STATE CLEAN WATER STRATEGIES
MEETING THE CHALLENGES OF THE FUTURE
December 1987
Office of Water
U.S. Environmental Protection Agency
Washington, D.C.
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NOTE TO THE READER:
This guidance is intended to be supportive of the program-specific guidance documents that provide
the details on what EP A and the States must do in order to meet the Congressional mandates under
. various provisions of the Water Quality Act (wQA). In carrying out responsibilities under the
WQA, EPA and the States must address the requirements and deadlines in these documents.
Documents that are available now (or in the immediate futUre) include:
.
.
Clean Lakes Program Guidance
Guidance on State Water Pollution Control Revolving Fund
.
.
Implementation of Requirements Under ~304(1) of the Clean Water Act, as Amended
Nonpoint Source Guidance
.
.
State Water Quality:;based Toxics Control Program Review Guidance
',' I' .
Other guidance documents, policies,~trat<;gies. and regulations will become available throughout
FY 1988. .
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STATE CLEAN WATER STRATEGIES:
MEETING THE CHALLENGES OF THE FUTURE
INTRODUCTION
The Water Quality Act of 1987 (WQA) offers a special opportunity for regulatory agencies, the
regulated community, and the public to implement the ambitious new initiatives in concert with
ongoing core Clean Water Act (CWA) programs. States have been actively involved in water
quality management planning since before the 1972 CWA, and, under the amendments, need to
address important new responsibilities in the areas of surface water toxics, nonpoint source
pollution, clean lakes, and estuaries. In addition, wetlands and groundwater represent very
important resources that merit protective efforts. Hence there is both a compelling need and an
excellent opportunity for States to be creatively responsive in fulfilling their statutory
responsibilities.
The Environmental Protection Agency (EPA) is actively encouraging States to meet the goals and
requirements of the WQA to the fullest extent possible, and to do so in an open, consultative
framework using the latest techniques of problem assessment and management. This document
describes what EPA views as a rational process for States to use in satisfying their WQA
requirements through an open and integrated three stage process of waterbody/resource
assessment, water resource targeting, and strategic management planning. Each State has unique
resources and environmental problems, different institutional arrangements, and different priorities.
The problem assessment and management process described in this guidance allows each State
great flexibility in determining how it will pursue an integrated approach to solving its particular
problems within its particular institutional framework.
The comprehensive process described in this guidance is intended to complement and coalesce, and
to be supportive of EPA's program-specific guidance documents, policies, strategies, and
regulations, which provide the details on what EPA and the States need to do in order to meet the
Congressional mandates under the various provisions of the WQA. Therefore, in carrying out their
responsibilities under the WQA (nonpoint sources, estuaries, Clean Lakes, and surface water
toxics), EPA and the States will take into account these other documents as well (see inside front
cover for listing).
WQA IMPLEMENTATION PRINCIPLES
The following principles serve as the foundation for the process described in this document, as well
as overall WQA implementation:
1. EPA and the States will strive to meet the statutory goals, requirements, and deadlines of the
Act to the fullest extent possible.
2. EPA and the States will pursue with vigor both the new initiatives under the 1987 WQA and
the ongoing programs, priorities and responsibilities of the traditional CWA programs.
3. Where all water quality problems cannot be addressed immediately, EPA and the States will,
using multi-year approaches, set priorities and direct their efforts and resources to
maximizing environmental benefits by dealing with the most serious water quality problems
and the most valuable and threatened resources first.
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4. Where possible, EPA and the States will combine activities across program areas to promote
environmental results, avoid redundant efforts, satisfy multiple requirements, and facilitate
efficient, effective use of resources.
5. In meeti!lg near-term WQA statutory deadlines, States will exercise diligence in collecting
existing and readily obtainable information to identify known and suspected water quality
problems. In the longer-term, States will continue to collect and generate new data.
6. In order to capture as much information, data, and expertise as possible, EPA and the States
will actively solicit input and participation from interested and informed parties throughout the
process. .
7. EP A will encourage States through policies, guidance, and assistance to use innovative,
comprehensive approaches to WQA implementation.
8. EPA will work with States to improve their capability to meet statutory requirements through
training, technical support, guidance, and review of State programs and support to upgrade
programs, as needed.
9. EP A will also exercise its oversight responsibilities to ensure national consistency in meeting
the requirements of the WQA.
10. EP A will work with other Federal agencies consistent with the WQA to share information and
data, and to encourage those agencies to operate their programs in support of State strategies.
11. The State may incorporate its multi-year sews into its water quality management (WQM) plan
pursuant to the Continuing Planning Process (CPP) or its ~ 106 Annual Program Plan. The
State will submit its completed WQA assessment(s) as part of its FY 1988 biennial ~305(b)
Report, which will be updated on an annual basis where specifically required by law.
THE RELATIONSHIP BETWEEN SCWS AND OTHER WQAlCW A ACTIVITIES
Before describing the State Clean Water Strategy (sewS) process, it is important to recognize that
this is a voluntary process that can be used along with other management planning documents and
activities underway. These activities fall into two general categories: new activities under the WQA
and ongoing activities under the ew A.
Other WQA Ma~erials and Actions
There are a number of documents that pertain to implementation of the WQA of 1987, and it is
important to understand the relationship among these various documents.
EPA initially produced a Section-bv-Section Analysis of the separate provisions of the WQA in
succinct narrative form. The purpose of this document was to familiarize Regions, States, and the
regulated community with the basic provisions in the law. The Clean Water Strate~ - 1987 then
set forth some general implementation principles and EPA's initial recommendations for States to
follow in developing an integrated, strategic approach to WQA implementation that is set fonh more
fully in this document. The Strategy also included eleven program-specific Attachments that
described the Agency's general pro~ strategy for each area.
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In addition, each program has been conducting workgroups to prepare individual guidance
documents, regulations, and policies for Regions and States to use in addressing specific
implementation issues. A number of these guidance documents are now available in final form (see
inside front cover for listing), and, as mentioned above, this document in no way supersedes those
program-specific guidances. Finally, the FY 1988 A~ency Qperatin~ Guidance sets forth the
specific national priorities and program activities that EPA Regions and States will undertake in FY
. 1988, and served as the basis for negotiating FY 1988 workplans.
The Clean Water Act and the Water Quality Act of 1987
EP A and the States have been engaged in an array of water pollution control programs and activities
for many years; The process described in this document is not intended to drive the entire water
pollution control program in the shon-term. Regions and States are expected to maintain the
integrity of their core water pollution control programs and activities consistent with available
resources and national priorities, policies, regulations and guidance. Congress continues to fund
these core programs, and did not intend for EPA or the States to lose momentum in existing
program implementation.
In addition, there are some mandates under the WQA of 1987 that place constraints on the degree to
which activities can be merged. In the area of surface water toxics controls under ~308, for
example, the initial round of individual control strategies for point sources must be implemented by
February 1989. In order to meet this statutory deadline, States do not have any discretion
regarding either timing or location of control measures. Consequently, these are critical activities
that must proceed immediately and independent of any coordinated effon, while the key
longer-term activities under ~308 (such as setting priorities for new toxics monitoring, problem
assessments and controls) may be folded into an integrated, strategic approach.
While the WQA sets forth some priorities explicitly in the law, however, EPA and the States have
some degree of flexibility in other areas. The sews exercise is intended to enable States to take
advantage of these opportunities, and to deal with their water quality problems in a holistic, rather
than piecemeal, fashion. This may lead to implementation of a watershed or geographic-based
approach, which combines the tools and resources of several programs on selected waterbodies, or
to an approach that provides a better mesh between ongoing CW A activities (such as wetlands
protection) and new WQA activities.
STATE CLEAN WATER STRATEGIES
State Clean Water Strategies (SCWS) provide States an opponunity to satisfy their WQA
requirements. through an open and integrated three stage process of waterbody/resources
assessment, water resource targeting, and strategic management planning. The following is a brief
description of how EPA views the process. Within this overall framework, however, States are
actively encouraged to use innovative and creative approaches to completing each step. Each State
and EP A should agree to a consultative process throughout the development and implementation of
the SCWS. In addition, where States appear to be using techniques that are especially successful,
EP A will make this information available immediately so that other States can benefit from these
experiences.
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There are three themes that recur throughout this guidance and throughout the entire sews
process. The first is the necessity to establish -- and keep in the forefront -- long-range, multi-year
water quality objectives. The second is the imPOrtance of establishing early, effective involvement
of public interest groups, elected officials, the media and others who may be interested and able to
assist in the process. The third is "targeting," which is the process of ordering and adjusting
priorities to ensure that available resources and efforts are applied to programs that will achieve the
greatest water quality benefits.
Step 1: Assessments (Fall - Spring 1987/88)
Assessment involves identifying impaired waters. The objectiv~s of this step are to:
.
Identify impaired waterbodies to use as the basis for pollution prevention 'and control
actions; .
.
Identify threatened waterbodies in need of protection;
Identify gaps in infonnation on water quality to use as the basis for determining where to
focus ongoing and future data collection efforts.
.
In conducting assessments, States should consider combining the similar WQA requirements under
several provisions of the WQA: ~316 nonpoint sources; ~315 Clean Lakes; ~317 estuary
programs; and the second phase of work under ~308 surface water toxics controls. Appendix 1
contains a brief description of the assessments required under each of these provisions. The
advantages of combining these assessments are to: help States identify geographical problems and
crossmedia "hot spots"; make data gaps more apparent; encourage non-traditional, multi-agency
coordination and cooperation; and form the basis for comprehensive pollution control efforts.
An assessment consists of three activities:
1. Obtain Existing Data: Given the time constraints imposed by the WQA statutory deadlines,
States will have to reply largely on existing and readily obtainable data and information to meet
their near-term WQA obligations. The largest source. of State water quality data is likely to
be in-house. However, States should expand their traditional efforts to
obtain data, and should seek out other existing and readily obtainable data that are available
from outside sources. The goal is to collect existing data on aquatic resources and habitat,
which goes beyond the infonnation on me in the Agency. The intent is to capture quickly as
much existing data as practicable. Appendix 2 contains a list of potential sources of data.
2. Evaluate Data Quality and Identify Gaps in Information: Once the State has
assembled its data and infonnation, the next step is to analyze and evaluate the data. The aim
of this analysis is to evaluate the quality and reliability of the data, identify gaps and
inconsistencies, and draw conclusions on the accuracy and confidence of the data. In addition,
this will help determine what additional data and information will be needed to support
longer-term activities and decisions.
3. Identify Waterbodies: The next task is to pull together the information in a meaningful
form to serve as a basis for priority-setting a.Qd decision-making. The data should be arrayed
in a manner that indicates the degree of impairment for various waterbodies, and described
the basis for that decision. At a minimum, the assessment should distinguish between two
levels of data: monitored and evaluated. The first level or "monitored waters" applies to
waters where conclusions are based on current, site-specific ambient data. The second level or
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"evaluated waters" applies to waters where conclusions are based on earlier ambient data,
information on sources of pollution, predictive modeling, fishery surveys, citizen surveys, and
other anecdotal data. Based on this preliminary waterbody assessment, States should also
draw initial conclusions on the need for future water sampling, analysis, and related data
gathering.
The assessment process should be completed by April 1988, and will be submined as part of the
State's FY 1988 ~"305(b) repon.
To accomplish this work, a State agency could work through its traditional channels. However,
EP A actively encourages States to expand their horizons, and to seek input from all informed
parties during all three steps outlined above. Opening the process can lead to new data, information
and ideas, and can also generate a broad-based coalition of suppon for the assessment itself. EP A
is not mandating a particular forum or format for promoting this expanded involvement, but urges
States to make every effon to involve their informed public.
In addition, because the ~305(b) process is being used to meet severalWQA mandated assessments
that EP A must review and approve, EP A will offer technical assistance and will be available for an
active, cooperative role in this process. EPA is required by various provisions of the WQA to
review and approve State assessments with anendant public participation requirements. Where a
State uses an open, collaborative approach to the assessment, with broad participation by water
quality experts and the informed public, EP A will likely be required to exercise much less review of
the resultant assessment than where a State chooses to rely on a more closed approach to
information gathering.
In either case, the assessments will have to meet minimum statutory requirements, which include:
.
A description of the process the State used to complete the assessment;
A summary of all information collected, analyzed, and used, including outside sources
of data;
.
.
A discussion of the nature, extent and results of public and expen participation,
especially any new forms/forums used to involve the informed public;
A description of the State's findings in terms of data gaps;
.
.
A summary of the overall dimensions of the State's water quality problems; and
An explanation of how the State prepared its assessment of the waterbodies.
.
Step 2: Water Resource Targeting (Summer 1988)
This step is the heart of the sews process, and involves identifying the sequence for protecting
resources. The objectives are to:
.
Arrange priorities in order to target water resources for immediate control action; and
Identify the most important water resources for further study, as necessary (for example,
intensive surveys, new water quality monitoring, and data/information collection
activities, etc.)
.
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This guidance does not provide a prescriptive ranking and targeting procedure that States must
follow. Rather it provides a'general framew~rk and a set of targeting criteria that States should
consider during the targeting stage of the process. A national workshop involving participants
representing Federal, State, local and environmental groups will be held in Spring 1988 to discuss
various approaches to targeting and the results of the workshop will be shared with all States.
The waterbodyassessment conducted in Step 1 provides information on the entire range of a
State's water quality problems. It is likely that this process will result in a fairly long list of
problem areas that represent a substantial workload. As a practical matter, therefore, States will
probably fInd it both useful and necessary to carve out a subset of work for the concerted action
within the multi-year time frame of the sews. This will be especially necessary for nonpoint
source programs, where the current level of base activity is very low. EP A is recommending that
this be accomplished based on a comparative evaluation of the State's waters. The guiding
principle for this step is to maximize environmental benefIt by devoting resources and efforts to
water problems in a priority order that recognizes the values of the waterbody in question, the
benefits to be realized from various control actions (including evidence of local public interest and
support), and the controllability of the problem(s).
Since different governmental agencies, groups, and individuals place a different value on water
resources for a number of reasons, the objective of the ranking and targeting process is to foster a
balanced approach that results in the targeting of water bodies that reflects an evaluation of relative
value and benefIt. In order to achieve that level of confIdence, the following criteria should be
considered: .
1. What waterbodies are most valuable from various perspectives -- aquatic habitat, recreation,
and water supply for example?
2. What waterbodies are subject to adverse effects from both pollution and aquatic habitat
destruction (wetlands), and can be impacted by water programs?
3. What tools are available to address the waterbodies identified?
4. What areas are most likely to be improved through governmental action?
5. Which problems are most amenable to the available tools and controls?
6. What is the degree of public support (local or statewide) to protect a particular aquatic resource?
7. How willing are other governmental agencies to take steps to use their tools and resources to
help address the problem?
8. Where would "combined actions" offer the greatest benefIt relative to the value of the aquatic
resource?
Water resource-based targeting is an effort that may be carried out as follows:
1. Group waterbodies based on the most serious problems: While this is not an exact
science, there are quantitative and surrogate indicators of use and/or use impairment that the
State can use to make meaningful and defensible groupings of waterbodies in something as
simple as high/medium/low categories; and
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2. Select areas for immediate control action and identify the most important areas
for further study: This involves looking at various combinations of short- and long-tenn
actions, controls, and management plans that offer the greatest potential for achieving
environmental benefits and meeting overall water program goals.
The State may choose to approach this process nan-owly on a program-by-program basis, or may
opt to focus more broadly across programs and adopt a watershed or geographic-based plan that
combines the tools and resources of several water programs. The process is not one with
"scientific validity." Rather it is one that relies on using both quantitative data and surrogate
indicators of use and/or use impairment, as well as expert judgement, to make meaningful,
defensible groupings of waterbodies.
While State environmental agencies are responsible for determining priorities, the overall goal of
this step is to end up with a meaningful targeting of waterbodies that helps the State direct its
activities. Consequently, public participation is vital to the success of the targeting phase to
generate the necessary consensus and support for future implementation and funding. EP A urges
States to expand their existing public involvement activities, and to consider using public interactive
workshops and invited public experts. To support States that choose to follow this approach, EPA
will provide training and technical assistance, as well as financial assistance to help States develop
meaningful public participation programs.
.
Step 3: State Management Plans (Fall 1988)
At the end of the first two steps, the State should have a sense of strategic direction. The last step
involves converting these concepts into a management plan to guide its actions over a multi-year
period. This plan should identify an approach, set out a general schedule for accomplishing the
overall mission (including some broad interim milestones for accomplishment), and explain how
resources and efforts will be directed to protecting and/or restoring aquatic resources and habitat.
In short, a management plan or a set of interrelated action plans provides the connection between
the strategic direction and the State's annual work plans for carrying out the work over a multi-year
period.
The SCWS addresses the following:
1. Scope of Coverage: The scope of a management plan depends upon whether the State
elected to use a comprehensive, integrated approach or a more traditional programmatic
approach. So long as WQA requirements for specific management plans (nonpoint source,
Clean Lakes, estuaries) are met, the State may submit either one comprehensive management
plan or one that consists of multiple plans covering each of its program areas. In either case,
the submission should pull together the results and conclusions from Steps 1 and 2
(assessment/targeting), explain how the data and information were translated into the
management plan and recognize the interconnections of water programs. .
2. Sequence of Actions: The management plan should address problems through a sequence
of activities and control efforts, and should describe how the State plans to address relative
priority problems in the appropriate order. Since the SCWS is multi-year, it should discuss a
proposed schedule in general terms, set out a challenging but realistic timetable, and establish
some interim milestones for accomplishment. Where a State plans to shift its base level water
program to a geographic or watershed approach in order to deal more effectively with
cross-medial cross program problems. it should explain how this will be caITied out without
undermining the integrity of its base level program.
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States are encouraged to use innovative approaches to pull together their information and decisions.
For example, a management plan may be a separate introductory chapter to the State's annual
program plan or may be incorporated into a State WQM plan, so long as it is multi-year and
recognizes the interconnections among water programs. On the other hand, it may be a separate
document that forms the basis for annual work plans in the future. EP A would look favorably on
other models or formats, and encourages States to use their ingenuity in displaying the materials
and the sequencing of actions.
The sews should be completed by the beginning of FY 1989 (October 1, 1988). It should:
.
Describe the process the State followed in developing its sews by updating the
description from Step 1 (assessment) to reflect what happened in Step 2 (targeting);
Discuss the nature, extent and results of public and expert participation, as well as any
plans to involve the informed public on a continuing basis;
.
.
Identify the waters that have been targeted for immediate control action, and explain the
means to reduce the pollutant loads and aquatic habitat destruction, including.
management plans/programs, individual controls on point and nonpoint sources, and
methods/procedures; .
Describe the most important data gaps and areas for further study, and highlight any
plans to generate the additional data and information necessary to make future decisions
on the nature and extent of the problem and the appropriate control solution, including
assistance most appropriately provided by EP A (research, technical assistance, training);
.
.
Outline a multi-year schedule for addressing problems in a sequential fashion based on
appropriate priorities. This schedule should address four or more years of strategic
planning activity;
Discuss the current legal and regulatory authorities available to suppon planned
activities, as well as potential sources of funding and personnel to support
implementation activities; and
.
.
Describe future plans for establishing longer-term working relationships with other State
programs and/or agencies to assist with the implementation of activities in a coordinated
manner.
Developing and Updating Management Plans in Future Years
In FY 1989, States that developed multi-year management plans may need to update these
documents to complete integration of key longer-term activities that will be necessary to fully
implement the surface water toxics provisions of the WQA. These changes may include expanding
and/or setting priorities for new water quality monitoring for toxics, as necessary. States may also
choose to update other aspects of their sewSs as a result of new information.
In addition, FY 1988 is the first year States will have an opponunity to develop sewSs, and not
all States will choose to participate. In addition, there may be States that begin the process in FY
1988, but are unable to complete the entire exercise in the recommended timeframes set forth in this
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guidance. In FY 1989, therefore, some new States may choose to develop sewSs through a
targeting and ranking exercise, and some States may complete the work commenced in FY 1988.
To assist in these efforts, EPA headquarters will promote transfer of information and ideas
generated by States thin successfully completed the sews exercise in FY 1988.
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APPENDIX 1
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APPENDIX 1
The Water Quality Act of 1987 (wQA) represents a comprehensive revision of the Clean Water
Act, and maI).dates a number of new State water pollution control initiatives to be carried out in
addition to ongoing water pollution control responsibilities. Several of these new WQA provisions
require Sates to use a similar approach of information collection, assessment, and development and
implementation of control mechanisms or management plans. Although each of these mandates
might be carried out independently under its separate program authority, it makes more sense to
combine these activities wherever possible, leading to comprehensive, integrated solutions to water
pollution.
There are four principal provisions of the WQA that involve information collection, assessment,
and control solutions:
~316: Management of Nonpoint Sources of Pollution: By August 1988, each State
must prepare an assessment and management program for nonpoint source pollution. The
assessment stage must:
.
Identify affected waters: a list of navigable waters which, without additional action to .
control NPS, cannot be expected to attain or maintain water quality standards (WQS) or.
beneficial uses;
.
Identify sources 01 pollution: categories and subcategories, or where appropriate
particular nonpoint sources which add significant pollution to each portion of the
identified waters in amounts which contribute to not meeting WQS or meeting beneficial
uses;
.
Describe cOnJrols:
Process, including intergovernmental coordination and public participation for
identifying best management practices (BMPs) and measures to controVreduce
pollution from each category/subcategory/particular NPS; and .
State and local programs for controlling NPS pollution and improving water
quality, including programs receiving Federal assistance under WQA provisions
for grants for NPS and groundwater protection.
The WQA also sets forth specific requirements for the contents of State management programs, and
provides that, to the maximum extent practicable, States must develop and implement their
management program on a watershed-by-watershed basis within the State.
~308: Individual Control Strategies for Toxic Pollutants: This provision of the WQA
requires States to undertake a progressive program of toxics reduction. By February 1989, each
State must:
.
Identify affected waters:
A list of all waters for which, after application of required technology-based
controls, cannot be expected to attain or maintain WQS due to toxic pollutants, or
attain or maintain that water quality necessary to protect beneficial uses due to
point source or NPS discharge 01 toxics, conventional or nonconventional
pollutants (this is the so called "long list" of waters);
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As a subset of above, a list of all waters which, after application of required
technology-based controls cannot reasonably be anticipated to attain or
maintain WQS for 9307( a) toxic pollutants due to either point or nonpoim
source pollution;
'-A list of all waters for which applicable WQS cannot be achieved after
technology-based controls due entirely or substantially to point source discharges
of 9307(a) toxics (this is the so called "shon list" of waters).
.
Identify the Sources of Pollution: for each segment identified on the "shon list,"
determine the specific point sources discharging any toxic pollutant that is preventing use
or impairing water quality, and the amount of each toxic pollutant discharged by each
source.
Implement Controls: for each segment on the "shon list," develop an individual control
strategy to reduce the discharge of toxic pollutants (through permits in combination with
existing point and nonpoint source controls) sufficient to achieve WQS within three
years. As a matter of policy, EP A is also requiring individual control strategies (through
permits) to be developed to address all known toxicity problems, including chlorine,
ammonia, and whole effluent toxicity. .
In a related provision (~308(d», States are directed to develop toxic chemical WQS and narrative
criteria based on biological assessment methods.
.
~31S: Clean Lakes: This provision of the WQA reaffIrms that lakes are a vital national
resource, and establishes a demonstration program. By April 1988 (and every two years thereafter)
each State is required to submit a repon on lake water quality that must:
.
Identify affected waters:
List and classify by eutrophic condition all publicly owned lakes;
List arid describe all publicly owned lakes for which uses are known to be
impaired (including lakes not meeting WQS or requiring control programs to
maintain WQS) and lakes where water quality has deteriorated as a result of acid
deposition;
Describe status and trends of lake water quality, including nature/extent of
pointlNPS loading and extent of impairment, particularly with respect to toxic
pollution.
.
Identify sources: N/A
Describe controls:
.
Procedures, processes, and methods (including land use provisions) to control
sources of pollution;
Methods and procedures, in conjunction with appropriate Federal agencies, to
restore lake quality;
Methods and procedures to mitigate the effects of harmful acidity, including
innovative methods of neutralizing and restoring buffering capacity of lakes and
methods of removing toxic metals and other toxic substances mobilized by high
acidity.
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In order to be eligible for grant assistance, States must submit the required reports that cover these
elements.
~317: National Estuary Program: Under these new provisions, Congress declares that it is
national policy to maintain and enhance the water quality in estuaries and provide for the biological
integrity of these waters. The Governor of a State or the EPA Administrator may nominate an
estuary of national significance, and convene a management conference to:
.
In selected waters, identify:
Trends in water quality, natural resources and uses of estuaries;
Data on toxics, nutrients, and natural resources to identify causes of environmental
problems;
In selected waters, identify: the relationship between inplace loads and point/NPS
pollutant loadings, and potential uses of the zone, water quality, and natural resources.
.
.
.
Develop plan:
Comprehensive conservation and management plan that recommends priority
corrective actions and compliance schedules for point/NPS sources of pollution;
Coordinated implementation by the States as well as Federal and local agencies.
The WQA provides for grants to assist in work necessary to develop a conservation and
management plan.
While each of these four provisions addresses a specific problem and sets forth specific
requirements, there are some common denominators among the various sections: collecting data
and information, identifying affected waters, identifying the sources of pollution, and developing
controls (individual control strategies, management programs or plans, or methods/procedures).
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I
Although these common themes lend themselves to an integrated, strategic approach to carrying out
the various WQA initiatives, it is important to recognize that other mandates under the WQA place
constraints on the degree to which activities can be merged. These are discussed in the text of the
SCWS guidance.
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APPENDIX 2
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DATA SOURCES APPLICABLE TO ASSESSMENT AND TARGETING
OF WATER BODIES
I. EPA -Data Sources
,-
A. ComputArized Data SY8t888
EPA maintains the followinq water quality-related data bases,
containinq state and EPA data. Most of this information is
linked toqether for access usinq the reach file codinq structure
under STORET. Permit Compliance System (PCS) data is available
directly throuqh PCS coordinators (located in reqions and states)
or throuqh Reach File Systems in related pilot project reqions
(Reqions I, II, III, IV, and V).
These data bases, individually and through linkaqes that have
been and are beinq developed, can be very useful in assessinq
water quality. For instance, ambient water quality data in the
STORET system's Water Body File can be compared with state water.
quality standards or EPA water quality criteria quickly to \
identify those water bodies where standards have been exceeded.
Reach File
a
Nation'. major water bodies divided into some 70,000
individual seqments (reaches).
Reaches assiqned numbers/name.
Locational data includes latitude/lonqitude, state and
county codes .
Associated Reach Characteristics File,contains physical
characteristics for seqments in Reach File--slope,
elevations, width, depth, velocity, etc.
Associated Gauqe File contains annual mean and low flow
monthly mean flow estimates
Linked to Drinking Water Supply File, qivinq location of
water supply sources/intake.
and
o
a
o
o
o
Contact:
Bob Horn, OWlS, Criteria and Standard. Division
EPA Headquarters
Phone: FTS 382-7103/ (202) 382-7103
Water ~litv File
o
o
Water qualitY'data from about 200,000 stations
Locational data for each station-- ID No., reach assiqnment,
latitude/longitude, state/county
Data on hundreds of parameters, .ost common of which include
pH, temperature, DO, solids, nitroqen, .etals
Info on use impairment from ASWIPCA State's Evaluation of
Proqress (STEP) and NPS reports
National Urban Runoff Program (NURP) study data
a
o
o
(listinq continued on next paqe)
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Contact:
2
~TORET CUstomer Support
Office of Information Resources
EPA Headquarters
FTS 382-7220 ~ (800) 424-9067
(Note: Until recently, STORET and the Water Quality File were
synonYmous, but STORET is now becoming a much broader
system linking a number of EPA data bases.)
Management
Industrial Facilities Discharae File (IFD)
o
o
o
Data on 60,000 industrial and municipal discharges
Industrial SIC codes, reach assiqnments, effluent data
Information on indirect discharges to POTWs
Contact:
Phil Taylor
OWRS, Monitoring and Data Support
EPA Headquarters
FTS 382-7046/ (202) 382-7046
Division
Permit ComDliance System
o
o
Records on 65,000 NPDES permits
Locational data on permitted facilities, including link to
Reach File
POllutant-specific discharge limits
Data from Discharge Monitoring Reports (DKRs)
Automatic detection of violations of effluent limits
Special feature of link to STORET provides estimates of
effluent dilution ratios (average or low stream flow)
o
o
o
o
o
o
Contact:
~
~
Larry Reed
OWEP, Enforcement Division
EPA Headquarters
FrS 475-8373/ (202) 475-8373
Phil Taylor (PCS/STORET link)
--see IFD File listing for phone number
Data on the distribution, abundance, and condition of
aquatic organisms, including fish tissue analysis
Descriptions of habitat at sampled sites--substrate type,
streambank stability, canopy type
Generates diversity indices/community structure analyses
Will incorporate CETIS (aee below)
o
o
Contact:
Barbara Lamborne
Office of Information Resources
EPA Headquarters
FTS 382-7220/ (202) 382-7220
Management
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3
ComclexEtfluent Toxicity Information System (CETIS)
o
Data ~rom whole effluent toxicity tests
David Eng
OWEP, Permits Division
EPA Headquarters
FTS 475-9522/ (202) 475-9522
Water BodY File (under development)
Contact:
Computerized system of recording information needed to
prepare 305(b) reports
Correlated with Reach File segments.
To contain assessment data, including type(s) and magnitude
of impairment, categories of point and nonpoint sources
o
o
o
Contact:
Bruce Newton
OWRS, Monitoring and Data Support Division
EPA Headquarters
FTS 382-7074/ (202) 382-7074
STORET Noncoint Source Stream Station File
data on 700 stations from 22 states estimated to be
primarily impacted by NPS
STORET number, river reach number, state, county
relative contribution of NPS in wet and low flow conditions
of nine general pollutant types
o
o
o
Contact:
Steve Dressing
OWRS, Criteria and Standards
Nonpoint Sources Branch
EPA Headquarters
FTS 382-7110/ (202) 382-7110
Division
FederalR8cortina Data System lFRDS)
Inv8ft~ory of public water supply systems in the u.S.
Li.~in9 of exceedences of national drinking water standards
in ~r8a~.d water (not in raw water 8upply)
Some information on location of raw water supplies for some
systems .
o
o
o
Contact:
Debbie Ross
Data Management section
Office of Drinking Water
EPA Head~arters
FTS 382--2804 / (202) 382-2804
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4
Needs surv.v File
D~~a trom ~he 1986 Needs Survey covering approximately
24,0~0 exis~ing and proposed POTWs in need of construction
Approxima~ely 200 data elements including tacility
characteristics and location, construction costs, population
served, ettluen~ charac~eristics, and more
o
o
o
Linked to the Reach File, PCS
Contact:
Lee Pasarew, OMPC, Municipal Facilities Division
EPA Headquarters
Phone: FTS 382-7251/(202) 382-7251
Grants Intormation Control Svstem CGICS}
Data on all EPA construction grants projects tor POTWs
Con~ain. administra~ive, tinancial, ~echnical, and project
s~atus intormation on each EPA gran~
o
o
o
Linked ~o the Needs Survey and PCS
Contact:
Sylvia Bell, OMPC, MUnicipal Construction Division
EPA Headquarters
FTS 382-5837/ (202) 382-5837
B. other EPA Data Source.
'.
Reaional Prioritv We~lands Lis~s
Lis~. ot .os~ valuable (productive, unique) and vulnerable
wetlands in each EPA Region
Prepared by EPA Regional Ottice.
o
o
Con~act:
ottica ot Watland. Protection
SPA Headquarters
PTS 382-7496 / (202) 382-7496
(al.o con~ac~ Reqional wetlands s~att)
O~her Proaram-Soecitic Guidance Ce.a.. 304Cl}. 319. 3l4}
o
under 304(1), reach-by-reach lis~ing ot ~oxic pollutants and
discharges
Contact:
Monitoring and Da~a Support Division
ottice ot Water
EPA Headquarter.
FTS 382-7040 / (202) 382-7040
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II.
5
Deoartment of Interior Data Sources
Water Data Storaae and Retrieval System (WATSTORE)
o Manaqed by USGS
o Water quality data for 5,000 samplinq stations
o Data on peak and daily flows from some 8,000 stations
o Incorporates data trom USGS's NASQAN system
(Note: all water quality data from WATSTORE included in STORET)
Contact:
OWen Williams
Water Resources Division
U.S.G.S.
Reston, VA
(703) 648-5684
National Water Data Exchanae (NAWDEX)
Manaqed by USGS
Listinq ot all orqanizations nationwide collectinq water
data
Master Water Index provides intormation on about 400,000
data collection sites
o
o
o
Contact:
OWen Williams
Water Resources
U.S.G.S.
Reston, VA
(703) 648-5684
Division
'.
National Wetlands Inventorv
(partially completed)
o
o
o
o
o
Manaqed by U.S. Fish and Wildlife Service
Computerized mappinq scheme tor entire country
Veqetation data--3500 wetlands species
Ecological community types
Cla..itication accordinq to wetlands types
Contac1::
Bill Wilen/Tom Dahl
Pishand Wildlife Service
u.S. Department ot Interior
Washinqton, D.C. 20240
(202) 653-8726
Nationwide Rivers Inventorv
Developed by National Park Service
List of over 1,500 river seqments (around 62,000 miles)
thouqht to have sufficient natural or cultural attributes to
qualify for National Wild and Scenic Rivers System; excludes
rivers in System and official candidate rivers
o
o
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6
Nationwide Rivers Inventory (cont.)
Contact:- Glen Euqster
.- Division ot Park anc:l Resource
.- National Parks Service
Philac:lelphia, PA
(215) 597-7386
Planninq
Enc:lanaerec:l SDecies Intormation Svstem lESIS)
o
o
o
o
o
o
o
Covers species listed unc:ler tederal Enc:lanqerec:l Species Act
Otticial status (endanqerec:l, threatenec:l)
Factors contributinq to present status
Habitat types with which species a.sociatec:l
Present/past location by county/state
Watershec:ls/subunits where tound
Counties/states with desiqnated critical habitat
Contact:
Michael J. Rein
Ottice ot Endanqerec:l Species
Department ot Interior
Washinqton, D.C. 20240
(703) 235-2760
Annual ReDort ot Lanc:ls Under Control ot the U.S. Fish anc:l
Wilc:llife Service
o
List ot all National Wildlite Retuqes,and other lanc:ls unc:ler
the control ot the Pish and wildlite Service
Division ot Realty
Fish and Wildlite Service
U.S. Department ot Interior
washinqton, D.C. 20240
(202) 653 7650
National Natural Lanc:lmarks Proaram (National Park Service)
Contact:
o
A revister ot siqniticant natural areas which illustrate the
diveraity ot the natural heritaqe ot the U.S.
Map. ot area.
Into on ecoloqical and geoloqical characteristics
Into on thre.~s
o
o
o
Contact:
Harc:ly Pearce
National Register Division
National Park Service
Wash, D.C. 20240
(202) 343-9525.
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7
Land Use and Data Analvsis (USGS)
Reports land use by 40 different land use types for entire
USA -
Most.~data is from middle 1970 's
Data-based on LANDSAT satellite imaqery
o
o
o
Contact:
National Cartoqraphic
USGS
Reston, VA
(703) 648-6045
Information Center
Inventorv of Private Recreation Facilities
o
o
Inventory of private recreation facilities
Data reported by state, county and town
Contact:
Paul Solomon
National Park Service
Wash., D.C. 20240
(202) 272-3730
National Survev of Fishina. Huntina and Wildlife Associated.
Recreation
Includes fishinq and huntinq information on expenditures,
times use, location and .ocio-economic characteristics
Covers non-conaumptive wildlife recreation
o
o
Contact:
"
Michael Hay
U.S. Fish and Wildlife
Washinqton, D.C. 20240
(202) 343-4902
Service
III. Mational OCeanic and At80aoheric Adainistration
National E.tuarine Inventorv
Cover. 92 major e.tuarie.
Da~:on e.tuary dimen.ion., drainaqe area, .tratification
cl...itication, fre.hwater inflow rate., flow rations, and
tidu ...
Land u.. information for 25 cateqorie. of land use
Computerized data ba.e
o
o
o
o
Contact:
Dan Ba8ta
NOAA
Washinqton, D.C.
(202) 443-8843
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8
National Coastal Wetlands Data Base
o
o
Type and extent of coastal wetlands by estuary
Based on statistical sample of 3000 National Wetland
Contact: Dan Basta
NOAA
(202) 443-8843
National Shelltish Reaister
o
Classifies shellfish beds accordinq to water quality and
productivity
Historical data available for some areas
o
Contact: Dan Basta (See above)
Shoreline Characterization
o
Characterizes estuarine shoreline accordinq to
shoreline types; and dredqinq activities
Shoreline type is reported on color coded NOAA
charts
eiqht
nautical
o
Contact: Dan Basta (See above)
National Coastal Pollutant Discharae Inventorv
o
Comprehensive data base ot pollutant aischarges enterinq
estuarine waters
Source cataqories include point sources, nonpoint sources,
upstream sources, oil and qas operations, dredqinq
operations and accidental spills.
Computerized data base
o
o
Contact: Dan Basta (See above)
IV. ~8r Federal Data Source.
National ...ources Inventory
o
o
National survey based on 160 acre units
Data on land use, conservation practices, soil type, erosion
Contact:
Jett Gable
Soil Conservation Service
U.S.D.A.
Washinqton, D.C. 20013
(202) 447-4530
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9
Land Areas ot the National Forest System (U.S. Forest Service)
o
o
Orqanized by state and county
Includes into on desiqnated wilderness areas, primitive
areas, recreation areas, wildlite preserves
Contact:
Forest Service
Department of Aqriculture
Washinqton, D.C. 20013
(202) 235-8105
Recreation Intormation Manaaement System
o
o
Recreational tacilities and areas in National Forest System
Data on types ot recreation, visitor days, participation by
activity
Contact:
Gene Welsch
Recreation Manaqemant
U.S. Forest Service
Washinqton, D.C. 20250
(202) 447-2311
Division
IV. Other Data Source.
State Natural Heritaae Proarams
o
Desiqned to identity elements essential to preservation of
bioloqical diversity
Inventorie. on existence and location ot rare and endanqered
plants and animal.
Inventorie. on unique plant communities, aquatic systems
OVer halt the stat.s have such proqrams, developed in
cooperation with The Nature Conservancy
o
o
o
Contact.:
state Natural Heritaqe proqram Ottice in your state
Listinq ot state Heritaq.
Larry Thomas
The Nature Conservancy
1800 North Kent st.
Arlinqton, VA 22209
(202) 841-5300
Priority Aauat~tes For Bioloaical Diversitv Conservation
proqram contacts:
o
Listinq, by state, ot waters containinq key elements ot
bioloqical diversity
Developed with assistance ot state heritaqe proqrams
o
(listinq continued on next paqe)
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10
Priority Aauatic sites (cont.)
Contact: Bob Chipley
.. The Nature Conservancy
.. 1800 North Kent st.
'Arlington, VA 22209
(202) 841-5300
Breedina Bird Survey
o
o
Census of 200 species by county
Historical data available
Contact:
Greq Butcher
Cornell Lab of
Ithica, N.Y.
(607) 255-4999
Ornitholoqy
Socio-Economic Environmental Demoarachic Info. System
o
Collection of socio-economic, environmental, demographic and
health related data bases
Covers geoqraphic reqions ranqinq from nation to minor civil
divisions
computerized data base updated annually
o
o
Contact:
Deane Herril
Lawrence Berkeley Lab
Department of Enerqy
Berkeley, CA
(415) 486-5063
'-.
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SUMMARY OF RESPONSES TO MAJOR COMMENTS RECEIVED
ON
. STATE CLEAN WATER STRATEGIES:
MEETING THE CHALLENGES OF THE FUTURE
The following discussion responds to the major comments received
on the "Final Draft: State Clean Water Strategies (SCWSs)." It
covers both responses to public comment that were incorporated
into the final document, as well as responses to significant
comments that did not lead to changes.
General Comments
One commenter felt the timeframes outlined in the SCWS would not
allow the necessary time to adequately address the process, and
suggested that development of a SCWS should occur over the next
several years. In the final guidance, we have provided one
additional quarter for completion of steps two and three (tar-
geting and management plan development). We have also added a
concluding section that indicates that some states may not
complete the entire process in one year, and that some new
States may decide to undertake a SCWS in FY 1988 and beyond.
The SCWS is a multi-year exercise that. is designed to begin
impacting annual work plans in FY 1989, so State managemerit
plans must be reasonably complete by next Fall in order to
impact FY 1989 work plans.
Two commenters noted that there was a need to restore the concept
of watershed or geographic-based approaches that had appeared in
earlier versions. One commenter also wanted to see some mention
of how SCWSs can be used to mesh current Clean Water Act (CWA)
programs (such as wetlands protection) with new initiatives
under the Water Quality Act (WQA). The final guidance has been
modified to incorporate both of these concepts.
One commenter noted that the multiplicity of conceptually
related guidance documents was confusing and might result in
regulatory requirements and deadlines getting lost. This commen-
ter (and one other commenter) suggested attaching the other
guidance documents as appendices. Because some of the related
guidance documents will not be available at the same time the
final SCWS is published, we have added a listing of the titles
of the specific documents on the inside front cover of the
SCWS, again noting that the requirements and deadlines in these
specific documents (and the statutes) should be met. .
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-2-
Finally, there were several commenters that felt the guidance
should be more directive about matters such as requiring States
to produce outputs consistent with the guidance, adding a
fourth section to address implementation, and using EPA authori-
ties under S303(e) to review and approve the sews management
plans. These recommendations were not included because the
nature of these changes seemed inconsistent with the "voluntary"
nature of the sews exercise. .
Public Involvement
A number of commenters addressed the subject of public partici-
pation. Some advocated strengthening the public participation
component of the sews, and others expressed concern about the
potential burden caused by elaborate public participation
requirements. EPA views the public participation element as a
cornerstone of the sews exercise because of its value in generat-
ing broad-based support for both action and funding. We have
made no changes with respect to the public participation discus-
sion in the final sews guidance.
Data
Three commenters noted concerns with the data and information
requirements in the final draft sews. One cited over-reliance
on existing data; another said EPA should actively discourage
use of old, "evaluated" data; and the third noted that the
guidance should place more emphasis on longer-term data collec-
tion. We have made minor adjustments to the final guidance to
clarify that the States' ability to meet near-term WQA require-
ments and deadlines will depend largely on use of existing,
readily available data, but that longer-term efforts will
require new monitoring and data collection activities.
Relationship Between sews and Grant Funding
A number of commenters noted that there is no basis in law for
awarding Federal funding to States based on the sews, particu-
lary future 5319 funding (if any). EPA has responsibilities
for awarding and managing Federal grants to ensure State consis-
tency with Federal regulations, including ensuring that States
adhere to statutory and regulatory requirements as well as
annual program guidance published by EPA. EPA believes that
the process outlined here will facilitate State efforts to meet
statutory and regulatory requirements. The sews is a voluntary
exercise. To the extent that a State has completed a sound
sews that builds on the requirements and deadlines that must be
met under S3l9 of the law, EPA will take this management plan
into consideration at the time of annual S3l9 grant negotiations.
Completion and approval of a sews would be a primary consider-
-------
n
-3-
ation in awarding funds for priority NPS activities. Funds for
basic NPS activities will be allocated by formula without
consideration of sews completion.
Targeting/Setting priorities
Several commenters felt the concept of targeting was not possible
and/or not desirable for a variety of reasons. EPA agrees that
there are difficulties associated with targeting, and proposes
to hold a national workshop to discuss various approaches to
targeting. The purpose of this workshop is to familiarize
States with available techniques in an effort to enhance the
opportunities for successful outcomes. As in the case of
public participation, however, targeting is a cornerstone of
the sews concept and is essential to making sound decisions
and for setting priorities for action over a muiti-year period.
He have made no changes to the targeting discussion in the
final guidance document.
coverage of ~304(1) Requirements
Two commenters felt that the sews should cover the initial
phase of work under ~304(1). As noted in the guidance, however,
the statutory requirements and deadlines for this particular
provision do not allow States any discretion regarding either
the timing or location of the control measures they are required
to put in place under ~304(1). Since the concept of targeting
involves setting priorities for action, and thereby implies
that some work will get done now and that other work will be
delayed until future years, there is an inherent conflict
between the two. States should consolidate their assessment
activities under ~304(1) with other assessments underway, but
individual control strategies must be in place by the statutory
deadline. .
sews is Voluntary
Two commenters noted that, while the sews is "voluntary" in
nature, it is being viewed as mandatory in some Regions and
that certainL_key clauses in the guidance implied it was manda-
tor"y. We have made minor modifications to the guidance to
clarify that it is voluntary, and we will continue working with
the Regions to ensure that they are implementing the concept
consistent with the spirit and intent of the guidance.
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