

       F.   Other relevant or  interacting programs in the area, both governmental
           and private.

II. The Environment Without the Proposed Action

      A.  General

            The social, economic and environmental setting of  the area  of the
            proposed action is important for the decision  maker and the public.
            The environmental setting is the starting point  from which  forecasts
            of the environmental impact of the  proposed action must be  made.
            While the focus should be on the immediate  area  of the  proposed
            actions, where appropriate, parts of the surrounding area should
            also be included  to avoid the risk  of overlooking  any important
            interbasin  or regional impacts.

            The importance of using maps to  illustrate  topics  is stressed—
            especially  where  environmentally sensitive  areas are concerned.
            The narrative should be concise, not exhaustive.  Only  those
            characteristics of the social and environmental  setting which are
            most important in relationship to the proposed action should  be
            discussed in any  detail, and those  which are not particularly
            relevant should be omitted.

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B.  Detailed description of the study area

      1.  Climate

            Describe the climatic conditions for the general area
            of the proposed actions including temperature, precipitation,
            humidity, wind direction and velocity.  List any specific
            adverse weather conditions and their frequency.

      2.  Topography

            Describe the topograpy of the area of the proposed actions
            delineating the major and minor drainage basins along with
            their characteristics—area, slope, elevation, natural and
            artificial drainage nets, erosion, and deposition.

      3.  Geology

            Geologic structures or formations that have a direct influence
            on either groundwater of surface water resources should be
            specifically mentioned.

      4.  Soils

            Identify soil types and their permeability, erosion potential,
            expansion, compaction and other characteristics in the
            appropriate areas.  This section should be much more detailed
            when land application is being considered.

      5.  Hydrology

            a.  Water quality

                  1.  Describe the existing surface and groundwater
                      quality using physical, chemical and biological
                      parameters.

                  2.  Describe the existing surface and groundwater
                      quantity and its relation to water uses and objectives.

                  3.  Regulatory and administrative procedures in force
                      to reduce water consumption should be noted if
                      significant.

                  4.  Address specifically relevant non-point sources
                      of pollution if they will impact the solution of
                      the point source problem or the selection of a
                      particular alternative.

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      b.  Water Quality Management

            1.  Describe or reference all pertinent areawide
                or basin water quality management plans.

            2.  Indicate the 25,  50 and 100 year flood levels
                for the area.  Identify any Corps of Engineer
                flood-plain plan  or proposed project.

6.  Biology

      a.  Indicate those species  in the area which have been designated
          rare or endangered, either at the State level or nationally.
          A list of         endangered animal species generally found
          in Region V is attached.  A similar list of plant species
          is being developed.

      b.  Describe wildlife habitat or portions thereof which might
          be affected by the project.

7.  Air Quality

      To the extent pertinent, discuss the major factors affecting
      air quality and the current and anticipated future air quality
      in the project area.  Identify and reference the air implemen-
      tation plan for the area.

8.  Land Use

      a.  If available, include a map of existing land uses such
          as residential, commercial and services, industrial,
          cluster housing, strip  development, mining, transportation,
          institutional, open space and outdoor recreation, agri-
          cultural, forest land,  water, archaeological, historical
          and other points of interest in the area of any proposed
          interceptors.

      b.  If available , include  a map of land uses, both private
          and public, for those categories listed above,  which are
          currently being proposed by local, State, national or
          regional governments in the areas of any proposed inter-
          ceptors .

      c.  Describe the extent and effectiveness of current land
          use planning by all levels of government.

      d.  Describe the administrative and regulatory land use
          controls now in effect.

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              e.   Describe development trends for the industrial,  agri-
                  cultural, commercial,  residential,  and recreational
                  sectors—especially those near or around bodies  of water.

              f.   Describe any aspects of these trends which might threaten
                  air or water quality or bring about other environmental
                  problems.

      9.  Aesthetics

            Describe the areas general aesthetic quality, including noise,
            and the overall "composition" of the area.

     10.  Population Projections and Economics

            Designate the current and projected population levels  (5, 10,and
            20 years).   The reasons for using a particular projection or
            forecast should be stated briefly.  This information may be in
            the Infiltration/Inflow Analysis and could simply be referenced
            here.

C.  Identification of Significant Environmentally Sensitive Areas

      1.  Identify and show on a map any areas which may be significantly
          impacted by the proposed action, and which are not described
          elsewhere in this Chapter.

      2.  Somaexamples of environmentally sensitive areas include:

            a.  Surface waters,

            b.  marshland and wetlands,

            c.  flood plains or flood-retention areas,

            d.  groundwater recharge areas,

            e.  steeply sloping lands,

            f.  forests and woodlands,

            g.  prime agricultural lands,

            h.  habitats of rare and endangered species,

            i.  public outdoor recreation areas,

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                 j.   sensitive geologic areas,  and

                 k.   archeological and historic sites

III.  Alternatives

        A.   General

              1. Alternative waste management techniques will be evaluated based
                 on  the Best Practicable Waste Treatment Technology (BPWTT)
                 or, as applicable, more stringent criteria required to meet
                 water quality standards.

              2.  Both the development and comparison of alternatives should be
                 presented in a clear and concise manner so the public can
                 follow the logic of the decision-making process.

              3.  One alternative which should always be included is that of
                 "no action"—allowing the existing wastewater treatment works
                 or  septic tanks to continue in use—so that the public will
                 understand the environmental implication of allowing the status
                 quo to continue.

        B.   Analysis of Joint Treatment or Regionalization Questions

             (Regional questions may have already been resolved by existing
              approved plans.  If this is the case, summarization of important
              conclusions and proper referencing of these regional plans may
              suffice).

              1.  Identification and assessment of feasible treatment works and
                  interceptor combinations within the planning area.  (It should
                  be noted that certain simplifying assumptions must be made for
                  purposes of this analysis, e.g., treatment processes.  These
                  simplifying assumptions must be clearly spelled out).

                    a.  Monetary costs of the feasible combinations should
                        be assessed in terms of the "total present worth" of
                        the entire system.

                    b.  Significant environmental effects resulting from the
                        implementation of each of the feasible combinations should
                        be presented.  Particular attention should be paid to
                        differences in impact between the proposed combinations.
                        Unique regional problems to be addressed are:

                          1.  effects of interceptor locations on land use
                              within and between urban areas.

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                  2.   Effects  of alternative  combinations  on stream
                      flows in the region.

            c.   Other non-monetary costs  should be evaluated,  including:

                  1.   Possible site limitations—is area available for
                      future expansion or additions?

                  2.   Possible differences  in operation and maintenance
                      capability and reliability.

      2.  Based on information contained  in 1,  a recommendation for a
          specific treatment configuration should be made.  This re-
          commendation should include:

            a.   A map of the regional area with specific service areas for
                each proposed treatment plant delineated,  and

            b.   A specific statement which identifies the  political units
                lying within the service  area of each proposed plant.

C.  Analysis of Alternative Treatment Systems Within a Specific Service Area

      1.  The effect which "no action" would have on communities involved
          must be addressed.  It is not sufficient just to indicate that
          the communities involved are under orders.  The  statement must
          examine potential effects on:

            a.   Surface water quality

            b.   Land use - examine restrictions on land use which might
                be imposed by "no action".

            c.   Groundwater quality - examination of limitations in
                utilizing private septic  systems.

            d.   Socio-economic character  of communities.

                  1.   Health hazards

                  2.   Industrial development

      2.  Preliminary alternative systems featuring at least one technique
          under each of the three categories below (treatment and discharge,
          wastewater reuse, and land application) will be  developed and
          screened.  A detailed proposal  will be prepared  for each unless
          adequate justification for eliminating a technique during the
          preliminary screening process is  presented.

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a. Treatment and discharge to surface waters

     1.  Biological treatment

     2.  Physical-chemical treatment

     3.  Systems combining the above techniques

b.  Treatment and wastewater reuse

     1.  Industrial processes

     2.  Groundwater recharge for water supply enhancement

     3.  Surface water supply enhancement

     4.  Recreation lakes

     5.  Land reclamation

c.  Land application—the application of wastewater effluents
    on the land involves the recycling of most of the organic
    matter and nutrients by biological action in the soil
    plus plant growth for the breakdown and disposal of
    nutrients.  Land application techniques include:

     1.  Irrigation including spray, ridge and furrow, and
         flood.

     2.  Overland flow

     3.  Infiltration - percolation

d.  Any facilities plan must consider the optimization of the
    performance efficiency of any existing facilities as an
    alternative to or integral part of any additional treatment
    facilities.

e.  Flow and waste reduction measures, including rehabilitation
    of existing sewers as demonstrated to be cost-effective
    through the Sewer System Evaluation Survey, should also be
    discussed.  These components of the Facilities Plan can
    simply be referenced.  Other flow and waste reduction
    measures include:

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           1.   Household water saving devices

           2.   Water meters

           3.   Water pricing

           4.   Land use and development regulations

           5.   Industrial reuse and recycling

         This  section should contain a discussion of limiting factors,
         assumptions, or conditions that affect the scope of alter-
         natives considered or analyses performed.  These constraints
         may be sufficient reason to reject a large number of
         alternatives outright, eliminate a portion of the analysis
         without further consideration, or they may reflect on the
         effectiveness or scope of available alternatives.

D.  Detailed evaluation of those alternatives which appear most
    feasible

     1.  A comprehensive evaluation must be made of the major
         environmental effects which will be common to all alterna-
         tives selected for detailed evaluation.  This statement
         must, among other things, address the following specific
         questions.

           a.   Adverse impacts which cannot be avoided should
               any one of the proposals be implemented.

           b.   The relationship between local short-term uses of
               the environment and the maintenance and enhancement
               of long-term productivity.

           c.   Irreversible and irretrievalbe commitments of
               resources which would be involved if any of the
               alternatives selected for full evaluation were
               implemented.

     2.  Analysis of the differing impacts of each alternative
         selected for full evaluation.

           a.   Calculation of "total present worth" for each
               alternative, including the possibility of phased
               additions, where appropriate.

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                 b.   A careful delineation of the unique environmental
                     effects,  both adverse and beneficial,  of the
                     alternatives in question.  Specific attention should
                     be given  to sludge disposal questions,  where
                     appropriate, including the exact location of any
                     disposal  sites.

                 c.   An examination of other non-monetary effects of
                     each alternative.  Specifically:

                       1.  Flexibility of system

                             a.  Ease of moving to higher levels of
                                 treatment, if necessary.

                             b.  Ease of accomodating unforeseen changes
                                 in service area or growth rates.

                       2.  Reliability of the alternative treatment
                           system in handling variations in quantity
                           and quality of wastewater flow.

                       3.  Operability of the alternative system in
                           light of the manpower which will be available
                           for operation and maintenance over the life
                           of  the facilities.

                       4.  Any greater than typical energy requirements
                           of  a particular treatment alternative.

                       5.  Any other non-monetary effects associated
                           with a particular alternative.

          3.   A list of any permits or other formal approvals which
              would  be needed  for the implementation of a particular
              alternative.

IV.   Selection and Description of a Proposed Alternative

       A.  Plan Selection

          1.   A number of comparative analysis should be conducted
              during the systematic development of system alternatives.

          2.   All comparisons  should be discussed in narrative form
              and displayed in a summary chart.  The major reasons
              for acceptance or rejection of an alternative should be
              stated in each case.  This selection must be based on a

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            careful evaluation of all costs involved:   monetary,
            environmental and other non-monetary costs.   An overall
            minimization of costs, both monetary and non-monetary,
            must be sought.

        3.  The concept of centralized vs.  decentralized systems  is
            receiving increased attention in current system proposals.
            When evaluated on the cost of the facilites alone,  the
            analyses often neglect to discuss adequately the residential,
            commercial and industrial development that a centralized
            project can induce.  Their vast network of collectors and
            interceptors often open up many new areas for development,
            or more rapid growth.  The final screening should speci-
            fically speak to these environmental implications of  each
            system.

    B.  Description of Proposed Action
        1.  A brief summary of the selected alternative and its
            environmental implications shall be provided.

        2.  Any mitigative actions necessary to alleviate adverse
            environmental impacts shall be set forth in this section.

V.  Public Participation

    A.  A public hearing will be held to explain the alternative
        proposals and obtain the views of all concerned interests.
        Reflecting inputs from the public, each alternative proposal
        will be reviewed with respect to environmental effects,
        monetary costs, plan implementation capability, resources
        and energy use, reliability and public acceptance.  Based on
        consideration of each of these factors, the alternative
        proposals will be ranked and a plan selected for implementation.

    B.  In the final cost-effectiveness analysis, the various efforts
        at involving the public, including the mandatory public
        hearing, must be presented.  A discussion of how the signi-
        ficant issues raised by the public were incorporated into
        the decision making process must be included.  In other words,
        the draft material presented at the public hearing must be
        modified to account for significant issues raised by the
        public.

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        Rare & Endangered Animal Species - Region V



Fish

     Salmoniformes

       Longjaw Cisco      Coregonus alpenae

     Perciformes

       Blue Pike          Stizostedion vitreum glaucum

Birds

     Falconiformes

       Arctic Peregrine Falcon        Falco peregrinus tundrius

     Passeriformes

       Kirtland's Warbler             Dendroica kirtlandii

Mammals

     Chiroptera

       Indiana Bat                    Myotis sodalis

     Carnivora

       Eastern Timber Wolf            Canis lupus lycaon
Source:  U. S. List of Endangered Fauna, U. S. Dept. of the
         Interior, Fish and Wildlife Service, May 1974

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