DRAFT GUIDELINES
   FOR AREAWIDE
 WASTE TREATMENT
    MANAGEMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
    WASHINGTON, D.C. 20460
         MAY 1974

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                                        DRAFT
         DRAFT GUIDELINES
               for


 AREAWIDE WASTE MANAGEMENT PLANNING
           SECTION  208
FEDERAL WATER POLLUTION CONTROL ACT
         AMENDMENTS OF 1972
  Environmental Protection Agency
     Washington, D. C.  20460
          May 3, 1974

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                                                             DRAFT
                            FOREWORD
     The Federal  Water  Pollution Control Act Amendments  of  1972 requires
the control  of point  and  nonpoint sources of water pollution  in meeting
the goals of the  Act.   Section 208 of the Act encourages  that  all activities
associated with point and nonpoint source problems  be  planned  and managed
through an integrated areawide waste treatment management program.  These
draft guidelines  apply  to those areas with complex  problems as designated
by the states for Section 208 planning and management.

     The guidelines are intended to assist the designated local planning
agencies for those areas in developing an areawide  plan  and implementation
program consistent with the minimum planning requirements and  procedures
for obtaining grant assistance set forth in the proposed  grant regulations
(40 CFR Part 35,  Subpart F).  Guidelines for defining  the responsibilities
of the states in  nondesignated areas will be forthcoming.

     This draft is scheduled to be revised as appropriate and  published as
the first edition in  late summer of 1974.  Any comments  and suggested
revisions should  be addressed to the Planning Assistance  Branch,  Water
Planning Division (AW-454), Office of Water and Hazardous Materials,
Environmental Protection Agency, Washington, D. C., 20460.
                                                Mark  A.  Pisano
                                      Director,  Water Planning Division

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                           TABLE OF CONTENTS
1.   Introduction
    1.1   Purpose
    1.2   Applicability
    1.3   Objectives of 208 Planning
    1.4   Plan Contents
    1.5   Planning Criteria

2.   Programmatic Relationships and Authorities

    2.1   Introduction
    2.2   Relationships Between Section 208 Planning and Other FWPCAA Provisions
         A.  Relationship between 208 and 303(e) Basin Plans
         B.  Relationship between 208 and Facilities Plans
         C.  Relationship between 208 Plans and 402 Permit Programs
    2.3  Relationship Between 208 Planning and Other EPA Programs
         A.  Relationship between 208 Planning and Air Quality Programs
         B.  Relationship between 208 and Solid Waste Programs
    2.4   Relationship between 208 Planning and Other Areawide Management Programs

3.   Planning Process
    3.1   Purpose
    3.2   Goals and Policies of the Act and Other Water Related Goals of
         the Planning Area
    3.3   Technical Planning
         A.  Purpose
         B.  Flow Chart
         C.  Inputs
             1.  Information from 303(e) Basin Plans and Facilities Plans
             2.  Information from NPDES Permits
             3.  Related Water Management Information
             4.  Technical Information
         D.  Planning Sequence
             1.  Assemble Existing Water Quality Data and Note Applicable
                 Standards
             2.  Identify Critical Water Quality Conditions
             3.  Construct an Inventory of Existing Dischargers
             4.  Projections
             5.  Segment Analysis
             6.  Determine Alternative Subplans for Treatment, Control  and
                 Flow Reduction Consistent with Eligible Waste Load Allocation
             7.  Screen Subplans to Select Leading Alternative Subplans
                 Consistent with Eligible Waste Load Allocations
             8.  Combine Subplans into Alternative Plans Consistent with
                 Eligible Waste Load Allocations

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    3.4  Management Planning
         A.  Purpose
         B.  Management Analysis
         C.  Development of Alternative Management Plans
    3.5  Combined Plan Evaluation and Selection
         A.  Combine Alternative Technical  Plans that Meet Standards with
             Alternative Management Plan Corresponding to Technical Plans
         B.  Compile Information on Alternative Areawide Plans
         C.  Compare Alternative Plans and  Select Final  Plan
             1.  Effects of Alternative Plans
             2.  Vary Alternatives if Necessary for Final Selection
         D.  Develop Detailed Description of Plan Features
         E.  Include Provisions  for Plan Revision and Updating
         F.  Plan Outputs
             1.  Technical  and Management Outputs
             2.  Provisions for  Plan Revision and Updating
             3.  Reports

4.  Detailed Considerations for  Land Use
    4.1  Introduction
    4.2  Pertinent Authorizations and Purpose
         A.  Federal Water  Pollution Control  Act
         B.  Typical State  Legislative Authorities
    4.3  Incorporating Land Use  Considerations in the 208 Planning Process
         A.  Introduction
         B.  First Phase
             1.  Establishing Land Use and  Water Quality Relationships
             2.  Analysis of Land Use Controls and Practices
             3.  Initial  Land Use Planning
         C.  Second Phase
             1.  Land Use Refinements
             2.  Final  Refinements

5.  Detailed Considerations for  Point Sources
    5.1  Introduction
    5.2  Municipal  Wastewater Facilities
         A.  Introduction
         B.  Inventory  Existing  Conditions  and Determine Existing  Flows
         C.  Estimate Future Waste Loads  and  Flows
             1.   Land Use and Development
             2.   Flow and Waste  Load  Forecasts
             3.   Sludge  Generation Forecasts
         D.   Develop and  Evaluate Alternatives
             1.   Flow and Waste  Reduction Measures
             2.   Industrial  Service
             3.   Sewers
             4.   Waste Management Techniques
             5.   Residual (Sludge)  Management
             6.   Location of Facilities
             7.   Regionalization

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             8.   Phased Development
             9.   Flexibility and Reliability
    5.3  Combined and Storm Sewer Discharges
         A.   Introduction
         B.   Inventory Existing Conditions
         C.   Estimate Future Waste Loads and Flows
         D.   Develop and Evaluate Alternatives
             1.   Flow and Waste Reduction
             2.   Alternative Control  Techniques
             3.   Location of Sewer Outlets
    5.4  Industrial  Wastewater
         A.   Introduction
         B.   Develop and Evaluate Alternatives
             1.   Flow and Waste Reduction
             2.   Minimum Effluent Limitations
             3.   Joint vs Separate Municipal and Industrial  Facilities
             4.   Pretreatment and Cost Recovery
    5.5  Other Point Sources
    5.6  Development of Alternative Subplans
         A.   Purpose
         B.   Continuous Point Source Subplans
         C.   Intermittent Point Source Subplans
         D.   Disposal of Residual Wastes
         E.   Screening of Alternatives
         F.   Description of Alternatives

6.  Detailed Considerations for Nonpoint Sources
    6.1  Introduction
    6.2  Statutory Requirements
    6.3  General  Approach of Nonpoint Source Control  Planning
    6.4  Identification and Evaluation of Nonpoint  Sources
         A.   Monitoring and Sampling to Identify Nonpoint Sources
         B.   Prediction of Nonpoint Source Loads
    6.5  Control  of Nonpoint Sources
         A.   Urban Stormwater Runoff
         B.   Construction Activities
             1.   Sediment
             2.   Chemicals
             3.   Biological Materials
         C.   Hydrographic Modifications
             1.   Channelization
             2.   Water Improvements
             3.   Urbanization
             4.   Dredging and Dredge Spoil Disposal
         D.   Land and Subsurface Disposal of Residual  Waste
             1.   Land and Subsurface Disposal of Liquid Waste
             2.   Land and Subsurface Disposal of Solid Waste
         E.   Agricultural  Activities
         F.   SiIvicultural  Activities
         G.   Mining Activities
                                    111

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         H.  Salt Water Intrusion
    6.6  Procedure for Selection of Feasible Nonpoint Source Controls
         to Meet Water Quality Standards and Goals
         A.  General
         B.  Relationship with Land Use Plan
         C.  Procedure for Selection of Controls
             1.  Cost and Effectiveness of Nonpoint Source Controls
             2.  Representative Data for Cost and Effectiveness
             3.  Estimation of Cost and Effectiveness Information
             4.  Develop Nonpoint Source Control Alternatives

7.  Regulatory and Fiscal  Controls
    7.1  Introduction
    7.2  Requirements of the Act
    7.3  The Regulatory Program
    7.4  Fiscal Controls
         A.  Pricing Policy
         B.  Taxation Policy

8.  Institutional Arrangements
    8.1  Introduction
    8.2  Requirements to be Met by the Areawide Management System
         A.  Allocation of Authorities and Need for Enabling Legislation
         B.  Required Authority
    8.3  Optional Approaches to an Areawide Management System
         A.  Responsibilities Performed Within the Areawide Management System
             1.  Coordination
             2.  Planning
             3.  Management
         B.  Optional Allocation of Responsibilities
             1.  Single Planning and Management Agency
             2.  Single Planning Agency and Single Management Agency
             3.  Single Planning Agency and Plural Management Agencies
         C.  Intergovernmental Aspects
             1.  Legal  Basis for Establishing s 208 Agencies
             2.  A-95 Review

9.  Financial  Arrangements
    9.1  Introduction
    9.2  Requirements of the Act
         A.  Capital  Construction Costs
         B.  Operational  Costs and Assessment of Revenue
         C.  Indirect (Overhead) Costs to Be financed
    9.3  Specific Problem  Areas
         A.  Capital  Construction Costs
         B.  Operational Costs and Revenue Assessment
         C.  Indirect (Overhead) Costs to Be Financed
    9.4 Other  Financial  Activities
                                    IV

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10.  Direct Resource Costs
     10.1   Introduction
     10.2   Basic Concepts in Identifying Resource Costs
           A.  Economic cost
           B.  Price levels
           C.  Interest rates
     10.3   Specific Cost Questions
           A.  Sunk costs and salvage values
           B.  Capital  and operating costs
           C.  Administrative costs
           D.  Accuracy of cost estimates
           E.  Present values

11.  Environmental, Social and Economic Impact Evaluation
     11.1   Purpose
     11.2   Environmental, Social  and Economic Impact Evaluation Process
           A.  Inventory Existing Conditions
           B.  Evaluation of the Existing Situation
           C.  Develop Baseline Projection
           D.  Evaluate Alternatives
     11.3   Environmental Effects of the Selected Plan

12.  Public Participation
     12.1   Introduction
           A.  Need for Public Involvement
           B.  Legal Requirements
           C.  Goals and Objectives of Public Involvement Programs
     12.2   Considerations for Development of a Public Involvement Program
     12.3   Timing of Key Public Involvement Issues
           A.  Initial  State
           B.  Design of Alternatives
           C.  Impact Assessment
           D.  Recommendation and Acceptance of the Final Plan
           E.  Implementation
     12.4   Public Participation and Program Development
     12.5   Program Evaluation
     12.6   Advisory Committee
     12.7   Institutional Alternatives for Representation of the General  Public

13.  Comparison of Alternatives and Selection of Plan
     13.1   Purpose
     13.2   The Plan Selection Process
           A.  Assessment of Alternative Areawide Plans
           B.  Development Recommended Plan
           C.  Hold Public Hearings to Present Proposed Plan

14.  Reports
     14.1   Report Structure
     14.2   Report on Annual Review of Plan

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15.  Plan Submittal, Review and Approval
     15.1  Introduction
     15.2  Local Review and Recommendation
     15.3  State Review and Certification of Approval
     15.4  EPA Review and Approval
Glossary


Bibliography

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                                                          DRAFT
                               CHAPTER 1

                             INTRODUCTION
1.1  Purpose

     The Federal Water Pollution Control  Act  Amendments of 1972 (hereinafter
referred to as the Act) address a myriad  of activities for controlling all
types of water pollution sources and problems.   EPA's overall approach for
dealing with these problems and for implementing the requirements of the
Act is set forth in the Water Strategy Paper.   Section 208 of the Act
encourages areawide management planning in  areas which, as a result of
urban-industrial concentrations or other  factors, have substantial water
quality control problems.  Regulations have been published (40 CFR Part 126)
on 208 area and agency designations and proposed (40 CFR Part 35, Subpart F)
on 208 planning grant applications.  This guideline presents an approach to
planning for areawide waste management under  Section 208.


1.2  Applicability

     This guideline is intended to assist 208 planning agencies in carrying
out their areawide waste management planning  responsibilities within designated
208 areas.  It applies also to other agencies  -- local, state, and federal --
that may be involved in the planning process  for those areas or in plan
review procedures.


1.3  Objectives of 208 Planning

     Through Section 208, local areas are provided a unique opportunity to
plan and manage a comprehensive program based  on integrated planning and
control over such activities as municipal and  industrial wastewater, storm
and combined sewer runoff,  nonpoint source  pollutants, and land use as it
relates to water quality.  Through a locally  controlled planning agency,
an area can select a plan that is cost effective and implementable.  Because
of the timing of the completion of the 208  planning effort, the plan should
be directed to meet the 1983 goals of the Act.   It should focus on an inte-
grated approach for identifying and controlling  the most serious water
pollution problems initially and, over time,  resolving the remaining problems,
where feasible.  Particular emphasis could  be  placed upon nonstructural
approaches to pollution control as a means  of  reducing the normally large
investments associated with traditional  structural measures.  The area
would also choose the management agency or  system best suited for assuring
implementation of the plan.   Periodic review  and updating of the plan and
management arrangements would enable timely changes in the plan in response
to changing conditions and  new information  within the area.  A sound approach
to areawide waste management planning should  be  based upon the above described

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 emphases  and  characteristics of Section 208.   In attempting to set forth
 such  an approach,  this guideline  incorporates  the following basic planning
 features:

      A.   Identify  problems. The pollution problems should be identified
      in terms  of their relative impact on water quality.  Similarly, exist-
      ing  institutional problems impeding solution of water quality problems
      should be identified.
      B.   Identify constraints.
      would  be  identified.
Both technical  and management constraints
      C.   Identify  possible solutions to problems.  All reasonable regulatory
      and  management control methods would be identified.

      D.   Develop alternative plans.  Alternative integrated technical and
      regulatory control methods for municipal and industrial wastes, storm-
      water  control, nonpoint source control, and growth and development
      would  be  combined  into areawide plans.  Comparable alternative options
      for  the management of these plans would also be identified.

      E.   Analyze alternative plans.  The alternatives would be evaluated in
      terms  of  minimizing overall costs, maintaining environmental, social,
      and  economic  values, and assuring adequate management authority, finan-
      cial capability, and institutional feasibility.

      F.   Selection of an areawide plan.   The selection should be based upon
      systematic comparison of the alternatives.

      G.   Periodic  updating of the plan.  A specific procedure would be
      defined for monitoring plan effects and developing annual revisions
      to the plan.

      A planning process based on the above approach and elaborated further
 in  these  guidelines should achieve the planning objectives of Section 208.
 In  seeking to meet these objectives, planning agencies may use discretion
 in  employing any other  logical planning process, as long as that process
 addresses the major issues of areawide waste management and produces a plan
 the contents of which are in line with the description set forth in the
 next  section.
1.4  Plan Contents

     The broad and integrated coverage of 208 planning means that a range
of short and long term objectives must be addressed.  Most immediately,
208 planning should look toward such specific outputs as technical require-
ments for permits, the location of and treatment levels for facilities,
initial construction priorities, and feasible measures leading to control
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of serious nonpoint source discharge problems.   The overall  contents of a
208 areawide waste management plan are set forth in the 40 CFR35, Subpart F
and summarized below.  Consistent with these proposed regulations and based
on a systematic comparison of the major alternatives in terms of costs,
environmental, social, and economic impacts, and implementation feasibility,
a 208 plan will include the following outputs:

     A.  Identification of anticipated municipal and industrial treatment
     works construction over a 20 year period.

     B.  Planning for facilities eligible under 40 CFR 35.917-1(a)-(i)  and
     and 40 CFR 35.1062 and for which Step 2 or Step 3 grant assistance is
     expected during the five year period following 208 plan approval.

     C.  Identification of required urban stormwater runoff control  systems.

     D.  Establishment of construction priorities over five and twenty  year
     periods.

     E.  Establishment of a regulatory program to: 1) provide for waste
     treatment management on an areawide basis and for identification,
     evaluation, and control or treatment of all point and nonpoint
     pollution sources; 2) regulate the location, modification, and
     construction of waste-discharging facilities; and 3)  assure that
     industrial or commercial wastes discharged into publicly owned  treat-
     ment works meet applicable pretreatment requirements.

     F.  Identification of agencies necessary to construct,  operate, and
     maintain facilities required by the plan and otherwise carry out the
     plan.

     G.  Identification of nonpoint sources of pollution related to
     agriculture, silviculture, mining, construction, and  certain forms of
     salt water intrusion, and procedures and methods (including land use
     requirements) to control those sources to the extent  feasible.

     H.  Processes to control the disposition of residual  waste and  land
     disposal of pollutants to protect ground and surface  water quality.

     I.  Selection of a management system to implement the plan and  identi-
     fication of the major management alternatives (including enforcement,
     financing, land use and other regulatory measures and associated
     management authorities and practices).

     J.  A schedule for implementing all elements of the plan, including
     identification of the costs of implementation.

     K.  Required certifications relating to consistency with other  plans
     and to public participation in the planning process and plan adoption.
                                   1-3

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      L.   Recommendations of appropriate  local governing bodies as  to  state
      certification and  EPA approval of the plan.


 1.5   Planning Criteria

      Planning for areawide waste treatment management should  be directed
 toward meeting the 1983 goals of the Act within the planning  area  accord-
 ing  to the  criteria contained herein.

      The  Federal Water  Pollution Control Act contains specific cost-
 effectiveness criteria  for the planning and development of wastewater
 management  programs in  particular as those programs relate to municipal
 treatment works and controls of combined sewer overflows and  storm sewer
 discharges.

      In the conduct of  its water program activities, EPA has defined  cost
 effectiveness analysis as an analysis featuring systematic comparison of
 alternatives to identify the solution which will minimize total costs to
 society over time to reliably meet given goals or objectives.  Total  costs
 to society  include resources costs plus social and environmental costs.
 Thus, the purpose of cost-effectiveness analysis is to select an alternative
 which efficiently uses  the nation's resources in meeting adopted goals while
 minimizing  adverse environmental  and social impacts.  This guideline  recog-
 nizes that, pursuant to Section 208(b)(2)(E), costs to society include
 adverse affects on the local  economy.   The concept of minimizing total
 costs to  society should be expanded to include minimizing:

         • resource costs

         • social  costs

         • environmental costs

         • economic costs

     Effectiveness refers  to meeting the 1983 goals of the Act while  providing
 for the highest practical  degree  of technical reliability in the pollution
 control  alternative that is chosen.

     Explicit criteria for determining adequacy of the management  provisions
 of carrying out areawide waste treatment management are not provided  in
 the Act.   This  guideline sets  forth the following criteria for evaluating
adequacy of the management provisions  of a 208  plan:

        • implementation feasibility and reliability

        • public  acceptability

     The  way in  which  the  planning criteria may be applied in plan
selection  is elaborated upon  in Chapters  3 and 13 of this  guideline.
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                               CHAPTER 2

               PROGRAMMATIC RELATIONSHIPS AND AUTHORITIES
2.1  Introduction

     This chapter summarizes the relationships between (a) planning
activities pursued under Section 208 of the FWPCAA and water pollution
control measures authorized by other sections of the Act; (b) EPA
programs addressed to both the protection of other environmental media
(e.g., air) and the promotion of environmentally sound practices (e.g.,
solid waste disposal); and (c) other areawide management programs.


2.2  Relationships Between Section 208 Planning and Other FWPCAA Provisions

     A.  Relationship between 208 and 303(e) Basin Plans

          303(e) basin plans constitute the overall framework within which
     208 plans are developed for specific portions of a basin characterized
     by complex pollution control problems.  Basin plans: 1) provide water
     quality standards and goals, 2) define critical water quality conditions,
     and 3) provide waste load constraints.  The results of 208 planning will
     constitute an integral part of these basin plans and the delineation of
     208 area boundaries may be facilitated by reference to the applicable
     basin plan.  The 208 area plans are to be certified annually by the
     Governor as being consistent with applicable basin plans.  Level B
     plans under section 208 may provide input relating to water use and
     management problems that affect water quality.

     B.  Relationship between 208 and Facilities Plans

          Facilities plans cover the planning and preliminary design portions
     of plans and studies (Step 1 elements) related to construction of publicly
     owned waste treatment works.  Facilities plans, through the systematic
     evaluation of alternatives, are intended to assure development of cost
     effective and environmentally sound municipal waste treatment systems.
     Thus, in contrast to 208 plans, facilities plans are limited essentially
     to abatement of pollution from municipal point sources and those indus-
     tries served or to be served by municipal waste treatment systems.

          Facilities plans may be completed or in progress when the 208
     areawide planning is undertaken.  Such planning should be construed as
     a step toward and supplementary to the more comprehensive 208 plan.

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     Features  included  in  approved  facilities  plans  and  scheduled  for
     plans and specifications  should  be  considered as  "existing" for
     208 planning purposes.  Generally,  other  facilities plans  and
     ongoing facilities  planning  efforts should  be reviewed  by  the 208
     agency, and  agreements  should  be reached  between  the facilities
     planning  and 208 planning  entities  for  coordination of  the respective
     planning  efforts,  recognizing  the land  use,  growth, and areawide
     aspects of the  208  planning  effort.   Such coordination  should be
     accomplished with  views toward achieving  maximum  consistency  with
     the 208 plan without  unduly  delaying  ongoing facilities planning
     efforts.   In general, no  facilities  planning should be  initiated
     within a  208 area  after 208  planning  has  been undertaken and  until
     a 208 plan has  been substantially developed.  However,  in  some cases,
     such concurrent facilities planning may be  justified and approved
     where urgency of solving  a specific problem  dictates the need for
     a shorter-term  and  more narrowly focused  planning effort.  Upon
     completion and  approval,  the 208 plan will  serve  as the facilities
     plan for  the designated area.  Subsequent applications  for grant
     assistance for  municipal  treatment  works  construction including
     detailed  design of  specific  facilities, preparation of  plans  and
     specifications, and actual construction,  will be  reviewed  for
     consistency  with the  208  plan.   Also, subsequent  detailed  designs
     of specific  facilities  for which grant  assistance is requested must
     not duplicate the  contents of  the 208 plan.

     C.  Relationship between  208 Plans  and  402  Permit Program

          The  402 National Pollutant  Discharge Elimination System  permit
     program is designed to  ensure  that  pollutant discharges will  not
     exceed prescribed  levels.  The permit system provides an essential
     tool for  implementation of the 208  plans  within the framework of
     the 303(e) basin plans.   No  permits may be  issued for point sources
     which are in conflict with approved 208 plans since they automatically
     become part  of  the  overall 303(e) basin plans.


2.3  Relationships between 208  Planning  and  Other EPA  Programs

     A.  Relationship between  208 Planning and Air Quality Programs

          Under the  Clean Air Act,  ambient air quality standards have been
     promulgated  for the nation.  Air Quality  Control  Regions that have  been
     deemed necessary or appropriate  for the attainment  and  maintenance  of
     ambient air  quality standards  have  been established. The  States have
     the responsibility  for  adopting  plans (SIPs) for  implementing the
     ambient air  quality standards.   During  the  208  planning process,
     reference should be made  to  the  requirements of the applicable SIP
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     for the Air Quality Control  Region or Regions  in  which the 208 area
     is located.

          If any portion of a 208 area is located within an Air Quality
     Maintenance Area identified  pursuant to 40 CFR 51.12(f),  208 planning
     efforts should be coordinated with the Air Quality Maintenance Plan
     development and implementation process.  The impact of 208 planning
     activities on air quality should be considered and complementary air
     and water management strategies, ensuring that 208 plans  are consistent
     with applicable portions of  SIPs, should be promoted.

     B.  Relationship between 208 and Solid Waste Programs

          During the 208 planning process, the State Plans  for Solid Waste
     Management should be examined for recommended  organizational  and
     technological solutions pertaining to the 208  area.  Local  agencies
     within the planning area which are to have the primary responsibility
     for regulating and implementing solid waste management controls should
     be identified.  In cooperation with such local agencies,  the mutual
     effects of these programs should be considered and appropriate measures
     taken to assure compatibility between the water quality management
     provisions of 208 planning and solid waste management  within the area.


2.4  Relationship between 208 Planning and Other Areawide Management Programs

     The land use aspects of 208  planning provide a direct  linkage with
other areawide planning efforts within the area including those supported
under the HUD 701 and flood insurance and disaster  programs, transportation
plans under DOT, and coastal zone management planning  under NOAA.   The 208
planning should be viewed as providing the water quality component of the
comprehensive plan for the area.   Consideration of  other area  planning
activities will help ensure that  their impact on water quality is incorpor-
ated into the 208 planning process and that 208 plans  are developed which
are mutually consistent with these activities.  Such consideration will
also facilitate the development of a coordinative relationship between 208
agencies and related agencies which should be carried  over  into the 208
implementation phase.
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                                CHAPTER 3

                             PLANNING PROCESS
3.1  Purpose

          The purpose of the planning process is to formulate an area-
     wide waste treatment management plan that can be implemented by
     a 208 management agency.  The planning process must integrate both
     technical needs for pollution control and management arrangements
     capable of implementing the controls.

          The technical planning portion of the planning process is
     concerned with identifying the priority water quality problems
     of the area, recognizing any constraints in dealing with the
     problems, and developing alternatives to achieve water quality
     goals.  The alternative plans may then be evaluated according
     to the planning criteria discussed in Chapter 1.

          Management planning is an essential part of the 208 planning
     process, and should be conducted concurrently with technical
     planning.  Ultimately, all components of the plan are geared
     to the implementation phase and dependent upon the development
     of an effective management plan for their accomplishment.
     Management  planning first identifies existing water quality
     management problems, such as lack of authority for controlling
     certain pollution sources as related to areawide waste treatment
     management.  Any constraints on devising an effective management
     approach must be identified as well.  Based upon a management
     analysis, alternative management systems having the potential
     for effective water quality management are identified.  Finally,
     such alternatives are analyzed in terms of their feasibility
     for implementing a given technical plan.  Because the feasibility
     of implementing a plan may depend on acquiring proper authority,
     it is part of the planning function to insure that the management
     agency(ies) has adequate legal authority to implement the plan.
     Accordingly, it is imperative that planning agencies consider
     management problems and alternative approaches during the initial
     phases of the planning process.

          The flow chart (see next page) displays the relationship
     between inputs, sequence of planning steps, and outputs of the
     planning process.  The text of this chapter provides detailed
     information on how the elements of the planning framework shown
     in the flow chart may be carried out.

3.2  Goals and Policies of the Act and Other Water Related Goals of the
     Planning Area

          To complement the 1983 water quality goals of the Act, certain
     provisions of the Title II provide for additional aspects of water
     quality protection such as:

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                                           AREAWIOE WASTE MANAGEMENT PLANNING  -  PLANNING PROCESS  FLOW  CHART
3.3   TECHNICAL  PLANNING

   A-B.   see text
   C.   Inputs
           OUTLINE NUMBERS  CORRESPOND TO  TEXT
0. Planning  Sequence
  1. Information from 303(e) Basin Plans
     and Facilities Plans
  2. Information from NPDES Permits
  3. Related Water Management Information
  4. Technical Information
     1.  Assemble  Existing Water Quality Data and Note
        Applicable  Standards
          •Select Model  to  Relate Source Loads to Water
           Quality
     2.  Identify  Critical Water Quality Conditions
        a.  Critical  Conditions
           (1)  Dry  Weather  Conditions
           (2)  Rainfall  Conditions
        b.  Data Collection  System
     3.  Construct an Inventory of Existing Dischargers
        a.  Point  Sources
        b.  Nonpoint Sources
     4.  Projections
        a.  Population Employmeit, Land Use Over the
           Planning Period
        b.  Define a Land Use  Plan to Accomodate Anticipated
           Growth Consistent  with Maintaining Water Quality
           Quality
        c.  Determine Waste  Loads over the Planning Period
     Determine Alternative Sub-Plans  of
     Treatment, Control,  and Flow
     Reduction, Consistent with  Eligible
     Waste Load Allocations
     For each Sub-Plan Show:
     Wasteloads, Costs,  Reliability,
     Environmental  Impact, Other Goals
     a. Continuous  Point Source  Sub-Plans
     b. Intermittent Point Source Sub-Plan
     c. Nonpoint Source Sub-Plans
  Screen Sub-P-lans to
  Select Leading
  Alternative Sub-Plans
  Consistent with Eligible
  Waste Load Allocations
Combine Sub-Plans
into Alternative
Areawide Plans
Consistent with
Eligible Waste Load
Allocations	
  3.4  MANAGEMENT PLANNING
 A. Purpose
   Development of Management System
   with Following Characteristics:
   1. Legal Authority
   2. Institutional Capability
   3. Financial Capability
   4. Capacility to Perform
      Management Functions
                  Management Analysis
                  evaluation of
                  1. Area's Experience and Potential
                     for Regional Water Quality
                     Management and Planning
                  2. Existing and Required Legal
                     Authority
                  3. Existing and Required
                     Institutional Arrangements
                  4. Existing and Required Financial
                     Arrangements
                                 Segment Analysis
                                 a. Effluent Limitations
                                    Segment Analysis
                                 b. Water Quality Segment
                                    Analysis
                                    1. Determine Total Maximum
                                       Daily Loads
                                    2. Select Eligible Sets of
                                       Waste Load Allocations
                                       Consistent with Options
                                    3. Test Sets of Waste Load
                                       Allocations Whether WLA's
                                       Can be Predicted to Result
                                       in Meeting Standards
                                                                                                                          If  WLA's Cannot be Predicted
                                                                                                                          to  Result  in Meeting Standards,
                                                                                                                          Choose  another Set of WLA's
                                                                                                                              _   „  J
                                    Development of Alternative
                                    Management Plans
                                    1. Review and Asses? Broad
                                       Management Options
                                    2. Develop Alternative
                                       Management Plans
                                    3. Assess Alternatives to Deter-
                                       mine Consistency with Technical
                                       Plans
                                    4. Screen Alternatives in Terms of
                                       Feasibility and Reliability

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3.5 Combined  Plan  Evaluation and  Selection
  A. Combine Alternative
    Technical Plans That Meet
    Standards with Alternative
    Management Plans
    Corresponding to Technical
    Plans
Compile Information on
Alternative Areawide Plans
1. Contribution to Water Quality
   and Other Related Water
   Management Goals of the Area
2. Technical Reliability
3. Monetary Costs
4. Environmental  Effects
5. Economic and Social  Effects
6. Implementation Feasibility
   and Reliability
7. Public  Acceptability
Compare Alternative Plans and
Select Final  Plan
1.  Effects of Alternative Plans
2.  Vary Alternatives if
   Necessary  for Final  Plan
   Selection
0. Develop Detailed
   Description
   of Plan Features
Include
Provisions
for Plan
Revision and
Updating
                                                                  F. Plan Outputs

                                                                     1.  Technical and Management  Outputs
                                                                        a.  Identification  of Municipal  and  Industrial Treatment Works Construction
                                                                        b.  Planning for Facilities  for  which  Step  2 and 3 Grant Assistance is
                                                                           Expected During  Five Year  Period Following 208 Approval
                                                                        c.  Identification  of Required Urban Stormwater Controls
                                                                        d.  Establishment of Construction  Priorities for the 208 Area
                                                                        e.  Establishment of a Regulatory  Program Required under Sec. 208(b)(2)(C)
                                                                        f.  Identification  of Agencies to  Carry  out Plan
                                                                        g.  Identification  and Procedures  and  Methods to Control Nonpoint Sources
                                                                        h.  Processes to Control Residual  Waste  and Land Disposal of Pollutants
                                                                        1.  Selection of Management  System
                                                                        j.  Schedule for Implementation;  Identification of Costs of Implementing Plan
                                                                        k.  Required Certifications  Relating to  Consistency with Other Plans and
                                                                           Public Participation
                                                                     2.  Provisions for Plan Revision  and  Updating
                                                                        a.  Performance Assessment
                                                                        b.  Procedures for  Plan Revision and Updating
                                                                     3.  Reports
                                                                        a.  Condensed Report on Outputs
                                                                        b.  Full  Report nn  Planning  Process

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          Water conservation through wastewater reuse or recycling

          Multiple use of waste water treatment systems and associated
          lands for such purposes  as recreation, aesthetics, and fish
          and wildlife habitat.

          Protection of groundwater quality

     Any other water-related goals of the 208 planning area should be
identified for consideration in development of the plans.   Other water-
related goals not specifically authorized under the Act may include
provision of adequate water supply and programs for land and water
resource management.

     The planning criteria discussed in Chapter 1  are to be applied
in meeting the established objectives, goals and policies  of the Act.
To the extent that other water-related goals of the planning area may
be met, consistent with the selection of the most cost-effective
Areawide Waste Treatment Management Plan, these related goals may be
incorporated into the plan.

     Finally, the planning process should be conducted in  such a way
as to be compatible with other plans for the 208 area, such as those
discussed in Chapter 2.


3.3  Technical Planning

     A.  Purpose

          The purpose of technical  planning is to develop  a coordinated
     pollution control  strategy for areas that may not be  able to meet
     water quality standards through application of base level technology.
     The control  strategy may be a combination of controls on 1) land use
     and growth,  2) municipal  wastewater systems,  3)  industrial  effluents
     and 4)  nonpoint sources,  where feasible, consistent with the pre-
     viously discussed  criteria.

          The way in which technical  planning should be conducted may be
     influenced by the  particular  problems  of the given area.  Technical
     planning procedures offered in these guidelines are generalized and
     to be used as a framework of  organization for planning.   The degree
     of emphasis  appropriate to given parts of the framework is  largely
     a matter of  planning judgement.

          In developing a control  strategy  appropriate to  particular areas
     it is essential  that alternatives considered be realistic in light of
     existing problems  and ability to solve those problems.   However,
     emphasis should  be given to control  methods beyond the traditional
     capital  intensive,  structural  approaches.
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     The basic method for developing the technical aspects of the
208 plan is the same as the planning methodology utilized in Sec. 303(e)
basin plans.  Nevertheless, a detailed investigation is undertaken in
the 208 plan to determine whether facilities plans are consistent with
the needs of the entire 208 area and whether they properly address
storm and combined sewer overflow and sewage and sludge disposal con-
siderations.  Finally, 208 technical planning is undertaken in close
cooperation with agencies possessing land use planning and control
authority in the 208 area.

B.   Flow Chart

     Many of the steps shown in the flow chart correspond to similar
planning steps undertaken as part of the Sec. 303(e) basin plans.  The
text provided herein elaborates on the meaning of the flow chart and
addresses planning considerations of the Sec. 303(e) planning method-
ology which may be of special concern in developing a 208 plan.

C.   Inputs

     1.   Information from 303(e) Basin Plans and Facilities Plans

          Available information from 303(e) basin plans and facilities
     plans provide the basic inputs for 208 planning.  In cases  in
     which detail necessary for developing an adequate 208 plan  is
     not available in the 303(e) basin plan, it will be necessary to
     obtain additional data.

          In general, the total allowable daily load to relevant stream
     segments that is established in 303(e) plans will  be regarded as
     a given constraint for the 208 plan.  Individual discharge  alloca-
     tions provided in the basin plan should be carefully evaluated in
     terms of their cost-effectiveness in meeting the water quality
     standards over the planning period.

          Facilities plans under Title II of the Act or preceding
     facility plans under 18 CFR and Sec.3(c) of the Water Quality Act
     of 1965 should be reviewed and revised if necessary to reflect
     the areawide emphasis of 208 plans.

     2.   Information from NPDES Permits

          Information on discharges into navigable water available
     through the National Pollutant Discharge Elimination System
     should be consulted and terms and conditions of any permits
     already issued to dischargers should be noted in determining
     pollution control strategies.

     3.   Related Hater Management Information

          Much of the information necessary for developing an effective
     208 plan is available from related water management programs and


                             3-3

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     studies  may  be  especially  useful  in  the  preparation  of a  208 plan:

        '  Basin Studies  under  the  Water Resources  Planning  Act
          of  1965

        •  Urban Studies  of  the  U.S.  Army  Corps  of  Engineers

        •  Flood Plain  Information  Studies  of  the U.S.  Geological
          Survey  and the U.S. Army Corps  of Engineers

        •  State and  local water supply studies  and data

        '  Other related  water management  information

     4.   Technical  Information

          A bibliography of technical  studies as related  to the  various
     parts of this  guideline is provided  at the end of this guide-
     line.

D.   Planning  Sequence

     1.   Assemble Existing  Water Quality  Data and  Note
         Applicable  Standards

          Since the  objective  of Sec.  208  plans is to  attain and  maintain
     state water  quality standards which  define the 1983  interim  goals
     of receiving water  quality, it is important to determine  how revi-
     sions to existing water quality standards  will be made such  as  to
     achieve  the  1983  goals of  the Act.

          The review, of  water quality  standards will occur  at  least
     once during  each  three year period beginning  with the  passage of
     the Act.  Upon  review  of standards,  recommendation for revision
     of standards will be considered and  adopted.   The 303(e)  basin
     plans will then be  revised accordingly during the next basin plan
     review.

          It  is important that  the state  be involved in an  identification
     of standards which  would meet the 1983 water  quality goals.   It may
     be necessary to make certain  assumptions concerning  the standards
     which would  correspond to  the 1983 goals prior to state adoption
     of such  standards.  Any assumptions  adopted for the  purposes of
     208 planning should be made explicit.

              Select a Model to Relate Source Loads to Water Quality

              Selection of a model  enabling  prediction of  water
          quality from source  load information  will be influenced by
          the  type of sources and  conditions  of water  quality  for


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     which predictions are undertaken.  The properties of
     different models are discussed in 303(e) guidelines.

2.  Identify Critical Water Quality Conditions

     a.  Critical Conditions

          Critical conditions will vary from basin to basin.
     Monitoring data provide a basis for choosing critical
     conditions around which pollution control strategies are
     designed.

          Assumptions concerning critical conditions should
     reflect careful investigation of basin conditions.   Assump-
     tions on the frequency of worst case conditions (e.g. once
     in 10 yr. 7-day low flow) should be such as to afford
     maximum protection of biological life in the waters. Survival
     of a balanced population of indigenous species is the criter-
     ion for selection of frequency and duration of worst case
     water quality conditions, whether the conditions are dry
     weather or rainfall related.

          Choice of critical conditions should consider a range
     of flow, meteorological and seasonal conditions.  In general,
     for point sources, the conditions under which continuous
     point source discharges present the worst conditions of
     pollution are low flow, dry weather conditions.  For non-
     point sources which are transported in runoff, critical
     conditions will be rainfall related, but may occur under
     a variety of flow conditions.

          (1) Dry Heather Conditions

               An analysis of the severity of pollution problems
          associated with dry weather conditions should be con-
          ducted.  Any dry weather flow conditions (including
          their duration and frequency) which are critical in
          terms of maintaining biological life in the waters
          should be noted.

          (2)  Rainfall Conditions

               An analysis of the severity of pollution problems
          associated with rainfall related stream conditions
          (whatever the stream flow prior to rainfall) should be
          conducted.  Any rainfall related flow conditions (includ-
          ing their duration and frequency) which are critical in
          terms of maintaining biological life in the waters should
          be noted.
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     b.  Data Collection System

          In the case that data from the Sec. 303(e) plan are
     lacking for certain segments, additional monitoring may
     be necessary for proper stream classification.

          Due to the emphasis of 208 planning on nonpoint sources,
     and due to the adoption of critical water quality conditions
     that encompass a range of stream flow conditions, it is quite
     possible that existing data will be insufficient to enable
     prediction of whether segments will meet standards under the
     assumed critical conditions.

          Monitoring to the extent necessary to determine nonpoint
     source load characteristics may be required as an input for
     the selected stream model.  (See Chapter6 ).

3.  Construct an Inventory of Existing Dischargers

     The inventory of dischargers developed in the basin plan
should be reviewed in order to identify and locate all significant
dischargers.

     a.  Point Sources

          Discharge inventories provided in relevant basin plans
     should be reviewed and compared with information provided
     by the National Pollutant Discharge Information System (NPDES).
     Special attention should be given to adequacy of information
     on storm and combined sewer discharges.   If appropriate, addi-
     tional  monitoring should be undertaken to update available
     inventory information.

     b.  Nonpoint Sources

          Since nonpoint source control is an integral part of
     208 planning, a discharge inventory for all significant
     nonpoint sources must be constructed (see Chapter 6 Detailed
     Consideration for Nonpoint Source Control).

4.  Projections

     In order to plan waste treatment and pollution control over
a 20 year period a series of assumptions about population, employ-
ment, and land use must be made.   Based upon such assumptions and
estimates of the wasteload generation characteristics of different
activities  it is possible to project future pollution control needs.

     a.  Population, Employment,  and Land Use Over the
         Planning Period
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          Techniques and data sources for these projections are
     discussed in 303(e) guidelines.   Particular emphasis should
     be placed on the effect that implementation of the 208 plan,
     local growth policies, plans for attainment and maintenance
     of air quality and other regional plans for transportation,
     solid waste management, water supply or public investment
     may have in altering historical  trends of population, employ-
     ment, and land use.

     b.  Define a Land Use Plan to Accomodate Anticipated Growth^
         Consistent with Maintaining  Water Quality

          An examination of the degree to which existing land
     use plans provide for water quality protection should be
     undertaken in cooperation with local agencies possessing
     land use planning and control authority.  Revisions to land
     use plans recommended as a result of such an examination
     should be proposed to the agencies possessing land use
     planning and control jurisdiction.  Further recommendations
     with respect to land use controls that could reduce the
     overall cost of meeting water quality standards should also
     be considered in developing the  208 plan.  Guidelines on
     incorporating water quality considerations into land use
     plans for 208 areas are provided in Chapter 4 , Detailed
     Considerations for Land  Use.

     c.  Determine Haste Loads over the Planning Period

          Using data on existing population employment and land
     use as well as monitoring information,the construction of
     materials balance for each significant source of pollution
     should be undertaken so as to relate instream water quality
     to pollution generation and transport where possible.  In
     the case of nonpoint sources, such a materials balance may
     be based on average factors for  wasteload generation per
     unit of activity or upon data gathered by adequate monitoring,
     depending on the nature of the nonpoint source problem in the
     area.  (Refer to Chapter 6).

          Utilizing the base line projections and factors of
     wasteload per unit of activity,  future waste loads may be
     projected.  These projections should be for increments of
     waste for five year periods, covering sources such as residen-
     tial, commercial, industrial, and nonpoint sources.  Further
     disaggregation into more specific source categories should be
     undertaken so as to cover each category for which controls are
     to be planned.

5-   Segment Analysis

     The basin plan provides for classification of all receiving
waters into effluent limited segments or water quality limited

                         3-7

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segments.  It is expected that most stream segments in urban-
industrial areas undertaking 208 plans will be water quality
limited.   Procedures for determining stream classification are
presented in 303(e) guidelines.

     It should be noted that the development of a 208 plan
entails consideration of control options, such as regional
waste treatment facilities, which pertain to the entire plan-
ning area.  Areawide planning may thus alter wasteload projections
previously developed under the basin plan, resulting in possible
segment classification revision.

     a.  Effluent Limitations Segment Analysis

          In any segments classified as effluent limited
     application of Best Practicable Treatment is required of
     all  point sources, other than publicly owned treatment
     works, by July 1, 1977, by  which time publicly owned treat-
     ment works are required to  apply effluent limitations based
     on Secondary Treatment.  By July 1, 1983 point sources other
     than publicly owned treatment works are to utilize Best
     Available Technology (BAT), while by such time publicly
     owned treatment works are to utilize Best Practicable Waste
     Treatment Technology (BPWTT).

          In addition to the requirements to meet BPT/BPWTT, any
     provisions for anti-degradation adopted in the basin plan
     should be applied,   (refer  to 303(e) guidelines)

     b.  Water Quality Segment Analysis

          By definition, water quality segments will  be in violation
     of water quality standards  even after all  point discharges
     receive treatment at least  as  stringent as required  by Section
     301(b)(l) of the Act.   Violation of standards in  these segments
     is caused either by point sources which must be subjected to
     controls beyond best practicable treatment ("BPT")/secondary
     treatment or by nonpoint sources which must be controlled.
     The  objective of water quality segment analysis  is  to deter-
     mine the most cost-effective allocation of waste loads between
     all  point and nonpoint discharges.

          The analysis would be  completed for each parameter which
     is in violation of water quality standards.   Each source
     contributing that parameter to the segment should be identi-
     fied and alternative remedial  measures considered.   The
     final  treatment control  strategy for the segment  should reflect
     a  combination of control  methods which will  meet  water quality
     standards for all  water quality parameters.
                        3-8

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(1)  Determine total maximum daily loads

     Refer to 303(e) guidelines.

(2) Select eligible sets of waste load allocations
    consistent with options

     Refer to 303(e) guidelines.  The following are
special considerations for determining wasteload
allocations as a part of a 208 plan:

   •  The number of alternative sets of both point
     and nonpoint individual wasteload allocations
     should be sufficient for thorough comparison of
     alternative means for achieving water quality
     standards according to the criteria of cost-
     effectiveness.

   •  In general, point source wasteload allocation will
     be based on the low flow condition.  Nonpoint
     source load allocations will be based on the incre-
     mental load resulting at rainfall-related flow
     conditions from nonpoint sources, when point
     sources have been controlled.

   •  Permit terms and conditions should be investigated
     so as to allow revision of wasteload allocation
     when permits are renewed.

   •  Allocations for future growth should be consistent
     with the area land use plan and growth projections.

(3)  Test sets of waste load allocations to determine
     whether waste load allocations can be predicted
     to result in meeting standards

     The same model, and considerations relevant in the
choice thereof, that was used in Chapter 3.3 D.I should
be used in determining whether wasteload allocations
enable meeting standards.  For a discussion of the toler-
ance level which should be used in determining whether
wasteload allocations can be predicted to result in
meeting standards, refer to 303(e) guidelines.

     In genera], many causes of uncertainty surrounding
the wasteload allocation process will be mitigated by
the close coordination between local  land use planning
and the 208 plan and by the intensive analysis of water
quality problems and possible controls in the 208 area.
     The choice of a tolerance level  for waste load
allocations and the reasons for choosing the tolerance
level  should be made explicit.

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6,    Determine Alternative  Subplans  of  Treatment,  Control  and
     Flow  Reduction  Consistent with  Eligible  Haste Load  Allocations

      Chapters 5  and 6  provide a  framework  for  analyzing pollution
 control options  for point  and nonpoint sources.   The  alternatives
 that are  presented  as  the  result of detailed planning for point
 and  nonpoint sources are referred to as  subplans.   Each subplan
 should  furnish information on the following:

      Wasteload characteristics of each alternative expressed
      in appropriate units  for relating to  the  water quality
      prediction  model

      Total  cost  of  each alternative expressed  as  its  present
      value  or average  equivalent value of  capital  and operating
      costs  for the  overall  alternative and subsystem  components.

      Information on the reliability of each  alternative and
      subsystem included in each  alternative

      Significant environmental effects of  each alternative
      consistent  with NEPA  procedures,  including a  specific
      statement on future development environmental  impact

      Contribution of each  alternative  to other water-related
      goals  of the planning area

      Subplans may be broken  into three major types  according  to
 the  nature  of the sources  and their water  quality  impact.  Such
 a  breakdown facilitates relation of the source loads  to critical
 water quality conditions.

      a.   Continuous  Point  Source Subplans

          Continuous point sources  are municipal  treatment works
      and  industrial  point  sources.   Detail on  this  subplan is
      provided in Chapter 5.

      b.   Intermittent  Point  Source  Subplans

          Intermittent point sources are industrial sources
      discharging on a  seasonal basis and rainfall-related point
      sources such as storm and combined sewer  overflows.   Detail
      on this subplan is provided in Chapter  5.

      c.   Nonpoint Source Subplans

          Nonpoint  sources are primarily rainfall-related.  Detail
      on this subplan is provided in Chapter  6.
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           7.  Screen Subplans to Select Leading Alternative Subplans
               Consistent with Eligible Waste Load Allocations

                The number of options of control under each subplan is
           numerous.  Thus, the number of possible subplans may be so
           great as to impede consideration of logical alternatives.   The
           only subplans that can be implemented are those for which a
           management alternative to implement the subplans exists.  At
           this stage in the planning process it is important to begin to
           integrate the results of technical planning and management planning

                At this step, subplans should be narrowed to those subplans
           that appear to be viable from both a technical and a management
           perspective.  Nevertheless, it is important that the remaining
           options be sufficiently varied in their approach to resolving
           the water quality problems of the area so that eventual  plan
           selection can be based upon consideration of a broad range of
           alternative plans.

           8.  Combine Subplans into Alternative Plans Consistent with
               Eligible Waste Load Allocations

                At this step viable subplans should be combined into
           alternative areawide subplans for final evaluation and selection.

                This step is not meant to preclude reconsidering options
           that were previously screened out, but to merely provide a
           convenient form of organizing a vast number of potential alter-
           natives for pollution control into a reasonable number of
           alternatives to evaluate.
3.4  Management Planning

     A.   Purpose

          The management planning process must be closely coordinated with
     the technical  planning process.   The goal  of management planning is
     to  develop a management system capable of implementing the areawide
     plan.   A feasible, reliable, implementable management system will
     require the following basic characteristics:

          1.   Adequate legal authority, as mandated by subsection
          208(c"JT2)  and related provisions of the Act. In many
          cases existing law will be  inadequate and supplemental
          or enabling legislation will  have to be passed to provide
          management agencies with the  needed authority prior to
          the time  of plan approval.   Detailed discussion of required
          authority  is presented in Chapters 8 and 9.
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 2.  An  institutional capability based on a practicable,
 effective, and coordinated institutional structuredThe
 great variety of local  institutions, practices, and ex-
 perience dictates that  a pragmatic strategy be followed
 in  constructing the management system.  The system may
 be  comprised of one or  more agencies, which may be exist-
 ing or  newly created and local, regional, or statewide
 in  jurisdiction.  The system may also incorporate exist-
 ing or  newly created intergovernmental arrangements,
 which may be State, local, and/or interlocal.  Although
 care must be taken to ensure that the management system
 fits the local situation, excessive fragmentation of
 authority and responsibility must be avoided.  The plan
 must assure that management functions can be performed
 in  an effective coordinated manner.  Detailed discussion
 of  institutional arrangements is provided in Chapter 8.

 3.  A financial capability appropriate to the water quality
 needs and objectives of the area.  Flexible, comprehensive
 financial arrangements must be included in the plan, to
 enable  the management system to meet its responsibilities
 in  such areas as capital construction, operational costs,
 revenue assessment, and the financing of indirect costs.
 Financial arrangements are discussed in detail  in Chapter 9.

 4.  Management functions.  In undertaking the management
 portion of the planning process, it is important to keep
 in  mind that "management" includes more than just treatment
 of  wastes.  Provision must be made within the management
 system  for the performance of such other essential func-
 tions as the administration of stormwater runoff and nonpoint
 source controls and involvement, through local  units of
 government possessing land use planning and control  authority,
 in  the application of land use measures.  Financing, regulatory,
 and enforcement mechanisms associated with these several func-
 tions should also be provided for in the plan.   The regulatory
 program is discussed in Chapter 7.

     Given the broad range of management functions and
 probable involvement of several  agencies, arrangements, and
 levels of government, it is useful to approach  planning from
 a systemic perspective.   The end result of planning should
 be  a management system capable of overall management of all
 aspects of water quality control  for the area.

     This system should make possible an equitable dis-
 tribution of services,  and, at some significant level,
must be representative  of constituent governing bodies
 (particularly general  purpose governments)  having account-
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     ability to the electorate.  In addition, since planning
     is fundamental in measuring and contributing to effective
     performance and since a continuing planning process is
     to carry over into the plan implementation phase, the
     planning responsibility may constructively be viewed as a
     critical element of the comprehensive management system.

          Based on the objectives and characteristics outlined
     above, the management component of the planning process
     should begin with an analysis of the existing management
     setting and proceed to the development of alternative
     management plans correlating with the technical alterna-
     tives .

B.  Management Analysis

     The initial step in the management planning process should be an
analysis of the area's experience in water quality management.  The
purpose of this analysis will be to evaluate the extant capability
within the area to meet the management requirements of Section 208 and
to develop an understanding of what is needed to satisfy these require-
ments.  Some of the analysis will have been accomplished in the desig-
nation and grant application stages.  During the planning process, this
preliminary assessment should be reviewed and, where necessary, ex-
panded to assure its accuracy and thoroughness.  The management analysis
touches on a number of overlapping considerations and should provide
the following:

     1.  An evaluation of the area's potential for regional
     water quality management.  This evaluation should seek
     to assess the effectiveness of regional management to
     date and the strength of the area's traditions and
     commitment to regional approaches.  The evaluation should
     incorporate an appraisal of the relationships between
     federally funded regional planning authorities and re-
     gional or local water quality mannagement agencies and
     between the latter agencies and local agencies (such as
     transportation, land disposal of wastes, land use
     planning, and water supply) whose activities impact water
     quality.  The purpose of the evaluation is to help assure
     that management plans are constructed on a realistic
     foundation, which reflects the area's experience in
     regionalized management.

     2.  An assessment of the specific legal authority required
     under subsection 208(c)(2) and related provisions to imple-
     ment the plan, and an approach to acquiring such authority.
     The approach should delineate what enabling or supplemental
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     legislation will  be necessary, the type of contractual
     agreements that might be employed, and the possibility for
     adapting to existing laws.  In instances where existing laws
     might be broadly interpreted as furnishing the required
     authority, but where such interpretation may be subject to
     dispute, it will  be best to seek specific statutory sanction.

     3.  An assessment of the extent to which the existing
     institutional  structure, including both agencies and inter-
     governmental arrangements, is adequate to perform the required
     208 functions, and of the type of changes needed (including
     staffing) to assure functional capability.

     4.  An evaluation of existing financial  arrangements to
     determine what changes will  be necessary to provide the
     management system with the capacity to meet its financial
     needs and obligations.

C.  Development of Alternative Management Plans

     Upon completion of the management analysis, alternative management
plans reflecting the results of this analysis should be developed.  In
most cases, only a  limited number of alternatives will  be appropriate.
Close coordination  with the technical  planning component of the planning
process will  be necessary throughout this stage to insure that  the
management alternatives developed are consistent with alternative
technical plans.  As an initial step in the formulation of management
alternatives, the broad options available with respect to the establish-
ment of a management system should be reviewed and assessed.  Careful
consideration should be given to the advantages and constraints of
these options in relation to the designated area.  (The subject of
management options  is  discussed in detail in Chapter 8).  Once
developed, the management alternatives should be screened in terms
of their feasibility and reliability for implementation.  Specific
feasibility/reliability criteria that should be utilized at this
stage (and systematically applied at the time of plan selection)
include the following:

     1.  Legal authority.  Determine whether alternative
     management plans  provide for the authority required under
     208(c)(2) and  related provisions.

     2.  Operational effectiveness.  Evaluate the extent to
     which the alternatives make possible the effective
     accomplishment of functions necessary for implementation
     of a 208 plan.

     3.  Practicability.  Assess the extent to which the alterna-
     tives build realistically on existing water quality manage-
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          ment entities and practices.   Determine whether each alterna-
          tive is an achievable extension of the areas previous efforts
          in regional water quality management.-- i.e., is it politically
          feasible?

          4.  Coordinative capacity.  Insure that the alternatives  provide
          processes and mechanisms for  resolving conflicts,  for balancing
          needs and resources, and for  enforcing the plan.  Evaluate
          their potential  for facilitating cooperation with  other
          areawide planning efforts and with local  activities that  impact
          water quality.

          5.  Public accountability.  Evaluate the alternatives as  to
          their provisions for ensuring that the management  system
          and its decision making procass are accountable for imple-
          menting the plan and will be  responsible to the area electo-
          rate.  Insure that the alternatives provide for substantial
          involvement of  general purpose governments and for adequate
          public participation.


3.5  Combined Plan Evaluation and Selection

     A.  Combine Alternative Technical  Plans that Meet Standards with
         Alternative Management Plan Corresponding to Technical  Plans'

          Technical planning and management planning should  have been
     carried out in such a way as to result in a series of alternative
     technical plans for which an alternative management plan to implement
     the technical plan has been presented.  At this step, the alternative
     technical plans and management plans are simply combined.

          For each alternative technical and management plan that are
     combined into alternative areawide plans, sufficient detail concerning
     the schedule of actions to be undertaken should be provided to enable
     accurate evaluation of the plan in terms of meeting 1983 water quality
     goals.

     B,  Compile Information on Alternative Areawide Plans

          The following kinds of information on effects of alternative
     plans should be assembled for use  in the comparison of alternative
     plans and selection of an areawide plan:

          1.  Contribution to Water Quality and Other Related Water Management
          Goals of the Area.  (Information from Chapters 5 and 6)

          2.  Technical Reliability (Information from Chapters 5 and 6)

          3.  Monetary Costs (Information from Chapters 5 and 6; methodology
          for cost evaluation provided  in Chapter 10)

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     4.  Environmental Effects (Information from Chapters 5 and 6;
     methodology for environmental evaluation provided in Chapter 11)

     5.  Economic and Social Effects (methodology for evaluation of
     economic and social effects provided in Chapter 11)

     6.  Implementation Feasibility and Reliability (Information
     from Chapters 7,8 and 9)

     7.  Public Acceptability (guidance on means to assure public involve-
     ment in the planning process provided in Chapter 12)

     Much of the above information is developed in the planning process,
which results in the presentation of alternative plans.   Some of the
above information which may not have been developed in very great
detail when alternative plans were being developed, should be gathered
in order to be able to proceed to final plan selection.   All  of the
above information may conveniently be assembled on tables such as
those provided in Chapter 13.

C.  Compare Alternative Plans and Select Final  Plan

     1.  Effects of Alternative Plans

          Information on effects of alternative plans should  be
     assembled in tables such as those provided in Chapter 13.
     Comparison of alternatives and selection of a final  plan should
     be the product of public deliberation over the merits of the
     different plans under consideration.  A discussion  of means to
     involve the public in the overall  planning process  is provided
     in Chapter 12.  Suggested procedures for public involvement in
     selection of the final  plan are provided in Chapter 13.

     2.  Vary Alternatives if Necessary for Final  Selection

          During the plan selection process a variant or composite
     of alternative plans originally evaluated  may be proposed as
     a final adjustment necessary to pick the most desirable  overall
     plan.   The planning process is iterative in nature  and thus the
     reconsideration of an option or subplan should always be under-
     taken  when it may lead  to a better overall  plan.

D.  Develop Detailed Description of Plan Features

     In the process of screening, evaluating and selecting plans, it
is likely that detailed features of .the plan may not have been
sufficiently developed to enable implementation of a plan in  every
detail.   At this step, the timing and detailed  features  of the plan


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to be implemented should be finalized.  A critical path chart depicting
sequence of plan implementation steps may be a useful  format for depict-
ing the details and schedule of the plans selected for implementation.

E.  Include Provisions for Plan Revision and Updating

     The 208 plan should cover a 20 year period, be updated as necessary,
and must be annually certified by the Governor.  The procedure that will
be followed in updating both technical and management  features of the
plan are to be specified in the initial plan submittal.

F.  Plan Outputs

     1.   Technical and Management Outputs

          The technical and management contents of a 208 areawide
     waste treatment management plan have been summarized in Chapter 1.4.
     The timing for the implementation of the plan should be shown in
     conjunction with the plan contents.

     2.  Provisions for Plan Revision and Updating

          a.  Performance Assessment

               The plan should set forth provisions for plan review
          and performance assessment with regard to meeting the objectives
          of areawide waste treatment planning.

          b.  Procedures for Plan Revision and Updating

               The plan should include provisions for  plan updating
          over the planning period. The provisions for revision and
          updating should describe procedures for modifying specific
          plan elements, and where possible, provide alternative courses
          of action to undertake, in the event that an originally  chosen
          course of action proves infeasible or inadvisable in the light
          of changed conditions.

     3.  Reports

          a.  Condensed Report on Outputs

               A condensed report on the plan should cover all the plan
          elements required by statute as well as other elements of the
          plan to be implemented.  The report should relate all plan
          elements to an implementation schedule.
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b.  Full  Report on the Planning Process

     A full  report documenting the way in which the planning
process was  carried out should be presented.   The format of
such a report could follow the outline of the planning
process followed in this guideline.   This report should
serve as  an  explanation of how the final  plan was chosen
and what  alternatives  to the  final  plan were  considered.
Pursuant  to  40 CFR 35, Subpart F,  Section 1064-1  (m-n),
the report should provide for:

    "the  identification of all  major  alternative  measures,
     including enforcement activities,  financing, land use
     and  other development controls and regulatory actions,
     administrative and management authorities  and practices
     necessary to carry out each  of the alternatives,  and
     selection of the  recommended  system;"

    "The  period of time necessary  to  carry  out  the plan and
     major alternatives, the  costs  of carrying  out the plan,
     and  major alternatives within  such time,  and economic,
     social,  and environmental  impacts  of carrying out the
     plan and major alternatives within such  time."  This
     documentation of  environmental impacts should satisfy
     the  environmental  assessment  requirements  set forth
     in 40 CFR 35 Part 6.
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                             CHAPTER  4

               DETAILED CONSIDERATIONS FOR LAND USE
4.1   Introduction

     This chapter discusses the principal  considerations  in  utilizing and
updating existing land use plans and controls to help attain water  quality
objectives.  In addition, for those areas  in which land  use  plans do not
exist, consideration will be given to developing land use plans  and controls.
Such considerations are important for two  reasons.  First,  the land use plan
can serve as a basis from which point and  nonpoint source controls  can be
developed and evaluated.  Second, consideration of possible  changes can be
explored as a means of reducing investment in point and  nonpoint source control


4.2  Pertinent Authorizations and Purpose

     A.  Federal Water Pollution Control Act

          ilOl(b), 201(c), 303, and 314(a)(2) make reference to
     land use requirements and to the preservation of land  resources.
     The most important authorizations of  these subsections  indicate that
     land use regulations should be utilized as methods  to  control  point
     and nonpoint sources of pollution.

          §208 provides that the areawide  waste treatment management
     plan include, "the establishment of a regulatory program to regulate
     the location, modification, and construction of any facilities
     within such area which may result in  any discharge  in such  area,.  .  .."
     This provides indirect authority for  the 208 plan to regulate  location
     of all pollutant dischargers by seeking appropriate changes in land
     use plans from the agencies possessing land use control jurisdiction
     in the 208 area.  The term "facilities" in §208(b)(2)(c)(ii)  includes
     any controllable source of pollutants, the regulation of which
     contributes to attaining water quality standards.

          A more explicit authority for the 208 plan to  consider
     land use in the 208 area is provided  in section 208(b)(2)(F-H)
     which states that the plan will set forth procedures and methods
     including land use requirements to control to the extent feasible
     nonpoint sources of pollution.  The term "land use  requirements"
     in section 208(b)(2)(F-H) should include those land use controls
     (legally permitted uses) and those land management  regulations
     (regulations of activities conducted  on land) which contribute to
     the attainment of water quality standards.

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     B.  Typical  State Legislative Authorities

          ].  Existing land use planning,  environmental  and conservation
          laws.   When evaluating the land  use planning  for the area,  the
          planning agency must be cognizant of existing  authorities and
          requirements under a State's  environmental, conservation, or
          land use planning programs.   These laws  may be applicable to
          the entire State or just to designated critical  areas (e.g.,
          wetlands, floodplains, special  interest  geographical  features,
          etc.).

          2.  State enabling laws.   An  examination of the  State statutes
          relating to the authorities for  land  use planning  and control
          should  be conducted.   This will  ensure a land  use  plan that
          is designed to  be implemented within  the legal and institutional
          framework that  exists.
4.3  Incorporating  Land  Use Considerations  in the 208 Planning  Process

     A.   Introduction

          It is  the intent of this section  to identify various  methods of
     land use control which the local governments and the management agency
     in  the 208  can utilize to control pollution.  This will enable the 208
     area to make tradeoffs between structural solutions (e.g., treatment
     facilities) to pollution problems and  nonstructural solutions such
     as  land use, thus increasing the flexibility in the choice of methods
     used to achieve water quality standards.  The 208 planning process
     seeks to balance all measures of pollution control  in such a manner
     as  to achieve  the best mix of all measures as determined by direct
     cost, environmental, social and economic considerations.

          The process which is discussed in this chapter for incorporating
     land use considerations into the 208 planning process is divided into
     two  phases.  The first phase focuses on a qualitative assessment of
     the  relationship between land use and water quality.  The desired out-
     put  of this phase is a land use plan and associated controls and policies
     which can be utilized in the analyses performed in Chapters 5 and 6.
     The  second phase seeks to refine the analyses and outputs of the first
     phase by suggesting changes and broadly evaluating  them according to
     the  criteria of cost-effectiveness.

          In  both phases, primary reliance will  be placed on utilizing
     existing land use plans and controls.  In some cases it may be  nec-
     essary  to update these in order to  incorporate changes responsive to
     water quality objectives.   In such  cases, the 208 planning agency
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must work closely with the local  governments possessing  legal
authority for land use planning and controls.

     It is also possible that some jurisdictions within  the  208  area
will not have land use plans and/or controls.   In this case,  the
208 agency should work with the appropriate jurisdiction to  gather
enough information about the area so that current and future  develop-
ment patterns and policies can be identified and, if necessary,  up-
dated to incorporate water quality objectives.

     The land use plan and controls which are the outputs of  this
chapter should be of sufficient detail  to establish the  basis for
facilities design alternatives and for the evaluation of nonpoint
source runoff.  More specifically, the plan should be of sufficient
detail so that the location, volume, and nature of wastewater flows
considered can be identified adequately in order to formulate system
or design parameters for the location, sizing,  and timing of  major
transmission systems (laterals and interceptors) and treatment sites.
Any specific legal regulations of local land use and development
ordinances which affect the assumptions made for the above wastewater
and land use impact data should be documented.   In addition,  the
origin of the wastewater sources, their location and geographic
distribution should be of a comparable level of detail in order  to
accurately relate the origin of flows to contributing land uses.

B.  First Phase
     1.  Establishing Land Use and Water Quality Relationships

          In recent years a number of studies have been completed
     which have examined the relationships between land use  and  water
     quality.  (See bibliography.)  Although limited in scope, these
     studies provide a basis for understanding the impacts land  use
     has on water quality.  To the extent that it is practical,  land
     use-water quality relationships should be identified and  incorpor-
     ated into the adjustments of the land use plan.

          There are several different methods of approaching the re-
     lationship between land use and water quality.   One of  these  is
     land capability planning.  This type of planning relates  variations
     in the physical environment such as soil differences, vegetation,
     wildlife, etc., to the capability of that environment to  assimi-
     late man-made growth and development.
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For example, an area may favor the growth  and  predominance  of trees
which serve to limit erosion,  flooding,  and  wind  velocity.   As such,
this area may be unsuitable for development.   Land  capability planning,
then, seeks to assess the suitability of a particular  area  for a
specific type and intensity of development (residential,  commercial,
industrial, etc.).

     Another way of viewing the land use water-quality relationship
would be to determine the area's water related constraints  on growth  and
development.  (Similarly, an estimate of air resources related con-
straints should be  made.)  Effective planning  would reconcile the  capacity
of the air and water resources of 208 area with pressures for growth
and development.

      In order to identify and understand  the  relationships,  some  inven-
torying and analysis of existing conditions  should  be  undertaken.  The
focus should be on  those areas within the  208  region having  an impact on or
impacted by water quality.   Thus,  the inventory and analysis  may in-
clude but not necessarily be limited to  the following:

     1.  Industrial, commercial,  residential  and other activities
         from which significant pollution  may be generated;

     2.  Topography and soil conditions  of the 208 area;

     3.  Significant sources of nonpoint source pollution;

     4.  Bodies of  water and related lands that would  be
         beneficially or adversely affected by a change in water
         quality;

     5.  Existing waste treatment and collection systems;

     6.  Solid  waste disposal  sites;

     7.  Environmentally sensitive areas:

          .   Aquifers  and aquifer recharge areas
          .   Marshland  and  wetlands
          .   Flood  plains
          .   Forests  and  woodlands
          .   Erodable  and/or poorly drained soils
          .   Steep  slopes
          .   Shorelands.
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2.  Analysis of Land Use Controls and Practices

     In order to successfully implement the 208 plan,  it  will  be
necessary to utilize a wide variety of land use controls  and  prac-
tices.  It is advisable to review the controls and practices  early
in the planning process to ensure that they are in conformance
with the plan and that they can be utilized in the implementation
of that plan, especially in controlling nonpoint sources.   The
implementation of the controls in the management of the  plans is
more fully discussed in Chapters 7 and 8.  Initially,  an  inventory
and analysis of land use controls and practices should be made
with particular attention paid to their possible effect  in achiev-
ing water quality.  The analysis of land use-water quality rela-
tionships should help determine those controls which could be
most effective.  This should be supplemented by an inventory  and
analysis of other ordinances, regulations and policies such as
taxation which may have a direct or indirect impact on water
quality.  At a minimum the following should be reviewed  as they
apply to the 208 area:

      .  Zoning
        Flood plain zoning and regulation
      .  Environmental performance zoning
      .  Subdivision regulations
        Planned Unit Development regulations
      .  Buffer zones
      .  Conservation and scenic easements
      .  Density bonuses
      .  Housing codes
      .  Building codes
      .  Construction permits
      .  Development permits
      .  Transferable development rights
      .  Hillside development regulations
      .  Grading regulations
      .  Taxation policies
        Public works policies
      .  Public investment policies
      .  Land conservation policies
      .  Discharge permits

Any additional regulations which may affect water quality should also
be reviewed.

     Emphasis should be placed on the analysis of those  controls
which could have the greatest impact toward achieving  water quality
standards in the specific 208 area.  A number of the studies  listed
in the bibliography may prove helpful in conducting this  analysis.
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     Any controls which are determined  to  have a  beneficial  impact
on water quality and are not presently  being  used should  be  identi-
fied.  Appropriate modifications  in existing  legislation  and/or
enforcement mechanisms should be  suggested.   If such controls
cannot be utilized, a justification for not using them should  be
made.

     In addition, it should be noted that  under the  National  Flood
Insurance Act of 1968 and the Flood Protection Act of 1973,  communi-
ties must adopt flood plain zoning  or other flood plain management
measures to become eligible for federally  subsidized flood  insurance
Any 208 plan must be fully consistent with the constraints mandated
by the above laws.

3.  Initial Land Use Planning

     The analysis of land use-water quality relationships and
land use controls and practices should  serve  as a basis for  deter-
mining the land use plan which will  be  used to establish  the  basis
for facilities design alternatives  and  to  evaluate nonpoint  source
runoff.  An additional input will  be the population  and economic
projections developed in Chapter  3  (3.3. D.4). These projections
should be disaggregated to show time-related  development  consistent
with the land use plan.  The projections should show growth  for the
fifth, tenth and twentieth year of  the  planning period disaggregated
into subareas (municipal or equivalent  area).   If these projection
patterns appear inconsistent from subarea  to  subarea, some adjust-
ments could be made among subareas  so as to reduce overall  invest-
ments in point and nonpoint source  control by  promoting orderly
growth within the entire 208 area.

     As was previously stated, the  intent  is  to rely primarily on
existing land use plans and controls and to update them to  help
attain water quality standards.  However,  as  previously described,
where no plan exists, one must be prepared.

     In determining the suitability of  this land  use plan,  the
following criteria should be employed:

     1)  Impact on water quality.  Since the achievement of water
         quality standards is a major objective of the planning
         process, it is important that  this be given careful
         consideration.

     2)  Implementation capability.  The plan  must be implementable
         especially those sections  having  a direct effect on water
         quality.  Careful  consideration must  be  given to the  land
         use controls required to carry out the plan, their.feasi-
         bility, and their relationship to existing  and proposed
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         institutional  and financial  mechanisms.

     3)  Consistency with other programs.  To the extent that it is
         practical, the land use plan should be consistent with  other
         programs, policies and plans such as those related to  trans-
         portation, water supply, capital improvements,  air quality,
         etc.

     4)  Public acceptance. Since a plan that is  unacceptable to the
         public is unlikely to be implemented,  it is essential  that
         serious consideration be given to the  public's  viewpoint.
         Appropriate public participation measures are discussed in
         Chapter 12.

Once a plan has been determined, the basic data and working maps
describing that plan should be prepared so that they can be used
for the analyses described in Chapters 5 and 6.  These would include:

     1)  A brief narrative description of the proposed land use
         controls and practices;

     2)  A justification for not using land use controls,  if any,
         which were determined to have a beneficial  impact on
         water quality.

     3)  Tables showing population and economic projections for  the
         fifth, tenth,  and twentieth year of the  planning  period
         disaggregated  to the municipal or equivalent level.

     4)  Working maps depicting growth and densities, disaggregated
         by subareas and extent of development  for the fifth, tenth,
         and twentieth  year of the planning period.  These maps
         should also show existing and proposed solid waste disposal
         sites.

C.  Second Phase
     1.   Land Use Refinements

          As the subplans are developed according  to  Chapters  5  and  6,
     it is likely that certain refinements in the  land  use  plan  and
     controls will  become evident.  For example, additional  controls
     or adjustments to development patterns might  be  considered  as
     means of reducing investments in point and nonpoint source
     controls.   This is especially important in particular  portions
     of the 208 area where very high levels of point  and nonpoint
     source controls would be needed to meet water quality  goals.
     In  those cases, changes in the land use plan  should be made when
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such changes would not result in an overriding increase in
non-water quality related costs and in adverse environmental,
social and economic impacts.

2.  Final Refinements

     After the various subplans have been developed,  further
land use refinements should be considered.  These refinements
should be evaluated according to the criteria discussed in
section 3.B.3 of this chapter.  In addition, they should be
evaluated according to the criteria of cost-effectiveness
discussed in Chapters 1, 5 and 6.  The focus of this  evaluation
should be on the consideration of alternative land use develop-
ment patterns which have the potential  for reducing investments
for point and nonpoint control measures.   Those changes that
result in reductions in such investments  should be adopted if
practicable from an overall  environmental, social, and economic
viewpoint.  The following questions may prove useful  in suggesting
some final refinements:

     1)  Is this the optimum development  pattern for   water
         qua!ity?

     2)  Could the number and magnitude of discharges be
         reduced if the development pattern was changed?

     3)  Will the location of discharges  have an adverse
         impact on water quality?

     4)  Will the timing of discharges  have an adverse impact
         on water quality?

     5)  Would the implementation of additional  land  use
         controls reduce overall  investments?

     While this final  refinement may occur at various places
in the planning process, it is preferable to do it at the
point where sub-plans  are combined into alternative areawide
plans consistent with waste load allocations (Chapter 3.3.D.9).
If the planning agency feels that the final  refinement would
more appropriately be  conducted at some other point in the
planning process, it should do it at that point.  However, it
should be noted that the final refinement will  be of  little
value if it is done prior to the combination of sub-plans.
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                               CHAPTER 5

               DETAILED CONSIDERATIONS FOR POINT SOURCES
5.1   Introduction

     Chapter 3 presents the framework for systematic evaluation and selection
of pollution control strategies for all sources of pollutants.   This chapter
describes detailed planning considerations that should be addressed in
establishing alternative subplans for control of point sources  of pollution.
The point sources considered in this chapter are discharges from municipal
treatment plants, combined sewer overflows, separate storm sewer discharges,
and industrial waste effluents.  Disposal of residual  wastes, particularly
wastewater sludge, and wastewater reuse considerations is also  discussed.

     The various point source problems and controls are presented separately
in the following sections of this chapter.  A separate section  covers com-
bined sewer overflows and storm sewer discharges because of their intermittent
flow characteristics.  This chapter stresses balanced  consideration of measures
other than the traditional capital intensive approaches toward  point source
control.   Consideration of alternatives should encompass all applicable struc-
tural and management measures for preventing, abating, reducing storing, treating,
separating, recycling, reclaiming and disposing of municipal  and industrial
wastewater and storm water discharges.  The concluding section  of this chapter
will bring together control options for these sources  into alternative subplans
for point source controls.


5.2  Municipal Wastewater Facilities

     A.  Introduction

          Planning of municipal facilities within an areawide planning area
     will provide for cost-effective, environmentally  sound,  and implementable
     treatment works, to meet the present needs of the area and will provide
     a general program for phasing facilities development to  meet future needs
     associated with the expected development related  to the  overall land  use
     plan.  Balanced evaluation of nonpoint source abatement  and prevention
     measures as well as point source measures must precede final selection
     of the treatment works.  Treatment works must meet the applicable
     requirements of Sections 201(g), 301, and 302 of  the Act.   As a minimum,
     facilities plans must provide for application, by 1983,  of the best
     practicable waste treatment technology (BPWTT).  Where necessary to
     meet wasteload allocation constraints, consistent with water quality
     standards, plans must provide for measures producing further pollutant
     reductions.  The determination of BPWTT, or measures providing for
     higher treatment levels if needed, is based uoon  evaluation of technologies

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included under each of the following waste management techniques:

     a.  treatment (biological  or physical-chemical)  and
         discharge to receiving waters;

     b.  treatment and reuse;

     c.  land application or land utilization.

     Comparison of the above techniques  and determination of BPWTT for
a specific case should include  management considerations of nutrients
in wastewater and sludges, development of integrated  (solid, liquid,
and thermal) waste facilities,  or enhancement of recreation and open
space opportunities.

     This section covers major  aspects of the municipal  wastewater
facilities planning presented  in the EPA document entitled "Guidance
for Facilities Planning".  More detailed information  on  facilities
planning is contained in that  document.   In 208 planning areas, special
attention should be given to the disposal  of sludge  from the municipal
wastewater system.  Sludge disposal  has  been a  problem in many areas
and it can be expected to become increasingly more acute in large
urban/industrial areas as waste treatment levels increase and development
pressures persist.

B.  Inventory Existing Conditions and Determine Existing Flows

     The existing waste treatment systems must be accurately assessed
to establish a basis for planning any systems modifications.  Where
available, the Section 303 Basin Plans will  provide  essential  information
on municipal point sources, waste loads, wastewater  flows, and water
quality within the planning area.  Permitting data would be an additional
source of information.  At the  start of the areawide  planning, this data
will be reviewed and supplemented as necessary.  The  assessment of each
existing waste treatment system will include a performance evaluation
of the treatment plant including plant performance,  operating problems,
operating personnel, sampling  programs and maintenance programs.  An
infiltration/inflow analysis should  also be made in  accordance with EPA
Guidance for Sewer System Evaluation to  determine whether excessive
infiltration or inflow exists  and, on a  preliminary  basis, costs of
any corrective measures required.  Should the analysis determine the
existence of excessive infiltration/inflow,  a more detailed sewer
system evaluation survey will  be made to more specifically define  the
problems and determine the needed corrective measures and their costs.
The detailed evaluation survey  would not be eligible  for grant assist-
ance under the 208 planning grant, but would be eligible for assistance
under a construction grant. An  inventory of sludge utilization and
disposal capability is also needed in order to  assure satisfactory
management of residual wastes.
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C.  Estimate Future Haste Loads and Flows

     To provide the basis for planning and preliminary design of
facilities, forecasts must be made of the future variations of
waste loads and the flows over the planning period.  As described
in Chapter 4, such forecasts should be based upon evaluation of land
use plans, economic and demographic growth trends for the planning
area; and any growth constraints imposed by air quality implementation
plans, zoning restrictions or permit conditions.  The effects of
selected flow and waste reduction measures, including sewer system
rehabilitation to correct infiltration/inflow, must also be reflected
in the flow forecasts to permit subsequent calculation of waste
treatment system cost reductions.

     1.  Land Use and Development

          Wastewater load and flow projections must conform to the time
     related development shown on the land use plan eventually adopted
     for the area (see Chapter 4).  The land use plan should provide
     for consistent uses in flood hazard or environmentally sensitive
     areas.  To avoid or minimize possible induced changes in the
     growth pattern from that projected from the land use plan,
     provision of excessive waste system capacities must be controlled.

     2.  Flow and Waste Load Forecasts

          The expected economic and population growth patterns for the
     planning area, as reflected by the land use plan, must be trans-
     lated into estimates of wastewater flows and waste loads.  A
     realistic allowance for unpreventable infiltration should be
     added.  The estimated future changes in flows and waste loads
     from industries to be served by the municipal system must reflect
     application of EPA pretreatment requirements for existing and new
     industries plus any expected process changes affecting wastewater
     and treatment residuals.  Wastewater flow forecasts should also
     include the effects of applying selected combinations of flow and
     waste reduction measures within the system and allowance for
     present and anticipated discharges from septic tank pumpages into
     the systems.

     3.  Sludge Generation Forecasts


          Estimates should also be made of the volumes and compositions
     of sludge which will be generated from treatment of the projected
     wastewater.  These forecasts would be modified to the different
     treatment levels that may be inherent in each of the alternative
     systems considered.
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D.  Develop and Evaluate Alternatives

     The development of facilities systems involves the systematic
comparison of many available subsystem and system options.  The
concept of an areawide plan for municipal  wastewater facilities does
not necessarily imply a single interconnected waste treatment system
for the area.  Separate wastewater systems for outlying areas may prove
to be more cost-effective, at least on a-near-term basis.   Subsystem
options for each municipal wastewater system being considered should
be identified and compatible options combined into preliminary treatment
systems for the entire area consistent with the alternative wasteload
allocation sets.  Using a rough assessment of costs and impacts, these
alternative facility plan components should be screened with respect
to goal attainment, monetary costs, and environmental, social, and
economic effects.  Consideration will  also be given to legal and
institutional constraints and implementation feasibility.   Those
alternatives found to be unacceptable should be rejected and the
remaining alternatives should then be evaluated in detail  to develop
a limited number of proposals for systematic comparison of other point
source controls.  Preliminary alternatives featuring each  of the pre-
viously discussed waste management techniques should be developed
unless adequate justification for eliminating a technique  during the
planning process is presented.

     The following paragraphs briefly describe major factors to be
considered and procedures to be applied in the development and
evaluation of alternative wastewater systems.

     1.  Flow and Haste Reduction Measures

          The Act encourages the use of a  variety of methods for
     reducing both the volume and amount of waste within municipal
     wastewater systems where such methods are cost efficient.  Some
     of the following measures would not only reduce wastewater loads,
     but would reduce water supply demands as well.

          a.  Infiltration/inflow reduction by sewer system rehabili-
          tation and repair and elimination of roof and foundation
          drains.

          b.  Household water conservation,  measures, such as household
          water saving appliances and  fixtures as well  as  designing
          more appliances for less water consumption.

          c.  Water and wastewater rates that impose costs proportionnal
          to water used and wastewater generated and use of water meters.

          d.  Educating the public on  the  value of their water resources
          in order to reduce their consumption.
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2.  Industrial Service

     Municipal waste treatment systems should be planned to serve
industrial users of the area whenever practicable and cost effective.
Special requirements, issues, and procedures associated with indus-
trial  use of a municipal system are covered in Section 5.4.B of
this chapter.

3.  Sewers

     Planning of a waste treatment system includes the comparison
of alternative arrangements of interceptors and collection pipes,
including phased development, to assure selection of a cost-
effective configuration.  In developing portions of the planning
area,  the capacities of the system, in particular the larger
lateral and interceptor sewers, should generally accomodate not
more than the 20-year wastewater projection based upon the land
use plan.  However, choice of interceptor and collection pipe sizes
should reflect cost-effective analysis of alternative pipe sizes
over the planning period.  The arbitrary practice of designing
interceptors for long term projected growth or ultimate development
within the service area should be discouraged.  Consideration should
be given to interim (short term) treatment works for outlying areas
or to septic tank units for individual or clustered developments
in low density areas as alternatives to immediate construction of
interceptors serving such areas.

4.  Waste Management Techniques

     Alternative waste management techniques must be evaluated to
determine the BPWTT for meeting applicable effluent limitations
including those related to wasteload allocation.  Information
pertinent to this evaluation is contained in an EPA document
entitled "Alternative Waste Management Techniques for Best
Practicable Waste Treatment" (Proposed in March 1974).  Selection
of a waste management technique relates closely to effluent dis-
posal  choices.  Preliminary alternative systems featuring at least
one technique under each of the three categories below (treatment
and discharge, wastewater reuses, and land application or land
utilization) will be identified and screened.  A more detailed
proposal will be prepared for each unless adequate justification
for eliminating a technique during the screening process is presented

     Published cost, performance, and other information is available
for many alternative treatment technologies.  Preliminary screening
of these technologies involves interrelating the costs and relative
treatment capabilities of each.
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a.  Treatment and Discharge

     Treatment and discharge techniques include the
following:

     (1) Biological  treatment including ponds, activated
     sludge, trickling filters, processes for nitrification,
     and denitrification.

     (2) Physical-chemical  treatment including chemical
     flocculation, filtration, activated carbon, break-
     point chlorination, ion exchange, and ammonia stripping.

     (3) Systems combining  the above techniques.

b.  Wastewater Reuse

     In comparing waste management techniques and alternative
systems, wastewater reuse applications should be evaluated as
a means of contributing to  local  water management goals.
Such applications include:

     (1) Industrial  processes

     (2) Groundwater recharge for water supply enhancement
     or preventing salt water intrusion

     (3) Surface water supply enhancement

     (4) Recreation lakes

     (5) Land reclamation.

     Wastewater reuse needs should be identified and defined
by volume, location, and quality.  These needs may influence
the location of the treatment facilities, the type of process
selected, and the degree of treatment required.

c.  Land Application

     The application of wastewater effluents on the land
involves the recycle of most of the organic matter and
nutrients by biological action in the soil plus plant
growth for the breakdown and disposal  of nutrients.  Such
treatment generally provides a high degree of pollutant
removal.  Planning of the land application techniques should
reflect criteria and other  information contained in the EPA
document on "Alternative Waste Management Techniques for Best
Practicable Waste Treatment".
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          Land application techniques include:

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

          (2) Overland flow.

          (3) Infiltration-percolation.

          (4) Other approaches such as evaporation,
              deep well injection, and subsurface
              leach fields.

5.  Residual (Sludge) Management

     Closely aligned with the evaluation of each waste management
technique is the management of the residual wastes.  This includes
the evaluation of alternative combinations of sludge processing and
sludge utilization techniques for satisfactorily and economically
disposing of the quantities of residual wastes.  Care must be
taken to assure that the areawide waste management activities do
not appreciably add to air quality or water quality problems due
to sludge processing and diposal.

     A variety of sludge processing and utilization techniques are
available including (a) thickening, (b) chemical conditioning,
(c) chemical stabilization, (d) aerobic and anaerobic digestion,
(e) dewatering, (f) thermal processing for volume reduction or
drying, (g) composting, and (h) land spreading as a soil  conditioner
Sludge disposal options are limited primarily to land disposal, and
land utilization and incineration, and must comply with the EPA
policy statement on acceptable methods, based on current knowledge,
for the ultimate disposal of sludges from publicly owned wastewater
treatment plants.

     Some disposal techniques such as soil conditioning and land
utilization realize the nutrient value of sludge as fertilizer.
They should be given special attention in the adoption of a sludge
disposal program for the area.  Furthermore, the consideration of
incineration should recognize local air pollution control regula-
tions and energy requirements.

6.  Location of Facilities

     Evaluation and choice of sites for treatment plants, inter-
ceptors, transmission lines, outfalls, pumping plants, and other
major works should comply with the land use plan.  Factors to be
considered in such locations include:

     a.  Possible odor and aesthetic problems
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     b.   Flexibility to convert to possible future reuse
         and additional pollution abatement needs.

     c.   Special  protection of potable, shellfish, and
         recreation waters.

     d.   Avoidance of floodplain and wetland areas, if
         practicable.

     e.   Induced  growth impacts in flood hazard or
         environmentally sensitive areas.

7.  Regionalization

     Regionalization options should be evaluated to assure use of
the most cost-effective facilities systems consistent with the
areawide waste management needs.  Various  combinations of treat-
ment plants, interceptors and other works  will  be identified and
consistent with wasteload allocations.   The economy of scale
associated with a large treatment plant must be balanced with
environmental and social impacts, especially if the interconnected
system would tend to induce growth patterns that conflict with the
land use plan. The effects of streamflow  depletion within the
area due to the transport of wastewater to a downstream plant
location and the, impacts of concentrating  wastes from plant efflu-
ents at fewer points must also be considered.

8.  Phased Development

     a.   General

          In examining the cost-effectiveness  of a waste treatment
     system, one  important aspect is the alternative of providing
     sufficient capacity initially to serve the projected needs of
     the area over the planning period versus  meeting those needs
     with phased  development of the systems and modular construction
     of individual facilities within the system.  The phased and
     modular development options would involve planning to construct
     facilities and facilities components  at intervals throughout
     the planning period to accomodate projected increases of
     waste loads  and flows.  The factors to be considered are:

          1.  The service life of the treatment works.

          2.  The incremental costs.

          3.  The flow and wasteload forecasts.
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     b.  Reserve and Excess Capacity

          The planning of waste treatment facilities will normally
     allow for some excess capacity to allow for daily, wet
     weather and seasonal flow variations as well as to provide
     for projected flow increases.  The system capacity excess
     beyond that needed to handle existing average daily flow,
     however, must be examined from a cost-effective viewpoint.
     This is particularly true of treatment plants serving areas
     experiencing growth where phased construction of the capacity
     may be more cost-effective than the initial construction of
     that capacity.  Also, to equalize daily flow variations, pro-
     vision of holding storage at the plant intake must be considered

     c.  Phased Development of System

          Phased development of the system pertaining to sewers
     and multiple plant systems is advisable in rapidly growing
     areas; in areas where the projected flows are somewhat un-
     certain; or where full initial development of facilities
     would tend to distort growth from that shown on the land use
     plan for the area.  The phasing must be accomplished so as to
     provide sufficient excess capacity at the beginning of each
     construction phase to accomodate expected flow increases
     during the phase.  Phasing of the sewers may involve provid-
     ing for parallel or multiple systems or extention of single
     lines.

     d.  Modular Development of Individual Facilities

          Modular development of individual facilities, pertaining
     to components of the wastewater treatment plant, is advisable
     in areas where high growth rates are projected; where the
     required degree of treatment must be upgraded later during
     the planning period; or where existing facilities are to be
     used initially but phased out later.  Modular development
     would also avoid long term operating problems associated with
     underutilization of certain components of the plant.  Where
     modular development is used, provisions should be made for
     future additions during the design of the initial facilities.

9.  Flexibility and Reliability

     Flexibility and reliability must be considered throughout
the planning of municipal facilities.  As alluded to in previous
sections flexibility factors include possible upgrading of water
quality objectives, future application of new technologies, future
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          application  of  wastewater  reuse,  modular and  phased  development
          of facilities,  and  temporary  treatment  plants.

               Reliability  considerations are  important in  that there is
          a risk  of failure of  any planned  wastewater system.   With  a
          view toward  minimizing  this risk,  the probability, duration,
          and impact of such  failures will  be  considered  for each  system
          and its components.


5.3  Combined and Storm Sewer Discharges

     A.   Introduction

          The overall  objective of this portion of the  chapter is  to assess
     pollution problems associated with combined  sewer  overflow and  storm
     sewer runoff and  identify  alternative  approaches for controlling those
     problems.  Storm  sewer discharges  and  combined  sewer overflows  can  be
     sources of significant quantities  of pollutants.   Because they  are  an
     integral part of  the municipal  wastewater collection system,  untreated
     overflows from combined  sewers  pose an  added  threat  to public health.

          Various techniques  for  controlling and  treating combined and
     stormwater flows  can be  incorporated into alternative areawide  subplans
     for point sources.   Quite  often those  problems  can be substantially
     reduced through effective  control  of the sources and/or the runoff
     before it enters  the storm and  combined sewer systems as  discussed  in
     Chapter 6.  The correlation  and comparison of the most cost-effective
     mix of controlling the problems at their source versus controlling  the
     runoff once  it enters  the  confined system can be made in  the  later
     steps of the planning  process where alternative subplans  for  point  and
     nonpoint sources  are merged  into alternative  areawide plans.  (Chapter
     3.3.  D.8).

     B.   Inventory Existing Conditions

          The existing combined and  storm sewer discharges for the entire
     area  must be accurately  assessed to define the  nature of  the  problems.
     Existing storm and combined  sewer  systems must  be  inventoried.   Such
     an  inventory should  include  locations and condition of intake bypasses,
     pipes, regulatory equipment  and other features  and an assessment of
     both  the existing performance of the system and its optimum performance
     with  intensive management, operation and maintenance.  Such information
     as  the flow  variations, design  capacities, wastewater constituents,  and
     waste loads  are needed.  Where  flow records are lacking,  estimates  of
     overflows and discharges based  upon observations should be  correlated
     with  rainfall  amounts.  Wasteload estimates should be based on  pollutant
     sampling and subsequent tests for such  parameters as dissolved  oxygen (DO),
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biochemical oxygen demand (BOD), ammonia nitrogen (NFL-N), total solids
(TS)5 suspended solids (SS), toxics, and both total  and fecal coliform
counts.

C.  Estimate Future Haste Loads and Flows

     To provide the basis for planning of possible control measures
for combined sewer overflows and storm sewer runoff, forecasts must
be made of the waste load magnitude, intensity, and duration of the
problems associated with such discharges throughout the planning period.
Information obtained on existing discharges can provide a convenient
base for the estimates.  Flow volumes and waste loads during storm
periods should be related to the tributary drainage area.  The
resulting information can permit forecasting of flow volumes and waste-
load increases resulting from future changes in land use and development
within the drainage area.  Such information can provide the basis for
estimating flows in storm sewer systems within the planning area.  Adjust-
ments in the projections should be made to account for density changes,
reduction in pollutant discharges due to future protection of environ-
mentally sensitive areas as reflected in the land use plan, and
probable flow and waste reduction measures both above and withing the
sewer systems.

D.  Develop and Evaluate Alternatives

     The development of alternative areawide control of combined sewer
overflows and storm sewer runoff involves the systematic comparison of
feasible control options including both structural and nonstructural
alternatives.  Operational strategies should be explored for the entire
system to attempt to maximize the system capacities.  EPA research has
demonstrated many types of control and treatment techniques, in
particular for combined sewer overflows.  Among these, storage options
both upstream from or within the systems appear feasible.  However, such
capacity would generally be limited to the most highly polluted initial
storm runoff from a low-frequency storm event (one chance in one to one
chance in five of being equalled or execeeded during any single year).

     Specific factors to be considered in the development and evaluation
of combined and storm sewer discharge subplan components are contained
in the following paragraphs.  In general, the most cost-effective
solution will be a mixture of operation/maintenance and construction
techniques.

     1.  Flow and Waste Reduction

          A variety of techniques can be used for reducing flow volumes
     and waste amounts from entering the system.  Consideration of these
     techniques should be coordinated with nonpoint source control options
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being planned for the tributary drainage area.   They include:

     a.  Reduce disturbance of land cover and maintain surface
         infiltration capacities.

     b.  Control  patterns and densities of urban development.

     c.  Reduce nonpoint source runoff through control measures
         for urban and construction activities.

     d.  Preservation or management of lands  that have natural
         or existing characteristics for retarding or reducing
         flow and surface pollutants.

     e.  Surface  runoff and in-system water control  measures such
         as use of permeable material  for paving, flow retardation
         structures, and other means of storing  and  retarding  runoff
         including planned intermittent shallow  flooding of parking
         areas, streets and other  surfaces where damage would  be
         minimal.

     In 208 planning, emphasis will  be placed on use of the above
techniques as alternatives or supplements to  the control  measures
discussed below as the former are  generally far  more cost-effective
and less environmentally disruptive.

2.  Alternative Control Techniques

     Alternative  control  techniques  that should  be considered  in
combined sewer overflow and storm  sewer discharges can be grouped
into the following five categories.   Although these  categories
apply primarily to combined sewer  overflows,  some of them could be
appropriate for storm sewer discharges.

     a.  Separation of sewage and  storm collection systems
     (generally the most costly and least environmentally acceptable
     approach);

     b.  Operational control  of the existing  system, (maximum
     use of the system storage by  computerized flow  regulation
     and subsequent treatment at the plant);

     c.  Storage  at points within  the system  or  at the point of
     discharge and subsequent treatment;

     d.  Direct treatment of overflows (in-line  high rate
     treatment methods).
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               e.   High level  of maintenance including  periodic  flushing
               of  sewer systems.

          3.   Location of Sewer Outlets

               Storm sewer capacities  are generally related  to the  potential
          damage and public inconvenience associated with  rainfall  events.
          These sewers usually outlet  into nearby waterways  that can  adequately
          receive  the runoff.   Future  storm sewer systems  anticipated within
          the planning area should be  evaluated  together with the existing
          storm sewer systems.

          The cumulative net increase  in runoff  attributed to these systems
     should be evaluated to determine  the associated effects on  flood stages
     in  the receiving waters.   More important, from a water  quality viewpoint,
     the waste loads existing  and anticipated future storm sewer discharges
     should be evaluated and compared  with the wasteload allocations  limits.
     Where such wasteload allocation limits would be exceeded, an extension
     or  relocation of the outlet sewers  to locations where the receiving
     streams  can  readily assimilate the  wastes may be more cost-effective
     than developing control measures.


5.4  Industrial Wastewater

     A.   Introduction

          The overall objective of planning for  the control  and  treatment
     of  industrial wastewater  is to provide the  most efficient approach
     for serving the present and future  industrial  wastewater treatment
     needs for the area.  Such treatment needs must meet the applicable
     requirements  of Section 204, 301,  302, 304, 306, 307, and 316  of
     the Act.  Industries served by municipal systems must comply with
     pretreatment  annd cost recovery requirements.   Direct discharge  of
     industrial wastes to receiving waters must  comply  as  a  minimum,  with
     the provisions of the pertinent Effluent Limitations  Guidelines  and
     New Sources  Performance Standards.   The application of  higher  treatment
     levels or internal wasteload reductions will be required where waste-
     load allocations dictate  more stringent restrictions.  Applications of
     higher levels of treatment to meet  water quality standards  can be
     mitigated through the restriction  of location of future industrial
     development to areas where receiving waters can more  readily assimilate
     the treated wastewater.  Such control of industrial  location should be
     factored into the land use plan and recognize other constraints  such
     as  air quality control.

          The procedures for evaluating  industrial  waste sources and  problems
     are basically parallel to those presented  in Section  5.2 of this chapter
     for municipal wastewater  systems.
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     The existing wastewater flows from all  major industrial  sources
should be accurately assessed for the area.   Existing information
should be used where available including information on those industries
that discharge into municipal systems.  Such information as average
flow-rates, flow variations, seasonal variations, wastewater character-
istics and constituents, and mode of disposal  are needed as a basis for
estimating design flows and wasteload reductions.  Particular emphasis
should be given to toxic constituents within the wastes and to thermal
pollutants present.  Forecasts must be made  of the future variations
of waste loads and flows over the planning period and the discharge
locations of those wastes.   Such forecasts should be based upon economic
and industrial trends, types of industries and constituents of associated
wastes, location constraints imposed by the  land use plan, and other
restrictions imposed by industrial permits and air quality implementation
plans.  Attention should be given to estimating waste sludges and slurries
generated by the industries as well  as to the  influence that industrial
loads will have on treatment plant sludge.  The effects of user charges,
pretreatment, and effluent  limitations guidelines or higher treatment
levels on water and wastewater flows should  be incorporated into the
projections.

B.  Develop and Evaluate Alternatives

     The development of alternative approaches for treatment of
industrial wastes and the degree of treatment  involves  a systematic
comparison of the following options:

     a.  Pretreatment and  discharge of wastewater to municipal  systems;

     b.  Direct treatment by individual  industries and  discharge of
         wastewater into receiving waters;

     c.  Direct treatment and discharge by groups of industries;

     d.  Reuse of industrial wastewater;

     e.  Land application.

     In conjunction with each of the above options,  consideration should
be given to discharge to either water or  land  and to the effects of flow
and waste reduction of possible internal  recycling and  process changes.
Various areawide options should be identified  in terms  of meeting waste-
load allocation constraints and compared  in  terms of a  rough  assessment
of costs and impacts.  Consideration should  also be  given to  institutional
constraints and feasibility.

     Specific issues to be  addressed are  included in the following
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paragraphs.

     1.   Flow and Haste Reduction

          Care should be given to accurately assessing the flow and
     waste reduction as it relates to those industries that discharge
     or will discharge into municipal systems.  The continually more
     stringent technical and financial requirements on industry should
     lead to process changes that use less water and create less waste-
     water.  Furthermore, these factors may include inplant recycling
     with corresponding reductions in wastewater volumes and possibly
     wasteloads.

     2.   Minimum Effluent Limitations
          Industrial wastewater treatment must comply with the minimum
     treatment requirements for Best Practicable Control  Technology
     (BPT) and Best Available Control Technology (BAT) by 1977 and 1983,
     respectively.  These treatment requirements are set forth for the
     industries cited in Section 306 of the Act in a series of EPA
     documents entitled "Development Document for Effluent Limitations
     Guidelines and New Source Performance Standards for 	
     Point Source Industry".  Those guidelines contain criteria by
     industry for Best Practicable Control Technology Currently
     Available (known commonly as BPT) and Best Available Control
     Technology Economically Attainable (known as BAT).  The guidelines
     also provide minimum criteria for New Source Performance Standards
     and New Source Pretreatment Standards.

     3.  Joint vs. Separate Municipal and Industrial Facilities

          Municipal waste treatment systems should be planned to serve
     industrial users of the area whenever practicable and cost-
     effective.  Because of the unusual economy of scale associated
     with larger municipal-industrial facilities, as compared to
     separate municipal and industrial facilities, a joint system will
     often be cost-effective.  In many cases, however, it may be more
     economical to have separate industrial treatment facilities
     because of such factors as characteristics and quantities of
     industrial waste, industrial pretreatment requirements, and indus-
     trial locations and groupings which facilitate joint industrial
     treatment and/or reuse of industrial wastewater.  These consider-
     ations are also relevant to the cost and effectiveness of sludge
     disposal options for each alternative facility.

          Industrial use of municipal facilities will be encouraged
     where total costs (environmental and monetary) would be minimized.
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          Hhere industrial  flow handled  by municipal  systems  is significant,
          cost of separate  treatment of  industrial  wastes  versus cost of
          pretreatment plus  joint municipal-industrial  facilities,  should
          be compared.  This involves comparing  the incremental cost of
          the municipal  facilities required to transport,  treat, and dispose
          industrial  wastes, together with the costs  of corresponding pre-
          treatment required,  with the cost of separate industrial  treatment
          and disposal facilities of those wastes.   In  particular,  the analysis
          will cover those  industries desiring municipal service but not so
          served when facilities  planning  is initiated.

          4.  Pretreatment  and Cost Recovery

               Industrial wastes  served  by municipal  systems  must comply
          with industrial pretreatment regulations  and  cost recovery
          regulations.  The  pretreatment regulations  basically requires
          the removal  of waste constituents  of industrial  wastes that are
          not compatible with  the municipal  wastewater  treatment process.
          Compatible wastes, generally BOD and suspended solids, can be
          passed to the municipal  treatment plant for treatment. The
          cost recovery regulations prescribe that  industrial  users  must
          bear a proportionate share of  the cost of operating and maintain-
          ing the municipal  system together with repayment of the portion
          of the Federal grant attributed  to that waste.   Care should be
          given to selecting industrial  sites where receiving waters can
          more readily assimilate the residual wastes and  associated nonpoint
          source runoff. Such control of  industrial  locations should be
          factored into the  land  use plan  and recognize other constraints
          such as air quality  control.


5.5  Other Point Sources

     The identification of  other  point sources within the  planning  area,
possible control options, and  feasible controls  should  be  included  into
point source subplans.  In  particular, private wastewater  systems should be
considered and evaluated preferably in conjunction  with the municipal  waste-
water facilities.  Generally,  these point  sources should include those re-
quired to obtain permits under the permit  program.


5.6  Development of Alternative Subplans

     A.   Purpose

          The alternative subplans for point source controls  should  correspond
     to  alternative waste!oad  allocation sets for critical  water quality
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      conditions for dry weather and rainfall conditions.  At least one
subplan must be developed to corresppond to each wasteload allocation
set.  Subplans for continuous point sources, primarily from municipal
and industrial treatment works, must satisfy the critical wasteload
allocation sets for dry weather conditions.  Subplans for both muni-
cipal and industrial treatment works and combined and storm sewer flows
during critical intermittent rainfall conditions must correspond to
wasteload allocations for combined sewer overflows and storm sewer
discharges.

     In merging those subplans with similar subplans for nonpoint sources
in Chapter 3, various mixes of these subplans can be interrelated and
compared in terms of the established criteria for overall plan comparison

B.  Continuous Point Source Subplans

     The preparation of point source subplans should correspond to
those wasteload allocations established in Chapter 3.  For critical
dry weather conditions during the course of the subplanning for
municipal and industrial wastewater sources, further options for
those sources should be explored and reasonable alternatives worthy
of consideration should be incorporated into additional  wasteload
allocation sets.  In most instances several alternative subplans can
be identified to meet a given wasteload allocation set.

C.  Intermittent Point Source Subplans

     The preparation of point source subplans for intermittent flows
must correspond to wasteload allocations for all point sources,
particularly for combined sewer overflows and storm sewer discharges,
for critical rainfall conditions.  The subplans must each be internally
consistent.  Generally, the treatment levels for the continuous point
sources will not be increased for the intermittent point source sub-
plans.  The additional waste treatment requirements will normally be met
through control of combined sewer overflows and, where practicable, storm
sewer discharges.

D.  Disposal of Residual Hastes

     The disposal of residual wastes for all point source subplans
should conform with an areawide program of areawide solid waste
disposal .


E.  Screening of Alternatives

     Based on comparative evaluation, the most desirable and undesirable
                                5-17

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aspects of each alternative subplan will be identified and any clearly
inferior alternatives will  be rejected.  In some cases* new alternatives
will be identified and formulated.  Where necessary to better distinguish
their relative merits, the  proposals will be refined and their compar-
isons repeated.  This iterative process will produce a limited and
manageable number of proposals for final evaluation and public review
as a basis for plan selection.

F.  Description of Alternatives

     Following screening of the system alternatives, the following
alternatives should be presented as an input to the systematic
comparison of areawide alternatives (Chapter 3).

          i.  Residual wasteload characteristics of each
              alternative

         ii.  Total cost of each alternative expressed as its
              present value or average annual  equivalent value
              of capital  and operating costs for overall alter-
              native and subsystem components

        iii.  Reliability and flexibility of each alternative and
              subsystems included in each alternative

         iv.  Significant environmental  effects of each alternative
              consistent with NEPA including a  specific statement on
              future developmental  environmental  impact.

          v.  Contribution  of each alternative  to other water-
              related goals of the planning area.
                             5-18

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                              CHAPTER 6


           DETAILED CONSIDERATIONS FOR NONPOINT SOURCE CONTROL


6.1   Introduction

          Chapter 3 presents the framework for the systematic evaluation
     of all sources of pollution and selection of alternative control
     plans for the area.  The control plans for an area must identify
     the nonpoint sources, evaluate their impact on water quality,  and
     delineate measures for their control.

          Point sources of water pollution are defined by P.L. 92-500.
     Nonpoint sources are not defined by the Act but are mentioned  in
     several sections.  By inference, the nonpoint sources are the
     accumulated pollutants in the stream, diffuse runoff, seepage,
     and percolation contributing to the degradation of the quality
     of surface and ground waters.  Realistically, they include the
     millions of small point sources that presently are not covered
     by effluent permits under the National Pollution Discharge
     Elimination System.  Natural sources (seeps, springs, etc.)
     are also included since there is no ownership to permit.

          The runoff, seepage, and percolation from a number of sources
     must be considered in the development of a control plan for an
     area.  These nonpoint sources include agriculture, construction,
     mining, silviculture, and urban/suburban areas.  Water quality
     degradation resulting from land and subsurface disposal of
     residual wastes, salt water intrusion, and hydrographic modi-
     fications must also be considered.


6.2  Statutory Requirements

          Section 208(b)(2)(F-I) states that a plan prepared under
     the waste treatment management planning process shall include:

          "A process to (i) identify, if appropriate,...nonpoint
           sources of pollution ...and (ii) set forth procedures
           and methods (including land use requirements) to control
           to the extent feasible such sources."

     Further, Section 208(b)(2)(J) and (K) provide that a plan shall
     include:

          "A process to control the disposition of all residual waste
           generated in such area which could affect water quality; and

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          "a process to control  disposal  of pollutants on land
           or in subsurface excavations within such area to
           protect ground and surface water quality;"

6.3  General Approach of Nonpoint Source  Control  Planning

          This chapter describes some of  the considerations that
     should be included in analysis  of npnpoint source pollution
     problems and suggests a systematic procedure for  integrating
     nonpoint source control into areawide plans.  The suggested
     procedure can be divided into three  parts:

         Problem Analysis

              The total  nonpoint source contribution to the
         waters of an area must  be identified.   The relative
         impact of nonpoint sources  and point sources  on the
         water quality of the area must be evaluated.   A
         general  appraisal  should be made and reported for all
         nonpoint sources and a  determination made  of  those
         sources  or category of  sources that are  significantly
         affecting the waters of the area.

              The significant nonpoint sources  must be identified
         as to type,  location, extent,  impact on  water quality
         and control ability.   The level of planning detail  for
         problem analysis should correspond to  the  severity
         of the different nonpoint source problems  in  the area.
         The use of monitoring and modeling in  nonpoint source
         problem assessment is discussed  further  in 6.4 of this
         chapter.

         Goal  Analysis

              The full delineation of the water quality problems
         of an area requires that nonpoint sources  be  considered
         along with point sources of water pollution.   The ob-
         jective  is to evaluate  the  pollution from  both point
         and nonpoint sources and to integrate  a  control  program
         for the  significant nonpoint sources into  an  overall
         water quality protection plan.   Nonpoint source controls
         may be necessary for several  reasons:

              1.   It  may not be  possible  to maintain water quality
                  standards using only  the point  source controls.

              2.    It may not be equitable to impose only point
                   source controls.

              3.    Nonpoint source controls may be  the most
                   cost-effective.
                             6-2

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          Control  Selection Process

                In  evaluating nonpoint source controls,  both the
          technical  feasibility of the controls and their cost-
          effectiveness and feasibility of implementation should
          be considered.   Controls that are generally regarded
          as being technically feasible are discussed in 6.5
          of this  Chapter.  Procedures for selecting the con-
          trols that are most cost-effective and implementable
          are discussed in 6.6 of this Chapter.  Because of the
          difficulty of determining precise cost-effectiveness
          of nonpoint source controls, procedure for selection
          of nonpoint source controls on the basis of estimated
          cost-effectiveness is also presented in 6.6 of this
          Chapter.

6.4  Identification  and Evaluation of Nonpoint Sources

          The nonpoint sources are the sources contributing to water
     quality degradation in a stretch of water, where that degradation
     cannot be accounted for by the known point sources.  This applies
     from the largest basin to the smallest sub-basin.  It can be
     expressed as  follows:

               N = (Q+S+D) - (P+I)
     where:
               N = Quantity (mass) of nonpoint source pollutants in  terms  of
                   a given parameter, under-a given critical flow condition
               Q = Quantity of pollutants in the water  leaving
                        the  test area
               S * Quantity of settlement and precipitation of
                        pollutant
               D = Quantity of decay of nonconservative pollutants
               P = Quantity of pollutants discharged by point sources (assumed
                   to be constant under a given critical flow condition)
               I = Quantity of pollutants in the water entering the test area

          The accuracy of the efforts to evaluate the significance of
     nonpoint sources will be a function of the accuracy of the  data
     collected.  The runoff, seepage, and percolation of pollutants
     from nonpoint sources is highly dependent on climatic, seasonal,
     and other variable events.  Such occurences as high rainfall,
     antecedent rainfalls, cropping patterns, street sweeping schedules,
     time of travel  of runoff, scouring and re-entry of pollutants,  etc.,
     must be considered in the evaluation.  While average conditions
     shed light on the general situation, an analysis based on high
     and/or low runoff periods, and covering specific climatic events
     and seasonal  periods, is more likely to provide an accurate
     evaluation of the significance of each nonpoint source.


                                 6-3

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     The data available in the records of various agencies should
be secured and evaluated.   These data from such sources as building
inspection offices, soil  and water conservation districts, planning
agencies, etc. can serve  to locate many of the potential nonpoint
sources of pollutants.   Soil survey maps, construction records,
urban sanitation records,  and other such documents can provide
much information for evaluation of the potential for pollution
from nonpoint sources.   A number of agencies (USGS, water treat-
ment plants, health units, etc.) maintain water quality records.
These records should provide insight to the effects of nonpoint
sources.

A.  Monitoring and Sampling to Identify Nonpoint Sources

     In the final  analysis, accurate identification of..nonpoint
sources will necessitate  monitoring and,in many cases, field
sampling.  The comprehensiveness of the monitoring and sampling
will depend on the adequacy of existing data,  the reliability
of nonpoint source prediction models, and the  complexity of the
nonpoint source problems  of the area.

     It is not expected that every nonpoint source contribution
in the area can be identified in the relatively short timeframe
of the initial 208 planning effort.  The monitoring and sampling
approach needed for nonpoint source identification should determine
a schedule of prioritized  activities that will  enable a given
degree of identification  of individual  nonpoint sources at given
points in time.  For example, if the total nonpoint source load
to the area is 1/3 of the  total  pollutant load for a given
parameter, the monitoring  and sampling activities should be
aimed at determining a  given percent of the nonpoint source
load by a given date.

     The initial coverage  of the monitoring and sampling approach
should be influenced by local conditions and available resources.
In general, the initial coverage of the monitoring and sampling
approach should proceed from two kinds of information.  First,
known and suspected nonpoint sources such as waste lagoons,
septic seepage areas, land fills, spray irrigation areas, major
construction sites, urban  storm water overflows,etc:, should" be mapped.
Second, instream water  quality data which could be related to the
specific nonpoint source  sites should be evaluated in order to
determine whether a given  increment of waste detectable in the
stream could be attributed to a given nonpoint source.  The sum
of the wasteloadsthat could be traced back to  contributing
sources should be a given  percent of the total  nonpoint source
load that is chosen for the initial monitoring and sampling
coverage.  If the individual nonpoint sources  that can be
identified do not sum up  to that given percent of the total
nonpoint source load, then additional data should be collected.
                               6-4

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     B.   Prediction of Nonpoint Source Loads

          Monitoring and field sampling is costly and must be conducted
     over a long time period to construct an accurate set of data on
     the nonpoint source problem.   It is therefore desirable to com-
     plement the monitoring and sampling approach with generalized
     predictions of nonpoint source loads from measurable watershed
     parameters such as soil type, slope, vegetative cover, land use,
     etc. Some  predictive models  have been developed.  Guidance on
     the applicability of these models and the services available
     from Federal agencies for utilizing the models is discussed in:

          "Methods for Identifying and Evaluating the Nature and
           Extent of Nonpoint Sources of Pollutants," EPA 430/9-73-014

          Additional guidance on prediction models and techniques
     for nonpoint sourcesis being  developed by EPA and will be available
     in subsequent guidance.

6.5  Control of Nonpoint Sources

          No single control method or set of control methods will be
     appropriate for all types of  nonpoint source problems.  Even
     controls for a particular type of source will vary in their
     effectiveness for controlling a particular type of source according
     to geographic location.  The  controls should be tailored to local
     conditions if they are to be  effective.  As with the problem of
     identifying  nonpoint sources  of pollution, expertise with the
     specific types of nonpoint sources and local conditions should
     be the basis for design of appropriate controls.

          The first step in determining necessary nonpoint source
     controls involves identifying the technically feasible structural
     controls and the practicable  nonstructural controls that are
     available for particular nonpoint source problems.  Control
     alternatives for particular types of nonpoint sources are described
     in this section.  The control alternatives discussed herein
     are directed towards types of nonpoint source problems likely
     to be encountered in urban-industrial areas.  References are
     provided on information concerning nonpoint sources that are
     more likely to occur in non-urban areas.  It is emphasized that
     these control alternatives are cited as examples and that other
     viable alternatives, if available, should also be investigated
     and considered.
                                   6-5

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     In depth information on the various control alternatives
may be obtained from the referenced guidance reports for each
type of source.  In general, controls for nonpoint sources
consist of either structural controls or land use and land
management controls.  The implementation and enforcement of
these nonpoint source controls is further discussed in
Chapter 7.3.
A.  Urban Stormwater Runoff

     Water pollution aspects of urban runoff are related to both
the quantity and quality of the storm water runoff.  When a rain
event occurs, the energy of dissipating raindrops dislodges
pollutants from street surfaces, roof tops, lawns and other urban
sources, causing contaminant particles to become suspended in
solution.  Subsequent runoff transports the pollutants across
urban land, into gutters, and eventually deposits the runoff
into receiving waters.  The pollutant concentration is greatest
at the beginning of a rainfall event and as the rainfall con-
tinues, subsequent runoff becomes less contaminated.

     Almost every conceivable pollutant has been identified in
urban runoff.  The more commonly associated urban pollutants
include: dust, dirt, pathogens, fertilizers, pesticides, battery
acid, rubber, grease, oil, animal and bird droppings, heavy
metals, salts, sand, gravel, coal, leaves, paper products,
plastics, glasswares, and metals.

     The pollutant load in a particular storm runoff depends
upon (1) the amount of material which has accumulated or developed
on surfaces since the last storm and (2) the efficiency of the
working action accomplished by the storm.  A direct relationship
exists between the cleanliness of the urban environment and
the pollutants in storm water runoff.

     Measures for controlling the pollution potential from urban
storm runoff include:

     1.  Public cooperation in reducing amounts of street litter;
     adoption and enforcement of anti-dumping and anti-littering
     ordinances; and mass public education programs,  i.e. "Clean
     Cities Campaign."

     2.  Installation of adequate waste receptacles on public
     streets; street sweeping and other working programs for reducing
     the accumulation of pollutants on urban streets; roof drainage
     controls; and use of catch basins to retain the first flush
     of polluted storm water runoff.

                               6-6

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     3.   Reduction in the indiscriminate use of fertilizers and
     pest control chemicals.

     4.   Land drainage modifications for reducing or eliminating
     the runoff of polluted waste waters; measures to minimize the
     impact of runoff water containing snow and ice control chemicals
     More detailed guidance can be obtained from:

          "Urban Runoff Characteristics" EPA-11024 DQU 10/70

          "Water Pollution Aspects of Street Surface Contaminants"
          EPA-R2-72-081   11/72

          "Water Pollution Aspects of Urban Runoff" American Public
          Works Association;  Federal Water Pollution Control
          Administration  WP-20-15   1/69

B.   Construction Activities

         Construction activities refer to major earth-disturbing
    operations required for the development of highways,  dams,
    aqueducts, housing tracts, shopping centers, and other facili-
    ties.  They include stripping of topsoils, grading of slopes,
    fertilization and vegetation of exposed soils,  pest  control,
    and site restoration following construction.

         Pollutants generated by construction activities  include
    sediments and chemical and biological materials.  They result
    from erosion of bare soils; careless spillage of materials;
    increased storm water runoff; excessive use of fertilizers,
    pesticides, or other materials; and other generally poor
    "housekeeping" practices  which permit pollutants to be
    transported from the site area by runoff waters.  Typical
    pollutants include:

         1.   Sediments

              Consisting of solid materials, both mineral and
         organic, sediments form the principal pollutant  load
         resulting from construction activities.  Sediment yields
         from areas of bare soils in construction sites may be
         several thousands times that derived from vegetated or
         undisturbed areas.  Other pollutants are picked  up by
         these sediment particles in a "piggy back" fashion and
         are transported from construction areas to receiving
         water bodies.

         2.   Chemicals

              These materials originate from both organic and
         inorganic sources.  They include petroleum products,
         pesticides, fertilizers, synthetic organic materials,
         metals, soil additives, and miscellaneous chemicals
         used in construction processes.

                                6-7

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                  Petroleum products form the largest group of
             materials consumed in construction activities.
             Pollutants result from leaky storage containers,
             use of oils for dust control, oil spills during
             transfers or transportation, and discarded oil-laden
             rags or other materials.

                  Pesticides are used  for control of undesirable
             plants, rodents, or insects.  Improper application
             methods will result in pollution through direct contact
             of pesticides with a water body or the drift of these
             materials into adjacent water bodies.

        3.    Biological Materials

                  These pollutants include soil  organisms of human
             and animal origin.  Bacteria, fungi, and viruses are
             involved.  Most prevalent where improper sanitary
             conditions exist, the biological  organisms can be
             pathogenic to humans or animals.

        Effective control of nonpoint  sources of pollution should be
   done on a site-by-site basis, should be dependent upon local
   conditions, and should be initiated during the preliminary stages
   of a project.  It should be considered during site planning
   and design, as well as during construction operations.   Adequate
   control  must include proper maintenance of the measures installed
   during the life of the facilities construction.   Nonpoint source
   control  programs might include:

        1.   Installing structural and  vegetative measures which  will
        protect environmentally sensitive areas  of the site.

        2.   Controlling the velocity and volume  of runoff water  to
        prevent erosion and transport  of sediments  and other pollutants.

        3.   Diverting runoff and trapping sediment.

        4.   Requiring that nonpoint source control  be considered in
        construction contracts as well as procedures for the maintenance
        and inspection of measures installed (require good "housekeeping"
        practice).

        5.   Using stage grading, seeding, and sodding procedures.

More detailed guidance can be obtained from:

     "Processes, Procedures, and Methods to Control  Pollution Resulting
     from All Construction Activity"  EPA-430/9-73-007
                                  6-8

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C.  Hydrographic Modifications

     The various modifications that may be made within a body of
water, to its banks, or in its drainage area, represent a potential
source on nonpoint pollution.  Some of the controls for pollution
resulting from hydrographic modifications that should be considered
are:

     1.  Channelization

          a.  Use of impoundments to control flow rather than
          enlarging channel capacity

          b.  Use of natural type design to avoid highway type
          alignment

          c.  Use of proper materials and design to avoid
          instability which causes subsequent scour and channel
          deterioration alignment, capacity, grade, and
          structural measures

          d.  Legal/institutional controls to avoid flood
          damage in flood  plains, etc.

          e.  Structural alternatives - levees, floodways,
          retarding basins.

     2.  Hater Impoundments

          a.  Release of poor quality water because of stratification

               Multi-levels outlets - dissolved oxygen
               Multi-level outlets - temperature
               Reservoir mixing
               Aeration of releases
               Pre-impoundment site preparation

          b.  Biological stimulation

               Plankton and other epilimnetic forms - reduced
               nutrient levels and chemicals treatment

               Rooted types - water level fluctuation, elimination
               of shallow  shoal  areas, and chemical treatment
                               6-9

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      3.   Urbanization

           a.   Regulation  of  land  use  to  control:

                (1)  sources and  type of pollutants

                (2)  amount and  location of  impervious  surfaces
                    (especially  important in  aquifer  recharge areas)

           b.   Waste management  and environmental sanitation  --  prevention
               of  waste  introduction in surface  and ground  waters

           c.   Public education  for waste control

      4.   Dredging and Dredge Spoil Disposal

           a.   Spoil  treatment during  dredging operation  --chemical
               treatment (to  aid in dewatering)  and disposal  techniques
               (floculation,  incineration,  filtration,  etc.)

           b.   Productive  uses of  spoil

                    Creation  of  wildlife  habitation areas
                    Land Development
                    Agricultural land  use

      More detailed  guidance  can be obtained  from:

           "The Control  of Pollution from Hydrographic  Modifications"
           EPA-430/9-73-017

D.   Land and Subsurface  Disposals  of Residual Waste

           Disposal  of residual  wastes on the land and  in subsurface  sites
    may result in  ground and  surface water  pollution  through  gradual  flow
    of liquid pollutants or leaching of solid pollutants  from disposal
    sites.   Some of  the  types of sources  and  possible  control methods  for
    land and subsurface  disposal of residual  wastes are the following:

           1.   Land  and  Subsurface Disposal of Liquid  Waste

                a.  Pollution from wells, waste,  brine, radioactive gas
                    storage

                         (1)  Site evaluation
                         (2)  Waste amenability  evaluation
                         (3)  Construction
                         (4)  Requisite equipment and  emergency  procedures
                         (5)  Monitoring  well and aquifer response
                                    6-10

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         b.   Pollution  from  otner  subsurface  excavations

              (1)   Lagoons,  basins  and  pits-siting  and  design  to
                   avoid  bypassing  natural  protective mechanisms

              (2)   Pretreatment,  lining,  barrier  wells, and  outright
                   use  bans

         c.   Septic tank-percolation  field  systems

              (1)   Abandonment in  favor of  sewerage systems

              (2)   Require  approval  of  installation site  and
                   installation by  competent  professionals

              (3)   Use  of proper operating  procedures and maintenance
                   for  such  systems

         d.  Sewer  leakage

              (1)   Formulation and  modernization  of sewer construction

              (2)   Codes  and specifications as  a  State  rather  than
                   local  responsibility

              (3)   Internal  and external  inspection and repair program
                   at five  year intervals

              (4)   Exclusion of the discharge of  materials  damaging
                   to sewers and/or ground  water

         e.   Tank  and pipeline leakage

              (1)   Use  of corrosion-preventing  coatings,  cathodic
                   protection or internal linings to prevent
                   corrosion-caused leaks

              (2)   Design of storage sites  to contain  leaked liquids
                   before soil absorption

              (3)   Automatic shut-off valves

              ^4)   Recovery of pumping  techniques

              (5)   Inspections and pressure testing

More detailed guidance can be obtained  from:

     "Ground Water Pollution From Subsurface Excavations"
     EPA-430/9-73-012
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  "Subsurface Water Pollution,  A Selected Annotated  Bibliography,
  "Part I  Subsurface Waste Injection"  and "Part III,  Percolation
  From Surface Sources",  EPA
2.   Land and Subsurface Disposal  of-Solid  Wastes

       a.   Existing Sites

            (1)   Compaction  of deposited wastes and  covering
                 with  at least two  feet of compacted soil  slopes
                 to promote  runoff,  thereby minimizing  infiltration

            (2)   Conversion  to a  sanitary  landfill

            (3)   Diversion of surface  runoff  or streams  around
                 the fill area

            (4)   Establishment of vegetative  cover

            (5)   Diversion of groundwater

            (6)   Extraction  and treatment  of  polluted waters

       b.   New Sites

            (1)   Diversion of surface  runoff  or streams  around
                 the fill area

            (2)   Operation as a sanitary landfill, including
                 daily application  of  six-inch  (minimum)  layers
                 of compact  cover soil and application of  two-foot
                 (minimum)layers  of compacted soil as final cover

            (3)   Sloping and vegetation of surfaces  to  promote
                 runoff, rather than infiltration

            (4)   Construction of  an impervious  barrier  in  the
                 bottom of the fill  area

            (5)   Collection  and treatment  of  polluted water

            (6)   Judicious consideration of hydrogeological conditions
                 in site selection
                               6-12

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           More detailed guidance can be obtained from:

                "Sanitary Land Fill Design and Operation"
                EPA SW-65-TS, 1972

                "Sanitary Land Fill Facts" SW-4-TS,  U.  S.  Dept.  of
                Health, 1970

                "Decision-Makers Quide in Solid Waste Management",
                Office of Solid Waste Management Programs, 1974.

       E.   Agricultural Activities

                More detailed guidance can be obtained from:

                "Methods and Practices for Controlling Water
                Pollution from Agricultural Nonpoint Sources"
                EPA-430/9-73-015

       F.   Silvicultural Activities

                More detailed guidance can be obtained from:

                "Processes, Procedures, and Methods  to Control
                Pollution Resulting From Silvicultural  Activities"
                EPA 430/9-73-010

       G.   Mining Activities

                More detailed guidance can be obtained from:

                "Processes,  Procedures, and Methods to Control
                Pollution from Mining Activities
                EPA-430/9-73-011

       H.   Salt Water Intrusion

                More detailed guidance can be obtained from:

                "Identification and Control of Pollution From Salt
                Water Intrusion"
                EPA-430/9-73-013

                Subsurface Water Pollution, A Selected Annotated Bibliog-
                raphy  Part II.  Saline Water Intrusion,EPA

6.6  Procedure for Selection of Feasible Nonpoint Source Controls to
     Meet Water Quality Standards and Goals
                               6-13

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A.  General
         Technically feasible nonpoint source controls have been
    discussed in this Chapter.   The selection of controls for
    nonpoint sources should determine the most efficient means
    of meeting water quality standards through both point and
    nonpoint source controls.  This requires a determination
    of the cost-effectiveness of nonpoint source controls and
    of their implementation feasibility.

         It is recognized that information on cost and effective-
    ness of nonpoint source controls is difficult to determine.
    In cases in which quantitative information on cost-effective-
    ness of nonpoint source controls cannot be adequately
    ascertained, more flexible procedures for estimation and
    later determination of cost-effectiveness of nonpoint source
    controls are suggested.

B.  Relationship with Land Use Plan

         Since land use measures may be undertaken to minimize
    water pollution problems, these measures may have included
    certain nonstructural controls of nonpoint sources.

         In determining nonpoint source control  measures needed
    to meet water'quality standards, any land use measures that
    reduce generation of nonpoint sources of pollution should be
    accounted for as an element in the nonpoint source subplan.

C.  Procedure for Selection of Controls

    1.  Cost and Effectiveness  of Nonpoint Source Controls

         For each category of nonpoint source that is creating
    water quality problems, all control options  that are tech-
    nically feasible should be presented.  For each control
    option, the cost of the control and the effectiveness of the
    control in abating the different pollutants  (either at
    their source, or their yield to receiving waters) should be
    presented.  In establishing the cost of nonstructural
    controls, such cost should be based upon the opportunity
    cost of the control as discussed in Chapter 10.

    2.  Representative Data for Cost and Effectiveness

         Since the cost and effectiveness of nonpoint source controls
    depend on the exact circumstances in which the control is
    utilized, cost and effectiveness vary considerably.   For
    purposes of evaluating cost-effectiveness of nonpoint source

                          6-14

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controls, data used should represent the cost and effectiveness
of the control applied to typical or average situations.   This
approach is meant to assure that the cost and effectiveness
of the control is neither overestimated or underestimated if
it is being considered for widespread application.  Naturally,
if the control is only applicable in very specific situations,
data should be representative of the specific situation.

3.  Estimation of Cost and Effectiveness Information

     Because the precise cause and effect relationship between
application of given nonpoint source controls and achievement
of a given reduction of wastes to receiving waters is difficult
to define, specification of cost-effectiveness of nonpoint
source controls may require preliminary estimation.

     Once a nonpoint source problem of a given type has been
identified in terms of its impact on the receiving waters
it should be possible to determine the approximate reduction
of the source load that could be obtained through a given
control.  Since the cost of the control can generally be
assessed with some degree of accuracy, the cost-effectiveness
estimation enables an overall ordering of the most feasible
controls for nonpoint sources.

      To the extent that monitoring and sampling information
subsequent to the implementation of a nonpoint source control
adopted in a 208 plan reveal an inefficient choice of nonpoint
source controls, plan revision and updating may be necessary.

4.  Develop Nonpoint Source Control Alternatives

     It is desirable to compare all alternatives for nonpoint
source control.   To simplify comparison of alternatives in the
technical planning process, a preliminary screening  of nonpoint
source control options should be conducted.  A reasonable number
of control options for each nonpoint source category to which
a significant nonpoint source problem is attributed  in the
inventory of dischargers in Chapter 3, should be presented for
consideration in the selection of cost-effective waste load
allocations.   The following information for each such control
should be developed:

     a.   Waste load characteristics of each alternative expressed
     in appropriate units for relating to water quality pre-
     diction model.

     b.   Total cost of each alternative expressed as its
     present value or average annual equivalent value as
     described in Chapter 10.
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c.  Reliability and flexibility of each alternative

d.  Significant environmental  effects of each alternative
    consistent with NEPA

e.  Contribution of each alternative to related water
    management objectives of the 208 plan.
                 6-16

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                             CHAPTER 7


                  REGULATORY AND FISCAL CONTROLS


7-1   Introduction

     The regulatory program constitutes an essential element in the
areawide waste management plan.  This chapter discusses the requirements
of such a program, along with certain regulatory and fiscal approaches
that may be involved in implementation of the program.


7.2  Requirements of the Act

     208 plans are required by § 208(b)(2)(C) to make provision for the
establishment of a regulatory program to:

     A.  provide for waste treatment management on an areawide basis
         and for identification, evaluation, and control or treatment
         of all point and nonpoint pollution sources,

     B.  regulate the location, modification, and construction of any
         facilities within the area which may result in any discharge
         in such area; and

     C.  assure that industrial or commercial wastes discharged into
         any treatment works in the area meet applicable pretreatment
         requirements.

The regulatory program is also affected by §208(b)(2)(F-K), which requires
that 208 plans: 1) set forth procedures and methods (including land use
requirements) to control to the extent feasible nonpoint pollution sources
related to agriculture, silviculture, mining, construction, and salt water
intrusion; and 2) establish processes to protect ground and surface water
quality through controls on the disposition of residual wastes and on land
disposal of pollutants.  In addition to the above requirements, s208 (c)(2)
is related to the regulatory program through its specification of the legal
authority needed by 208 management agencies.  This section of the Act is
discussed in Chapter 8.


7.3  The Regulatory Program

     Previous chapters of this guideline describe a number of land use
measures and techniques for the control of point source discharges and
nonpoint source pollution.  208 plans are expected to  incorporate a
balanced selection of these controls, and also a means  of  administering
them.  This selection, together with additional management practices and
procedures, will represent the regulatory program required for 208 areas.

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The land use controls set forth in Chapter 4 and the point and nonpoint
source controls discussed in Chapters 5 and 6 provide a basis for, and
should be consulted in, the formulation of a regulatory program.  Fiscal
controls, discussed below, may also be part of such a program.

     These several controls represent a combination of direct and indirect
approaches, and the mix of appropriate controls may vary from area to area,
The various controls are interrelated.  Land use measures, for example,
may be employed in regulating both point source discharges and nonpoint
source pollution.   Fiscal controls may affect land use and influence
the decisions of individual and groups of discharges.  The regulatory
program therefore should be viewed as an integrated program.

     Once a balanced and integrated set of controls has been selected,
the capability to enforce them becomes the primary concern.  208 plans
must provide a means of implementing the selected controls.  The principal
land use measures, such as zoning, building codes, and subdivision regula-
tions, are based on the police power of the State and traditionally are
delegated to local jurisdictions.   Implementative authority is therefore
already available for such measures, although additional authority or
changes in the way existing authority is employed may be called for by
the plan.  The regulation of point source discharges can be accomplished,
as noted above, through land use controls and, of course,  through the
ection 402 permit program and associated monitoring and pretreatment
requirements.  Implementation of those elements of the regulatory program
dealing with nonpoint source controls is more likely to require enabling
legislation.   Land use measures may, again, be employed in regulating
nonpoint sources,  but new legislation may be necessary to  make controls
effective.  Such legislation, for  example, could provide permitting
authority over activities causing  nonpoint source pollution.   Construction
permits may also be employed as measures for controlling such activities.
In addition,  208 management agencies may coordinate with other agencies
which administer licensing programs or management practices related to
nonpoint source pollution.

7.4  Fiscal Controls

     In addition to the controls discussed above and in other chapters
of this guideline, various fiscal  controls may be provided in the 208
plan to augment the required regulatory program.   Examples of such
controls include the pricing policies of wastewater agencies  and taxation
policy.

     A.  Pricing Policy

          In discussing cost-effective ways to meet demands for waste
     water treatment in municipal  systems,  Chapter 5 mentions methods
     which can be used to reduce the flow of wastewater or its waste
     content.

          In considering pricing policy in this context, there are two
     questions.  The first, for many areas, is whether or  not to meter.

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Unless there are meters, charges cannot be assessed for incremental
use, and therefore a pricing policy cannot effect flow and waste
reduction.  Savings from a reduction in water and wastewater flow
must be balanced against the costs of metering.  The relevant
savings and costs apply to both the water and waste treatment systems.

     If a decision is made to meter, or to meter certain classes
of users, the second question is at what level to set rates.  To
encourage cost-effective choices on the part of users, economic
analysis indicates that at the margin of use, rates should equal
marginal costs.  Such rates should reflect the incremental cost
attributable to flow, the incremental cost of BOD removal, etc.

     In practice, and in current guidelines, the emphasis in
developing user charges has been on identifying average costs
attributable to flow or BOD removal, or removal of other constituents.
While rates based on such estimates are not ideal, they have been
found effective in inducing wastewater flow reduction and industrial
process change.

B.  Taxation Policy

     The use of differential assessment ratios, where legal, can
serve as an inducement to keep land in a non-urban classification
for purposes of open spaces or low density.  Such a policy permits
owners to maintain land in its present use, but does not prohibit
its sale for a more intensive use at a later specified date.  The
policy therefore tends to slow down the rate of development, without
completely prohibiting such development.  Under such a policy, however,
there is no assurance that the most environmentally sensitive areas
are given the most protection.
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                            CHAPTER 8

                   INSTITUTIONAL ARRANGEMENTS
8.1  Introduction
     Institutional arrangements for planning and management purposes are
a primary concern in the planning process because of the relationship of
areawide waste treatment management to the governmental jurisdiction in-
volved in the local area.  In most cases, new arrangements will  need to be
established to adequately relate existing governments of various types and
powers to the areawide management agency or agencies.  The overall  concept
to be kept in mind is that of a management system, whether that system is
made up primarily of a single agency or plural agencies.  Such a. system
will have functional responsibility not only for planning and waste treat-
ment management but also for the administration of stormwater runoff and
nonpoint source controls and for involvement, through appropriate units
of local government, in the application of land use control measures.
Whatever system is established must have the required capability to im-
plement and update an areawide waste management plan.  The system should
bfe a,realistic and logical outgrowth of the institutional situation exist-
ing at the time planning for the area begins.  This chapter discusses
management planning from the point of view of what is required by the Act
and in terms of optional approaches that may be considered in establishing
a management system.


 8.2  Requirements to be Met by the Areawide Management System

      A.  Allocation of Authorities and Need for Enabling Legislation

          The specified authorities required by the Act to be vested
      in a designated agency or agencies within the management system
      will rarely have been delegated under State law to any one
      particular governmental jurisdiction or agency in a 208 area.
      In many situations, changes in State law or new enabling legis-
      lation will have to be passed before all authorities can be
      coordinated as is necessary for carrying out an areawide waste
      treatment management plan.

      EL  Required Authority

          The required authority is set forth in §208(c)(2) of the
      Act:
          1.  §208(c)(2)(A) requires that there must be adequate
          authority within the management system "to carry out
          appropriate portions of an areawide waste treatment
          management plan developed under subsection (b)	"

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The contents of the areawide plan are discussed in Chapter 3.  From
the perspective of the legal capability of the management system to
carry out the plan, the plan itself must be checked to ascertain
whether each of the local agencies has the legal capability for
carrying out the functions assigned to it by the plan and that all
required functions have been so assigned.

2.  §208(c)(2)(B) requires that the waste treatment management
agencies within the management system have adequate authority "to
manage effectively waste treatment works and related facilities"
in conformance with the plan.  In this regard, the broad definition
of "treatment works" as set forth in §212(b) and discussed in Chapter
5 should be kept in mind.  Management planning must establish some
means of coordination among the agencies and arrangements involved
in administering the plan so that conflicts can be resolved and the
plan can be properly enforced.

3.  §208(c)(2)(C) requires that waste treatment management agencies
within the management system have adequate authority "directly or
by contract, to design and construct new works, and to operate and
maintain new and existing works" as required by the plan.  Generally,
existing agencies already have this authority.  However, where such
works are to be located outside the immediate geographic jurisdic-
tion or to accept discharge from outside its area, adequate enabling
legislation to meet this requirement may have to be enacted.   Where
approval of a superior agency is required, said approval should be
secured before a grant application is made.

4.  §208(c)(2)(D) requires that waste treatment management agencies
within the management system have adequate authority "to accept and
utilize grants, or other funds from any sources, for waste treatment
management purposes."  Most such agencies have this authority under
State law.  Where such authority does not exist, enabling legislation
will  have to be passed.  When State law provides that all such grants
must pass through a central State agency, the terms of the grant it-
self in requiring that the funds will go to the designated waste
treatment management agency will guarantee that no funds may be
siphoned off by the State agency for uses other than those set
forth in the application.

5.  §208(c)(2)(E) - (G) deals with authority required in relation
to financial arrangements.  Detailed discussion of this subject
is presented in Chapter 9.
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          6.  §208(c)(2)(H) requires that the waste treatment manage-
          ment agencies within the management system have adequate
          authority "to refuse to receive any wastes from any
          municipality or subdivision thereof, which does not comply
          with any provisions of the approved plan."  This authority,
          which may be exercised by an appropriate State agency,
          will generally be employed in extreme cases as a last
          resort.  Practically, other methods such as negotiation,
          fines or additional charges, moratoria, and resort to
          the courts should be utilized so that a situation of
          complete shut-off can be avoided.
                           a
          7.  §208(c)(2)(I) requires that the waste treatment manage-
          ment agencies within the management system have adequate
          authority "to accept for treatment industrial wastes."
          This authority also involves the right to refuse such
          wastes if they do not meet applicable pretreatment re-
          quirements as mentioned in §208(b)(2)(C)(iii).  Other
          grounds for refusal would exist when such industry
          is not in compliance with the areawide plan or when
          applicable State or national laws relating to discharge
          are being violated.

      The required authorities set forth above should be carefully
checked with the extant statutory authority.  Where, due to either
gaps in the statutes or judicial decisions related thereto, there
are doubts as to the statutory basis for any of the required authori-
ties, changes in those statutes should be made so as to grant express
authority to the areawide waste treatment management agencies to carry
out the functions required.  In instances where legal authority is open
to interpretation, it may also be helpful to solicit and include in the
plan submittavl an opinion from the State Attorney General.


8.3  Optional Approaches to an Areawide Management System

     A.  Responsibilities Performed Within the Areawide Management System

          The responsibilities that must be assumed by the areawide
     management system can be summarized under three types (1) coordina-
     tion, (2) planning, and (3) management.

          1.  Coordination

               As noted above, the management system must be provided
          with some means of insuring that the system's different
          functions are being performed on a coordinated basis and
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     in compliance with the areawide plan.   The coordinative
     authority may take a variety of forms  and involve several
     levels of government.   Existing agencies such as regional
     councils, procedures such as the A-95  review, mechanisms
     such as intergovernmental contracts, agreements, and
     memoranda of understanding may serve in a coordinative
     capacity.  The State may also play a coordinative role.
     Another approach to coordinative management would be to
     provide regional sewage treatment agencies which allocate
     wasteloads for a 208 area with review  and approval  authority
     over land use decisions that will result in significantly
     exceeding wasteload allocations.  Such authority could
     also be lodged in other regional or State agencies, or
     in a newly created commission representative of constituent
     jurisdictions.  Whatever approach is taken, the essential
     consideration is that coordinative authority capable of
     facilitating the resolution of conflicts and implementa-
     tion of the plan be a central component of the management
     system.

     2.  Planning

          208 planning constitutes an integral part of the
     comprehensive planning process for the area.  Once imple-
     mentation of the initial  208 plan has  begun, it will have
     to be updated both to maintain consistency with the
     comprehensive plan and to make changes required by
     changing conditions and by the need to accomplish the
     water quality objectives  of 208 planning.  Thus planning
     will be an important element in the overall 208 management
     system and a continuing planning process should be provided
     for in the implementation phase.

     3.  Management

          Management, in the traditional operational sense
     of the term, includes responsibility for facilities design,
     construction, operation,  and maintenance; for administration
     and financing; and for implementation  of the regulatory
     program.  Agencies exercising these responsibilities should
     be expected to provide both inputs and feedbacks to the
     planning process.


B.  Optional Allocation of Responsibilities

     The allocation of responsibilities of  the management system
among local agencies will probably depend upon which and how many
local governmental jurisdictions either operate waste treatment
systems or exercise authority over land use, stormwater runoff,
and nonpoint source controls.   A survey of  the literature
                             8-4

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of local government may be made for a comparison of various
approaches used in different areas.  Generally, whatever
allocation plan is adopted will probably be a variant of
one of the three basic options discussed below:

     1.  Single Planning and Management Agency

          One option is to establish a single planning and
     management agency with a geographical jurisdiction the
     same as the 208 planning area.  In some situations
     where a single governmental jurisdiction already exists,
     and whose jurisdiction encompasses the entire 208 area,
     it may be assigned both the planning and management
     responsibilities.  This would facilitate closer coordi-
     nation between planning and management than where these
     two responsibilities are assigned to separate agencies,
     and would achieve greater economies of scale.  Where
     such an agency is based partly on a Council of Govern-
     ments (COG) or regional planning agency which has been
     designated as a clearing house agency under A-95, final
     approval of specific projects in the 208 area can be
     expedited.  Where A-95 authority is lacking, the new
     agency adds another level of decision making to the
     A-95 process.  In the latter case adequate provision
     will have to be made to insure that elected officials
     are included on the agency board so as to meet the
     representation requirements of the Act.

     2.  Single Planning Agency and a Single Management Agency

          Another option is to divide the planning and manage-
     ment responsibilities between two separate agencies.  This
     would make day-to-day coordination more difficult but
     might facilitate approval of specific projects if the
     planning agency has A-95 authority.  A previously
     established COG or regional planning agency could be
     utilized as the planning agency for 208.  Since such
     organizations already have local elected officials on
     their boards, the representation requirements would
     automatically be met.  This would also mean that the
     management agency would be under the direction of pro-
     fessional management as it carries out the day-to-day
     implementation of the areawide management plan.  Where
     separate management agenicies are involved in waste
     treatment, consolidation of such agencies would have
     to be brought about entailing some loss of local authority.
     Economies of scale could also be attained as in Option 1
     above.

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     3.  Single Planning Agency and Plural  Management Agencies

          A third basic option would be to  have a single planning
     agency and more than one management agency.  This option
     would allow those management agencies  already providing
     waste treatment service to continue doing so with a
     minimum effect upon their internal administration.
     Coordination between the planning agency and the manage-
     ment agencies is made more difficult but individual
     governmental jurisdiction could retain their own waste
     treatment agencies and other authority.   This option,
     therefore, would permit the maintenance of existing
     institutions and agencies to a closer  degree than the
     other basic options.  Representation requirements of the
     Act could be met by the planning agency as in the other
     basic optional approaches.  Economies  of scale would not
     as likely be attained due to fragmentation.  Nevertheless,
     where the option is favored, provision for effective
     coordination among the several  jurisdictions and agencies
     must be made.

C.  Intergovernmental Aspects

     No matter which of the above options is  chosen, inter-
governmental relationships are of primary importance in both
the establishment of the management system  as well  as in the
implementation of the areawide plan.

     1.  Legal Basis for Establishing §208  Agencies

          Adjustment in the authority exercised and in services
     performed by local, regional or State  governments in a §208
     area may be effected by different legal  forms of agreement
     given statutory authorization.

          a.  Contract.  Where a single agency already en-
          compasses the entire §208 area, other participating
          local units of government may contract with it to
          provide the services required.  A county, metropoli-
          tan government, or metropolitan special district are
          examples of such a unit.

          b.  Joint Exercise of Powers.  Where they do not already
          exist, consolidated agencies may  be established jointly
          by the participating local units  of government.
                                8-6

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     Interlocal contracts or agreements may be utilized
     in such joint exercise of powers.

     c.  Transfer of Functions by the State.  Where a new
     areawide agency is established, the State may transfer
     functions to it from other local, regional, or State
     agencies.

2.  A-95 Review

         In accordance with OMB (Office of Management and
    Budget) Circular A-95 Revised, dated November 13, 1973,
    all applicants under Federal programs providing assistance
    to State, local, and areawide projects and activities
    that are planned on a multijurisdictional basis, must
    notify the appropriate State and areawide planning and
    development clearinghouse for its review  and comment.
    The regional clearing house reviews the proposed
    application as to its consistency with areawide plans
    including comprehensive planning, environmental concerns,
    water supply and distribution systems, sewage facilities
    and waste treatment works, and land use.  In most cases,
    either a regional planning agency or COG serves as the
    regional clearinghouse agency, and as mentioned above,
    may be utilized also as the areawide planning agency
    under §208.  As part of its review responsibilities,
    the State checks to see that any proposed application
    is consistent with basin planning under §303.  On the
    national level, EPA reviews the annual certification
    of State plans.
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                              CHAPTER 9


                        FINANCIAL  ARRANGEMENTS
9.1   Introduction

      Financial planning  is  an  integral part of the 208 areawide
planning process.  The financial  arrangements necessary for the
areawide agency(s) to carry out the areawide plan must be included
in the plan.  The areawide  plan should not include proposals which
the implementing agency(s)  cannot finance because of lack of legal
capacity or actual capability.  The purpose of this chapter is to
identify the areas in which problems may arise in complying with the
financial requirements of the  Act.  It does not set forth methods
or procedures for financial arrangement for funding the costs of
capital construction or  for raising revenues or assessment of
waste treatment charges.  It is better left for the applicants
to ascertain the methods of financing most suited for their particu-
lar problems and as authorized by their enabling legislation.

     These problem areas are divided into three categories:

     A.  Capital construction  costs

     B.  Operational costs  (revenue)

     C.  Indirect (overhead) cost to be financed

With respect to each of these  financing arrangements, pertinent
provisions of the Act and specific problems are set forth below.
Short term and long term budgeting and other financial  activities
are also discussed.
9.2  Requirements of the Act

     Provisions directly and indirectly affecting financial arrange-
ments are dispersed throughout the Act.  Those specifically affecting
208 areawide waste treatment management are set forth in Title II.
There should be an overall integrated approach to planning and
budgeting the financial arrangements in order to comply with these
various requirements.

     A.  Capital Construction Costs

          1.  §208(b)(2)(E) requires that the areawide management
     plan include identification of the measures necessary to carry
     out the plan including financing and the costs of carrying out
     the plan within the necessary period of time.  This applies to
     all capital costs associated with point and nonpoint source controls.

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     2.  §204(a)(4) requires that the applicant proposing to
construct treatment works agrees to pay the non-Federal costs
of such work.

     3.  §204(b)(l)(C) provides that the Administrator shall
not approve any grant for any treatment works unless he shall
first determine that the applicant has the financial capability
to insure adequate construction, operation and maintenance
of the treatment works throughout the applicant's jurisdiction.

     4.  §208(c)(2)(C) requires that the waste treatment manage-
ment agency(s) have adequate authority directly or by contract
to design and construct new works and operate and maintain them.

     5.  §208(c)(2)(D) requires a management agency have adequate
authority to accept and utilize grants or other funds from any
source for waste treatment management purposes.

     6.  §208(c)(2)(F) requires that the waste treatment manage-
ment agency(s) have adequate authority to incur short  and
long term indebtedness.

     7.  i204(b)(l)(B) provides that the Administrator shall
not approve any grant for any treatment works unless the appli-
cant has made provision for industrial cost recovery (the
recovery from industrial users of the treatment works of that
portion of the cost of construction of such treatment works
which is allocable to the treatment of such industrial waste
to the extent attributable to the Federal share of the cost of
construction).

     8.  Section 12 provides for an Environmental Financing
Activity under the Secretary of the Treasury.  This Authority
is established to assure that inability to borrow necessary
funds on reasonable terms does not prevent State or local
public bodies from carrying out waste treatment works con-
struction projects eligible for assistance under the Act.
The Authority is authorized to purchase the obligation of
these public bodies to finance the non-Federal share of such
construction.
B.  Operational Costs and Assessment of Revenue

   1.  §204(b)(l)(C)  provides that the Administrator shall not
approve any grant tor any treatment works unless the applicant
has financial capability to insure operation and maintenance
of the treatment works.
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     2.  §208(c)(2)(E) provides that the waste treatment manage-
ment agency must have adequate authority to raise revenues,
including the assessment of waste treatment charges, to implement
all elements of the plan.

     3.  §208(c)(2)(G) provides that the waste treatment manage-
ment agency must have adequate authority to assure, in imple-
mentation of an areawide waste treatment management plan, that
each participating community pay its proportionate share of the
treatment costs.

     4.  §204(b)(l)(A) provides that the Administrator shall not
approve any grants for any treatment works unless the applicant
has adopted a system of user charges assuring that each recipient
of waste treatment services will pay its proportionate share of
the cost of operation and maintenance (including replacement)
of any waste treatment services provided by the applicant.


C.  Indirect (Overhead) Costs to be Financed

     1.  §208(b)(3) requires that the areawide waste treatment
management plan shall be certified annually by the Governor
of the State or his designee as being consistent with the
applicable basin plan.  S208(f)(l) provides that the Administrator
shall make grants to designated agencies for payment of the
reasonable costs of developing and operating a continuing
areawide waste treatment management planning process.  From
these two sections it is the intent of the Act that there
will be an ongoing planning process within each area which
must be financially supported.

     2.  §208(b)(2)(F)-(K) provide that the areawide management
plan shall include processes to identify and/or control nonpoint
sources of pollution.

     3.  §201(e) provides that the Administrator shall encourage
waste treatment management which results in integrating facilities
for sewage treatment and recycling.  It further provides that
such integrated facilities shall be designed and operated to
produce revenues in excess of capital and operation and mainte-
nance costs and that such revenues shall be used by the designated
regional management agency to aid in financing other environmental
improvement programs.
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9.3  Specific Problem Areas

     A.   Capital  Construction  Costs

         Due to the number and variety  of methods  for  financing  waste
     treatment management  under  State and local  laws,  each  plan  should
     include the  broad range of  financial arrangements available rather
     than following any rigid  formula.  Some requirements of  the Act
     should  present few if any difficulties with regard to  financial
     arrangements.   Other  requirements  are more  likely to cause  problems.
     Arrangements which should be relatively t&sy  to provide  are as
     fol1ows:

         1.   Capital  funds may be raised or generated from  the general
     fund.   This  is  particularly true if the applicant is a governmental
     unit of general  jurisdiction.

         2.   Capital  funds may be generated from grants or  funds  from
     any  other source.   In some instances, matching funds may be  required.

         3.   The  capacity and  ability to contract indicates a limited
     ability to generate short term indebtedness.

         4.   The  capacity to incur short term indebtedness may be demon-
     strated by the  ability to issue bond anticipation notes, grant
     anticipation notes, or to borrow from State agencies.  Such short
     term  indebtedness must,  of course,  comply with constitutional
     limitations  on  such borrowing and with  any State or local statutory
     requirements.

        5.  The capacity to  incur long  term debt may be demonstrated by
     the capacity to issue general  obligation bonds,  revenue bonds, or
     the capacity to borrow from  State agencies.   Exercise of this capacity
     to borrow is of course limited in many  instances by constitutional  or
     statutory provisions.  There must also  be  compliance with State and
     local statutory requirements for the  issuance  of bonds  or the incurring
     of such long term indebtedness.

        Areas in which problems  may  be  encountered in  complying  with  the
    Act include the following:

        1.  The industrial cost  recovery  requirements  of the  Act are
    St^ lY T6red  in 3^  CFR>  Subpart E'  of the 9™nt  regulations.
    ™n -H 1 !heft recovery charges may be  allocated  on  a  systemwide basis
    provided that the treatment  works project  for  which  the grant is made
    is substantially interconnected with a goal  to be  completely inter-
    connected physically with  all other portions of  the  system.   In order
    to avoid any  problems  of priority between  bond holders  and the indus-
    trial cost recovery share, the industrial  cost recovery share must
    ?M^tH^Seregated.and,ac?ounted  for seParately.   In  instances where
    nr™?Sn ^  T m?  5ake long term Mnd1n9 commitments  for repayment,
    provision can be made  for  transferability  of this commitment in'order
    to promote industrial  growth and change within the area.   It is implied
    that  a long term commitment  to repay is in exchange for provision of


                                 9-4

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services to treat the user's industrial wastes.  Both the commitment
and the right to services should be transferable, subject, however,
to approval by the waste treatment management agency.

     2.  In the event of consolidation of two or more areas or agen-
cies each of which previously had supplied waste treatment services
and had incurred indebtedness and other contractual obligations to
provide such services, the problem of the consolidated agency assum-
ing the indebtedness and contractual obligations must be identified
and a legally acceptable method of overcoming this problem must be
set forth.  Particular attention must be paid to such contractual
obligations as personnel contracts, retirement benefits, long term
supply contracts, etc.

     3.  In the event of consolidation, problems may arise with re-
spect to the new waste treatment management agency reimbursing the
participating agencies for the value of their existing facilities
and assets.  A fair and uniform method of arriving at the values
of these assets and a legally acceptable method of handling the
transfer should be set forth.

B.  Operational Costs and Revenue Assessments

     1.  User charges.  40 CFR, Subpart E, and related guidelines
provide the basis for establishing user charges.  As set forth in
these regulations and guidelines, the Act requires that each recip-
ient of waste treatment services pay its proportionate share of costs
of operation and maintenance.  Charges based on property values only
will not suffice in most instances to satisfy this requirement of the
Act.  An exception to this is the situation in which such charges
have been used historically, the change-over would be costly and
disruptive,  and the goal of proportionality among user classes can
be achieved by such systems.  Uniform rates on volume among classes
of users will suffice provided that the classification reflect-,the
differences in cost of treatment among classes of users.

     2.  Participating communities' proportionate shares.  In deter-
mining each participating community's proportionate share of treatment
costs, the differentials among communities should be explained and
justified.  In the event that all participating communities are charged
on the same basis, the reasons and justification for doing so should
be explained.  The provisions and effects of inter!ocal agreements and
contracts to supply waste treatment services should be reviewed and
set forth.  The methods of charging users within each of the partici-
pating communities should be defined.  The user charge requirement
cannot be avoided by interlocal agreements or contracts to supply
waste treatment services.  User charge requirements must be reflected
in determining the participating communities' proportionate shares of
treatment costs.
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     C.  Indirect (Overhead) Cost to be Financed

          1.  Ongoing planning is a function for which provision
     must be made in budgeting.  The amount and the source of such
     funds should be set forth.  Items of the ongoing planning
     process which should be budgeted include, among others,
     discharge source inventory, monitoring, surveillance, and
     performance evaluation to the extent needed to supplement
     the State sponsored efforts on these items.

          2.  The ongoing planning process also requires public
     participation.   In order to participate, the public must be
     informed.  Participation of the public and information
     dissemination to the public are important matters,  and the
     cost to provide the information and encourage public partici-
     pation should be budgeted.

          3.  To the extent that the areawide waste treatment
     management agency is involved in the ongoing identification
     and control  of nonpoint sources of pollution, the cost should
     be budgeted and the source of income indicated.   If performed
     by State level  agencies, this should be noted.

          4.  To the extent that the waste treatment  management
     agencies are involved in the permit system, the  expense in
     excess of that  collected for permit fees should  be  budgeted
     and the source  of income provided.
9.4  Other Financial  Activities

     A.   The plan should indicate  a  20-year projection  of financial
     arrangements to  provide  the treatment  works  necessary to meet
     the anticipated  municipal  and industrial waste  treatment needs
     of the area over the 20-year  period.

     B.   A more detailed 5-year projection  including capital  improve-
     ment budgeting and  cash  flow  should be provided.   It should
     include start-up costs,  carrying  charges during the  first years
     of operation and similar nonrecurring  costs  associated with  the
     implementation of a new  treatment works or waste treatment
     management system.

     C.   The legal capacity of  the agency(s) to perform as planned
     should be  set forth in an  opinion letter of  legal  counsel for
     the Agency.   In  the case of financial  arrangements,  opinions of
     special  counsel  experts  in the  field of bond financing is
     acceptable.
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D.  The financial capability of the Agency to perform as planned
should be set forth in the report of the independent auditor
for such Agency.  As an example, the extent to which the Agency
has unused bonding capability should be identified if general
obligation bonds are to be used as a method of financing.

E.  Where legislative or electoral approval of financial
arrangements are required, the method of obtaining such
approvals should be identified.

F.  Financial arrangements (fiscal/economic) may be used to
influence behavior (amount and type of discharge).  The use of
such arrangements is discussed in Chapter 7.
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                               CHAPTER 10
                         DIRECT RESOURCE COSTS
10.1   Introduction

     The Act requires that areawide plans consider alternative methods
for waste management, that the cost of carrying out alternatives  be
identified, as well as their economic, social  and environmental  impacts,
and,  generally, that the choice of alternative be "cost efficient"  or
"cost effective"--that is, water quality goals should be met at minimum
cost.

     As cited in Chapter 1. , cost-effectiveness analysis is defined  as
an analysis featuring systematic comparison of alternatives  to identify
the solution which will minimize total costs to society over time to
reliably meet given goals or objectives.  Total costs to society  include
resource costs plus social and environmental costs.  The analysis involves
identification and study of the tradeoffs among resource costs, environmental
effects and other aspects of the alternatives, leading to selection of  the
best plan.

     Resource cost (discussed in this chapter) refers to the values of
goods and services representing primary project inputs, including capital
cost as well as operations, maintenance and replacement cost.   Resource
cost may be more or less readily measured in monetary terms; environmental
and social effects, discussed in the next chapter, are more  difficult to
put into monetary terms, and must be described and evaluated in a more
judgemental way.


10.2  Basic concepts in identifying resource costs

     A. Economic cost

          In considering the cost of implementing a plan, it is necessary
     to distinguish between outlays and economic costs.  In  many  instances
     cash outlays adequately represent cost, but sometimes a resource is
     used for which no cash outlay is made.  The cost in such a case  is
     the value that the resource would have in its best alternative use--
     its "opportunity cost."  For example, acquiring public  land  for  a
     treatment plant may involve no cash outlay, but may have an  opportunity
     cost in terms of foregone recreation or commercial use.  If  such
     opportunity costs are not considered, plan selection will be biased

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toward those options which do not require outlays, though in fact
they involve other costs.

     Moreover, the definition of cost as opportunity cost implies that
the cost to the community and nation as a whole are considered, not
merely the cost to one party or another, in evaluating alternative
plans.

B. Price levels
     Where costs are estimated for future periods, they should be
stated in terms of base period dollars; future costs should not reflect
any expected overall increase in wages and prices.

     Exceptions to the foregoing should be made if there is justifica-
tion for expecting significant changes in relative prices during the
planning period.  For example, at the present time, there are energy
shortages, and the long-term prospect is for higher energy costs.  Even
though it is practically impossible to predict how much energy costs
will rise, it is essential  that the choice of alternatives be tested
for the effect of higher energy costs.

C. Interest rates
     Discounting is essentially a way to take account of the fact that
the investment of funds in a project has an opportunity cost, in the
sense that the funds could also have been used productively in the
private sector of the economy or in some other public project.  The
applicable discount rate determines the optimal  choice between capital
expenditures now versus higher operating costs in the future, the
optimal amount of reserve capacity to build, and so on.

     In discounting, the costs of a plan are stated in terms of their
present values.   That is, future costs are discounted at an applicable
rate of interest back to some initial  starting date, and added to the
initial capital  costs.   Alternatively, the present values may be
converted into equivalent annualized values.  Standard procedures are
described in engineering economics and business  finance texts.

     The interest rate  to be used in evaluating  water-related public
projects is prescribed  by the Water Resources Council, a Federal
inter-departmental  group, in its "Principles and Standards for Planning
Water and Related Land  Resources", as amended by PL 93-251 (1974).  The
rate specified by the Council is based on the interest rate on Federal
Securities with  maturities of 15 years or more;  the rate to be used for
the coming fiscal year  is determined by the Council on July 1.  For
fiscal  year 1974, the rate is 5 5/8%.   Because it is recognized that
such a rate is low  in terms of opportunity costs in the private sector,
a rate of 7% is  suggested for evaluation purposes in a 208 plan.
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 Specific cost questions

A. Sunk costs and salvage values

     These terms refer to capital assets in existence at the beginning
or end of a program.

     For simplicity, investments and cost commitments made prior to
or concurrent with the planning study are regarded as sunk costs and
not included as a cost for plan evaluation and comparison.  Such
investments and cost commitments include, for example: (1) investments
in existing wastewater treatment facilities and associated lands to be
incorporated into a plan; (2) outstanding bond indebtedness.  However,
if inherited assets were to be disposed of in one alternative—say a
small treatment plant were to be scrapped and the land sold—their
sale value would be treated as a credit to that plan.

     Salvage value.  Normally, land for treatment works, including
land used as part of the treatment process or for ultimate disposal
of residues, should be assumed to have a salvage value at the end of
the planning period equal to its prevailing market value at the time
of the analysis less any costs required to restore the lands to pre-
project conditions.  Salvage value of land reclaimed by land treatment
or sludge disposal should be estimated as the value of the reclaimed
land.  Rights-of-way and easements should be considered to have a
salvage value not greater than the prevailing market value at the
time of the analysis.

     Permanent structures should be assumed to have a salvage value
at the end of the planning period if those structures can be expected
to continue to fulfill their planned use.  Where a structure can be
expected to continue to be used as planned, salvage value should be
based on the remaining functional life of the structure based on a
straight line depreciation over the assumed functional life of the
structure.  The same approach for determining salvage value applies
to process and auxiliary equipment that will have useable value at
the end of the planning period.

B.  Capital and operating costs
     Elements of total cost include capital construction cost, annual
operation and maintenance costs and equipment replacement costs.

     As set out in EPA cost-effectiveness guidelines (40 CFR 35),
capital costs for facilities include: cost of land, relocation and
right-of-way and easement acquisition; design engineering, field
exploration and engineering services during construction; contractors
                              10-3

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costs of construction including overhead and profit;  administrative
and legal services including cost of bond sales;  and  startup costs
such as operator training.   Contingency allowances consistent with
the level of complexity and detail  of the cost estimate are also
included.

     The capital costs of a plan would include those  incurred by
public agencies, as well  as those incurred by private parties.  These
two categories of cost are  carried  forward to the summary table shown
in Chapter 13.  For the private costs, treatment  facilities built by
industrial companies for direct discharges or for pretreatment would
be included.

     Where waste and flow reduction measures are  carried out by a
large number of industrial  and household dischargers, in response to
user charges, it is difficult to estimate the private costs.   Unless
the costs have a bearing on the choice of a cost-effective plan, such
estimates are unnecessary.

     Annual operating and maintenance costs for each  alternate plan
must be established.  These costs should be adequate  to ensure effect-
ive and dependable operation and include all costs for operating and
maintaining the facilities  under study including  power, labor, parts,
materials, overhead, chemicals and  repair or replacement of equipment
and structures.

     Cost-effectiveness analyses require establishing a service life
for each component and salvage values for components  having service
lives longer than the planning period.  The following service lives
are to be used, unless other periods can be justified:

                     Land                Permanent
                     Structures          30-50 years
                     Process Equipment   15-30 years
                     Auxiliary Equipment 10-15 years

C.  Administrative Costs

     Areawide waste planning and management is likely to include a
number of ongoing costs not always  associated with facilities manage-
ment, for activities such as monitoring of streams, monitoring the
waste characteristics of major industrial  dischargers,  periodic checks
of infiltration and inflow, records of storm and  runoff characteristics,
collecting and analyzing data on residential water use, etc.   These
functions are as important  to the effectiveness of a  plan as the physical
units in place.  The costs  may not  vary significantly in alternative
plans, but should be included in financial projections.  Whether such
costs can be recovered by direct charges -- e.g.  permit fees, monitoring
fees, etc. -- should be considered  and evaluated.
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D.  Accuracy 'of cost estimates

     The accuracy of cost estimates for all point and nonpoint elements
of 208 plans should be sufficient to assure the reliable selection of
the cost-effective solution, in a comparison of alternatives.  Gross
cost estimates ordinarily suffice for preliminary screening.   Comparison
of those plans selected for detailed evaluations should be based on
information such as the following:

     Unit process costs associated with the different wastewater
     and sludge treatment processes considered.  The unit costs
     should be applicable to the locality or region.

     Preliminary engineering layouts, quantity estimates, and
     unit costs for the sewer lines and appurtenant works.
     Such unit costs should be representative of the area, based
     on recent comparable projects.

     Market value of land or easements required for facilities.

     The above detail of cost estimates should be refined sufficiently
to provide a basis for the 5-year financial budget stipulated in
Chapter 9.  Such estimates might be based upon preliminary engineering
layouts and designs, taking account of facilities in place.  Should
the more refined estimates of the selected system differ considerably
from the previous estimates, the prior comparative evaluations of
alternatives should be revised to assure the selection of the most
cost-effective system.  Since, in Chapter 9, financial budgets are
stipulated to cover the first five years, the level of detail for
costs will ordinarily be greater for that period.

E.  Present values

     Using the interest rate of 7 percent suggested in 10.2.C, the
costs for construction and operations, by year, should be discounted
to the proposed plan initiation date, to obtain the present value
(or, what is much the same thing, the annualized value) of the plan
alternatives.  An example is given in EPA Guidance for Facilities
Planning, January 1974, Appendix to Chapter 4.
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                               CHAPTER 11

            ENVIRONMENTAL, SOCIAL AND ECONOMIC IMPACT EVALUATION


11.1   Purpose

     The purpose of this chapter is to provide guidance for integrating
the environmental, social and economic impact evaluation into the 208
planning process.  It is also intended to meet,  in part,  the  requirements of Sec
102(2)(c) of the National Environmental  Policy Act of 1969.  Thus,  this
evaluation will provide the necessary information to support  the applicant's
integral environmental assessment.  The information will  also be used  to
support the preparation of an Environmental Impact Statement  if it  is  required.

     The evaluation must be viewed as an integral part of the planning
process.  As such, it will be performed during the entirety of the  planning
process rather than after the selection of the 208 plan.  Citizens  and local
units of government should be provided the opportunity to participate  from
the beginning in this evaluation process.  As a result, affected citizens
and units of government will  be better able to analyze the various  alterna-
tives and thus aid in the identification of specific plan impacts,  and
provide meaningful views for consideration in the selection of the  areawide
plan.


11.2  Environmental, Social and Economic Impact Evaluation Process

     A.  Inventory Existing Conditions

          The purpose of inventorying existing conditions is  twofold:
     (1)  it will aid in goal and problem identification; and (2) it
     will serve as a basis for the analysis and comparison of alterna-
     tives.  The inventory will undoubtedly require additions as new
     problem areas are identified in the planning process. At a minimum,
     the inventory will  encompass the 208 planning area together with
     pertinent areas outside of the planning area that would  be affected
     by the plan.  For example, land disposal sites for effluent or
     sludge, other wastewater reuse sites and the downstream  river  corridor
     that would be affected through effective water quality management
     would be considered.

          The data should complement rather than duplicate information
     presented elsewhere in conjunction with this planning. Only that data
     which is relevant to the analyses of alternatives or determination  of
     impacts should be included.  Thus, the  inventory may  include but not
     necessarily be limited  to the following:

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 1.   Climate  and  precipitation;

 2.   Topography;

 3.   Geology;

 4.   Soils  including erodability;

 5.   Hydrology  (surface and groundwater):

           a.   water quality
           b.   water quantity
           c.   water uses
           d.   flood hazards;
 6.   Biology:
           a.   rare  and  endangered species
           b.   wild!ife  habitats;

 7.   Air quality;

 8.   Land uses:

           a.   amount of growth
           b.   type  of growth
           c.   intensity of growth   (The growth data should
               be  of recent origin.  There is no necessity to
               examine growth trends further back than 1960).
           d.   significant environmentally sensitive areas;

 9.   Wastewater management resources including energy;

10.   Economic  activity (gross assessment):

           a.   income per capita
           b.   agriculture
           c.   mining
           d.   manufacturing
           e.   service;

11.   Employment trends including regional availability of skilled
     manpower  for  treatment plant operation and monitoring.

12.   Public Health;  and
                          11-2

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    13.  Aesthetics:

               a.  recreational accessibility and activities
               b.  unique archeological, historical, scientific
                   and cultural areas
               c.  noise pollution.

     The inventory should also include identification of adopted goals
and pertinent constraints.  Such goals might typically include:

          1.  Preservation of high quality surface water;

          2.  Preservation of coastal or other wetlands;

          3.  Preservation or enhancement of fish and wildlife;

          4.  Enhancement of municipal services.

Examples of constraints include:

          1.  Air quality regulation and implementation plans;

          2.  Local climate, topography, soils, etc; and

          3.  Restrictions on flood plain use or other land uses;
     In most cases the data needed for the inventory should  be  readily
available in existing documents.  Thus, primary data collection should
be minimal .

B.  Evaluation of the Existing Situation

     Based upon the inventory of existing conditions a brief analysis
of the existing situation should be conducted.  The intent of this
evaluation is to prioritize pollution problems and sensitive impact
areas.   This prioritization will be a primary concern during the remainder
of the evaluation.  Public participation (including government  agencies)
will  be needed to help with problem and impact prioritization.


C.  Develop Baseline Projection

     The inventory and evaluation of the existing situation  will  serve
as inputs into the development of a baseline projection.   It will be
necessary to construct a baseline projection of relevant  environmental,
social, and economic factors so that each of the alternatives can be
                              11-3

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     evaluated.   These factors or indicators are presented in Table 13.1
     (Chapter 13).   The baseline projection can be established by extra-
     polating present indicator trends  assuming that no additional  water
     quality actions will  be taken other than those that have already
     been approved.   Alternatively,  the 208 plan alternative that deviates
     the least from  the status quo can  serve as the baseline.


     D.  Evaluate Alternatives

          After the  alternatives have been developed,  each of them should
     be evaluated by comparing their impacts to the baseline projection.
     Special  consideration should be given to those sensitive impact areas
     identified  in  the evaluation  of the existing situation.

          It is  not  necessary to do  a complete environmental  assessment
     of each of the  alternatives.  In every case,  however,  the impacts
     of both the structural  and nonstructural  aspects  of the plan should
     be considered.   Table 13.1  contains a list of those environmental,
     social  and  economic factors believed to be generally most important.
     Special  attention should be given  to long-term impacts,  irreversible
     impacts, and indirect impacts such as development.   Resource and energy
     use associated  with each alternative should also  be highlighted.  The
     results should  be displayed in  a format for use in  public meetings
     and other participation efforts.


11.3  Environmental  Effects  of the Selected Plan

     The results of  the environmental,  social, and economic impact  evaluation
will be used in  the  plan selection process (Chapter 13).   Once a  plan has
been adopted, a  complete description of the impacts that the selected plan
will have on the area's environment  should be completed.   The vast  majority
of the data  required to do this should  be readily available as a  result of
the evaluations  already performed.  This more detailed evaluation should
describe the impacts of the  proposed structural  and nonstructural  actions.
Whenever possible,  the impact of each action on each affected environmental,
social or economic  category  (see Table  13.1) should be described  and dis-
played.  However, if more  than one action impacts  a category, the cumulative
impact should be described.   Impacts may  be  categorized as:

     1.  Beneficial  or adverse;

     2.  Short or long-run;

     3.  Reversible  or irreversible; and

     4.  Primary (direct)  or secondary  (induced).
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     Included in the irreversible impacts should be an evaluation of any
irreversible commitments of resources including energy.   (See §6.304 (c-f)
of 40 CFR Chapter I, Part 6 for an explanation of these terms and examples).

     Emphasis should be given to the cumulative impacts of all  elements
of the plan.  In addition, more localized impacts of specific plan elements,
such as treatment plant locations, interceptor sewers, and industrial  site
locations, should also be assessed and highlighted when these impacts  are
judged as significant.  Greater emphasis should be given to those localized
impacts of individual projects anticipated to be developed during the
initial five years of plan implementation.
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                               CHAPTER 12

                         PUBLIC PARTICIPATION
12.1   Introduction
      A.   Need for Public Involvement

          An effective public involvement program is essential to
      ensuring the success of any areawide water quality management
      effort.  In addition to the legal requirements there are sound
      reasons for undertaking such efforts.  Public participation
      provides an opportunity for resolution of conflict, an opportunity
      for the presentation of contrasting points of view, and the
      transmittal of important information.  If a planning agency
      has made adequate provisions for public involvement the final
      plan should accurately reflect community goals and preferences.
      Such involvement would also reinforce public trust in the
      planning process, thereby increasing the likelihood of public
      acceptance of the final plan and achievement of water quality
      goals.

      B.   Legal Requirements

          Public participation is an important element in any water
      resources planning effort.  The authors of the Federal Water
      Pollution Control Act Amendments (P.L. 92-500) recognized this
      fact and set forth certain minimum requirements for public
      involvement.  Section 101(e) states:

               Public participation in the development, revision,
               and enforcement of any regulation, standard,
               effluent limitation, plan, or program established
               by the Administrator (of EPA) or any State under
               this Act shall be provided for, encourage, and
               assisted by the Administrator and the States.

      In accordance with certain requirements established in the Act
      the Environmental Protection Agency has published regulations
      specifying minimum guidelines for public participation in water
      pollution control efforts.  These regulations (40 CFR 105)
      require State agencies to do the following:

          1.  Develop a program that will provide informational
              materials for public use at the earliest possible time.

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 2.   Make sure that such information—which is to include water
     quality data and other pertinent information—is conveni-
     ently accessible to the public at informational  "depositories"
     in appropriate locations.

 3.   Provide technical  and information assistance "to public
     groups for citizen education,  community workshops,  training,
     and dissemination  of information to communities."

 4.   Develop mechanisms that will  allow interested or affected
     individuals and organizations  to have early consultation
     with the agencies  on program  matters.

 5.   Develop and maintain lists  of  individuals who wish  to
     receive information from the  agency on a regular basis.

 6.   Follow EPA regulations concerning procedures for the
     holding of public  hearings  if  the State agency's pro-
     cedures are less stringent.

 7-   Conduct public hearings whenever there is significant
     public interest.

 8.   Whenever there is  doubt concerning the degree of public
     interest, the question should  be resolved in favor  of
     holding the hearing or, if  necessary,  of providing  alter-
     native opportunity for public  participation.

 9.   Give the public at least 30 days notice prior to hearings
     and prepare detailed fact sheets on the issues involved.

10.   Provide an opportunity for  public comment before any
     settlement with a  pollution source is  negotiated.

11.   Encourage the public to report violations of water  quality
     laws.

12.   Develop procedures for the  consideration of evidence sub-
     mitted by the public.

13.   Include a summary  of public participation in any application
     for a construction project  grant.   Each summary  must include
     a description of the measures  taken by the agency to provide
     for, encourage and assist public participation in relation
     to the matter; the public response to  such measures; and the
     disposition of significant  points raised.
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    It must be stressed that the actions covered in these regulations
    represent only the minimum steps that local  agencies may undertake
    in the area of public involvement.   The success of any 208 planning
    effort will probably depend in large part on the degree of public
    involvement that the local planning agency is able to achieve.

    C.   Goals and Objectives of Public  Involvement Programs

         Beyond satisfaction of the legal requirements for public par-
    ticipation there are several sound  objectives that any agency involved
    in a 208 planning effort should try to achieve:

         1.   At the very beginning of any planning effort the Agency
             involved should seek to identify affected public interests
             and maintain their involvement throughout the planning
             process.

         2.   An informed public.  It is of primary importance to provide
             the public with an opportunity to thoroughly familiarize
             themselves with all the various aspects of the planning
             effort so that they can contribute in a meaningful  way to
             intelligent decisions.

         3.   Citizens should be provided with an opportunity to:

             a.  Help in defining the community/s goals and problems.

             b.  Assist in delineating  types of solutions.

             c.  Formulate several alternative solutions for waste-
                 water management consistent with the views of the
                 public.

             d.  Assist in defining the impact assessment of each
                 alternative and react  to the solutions.

             e.  Facilitate the identification of public preferences
                 from these various alternatives.

         Achievement of these objectives does not guarantee an increased
    probability of actual plan implementation, but it will  help to ensure
    that whatever plan is finally selected reflects the preferences of
    those most affected.
12.2  Considerations for Development of a Public Involvement Program

          A detailed public involvement program should be assembled as
      soon as possible after area designation.   The plan should detail
      the specific mechanisms to be used at each step in the planning
      process.   It is important that the process be structured so that
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     it depends absolutely upon receiving public inputs at each specific
     stage.   Once developed,  programs  must be continually evaluated and
     adjusted in response to  changing  requirements.

          In devising  a public involvement plan, the responsible agency
     should  consider the requirement that the 208 plan be completed
     within  two years  after grant approval.   Since on-going public
     participation is  potentially a  lengthy and time-consuming process,
     planners should maintain a realistic balance between the need for
     public  involvement and the need to  complete the planning process
     within  the allotted time.

12.3  Timing of Key Public Involvement Issues

      A.   Initial  Stage

           During  the  first stage of a 208 project the planning agency
      will  identify the participants and their responsibilities,  establish
      channels of communication between  the participants  and convince
      potential participants  that their  inputs are needed.   Other inputs
      to be  obtained at this  stage include:

           1.  an  evaluation  of public awareness of water quality problems;

           2.  an  assessment  of the  relative importance of water  quality
               goals in relation to  other community goals;

           3.  an  evaluation  of community attitudes  toward growth and
               the role that  water quality management can play in
               achieving community growth objectives;

           4.  an  assessment  of public attitudes about the use of land
               use controls in  regulating water quality;

           5.  a determination  of the  public's willingness  to participate
               in  regional  plans that  might result in some loss of local
               autonomy and control.

           6.  An  estimate of public attitudes toward land  disposal  and
               other innovative and  controversial  pollution control
               technologies.

      B.   Design of Alternatives

           Inputs  from the initial stage will  be used to  establish design
      criteria for the development of  plan alternatives.   As this is
      done,  other  essential inputs include:

           1.  an  assessment  of the  acceptability of certain economic, social
               and environmental  impacts,  such as new uses  for water permitted
               by  improving its quality,  disruptions due  to the construction
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               of facilities, new demands on water supply and potential
               for stimulating community growth.

           2.  an evaluation of community attitudes toward institutional
               and financial alternatives that might be adopted to imple-
               ment the plan.

      C.   Impact Assessment

           Public response to preliminary impact assessment of the various
      alternatives is required.  The public will now have the opportunity
      to suggest the study of impacts that were not addressed or to urge
      more detailed study of those that were considered.  Special efforts
      should be made to obtain the reactions of those individuals and
      institutions that would bear the responsibility for financing,
      construction, operations, monitoring and enforcement.

      D.   Recommendation and Acceptance of the Final Plan

           During this stage the planning agency will consider any reasons
      why the least-cost plan should not be chosen, such as the attainment
      of additional benefits from increased expenditures, or the minimi-
      zation of undesirable social, economic and environmental impacts.
      Public comment is needed to conduct an analysis that accurately
      reflects community goals and preferences.

           At this stage it is vital that elected officials who are
      responsible for local approval of the recommended plan are made
      aware of public comments and opinions.  This is a major responsibility
      of the entire public participation program.

      E.   Implementation

           Once an areawide plan has been selected the need for public
      involvement will be greatly reduced; however, it must still continue.
      The public should then be assisted and encouraged to participate
      in planning for individual waste treatment works that is undertaken
      as the 208 plan is implemented.  (See 39 FR 29, "Construction Grants
      for Waste Treatment Works," February 11, 1974.)  The public should
      also have the opportunity to participate in any periodic updating
      of the 208 plan.  Information must be available on a continuous
      basis to permit adequate monitoring of progress made under the plan.

12.4  Public Participation Program Development

           A thorough plan for public involvement should be assembled
      as soon after designation as possible.  The plan should detail
      the specific mechanisms that are to be employed at each step in
      the 2138 planning process.  While there are no hard and fast rules
      for structuring a public involvement program several steps appear
      to be essential.  The following1 tables suggest the way in which
      integration of the planning process and public involvement mechanisms
      may be achieved.

                                    12-5

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SUGGESTED PUBLIC
INVOLVEMENT
One-Way One-Way
Output 1 input
[ Two-Way
1 Interaction
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fin
DESIGNATION j
TECHNICAL PLANNING
(a.) Assemble existing water
quality data.
(b.) Construct inventory of
existing dischargers.
(C.) Projections ,
eludes Land Use Plan)
(d.) Effluent Limited
Segment Analysis






(e.) Water quality
segment analysis
(f.) Determine alternate
subplans of treatment
control flow reduction
consistent with elegible
WLA (including inform-
ation on cost) effective-
! ness, reliability, and
1 environmental imosct.
j
' (g.) Screen subp!ans to
| select leading alternative
""i subplans

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c.) Conduct management
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-
               12-6

-------
SUGGESTED PUBLIC
INVOLVEMENT
Mechanics for Section 208
Planning /
/ c
208 PLANNING STEPS
(j.) Evaluation and selection
of combined technical
and manpower plans
(b.) Evaluate alternative area-
wide plans:
1 . Cost effectiveness
2. Social environmental
impact.
i TECHNICAL-MANAGEMENT
PLANNING
(c.) Select areawide plan
to implement:
1. Technical feasible
2. Management feasible
1. Public acceptance
(d.) Develop detail for plan
output and revise.
(e.) Outputs
(f.) Reports
Remarks

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12-7

-------
12.5  Program Evaluation

           An important part of any public involvement program is a
      set of feedback mechanisms to continually monitor the success
      or failure of the involvement mechanism being used.   If the
      feedback indicates that ongoing  efforts are inadequate, ad-
      justments should be made as soon as  possible so that the success
      of the program will not be jeopardized.  In making an evaluation,
      information may be drawn from a  variety of sources,  including:

           1.  number and tone of informal  contacts initiated by
               the public;

           2.  attendance at meetings  and  hearings;

           3.  amount of related public-sponsored activity such as
               meetings, workshops, door-to-door campaigns, etc.

           4.  amount and tone of media  coverage;  and

           5.  formal  surveys

12.6  Advisory Committee

           In compliance with Section  304(j)  of P.L.  92-500 the Adminis-
      trator of the Environmental  Protection  Agency has  entered into  an
      agreement with the Secretaries of  the Departments  of Agriculture,
      Army,  and Interior.   Notice of Final Agreements was  published in
      the Federal  Register,  Vol.  38, No. 225,  November  23,  1973.

           As a result of this agreement the  planning agency in each
      area designated  under Section 208(a)(2)  must provide for the
      creation of an advisory committee  and invite representatives  of
      the Departments  of Agriculture,  Interior,  and Army to participate.
      Each Department  may or may not participate as it  deems appropriate
      The purpose of this  requirement  is to provide for  maximum utiliza-
      tion of the appropriate programs authorized  under  other Federal
      laws to be carried out for achievement  and maintenance of water
      quality through  appropriate  implementation of plans  approved  under
      Section 208.

           Pursuant to 208(2)(A)  grant regulations  for  Section 208
      (40 CFR 35 ,  Subpart  F)  further  state that provisions  must  be
      made for inclusion of representative of the  State  and  public  on
      an  Areawide  Planning  Advisory Committee.   The membership may
      be  further expanded as  may be appropriate  in  the  opinion of EPA,
      the State(s)  and the  applicant agency.
                                  12-8

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12.7  Institutional Alternatives For Representation of the General Public

          The requirement for public involvement in areawide water
      quality planning and management is clearly defined by the Act
      and Agency regulations.  The institutional arrangements that
      may be utilized to implement these requirements are a matter
      of local discretion as long as the mechanisms used meet
      criteria of the Act and regulations.  Whatever institutional
      arrangement is finally selected should meet the following
      requirements:

          1.  Provide clearly defined channels through which citizens
              may influence decision-makers.

          2.  Defines responsibility for actively carrying out public
              involvement activities.

          3.  Provides adequate funding for public participation
              throughout the planning process.

          4.  Responsive to all interested citizens, but not
              dominated by any single interest group.

      Although a number of institutional arrangements may satisfy
      these requirements, a formal mechanism to ensure full citizen
      understanding and approval of the selected plan will probably
      be necessary given the scope and complexity of areawide water
      quality management.

           One exemplary arrangement would feature a fully funded
      public participation working group acting in partnership with
      the 208 planning staff and management agency.  At least two
      full time staff members would be needed to carry out the tasks
      of the working group.  Additional funds should be made available
      to cover the cost of printing, announcements in the media and
      other incidental expenses.  An illustration of this  type of
      arrangement is provided on the following page.
                                  12-9

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                     ORGANIZATIONAL STRUCTURE
                           Advisory Committee*
                           208 Planning Staff
                           Citizen Participation
                               Working Group
                 208 Management
                      Agency
   **
      Effluent
      Limitations
Water Standards
  Attainment
  Nonpoint
Source Study
*Composed of non-voting Federal  representatives  (in compliance with
 the 204(j) agreement), State and local  representation and a voting
 member of the Citizens Participation Working Group.

**The Working Group may wish to  divide itself along the lines of major
 areas of concern as illustrated.
                                  12-10

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                           CHAPTER 13


          COMPARISON OF ALTERNATIVES AND SELECTION OF PLAN
13.1  Purpose

      The purpose of this chapter is to provide guidance in the
comparison of alternative plans leading to the selection of an area-
wide waste treatment management plan for the area.  The process
presented assumes that each of the alternatives, if implemented,
would meet all regulatory requirements.  In addition, it is assumed
that the alternatives are in compliance with appropriate goals and
objectives.  The intention of the process presented in this chapter
is to compare the plans in terms of the defined criteria of cost
effectiveness (monetary costs, environmental, social and economic
impacts), technical reliability, feasibility of plan implementation,
and public acceptability.  Emphasis will also be placed upon drawing
together the evaluations already completed so that the alternatives
can be more easily discussed and compared.  Finally, while public
participation is necessary throughout the planning process, it is
essential that the public be involved to a significant degree during
this process.
13.2  The Plan Selection Process

      A.  Assessment of Alternative Areawide Plans

           No rigorous analytical method exists which will reaaily
      identify the best plan for the area.  As discussed in previous
      chapters, many factors should be considered in comparing the
      alternatives.  Some of the factors, in particular cost assess-
      ments, can be quantified.  Others cannot be easily quantified
      but can only be qualitatively assessed based upon professional
      judgement aided by the cumulative views of the public.  Plan
      assessment involves the comparison of all key factors deemed
      pertinent for reliable decision making.  Table 13.1 contains
      a list of those which are believed to be generally most
      important.  The inputs for that table are to be developed in
      the technical planning process (Chapter 3.5.B), the step at
      which alternative plans are evaluated in light of information
      on their cost, technical reliability, environmental, social
      and economic impact, and implementation feasibility and re-
      liability.  The effects of the alternatives should be assessed
      quantitatively whenever possible.  In all other cases a qual-
      itative assessment should be made.

-------
     Representatives from all affected groups should be involved
in the assessment of the alternative proposals.  The definition
of affected groups may be as broad or specific as desired.  How-
ever, it should match the level of specificity that is chosen
to analyze impact so that meaningful dialogues can be established.
In most areas, affected groups would include conservation groups,
economic interests, local elected officials, planning agencies,
state departments of health, water pollution control and natural
resources, the regional office of EPA and the Areawide Planning
Advisory Committee.  The efficiency of the plan approval and
implementation process will be much improved if the people who
are responsible for carrying it out fully understand and contribute
to the assessment and recommendation of alternatives.

B.  Develop Recommended Plan

    Once the alternative plans have been assessed, the planning
agency should be in a good position to compare the alternatives
and, as a result of the comparison, develop a recommended plan.
A logical approach for comparing the alternatives would be to
initially identify that alternative which will achieve water
quality objectives at minimum monetary cost.  This least cost
plan can serve as a base against which the increased costs and
additional effects of other alternatives can be compared for
the purpose of selecting the best plan for the area.  The major
environmental, social and economic impacts of this least cost
plan should be listed, including a discussion of the institu-
tional and financial issues that would be raised if the plan
were recommended.  One suggested format is shown in Table 13.2.
Most of the required impact information should be contained in
Table 13.1.

     The next step should be the identification of the incre-
mental monetary cost and incremental impacts of each of the
remaining alternative plans in relation to the base plan.
Information contained in Table 13.1 would provide the  basis
for this incremental evaluation.  Description of alternatives
should include the plan elements (such as construction, zoning,
operations, etc.) and measures or statements of the changes
in the impacts of those plan elements.   In addition to the
environmental, social, economic, and management impacts,
additional benefits that could be gained or undesirable
situations that could be avoided  should be described.   The
alternatives should be described to make comparisons with the
additional costs required as direct as possible.   The  results
may be summarized in the format of Table 13.3.
                       13-2

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     The planning agency should then conduct workshops for the
appropriate elected officials who will be reviewing and
commenting on the proposed plan.  The objective of the work-
shops should be to fully inform them of the consequences of
implementing any of the alternative areawide plans.  The
agency should also take note of their responses to the
alternatives to see if they can be changed to improve plan
acceptability.  Since these workshops and the public hearings
to follow could very well result in requirements for sub-
stantial changes in the design of plan elements and the
analysis of additional impacts, the agency should schedule
resource expenditures to be able to respond fully to the
need for additional analysis.

     At the conclusion of the workshops, the planning agency
should recommend a single plan as the proposed 208 plan.  The
plan elements, costs, impacts, and implementation issues can
be summarized in the format shown in Table 13.2.  The plan
description should be accompanied by a brief report that
summarizes the process followed, the alternatives considered
and the criteria used to reach a final recommendation.  The
report and charts should be suitable for use at public hearings

C.  Hold Public Hearings to Present Proposed Plan

     The planning agency should conduct formal public hearings
on the proposed plan and the alternatives considered in its
development.  The planning agency should then respond to the
issues raised at the hearings and modify the proposed plan
if appropriate (as judged by the agency).   The planning agency
will then submit the proposed plan to the appropriate local
governing bodies for review and recommendations as specified
in Chapter 15 (15.2).
                            13-3

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                            TABLE 13.1


         COSTS AND EFFECTS OF ALTERNATIVE AREAWIDE PLANS


                                                    Alternative Plans


Significant Effects                               P-l_     P-2       P-3


1.  Water Quality Goals

    A.  Contribution to goals and
        policies of the Act.

    B.  Contributions to other water-
        related goals of the planning
        area.

2.  Technical Reliability

    A.  Frequency of plant upsets

    B.  Frequency of spills

    C.  Frequency and effects of
        combined sewer overflows

    D.  Nonpoint source control

3.  Monetary Costs

    A.  Capital costs including discounted
        deferred costs

        (1) public
        (2) private
        (3) total

    B.  O.M. & R Costs

        (1) public
        (2) private
        (3) total

    C.  Net revenue (public)

    D.  Overhead and plan management

    E.  Total average annual costs
        (1) public
        (2) private
        (3) total                13_4

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                          TABLE 13.1 (cont)


              COSTS AND EFFECTS OF ALTERNATIVE AREAWIDE PLANS


                                                 Alternative Plans
                                               P-1       P-2      P-3


Significant Effects



4.   Environmental Effects

    A.  Hydrology (surface and groundwater)

        (1)  water quality
        (2)  water quantity
        (3)  water uses
        (4)  flood hazards

    B.  Biology

        (1)  rare and endangered species
        (2)  wildlife habitats

    C.  Air quality

    D.  Land

        (1)  amount of growth
        (2)  type of growth
        (3)  intensity of growth

        (the above should be related
        to the 208 land use plan)

        (4)  soil erosion damage
        (5)  significant environmentally
             sensitive areas

    E.  Energy and Resource Use

        (1)  energy (power)
        (2)  chemicals
        (3)  land commitment for planned
            features
                                  13-5

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                           TABLE 13.1 (cont)

          COSTS AND EFFECTS OF ALTERNATIVE AREAWIDE PLANS


                                                  Alternative Plans

                                               P-1      P-2      P-3

Significant Effects


5.   Social and Economic Effects

    A.  Changes in economic activity
        where appropriate

        (1)  income per capita
        (2)  agriculture
        (3)  mining
        (4)  manufacturing
        (5)  services

    B.  Employment changes

        (1)  regional availability of
             skilled manpower for
             treatment plant operation
             and monitoring
        (2)  dislocation

    C.  Dislocation of individuals, businesses,
        or public services

    D.  Public health

    E.  Aesthetics

        (1)  recreational accessibility and
             activities
        (2)  unique archeological, historical,
             scientific and cultural areas
        (3)  noise pollution

6.   Implementation Feasibility and  Reliability

    A.  Legal capability
    B.  Operational effectiveness
    C.  Practicability
    D.  Coordinative capacity
    E.  Public accountability

7.   Public Acceptability

                                  13-6

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PLAN ELEMENTS
   1.
   2.
   3.
TOTAL COST  $
IMPACTS
                            TABLE 13.2

                         LEAST COST PLAN
(A summary list of planning, construction, zoning,
sludge and effluent disposal, operations, moni-
toring actions, etc., indicating their geographic
sites).
                                     DESCRIPTION
Economic

   1.

   2.

   3.

Social

   1.

   2.

   3.

Environmental

   1.

   2.

   3.
IMPLEMENTATION

   (Institutional  and financial issues.)
                                      13-7

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                TABLE 13.3
ALTERNATIVE LEAST COST PLAN MODIFICATIONS

Plan Elements
1.
2.
3.

Least
Cost
Alternative



Alternative
A



Impacts


13-8
Cost
Increase



Alternative
B



Impacts



Cost
Increase



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                               CHAPTER 14

                                 REPORTS
14.1  Report Structure


      The planning report should be structured to contain the following
four basic components in the main report:

           a.   Description of the overall adopted plan and each element
           of the plan.  This information should include each of the
           specific plan outputs cited in Chapter 4 and the adopted land
           use plan.

           b.   Proposed management system for implementation of the plan,
           including the management agencies to be designated.

           c.   Proposed program for monitoring the results of the plan
           implementation on water quality and undertaking the annual
           review and associated revisions of the plan.

           d.   Recommendation by the governing bodies of local  governments
           having responsibility for, or which would be affected by,
           implementation of the plan and having jurisdiction in the
           planning area as to State certification and EPA approval
           of the plan.

      Supporting information should be appended to the report on the
following topics:

           a.   Preliminary engineering layouts and designs, technical
           data, and cost estimates for alternative sub-plans and
           areawide plans.

           b.   Evaluation and comparison of the direct costs; environmental,
           social, and economic impacts; implementation feasibility; and
           other related information of the leading alternative areawide
           plans.

           c.   The principal rationale incorporated into the adopted land
           use plan, including alternative land use plan comparisons.

           d.   Supplementing engineering feasibility data on the features
           included in the first stage development of the municipal wastewater
           facilities portion of the adopted plan.  This information should
           include:

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                 1.    Collection system and  interceptor configurations,
                 profiles,  sizes, and cost breakdowns;

                 2.    Treatment plant data,  including site plan,  layouts
                 of  unit processes,  flow charts,  and design,  and  per-
                 formance data;

                 3.    Combined sewer overflow and storm sewer control
                 measures,  including site plan,  layouts of processes,
                 flow charts,  and design and performance data;

                 4.    Sludge  handling and disposal  facilities information,
                 including  design and performance data, disposal  site
                 layouts, and  sludge conveyance  facilities details;

                 5.    Effluent disposal  data,  including layouts and
                 profiles of  outfalls for either  inland surface waters  or
                 oceans  and descriptions and illustrations of deep well
                 injection  facilities or land  disposal  facilities; and

                 6.    Wastewater reuse facilities data.

            e.    A summary  of  the public participation  involved throughout
            the planning process.

 14.2  Report on Annual  Review of Plan
      The adopted plan must be reviewed  and  updated  annually.   If
substantial  revisions result from  such reviews,  the  entire  planning
report should be reviewed accordingly.   Relatively minor  revisions result-
ing from such an update could  be documented,  if  practicable,  in  an
addendum to  the initial  report.
                                 14-2

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                                CHAPTER 15

                  PLAN SUBMITTAL, REVIEW AND APPROVAL
15.1  Introduction

     Each 208 planning agency must submit its areawide waste treatment
management plan, including recommendations for management agencies, to
the appropriate EPA Regional Administrator within 24 months after the
award of the planning grant.  This plan must be submitted to EPA through
the Governor or State reviewing agency designated by the Governor.


15.2  Local Review and Recommendation

     Prior to submitting its plan to EPA through the appropriate Governor
or State reviewing agency, the planning agency must provide the governing
bodies of local governments having responsibility for, or which would be
directly affected by, implementation of the plan and having jurisdiction
in the planning area, with an opportunity to comment on the plan and
proposed management agencies and make recommendations for approval or dis-
approval.  In the event that a local unit of government fails to provide a
recommendation within 30 days of receiving the request, the planning agency
may consider that the plan has been favorably recommended by that unit of
local government.

     The recommendations, whether favorable or unfavorable, are to be
forwarded by the planning agency to the Governor in connection with his
certification of the initial plan.  The local comments are also to be
forwarded to the appropriate EPA Regional Administrator when the plan is
submitted to EPA by the State.


15.3  State Review and Certification of Approval

     When the plan is received by the Governor prior to its submission to
EPA, the Governor or the State reviewing agency must review the plan for
the necessary certification of approval required by Section 208(b)(3) of
the Act.  The purpose of the State's review is to determine whether:

     1.  The plan is in compliance with the provisions of the State
     basin plan(s) and the State Program prepared under Section 106
     of the Act and will be accepted as a detailed portion of the
     State plans when approved by EPA;

-------
     2.  The plan is internally consistent with the water quality
     control needs of the area;

     3.  The plan is consistent with all  State and local legislation,
     regulations or other requirements or plans regarding land use
     and protection of the environment; and

     4.  The plan provides an adequate basis for selection and designa-
     tion of management agencies to be designated under Section (c) of
     the Act.

     Based on the State's review of the plan and the recommendations received
from the local  units of government, the Governor must then determine whether
to approve or disapprove the plan.

     If the Governor approves the plan, he must then forward the plan to the
appropriate EPA Regional Administrator with his certification of approval
and proposed designation of management agencies.  The Governor must also
forward the recommendations received from the local units of government.

     If disapproval is necessary, that is, if no certification of approval
can be issued by the Governor due to failure of the planning agency to
comply with one or more of the above provisions, the Governor must notify
the appropriate EPA Regional Administrator and the planning agency that the
plan is deficient and specify how the plan is to be modified so that it may
receive State certification of approval.


15.4  EPA Review and Approval

     The appropriate EPA Regional Administrator will be responsible for plan
approval.  The Regional Administrator's approval of the plan will  be based
upon (1) the State's certification of approval and proposed designation of
management agencies, and (2) EPA's review of the plan submission for con-
formance with provisions of Sections 201  and 208 of the Act and the require-
ments set forth in 40 CFR 35, Subpart F,  as well as any other applicable
regulations.  State and local comments and recommendations will also be
considered.  (Note:  EPA will not approve any plan in the absence of proposed
designations of management agencies.)

     Within 120 days after receiving the  plan submittal, the Regional
Administrator must:

     1.  Notify the State(s) and the planning agency of approval of the
     plan and the proposed management agency designations; or

     2.  Notify the State(s) and the planning agency that the submittal
     is deficient in one or more respects and specify the ways in which
     the submittal must be modified to receive EPA approval.  EPA must
                                 15-2

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also specify the time period allowed for the modifications; or

3.  Notify the State(s) and the planning agency that the designa-
tion of waste treatment management agencies cannot be approved
due to failure to meet the requirements set forth in Section 208
(c)(2) of the Act, thereby delaying further consideration of the
plan until the deficiencies are remedied.  EPA must also specify
the time period allowed for correcting the deficiencies.
                              15-3

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                               GLOSSARY


Ihej\cjt - Public Law 92-500.  "This Act may be cited as the 'Federal
          Water Pollution Control Act Amendments of 1972.'"  (Act,
          sec. 1).

Base level technology - Minimum level of treatment required by the Act.

Basin - "The term  'basin' means the streams, rivers, and tributaries
          and the  total land and surface water area contained in one
          of the major and minor basins defined by EPA, or other basin
          unit as  agreed upon by the state(s) and the Regional  Admin-
          istrator."  (proposed regulations 40 CFR 130.2(1)).

Best Available Technology (BAT) - "Not later than July 1, 1983, effluent
          limitations for categories and classes of point sources, other
          than publicly owned treatment works,...shall require application
          of the best available technology economically achievable for
          such category or class, which will result in reasonable further
          progress toward the national goal of eliminating the discharge
          of all pollutants as determined  in accordance with regulations
          issued by the Administrator pursuant to section 304(b)(2) of
          this Act."  (Act, sec. 301(b)(2)(A)).

Best Practicable Control Technology (BPCT) - "Not later than July 1,
          1977, effluent limitations for point'Sources, other than
          publicly owned treatment works,  shall require the application
          of the best practicable control  technology currently available
          as defined by the Administrator  pursuant to section 304(b)  of
          this Act."  (Act, sec. 301(b)(l)(A)).  This is also referred
          to as Best Practicable Technology (BPT).

Best Practicable Haste Treatment Technology (BPWTT) - "Waste treatment
          management plans and practices shall provide for the application
          of the best practicable waste treatment technology before any
          discharge into receiving waters, including reclaiming and
          recycling of water and confined  disposal of pollutants so they
          will not migrate to cause water  or other environmental pollution.'
          (Act, sec. 201(b)).

Capital intensive  - Measure requiring primarily initial capital outlays
          for its  development and relatively little cost for operation and
          maintenance.

Combined  sewer - "A sewer intended to serve as a sanitary sewer and a
          storm sewer, or as an industrial sewer and a storm sewer."
          (40 CFR  35.905-2)

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Discharge of pollutants  -  "The  term  'discharge of a pollutant' and the
          term 'discharge  of pollutants'  each means (A) any addition
          of any pollutant to navigable waters from any point source,
          (B) any addition of any  pollutant  to the waters of the contig-
          uous zone  or  the ocean from any point source other than a
          vessel  or  other  floating craft."   (Act, sec. 502(12)).

Effluent limitation  -  "The term 'effluent limitation' means any
          restriction  established  by a State or the Administrator
          on quantities, rates, and concentrations of chemical,
          physical,  biological, and other constituents which are
          discharged from  point sources into navigable waters, the
          waters of  the  contiguous zone,  or  the ocean, including
          schedules  of  compliance."  (Act, sec. 502 (11)).

Effluent limited segments  - "Any segment  where water quality is meeting
          and will continue to  meet applicable water quality standards
          or where there is adequate demonstration that water quality
          will  meet  applicable  water quality standards after the applica-
          tion of the  effluent  limitations required by sections 301(b)(l)(A)
          and 301(b)(l)(B)  of the Act."   (proposed regulations, 40 CFR
          part 131).

Facilities planning  -  Pertains  to  "provision for cost-effective,
          environmentally  sound and implementable treatment works
          which will meet  applicable requirements of sections 201 (g),
          301,  and 302 of  the Act."  (201  guidance, p.3).

Infiltration - "The  water  entering a sewer system, including sewer
          service connections,  from the ground, through such means as,
          but not limited  to, defective pipes, pipe joints, connections,
          and manhole walls.  Infiltration does not include, and is
          distinguished  from, inflow."  (40  CFR 35.905-9).

Inflow - "The water  discharged  into a sewer  system, including service
          connections,  from such sources  as, but not limited to, roof
          leaders, cellar,  yard and area  drains, foundation drains,
          cooling water  dischargers, drains  from spring and swampy
          areas,  manhole covers, cross connections from storm sewers and
          combined sewers,  catch basins,  storm waters, surface runoff,
          street wash waters, or drainage.   Inflow does not include, and
          is distinguished  from, infiltration."  (40 CFR 35.905-11).

Inplace pollution source -  Time build up  of  pollutant load deposited
          in a  receiving water  bed and existing as a load upon that
          receiving  water.

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-kjllld__u_s_e - The physical mode of utilization or conservation of a given
          land area at a given point in time.

         controls - Methods for regulating the uses to which a given
          land area may be put, including such things as zoning,  sub-
          division regulation, and flood-plain regulation.

Materials balance - An illustration of the principle of conservation
          of matter; that is, an accounting may be performed of all
          transfers of mass from one point or state to other points  or
          states, such that the total original mass is entirely accounted
          for.

Maximum daily load - "Each plan shall include for each water quality
          segment identified pursuant to sec. 131.203, the  total  maximum
          daily loads of pollutants, including thermal loads,  allowable
          for each specific criterion being violated or expected  to  be
          violated."  (proposed regulations 40 CFR part 131.205).

Navigable waters - "The term 'navigable waters'  means the waters  of
          the United States, including the territorial seas."   (Act,
          sec. 502(7)).

1983 goals - Pertains to goals outlined in sec.  101(a) and  elsewhere
          in the Act.

1977 goals - Pertains to the July 1, 1977 milestone set by  the Act,
          particularly in terms of treatment technology and limitations.

Nonpoint source - Generalized discharge of waste into a water  body
          which cannot be located as to specific source, as outlined
          in Section 304(e) of the Act.

Permits - "The Administration may... issue a permit for the  discharge
          of any pollutant, or combination of pollutants, .. .upon  condi-
          tion that such discharge will meet either all  applicable
          requirements under sections 301, 302,  306, 307, 308,  and 403
          of this Act, or prior to the taking of necessary  implementing
          actions relating to all  such requirements, such conditions as
          the Administrator determines necessary to carry out  the pro-
          visions of this Act.  (Act, sec. 402(a)(l)).  "The Administrator
          shall  authorize a state, which he determines has  the capability
          of administering a permit program which will carry out  the
          objective of this Act, to issue permits for discharges  into
          the navigable waters within the jurisdiction of such state."
          (Act,  sec. 402(a)(5)).  The permit program is a part of the
          National  Pollutant Discharge Elimination System (NPDES).

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Planning agency - "The governor...or governors shall...designate each
          208 planning area including its boundaries,  and  for  each  area
          a single representative  agency to be responsible for the
          planning....The agency shall  be a representative organization
          whose membership shall include but need not  be limited to
          elected officials of local  governments, or their designees,
          having jurisdiction in the designated planning area."   (40  CFR
          126.12, 126.13, 126.11).

Planning period - "The period over which a waste treatment management
          system is  evaluated for  cost-effectiveness.   The planning
          period commences with the initial  operation  of the system."
          (40 CFR Appendix A, d(3)).   In this case, the planning period
          is 20 years.

Planning process - Strategy for directing resources, establishing
          priorities,  scheduling actions, and reporting programs toward
          achievement  of program objectives.

Point source - "The  term 'point source1  means any discernible, confined
          and discrete conveyance,  including  but not limited to  any pipe,
          ditch, channel, tunnel,  conduit, well, discrete  fissure,  con-
          tainer, rolling stock, concentrated animal feeding operation, or
          vessel or  other floating  craft, from which pollutants  are or can
          be discharged."  (Act, sec.  502(14)).

Pollutant - "The term  'pollutant1 means  dredged  spoil,  soil, solid  waste,
          incinerator  residue,  sewage;garbage,  sewage  sludge,  munitions,
          chemical  wastes, biological  materials, radioactive materials,
          heat, wrecked or discarded  equipment,  rock,  sand, cellar  dirt
          and industrial, municipal,  and agricultural waste discharged
          into water."  (Act, sec.  502(6)).

Pretreatment - "The  Administrator  shall.. .publish proposed regulations
          establishing pretreatment standards for introduction of pollu-
          tants into treatment works...which  are publicly  owned  for those
          pollutants that are determined not  to  be susceptible to treatment
          by such treatment works or  which would interfere with  the oper-
          ation of such treatment works."  (Act, sec.  307(b)(l)).   "Not
          later than July 1,  1977,...in  the case of discharge  into  a
          publicly owned treatment  works,...shall  require  compliance  with
          any applicable pretreatment requirements...under section  307
          of this Act."  (Act,  sec.  301(b)(l)(A)).

Residual waste - Solids removed from  wastewater  during  treatment.

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Secondary treatment - "There shall  be required...for  publicly owned
          treatment works in existence on July 1,  1977, or approved...
          prior to June 30, 1974...effluent limitations based upon
          secondary treatment as defined by the Administrator pursuant
          to section 304(d)(l) of this Act."  (Act, sec.  301 (b)(l )(B)).
          "The Administrator...shall  publish...information,  in terms of
          amounts of constituents and chemical, physical, and biological
          characteristics of pollutants, on the degree of effluent
          reduction attainable through the application of secondary
          treatment." (Act, Sec. 304(d)(l)).

State water quality standards - Standards of water quality set by the
          State for intrastate waters, that shall  be  at least as
          stringent as Federal standards and shall  further the goals
          of the Act.

Storm sewer - A sewer intended to carry only storm waters, surface
          run-off, street wash waters, and drainage." (40 CFR 35.905-22).

Upstream pollutant source - Source of pollutants discharged  into the
          receiving waters which is located upstream  from the area of
          consideration.

Waste load allocation - "A waste load allocation for  a segment is the
          assignment of target loads  to point and  nonpoint sources so
          as to achieve water quality standards  in the most  effective
          manner."  (303 guidelines).

Waste treatment facilities - "Any devices and systems used in the
          storage, treatment, recycling and reclamation of municipal
          sewage or industrial wastes of a liquid  nature...in addition,
          ...any other method or system for preventing, abating,
          reducing, storing, treating, separating, or disposing of
          municipal waste, including  waste in combined storm water
          and sanitary sewer systems."  (Act, sec. 212(2)).  Also
          termed treatment works.

Water quality limited segments - "Any segment where it is known that
          water quality does not meet applicable water quality standards,
          and is not expected to meet water quality standards even after
          the application of the effluent limitations required by sections
          301(b)(l)(A) and 301(b)(l)(B) of the Act."   (proposed regulations
          40 CFR part 131).

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                                BIBLIOGRAPHY
CHAPTER 3
Advisory Commission on Intergovernmental Relations.
   .Regional Decision Making: New Strategies for Substate Districts
   Washington, D.C., 1973.                 ~

Council of State Governments.  1971 Suggested State Legislation
   O97"1)' 1972 Suggested State Legislation (1972): 1973 Suggpst.pd
   State Legislation (1973).'~                  	

Fox, Irving K., et.al. Institutional Design for Water Quality Management:
   A Case Study of  the Wisconsin River Basin, vol. I-IX. Resources Center,
   University of Wisconsin, Madison, Wisconsin, 1971.

Kneese, Allen V., and Blair T. Bower.  Managing Water Quality.
   Baltimore, Maryland: Johns Hopkins Press, 1968.

U.S. Environmental  Protection Agency.  Institutional Arrangements for Water
   Quality Management Planning. Harold E. Wise and Associates, Washington, D.  C
   1971.

U.S. Environmental  Protection Agency.  Problems and Approaches to Areawide
   Water Quality Management, vol. I-IV.  School of Public and Environmental
   Affairs, Indiana University, Washington, D. C., 1973.


CHAPTER 4

Bosselman, Fred and David Callies.  The Quiet Revolution in Land Use Control.
   Washington, D.C.: Government Printing Office, 1971.

Chapin, F. Stuart, Jr.  Urban Land Use Planning.  Urbana, Illinois:
   University of Illinois Press, 1965.

Federal Water Quality Administration, United States Department of Interior.
   A Preliminary Analysis of the Effects of Urbanization on Water Quality.
   Washington, D.  C. : Government Printing Office, 1970.

Leopold, Luna B.,  et.al.   A Procedure for Evaluating Environmental Impact.
   Washington, D.  C. : U.S. Geological Survey, 1971.

McHarg, Ian.   Design with Nature. Gerden City:  Natural History Press, 1969.

Ohio Department of Natural Resources, Division of Planning.  A New Approach
   to Land Use Planning in Ohio. 1973

University of Delaware Water Resources Center.  The Christina Basin:  The
   The Protection  of Water Resources As a Basis for Planning in Developing
   Areas.   Newark, Delaware:  Delaware University, 1972.

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University of Delaware Water Resources Center.   Water Resources As a Basis
   for Comprehensive Planning and Development in the Christina River Basin.
   U.S.  Department of Interior, Office of Water Resources, Washington, D.C. 1973.

U.S.  Environmental Protection Agency, Office of Research and Development,
   Promoting Environmental  Quality Through Urban Planning and Controls.
   Socioeconomic Environmental Studies series,  1974.
CHAPTER 6

American Public Works Association.   Water Pollution Aspects of Urban Runoff.
   Federal Water Pollution Control  Administration, Washington, D. C., 1969.

Brunner, Dick and Daniel  Keller.   Sanitary Land Fill Design and Operation.
   U.S. Environmental Protection  Agency, Washington, D. C.,1972.

Sorg, Thomas J. and H. Lanier Hickman.   Sanitary Land Fill Facts,
   U.S. Department of Health, Washington, D. C., 1970.

U.S. Environmental Protection Agency.  Decision-Makers  Guide in Solid Waste
   Management.  Washington, D. C., 1974.

U.S. Environmental Protection Agency.  Ground Water Pollution from Subsurface
   Excavations. Washington, D. C.,  1973.

U.S. Environmental Protection Agency.  Methods for Identifying and Evaluating
   the Nature and Extent  of Nonpoint Sources of Pollutants, Washington,  D.C.,
   1973.

U.S. Environmental Protection Agency.  Identification and Control of Pollution
   from Salt Water Intrusion.  Washington, D. C.,  1973.

U.S. Environmental Protection Agency.  Methods and Practices for Controlling
   Water Pollution from Agricultural Nonpoint Sources.   Washington, D.  C.,  1973.

U.S. Environmental Protection Agency.  Processes,  Procedures, and Methods to
   Control Pollution from Mining  Activities.  Washington, D. C.,1973.

U.S. Environmental Protection Agency. Processes, Procedures, and Methods
   to Control Pollution Resulting from All Construction Activity.  Washington,
   D. C., 1973.

U.S. Environmental Protection Agency.  Processes,  Procedures, and Methods to
   Control Pollution Resulting from Sivicultural Activities. Washington, D. C.,
   1973.

U.S. Environmental Protection Agency.  Subsurface Water Pollution, A Selected
   Annotated Bibliography. Part I-  "Subsurface Waste Injection"; Part II-
   "Saline Water Intrusion"  Part III - "Percolation from Surface Sources".
   Washington,  D. C.

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U.S. Environmental Protection Agency.  The Control of Pollution from
   Hydrographic Modifications.  Washington, D. C., 1973.

U.S. Environmental Protection Agency.  Urban Runoff Characteristics,
   Washington, D. C. 1970.

U.S. Environmental Protection Agency.  Water Pollution Aspects of Street
   Surface Contaminants. Washington, D. C., 1972.


CHAPTER 7

Bailey, James R., et.al.  A Study of Flow Reduction and Treatment of Waste
   Water from Households.  Federal Water Quality Administration, Washington,
   D. C. :  Government Printing Office, 1969.

Hanke, Steve H. and Robert K. Davis.  "Potential for Marginal  Cost Pricing
   in Water Resource Management", Water Resources Research, 1973, p. 808-825.

Hirshleifer, Jack, James C. DeHaven and Jerome Milliman.  Water Supply:
   Economics, Technology and Policy.  Chicago, Illinois:  University of
   Chicago Press, 1960.

Howe, Charles W. and P.P. Linaweaver, Jr. "The Impact of Price on Residential
   Water Demand and Its Relation to System Design and Price Structure",
   Water Resources Research, 1967, p. 13-32.

Linaweaver, P.P., Jr., John C. Geyer and Jerome B. Wolff.   A Study of
   Residential Water Use.  Department of Housing and Urban Development,
   Washington, D. C. :  Government Printing Office, 1967.

National Water Commission.  Water Policies for the Future.  Washington,  D. C.  :
   Government Printing Office, 1973.  "Pricing as a Means  of Motivating  Better
   Use," p. 247 ff.


CHAPTER 8

U.S. Environmental Protection Agency.  Institutional Arrangements for Water
   Quality Management Planning.  Harold E. Wise and Associates, Washington,
   D. C. 1971.

U.S. Environmental Protection Agency.  Problems and Approaches to Areawide
   Water Quality Management, vol. I-IV.  School of Public  and Environmental
   Affairs.  Indiana University, Washington, D. C., 1973.
CHAPTER 10

Fifer, C.  Lee.  Effluent Charge Systems:  Analyses and Legislation.   Center
   for Study of Science, Technology and Public Policy, University of Virginia,
   1971.

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Grant, Tugent L. and W. Grant Ireson.  Principles of Engineering Economy,
   5th edition. New York:  Ronald Press, 1970.

Grant, Joseph M. "How Local Communities Can Meet the Financial Obligations
   to Accomplish the National Environmental Goal",  Engineering Issues-
   Journal of Professional Activities, ASCE, vol. 99, no.2,April 1973.

Hickman, Paul T.  The Introduction of an Industrial Haste Surcharge
   Program, Presented to the Missouri Water Pollution Control Association,
   March 2, 1964.

Mines, William N.  Public Regulation of Water Quality in the United States,
   National Water Commission Legal Study No. 18, December, 1971.

U.S. Advisory Commission on Intergovernmental Relations, State and Local
   Finances. (1971).

U.S. Environmental Protection Agency.  Alternative Financing Methods for
   Clean Water.  Office of Water Programs, Washington, D. C. 1971.

U.S. Environmental Protection Agency.  Problems and Approaches to Areawide
   Water Quality Management, vol. I-IV.  School of Public and Environmental
   Affairs, Indiana University, Washington, D. C., 1973.

CHAPTER 12

Bishop, Bruce.   Public Participation In Water Resources  Planning.   U.S.
   Army Engineer Institute for Water Resources, Alexandria, Virginia,  1970,

U.S. Environmental Protection Agency, Public Involvement for Water  Quality
   Management Planning: 303(e[ Basin Planning, Appendix.   Linton, Mi elds,
   and Coston,  Inc., Washington, 'O.C.  1973

Warner, Katherine P- Public Participation In Water Resources Planning.
   National Technical  Information Service,  Springfield,  Virginia,  1971.

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