a-1
United States Washington DC 20460 September 1979
Environmental Protection
Agency 10OR79101
EPA
100/
1980.2
&EPA A Progress Report:
State Implementation
\ of EPA GuidSeines
J on the Use of Population
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ERRATA SHEET
A misprint was made in printing the cover of this report.
title of this report should read:
The
A Progress Report: State Implementation of
EPA Guidelines on the Use of Population Proje'ctions
This report was prepared by the Sierra Club, 530 Bush Street,
San Francisco, California 94108 financed in part by a grant from
the Environmental Protection Agency. The contents do not
necessarily reflect the views and policies of the Environmental
Protection Agency.
Should you have any questions concerning this report, please
contact Cathy O'Connell, Environmental Protection Specialist on
(202) 755-8056.
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SIERRA pia
CLUB VlSsli/ 530 Bush Street San Francisco, California 94108 (415)981-8634
September 15, 1979
TO: Environmental Leaders, Activists on Population Projections,
and Others
FROM: Judith Kunofsky, Population & Growth Policy Specialist
and Project Director
Donald Foruian, Project Associate
One of the most important, and often ignored, influences
on environmental decision-making at all levels of govern-
ment is the population projection used. Projections are
used to prepare clean air and clean water plans throughout
the country, to calculate the size of a sewage treatment
facility for which federal funding is available, to assess
the need for and extent of highway expansions or mass
transit, to evaluate costs and"benefits of proposed
water diver's ion" plroj ects , to project recreational
needs and forecast energy demand.
Because the use of population projections can in some
ways be self-fulfilling, they are important tools for
_those concerne'd ~'abou t land "use "or growth policy.
The way projections are used can help solve - or aggravate -
environmental problems. Construction of a sewage treatment
facility can foster the paving over of prime agricultural
land. The ensuing sprawl development can create new and
worse air pollution and water pollution, and increase energy
use. A water diversion project designed to meet "projected
needs" can cause problems at the source of the water and
in the basin to which the water is brought. A highway
built to fill projections of automobile travel can take
needed funds - and riders - away from mass transit.
Similarly, by shaping federal investment, the use of
population projections can be a strong influence on the
future of America's cities and towns: They can assist in
economic changes which would not otherwise have occurred.
They can help fund development in parts of an area which
would otherwise have remained undeveloped or, conversely,
help promote the revitalization of a city.
CO
CO
CO
era
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The fifty states are now in the process of implementing
relatively new EPA guidelines on the use of population
projections in its programs. The attached report is one
of the results of a small grant from the Environmental
Protection Agency to the Sierra Club to conduct a tele-
phone survey of the states and let you know how well
the process has been going. We have paid particular
attention to how much and what kinds of public partici-
pation has been taking place.
Section 4.4 of the report describes opportunities for
your involvement in the next few months.
The EPA process is also important because it may serve
as a model for similar efforts in other federal agencies.
The Office of Management & Budget and Department of
Commerce are expected, this fall, to issue a. proposal
for the development and use of a consistent set of popu-
lation projections in all federal programs which use
projections in a funding formula. This is likely to
involve not only EPA's pollution control programs, but
also various transportation, water policy, and urban
development programs (and others) throughout the federal
government.
We are available to assist you in. learning sore about
EPA's use of population projections and what your state
has been doing. As a result of our telephone conversations,
we have much more information about each state than we
have been able to include in this report. We strongly
urge anyone interested in becoming involved at the state
level to contact us for assistance and additional ideas.
Finally5 the Sierra Club publishes Population Report, a
free newsletter that focuses on federal policy on the use
of population projections and national trends in population
growth. We would be happy to send it to you.
\\ Judith Kunofsky > Donald Forman
Thanks to Annie Stine for the graphics and Marina Wadopian
for production assistance.
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TABLE OF CONTENTS
Cover Letter Pa§e 1
Chapter 1: INTRODUCTION 5
1.1 Sierra Club Involvement in Population Projections
1.2 History of the EPA Projections Guidelines
1.3 Objectives of the EPA Guidelines
1.4 Project Procedures
Chapter 2: THE EPA GUIDELINES ON THE USE OF POPULATION PROJECTIONS ^
2.0 Flow Chart for the EPA Projections Guidelines
2.1 A Two-Minute Version of the Guidelines
2.2 A Ten-Minute Version of the Guidelines
2.3 Further Questions
2.4 Examples
2.5 Text of the Guidelines and Discussion in the Federal Register
Chapter 3: SUMMARIES AND CONCLUSIONS: LEAD AGENCIES & EPA 41
3.1 Special State Activities for the Process
3.2 General Attitudes
3.3 Use of Available Time
3.4 Locus of Responsibility Within the States
3.5 Methodologies and Approaches
3.6 Consistency of Projections Within the States
3.7 State Reactions to the EPA Projections
3.8 Variance Requests
3.9 Communications Problems
3.10 Energy-Impact States
3.11 Timing of the Requirements
3.12 Vision
Chapter 4: SUMMARIES AND CONCLUSIONS: INVOLVEMENT WITHIN THE STATE 65
4.1 Coordination Among State Agencies
4.2 Involvement of Substate Governments
4'.3 Public Involvement
4.4 What Remains to be Done
(continued)
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Chapter 5: RECOMMENDATIONS page 79
5.1 State Activities to Involve the Public
5.2 Public Meetings on Projections
5.3 Communications Between EPA and the States
5.4 Written Guidance for the States
5.5 States Which Have Had Difficulties
5.6 Involvement of Other State Agencies
5.7 Revisions of the Projections and Integration with Other
Federal Requirements
5.8 Earlier Deadline for Variance Requests
5.9 Urban Areas "ith Decreasing Populations or Low Growth Rates
5.10 Proposed Federal-Wide Process
Aonendices
Appendix A: ADDITIONAL COMMENTS OF THE STATES Pa§e 93
A.I General Supportive Comments
A.2 General Negative Comments
A.3 Miscellaneous Comments
A. 4 Specific Suggestions or Problems
A.5 Reactions to possible Federal-Wide System
Appendix 3: INDIVIDUAL STATE REPORTS 103
Appendix C: GLOSSARY l33
Appendix D: EPA CONTACTS 137
Appendix E: "Population Projections: How They Are Made ... And 139
now They Make Themselves Come True", reprint from Sierra
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CHAPTER 1
INTRODUCTION
1.1 Sierra Club Involvement in Population Projections
1.2 History of the EPA Projections Guidelines
1.3 Objectives of the EPA Guidelines
1.4 Project Procedures
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1.1 SIERRA CLUB INVOLVEMENT IN POPULATION PROJECTIONS
For several years the Sierra Club has been interested in
the use and abuse of population projections in federally-
funded programs. The Sierra Club has sponsored a continuing
program of training its members and involving them in the
issue of population projections.
Projecting the numbers of people expected to live in a
region and the distribution of their homes and jobs
around the region is one of the important components
of developing air and water quality plans. The numbers
and their distribution affect transportation patterns
and automobile use; the amount of water used in lawns
and gardens; runoff problems associated with construction
activities; the number of dry-cleaners and attendant air
pollution; the amount of area cover?-d bv pavement and
therefore possible problems with drainage of stormwater,
etc.
In general, the higher the projection, i.e., the greater
the population, the more difficult it is to meet any
particular set of standards. This is because there are
more people whose activities can produce pollution.
The distribution of population, though, is also very
significant. For example, a population living in
suburbia and commuting with automobiles to jobs would
produce more air pollution per person and in total than
if they were living more compactly and used buses, or
if they commuted shorter distances by automobile.
In at least some cases in the past, communities used
different projections for different purposes. This was
not only confusing and a possible waste of money and dupli-
cation of effort, but also was not a good way to meet
public needs: Use of different projections might direct
growth in different ways, thus cancelling the impact of
both the programs. Or one program may be using projections
to calculate needs for certain public services, while
another program causes growth to occur elsewhere in the
community. Thus, the first program's efforts are not
only useless but expensive.
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In September, 1978 the Environmental Protection Agency
(EPA) published guidelines that fundamentally changed the
process by which population projections are developed
for use in EPA's water quality and air quality programs.
Essentially, the change was as follows: In the past,
whatever projection a community or its consultant pre-
pared was accepted as reasonable. This "bottom-up"
approach resulted in projections being used around the
country which totalled several tens of millions more than
the projected U.S. population for 1990 even under the
highest fertility assumptions. Now, however, the process
is more a "cascading" or "top-down" one: Each state has
received a federally-prepared projection and all fifty
sum to the Census Bureau's medium projection for U.S.
population growth. The states have until October 1, 1979
to submit to EPA allocations of that projection for parts
of the state. EPA funding for the construction of sewage
treatement facilities and related planning efforts for air
and water quality are then tied to those projections.
In spring, 1979 the Sierra Club wanted to inform its members
of the status of state implementation of the population
projections guidelines. EPA at that time did not have
sufficient information on the states to enable this. The
Environmental Protection Agency then agreed to give the
Sierra Club a small grant to conduct a telephone survey of
all fifty states to assess the status of the disaggregations
in each state and provide that information to our members.
It is our hope that this information will enable many more
people around the country to become involved in the process.
In addition, the Sierra Club agreed to compile
problems identified by the states in order to provide
EPA with information which might further inprove the
process in the future.
This report is one of the results of that grant.
This project has been financed in part with Federal
funds from the Environmental Protection Agency under
grant number T90101801i. The contents 'lo not necessarily
reflect the views and policies of the Environmental
Protection Agency.
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This report has been prepared with a variety of audiences
in mind. We are primarily addressing citizen activists
around the country, whom we hope will become more involved
in the development and use of population projections for
their communities. We are also sending this report to each
of the individuals in state governments whom we contacted.
We hope that our compilation of suggestions for improving
the process will be of use to the Environmental Protection
Agency. "Finally, in some ways the EPA guidelines are a
"pilot study" of how such a process of developing national
consistency in projections can work. The Office of Manage-
ment and Budget and Department of Commerce will scon be
proposing a similar system to cover all federal programs
which use population projections in funding-allocation
formulas. We hope that our observations and recommendations
will be of use in demonstrating the strengths and weaknesses
of EPA's approach and will therefore enable a federal-wide
system to be a more effective and useful one.
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1.2 HISTORY OF THE EPA PROJECTIONS GUIDELINES
The Federal Water Pollution Control Act Amendments of
1972 stated that the size of any sewage treatment facility
built under the terms of the Act should
"relate directly to the needs to be served by such
works, including sufficient reserve capacity. The
amount of reserve capacity provided shall be approved
by the Administrator (of EPA) on the basis of a
comparison of the cost of constructing such reserves
as a part of the works to be funded and the anticipated
cost of providing expanded capacity at a date when
such capacity will be required." (section 204(a)(5) )
The Act also required EPA to publish cost-effectiveness
guidelines for conducting such an analysis, and to revise
them at least on an annual basis. Guidelines were published,
and a proposed set of amendments to those, incorporating
many of the concepts currently being implemented, was
circulated in mid-1976. Proposed amendments were then
published in the Federal Register on February 4, 1977.
In 1977, Congress debated and passed amendments to
the Act, now called the Clean Water Act. The House of
Representatives proposed no change in section 204 (a)(5).
The Senate, however, proposed that federal funding be
limited to facilities with reserve capacity for ten years
in the future; interceptor sewers and "associated appurtenances'
were to be funded 20 years into the future.
The Senate report stated that, "One purpose of this amendment
is to concentrate available funds on correction of existing
municipal problems" (emphasis added). Senator Muskie
commented that the goal of the funds provided by the Clean
Water Act "is not to finance the future growth needs of the
United States." An Administration representative supported
the Senate proposal, known as the 10-20 formula, citing
the successful California experience in implementing such
limitations and acknowledged that "Overbuilding has been a
problem."
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The Conference Committee version, which was integrated
into the Clean Water Act, amended Section 204 (a) (5) to
add the following to the section quoted above:
... at a date when such capacity will be required
"after taking into account, in accordance with regu-
lations promulgated by the Administrator, efforts to
reduce total flow of sewage and unnecessary water
consumption. The amount of reserve capacity eligible
for a grant und«-->r this title shall be determined by
the Administrator taking into account the projected
population and associated commercial and industrial
establishments within the jurisdiction of the appli-
cant to be served by such treatment works as identified
in an approved facilities plan, an areawide plan under
section 208, or an applicable municipal master plan of
development. For the purpose of this paragraph, section
208, and any such plan, projected population shall be
determined on the basis of the latest information
available from the United States Department of Commerce
or from the States as the Administrator, by regulation,
determines appropriate "
In compliance with this requirement, and following the
ideas developed in the earlier published draft, EPA issued
interim regulations implementing the Clean Water Act of
1977 on April 25, 1978. These included, in Appendix A,
cost-effectiveness guidelines with a section on population
projections, and went into effect June 26 of that year.
After a comment period, a final set of regulations for the
Construction Grants Program was printed in the Federal
Register on September 27, 1978. These contained the
guidelines on population projections which are the subject
of this report. A copy of the guidelines and the Federal
Register discussion of comments received on the earlier
draft is in section 2.5.
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1.3 OBJECTIVES OF THE EPA GUIDELINES
These guidelines appear to have developed over a period
of years because of a variety of concerns:
A. Congressional testimony that the total projections
being used around the country was substantially greater
than any reasonable projection of U.S. population,
and that as a result substantial overbuilding was
taking place.
B. Concern in Congress and the Administration that the
size and staging of municipal sewage treatment facilicies
be cost-effective, i.e. produce the most improvement
in water quality per dollar expended:
To the extent that money is used for "reserve capacity"
in one community, it is not available to solve current
water pollution problems elsewhere.
To the extent that a facility is built which is too
big, the community must bear the burden of excessive
operation and maintenance costs, as well as its
share of the construction costs.
C. Concern that the wastewater treatment program could
create new pollution problems by subsidizing sprawl
and loss of agricultural land and ^jravating air and
water pollution - unless the solution is in scale to
the problem being addressed.
D. Concern reflected in the President's Urban Policy, of
which these guidelines are a part, that federal programs
help maintain the integrity of cities and towns.
E. Complaints from a variety of sources that inconsistent
projections are often used in a particular community
among various EPA programs or among the programs of
different federal agencies. In the former case, plans
to meet air quality and water quality standards might be
inconsistent. In the latter, federal programs might be
using projections in such a way that the programs effects
do not reinforce each other.
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1.4 PROJECT PROCEDURES
Project staff consisted of Judith Kunofsky and Donald Forman
who were based in the national office of the Sierra Club in
San Francisco. Additional volunteers were involved in other
states.
Staff first contacted each Regional Office of the Environmental
Protection Agency and spoke with the individuals who are working
the most closely with the states in complying with the projec-
tions regulations. We spoke with approximately 44 people in
SP-K. We asked for their most recent information on the state's
progress in implementing the guidelines and for the name of
their contact in the state.
We then called each of the fifty states, beginning with the
person identified by the EPA staff. In some states, this
person was the one with responsibility for implementing the
process. In other states we were referred subsequently to
various people until we found a person with responsibility
for the projections.
We informed each state that we were preparing a report for
our members on the implementation of the projections guidelines,
and that we were looking for suggestions for improving the
process.
We followed a prepared list of questions, adjusting them to
fit the situations in particular states- and omitting certain
low priority questions in the interest of time. The state
calls lasted between twenty minutes and one hour. Notes on
the discussions were almost always retyped within twenty-four
hours of the calls.
The project began on August 9. Phone calls were made during
a six week period between July 16 and August 27. We spoke
with approximately 70 people in the states.
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Disclaimers
We attempted to record our conversations with the states and
to summarize them as accurately as possible. Because these
were phone interviews, and because the states did not have
an opportunity to review our summaries, it is possible we have
misrepresented details of the situation in some states. Nonetheless,
we believe that the overall picture we-present in this report is
an accurate one, representing the situation in each of the states
as of the date of our discussions with them and as reported by the
individuals we contacted.
In some cases we found that different individuals in one state
gave very different accounts of the general process of prepar-
ing projections in the state and how the state was complying
with EPA; therefore it is possible that for some states in
which we spoke with only one person, the picture we received
is not complete.
Furthermore, our conversations were with individuals who at
times were undoubtedly expressing their personal opinions
rather than official views of the states. Our discussion of
suggestions for improving the process and general attitudes
reflects a compilation of these individual views and should
not be interpreted to necessarily reflect the official views
of the states.
In many states the process of complying with EPA guidelines
was nowhere near completed at the time of our discussions
with them. The situation in particular statrs, then, may be
different at the time of publication of this report than
when our information was gathered.
Finally, the report includes stories of particular states
and opinions of individuals with whom we spoke. Those
opinions, although sometimes placed in quotation marks,
are in some cases paraphrases. We attempted to retain the
intent of the speaker while clarifying wording and grammar.
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CHAPTER 2
THE EPA GUIDELINES ON THE USE OF POPULATION PROJECTIONS
The most "accurate" description of any set of regulations or
guidelines is, of course, the original text itself. However
in this case, where the guidelines are in small type and
tersely written, a more leisurely explanation is certainly
warranted. We here present,first, a two-minute version,
the Federal Register discussion of comments received in
response to an earlier draft, and then the text of the
guidelines themselves.
2.1 A Two-Minute Version of the Guidelines
2.2 A Ten-Minute Version of the Guidelines
2.3 Further Questions
2.4 Examples
2.5 Discussion in the Federal Register and Text of the Guidelines
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2.1 A TWO-MINUTE VERSION OF THE GUIDELINES
In the past, population projactions were prepared by local
governments or by consulting engineers preparing to build
a particular sewage treatment facility for the local
government. The population projection for the area to be
served together with information and assumptions about per
capita water use and expected industrial water use are
used in a "cost-effectiveness analysis" which determines
how large a facility should be built initially to maximize
the benefit gained per dollar spent.
Under the Clean Water Act, a sewage treatment facility whose
size is determined by such an analysis is entitled to have 75%
of its construction costs paid for by the federal government.
If the facility uses innovative or alternative technologies,
the federal share of the cost can be 85%. A community can
always build a larger facility as long as the additional
construction costs are paid for in some other way.
The population projections that were prepared in this way
totalled tens of millions of peorle rora than even the high
projection of U.S. population in the year 1990. Furthermora,
they were often inconsistent with projections being used in
EPA or other federal programs in the same community.
EPA's process is now a "cascading" or "top-down" approach.
The Bureau of the Census prepares projections for the U.S. popu-
lation. EPA contracted with the Bureau of Economic Analysis (BEA)
to disaggregate, or allocate, the medium Census Bureau projeccion
to projections for each of the states. Each state was sent this
projection, and can either accept it or anneal. Then each
state divides that projection into projections for so-called
"designated 208 agencies" and other parts of the state such
as counties. (Under Section 208 of the Clean Water Act, the
Governor of a state can choose - i.e., designate - certain
substate agencies to develop the clean water plans for their
area. These agencies, which are sometimes regional planning
agencies or counties, are often called "designated 208 agencies"
or "208's". Similarly, Section 201 of the Act sets up the
program of federal funding for construction of publicly owned
sewage treatment facilities. Those facilities are sometimes
called "201 facilities" and the areas they serve "facility
planning areas" or "201 areas." )
Subsequently, each 208 agency or county will prepare projections
for its cities, towns, and facility planning areas. The
projections that come out of this process are the only ones
which will qualify for use in determining how much federal
funding is available.
Since the "reserve capacity" in a sewage treatment facility
can be a major determinant of how much and when and where
growth occurs in a community, it is important for the public
to be involved. -18-
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2.2 A TEN-MINUTE VERSION OF THE GUIDELINES
A. The EPA Projections for the-States
In 1977, the Bureau of Economic Analysis in the Department
of Commerce prepared a population projection for each of the
states. They began with a projection for U.S. population
prepared by the Bureau of the Census, also in the Department
of Commerce. That projection, known as Series II, assumes
an average family size of 2.1 children per woman and 400,000
net migration to the United States. That fertility rate is
higher than the current level and the migration rate is lower.
(See 2.3, Question K, for further discussion oJ the projection)
The projection for the year 2000 is 265,078,000, which is a
20^ increase over the 1979 population of about 220,000,000.
A draft projection was send to each state for comment, but
many states did not respond. Changes were made by 3EA in
response to the comments for many of the states. The revised
projection was then sent to the states.
Although BEA will be releasing an updated set of projections
in 1979 as part of its "OBERS" series of projections, those
numbers do not replace the ones sent to the states for use
in the EPA guidelines at this time.
The number each state was sent can be found in Appendix B,
Individual State Reports.
B. State Review of the EPA Projection
Each state must review this projection and has several choices:
1. The state can use the BEA projection, which we refer to in
this report at the "EPA projection."
2. The state can use a projection which the state had already
prepared as of 6/26/78 instead of the EPA projection as long
as the year 2000 population projected is not more than c:ia
EPA projection plus 5% for the same year. The June 26, I9?c
date was when the interim regulations had taken effect.
If a state wants to use a projection existing on 6/26/78
but which is more than 5% greater than EPA's or prefers
any projection prepared more recently than that, it
must get EPA agreement to do so. In the terms of the guide-
lines, the state must "request a variance."
Such a request, together with the justification, must be sent
to the EPA Regional Administrator who will forward it to
the EPA Administrator in Washington, D.C. However, prior to
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making such a request, the state must issue a public
notice of its intention to do so. The Regional Administrator
of EPA must then "solicit public comments and hold a public
hearing if important issues are raised about ;;he State
projection's validity." EPA regulations require a 45 day
notice for a public hearing, which can be reduced by EPA to no
less than 30 days if the longer notice "is not needed to encourage
public participation " in that hearing.
C. Disaggregating the State Projection
After it has been decided what projection the state will use,
the state must prepare a "disaggregation" of that projection
to parts of the state. A disaggregation is a division of a.
projection into projections for smaller geographical areas.
It is sometimes called an "allocation".
The particular geographical areas in the state for which
a projection must be prepared are described in the guidelines
and depend on how the state is doing its water quality planning
under the Clean Water Act.
The state must determine a population projection for each of
the following substate areas:
a) each designated 208 agency (see section 2.1)
b) outside designated 208 areas, for each SMSA (Standard
Metropolitan Statistical Area) and "all non-SMSA
counties or other jurisdictions." (see definition in 2.3H)
The sum of these projections must not exceed the state projection.
It can be lower if the state wishes.
The state must prepare its disaggregations in consultation with
air quality planning agencies, designated 208 agencies, and
other regional planning agencies.
We have found that in some states the agency in the "lead"
position is the one responsible for water quality planning;
in some it is the agency which prepares population projections
for the state; in others it is a more general policy or
planning agency (see section 3.4).
The dissggregations must be submitted to EPA by October 1, 1979.
However before the state submits them, the state must hold a
public meeting on the subject. Federal regulations for the
Clean Water Act require no less than a thirty day notice for
a public meeting.
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D. Comparing the Projections With Those of 208 Agencies
llany designated 208 agencies have already prepared projections.
Some have been submitted to EPA in the past and in some cases
approved.
The guidelines deal with the problem that the projection the
state prepares for the 208 agency's part of the state might
not be the same as that agency's own projection. We should
note here that in some states the 208 agencies began with
state-produced projections.
The guidelines allow the projections to differ in certain
circumstances: "Where a designated 208 area has, as of June 26,
1978, already prepared a population projection, it nay be used
if the year 2000 population does not exceed that of the
disaggregated projection by more than 10 percent.... If the
208 area population forecast exceeds the 10% allowance, the
208 agency must lower its projection within the allowance...."
Any such variances for these agencies are over and above the
projection being used by the state for this process (see
section 2.3 for further discussion).
This whole matter might, at first glance, seem superfluous.
If a designated 208 agency already has a projection, why
doesn't the state simply prepare its disaggregation to "give"
that area of the state the number it is already using?
There are several possible reasons a state might not want or
be able to do this:
1. The projection of the 208 agency may be substantially
greater than a projection already prepared by the state
which the state intends to use. This is not an uncommon
occurrence.
2. The projections of all the 208 agencies taken
together with the rest of the state may be sub-
stantially greater than the projection which the
state wants to use or that EPA permits the state
to use.
3. The state may want to project relatively larger populations
for its non-designated areas (for whatever reasons) and
may do so by preparing a disaggregation which gives the
designated areas less than they have prepared.
These possibilities are discussed in greater detail in-
section 2.4 below.
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E. Submitting the Projections Co EPA
When the state's disaggregations are ready, the state aust
call a public meeting. EPA regulations require no less than
thirty days notice for a public meeting.
Many states have combined these meetings with hearings on the
208 plans. Other have scheduled separate meetings. Still
others, which already had projections developed separately
from the 208 process believe they complied with the public
meeting requirement in their initial development of those
numbers (see section 4.3 for further comments and analysis).
The projections, revised if necessary, are then submitted
by the states to EPA "as an output of the statewide water
quality management process," i.e. the 208 process. In some
states, those plans and the projections were submitted in
draft or final form many months ago.
F. Using the Projections
After the projections disaggregations have been
approved by the EPA Regional Administrator, they are supposed
to be used in the following ways:
1. for future 208 planning
2. for future "needs surveys", conducted every two years
by EPA
3. for the cost-effectiveness analysis, and then the
size of a particular sewage treatment facility whose
facility plans are "prepared under step 1 grant assistance
awarded later than 6 months after Agency approval of the
State disaggregations." (A step 1 grant is the first
one awarded by EPA for developing the plans for a facility)
G. Projections for Facility Planning Areas
In some cases, the projections the state prepares will not be
down to the level required for planning a particular facility.
Timetables for preparing those projections are discussed in
section 2.3H below.
H. Revising the Projections
The guidelines say that "State projections and disaggregations
may be updated periodically in accordance with Agency guidelines."
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2.3 FURTHER QUESTIONS
A. Do these guidelines prevent a community from building a larger
sewage treatment facility or planning for more population
growth than is in the projection that comes from this process?
No. A community can build a larger facility if it pays for
the additional capacity itself. Similarly, a community can
plan for larger population growth as long as those larger
projections are the ones used in its air quality and water quality
plans. The guidelines are not restrictions on planning or
on community goals, only on the amount of federal money available.
B. Does this process affect how much money each state gets for
the Construction Grants Program, which funds sewage treatment
facilities throughout the state?
No. The Clean Water Act Amendments of 1977 fix the amount of
money, or rather the percentage of the appropriation, which
is available to each state. The final population projection
prepared under this process therefore does not affect the money
available.
The size of any particular facility, though, and therefore the
relative distribution of money around the state, may be affected.
Suppose, for example, that the state keeps the same priority
list it had before, i.e. cVes not change its ordering of what
projects it wants to build first. And suppose that the effect
of the guidelines in that particular state is to reduce the
population projections being used by local governments or
planning bodies for this program. Then the effect of the guide-
lines on actual construction is that the state, with its fixed
pool of federal money, can fund more facilities, each of w'nich
receives less federal funding.
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C. What if a state prepares its population projection by
aggregating (i.e. summing or adding up) projections
prepared initially for substate regions?
The state still must submit any request for a variance from
the state number first.
Quite a few states, including North Dakota, Nevada, New York,
Montana, and Utah, are preparing their projections this way
(see Appendix B).
D. Are the state disaggregations supposed to reflect "trends"
or "goals"?
The guidelines do not specify either, although at least one
state mistakenly assumed that the disaggregations were required
to be "trend" or "baseline" projections. In fact, S3»eral
states are explicitly including established state goals in
their disaggregations.*
One of the problems with population projections is that equally
qualified professionals could produce different population
projections for the same geographical area; there is therefore
always a policy decision to be made on whose projections are
to be used.
E. Who decides in what circumstances a designated 208 agency
is allowed to use the up-to-10% variance?
That decision, according to EPA, is made jointly by the state
and the EPA Regional Administrator
*See definitions and discussion in section 3.5.
-24-
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F. Do the 10% variances available Co designated 208 agencies
have to be included in the 5% variance available to states?
No. The guidelines specifically say they do not: "Where a
designated 208 area has, as of June 26, 1978, already prepared
a population projection, it may be used if the year 2000
projection does not exceed that of the disaggregated projection
by more than 10 percent. THE STATE MAY THEN INCREASE' ITS
POPULATION PROJECTION TO INCLUDE ALL SUCH VARIANCES RATHER
THAN LOWER THE POPULATION PROJECTION TOTALS FOR THE OTHER
AREAS." (emphasis added)
This is the most widely ioisunderstood provision of the
guidelines (see section 2.4 below).
G. Can the state projection be more than 5% lower than EPA's?
Yes. The state's projection can be as low as it likes. The
guidelines talk about the need for a variance only when the
state's projection is higher than EPA's.
In fact, quite a few states have submitted or will be submitting
projections lower than EPA's. See Appendix B for examples.
H. What must be done after October 1?
Paragraphs (4) and (5) in the guidelines describe what
additional disaggregations must be prepared after EPA approves
the ones submitted by October 1.
The specific reference to another deadline is in paragraph (6)
which states that, "Facilities plans prepared under step 1
grant assistance awarded later than 6 months after Agency
approval of the State disaggregations shall follow population
forecasts developed in accordance with these guidelines."
Certain of the additional disaggregations are required (within
designated 208 areas and within SMSA's which are outside 208Ts)
while others are optional (outside both SMSA's and 208's).
Projections in these latter areas need to be prepared only in
conjunction with a particular facility plan.
(An SMSA, or Standard Metropolitan Statistical Area, is a metro-
politan area containing at least one city - or twin cities -
of 50,000 or more population, the county in which it is located,
and any adjacent counties that are both metropolitan in character
and socially and economically integrated with the central city.
A list of SMSA's is prepared fay the U.S. Office of Management
and Budget.
-25-
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I. How did the Bureau of Economic Analysis produce the
state projections?
The Bureau of Economic Analysis (3EA) produces a set of
projections called OBERS, an acronym for the names of the
two agencies which originally had responsibility for the
program. The 1972 OBERS projections were published in 1974
and included a consistent set of economic and population fore-
casts for economic areas, water resources regions and subareas,
states, Standard Metropolitan Statistical Areas (SMSA's) and
Non-SMSA portions of the areas. The next complete set is
due in 1979.
For EPA, BEA updated its 1972 projections only at the state
level. They used their economic model to project the state
analogue of gross national product and used state trends to
project per capita income. By relating the two, they developed
a population projection for each state.
They did not do a demographic projection, i.e. one which looks
at fertility and migration trends for the states. That is
type of projections are prepared by the Bureau of the Census.
The most recent set of Census Bureau demographic projections
was released in October, 1978. Those projections are different
from the BEA projections and are not involved in the EPA
process, bee also question K. below.
J. How does this process relate to the one which will be
proposed by the Office of Management & Budget and Department
of Commerce, which would apply to -U.1 federal programs which
use projections in their funding decisions?
The EPA guidelines are a separate process. The proposals by
O.M.B. and the Dept. of Commerce are not scheduled to appear
in draft form in the Federal Register until fall, 1979 and
the state projections in that process would not be available
until perhaps 1981. If the OMB proposals are issued in final
form, EPA might then need to revise its own guidelines to
ensure consistency; however the EPA guidelines are in effect now
are will remain so even if the OMB proposals are not issued
in final form.
Of course, many people are looking at the EPA process as a
pilot program of how such a nationally consistent system might
work.
-26-
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K. Is Che projection 3EA used the most recent projection for
the United States.
Actually, it is not, but the differences are small. The Bureau
of the Census medium (Series II) projection for the year 2000,
issued in October, 1975, was 262,494,000. They updated the
projection in July, 1977 and this most recent projection gives
260,378VOOO for the year 2000.
The BEA projections were released in early 1977 and began
with the earlier Census Bureau projection. However BEA also
took account of the acknowledged undercount in 1970 of more
than four million people. That explains why the BEA projection
for the year 2000 is several million people greater than the
Census Bureau's.
The projections above also include projections for the District
of Columbia, which is not discussed in this report. The BEA
lists a 7/77 population for the District of 690,000 and a year
2000 projection of 661,000.
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2.4 EXAMPLES
EXAMPLE *,
Suppose a state has one designated 208 agency, called Metro COG
and exactly one other SMSA encompassing the rest of the state,
called Greater Bigtown. Suppose that the projection the state
has to use is one million for the year 2000 and that the
existing Metro COG projection, bei:>g used in water quality
planning, is 600,000 for that year.
Possibility //I: Give Metro COG exactly the projection it already
has and ^ive Greater Bigtown a projection of 400,000 for
the yearW2000.
However this may be unacceptable to Greater Bigtown, which
itself may have a larger projection or want a larger one.
Possibility #2: Give MetroCOG 91% of its projection, namely
546,000. Then allow Metro COG to get a 10% variance.
In other words, Metro COG can use a projection of 546,000
+ 54,600 which is 600,600; Metro COG can now continue to
use theprojection it wanted. The state now can give
Greater Bigtown a projection of 1,000,000 minus 546,000
or 454,000!
The state winds up being able to use a projection of
600,000 + 454,000, or 1,054,000.
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EXAMPLE B
Suppose a state is working with a projection of one million
for the year 2000, as in Example A. But suppose the state
now has two designated 208 agencies called Metro COG and
Area COG and that everything else in the state is part of
Greater Bigtown, an SMSA. Suppose that Metro COG and Area COG
have been using projections of 500,000 each for the year
2000.
Clearly, the state can't produce a disaggregation with
500,000 each for Metro COG and Area COG because there would
be nothing left for Greater Bigtown, not even the current
level of its population.
Possibility #1: Suppose one of the designated 208 agencies
has also prepared a population projection lower than
the one they eventually chose to use for the 208 process.
Give the 208 _that projection and see if enough is
left to satisfy Greater Bigtox-m.
Possibility #2: Give both Metro COG and Area COG 91% of
their original projections, or 455,000 each. As in
Example A, "give" each area its 10% variance, bringing
them back to roughly 500,000 each. The state now
has left to allocate 1,000,000 - 455,000 - 455,000, or
90,000. If this is acceptable to Greater Bigtown,
the state's problems are solved.
If this is not acceptable to Greater Bigtown or to the
state, for whatever reasons, the state has no choice
but to a) give Metro COG or Area TOG even lower projections
b) request a variance of the state number from EPA.
Possibility #3: Suppose the state already has a set of
projections for regions or counties, or perhaps several
sets. If one set jives a total projection of roughly
one million, the state could allocate population according
to that projection. Or, if the state has county pro-
jections totalling, say, 1,200,000, the state could give
each of the three areas under consideration 83% of the
sum of their constituent counties' projections.
-29-
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-30-
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2.5 TEXT OF THE GUIDELINES AND DISCUSSION IN THE FEDERAL REGISTER
This section contains that portion of the Construction
Grants Regulations in the Federal Register of September 27,
1978 which dealt with population projections.
In order are:
* cover page for the entire package of regulations
* two pages of introductory discussion
* three pages of discussion specifically on the public
response to the earlier draft of the projections
guidelines
* text of the guidelines themselves.
-31-
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WEDNESDAY, SEPTEMBER 27,
1978
PART III
ENVIRONMENTAL
PROTECTION
AGENCY
a
MUNICIPAL
WASTEWATER
TREATMENT WORKS
Construction Grants Program
-35-
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44022
[6560-01]
Title 40Protection of Erwirpnrnaai
CHAPTER IENVIRONMENTAL
PROTECTION AGENCY
CFRL951-3]
PART 35 STATS AND LOCAL
ASSISTANCE
Subparf £Grantt For Construction
of Traaimant Works
AGENCY: Environmental Protection
Agency.
ACTION: Rule.
SUMMARY: This is a conformed ver-
sion of regulations governing the'con-
struction grants program for munici-
pal wastewater treatment works. The
substantial changes in the regulations
serve several purposes. The majority
of the changes implement amend-
ments to the .Federal Water Pollution
Control Act (FWPCA or the Act) as
amended, contained in the Clean
Water Act of 1911
-------
f
X rrV f
ulations, the final regulations included
both revisions to the technical amend-
ments and editorial chances.
Altogether the Agency circulated
more than 30,000 copies of various
drafts of the regulations- We received
invaluable assistance from the organi-
zations, agencies, and the public at
large. Commenters raised a variety of
issues. The major issues raised during
the official comment period are dis-
cussed below under the appropriate
subject area.
Various related regulations have
been or will be published soon. As re-
quired by statutory deadline, EPA
published two short amendments to
the construction grants program regu-
lations early this year. On January 10,
1978 (43 FR 1597), fiscal years 1973-81
authorizations were allotted. On June
29, 1978 (43 FR 28202), we published a
correction of the section number for
the allotment regulation. It is 3 35.910-
3 in this conformed regulation. On
February 23, 1978 (43 FR 7426), the re-
imbursement grant regulations (subpt.
D) were revised to extend eligibility
dates. On June 26, 1978 (43 FR 27736),
EPA published final pretreatment reg-
ulations as 40 CFR part 403. Those
regulations establish the responsibil-
ities of Government. Industry, and the
public to implement national pretreat-
ment standards to control pollutants
that pass through or interfere with
treatment processes in publicly-owned
treatment worics or that may contami-
nate sewage sludge.
On August 7, 1973, we published pro-
posed regulations on public participa-
tion in the Frnnut RICISTSH (43 FR
34794). Those regulations Implement
section lOKe) of the FWPCA which
requires SPA to provide for, encour-
age, and assist public participation in
EPA programs. The regulations would
replace 40 CFR part 105 (Public Par-
ticipation in Water Pollution Control)
and 40 CFR part 249 (Public Participa-
tion in Solid Waste Management) with
a new 40 CFR part 25.
References to pan 25 are inserted in
this regulation in anticipation of pub-
lication at final public participation
regulations. In the interim any refer-
ence to part 25 in these regulations
should be interpreted as referencing
the current part 105 regulations. The
new part 25 would establish overall
public participation requirements for
programs under the Clean Water Act,
the Safe Drinking Water Act, and the
Resource Conservation and Recovery
Act. The regulations. In addition,
revise public participation require-
ments in 40 CFR part 35 subpart 2,
specifically for the construction grants
program. They focus the public's at-
tention on decisions made during the
planning of the wastewater treatment
facilities. They also provide the oppor-
RUMS AND REGULATIONS
tunity for pubiic involvement in later
stages of project development.
EPA published proposed reguiatlons
for the water quality management
program in the FEDERAL REGISTER on
September 12, 1973 (43 FR 40742).
Those regulations replace 40 CFR
parts 130 and 131 and portions of part
35 with a new 40 CFR part 35, subpart
G. The regulations govern the water
quality management program under
sections 106, 208, and 303(e) of the
FWPCA and include changes made to
implement provisions of the 1977 Act.
The regulations require a State/EPA
agreement, which Is intended to ser/e
as the principal management tool for
the water quality management pro-
gram. The State/EPA agreement will
integrate the planning, management,
and implementation of ail water qual-
ity management programs under the
Clean Water Act, P.CRA, and SDWA
by fiscal year 1980. At a minimum, the
fiscal year 1979 agreement shall cover
programs authorized by sections 106,
2Q5(g), 208, 303, and 314 of the Clean
Water Act. The State/EPA agreement
is distinct from the construction grant
delegation agreements that may be ne-
gotiated under section 205(g) of the
FWPCA, as amended by the 1977 Act.
The water quality management
(WQM) regulations coordinate the es-
tablishment of State and areawide
WQM agencies' sewage treatment pri-
orities with the construction grants
priority system and lists. WQM plans
are to provide certain facility planning
related information such as planning
area delineations, waste load alloca-
tions, and population projection disag-
gregations. Construction grant facility
plans will have to be based on this in-
formation. Overall the WQM program
regulations lirUc that program and the
construction grants program together
much more closely.
On September 20, 1978 (43 FR 42251)
we published in the FEDERAL REGISTER
final regulations on State management
assistance grants (subpt. F). They
make funds available to States to man-
age the construction grants program
and to hire and train staff needed to
implement delegated functions.
Prom time to time EPA issues guid-
ance and technical information to sup-
plement regulations and to assist
those participating and interested in
EPA programs. A listing of informa-
tion and copies may b« obtained from
the General Services Administration
(SFSS), Centralized Mailing Lists Ser-
vices, Building 41. Denver FederaJ
Center, Denver, Colo. 30225. (See
§35.900e*Al «
-------
\
monitoring requirements. Still others
concurred with the requirements as
written. EPA has worded the regula-
tions to allow considerable flexibility
tn monitoring so that local conditions
can dictate the extent of the require-
ment within limits designed to ensure
that minimum monitoring to protect
the health of the community is re-
quired.
Concern was expressed that best
practicable waste treatment criteria
were not defined. These criteria are
defined in chapter II of "Alternative
Waste Management Techniques for
Best Practicable Waste Treatment,"
EPA-430/9-75-013, MCD-13, under al-
ternatives employing land application
techniques.
EPA received recommendations that
nonprofit organizations be deemed eli-
gible for grants and for management
of on-site systems. The Act allows
award of grants only to "public
bodies." Nonprofit organizations with
the capability and authority to plan,
design, construct, and operate treat-
ment works for public purposes would
be eligible to function Ln that capacity
under agreement with the public body.
If the nonprofit organization is consti-
tuted a public body under State law, it
could qualify for consideration for a
grant (e.g.. a citizen's association
which Is officially constituted as a
sewer district).
One comment asked what Is a
"number of Individual units," is there
a maximum number of individual
units, and if there is a dollar ceiling
for individual systems. There is no ab-
solute dollar ceiling for individual sys-
tems: the law specifically states a
minimum of "one or more principal
residences or small commercial estab-
lishments." The maximum number of
units would be established through se-
lection of the appropriate alternative
oj unconventional technology for indi-
vidual residences or clusters of resi-
dences. Under the definition elsewhere
in the regulation <§ 35.915-l(e)>, this
technology would be applied in com-
munities of 3,500 population or less, or
highly dispersed sections of larger
communities.
One comment referred to the state-
ment that all individual systems quali-
fy as alternative systems, yet the cost-
effectiveness guidelines provision for
the 115 percent cost preference for in-
novative and alternative systems does
not apply to individual systems. The
law specifically states privately owned
Individual systems must cost less than
the cost of providing a system of col-
lection and central treatment.
Other comments recommended more
coordination between EPA and the
Fanners' Home Administration
(FmHA). Such coordination has al-
ready been initiated; FmHA's final de-
cision on projects is often made pend-
RUL£S AND REGULATIONS
ing EPA approval of a grant. In addi-
tion, coordination between the two
agencies in areas such as joint applica-
tions, standardization of definitions of
high-cost projects, and other stream-
lining of administrative procedures is
proceeding under the aegis of a White
House working group on rural water
and sewer problems. This coordination
also will be extended to other Federal
agencies through this group.
One comment recommended exten-
sion of grant eligibility to bathroom
fixtures and plumbing utilizing flow
reduction technology. Congressional
intent expressed in the legislative his-
tory is quite clear that commodes or
associated plumbing are not eligible
for grant funding. If eligible, adminis-
trative difficulties and costs would be
very large.
EPA encourages the use of the facili-
ty plan to evaluate every feasible al-
ternative for solution of the water pol-
lution problem whether or not such a
solution involves grant ineligible facili-
ties or methods. Assistance in grants
packaging, construction supervision,
planning and initial training for oper-
ations and maintenance are all gener-
ally grant eligible.
There were several requests to
define terms and concepts more spe-
cifically. This will be done in separate
guidance to be issued at an early date.
Regulatory changes relating to indi-
vidual systems are found in §§ 35 905-
23, 35.917-Kb). 35.917-2ta), 35.918,
35.918-1. 35.918-2, and 35 518-3.
44031
COST-EFFECTIVENESS
GUIDELINES AND RESESVE
Background. On February 4, 1977.
EPA published in the FEDERAL REGIS-
TER proposed guidelines to amend and
supplement the Cost-Effectiveness
Analysis Guidelines (Appendix A to 40
CFR, Part 35, Subpart E). That pro-
posed revision was intended to provide
for cost-effective sizes of and suffi-
cient reserve capacity for wastewater
treatment works and. at the same
time, to avoid overdesign. Coverage in-
cluded guidance and alternative proce-
dures for forecasting growth of popu-
lation.for estimating wastewater
flows, for determining cost-effective
construction staging periods, and for
providing extra capacity beyond that
determined to be cost-effective.
Most of the commenters on the pro-
posed revisions, while agreeing in prin-
ciple with the proposal, raised ques-
tions or suggested modifications that
convinced the Agency several changes
were warranted. Also, additional guid-
ance was required to Implement sec-
tion 16 (Cost-Effectiveness) and sec-
tion 21 (Reserve Capacity) of the 1977
Clean Water Act. Accordingly, the
EPA revised the Cost-Effectiveness
Analysis Guidelines to Incorporate
these changes, and on April 25, 1973,
published them as part of a set of In-
terim regulations to implement the
Clean Water Act. These interim guide-
lines were effective as of June 26, 1978.
Commenters on the interim guidelines
suggested revisions that convinced the
Agency to make some additional
changes.
Innovative and alternative technol-
ogies. Section 16 of the 1977 Act en-
courages the use of innovative and al-
ternative wastewater treatment tech-
nologies by extending grant eligibility
to such projects if the life cycle cost
does not exceed that of the most cost-
effective alternative by more than 15
percent. The Agency's interim guide-
lines called for using option 3 of the
following options for calculating the
cost-effectiveness preference:
1. Use the life cycle cost of the
entire proposed waste treatment
system as a base for calculating the
cost difference;
2. Apply the 15 percent increase to
innovative and alternative components
(and other differing portions) as com-
pared with corresponding portions of
the least costly nonmnovative alterna-
tive; or
Use, as a base, the entire proposed
waste treatment system where the
system primarily (more '.han 50 per-
cent of its cost) involves innovative or
alternative technologies. Should Inno-
vative or alternative components com-
prise 50 percent or less of the system
cost, the calculation base would be
that for option- 2.
Some commenters have expressed a
preference for option 2. The Agency
does not concur because option 2
would be difficult to administer and
would also restrict unnecessarily the
number of projects qualifying for the
15 percent preference. The Agency has
rewritten option 3 to state that all pro-
jects with alternative and innovative
components will qualify for the prefer-
ence, except for those in which alter-
native or Innovative unit processes re-
place conventional processes In a
treatment plant and account for less
than 50 percent of the cost. This lan-
guage represents a slight liberalization
of option 3, allowing some additional
projects to qualify for the cost prefer-
ence. This revision also clarifies and
simplifies the old language.
Other commenters noted that collec-
tion systems common to both the con-
ventional option and alternative tech-
nology system should not be included
tn the calculation base. The Agency
agrees and has modified the guidelines
accordingly.
Another coramenter noted that the
15,percent cost-effectiveness pfefer-
ence must be mandatory rather than
permissive. Both the law and these
regulations mandate a 15 percent mon-
etary cost-effectiveness preference for
all innovative or alternative projects
ROtRAl «0«THt. VOL 43, MO. 184WEDNSSOAT, SEJTEMBfS 77, 1973
-36-
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44032
or components thereof that meet the
Agency's criterion for such projects.
However, this aoes not mean that the
grantee must adopt an option featur-
ing innovative or alternative technol-
ogies wherever their monetary costs
are less than the 15 percent ceiling ce-
causs r.onmonetary factors must be
taker, into account as -veil.
Discount 'nie. The Agency consid-
ered raising the discount rate for eval-
uating1 proposed wastewafr treatment
works from that used by the Acency
(currently 6V« percent; to 10 percent.
The former rate is used by the Water
Resources Council (WHO to evaluate
ths costs and benefits of 7. ater re-
sources projects. EPA. as a member
unrcy. adopted this -ate in 1973 when
it published '.he Cost-Effectiveness
Analysis Guidelines (appendix A of
Construction Grant Regulations), al-
though the construction grants pro-
gram LS not covered by the WRC
"principles and standards" for evaluat-
ing water resource projects. The latter
rats (10 percent) is cited in Office of
Management and Budget (OMB) cir-
cular A-9-! for use In agency programs
net covered by the WRC "principles
anc! standards."
The 10-percent rate is believed to ap-
proximate the opportunity cost of cap-
ital. The "Opportunity Cost of Capital
Concept" nas the rr.cst theoretical eco-
nomic justification for cost-effective-
ROSS analysis. This concept suggests
the proper discount rate to use for
pubuc investment projects should be
based on the rate of return to private
sector investment (before taxes and
adjusted ior inflation). This is because
resources used for public investment
have alternative uses in the produc-
tion of private commodities which so-
ciety foresees for the sake of the
public investment.
Use of the 10-percent discount rate
would help produce a more economi-
cally efficient distribution of construc-
tion grant funds. The expected result
is th?.t the optimal (cost-effective)
staging period (the number o: years
for which the treatment plant Ls de-
signed to handle a community's
growth In terras of sewerage dis-
charge) will decrease frotr. about 10-20
years to about 9-16 years. These
shorter staging periods will result in
slightly smaller treatment works and
in smaller initial treatment expendi-
tures for each proposed treatment
system. This should permit a. some-
what greater number of treatment sys-
tems to be funded.
Despite these considerations, the
Agency has decided against raising the
discount rate to 10 percent. The
higher discount rate would have the
effect of lowering the total present
worth cost of facilities with high oper-
ation and maintenance costs in com-
parison with the total present worth
SULES AND 2EGUIATJCNS
cost of capital intensive facilities with
low operation and maintenance costs
such as land treatment and energy re-
covery facilities. This could largely
offset the 15-percent cost-effectiveness
preference given to such measures
under the 1977 Act and these guide-
lines. It would also run counter to the
President's recent decision to retain
the existing discount rate for water re-
sources projects.
Many commenters representing a
wide variety of Interests opposed in-
creasing the discount rate (only one
favored such action) primarily because
such actions would tend to disadvan-
tage capital intensive land treatment
and energy recovery alternatives and
would favor operation and mainte-
nance cost intensive options.
The Agency has decided to retain
the WHC discount rate (currently S*'i
percent) because this rate is consistent
with the President's water resources
policy and the net programmatic ad-
vantages, if any, of increasing the rate
are not of overriding importance.
Cost escalation. Several commenters
advocated use of a salvage value for
land higher than the prevailing
market price as required in the inter-
im guidelines because of the very rush
rate of land value appreciation. The
Agency has analysed farmland value
appreciation since 1960 and since 1970
and has compared these rates with
cost escalation rates for construction,
energy and labor. The analysis showed
that land values over both the 17-year
and 7-year periods have escalated
roughly 3 percent faster than costs as-
sociated with construction or oper-
ation and maintenance of a treatment
works. On this basis, the final guide-
lines will require. In the calculation of
land salvage value, a land appreciation
rate of 3 percent compounded annual-
ly, unless the grantee Justifies a
higher or lower percentage based upon
historical differences between local
land cost escalation and construction
cost escalation. This allowance repre-
sents the estimated difference la rates
between land cost appreciation and
the cost escalation of goods and ser-
vices related to construction.
Several commenters suggested esca-
lation of energy, chemical, and labor
costs in the cost-effectiveness analysis
to account for anticipated high in-
creases in these costs. It should be
noted that the cost effectiveness anal-
ysis procedures call for use of constant
dollars based on prevailing marfeet
prices at the time of the analysis and a
low discount rate which is less than
the inflation-free rate based on the op-
portunity cost of capital concept. This
approach, rather than Implying no
future Inflation, simply assumes that
the costs of all resources involved in
treatment works construction and op-
eration will increase at about the same
\sc\jssion
rate on a long-term basis. The results
of the cast-effectiveness analysis
would be distorted, however, if the
prices of certain resource inputs
changed significantly over the plan-
ning period in relation r.o the prices of
other resource.1). The Agency has ana-
lyzed historic data on wastewater fa-
cility construction price indexes and
on prices ol various operation and
maintenance components, including
labor, electricity, chemicals, coal, .pe-
troleum distillates, and natural gas.
We also reviewed projections of future
energy use prepared by the Depart-
ment of Energy. Only the historic and
projected increase in natural ?as
prices were found to significantly
exceed (by nearly 4 percent) those for
construction and the average of other
operation and maintenance elements.
Thus, the Agency has revised the
guidelines to require escalation of rela-
tive natural gas prices over the pi?..-1.-
nlng period at a compound rate of i
percent annually, unless the grantee
justifies a higher or lower percentage
based upon regional differentials be-
tween historical natural jas price esca-
lation and construction cost escala-
tion.
} Xtsen-e cqjactTy] The Clean Water
'Ai'i i lit]ui»~es '1115' A-jency. in ae'.ermip-
ing the amount of reserve capacity eli-
gible for a grant, to take into account
the projector! popuiat'qri presented in
a facility plan. The population must
be baaed on the latest information
available from the U S. Department of
Commerce or from the States as EPA
determines appropriate. The interim
guidelines called for population fore-
casts in facility plans to be based upon
disaggregatlon of State population
totals already developed by the De-
partment of Commerce. Several com-
menters, principally 203 planning
agencies, oppose this approach and
contend that population forecasting-is
a policy matter that should best be ad-
dressed by local governmental units.
Others, principally environmental
groups and individuals, favor the dis-
aggregation approach as a means of
preventing excessive capacity and re-
sultant secondary impacts.
The Agency believes the disaggrega-
tion approach should be retained be-
cause, to avoid providing excessive re-
serve capacity, forecasts of population
and economic activities for Individual
small areas such as facility planning
areas or designated 208 areas snould
be reasonably consistent with Stats
and national projections. This ap-
proach is consonant with the Presi-
dent's urban policy intended to revital-
ize cities and discourage urban sprawl.
The guidelines permft Inclusion of
extra capacity in a treatment wor'is at
the expense sf the grantee to accom-
modate local growth policies. The final
guidelines allow reasonable departures
SCfSM JZGISTH, VOL «, NO. 13«WEBNKOAY, SKTIM3W V', 1978
07-
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8UIES AND SEGUtATJONS
from the Department of Commerce
State projections and their disaggrega-
tions to designated 208 areawide plan-
ning areas, where the State or desig-
nated 208 agency has already prepared
projections. The final guidelines
permit use of SUte projections aJ-
ready prepared by the State if the
year 2000 State projection does not
exceed that of the Department of
Commerce projection by more than 5
percent. The Administrator may ap-
prove State population projections
that exceed the Department of Com-
merce projections by more than 5 per-
cent if justified by the State. Where a
designated 208 agency has already pre-
pared a population projection for its
area. It may be used if the year 2000
population does not exceed that of the
disaggregation, based on the Depart-
ment of Commerce projection, by
more than 10 percent.
One State suggested allowing a State
prepared population forecast to
exceed the Bureau of Economic Analy-
sis forecast by 10 percent without jus-
tification. The Agency does not concur
because the present 5-percent depar-
ture is substantial. Also, since the
State may increase its total after the
208 agencies have received their var-
iances up to 10 percent, the total final
State departure from the Bureau of
Economic Analysis projection may al-
ready approach 10 percent or even
more In some cases. Another State
commented that States already having
policies of disaggregating State totals
among counties, even within designat-
ed 203 areas, should be allowed to con-
tinue to do so. The Agency agrees and
has Included such a provision in the
final guidelines.
One commenter has suggested that
population projections In 201 and 208
plans should no longer be wedded to
existing zoning ordinances, which may
be exclusionary and forbid immigra-
tion by lower income people. Instead
he suggested that future population
and the resulting reserve capacity for
grant funded projects should rely on
regional population projections and. in
particular, regional allocations of low-
and moderate-income apartment units.
The Agency cannot fully comply with
this suggestion because it believes that
zoning and land-use decisions should
be left primarily with local govern-
mental units, and decisions on cost-ef-
fectiveness should be based on total
and not partial population projections
in an area. However, these regulations
require the local population projec-
tions for 201 plans to fall within ceil-
ings based on disaggregation of State
and regional population totals.
Several commenters advocate a
much more flexible population fore-
casting approach by permitting use of
population projections other than the
Bureau of Economic Analysis. The
Agency do«s not concur because use of.
various projections would be inequita-
ble and would lead in many instances
to funding excessive reserve capacity
to accommodate growth.
One commenter stated that the pop-
ulation disaggregation approach is too
simplistic for interstate metropolitan
areas whera factors influencing popu-
lation change go beyond State bound-
aries. The Agency concedes that such
situations may pose difficult forecast-
ing and disaggregation problems. Nev-
ertheless, the Agency believes the in-
terstate disaggregation problems can
be worked out through consultations
among the concerned States, designat-
ed 208 agencies and other regional
planning agencies.
Some commenters pointed out the
need for public involvement in- the
review of the State population disag-
gregations. The Agency agrees that
the public should have an opportunity
to review and comment on the disag-
gregation before Agency review. Ac-
cordingly, the final guidelines now re-
quire the State to hold a public meet-
ing on its disaggregations before sub-
mitting them for Agency review.
The Agency believes :hat the same
population projections should be used
for both air and water quality plan-
ning. Appendix A now requires, as an
initial step toward implementing this
objective, that States, when disaggre-
gating total State population, consult
with organizations of local officials re-
sponsible for water quality and air
quality planning. In many instances
the organizations certified by Gover-
nors pursuant to section 174(a) of the
Clean Air Act to do air quality plan-
i ning are also 208 agencies.
borne cooimenters nave oojected to
the per capita How limitations of 60-80
gallons per capita per day (the second
method of estimating wastewater
flows) as being unrealisticaily low. The
Agency believes that such dry weather
base flow allowances are adequate for
smaller communities where flow data
are Lacking. These allowances exclude
Infiltration and inflow. Residential
wastewater flows nationwide average
only 45 gallons p«r capita per day.
Other commenters favor increasing
future per capita flows over time.
They contend that increasing per
capita flows have been observed
during the past 10 years and that with
Increasing affluence this trend will
continue. The Agency agrees that per
capita water usage and wastewater
flows have increased in the past but
believes that this trend is reversing.
This can be attributed to the increase
of personal water conservation habits
encouraged by periodic water short-
ages or higher water supply and sewer-
age costs even in normally water rich
areas. Moreover, plumbing codes.
State laws and ordinances are nxpidly
44033
being revised in many areas to requirs
installation of water-saving fixtures in
new dwellings, hotels, moteis, and
other buildings.
Section 21 of the 1977 Act. requires
the Agency, in approving the amount
of reserve capacity for a treatment
worts, to take into account efforts to
reduce the flow of sewage ana unnec-
essary water consumption. The Presi-
dent's water resource policy features
water conservation as its cornerstor.s
and requires Federal agencies to '.01-
plement appropriate conservation
measures.
The guidelines require a cost-effec-
tiveness evaluation of flow-reduct.on
measures such as plastic toilet dams
and low flow sr.owerheads: changes :n
laws, ordinances, or plumbing cooes re-
quiring installation of water-savins,' de-
vices in future habitations; and water
pricing changes. The grantee must ae-
velop a recommended now reduction
program featuring a puuiic .informa-
tion program plus cost-effective meas-
ures for which the grantes has imple-
mentation authority or can obtain co-
operation from an entity with such au-
thority. Exempted from these require-
ments are those communities with a
population less than 10.000 or with
average daily base Hows, excluding in-
filtration/Inflow and industrial flows.
for treatment worss design of less
than 70 gallons per capita per day or
with ongoing flow reduction pro^ra-T-s.
Several commenters have su^ge-sied
that small communities should be en-
couraged to conserve water ar.d thus
should not be exempt from the now
reduction requirements. The Agsncy
concedes that some water conservation.
potential exists for smaller communi-
ties even though such communities
tend to use and waste less water than
the larger, more affluent cities. Never-
theless, the Agency believes that -he
limited cost savings obtainable in
small communities from flow reduc-
tion programs may not be comment-
rate with the administrative burden
Imposed. Some commenters have
pointed out that the 70 gallons par
capita per day exemption criterion 13
too stringent and have suggested a 100
gallons per capita per day criterion.
The Agency disagrees because the 70
gallons per capita per day figure,
which reprssento an average -iry
weather base How, is large enough Co
exempt most small communities ai;J
water-conserving larger cities. Almost
all communities, including larger
water users, would be exempt if tha
suggested 100 gallons per capita per
day criterion were used.
Two commenters objected to the
flow reduction requirements as being
unreasonable for areas with adequate
water supplies. The Agency disagrees.
During the past 20 years, persistent
drought and accompanying water
FIDJRAt *fr6«THa, VOL 43, WO. 183WTONiSOAY, S£rTtMB« 27, 197J
-58-
-------
RUl£S AND REGULATIONS
4408'
volvement In any contract dispute will
not make EPA a party to any contract
entered Into by the grantee. (See
§35.938-8.)
(d) Delegation to States. The author-
ity to provide technical and legal as-
sistance In the administration of con-
tract matters described in this section
may be delegated to a State agency
under Subpart ? of this part if the
State agency can demonstrate that it
has the appropriate legal authority to
undertake such 'unctions.
COST-cmcrrvcfESS ANALYSIS GUIDELINES
1. Purpose. These ijuidelines represent
Agency policies and procedures for deter-
mining the most cost-effective waste treat-
ment management system or component
part.
2. Authority. These juideltnes are pro-
vided under sections 212<2)(C) ana 217 of
the Clean Water Act.
2. Applicability. These guidelines, except
as otherwise noted, apply to all facilities
planning under step 1 frant assistance
awarded after September 30, 1978. The
guidelines also apply to" State or locally fi-
nanced facilities planning on which subse-
quent step 2 or step 3 Federal grant assist-
ance Is based.
4. Dfjinitionj. Terms used in these guide-
lines ire defined is follows:
a. Waite treat-Kent management system-
Used synonymously with "complete waste
treatment system" is defined in 5 35.905 of
this subpart.
b. Cost-effectiveness anzlvsu. An analysis
performed to determine which waste treat-
ment management system or component
par*, will result In the minimum total re-
sources costs over '.Ime to meet Federal,
State, or local requirements.
c. Pia.nm.ny period. The period over which
a waste treatment management system is
evaluated for cost-effectiveness. The plan-
ning period begins with the system's Initial
operation.
d. Useful life. The estimated period of
time during which a treatment worts or a
component of a waste treatment manage-
ment system will be operated.
e. Disayartya.t-.on. The process or result of
breaking down a sum total o( population or
economic activity for i State or other Juris-
diction (I.e.. designated 203 area or SMSA)
into smaller oreaj or jurisdictions.
5. Identification, selection, and screening
of alternatives, a. Identification c/ atterna.-
tivet. All feasible alternative waste manage-
ment systems shall b« Initially Identified.
These alternatives should Include systems
discharging to receiving waters, land appli-
cation systems, on-site and other non-cen-
tralized systems. Including revenue generat-
ing applications, and systems employing the
reuse of wastewater and recycyling of pol-
lutants. In Identifying alternatives, the ap-
plicant ihail consider the possibility of no
action and staged development of the
system.
b. Screening a/ aiieTiatrcei. The Identi-
fied alternatives shall be systematically
screened to determine those capable of
meeting the applicable Federal, State and
local criteria.
c. Selection of aitamatives. The Identified
alternatives shall be initially analyzed to de-
termine which systems have cost-effective
potential and which should be fully evaluat-
ed according to the cost-effectiveness analy-
sis procedures ustablishea in the guideline!.
d. Extent oj ejfort. The extent of effort
and the level of sophistication used In the
cost-effectiveness analysis should reflect the
project's slie rind importance. Where proc-
esses or techniques are claimed to be inno-
vative technology on the basis of '.he cost
reduction criterion contained in paragraph
6e(l) of appendix 2 to this subpart, * suffi-
ciently detailed cost analyse shall be includ-
ed to substantiate the claim :o the iatisfac-
tlon of the Regional Administrator.
6. Coit-effec.'.iyeness analysis procedures.
a. .Vfetftod 01' analysis. The resources costs
shall be determined by evaluating opportu-
nity costs. For resources that can be ex-
pressed In monetary terms, the analysis will
use the interest (discount) rate established
in paragraph Se. Monetary costs shall be
calculated In terms of present worth values
or equivalent annual values over the plan-
ning period defined In section so. The anal-
ysis shall descriptively present noarr.one-
tary factors i e.g.. social and environmental)
in order to determine their significance and
impact. Nottmonetary factors Include prima-
ry and secondary environmental effects, im-
plementation, capability, operabihty. per-
formance reliability and flexibility. Al-
though such factors is use and recovery of
energy and scarce resources and recycling ot
nutrients arc to be Induced in the monetary
eost inalyst!i. the non-monetary evaluation
shall also Include them. The most cost-effec-
tive alternative shall be the waste treatment
management system which the analysis de-
termines to have the lowest present worth
or equivalent annual value unless nonmone-
tary costs ire overriding. The most cost-ef-
fective alternative must also meet the mini-
mum requirements of applicable eff.uent
limitations, groundwater protection, or
other applicable standards estaoiished
under the Act.
b. Planning period. The planning period
for the cost;-effectiveness analysis shall be
20 yean.
c. Elements of monetary costs. The mone-
tary costs to b« considered shall include the
total value of the resources which are at-
tributable t.o the waste treatment manage-
ment system or to one of Its component
parts. To dct< -mine these values, ill monies
necessary for capital construction costs and
operation iind maintenance costs shall be
Identified.
(1) Capital construction costs used in a
cost-effective analysis shall tnckide all con-
tractors' costs of construction including
overhead and profit, costs of land, reloca-
tion, and right-of-way and easement acquisi-
tion: costs of design engineering, field explo-
ration and engineering services during con-
struction: costs of administrative and legal
services including costs of bond sales: star-
tup costs such as operator training; ana in-
terest during construction. Capital construc-
tion cosu shall also Include contingency
allowance-s consistent with the cost esti-
mate's level of precision and detail.
(2) Thii cost-effectiveness analysis shall
Include annual costs for operation and
mamtana-nce (including routine replacement
of equipment and equipment parts). These
costs shaJl be adequate to ensure effective
and dependable operation during me sys-
tem's planning period. Annual costs shall be
divided between fixed annual costs and costs
which would depend on the annual quantity
of wastthe total capita! expenditures.
l = the Interest rate (discount rate m section
6e>.
(2) Where expenditures will not be uni-
form, or when the construction period will
be greater than 4 years, interest durins con-
struction ohail be calculated on i year-by-
year basis.
1. Useful life. (!) The treatment works'
useful Ufa for a cost-effectiveness analysis
shall be as follows:
Landpermanent.
Wiste water conveyance structures (in-
cludes collection systems, outfall pipes.
Interceptors. force mains, tunnels.
etc.)50 years.
Other structures (includes plant building,
concrete process tankage. oa.iins, lift sta-
tions structures, etc j30-50 years.
Process equipment15-20 /ears.
Auxiliary equipment10-15 yeirs.
(2) Other useful i.fe periods will be accept-
able when sufficient justification con be
provided. Where a system or a component is
for interim service, the anticipated useful
life shall be reduced to the period for inter-
im service.
h. Salvage value. (I: Land purchased for
treatment works, including land ised is
part of the treatment process or for ulti-
mate disposal of residues, may be assumed
FJDEJUkl ZEGISTia, VOL 43, NO. 13«WJDNE50AY, StPTJMBES 27, 197J
-39-
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44088
to hnvi- » iJihAvc \nlue al lh« end of the
Ulanrtmn period s lf«t co.ua! tu its prrva.il-
In* market value 1 the uiTie of (.n* analysis
In calculating the s\Saee value o( land, the
land \alu<* shall Oe apttrr-ciaK-d ai a com-
pound rate of 3 pcrr* nl annually over the
piAnning period, unlr s the Regional Ad-
ministrator deterrru'H's ihs.t the grantee has
justified the o« oi ^ grt -.tor or lr-,;scr per-
centage based upon hist-, noal oifferences
between local land cost ^vilatlon and con-
struction cost esciiatic/n. TK land rost -esca-
lation rate may Se updated ix-nodicaMy in
accordance with Agcnc? guidelines. Right-
of-way easements shall be considered to
h»ve a salvage value not >rreater than the
prevailing martet ^alue it the time of the
analysts.
(2) Structures v\l\ be assumed to hive a
salvage \»lu* It were us ». use for them it
the end of the pUr.r.lns Period In this cane,
salvage v*lue shall be estimated using
s'.ralght line depreciation during the useful
Hie of the treatment works.
(3) The method used in paragraph Sh<2)
may be used lo estimal^ saK&ge value at the
end of the planning period for phased nddl-
tlona of process equipment and auxiliary
equipment.
<«> When the anticipated useful life of a
facility Is less than 20 years (for analysis of
Interim facilities), salvage value can &«
claimed for equipment If it can be clearly
demonstrated that a specific market or
reuse opportunity will exist.
7. Innovative and alls-main**
treatment proc«jfs and
i. Beginning October V, 1973, the capital
COSH of publicly owned treatment »ork.s
which use processes and techniques meeting
the criteria of appendix E to this subpaj-t
and which have only & viator pollution con-
trol function, rray be eligible if the presT.l
worth cost of Uie treatment works is r.ot
more than IIS percent of the present wor.h
cost of the mo»t cost-effectue pollution con-
trol system, exclusivp of collection severs
and Interceptors common to the two sys-
tems being eompp.red, by 115 percent,
except for the following situation.
b. Where Innovative or alternative unit
processes would sorve in lieu of conventional
unit processes in a conventional »asle »ater
treatment plant, and the present vkorth
costs of the nonconvcniK/rtal unit processes
are less than 50 percent, of the present
worth costs of the treatment plant, multiply
the present worth coils of the replaced con-
ventional processes by 115 percent, and idd
the cost of nonreplaced unit processes.
c. The eligibility of multipurpose projects
which combine a water 'pollution control
function with another .'unction, and uhlch
use processes and techniques meeting the
criteria of appendix S to this subpart. shall
be determined In accord-vice with guidance
issued by the Administrator.
M. The above provisions exclude Individual
systems under 5 35.918. The regional Admin-
istrator may ailo* a grantee to apply the 15-
percent preference authorized by this sec-
tion to facility plans prepared under step 1
grant assistance a»irc!ed before October 1.
1918.
RULES AND REGULATIONS
4. Co-s t ~tffec Ci ve sidling and sizing 57
tr?4i7Tlft?li t£0fJCt.
a. ^"opuicUion pro^-cftoru (1) The disas-
grexatlon of Stair urujertioiis of population
shall be the bas:* for the population (ore-
casts presented in individual facility plans,
except as noted. The«;e Stale projections,
shall be those developed In 1977 by the
Bureau of Economic AiiaiyMs (BEA), De-
partment nf Commerce, uril^vi. a.s of June
2S. 1978. the SiaU- has nireAdy prepared
projections Thv" -State projections may b«
used instead of the BHLA pro;c< lions If the
year 2000 State population ao<:s P.ot exceed
that of the BEA projection by more than 5
percent. If the difference exceeds this
amount, the Slau* must cither justify or
lower its projection. Justification must be
based on the historical und current trends
(e g.. energy and industrial development.
military base openings) not taken into ac-
count in the BEA projections. The State
must submit for approval to the Administra-
tor the request and justification for use of
State projections higher than the 3SA pro-
jections. By that tune, the State shall issue
a public notice of the request. Before the
Administrator's approval of the SUt* pro-
jection, the Regional Administrator 'shall 10-
llcit public corruT.ents and hold » public
hearing If Important issues ire raised about
the State projection'! validity, Sute pro)**-
DOCU and dlsaggregaUons may be updated
periodically In accordance with Agency
ruldejlnes.
(2) Each State, working alth designated
203 planning agencies- organizations certi-
fied by the Governor under section 174(a> of
the Clean Air Act, as amended, and other
reftonal planning agencies In the Stale's
nondeslgnated are**, shall disaggregate the
State population projection among tu desig-
nated 208 areas, other standard metropoli-
tan statistic*! ireas (SMSA's) not Included
In the 208 area, and non-SMSA counties or
other appropriate Jurisdictions. States that
had enacted laws, &i of June 28. 1973, man-
dating disassrevraiion of Sute population
totals to each county for areawide 203 plan-
ning may retain this requirement. When
disaggregating the Stale population total.
the State snail lake into account Hie pro-
jected population and economic activities
identified in facility plans, ireawlde 208
plans and municipal master plans. The sum
of the dlsascregateci projections shall not
etcced the State projection. Where i deaif-
naied 208 area has, as of June 26, 1978, al-
ready prepared a population projection. It
may be used if the year 2000 population
does not exceed that of the disaggregated
projection by more thaa 10 percent. The
S'.ate may Ihcn Increase its population pro-
jection to include all such variances rather
than lower the rxjpulatlon projection totals
for the other areas. If the 208 area popula-
tion forecast exceeds the 10 percent
allowance, the 208 agency must lower Its
projection within the allowance and submit
the revised projection for approval to the
SUle and the Regional Administrator.
(3) The Stale projection totals and the
dtsangregations will be submitted as an
output of the statewide *Mcr quality man-
agement process. The suornission shall In-
clude a list of designated 208 are&s, »U
SMSA's, and counties or other units outside
the 208 areas. For each unit the disaggre-
gated population shall b«? shown for the
years 1930. 1990. and 20M. Kach State will
submit its projection totals and disaggresa-
tions for the Regional Administrator's sp-
provil before October 1. 1979 Before thks
submission, the State shall hold a public
meeting on the dlsaegregations ind shall
provide public notice of thr meeting consist-
ent flth part 25 of this chapter. (See
535 917CCU
(4) When the State projection totals and
arc approved they shall be
used thereafter for art-iwtde water quality
management plannmit is well « for facility
planning and the n*edi surveys under sec-
tion 51G(b) of the Act. Within areawlde 208
piannmx ireas. the designated agencies, in
consultation with the States, shall disaggre-
gate the 203 area projections among the
SMSA and non-SMSA areas and then disag-
gregate these SMSA and non-SMSA projec-
uons among ihe facility planning areas and
the remaining ireas. For those SMSA'j not
included within designated 208 planning
areas, each State, with assistance from ap-
propriate regional planning agencies, shall
disaggregate '.he SMSA projection among
the facilily ^planning areas and the remain-
ing areas within the SMSA. The State shall
check the facility planning area forecasts to
ensure reasonableness and consistency with
the SMSA projections.
(5) ?or non-5MSA facility planning areas
not Included In designated areawlde 208
areas, the State may disaggregate popula-
tion projections for non-SMSA counties
imong facility planning areas ind remain-
Ing areas. Otherwise, '.he grantee is to fore-
cast future population growth for the facili-
ty planning area by linear extrapolation at
the recent past (1940 to present) population
trends (or the planning area, use of correla-
tions of planning are* jrowth with popula-
tion growth for the township, county or
other larger parent irea population, or in-
other appropriate method, A population
forecast may be raised above that Indicated
by the extiruion of past trends where Ukely
impacts (e.g.. sigroncar.t new energy devel-
opments, large r-ew Industries, Federal In-
stallations, or institutions) justify the dif-
ference. The facilities plan tnust document
the Justification. These population forecasts
should be based on estimates of new em-
plos-ment to be generated. The State shall
checi Individual population forecasts lo
Insure consistency wld. overall projections
for non-SMSA counties ind Justification for
any difference from p*st trends.
(8) Facilities plans prepared under step 1
grant assistance awarded later than S
months a/Ur Azency approval of the State
cSbagST??ai'.on5 shall follow population fore-
casts developed in iccorrfaaoe with these
f* .i/JoHr
li.
b, PfcLste ex.-
n-wmu wcrsr?*. VOL «s, MO. i« WTOKSSOAT, s»riM»st 27, i-m
-40-
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CHAPTER 3
SUMMARIES AND CONCLUSIONS : LEAD AGENCIES & EPA
3.1 Special State Activities for the Process
3.2 General Attitudes
3.3 Use of Available Time
3.4 Locus of Responsibility Within the States
3.5 Methodologies and Approaches
3.6 Consistency of Projections Within the States
3.7 State Reactions to the EPA Projections
3.8 Variance Requests
3,9 Communications Problems
3.10 Energy-Impact States
3.11 Timing of the Requirements
3.12 Vision
-41-
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3.1 SPECIAL STATE ACTIVITIES FOR THE PROCESS
Of the fifty states, approximately twenty have sufficiently
refined, consistent, and updated processes of preparing and
using projections that little new was needed to comply with
EPA requirements for the October 1 submission except possibly
for the public meeting:
Hawaii, for example, developed a complete set of projections
which were released in March, 1978. Those projections were
automatically used in water quality planning.
Arizona developed a complete set of projections which were
adopted in 1977. A state Executive Order requires these
projections, down to the association-of-governcients, or
regional, level, to be used in all state planning. All but
one of the designated 208 agencies had projections for their
areas no greater than the state-prepared ceilings. The one
whose projections exceeded the state disaggregation is now
revising its projection downward.
Maryland has preexisting projections prepared by their
"Department of Planning and used for county water and sewer
plans. They are submitting these figures, meeting the public
meeting requirement in the 208 hearings going on this summer.
The characteristics of states in this category seem to be:
1) having prepared population projections for the state
in the recent past or good enough to still be useful and
2) having prepared projections for substate regions which
were used in water quality planning or having a'lready compared
the state's own disaggregations with the projections of designated
208 agencies and begun to reconcile them.
For those states which have had to perform new tasks in
compliance with the EPA guidelines, the tasks included:
a) Preparing a state projection which did not already
exist or deciding to use the EPA projection. West Virginia,
for example, had no preexisting projection. They decided to
use EPA's projection for the state, prepared disaggregations
to the county level, and will hold a public meeting.
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b) Comparing a stace-produced number with the EPA pro-
jection and, in some cases, requesting a variance and preparing
the justification. Montana, for example, has a set of projections
prepared initially at the county level and summed to produce
a projection for the state. Montana's projection is much higher
than EPA's and they will be requesting a variance.
c) Comparing state-produced disaggregacions with the
projections prepared by designated 208 agencies. Mew York,
for example, has made such comparisons and indicated which
designated 208 agencies will receive variances and can use
their current projections in the interim, and which must
immediately uodify theirs. In future water quality planning,
designated 208 agencies will have to use the state's projections.
By comparison, California is using a preexisting state projection,
but not the associated disaggregation. Instead, the state will
prepare a disaggregation in such a way that, with the 10% variances
allowed for 208's, each designated area gets the projection
it wants.
d) Preparing a disaggregation <-.C whatever projection
for the state was available. For example, Alabama had a
preexisting disaggregation but decided to prepare another
because intrastate trends have changed. Perhaps seven to nine
states appear not to have had disaggregations for their
own state projection,
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3.2 GENERAL ATTITUDES
Some states found the process helpful:
It's a good idea to tie down projections. It simplified
things.
This is definitely needed in order to avoid ^ver- and
under-design.
The disaggregations make it easier to deal with population
and allow us to spend time on other issues.
Since 1966 we've required county water and sewer plans
that say where and when service will be.... I was happy
to see the EPA guidelines; it gives us more impetus.
Several states thought the process was an annoyance:
The whole thing is a lot of monkey business, an exercise
in futility, an annoyance.
I would like a more "flexible" system, although preserving
integrity and objectivity.
I'm sure we're not the only state that these guidelines
are going to cause trouble.
In some states the projections were sufficiently consistent
or noncontroversial as to have produced little interest on
the state's part in the guidelines.
The remainder seemed to regard it as another federal requirement
with which they were obliged and willing to comply.
Many states and especially many of those which seemed clearest
in their understanding of the regulations and most experienced
in dealing with projections expressed strong support for the
"cascading" structure of the guidelines. Some particularly were
pleased with EPA for having involved the states rather than
going directly to substate governments. One urged EPA to
continue to regard the states as the "first line of contact"
in resolving intrastate conflicts over projections.
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This result of our survey may perhaps be surprising, since there
may be an impression in some quarters that states are having
great difficulty with these guidelines. It is certainly
possible that the people with whom we spoke were not being
totally honest with us or were in fact not the ones with the
strong negative opinions. We regard this as unlikely, though,
given the frankness with which they answered many of our
questions and the fact that we spoke with many dozens of
people.
Two states which had opposed the general structure when the
draft guidelines were open for public cotoaent did not do so
in our conversations with them. It should be noted that
the state projections in both those cases were within 5% of
the EPA projection. We do not speculate on how those states
might have reacted had there been significant differences in
these numbers.
Mc-st of the problems mentioned with the guidelines were over
the BEA model, specific state projections, the process of
consultation with the states over those projections, the
timing of these requirements, and the amount of "flexibility"
available, or were based on misinterpretations of the
guidelines. These problems are discussed in later sections
of this report.
On the basis of our telephone discussions we suspect that as
states become clearer in understanding the guidelines and as
the relevant state agencies gain experience with projections,
this process will come to work well in most states, including
those which had trouble with it this time.
Appendix A contains a selection of supportive and critical
comments made fay state representatives on the entire process.
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3.3 USE Ot' AVAILABLE TIME
Among the states which had substantial work to accomplish
to meet EPA's deadline, there was great variation in the
utilization of the available time. At one extreme, there
are five states which admitted or implied to us that they
would not meet the deadline. There are five others that
we believe are likely not to meet it. And there are
additional states that will meet the deadline only if
their last-minute variance requests are approved and without
a public hearing. Some states will meet the deadline only
as a result of providing minimal notice of their public
meetings. Some of these states had hardly or just begun
the process when we spoke with them, even though it was
less than three months before the deadline.
Reasons for lateness typically include communications problems
with EPA, under staffing, too many other things to do, or
problems of jurisdiction within the state.
Other states, however, got off to early starts and used the
time available with great effectiveness. Florida held its
public meetings in January, revised its projections in
response to those meetings, and submitted its disaggregations
to EPA April 3. , Nevada submitted its variance request in
April. Ohio disaggregated the EPA total to the county level
and submitted these projections to designated agencies and
river basin advisory councils. All but two of the regional
councils submitted revisions that fell outside the allowed
range. The ensuing process of thorough local review to
achieve acceptable totals for most counties took nine months,
and the state is now negotiating disaggregations for facility
planning areas outside the designated areas. All this was
achieved before some other states had even prepared a work
plan for the process.
Since a draft of the guidelines was in the Federal Register
in early 1977 and since states saw EPA's projection for them
in early 1978, it is difficult to understand why some states
waited until summer 1979 to begin the work.
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3.4 LOCUS OF RESPONSIBILITY WITHIN THE STATES
All but seven states seem to have basically one agency
which prepares projections for the state, according to our
telephone interviews. We will be referring to these as
the "projections agencies'.' Of the seven states which do not,
six have no such agency and one has two of them, one of
which prepares projections for federal programs and the other
for instate use.
In the 43 states with projections agencies, the projections for
compliance with EPA. requirements were prepared by or through
that agency in 37 cases. In the six states remaining ( CA,
KA, ME, NJ, OR, WV), in which the projections agency was
not utilized in this process, the reasons were among the
following:
* The state projections agency does only trend projections
and its work does not represent the administration's policies
on the use of projections in state or federal programs.
* The state is using the process in order to implement a
state growth policy, a function not appropriate in that state
to the agency which prepares the projections.
* The projections agency was in the process of preparing
projections, but those would not be ready on time.
* The water quality people wanted to use the projections
prepared by designated 208 agencies rather than atate-prepared
projections.
In 7-8 states we had difficulty identifying a person who could
be said to be responsible for the state complying with EPA.
In four states where we eventually found such an individual,
it took us many calls to locate the person. In some cases where
we were able to locate the right person, other individuals in
those states who attempted to do so on their own had great
difficulty and sometimes never succeeded. See section 4.3,
Public Involvement.
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In several states, the person we identified as probably the
one responsible for implementing the guidelines knew little
or nothing about them. In some cases this might have been
because that person supervised someone who knew the process
well; however in other cases there appeared to be no one in
the state who was well acquainted with what the guidelines said.
Several states themselves identified problems with implementing
the guidelines as related to the lack of clarity within state
government over who was responsible. In those states where
the projections agency had refused to participate, an environ-
mental agency sometimes was left holding the ball despite its
feeling it did not have the expertise to do a good job. In
one state three agencies already had projections; one of the
two didn't want the responsibility in this case but the other
two both did. In one state, as of the date of our contact
the Governor had not yet designated a lead agency.
Several states commented that the agency signing the work
agreement with EPA was not the agency with responsibility for
producing the projections. It was therefore difficult to
hold the latter to requirements or deadlines. Furthermore,
since the projections agency is not usually the one which
deals with EPA, there are not good working relationships,
messages can get garbled, and the point of the guidelines can
easily be missed.
In one state an Executive Order prohibits state agencies
from using any projections but those currently being prepared
by a particular agency, but allow others to use preexisting
projections in the interim. The agency trying to comply with
EPA does not know to what degree it can amend its existing
basin plan projections.
Despite all this, all the states appear to be producing some
set of projections and disaggregations for EPA. But the
confusion in some has the effect of slowing down the process,
making it probably less useful to the state, and making public
involvement all but impossible.
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3.5 METHODOLOGIES AND APPROACHES
Methodologies used by states to prepare their projections
and disaggregations varied widely.
Although most states prepare state projections first, quite
a few prepare projections for substate areas, typically counties
or multicounty economic regions,and then sum those projections
to produce a state projection. Examples of these include:
Utah, Montana, Nevada, New York, South Dakota, and Wyoming.
The methodologies used range from pure demographic projections,
pure econometric ones, with some states using combined
methodologies (see Glossary, Appendix C, for definitions).
Disaggregations include those techniques as well as a variety
of trend and ratio methods.
Although in some cases it was not clear to us what sorts of
methodologies were used at the state level, it seems that
the following states are examples of ones which use certain
techniques to produce state projections:
pure demographic:
pure economic:
combined:
California, Maryland, Massachusetts,
New Hampshire, South Carolina, Vermont,
and others
Colorado
Arizona, Connecticut, Hawaii.
Similarly, states prepared the disaggregations using
different techniques, as mentioned a'bove, and using different
philosophies. They ranged from pure "trend" or "baseline"
projections to more or less inclusion of policy considerations.
See further in this section for definitions. New Jersey's
disaggregations, for example, are prepared as a reflection of
clearly articulated growth policy goals within the state (see
Appendix B).
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Of the states whose disaggragations were "baseline", some
used elaborate demographic or econometric models, while others
did not. One state, for example, comy/ored with 1970 census
results with the 1977 estimates and simply extrapolated the
growth trends from that period. When asked if they really
expected the areas to grow at the same rate for the rest of
the century, the state replied that that's the best they
have.
One state commented that since "there are no well-documented
disaggregation methodologies except for land-based ones
which are complex and require massive data,... we fall back on
a quasi-technical and quasi-political process, which may be
OK but which many planners don't like because it doesn't
produce a pure projection."
We believe that two states are likely to present EPA with
projections which include mere arithmetic manipulation of the
numbers, reflecting neither technical rationales nor state
growth policies.
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"Trend" and "Policy" Projections
Although in some cases these two sorts of approaches to
a projection cannot be precisely distinguished, we use the
terms in the following ways: A projection which relies only
on past or current trends in job creation, migration, fertility,
land use, etc. or includes only future events out of the control
of public policy (or decisions already made) is a "trend"
or "baseline" projection. A baseline projection is sometines
also defined as "a projection based on a defined set of
economic and/or demographic assumptions and which attempt to
capture and reflect the essence of historical growth patterns.
They do not attempt to take into account changes in intervention
strategies by any level of government or by the private sector."
This perhaps does not clear up the definition, since we are
not here defining"intervention strategy"!
We are using "policy" projection to refer to situations
where a state government has articulated goals for the amount
or distribution of growth in the state. In some cases these
involve protection of agricultural land, prevention of sprawl,
revitalization of cities, or others. These policies may be
being implemented in other state programs or the state may be
using the EPA process, and its effect on directing federal
money within the state, as a_ or the tool to implement the
state's goals.
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States whose projections reflect policies
Hawaii has an ongoing State Commission on Population and Hawaii's
Future, composed of seven public members, a representative of
state government, and one from the U.S. Department of Defense.
The Commission is very involved in the development of the
projections, and the latter reflect a number of growth policy
considerations involving distribution of population among the
islands and the overall economic assumptions used in preparing
the state projection.
Conneccicut's upcoming set of projections will reflect a State
Plan of Conservation and Development approved by the legislature.
New Jersey's projections are being specifically designed to
reflect certain goals of the administration: preservation and
enhancement of existing urban areas, substantial reduction in
growth in currently undeveloped areas, and maintenance of moderate
rates of growth in suburbs. These projections will be presented
to 208 advisory committees and others for their response.
California's projections reflect the administration's commitment
to an urban strategy, one of whore components is having state
agencies use projections which have been prepared by councils
of government.
Massachusetts' projections were initially developed by a
state agency but were the subject of extensive discussions
throughout the state as part of the Massachusetts Growth Policy
Report. Local Growth Policy Committees existed in 330 of the
state's 351 communities and meetings and discussions were held
over a 20 month period. The question of how and where
Massachusetts' communities should change was widely debated and
projections were adjusted to form a mutually consistent and
acceptable set which will now be used in all state and local
planning.
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3.6 CONSISTENCY OF PROJECTIONS WITHIN THE STATES
At least sixteen and possibly as nany as twenty-six states
already have a formal or informal policy of consistency
among the projections used by state agencies - although in
a few cases this is not strictly enforced. Almost half the states
are already planning to use the disaggregations prepared
for EPA for other purposes.
Two states, however, specifically do not want these numbers
used by other state agencies. In one case it was because
of disagreement with the population estimate on which
the projection was based, leading to inconparability of
the projections with others used in the state (see section
3.7). In the other case it was because of differences between
the EPA projection and the state's CXTU, without any problem
with the estimate. A third state expressed reservations
about further use of the disaggregations produced for EPA
because of the "crudeness of their methodology."
Many of the states commented that their efforts to develop
intra-state consistency are hampered by the varying require-
ments of federal programs. One state referred to state
agencies dealing with the Dept. of Commerce; Dept. of Labor;
Health, Education & Welfare; and EPA, whose needs and
requirements differ, while other states mentioned HUD programs
and DPT. These states were supportive of federal efforts to
develop consistent requirements since that would serve state
needs as well.
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In some states, though, problems within the state hamper the
development of such consistency. Some are discussed in other
sections of this report (see, for example, section 3.4). In
one state, all planning is done with the same statewide popu-
lation projections, but different programs use different
disaggregations. In another state, one agency prepares county-
level "trend" projections while several others use the regional
planning agency projections because the latter are tied into
air quality and water quality planning and reflect more closely
local land use constraints and decisions. One state has four
sets of operating projections: two for HUD programs, one done
by a consultant for health planning, and an environmental
set. Only the latter, according to our state contact, has had
strong local input.
Two states complained that consultants and/or municipalities
"can't be forced to use the same projections," despite the
state being the source of the program's money. In one of
those cases, the state had attempted to ensure that the
consultant work regularly with the regional planning body;
however that proved impossible to enforce and is now causing
substantial problems. Despite these states' experience,
others have no similar problems ensuring the use of state-
produced projections by substate governments.
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3.7 STATE REACTIONS TO THE EPA PROJECTIONS
By far the most comments from the states on ways to improve
the implementation of the EPA guidelines were on the EPA
state projections. Several states claimed to have not heard
anything about the model or the purpose until they received
the EPA projections "in the mail;" we did not check whether
they meant the original set sent out in early 1977 for their
review or the final set.
The states want more involvement in the process of developing
the assumptions used in preparing the projections. There
were many complaints about BEA's data base and assumptions
being not detailed enough, outdated, or too general. Some
states claimed to have no idea what methods BEA had used to
produce the projections for EPA.
Roughly 25% of the states had either questions about or
disagreements with the BEA model, the final numbers, or the
process of consultation with the states.
Respite these disagreements, virtually none of the states expressed
objection to EPA's having prepared a set of state proiections.
l-7e must admit, however, that we did not ask a direct question
on this subject. Nevertheless the states were being quite
frank with us in general and one might suppose that if they
felt strongly about this issue they would have mentioned it.
We guess that the situation would have been very different
had the 5% "automatic" variance and the procedure for requesting
even greater variances not been available.
Sample comments of state representatives follow:
Communication
Several states complained that communication with BEA about
their model is very difficult or impossible. "To talk with
BEA you need to know the details of their model and that's
almost impossible." BEA is far away and it's "not easy to
complain to them." Furthermore, since "there is no formal
mechanism for EPA and the state to discuss the projections"
of BEA, the state has no effective way to consider or challenge
the BEA methodology.
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BEA's Model
Some states use or prefer demographic to econometric models
(see Glossary). Since BEA used the latter, it was difficult
for those states to compare their own projections with EPA's
and evaluate the differences.
One state did not like any federal agency coming up with
numbers for the states at all, but added that EPA is "taking
the heat" only because they instituted this process first.
(It should be noted here that we did not find as much heat
as several states thought we would)
"BEA didn't take into account energy development: uranium,
coal, oil, and gas."
One state complained that several of BEA's assumptions are
unrealistic in general and particularly bad for that state:
* 4^ unemployment
* no cyclic fluctuations in the economy
* people moving primarily in response to jobs and income,
rather than "quality of life" considerations."
Trend Projections
Two states in the northeast objected to EPA having used
"current trends" in preparing projections for the states.
This, they said, was inconsistent with the President's Urban
Policy, particularly if funding is in any way tied to the
numbers. They felt that federal policies should be used to
prepare projections, giving more weight to already-developed
communities in the northeast.
Estimates
3 states disagreed with the estimates of past and present
population used by BEA as inputs for projecting as being
incompatible with the state's own assumptions and with those
used in other programs. One mentioned specifically BEA's
state-by-state allocation of the 1970 census undercount;
this factor is not accounted for in the state's own projections
nor, they said, in Bureau of the Census estimates. As a
result, one state commented, EPA ensured that the projections
developed in compliance with EPA requirements will not be
used for any other purposes within the state.
'Another state mentioned that the BEA estimates and projections
do not include the military population or ship's crews, while
the state's own do. However in this case the state's projections
is still less than BEA's; since the state uses its own fore-
casts in planning, it really doesn't matter.
A third state mentioned that the undercount of illegal aliens
is significant in that state and needs to be dealt with.
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3.8 VARIANCE REQUESTS
Although a few states had great disagreements with the EPA
projections for their area, from a nationwide perspective
there was general satisfaction with those projections.
According to our telephone interviews, we believe that
three states requested variances of more than 5% by August 15:
Colorado, Indiana, and Nevada. We believe that possibly six
to eleven additional states are likely to make such requests
by October 1. These include Montana, Utah, Wyoming, Washington,
New Mexico, and Oklahoma, as well as others who have not yet
decided what they will do.
The largest percentage increase we expect to be submitted
will be approximately 35% (Utah), with the largest numerical
increase possibly being almost a million and a half from one
eastern state.
Although controversy over the state numbers is restricted to
a relatively small number of states, the differences can
imply major and potentially serious impacts within those
states.
Several states were unclear about what kind of supporting
information EPA would want to accompany a request for a
variance.
Four states definitely are planning to use the provision
o- the guidelines allowing up to 107' variances e.o~ desr'-^ru-.ter1.
208 agencies with preexisting projections: California,
Colorado, Georgia, and New York. Approximately half the
states have decided not to take advantage of that provision;
this includes several states in which designated agencies
have projections larger than those which the state has or
will produce. The remainder of the states either have not
yet compared their numbers with the 208's projections, have
not yet prepared their own disaggregations, or did not
indicate to us what they intended to do.
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3.9 COMMUNICATIONS PROBLEMS
Many states evidence substantial confusion over what was
required of them, even on questions clearly dealt with
in the guidelines. This may have been because they did
not read the guidelines carefully enough (or, in some cases,
at all), because the guidelines were perhaps too tersely
written, or because of insufficient or confusing communi-
cations with EPA staff.
We point out the following to identify the typical problems:
A. Some states were unaware that anything needed to be done
at all. In some cases these were states whose projections
processes were sufficiently consistent and complete that
little, in fact, needed to be done. In others, the states
needed to hold a public meeting or sometimes undertake
substantial amounts of work. One state observed that it
relies on ZPA to highlight for it what needs to be done;
that they do not have sufficient staff to pore through
new regulations.
B. There was much confusion over what needs to be submitted
to EPA by October 1, although the guidelines are clear on
this point. Several states, believing that projections
were needed doxra to the facility planning level by October,
mistakenly thought' they would be "unable to satisfy EPA's
requirements.
C. Several states mistakenly believed that the 10% variances
available to designated 208 areas must fit within the
original state total,
D. Some states mistakenly thought that the EPA process is
connected with the upcoming OMB/Commerce proposals
(see cover letter, and sections 4.4, Appendix A.5, and
elsewhere), and one state delayed its disaggregations
waiting for word about the OMB/Commerce process.
E. Some states did not know that a public meeting was
required. This was true not only in states where a
"projections" agency was carrying out the requirements
but also in a few cases where an "environmental" agency
was in charge.
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3.10 ENERGY-HIPACT STATES
Much of Che dissatisfaction with the EPA process, and with
the EPA stats, projections in particular, came from energy-
impact states: Alaska, Colorado, Utah, Wyoming, Montana,
New Mexico. Wyoming, for example, updates its projections
every six months and was concerned that if frequent revisions
to the projections used by EPA are not permitted, planning
will be done and facilities sized based on patently outdated
projections.
States with "boom towns" were particularly concerned that
"locking" a town into a previously-prepared county projection
is not productive.
Furthermore, states appear to be using different philosophies
in determining what energy-related facilities should be
assumed in preparing the projections, even under a "baseline"
or "trend" series. One claims not to include any project
unless it is under construction or the environmental impact
statement has been approved. Another may perhaps be including
all projects proposed in the President's energy message ,
regardless of the likelihood of their being carried out.
One state expressed frustration with having to prepare and
submit only one projection, since they believe the state
population in the future will to a great extent be determined
by national decisions which have not yet been made. That
state suggested that states be allowed to submit an "alternative"
projection which would come into use if a particular scenario
does materialize. The concerns expressed in this suggestion
might, in our opinion, be easily alleviated if appropriate
arrangements are made for quick revision of a state's pro-
jection should conditions change quickly.
In quite a few cases we asked for ideas on how EPA might
best deal with the problem of energy-impact states or towns.
Ideas included allowing frequent revisions of the state's package
of projections, allowing updates of projections for a particular
substate region if that area has grown more than a pre-
established amount, having a certain "pool" of population which
is not allocated to any state which would then be available to
energy-impact areas if needed.
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3.11 TIMING OF THE REQUIREMENTS
Many states expressed concern about the timing of the
requirement for the disaggregations in relation to the
timing of other processes in which states are also involved.
Some of the problems relate to timetables imposed by federal
.requirements while others involve internal state timetables.
Other Federal Requirements
How do these guidelines affect projections used in 208 plans
already submitted and approved? New York has explicitly
discussed with designated 208 agencies which projections must
be updated and under what timetables. However we do not
know if other states, in which plans of 208 agencies must be
revised, have thought this through clearly.
What is the relationship with HUD "701" plans? Under an
interagency agreement between EPA and Che Dept. of Housing &
Urban Development, projections used in the latter's "701" plans
must be the same as those used in EPA's 208 plans. Who
follows whose lead?
How will the process be affected by the release of a new set
of BEA projections in 1979? by proposals of OMB/Commerce?
See 2.2A, I, and J.
State Timetables
In some states, an update of the state's own projections is
almost, but not quite, ready. Those states, which include
Mains and Connecticut do not believe that what they submit by
October 1 will be very useful and some expect to resubrait disaggre-
gations soon thereafter. However there is no way that c.ny
fixed timetable for submitting projections would satisfy all the
states, Illinois, Indiana, and Kansas are also about to
release updated projections.
Other states, particularly those growing very rapidly, were
concerned about the June 1978 date mentioned in the guidelines
as the date by which a set of projections must have been in
existence in order for it to be submitted to EPA without a
variance request. They, as well as several other states,
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believe they are growing very rapidly - generally in response
Co decisions made by the federal governmenc - and chaC special
consideration should be given to frequenc updaces or
perhaps even interim adjustments in projections for parts
of the state (see section 3.10).
Some states had prepared their projections before the guidelines
were issued, either for their own use or in specific response
to Clean Water Act requirements, but did not prepare disaggre-
gations to the now required geographical detail.
Approximately seven states mentioned their lack of enthusiasm
about preparing projections when the 1980 census is almost
here.
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3.12 VISION
Although most states will have complied with the letter of
the guidelines, in only a few states were the individuals
responsible aware of or planning to use the opportunities
made available by the guidelines (see section 3.5).
These opportunities include:
* using the process to further the state's own goal
of consistency among projections used by state agencies
* trying to develop consistency among the projections
used for federal programs
* articulating a growth policy via the projections
* conducting productive negotiations with substate
governments which might otherwise not have taken place.
It is our belief that a state seeing the guidelines as
something other than a-dull federal requirement was, in
part, dependent on prior experience in the agency or state
with making or using projections, one individual with a
particular interest in the "philosophy" of the use of
projections, or prior state formulation of or interest in
growth management or growth policy.
A major hurdle was that, as many states mentioned spontaneously,
they thought of this as simply another regulation and "don't
really understand what EPA wants" or what problems EPA was
trying to solve in promulgating the guidelines.
Quite a few states already have or are working towards a
policy of consistent projections among all state agencies
(see section 3.6); in most of those, the states attempted
to use the opportunity of complying with EPA to foster that
policy. Some of them mentioned that this was not always
easy because of the conflicting requirements of other federal
or state agencies.
We are not trying to imply that had the option of not simply
preparing "trend" projections been mentioned to the states,
that large numbers would have taken advantage of it. In
some states the question of growth policy is too controversial;
in others it is being debated but no policies have been
developed. One state volunteered that even had they
realized the projections need not be "baseline" projections,
they would have prepared such anyway "because that's what
we've had experience with."
Although most states did not seem to realize it, it is
a political choice to use "trend" projections. It was the
lack of such awareness that, in our opinion, caused the
poor attention to public involvement by most states (see
section 4.3).
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CHAPTER 4
SUMMARIES AND CONCLUSIONS: INVOLVEMENT WITHIN THE STATE
4.1 Coordination Among Scats Agencies
4.2 Involvement of Substate Governments
4.3 Public Involvement
4.4 What Remains to be Done
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4.1 COORDINATION AMONG STATE AGENCIES
The present EPA process appears at first glancs to involve
only water-quality planning, but it has important ramifications
well beyond water. Therefore it is vital to its success that
a variety of the branches of state government be involved.
First of all, in many states water quality functions are
divided among more than one agency. In some states the3e
were all involved, but in others one agency would handle
the process and the other would continue in blissful ignorance.
In some extreme cases the 208 office would be handling
disaggregations and the 201, or construction grants, office
within the same agency wouldn't know about it.
Second, the process is in actuality as much tied to air quality
as to water quality. The guidelines specifically mention
required consultation with agencies doing air quality planning.
Furthermore, future revisions of state implementation plans
for meeting the Clean Air Act requirements must use the same
projections as those used in the 208 plans.
In our telephone interviews we did not specifically ask about
air agency contacts, but from the fact that only three or four
states volunteered any mention of such contacts, we must con-
clude that they were not high in the consciousness of those
implementing this process. Such consultations (or lack there-
of, may not even be meeting the letter of the guidelines).
Furthermore, we do not know to what extent state air quality
agencies (as opposed to the substate ones mentioned in the
guidelines) were involved. In many cases these agencies were
in the same department as the one handling water quality;
however, as we found was the case among water people, mere
co-presence within a department does not ensure communication.
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A third interagsncy ramification of this process is that
it is intrinsically related to land use and tharefore relates
to the work of whatever land use or planning agencies a
state has. This kind of contact was frequently realized
because in many of the states the initial disaggregations
were prepared by a state planning agency which then gave
them to the water agency, which often modified them and
handled public and local government participation.
Unfortunately, however, it is not clear that the "planning"
people were always informed of the accual impacts of use
of the projections; often they seemed to be simple technicians
preparing numbers. For other interagency problems, see
section 3.6.
The reader may have noticed a certain pessimism on our
part regarding effectiveness of coordination among state
agencies. But we must note that there were six states which
gave indications of efforts to achieve this. For example:
* Quite a number of other state agencies attended
Florida's Tallahassee projections meeting, including the
Division of Forestry, Dept. of Transportation, Dept. of
Health Planning & Development, and the Dept. of State Planning.
* The state projections in Delaware ara prepared by
the Population Consortium, which includes representation from
the Dept. of Transportation; Office of Management, Budget,
and Planning; Dept. of Development and Housing; and the
Dept. of Health and Social Services.
* California has an interagency group on population
projections which has met occasionally over the past few
years and more recently has discussed California's compliance
with the EPA guidelines. The air quality and water quality
agencies have both been particularly involved.
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4.2 INVOLVEMENT OF SUBSTATE GOVERNMENTS
In producing population disaggregations there is no substitute
for interactions among the various levels of government. The
federal government has to deal with states who have to deal
with counties and COG's and 208's, who have to deal with
municipalities.
"It's a negotiating process. You don't jam a population
figure down a throat."
This kind of negotiation is necessary to get accurate base
data or desirable trends; it is also needed to get the
adherence of local governments to the projections once produced.
Fortunately, this kind of intergovernmental contact is also
highly desirable for reasons that go far beyond projections.
It is the keystone to effective regional planning of all
kinds, and to effective implementation of almost any state
program.
So we see it as a bonus that states with effective projections
mechanisms in the course of them achieved considerable contact
with different layers of government.
Ohio was exceptional in its efforts in this direction:
"We're kind of proud of what we've done. Local communities
realized that this will determine the size of their
facilities and so they took it seriously.... We submitted
(our county projections) to designated agencies and advisory
councils for each river basin. We let the regional councils
revise them as long as they maintained a regional control
total. All but two of them fell outside the allowed
range, so we forced them to revise downward.
The Dayton metro area requested a 200,000 decrease. They
documented it well, so we granted it.... If a city or
county could document for us a change from our projection;
we accepted it.
This process took us nine months, but we agreed on county
totals except for three or four counties which we're still
working on. We had very thorough local review and local
input. I travelled all over the state.
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(Ohio, continued)
We've held public hearings on the county level and
small area projections: fourteen hearings in July and
August. Then we'll go back and work one by one with
the communities that don't like their projections....
When we make a change, we go back to the local advisory
committee to get their approval again since it involves
changes for the whole region."
It's time consuming, especially of staff time, but it's
worth it. People may not like what we come up with,
but they are generally agreed to accept it until the
1980 census.
Texas is another state that seems to have achieved considerable
cooperation and interaction between the state and local
governments:
"It was good that the federal government left intrastate
disaggregacions to the state, and the state left this
to smaller units. Noone felt anybody was forcing anything
on anyone. Each county did their own disaggregation, and
with one exception they've all been reconciled.
"There's been discussion, but not much controversy. There
weren't many discrepancies because the local areas had
been working with the governor's office for years on
projections. There were discrepancies in a few local
areas, but there were handled within the counties."
Maryland is a state with considerable experience in projections
and it wants to move towards more interaction:
"In the future we anticipate a more open and cooperative
method for all planning areas an advisory group of
state agencies and counties, lots of chance for local
input."
Unfortunately, not all states were equally successful in
achieving local involvement. Some states told us:
"'No local government involvement until now."
"Local governments have been involved only by having
received the notice. They won't be involved much until
the facilities planning process (201)."
"I used to consult with local governments and the public
but their information usually isn't good. I don't do
that any more. I do better projections by myself."
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Further, many states reported individual procedures which
were especially effective in generating local involvement.
Since these were by and large the same procedures used to
general public participation, we refer the reader to
section 4.3.
A frequently mentioned problem in many states was the one
or two designated areas that requested exhorbitant pro-
jections. It is difficult for us to find any overall pattern
in how these were handled, i.e. in what cases the state
changed its projections or granted a variance and in what
cases the designated 208 agency is revising its. But,
in most cases, these problems led to serious discussion
between the state and that agency. And since these were
parts of the state where growth is a particularly significant
issue, we regard it as useful in itself that this process
has led to discussions between levels of government.
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4.3 PUBLIC INVOLVEMENT
In this section we discuss involvement of the non-governmental
public in preparing, considering, or evaluating the projections
used for the EPA requirements. It was disappointing to us
that,in many states, our questions about public involvement
were answered exclusively by reference to the involvement
of local governments and it was sometimes difficult for us
to make clear that we were particularly interested in the
direct involvement of the non-governmental public.
It is hard to give an overall assessment of public
involvement throughout the country. In some cases, there
were pre-existing projections which were used widely throughout
the state. Some of the projections in these states incorporated
clearly articulated policy goals (see section 3.5). ''any
were pure "trend" or "baseline" projections (see definitions
in seccion 3.5); of those, some were prepared with the
involvement of advisory committees that included university
representatives (Arizona, for example) or business representatives
(Delaware, for example), 'jthers were prepared purely by
technical professionals.
Some of these states, which in most cases had little to do
to conrolv with the t»iHH«»l;J.r>es, are now scheduling public
meetings as the guidelines require (examples: Illinois, Michigan,Minnesota)
Others believe they have already satisfied those requirements
either through public involvement in the projections process
or as a result of hearings on the 208 plans
Most states which prepared projections for the 208 program
reported having included consideration of those projections
in the 208 hearings. In some of those, projections were
singled out as a separate item of discussion - but no state
in this category could recall any of the discussion. In others,
projections were among the subjects on which public comments
could have been made, but generally were not.
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Some states claimed to have discussed projections with their
208 advisory committees. In at least one state, though,
the topic never caine up.
One projections agency described its work as "intentionally
a bit ivory-towerish. Environmentalists are not involved."
In some states citizens were actively involved in debates
over population projections at the designated 208 level -
e:oimples are the Atlanta Regional Commission, Southeast
Michigan Council of Governments, Association of (San Francisco)
Bay Area Governments. However our telephone survey was of
state governments and we did not ask about involvement at
this level.
We believe it is fair to say that except for a handful of
states in which the projections are reflective of or used
as growth prdicy, or those states in which all the decisions
were made at the designated 208 level, there has been
virtually no involvement of the non-governmental public in
the process of deciding how projections should be prepared
or considering the process as it developed.
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Inadequacies
In quite a. few cases, scate staff with whom we spoke were
unaware of the requirement for a public meeting before the
disaggregations are submitted to EPA. To be fair, in some
cases we were speaking with staff of the "projections agency','
who defer to the environmental agency on such matters. On
the other hand, it is quite likely that in some of those
cases the environmental "person" regarded their responsibilities
as being simply to forward the projections to EPA. Further-
more, in a few cases even the latter individuals admitted
to not knowing about the requirement for a public meeting.
In some states we believe the state meetings will be
virtually a farce for a. number of possible reasons:
* The state is giving insufficient notice or not
announcing the meeting widely enough.
* Even after the state has given notice of a request
for a variance, no information will be available for citizens
to look at until a few days before the meeting itself.
* The meeting (in fact the entire process) is scheduled
so closely before the deadline that the chance of public
involvement making a difference, is virtually nil. But Florida
shows how a state, by starting early, can stimulate considerable
statewide involvement.
* The state does not want public involvement, sees it
as a nuisance which cannot contribute to their work.
One state in fact described its own public meetings as
"being done almost as an afterthought, without serious interest
in getting public involvement." Another state official said
he used to work with local governments and the public but
doesn't do that any more because he can produce better
projections than they can.
Furthermore, not only did some states hold these beliefs,
but they expressed them to a.caller from the Sierra Club, whom
they might have presumed would have a great commitment to
public participation.
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Analysis
It is our belief Chat there are several reasons why state
officials have not seen much value in public involvement:
* They are preparing "trend" projections and see the
public as not being able to provide useful data about what
is happening or professional reflection on the technical
methods they are using. These states do not acknowledge
that choosing to use "trend" projections is in. itself a
political decision, nor that there are different views on
what is a "trend."
* They have seen no public interest and cannot believe
there would be any. However even in some states where citizens
have tried to become involved, they have in several cases been
unable to find out what the state was doing. See, for example,
the individual state reports for Mew Jersey and Pennsylvania.
When we ourselves called Delaware, we were explicitly and
incorrectly told by one official that no one in the state
was working on the process, and we suspect that a caller less
persistent than ourselves would probably never have located
a more knowledgeable official. Furthermore, citizens are
not likely to become involved in something which is presented
as a purely technical phenomenon that supposedly neither
influences nor can be influenced by public policy decisions.
* The state may be negative about the EPA process as a
whole and wants to devote as little energy to it as possible.
* The state regards discussions in the context of 208
plans as sufficient. However in too many cases the public
(as well as state officials themselves) has a mistaken notion
of the "accuracy" or non-controversial nature, supposedly,
of population projections. There would therefore in many
cases be no reason for a 208 advisory committee or others to
spontaneously pay attention to the choices made in producing
projections.
* Although the state's water quality agency is familiar
with and perhaps even sympathetic to public involvement, the
projections are prepared by a "projections agency" which has
no familiarity with how or why to involve the non-governmental
public, may in fact be actively hostile to anything but
professionally prepared "trend" projections, and regards its
task as simply to produce good sets of numbers.
All these reasons are self-reinforcing, for a state which
has failed until now to involve the public is unlikely even
to jsee signs of public interest which might encourage further
such efforts on the state's part. As in so many other domains,
the nurturance of public involvement with projections requires
careful attention from the state over the years through many
rounds of updates.
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Successful Activities Towards Public Involvement
Despite the preceding fairly bleak account of public
involvement throughout the country, quite a number of the
states did engage in activities which we believe are appropriate
for stimulating participation. We believe that if such
activities are incorporated into projections procedures
through the years, they will encourage the development of a
public following which will be able in the future to make
significant contributions. And an additional and immediate
benefit is that most of these activities have been highly
successful in generating the involvement of local government:
* Massachusetts had an extensive growth policy process.
* Florida held seven meetings around the state solely on
population.
* New York will publish a detailed handbook on projections
for local contractors.
* New Jersey is using the process as a forum for articulating
growth policy, one which will then will be widely discussed.
* Arizona has university planners and demographers on its
technical advisory committee.
* Hawaii has an ongoing Commission on Population and
Hawaii's Future.
* Ohio spent nine months negotiating over the county
level projections, has held fourteen public meetings, and is
now negotiating over projections for facilities planning areas.
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4.4 WHAT REMAINS TO 3E DONE
Although many states will have completed the process of
submitting projections by the October 1 deadline, others will
not. These latter states will still be making decisions on
how to submit their projections.
Many important opportunities for public involvement still
remain:
* When variance requests are submitted, the EPA Regional
Administrator is required to solicit public comment and, if
there is controversy, hold a public hearing. Since quite a
few states are submitting last-minute requests for such
variances, chere is still a chance for public review of the
request and for a hearing to be requested.
* Because public hearings require a 45 day notice, reducible
to no less than 30 days, those states in which hearings will be
held still have time for public participation in that hearing.
* If the variance requests are rejected, in whole or in
part, states will have to prepare new projections.
* Several states seem to be violating even the letter of
the guidelines on the requirement for a public meeting, and EPA
might ask them to go back and hold one or otherwise improve
public participation.
* The Office of Management & Budget and Dept. of Commerce
are scheduled to propose a similar system for all federal
programs which use projections in their funding r'oraulas. These
proposals are scheduled to appear in the Federal Register this
fall, with several months for public comment and public hearings
around the country. The Sierra Club's newsletter, Population
Report, which is available free on request, will keep readers
up to date on these proposals.
* Several states indicated they will resubmit projections
in the near future, when their state updates are available.
These include Connecticut, Kansas, and Maine.
* All states will have continuing updates of their clean
water and clean air plans, and projections for these will be
periodically updated.
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* Many scales have not yet prepared the projections
to the facility planning level, which will soon be required
for areas submitting step 1 grant applications. These
projections need considerable local involvement.
* EPA is developing regulations to tie together in a
consistent way the projections used in clean air planning
and the impact of the construction of sewage treatment facilities,
Public involvement is needed in commenting on the proposals
for this effort, which is iiiplementation of Section 316 of
the Clean Air Act, and in implementation at the local level.
* Many states are involved in trying to establish
statewide consistency in their use of projections.
* Many states have regular projections processes, and
these involve more or less frequent revisions of projections
for the state and substate levels.
-------
CHAPTER 3
RECOMMENDATIONS
5.1 State Activities to Involve the Public
5.2 Public Meetings on Projections
5.3 Communications Between EPA and the States
5.4 Written Guidance for the States
5,5 States Which Have Had Difficulties
5.6 Involvement of Other State Agencies
5.7 Revisions of the Projections and Integration '-rich Other
Federal Requirements
5.8 Earlier Deadline for Variance Requests
5.9 Urban Areas With Decreasing Populations or Low Growth Rates
5.10 Proposed Federal-Wide Process
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5.1 STATE ACTIVITIES TO INVOLVE THE PUBLIC
(see Chapter 4)
Unfortunately, it is not easy to spark overnight interest
in a subject like population projections that has long been
relegated to the private chambers of state demographers
and water quality planners. Whether or not they have done
so in the past, all states will now be required to prepare
regular updates of their projections, and the task of en-
couraging public involvement must be seen as a year to year
process to be built up gradually, not as something to be
attempted once and abandoned if not greeted with immediate
and spectacular outpourings.
Federal agencies overseeing state projections processes must
give careful attention to formulating guidelines for insuring
state processes that genuinely attempt to involve the public,
aid are not pro forma displays.
These guidelines might include itenizations of procedures
for states to follow, but they should also contain the
flexibility co encourage state experimentation. In Section
4.3, Public Involvement, we listed some of the innovative
procedures used by various states to involve the public.
It might be noted that most of these procedures are also
highly effective in involving local governments and, in some
cases (e.g. Florida), state agencies that are not otherwise
involved.
We offer the following recommendations to states to facilitate
public involvement:
A. Written Materials on the State's Projections Effort
It would be extremely useful to the public, local government, and
others for states to produce a brochure on the results of the
state's projections work, describing not only the numbers and
the methodology, but also:
* wh° was involved in developing the assumptions
* how local governments and the public participated
* whether any state policies were included
* which federal or state agencies will be using the projections
and for what purposes.
The handbook being prepared by Mew York state is a beginning along
these lines.
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B. Briefing of 208 Advisory Committees
Many states have statewide and/or regional citizens advisory
committees for their water quality programs. In at least one
case we know that such a committee never discussed projections,
and we suspect the situation to be widespread. We urge states to
specifically inform these committees about projections. This
is important even in states that have essentially completed
the projections process, because these committees need to under-
stand the role of projections in order to help integrate them
into the overall continuing planning process for clean water.
C. Regularly Involving the Public in Projections
We recommend that states regularly involve the public - the non-
governmental public in particular - in their ongoing work of
developing and using population projections, whether tied to
an environmental planning program or not.
In section 5.10 below we recommend that states establish
formal advisory committees specifically on the issue of population
projections, with mandatory membership of a certain number of
non-governmental individuals with varied backgrounds and interests.
D. Involvement of "Population People" in Environmental Planning
State agencies managing federal or state environmental planning
programs should establish contacts with demographers, population
organizations such as Zero Population Growth, and other individuals
and groups who might be particularly interested in population.
This is especially important in states where projections are
prepared by water agencies who might otherwise lack demographic
expertise and knowledge of who in the state is interested in
population per se. These people and organizations might be
added to mailing lists on projections-related issues but also,
being few in number in some states, where appropriate might be
contacted personally as well.
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E. Consideration of the Impact of the Projections
Statewide discussion should be fostered of the impact of
the projections used. As cr.e state official commented, people
understand what the projections mean only as they consider
the impact of the numbers and distribution on water quality,
housing, land use, open space, jobs, air quality, etc.
It is no wonder that much of the public is not interested
in projections abstractly: divorced from considerations of
impact, the numbers are much more difficult to grasp.
One state official commented to us that his agency was
obligated to prepare the projections, but that he hoped some
other state agency would consider the impacts, some of which
he thought were adverse.
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5.2 PUBLIC MEETINGS ON PROJECTIONS
(see section 4,3)
In many states, the public meetings on the disaggregations
were combined with meetings on the water quality plans.
Although this has the benefit of focusing attention on the
impacts of growth rather than on the numbers themselves, in
most cases the projections were never the subject of
comment.
EPA should suggest to the states that, when holding meetings
on a number of subject, population projections be specifically
given a special place on the agency and their importance
highlighted for those attending.
Furthermore, EPA should strictly enforce the following:
* holding of a meeting when required
* adequate public notice
* calculating the time of issuance of public notice only
from the date materials are available to be reviewed
by public, not merely when a notice is published
* scheduling meetings in accessible locations at times
during which the public can attend without difficulty
* scheduling meetings sufficiently before submissions
deadlines to allow public concerns to be evaluated
and incorporated into the state's proposals.
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5.3 COMMUNICATIONS BETWEEN EPA AND THE STATES
(see sections 3.3 & 3.9)
Various problems of communication between EPA and the
states were common, and described in detail in sections 3.3
and 3.9. EPA should be careful to highlight those portions
of regulations which require something new of the states,
particularly (as in this case) when a process is likely to
involve extentive negotiations with substate agencies.
Such discussions should occur well before any deadlines in
order to make it possible for states to finish on time.
5.* WRITTEN GUIDANCE FOR THE STATES
(see chapters 3 & 4)
EPA should produce written, explanatory materials for the
states on what is being asked of them, why the guidelines were
developed, and how they can be implemented in various ways.
Availability of such material would , we hope, eliminate many
of the misunderstandings which occurred this time around and
also provide states with more of an understanding of EPA's
reasons for promulgating these guidelines. Otherwise, states
often regard them simply as another bureaucratic requirement.
It should be remember that in many states the agencies pro-
ducing the projections have no direct contact with EPA or
familiarity with the impact of use of the projections in
various programs.
Furthermore, most states did not avail themselves of the
opportunities made possible by the flexibility written into
the guidelines. In many cases their staff was overworked and
unlikely to notice anything but the mere requirements of
the guidelines; in other cases states or the programs respon-
sible were sufficiently unfamiliar with the use of population
projections, that other possibilities did not occur to them.
Guidance from EPA might well include case studies and examples
of how the guidelines might be applied in various circumstances,
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5.5 STATES WHICH HAVE HAD DIFFICULTIES
EPA should work particularly closely with those few states
which appear to have had or be having difficulty complying
with the guidelines, serious misunderstandings about them,
or problems developing a locus of responsibility within
the state.
We expect that if this is done, such problems will be sub-
stantially reduced, if not eliminated, by the time of the
next revision.
5.6 INVOLVEMENT OF OTHER STATE AGENCIES
(see section 4.1)
EPA should strictly enforce requirements for involvement of
state agencies and local governments. In particular, when
guidelines such as these require specific consultation with,
for example, air quality planning agencies, EPA should
notify those state agencies directly to ensure they are aware
that their participation is needed.
This is particularly important for those states where the
projections are being prepared not by an environmental agency
but by a projections agency which might not appreciate the
desirability of involving others in state government.
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5.7 REVISIONS OF THE PROJECTIONS AND
INTEGRATION WITH OTHER FEDERAL REQUIREMENTS
(see sections 3.6 & 3.11)
EPA should make clearer determinations of how revisions to
the state projections and the disaggregations can be
integrated into ongoing environmental planning efforts.
EPA should also resolve with the Dept. of Housing & Urban
Development the relationship between projections prepared for
EPA's 208 program, new in some ways constrained by these
guidelines, and projections used for HUD's "701" plans.
5.8 EARLIER DEADLINE FOR VARIANCE REQUESTS
Several states are delaying the submission of variance
requests until close to October 1 and submitting them together
with disaggregations. This has the result that if the variances
are denied, these states will not have submitted adequate
disaggregations.
Furthermore, such late submissions make it difficult for
public reaction to the variance request to be adequately
considered and incorporated.
These situations could be avoided if the deadline for requesting
a variance of the state number were considerably earlier than
that for submitting disaggregations.
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5.9 URBAN AREAS WITH DECREASING POPULATIONS
OR LOW GROWTH RATES
(see section 3.7)
A major weakness in Che guidelines is that while they
rnay prove to be effective in preventing overbuilding, they
are not very effective in those areas which, from a variety
of criteria, should experience more rapid growth.
If one takes the trends in, for example, many urban areas,
one sees substantial decreases in the center city population.
This problem could be resolved if the states were to realize
that they need not use "trends" in producing the projection;
they could instead, as New Jersey is doing, establish goals
for population in urban areas and have the projections reflect
those goals. We have addressed this more general problem
elsewhere in the report.
Nevertheless the problem remains when we look at the state
projections; they have been prepared according to "trends" for
the states, and the process does not appear to allow this
to change. The only opportunity would seem to be for a state
itself to produce a higher overall projection and convince
EPA that such is the "real" trend.
Since these regulations are considered to be part of the
President's Urban Policies, effects on our established cities
should be carefully considered.
We recommend that a thorough analysis be done of how population
projections are used in making funding decisions throughout
the federal government and, in particular, how this affects
urban areas.
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5.10 PROPOSED FEDERAL-WIDE PROCESS
The EPA projections guidelines are in many ways a pilot
study for how such a process might operate at a federal-
wide level. As we mentioned in the cover letter to this
report, a proposal for development of consistent projections
which must be used in those federal programs x^hich use
projections in a funding formula is expected to be proposed
by OMB & the Department of Commerce this fall.
Much of the analysis and many of the recommendations in this report will,
we hope, !;e of use to those developing this proposal.
We offer the following specific recommendations:
A. Most states would find federal-wide consistency a substantial
step forward. Several complained to us that different
requirements in EPA, HUD, DOT, and HEW programs cause them
to need to produce several sets of projections.
B. Although most states were satisfied with the EPA numbers,
this was because of their similarity to the states' own
projections and the provision in the guidelines allowing
them to use the latter if differences were minor. In order
to maintain smooth working relationships with states, to
increase the possibility of this process being useful to
the states in their own, non-federally-required work,
and to avoid duplication of efforts by states, we feel
strongly that variances such as the 5% one allowed by EPA
should be maintained.
C. Our recommendation for written guidance to the states (see
section 5.4) is even more important if the projections are
to be used more widely. This guidance should not simply
be a rephrasing of guidelines, but should include examples,
and answers to common questions in easily readable format.
We believe the materials should be written at a level
understandable to the potentially-interested public.
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D. Because the process has thus far been tied only to
certain environmental planning requirements, the agencies
overseeing Che process have been either environmental ones
or what we have been calling "projections agencies." If.
the process were implemented to cover many more federal
programs, presumably the latter agencies would get
greater responsibilities and the former less.
However it is precisely the "projections" agencies which
in many states have no interest in or knowledge of public
participation. We believe that requirements for public
involvement must be carefully and tightly written and
enforced, because t'.ie risk of lack of public involvement
is greater.
We recommend serious consideration of states establishing
state advisory committees on projections with mandatory
membership of a certain number of non-governmental
individuals including varied backgrounds in all the relevant
program areas: water, air, solid waste, housing, education,
transportation, etc., as well as population.
Leaving such options open to the states is likely to be
productive only in those states which have thus far displayed
public participation in implementing the EPA guidelines.
Several states complained that they were not sufficiently
consulted when the 3EA/EPA projections were developed. In
two cases the estimates used were not comparable to those
used by the states. Such problems should be taken seriously,
and opportunity for state involvement should be created.
The various federal planning requirements should be spelled
out on a timetable and the relationship of development of
the projections to that timetable should be made clear to
the states. Otherwise there may well be rampant confusion
about which update of the projections is required to be
used by whom, when. The particular cases of states whose
cwn projections timetables are incompatible with required
state updates for federal purposes should be dealt with
in advance.
-90-
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APPENDICES
-91-
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APPENDIX A
ADDITIONAL COMMENTS OF THE STATES
In. our telephone interviews we offered states the opportunity
to make whatever comments they wished on the EPA projections
guidelines. In Chapter 3, Summaries and Conclusions, we
have quoted or mentioned many of those comments.
In this section we present additional comments which did
not fit anywhere else or are more general.
A.I General Supportive Comments
A.2 General Negative Comments
A.3 Miscellaneous Comments
A.4 Specific Suggestions or Problems
A.5 Reactions to Possible Federal-Wide System
-93-
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-94-
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A.I GENERAL SUPPORTIVE COMMENTS
It's good to force states to look at projections because
it makes them think about the impact of the growth. It
will stop local governments from manipulating projections
high or low to get what they want.
Despite the fact that we are participating reluctantly, I
think the process provided good liaison opportunities with
substate agencies.
This makes good sense if done at the beginning of 208 planning
and it will make good sense in 1985 when the new census data
".re available.
We're proud of what we've done. Local communities realized
that this will determine the size of their facilities and so
they took it seriously.
This is definitely needed in order to avoid over- and under-
dusign. It is particularly important for the 208's but not
in rural areas and the SMSA's which are (in that state) mostly
quite small and not showing much growth.
We're already using the interim figures. We're being fairly
stringent kbout them. We're telling local governments that
consultants will no longer be preparing projections. We'll be
handing the projections to them.
Disaggregating to facility planning areas is a good thing. I've
seena'lot of abuse (this person said). A jurisdiction would come
and project the bulk of the growth in one end of the county, and
then a couple of years later they'd come back and project all
their growth in the other end.
No doubt about it. We need standardized population projections
that are acceptable to everyone involved.
I now know more after going through this process.
States should develop their own disaggregations, resolving their
own needs and what EPA will accept. Many states are like us and
haven't had the foresight or resources to develop disaggregations
previously.
The process wasn't very tedious or complicated. For one thing
because we've been here before.
-95-
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The process will probably result in benefits, particularly if
people work out good compromises.
We try hard to keep projects from getting out of hand.
Consistent projections (which we've had in the state) have
been a good experience.
I concur in EPA's approach of getting everybody involved.
EPA should extent this approach to its other programs, MPDES
permits and non-point source programs in particular. Population
is clearly an important factor in estimating future waste
quantities, but the regulations now address the use of projections
in these programs only indirectly.
Don't ruin £0od things going on in the states right now with too
many regulations. The current level of detail in the projections
guidelines is good now.
If EPA will support a state when it has a strong program, things
will work well. They've built flexibility (the 5 and 10% pro-
visions) into it. If EPA is willing to take the heat, it will
be OK.
The process we used was time-consuming, particularly of staff
time. But because of the local consultation, people are
generally agreed to accept the results, at least until the 1980
census.
EPA should look to the states as the "first line of contact"
for resolving conflicts with local governments.
-96-
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A.2 GENERAL NEGATIVE COMMENTS
The requirements are difficult to read.
EPA has said that if there's some reason for deviating from
these projections they'll be flexible but most people (in our
local governments) are afraid that EPA won't allow any change
in the projections. We're afraid they'll put these in concrete.
We're under some awfully rigid requirements that could cause
problems for a specific county, say one where the figures don't
reflect what we (now) know or expect. The tools of the trade
don't allow us to project in a rapidly expanding county.
The EPA should ask states for projections. They'd get more
state input. The regulations seemed not to realize that lots
of people across the country are wrestling or dealing with the
same thing.
They (EPA) made no effort to get input the way the states are
required to get it. The state projection just showed up in
the mail one day. (comment of two states)
The system set up now is workable. But it's probably too hard
to deal with. It's so structured there's no way to deal with
anything out of the ordinary.
The whole thing is a lot of monkey business, an exercise in
futility, an annoyance. It should be done case by case; the
total of the parts might well exceed the whole. If we're looking
at a town that looks like it's going to grow, we give it
funding for growth.
We didn't get enough money for planning in the non-designated
parts of the state and as a result our projections aren't very
good there. We're telling our contractors that the local numbers
shouldn't be treated as gospel for 201 planning.
Doing disaggregations to the county level is worthwhile, but
doing them in rural areas to facility planning areas is not.
The regs. seem more appropriate for denser populated urban states.
We shouldn't have to do this as part; of the statewide 208 program.
It's more related to Cr-n^tructi'-m Grants in 205g or someone else.
These guidelines are constructed to produce a "convenient" pro-
jection. But really you should be going to the level of govern-
ment which has the most information, which is some cases will
be a local government not the state or the feds.
-97-
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We shouldn't have to do disaggregations at all since our
state's growth is totally a function of federal decision.
We would prefer to submit two projections not one. In many
parts of the state, the economy is dependent on one industry
or one company and it is difficult to pick a particular future.
Having additional projections ready and approved means one
can svitch to using that projection as soon as a decision is
made. This is particularly important when situations are
changing rapidly.
-98-
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A.3 MISCELLANEOUS COMMENTS
This is an unplanned planning program. Agencies that work
with HUD are more used to this.
The process is easy for states that are well-prepared but
very hard for others.
The feds want to ignore the energy boom. I'll have to eat
my words if I?A accepts our request for a variance.
Vie have a problem with asking our Governor to accept projections
prepared outside the state. We feel our projections are as
good as EPA's.
The methodology should be reviewed stringently but there should
be some leeway in the actual numbers produced.
EPA needs to be "flexible", particularly at the facilities planning
level (a comment of quite a few states).
-99-
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A.4 SPECIFIC SUGGESTIONS OR PROBLEMS
This section covers ideas not included in earlier chapters
or in the State Reoorts.
One state felt the 5% and 10% variances were "arbitrary" and
that if such variances are allowed at the state and 208 level
they should also be allowed at the facilities planning level.
Two states commented that treating the designated and non-
designated areas differently (as far as possible variances)
polarizes them and is unfair to the nondesignated areas.
One state commented that because the 10% variances allowed
to the designated areas do not take population away from other
parts of the state, it is politically impossible for the
Governor to refuse to grant one. (?n the other hand, several
states in which there are significant differences between the
208 and the state projections are not going to grant the
variances and have no problems with that)
One state accepted a 5% variance even though it really wanted
a somewhat larger one because the process was easier.
One state has several problem counties which contain large
military bases. They have to rely on the army's figures for
those but there may be closing of bases in other states which
would mean more people in their state.
Five states mentioned having communities with large seasonal
populations of tourists and retired people and not knowing
how EPA wanted them to handle this in their projections.
One state commented that since most of the step 1 grants in
that area have already been awarded the guidelines should
perhaps also cover step 2 grants. Related to this is the
following:
In one state the current set of projections is now significantly
different in parts of the state from the former set. One la?ge
project is now completing its planning phase (step 1 grant) and
it appears that the projection which was used is very much inflated
compared with the more recent projection. One person in the state
government stated a preference for having the most recent projection
used even if it is developed at the end of a lengthy and expensive
planning process. That state had attempted to get the contractors
to consult regularly with local government planners but this
apparently was difficult to implement.
-100-
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A.5 REACTIONS TO POSSIBLE FEDERAL-WIDE SYSTEM
In our telephone interviews, quite a few of the state people
were aware that the federal government is considering developing
a process to ensure consistent use of population projections by
all federal programs which use projections in funding formulas.
States generally expressed support for the idea of consistent
projections to be used by state and federal programs, with
some commenting on the technical or political hurdles to be over-
come.
Some states were acquainted with the details of the proposals
being developed by the Office of Management & Budget and Department
of Commerce along these lines. In some discussions, the nature
of the conversation led us to tell states about these proposals;
in others the issue never arose.
General Supportive Comments
Sounds rather progressive.
I wish them luck.
The idea has merit but will take time.
All federal agencies should use the same numbers.
There's some practical value to the OMB plan, but also headaches.
There are now (in our state) no official numbers at any level. The
feds should use the same numbers; every program in DHEW uses a
different projection.
A very strong, good move as long as there is substantial state
involvement in reviewing the state projections.
-101-
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General Negative Comments
It's sensible to use different methodologies for different
purposes. The Federal DOT projections have been useful to us
and in the short term they have come out very close. I caution
against using one set of numbers for all purposes.
There will be a similar problem with the OMB plan to the one
the states now have with the locals. The states are likely to
say that there's not enough state involvement.
Projections are not appropriate for allocating money.
Joint BEA/Census projections (to be proposed by OMB and Commerce)
might not be better. One small state commented that it was
difficult for them to luve influence. A larger state suggested
outside review in developing the projections.
We are "headed for a big battle with OMB." States know the
trends better than the feds. The OMB proposals don't take into
account federal policy objectives such as Carter's urban policy.
If we look at the long-term situation, for example, the northeast
has plenty of x^ater and will get more growth.
If done wrong, this could reinforce current population shifts
around the country (which is bad).
Other Comments
You nead to look at the implications of using different projections.
Overbuilding of hospitals, for example, causes higher rates to
its patients but overbuilding of highways brings no complaints
because it wasn't built with local money.
All calculations of need should be done straight, with a safety
factor added explicitly at the end. The way it's done now, they
add a safety factor in each calculation, and the final number is
wildly inflated.
In non-EPA programs, one has to get the analogue of per capita
use and the design period. One fact that also needs to be considered
is the risk. For example, in the case of hospital needs, coming
up short is a real problem.
-102-
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APPENDIX B
INDIVIDUAL STATE REPORTS
Each state raport that follows is the summary of
one or more telephone interviews lasting'between
twenty and sixty minutes each. Because of
limitations of space we had to omit much of the
information we learned in those calls; we would
be happy to provide additional details on
request on particular states.
"Date of contact" refers to the date of our most
recent telephone conversation with a state representative.
Material in the summaries is therefore no more recent
than that date; because some states were at the time
in the midst of deciding how to handle the projections,
the situation at the time you are reading this may
be very different.
"7/77 estimate" refers to the estimate of population in
July, 1977 used by the Bureau of Economic Analysis
in preparing in preparing their projections for EPA.
"EFA projection" is the projection for the year 2000
for the state prepared by BEA for EPA.
"State projection" is the state's official, or usual,
or only available projection prepared by the state's
projection agency. It may be several years old, or
very recent.
"Projection submitted" is the projection for the state
which has been or will be submitted to EPA. Except
where indicated, it does not include 10% variances which
may be granted to designated 208 agencies.
The section entitled, "State Projections" describes
the state's usual process of developing projections,
independent of EPA requirements. The next section,
"Special activities for EPA" includes projections
developed as part of EPA planning processes (sach as
208) or specifically to comply with these guidelines
In some cases it was difficult for us to tell in
which of these two categories some activity has fallen.
In the "Other Comments" section we present, for some
states, a brief analysis of strengths and weaknesses
in a state's approach to the EPA guidelines.
-103-
-------
-104-
-------
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APPENDIX C
GLOSSARY
In this section we try to define or describe some of the
more technical terms used in the report.
Types of Population Projections
We generally describe the projections used as being demographic,
econometric (or economic), a combined approach or a ratio or
trend^ projection (see section 3.5 and the State Reports). A
demographic projection makes separate assumptions about fertility,
mortality, and migration and calculates a future population.
It is also called a "cohort-surviva1." or "cohort-component"
projection.
An econometric projection begins with a forecast of jobs.
Then, by making assumptions about the labor-force participation
rate and the unemployment level, translates that iito a
projection of population.
A combined approach uses both demographic and econometric elements,
and can be of various types. A common one b*.ses the migration
assumptions in the demographic model on that part of the pro-
jected labor force which cannot be met by locally-born individuals.
Some states use various kinds of trends or extrapolations, and
continue an area's rate of growth into the future (see Idaho)
or an area's proportion of the state's growth (see Alabama).
201 Facility/ 201 Plan/ 201 Projection/Construction Grants Program
Section 201 of the Clean Water Act establishes a program of
federal funding of 75% or 85% (in certain cases) of the
construction costs of publicly owned sewage treatment facilities.
The area which a particular facility is being designed to
serve is the "facility planning area." The population projection
used to plan the facility is the "201 projection." The plan is
the "201 plan." Etc.
These facilities take care of "point sources" of po_lution, i.e.
those coming out of or from a pipe or similar area.
The program in EPA's Office of Water and Hazardous Materials
which makes the grants for these facilities is called the
Construction Grants Program.
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Population Projection/ Forecast/ Estimate/ Census
A census is an actual count of the number of people in
an area. The next census will be taken in 1980.
An estimate is a guess of the number of people in an
area prepared between censuses; it is based on any of
a number of indicators of population change: births,
deaths, construction permits, school enrollments, drivers'
licenses, estimates of jobs, etc.
A population projection is a guess, or scenario, of how
many people would live in a particular geographical area
at some time in the future. It consists of base data
(census or estimates, current and past fertility, migration,
mortality, etc.), a model (demographic, economic, straight-
line trand, etc.), and assumptions ('That will the fertility
be in twenty years? How may jobs will there be in this
area?).
A projection is not necessarily a prediction; the latter
is used when the person preparing a projection thinks that
a particular projection is the most likely to happen.
However one can prepare any number of projections, including
those which one thinks involve assumptions unlikely to
materialize.
A forecast is a projection which someone thinks is reasonably
likely to come true. That is, the term involves more of
a commitment of reasonableness than a projection.
A prediction is a best guess. As far as we can tell, no
state agencies ever uo population predictions.
A baseline projection is one which is used by official
agencies and is regarded as the standard projection to be used,
or one thought of as reasonably likely to occur if "current
trends" continue.
Disaggregation
A disaggregation of a projection is a division of one projection
into projections for smaller geographical areas. So, for
example, a state may prepare a population projection for the
state and then disaggregate (or divide or allocate) to
projections for counties.
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2Q8 Plan/ 208 Agency/ 208's/ 208 Level
Section 208 of the Clean Water Act requires states to develop
plans to meet clean water standards. Sources of water pollution
come from point sources and non-point sources. Examples of the
latter are agricultural runoff and runoff from urban construction
sites.
The p.?.ans, whether for entire states or parts of them, are called
208 plans.
The Governor of a state may choose- - or designate - captain
substate agencies to prepare the water quality plans for their
geographical areas. Those agencies are called 208 agencies or
208's. Their geographical area is sometimes called the 208 level.
Although these designated 208 agencies in some cases are counties,
more often they are multi-county planning agencies, which in
different states have different legal statuses, sources of funding,
roles, and responsibilities. They are known as:
* councils of government (COG's)
* areawide planning agencies
* metropolitan planning agencies or organizations
* associations of government
* area planning and development commissions (APDC's)
However not all agencies with the above names have been
designated for 208 planning'.
Needs Survey
EPA conducts Needs Surveys every two years to determine what
is still needed in each state to comply with various portions
of the Clean Water Act. The cost of complying is also
estimated. Population projections are, of course, used in
determining and estimating the needs.
Surveys were conducted in 1973, 1974, 1976, and 1978.
Step 1 Grants
Under the Construction Grants Program (see above), EPA makes
grants in three steps for the construction of a sewage treatment
facility. Step 1, the first, is a planning grant. Step 2 is
for design of the facility and step 3 is for actual construction.
The EPA projections guidelines refer to a. deadline after which
all Step 1 grants must use projections consistent with the
guidelines.
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APPENDIX 0
EPA CONTACTS
Listed below are individuals in EPA headquarters and regional
offices who can provide you with additional information about
the EPA requireemnts and particular states.
EPA Headquarters
Cathy O'Connell, 202/755-8253 or 202/426-9404 (leave message)
Facility Requirements Division (WH 595)
Office of Water Program Operations, OWWM
EPA
401 M Street, S.W.
Washington, O.C. 20460
Region I (CT, MA, ME, NH, RI, VT) - Boston
Roger Duwart, 617/223-5130
Water Quality Branch
Region II (NJ, NY) - New York City
Beverly Reith, 212/264-1840
EIS Preparation Branch, Water Division
Region III (DE, MO, PA, VA, WV, & DC) - Philadelphia
Gene Mattis, 215/597-3423
Uater Quality Management Coordinator
DE, MO, DC: Larry Merrill, 215/597-9966
PA: Rich Setzer, 215/595-9151
VA, WV: Hank Zygmunt, 215/597-8168
Region IV (AL, FL, GA, KY, MS, NC, SC, TN) - Atlanta
James Kutzman, 404/881-4989
Chief, Applied Technology Section
Water Division
Region V (IL, IN, MI, MM, OH, WI) - Chicago
Mary Lou Lageman, 312/353-2000
Regional Economist, Planning & Evaluation Branch
IL, IN: (Mr.) Noel Kohl, 312/353-2163
MI: Jim Filippini, 312/353-2160
MN, WI: (Mr.) Dale Luecht, 312/353-2168
OH: Ed Matters, 312/353-2172
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Region VI (AR, LA, MM, OK, IX) - Dallas
Thomas Lara, 214/767-2624
Region VII (IA, KA, MO, NB) - Kansas City
IA: Vic Zieglar, 816/374-5429
KA: Larry Sheridan, 816/374-5429
MO: (Mr.) Lee Duvall, 816/374-5429
NB: John Houlihan, 816/374-5429
Region VIII (CO, Ml, ND, SD, UT, WY)- Denver
CO: Bruce Zander, 303/837-4963
Ml: Robert Fox, 406/449-5486 (note area code)
ND, SD: Roger Dean, 303/837-2721
UT: Paul Arell, Doug Johnson, 303/837-4963
WY: Mike Strieby, 303/837-4963
Region IX (A2, CA, HI, NV) - San Francisco
AZ: Mark Brucker, 415/556-3793
CA: Loretta Barsamian, 415/556-2833
HI: Kitt Armstrong, 415/556-8085
NV: Rick Hoffman, 415/556-3039
Region X (AK, ID, OR, WA)- Seattle
Mike Gearheard, 206/767-1237
AK: Stan Brust, 907/271-5083 (note area code)
ID: Eldon Edinundson, 208/384-1450 (note area code)
OR: Cecil Ouellette, 503/221-3250 (note area code)
WA: Al Ewing, 206/455-7218
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How They Are Made... And How
They Make Themselves Come True
JUDITH KUNOFSKY
| OK \IMOSI liltecn years, ihc Sierra Club has acknowl-
edged ih.ii population growth is a cause ol all environmen-
tal problems The environmental effects of the almost 220
iiulhuii Americans .ire compounded by .in annual increase ot
almost 2 million: the Census Bureau's "medium level" forecast
foresees a total population of 296 million in 2025only 4.7
ve.irs away A growing population intensifies pressure on fragile
land, contributes to pollution of air and water, provides the
impetus for the uiham/uiion of agricultural land and the con-
struction of an ever-increasing number of power plants. While
giowth rates have declined both in this country and in many
other parts of the world, overall population continues to
increase.
The way we evaluate how fast the population si/.e is chang-
ing, what programs might help reduce the growth rate, how bad
(or good) the situation might be in the future is through the use of
population projections Moreover, for many programs with
significant environmental impactsewage treatment facilities.
major water diversion projects, massive regional energy
developmentthe population projection for the appropriate re-
gion is used to justify the project. Ironically, in many cases,
using a projection this way actually helps bring about the growth
iliat was foreseen. In other words, sometimes the projection
causes the growth1
A population projection tor a given geographical area states
what the population size and growth rate would be at certain
dates in the future It differs from a population estimate, which
is usually a statement about the past or current population of an
area. Projections are prepared for the world, lor nations, states,
counties, cities and smaller geographical areas, and can be pre-
pared with u variety ol detail and sophistication. Some proj-
ections uive only the total number of people; others describe
distribution by age, sex and sometimes race, religion or other
group identification. Population projections are prepared using
different models, or mathematical tormulations, that express
different theories about why and how population size and
growth rates change. For example, one might assume that a
community's overall population will continue to increase at 1% a
year. Or one might make separate assumptions about family
si/.e, mortality, lertility timing and migration, and apply those
assumptions to a detailed breakdown of the current population
by age and sex. Alternatively, one might relate population
change to a projection ol regional job availability.
A projection is not a prediction: even in theory, a projection
need not tell us what is most likely to happen. A projection
reflects the consequences of a continuation of "current trends"
and the extent to which the model chosen accurately mirrors the
real world. The difference between them is that current trends
always change, and they change, at least in part, as a result of
our evaluation of and reaction to those trends. For example,
approximately one out of rive births in the U.S. is to a teenager.
One might prepare a population projection based on this situa-
tion However, one might feel that as a society we will adopt
programs to change the trend, and therefore project a reduction
in teenage parenting.
Population projections are based on much accumulated expe-
rience and are almost always prepared to reflect what are be-
lieved to be current trends. Of course, it is difficult to distinguish
between a current trend and a short-term aberration in behavior,
in tertility or migration. It is important to realize that it is not a
question of an adequately prepared projection being right or
wrong, but simply that the world is much too complicated for
there to be a correct guess of the future.
Demographer Peter Morrison has written that, "Forecasting
is least effective when it is conducted as an exclusively mechan-
ical process. It is tempting to adopt an approved method, plug in
some numbers, and crank out some more numbers that tell
people what to do ... It should be possible, however, to im-
prove the odds on making right decisions not only by laboring to
improve the models, but also by sharpening our ability to evalu-
ate and assess the products of forecasting models. . . . Those
who use demographic forecasts must exercise at least as much
judgment as those who make them."
Population projections are used in three ways. Projections are
used to give us an idea of population size and growth rates in the
future. We can evaluate whether the U.S. has reached or will
reach zero population growth, how fast our numbers might be
increasing in the year 2000, what the contribution of immigra-
tion at various levels is to the U.S. population, the significance
of the heavy migration to the Sun Belt, how fast Monterey,
California, is gaining people or how fast another region is losing
people From these projections we can then evaluate the need for
corrective or supportive actions, the wisdom of adopting various
population policies to change or reinforce trends.
Projections also are used in determining the allocation of
federal funding, the decision to go ahead with or to reject vari-
ous federal, local and state projects. All major government
investmentssuch as roads, dams, sewage treatment plants, and
U JANUAKY/H.HIUIAK'r
-------
/.Y it fair for a community
that consciously or unconsciously
submits an inflated projection
to receive a bigger chunk of the tax dollars?
sewersullcmpt to solve current problems (such as water pollu-
tion), or may provide for additional capacity to continue to abate
a problem or to anticipate a future problem. A new reservoir
may, lor example, provide for the anticipated water needs of a
community that does not now have a water shortage.
In order to determine the.se future needs, the agency propos-
ing a project prepares a projection of the quantities involved,
whether they're quantities of water, untreated sewage or vehi-
cles expected. In each case, an essential component of the de-
mand projection is a projection of the number of people who will
he living in the .nea in question or who will be served by the
lability. The population projection is then used to determine
whether a project IN needed, where it should bo located, how
large it should be, (he cost-effectiveness ol the proposal and,
finally, the amount of money to be made available by the appro-
priate level of government. Population projections, therefore,
are crucial and indispensable factors in the evaluation of needs
by communities and by government agencies with funding
authority.
Population projections are also used in devising computer
models that involve both population and economic projections.
These models are used to esiimate the effectiveness of proposed
environmental controls. For example, a model may postulate
various types ol air pollutants emitted by different sources, fac-
tor in topography and weather conditions, then evaluate various
strategies for meeting federal air-quality standards. Modeling
can also be used to gauge the effect on population of proposed
energy development, a new industrial facility or water devel-
opment. But population projections are much more than a rather
academic, statistical exercise. The projections themselves can
have a tremendous effect on growth. This is because construc-
tion projects olten loster (he population and economic changes
that were projected. In other words, if a community provides
sewer hookups lor j doubled population, people ma^y move to
that communitybecause there are sewer hookups.
This situation poses certain problems:
Is it fair for a community that consciously or unconsciously
submits an inflated projection to receive a bigger chunk of the
ta.x dollars'?
The growth thai is induced by an inflated population projec-
tion may reflect (lie desires of only certain special interests in a
community.
One federal program may undermine the goals of another, as
when the federal government funds a sewage treatment plant to
solve current water pollution problems, and the reserve capacity
of that plant facilitates growth in an area that depends heavily on
ihe automobile. As a result, auto commuting increases, and air
quality gets worse.
Another example would be if a city with decreasing popula-
tion were forced lo use a projection reflecting only the "current
trends," thereby aiding and accelerating the population de-
crease. This direction might he contrary to an established federal
or state or local policy of rebuilding the city's population and
industrial base.
Different government agencies have experienced different
problems connected with population projections. In the
abstract, these problems may seem almost impossibly abstruse,
but ca.se studies shed some light.
Water Development and a Wilderness Study Area:
The Forest Service and Medicine Bow
National Forest, Wyoming
THH U.S. Forest Service, within the Department of Agricul-
ture, has been developing a management plan for the Huston
Park Unit of the Medicine Bow National Forest in Wyoming
The unit i.s near the city of Cheyenne, and the key point of
contention has been the extent to which the Forest Service will
accede to the Cheyenne Water Board's request that land be re-
served for further development of the city's water supplies.
Some of the remaining areas within tht: unit were to be made
available for study for potential inclusion in the National Wil-
derness Preservation System.'The rive options presented ranged
from reserving one third of the acreage requested tor potential
water development to reserving all the acreage requested. In
urea, the acreage requested for wilderness study ranged from
none to 43,010 acres. The original choice made by '.he Forest
Service was to reserve all the acreage requested for water devel-
opment and to allocate 29,770 acres for wilderness study.
Substantial controversy arose, however, after publication of
the Draft Environmental Impact Statement in late 1976. The
Cheyenne Water Board had used a projection of 113,490 for
Cheyenne for the year 2000, compared with 43,813 in 1973
However the Economic Research Unit of the Office of the State
Planning Coordinator had projected a year-2000 population of
73,400 for the entire Laramic County, in which Cheyenne is
located, of which about 60,000 would be in the city of
Cheyenne. This discrepancy was noted not only by The Wilder-
ness Society and the Wyoming Outdoor Council, but also by the
Office of Industrial Siting Administration of the state and by the
governor. Governor Ed Herschler wrote that, "The draft state-
ment . . . fails to adequately address several important matters.
. . The discussion of the population projections and the in-
creased demand for water resulting from the projected popula-
tion should be more specific and definitive."
Objections were sufficiently compelling that in the final re-
port, dated September 1977, the Forest Service had changed its
recommended management plan to one allocating about half the
requested acreage for potential water development and 36,840
acres for wilderness study. The city immediately appealed to the
director of the Forest Service, and the matter is still being
negotiated.
Water Development and Hydroelectric Power:
The Army Corps of Engineers in Alaska
THE Army Corps of Engineers has proposed building a dam
on the wild Susitna River in Alaska. If built, this would be
the most expensive hydroelectric dam project in the Corps' his-
tory, with costs estimated between SI.5 billion and 56 billion,
SIERRA 35
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'{'hi' sum total of all Mate projections
used . . . should he equal to
or reasonably related to
a projection of U.S. population.
Corps analysts have admitted thai, "by making assumptions
about lulure populations and economic growth and then
providing energy sulfieic-ni U> sustain such growth, the initial
projections may become s'elf-fullillinjj prophecy." But the
project's environmental impact statement lakes a different,
more simplistic.- view, it claims that the population and indus-
tnal growth will occur whether or not the dam i.s built and that
ihe increased availability ol power will nut stimulate* industrial
development.
The Corps did point out, though, that "by presuming that
energy needs must be met. Ihe opportunity to u.se the provision
ul power as a tool lo direct growth toward socially desirable
goals i.s I'oregone In the absence, however, of any such gener-
ally accepted growth goals, it seems highly presumptuous to do
otherwise than plan as to satisfy the energy needs required to
sustain thai level ol tuiure development deemed most likely"
1 lie statement is somewhat circular, but it does point out
clearly that unless we as a country begin to develop and articu-
late more clearly our national, regional and local population
and development goals, ihe tie /ncto growth policy will con-
tinue to relied past trendsor the wishes of the most vocal
and opinionated special interests.
II we are lo use population projections intelligently and
correctly- -as planning tools rather than as pronouncements
ol unalterable preconditionsa lew principles should be
followed
The lederal government should continue to produce pro-
jections lor the country as a whole thai include a range of in-
terpretations ol cut rent trends in U S population growth.
Moreover the lederal government should seriously consider
producing alternative projections, that present a more goal-
oriented attitude towards U S. population growth, i.e., that
exhibit alternative population paths including fertility and mi-
gration assumptions that are not now regarded as current
tiends.
There is nothing wrong with the lederal government continu-
ing to produce a consistent se! of population and economic
projections for regions and communities, according to current
trends (as does the Bureau of Economic Analysis for the Water
Resources Council). However, population projections that are
developed for use by the government in I muting must satisfy
the (ollowing conditions:
Projections must he prepared using demographic-ally accept-
able techniques anil must be periodically updated. This point
should be no surprise.
The sum total ol all slate projections used - -or all projections
lor smaller geographical units should be equal to or rea-
sonably related to a projection ol U.S. population. The sum ol
the parts must approximate the whole.
» Projections must lake into account the relevance of goals as
well as trends
There must be opportunities for input by slate and local gov-
ernments as well as the public.
All federal agencies should use ihe same projections in a
community or slate
Communities must be encouraged to prepare and use pro-
jections that reflect goals, not simply trends 'This is particularly
true for population distribution within a community but should
also be true for population si/e itself Implementation of the
Clean Air Act, Clean Water Act and other national legislation
has, m some communities, led to this type of innovative think-
ing, but this needs to be encouraged Far more than it has been.
As the federal government improves its ability to articulate
national policies lor urban development, protection ot agricul-
tural land, water policy, housing, population growth und so on.
these policies should be rcikaed in its population projections
There is good news about the federal government's use of popu-
lation projections. The hnvironmental Protection Agency
(HPA) has developed a new and environmentally sound process,
one that follows the principles outlined above
The EPA's process begins with the Census Bureau's "Series
II" projection for the United States. This is the medium projec-
tion, the one most often quoted and used. It is the projection that
gives a U.S population in the year 2000 of 260 millionand
one in which U.S. population never stojis increasing Thr
Bureau ol Heonomie Analysis (Bt.A) ol the Department ol
Commerce periodically prepares a consistent set of population
and economic projections tor more than 600 geographical re-
gions in the country, including each stale. At hPA's inquest, the
BKA divided the Census Bureau's single projection into 5U .state
projections. Each state would then divide its projection into a
number of smaller projections for regions (such as those with
water quality planning agencies"2(M" agencies) Each re-
gion would further break down the projections tor constituent
counties, cities and sewage-facility planning areas ("201"
areas). The available tederal funding would be limited to 75^ or
X.V/}- oi the cost ot a facility whose sue would be determined by
the HPA's population projection Communities that wish to con-
struct larger facilities could do so at their own additional
expense.
The EPA procedure also includes provisions for reasonable
exceptions and variations within strict limits. Environmentalists
have praised the proposed FiPA procedure because it involves a
national overview ol population projections, because states
have an important role to play; and because communities can
determine where and how they want growth to occur. Implemen-
tation of these regulations would go a long way toward remedy-
ing the problems involved in the use of population projections.
But much would still need to be done: state governments and
communities still have their own policies on how population
projections are prepared and used. More importantly, the devel-
opment of a community consensus on the most environmentally
sound and socially beneficial projections tor their area is a task
that remains to be accomplished virtually everywhere in the
country, n
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JANUARY-'H'BUUARY
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