&EPA United States Environmental Protection Agency Office of Water and Waste Management Washington DC 20460 July 30, 1979 Water Grants and Loans for Municipal Water Supply and Wastewater Treatment Systems: Water Conservation Provisions Final Report of Task Force 11 U.S. Department of Agriculture U.S. Environmental Protection Agency U.S. Department of Commerce U.S. Department of Housing and Urban Development ------- GRANTS AND LOANS FOR MUNICIPAL WATER SUPPLY AND WATEWATER TREATMENT SYSTEMS: WATER CONSERVATION PROVISIONS FINAL REPORT OF TASK FORCE 11 U.S. DEPARTMENT OF AGRICULTURE U.S. DEPARTMENT OF COMMERCE U.S. ENVIRONMENTAL PROTECTION AGENCY U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ------- EXECUTIVE SUMMARY The Directive On ^uly 12, 1978, the President Issued a memorandum to the Administrator of the Environmental Protection Agency (EPA), and the Secretaries of the Departments of Agriculture (DOA), Commerce (DOC), and Housing and Urban Development (HUD), directing them to: review those programs of your agency that provide loans and grants for municipal water supply and wastewater treatment systems, and modify those programs to remove any disincentives to water con- servation and to require appropriate community water conservation programs as a condition of such loans and grants. These water conservation modifi- cations are to apply to all loans and grants awarded after September 30, 1979. This Directive is part of the implementation phase of the President's V'ater Policy Message to Congress, Issued on June 6, 1978. That message provided for a new national emphasis on water conservation on the part of agencies.and Departments within the Executive Branch of -the Federal government. The President assigned the task of seeing that these policy initiatives were fully and promptly implemented to the Secretary of the Interior. In turn, the Secretary established nineteen separate task forces to assist..him in overseeing implementation of the water policy directives. Six of these task forces are considering various aspects of the water policy message that relate to water conservation. The President's Directive for Task Force number 11 charged the Administrator of the Environmental Protection Agency with the responsibility of coordinating the review of appropriate programs of EPA, HUD, Commerce and Agriculture, and reporting to the Secretary of the Interior on the results of program modifications which would encourage water conservation in grant and lean programs for water supply and wastewater treatment. 1 ------- Affected Programs The-Task Force reviewed the programs of each of Its agencies to determine which programs were affected by the President's Directive. Some of the major affected programs are: Department/Agency Agriculture Name of -Affected Programs Farmers Home Administration Commerce Economic Development Administration National Oceanic and Atmospheric Administration Water and Waste Disposal Systems for Rural Communities Public Works and Development Facilities State Coastal Management and Energy Impact Programs Housing and Urban Development Environmental Protection Agency Construction Grants for Wastewater and Treatment Works Water Quality Management Program Water Pollution Control Regulation Research and Development Program Community Development Block Grants Small Cities Program Urban Development Action Grants Comprehensive Planning Assistance Program Some of the programs listed are not municipal water supply and wastewater treatment system grant and loan programs. Some of the Task Force agencies included such programs because they have a substantial effect on grant and loan programs. 11 ------- Interim Report On November 27, 1978 the Task Force Issued an interim report containing a description of each affected program, existing water conservation provisions, potential options, and other pertinent information. Copies of the report were distributed and discussed at several national and regional water poltcy implementation meetings. Reviewers were asked to identify additional options and provide comments on the feasibility of the options presented. Existing Water Conservation Measures Some of the Task Force Agency programs already include provisions which encourage water conservation: e Farmers Home Administration: Highest priority for funding shall be given to an existing community water supply system requiring immediate action as a result of unanticipated diminution or deterioration of its water supply. Distribution system leakage shall not exceed FmHA criteria. Combined sanitary and storm sewers will not generally be financed. 0 Department of Commerce 0 Economic Development Administration: Metered water systems are required. c National Oceanic and Atmospheric Administration: Neither the Energy Impact nor the Coastal Zone Management Programs contain incentives or disincentives for water conservation. 8 Environmental Protection^Agency; Flow reduction analyses are required as part of facility planning. Innovative and alternative systems, including those resulting 1n wastewater reuse and recycling, must be evaluated and when selected will receive 85% instead of the normal 75% Federal funding. States may give a higher priority to innovative or alternative projects and must set aside 2% (3% in fiscalJ981) of the state allocation of construction grants funds for such projects. 111 ------- Best Management practices for control of non-point source water pollution often result tn water conservation. Public Participation Throughout the development of the reports the Task Force conducted open Interagency meetings. The Department of the Interior conducted a number of national and regional conferences on the Task Force efforts. EPA conducted a National Water Conservation Conference 1n November 1978. The final report contains copies of all letters and oral comments and detailed responses to each. Public comment on any option 1s stm encouraged and may be made to the Department of the Interior or directly to the appropriate Task Force agency. Task Force Assumptions The Task Force utilized a slightly modified version of the Department of the Interior's definition of wa^er conservation: Actions to implement the President's policy on water conservation should consist of proposed changes that will (a) reduce the demand for water; (b) improve efficiency in use and reduce losses and wastes; and (c) Improve land and waste management practices to conserve water The Task Force judged the benefits of water conservation to be proven and the need for water conservation to be documented. The Task Force relied extensively on the December 6, 1977 report of the Interagency Water Conservation Task Force and the Water Resources Council's "Second National Assessment of the Nation's Water Resources" for these Judgements. i The Task Force found that cost savings and energy considerations generally I argued for not limiting water conservation measures to water short areas. 1v ------- Major Issues The Task Force encountered a number of Issues in developing water conservation options. The most serious of these was statutory authority. In no case was water conservation a primary or even a secondary statutory goal. On the other hand, water conservation was not specifically precluded by statutory language. In almost all cases the statutes were silent on the issue of water conservation. The Task Force agencies took varying positions on the implication of statutory silence. The Department of Housing and Urban Development took the position that since their statutes were silent on water conservation, it could not impose any conditions on its programs. It would allow grant and loan funds to be used for water conservation measures to the extent local agencies determined it to be appropriate. The Economic Development Administration took the position that it would require or encourage water conservation measures when doing so was consisttnt with and supportive of its primary statutory goal of encouraging economic development in depressed areas. The Environmental Protection Agency took the position that its statutory goals were water quality and public health protection. Where construction grant assistance is involved, the evaluation of flow reduction measures to reduce needed reserve capacity is specifically provided for by the Clean Water Act. Additional legislation would be necessary for it to implement measures unrelated to these goals. The Farmers Home Administration took the position that water conservation was consistent with its statutory goals and that it would implement all reasonable water conservation measures. Potential levels of Federal Involvement in implementing water conservation measures included Federal funding. Federal requirements , Federal encouragement, ------- and Federal assistance. Recognizing the validity and significance of geographical, historical, and water resource differences, the need for State and local flexibility, public and congressional concerns over red tape and program complexity, Agency resources available to implement options, the Task Force agencies generally selected options Involving encouragement and assistance. These decisions also reflected a desire to move incrementally; that is, to encourage and financially support water conservation for a time, and then evaluate its effectiveness before considering the Imposition of water conservation requirements. The options selected are expected to result in significant water conservation. However, the level actually realized is dependent on a number of factors outside the control of the Task Force agencies. These factors include the level of Federal appropriations, the responsiveness of State and local governments to Federal encouragement, revision of HUD minimum property standards, revision of national plumbing codes, inability of wastewater source substitution projects to compete with Federally subsidized water prices, public education, redefinition of water short areas to include those not maintaining minimum Instream flows or groundwater levels, consideration of water conservation 1n lieu of Federal rescue projects, revision of water law to address use-or-lose requirements, coordination of water resources and water quality programs, and Increased eligibility of water conservation devices, including water meters. Final Report Each Task Force agency was requested to review available options in terms of benefits, costs and data needs and report to the Task Force on which options it would commit to Implement. The decisions of the Task Force agencies on each option are briefly summarized on the following pages: vi ------- Department of Agriculture - Farmers Jtome Administration Water and Waste Disposal Systems for Rural Communities Option 1. Water. Meters; Water Meters can provide an Incentive to conserve water by making the user more aware of the relationship between cost and" usage level. Water meters could be required and made eligible for assistance 1n all projects. Implementation FmHA regulations have been modified to require water meters and to make the costs of necessary meters eligible. Exemptions possible. 2. Leakage; It may be cheaper to repair leaky water supply distri- bution systems than to expand system capacity. FmHA could give leakage evaluation Increased emphasis and fund repairs when cost-effective. FmHA will modify regulations to give Increased emphasis to leakage analysis and will fund repairs when cost-effective. 3. Rate Structures: Water conservation and equity would be served by Improved water & sewer rate structures. FmHA could require that rate structures be equitable. FmHA will modify Its regulations to require water and sewer system rate structures to be equitable. 4. Public Education: Water and sewer system authorities could inform users FmHA will modify its regulations to require communities receiving assistance vii ------- of water conservation measures and benefits. FmHA could require systems to develop and Implement water conser- vation public education programs. to develop water conservation public education programs. 5. Facility Design: Design engineers could Incorporate water conserving features more fully Into FmHA funded water and sewer facilities. FmHA will require water conservation measures to be Incorporated Into the design and operation of proposed water and sewer facilities whenever econo- mically feasible. ------- Implementation EDA will include water conservation measures 1n Its agenda of matters to be discussed with applicants at pre- applicatlon conferences. Department of Commerce - Economic Development Administration Public Works and Development Facilities Option 1. Design Criteria: EDA could: 8 require that a detailed 11st of water conservation criteria be Incorporated Into project design; or, 0 Inform applicants of water con- servation criteria that could be Incorporated Into project design; or, 0 prepare and distribute a technical guidance manual which details water conserving project design criteria; or, 0 revise regulations to specify design criteria, flow reduction measures, and maximum allowable Infiltration/ inflow rates for sewers and leakage rates for water supply distribution systems. 2. Water Conservation Plans; EDA could: 0 require water conservation plans to be EDA will require applicants to prepare prepared by all applicants; or, water conservation plans in water 0 require water conservation plans to be short areas. prepared by all applicants in water- short areas; or, 1x ------- allow regional office discretion 1n determining where water conservation plans are required; or, require applicants to consider developing water conservation plans. 3. Assistance: Communities desiring to prepare a water conservation plan would benefit from technical assistance 1n the form of a Water Conservation Handbook. The Handbook could provide Information on plan components, options, available devices, model ordinances, rate structures, public Information and education programs. EDA could prepare this handbook Independently or jointly with other Federal grant & loan agencies. EDA will prepare a handbook, preferably cooperatively with other Federal grant & loan agencies, providing general and technical guidance on water conservation practices and covering all of the Federal assistance programs providing financial assistance for the construction of water supply and wastewater treatment systems. 4. Dev1oeJ:Hg1bnity; Water conservation plan elements providing for Installa- tion of water conserving devices would receive greater Implementation 1f the devices were eligible for Federal financial assistance. EDA will require metering as a part of all water and sewer projects and will allow metering facilities as an eligible project cost. EDA cannot legally fund water conservation devices 1n residences as eligible costs in general water projects. However, when ------- EDA funds the construction of a building, such devices may be Included as an eligible project cost. ------- Department of Commerce - National Oceanic and Atmospheric Administration Coastal Energy Impact Program Option Implementation 1. Grant and Loan Criterion: NOAA could include water conservation as a criterion in providing loans and grants for municipal water supply and wastewater facilities. NOAA has determined that this option would not result in any significant conservation of water. It will not be Implemented. State Coastal Management Programs Option 1. Planning; NOAA could issue policy or guidance to participating states indicating additional State responsi- NOAA has determined that this option would not result in any significant conservation of water. It will not bilities to: identify water-short areas, be Implemented. conditions development permits, review policies and activities for consistency with water conservation needs in identified areas. xii ------- Environmental Protection Agency Construction Grant Program Option 1. Reelamation/Reuse Study Area: EPA could encourage applicants to extend wastewater reclamation and reuse study areas beyond facility service areas. Implementation EPA will revise facility planning guidance to Incorporate this option. 2. Grantee Authority: EPA could require States to develop priority lists such that construction grants would only be offered to agencies with the authority to Implement or assure Implementation of all aspects of projects, Including flow reduction measures. EPA determined that this option could best be addressed through the Section 208 and 106 water quality management program. Accordingly, 1t will not be Implemented through the construction grant program. 3. Flow Reduction Analyses: The thorough- ness and rigor of applicant flow reduction analyses could be Improved if EPA prepared a Flow Reduction Handbook. EPA has budgeted funds so that Handbook should be available for distribution by October 1980. 4. Rate Structures: EPA could encourage applicants to adopt water conserving rate structures by preparing guidance on all aspects of alternative rate EPA will provide guidance on water conserving rate structures in its Flow Reduction Handbook which is to be issued by October 1980. xiii ------- structures 1n the Flow Reduction Hand- book and by encouraging applicants to evaluate surcharges and other Innovative pricing policies In the development of their facility plans. are adequate so that this option will not be Implemented. 5. Inflow/Infiltration Analyses; In order EPA has determined that Its existing to reduce the Infiltration of saline regulations and guidance 1n this area ground water Into sewer systems, which may Impede wastewater reclamation and reuse, and to reduce the level of inflow into sewer system, which may negate the economic benefits of flow reduction measures, EPA could require or encourage more rigorous sewer subsystem infiltration and Inflow analyses. 6. Sewer Ordinance Criteria: In order to reduce the Infiltration of saline ground water into sewer systems which may Impede wastewater reclamation and reuse, EPA could Issue regulations specifying minimum construction, testing and materials criteria for new sewer construction in high ground water areas. EPA has determined that Its existing guidance on new sewer construction is adequate and sufficient. This option will not be implemented. xiv ------- 7. Training: Public acceptance of waste- EPA will Issue guidance implementing water reclamation and reuse 1s dependent this option by October 1980. to a degree on well operated, Incident free systems. EPA could encourage states to utilize a portion of their S109(b) grant funds to conduct a reclamation and reuse training program. 8. Public Information and Education Program; EPA will develop an expanded program EPA could expand its 5214 public 1nfor- -by October 1980. Program elements mation and education program on the will be implemented as funds and land treatment, recycling and reuse of resources permit. wastewater and flow reduction measures. ------- all assigned tasks of an approval plan 1n Environmental Protection Agency State and Areawide Water Quality Management Grants Option Implementation 1. Management Agency Authority: Upon EPA published revised final water f approval of a water quality management quality management regulations on plan, only management agencies deslgnat- May 23, 1979 that require that agencies ed by the plan may receive construction have sufficient authority to Implement grants. EPA could revise Its water quality management regulations to order to be designated."" require' that designated management agen- cies have sufficient authority to imple- ment or assure implementation of all tasks assigned them by the plan. These tasks could include any flow reduction measures associated with a construction grant project. 2. Priority Systems; EPA could revise its regulations and guidance to water quality management agencies encouraging them to make recommendations to the States on priority systems and lists in such areas as study area boundaries, capacity expansion projects that could be accomplished by flow reduction, and projects where flow reduction and reclamation and reuse are particularly relevant. EPA issued revised final regulations on May 23, 1979 implementing this option* xv1 ------- 3. Planning: Guidance could be Issued to water quality management planning agencies encouraging them to determine the boundaries of water short areas and 4 the relationship between water quantity and water quality in such areas, including a water quality-quantity budget where necessary. 4. Water Conservation Plan: Water quality management regulations and guidance could be revised to encourage agencies to prepare a water conservation plan whenever water quality is adversely affected by an inadequate quantity of water. EPA issued revised regulations implement- ing this option on May 23, 1979? 5. Funding of Agricultural BMP's: The Clean Water Act authorized funds to assist farmers in implementing approved best management practices. EPA could aggressively assist the Department of Agriculture in the selection of best management practices for fundina. EPA is implementing this option. xvii ------- 6. Permit Conditions: EPA could revise its water quality management regulations to encourage agencies to develop flow reduction measures for inclusion in discharge permits. EPA issued revised final regulations implementing this option on Hay 23, 1979. 7. Planning Consistency: EPA could revise EPA issued revised final regulations its water quality management regulations implementing this option on May 23, 1979. to require facility plans to be consist- ent with adopted and approved water quality management plans. Consistency could include flow reduction measures and per capita flows. *In August 1979, EPA decided to focus the limited resources of the Water Quality Management (208) program on the control of non-point source . pollution. Accordingly, implementation guidance initially contemplated for municipal, point sources pollution problems, will not be issued. xvm ------- Environmental Protection Agency State Pollution Control Program Grants Option 1. Water Conservation Eligibility: EPA program grant regulations and guidance could be revised to state that the Implementation of water conservation measures 1s an eligible cost when provided for 1n the State-EPA agreement. Implementation EPA Issued revised final regulations Implementing this option on May 23, 1979. If sufficient questions arise on these regulations, EPA will Issue additional guidance. 2. Coordination: EPA could require or encourage water quality and water resources agencies to coordinate In such areas as the quantity and quality aspects of water resource plans; water rights and allocation decisions; water conservation plans; and decisions affecting minimum Instream flows and ground-water elevations, reclamation and reuse. EPA could address this Issue and develop recommendations through the Section 102(d) Water Allocation-Water Quality Coordination Study which 1s to be submitted to the Congress. EPA has determined that 1t cannot require such coordination; however, the 1980 State-EPA agreement guidance encourages coordination of environmental programs. Additional guidance encouraging coordination will be issued to State water quality agencies by October 1979. Water resources-water quality agency coordinatic: will be thoroughly discussed and recommend atlons presented in the EPA Section 102fd) study to be published in the fall of 19§0. xix ------- 3. Water Quantity Criteria; EPA could Issue regulations or guidance requiring or encouraging States to adopt quantity criteria, such as minimum stream flows, * ground water elevations or surrogates, as part of water quality standards. EPA will encourage States to adopt water quantity criteria as part of water quality standards. EPA 1s presently reviewing Its water quality standards regulations and will determine whether to go beyond encouragement as part of this review. No date for completion of this review 1s available. 4. Water Quality Report: EPA could revise Its regulations or guidance to expand the scope of the water quality report prepared biennially by each State to Include ground-water quality problems and both surface and ground-water quality problems caused by an Inadequate quantity of water. EPA Issued guidance on March 8, 1979 encouraging States to expand the report scope. xx ------- Environments:! Protection Agency Water Allocation-Water Quality Coordination Study Option Implementation 1. Report to Congress; The EPA Section EPA will address these Issues 1n the 102(d) Water Allocation-Water Quality study, which will be submitted to the Coordination Study could address the Congress In the fall of 1980. relationship of water conservation to the water quality-water quantity Issue. In particular, Instream flow and ground water criteria and management, consumptive waste treatment technology, agricultural water use, and water law could be evaluated. Lead EPA Water Conservation Office \ 2. Implementation Oversight: EPA could EPA has designated the Water Planning establish a lead office for EPA's water Division, Office of Water Program conservation activities to Insure timely Operationsas lead EPA water conservation Implementation of the water conservation office (Mr. Peter Wise, 202 755-6965). measures contained 1n this report, and to provide a contact point for the public. xx 1 ------- Environmental Protection Agency Clean Lakes Program Option 1. Grant Conditions: EPA could condition EPA has determined that this option Its Clean Lakes grants on the develop- would yield minimal water conservation ment and Implementation of community and will therefore not Implement It. water conservation programs. xxii ------- Environmental Protection Agency Water Pollution Control Regulations Option 1. Background NPDES Permit Program Implementation 2. Economic Incentive: Waste collection, Revised final NPDES permit regulations conveyance, treatment and disposal costs were Issued on June 7, 1979. are generally related to the volume of water in which the wastes are dissolved or suspended. The NPDES permit program provides permittees with an economic Incentive to conserve water. 3. Protection: The protection of surface and groundwater supplies from contami- nation by Improper waste disposal 1s a means of water conservation*. The provision of program grants to approved states to Implement the NPDES permit program encourages such water conserva- tion. Revised final NPDES permit regulations were Issued on June 7, 1979. The Issuance of program grants to States to Implement State permit programs continues. 4. Permit Conditions: NPDES regulations could provide for the Inclusion of those water quality management and facility plan flow reduction measures In Section 402 NPDES permits that would result 1n water quality benefits. Revised final NPDES permit regulations contain such provisions. XX111 ------- 5. Best Management Practices: NPDES regula- Revised final NPDES permit regulations tlons could provide for the tncorpora- contain such provisions. tlon of requirements for Best Management Practices (treatment requirements, opera- tion and schedule of activities ancillary to Industrial manufacturing or treatment processes which may result 1n the runoff, spillage, leakaqa or drainage of a toxic or hazardous pollutant. 6. Effluent Guidelines: Section 301(b)(2)(A) Already Implemented. of the Clean Water Act states that effluent limitations shall require best available technology economi- cally achievable for non-publlcly owned treatment works. Secftion 304 (b)(2)(B) requires EPA to specify factors to be taken into account 1n determining the best measures and practices necessary to the achieve- ment of such limitations. EPA could specify water conservation as one of the factors. xxiv ------- 7. Standards of Performance: In developing Already Implemented. National Standards of Performance for new sources of pollution, EPA could consider reducing or eliminating the quantity of effluent discharged. 8. Pollutant Expression: EPA could express, Already Implemented. Guidance for where possible, NPDES permit limitations developing new or revised effluent 1n terms of pollutant mass and concen- guidelines will be Issued by October 1979. tratlon Instead of only concentration. 9. Conditioning Compliance Schedule: EPA Revised final NPDES permit regulations could revise NPDES permit regulations to contain such provisions. provide for the conditioning of certain Section 301(1) Industrial permit compliance schedule extensions on Implementation of flow reduction measures. xxv ------- Environmental Protection Agency Water Pollution Control Regulations - Section 404 Dredge and Ftll Permits Option Implementation 1. Permit Conditions; EPA could issue This option will not be implemented guidance or regulations to insure that because such regulations and guidance water conservation is taken into account are beyond the statutory intent. Other in any State or Corps of Engineers Section 404 permit or State Section 208(b)(4)(B) regulatory program governing projects proposing to construct instream facilities to divert or otherwise modify stream flow. Permits could be conditioned on an evaluation of water conserva- tion measures in project planning and implementation of cost-effective measures. means, including the National Environmental Policy Act, are available to address these issues. xxvi ------- Environmental Protection Agency Safe Dr-fnklng Water Act Option 1. Background Implementation 2. Distribution System Leakage; EPA could EPA will Issue guidance encouraging Issue guidance or regulations providing States and EPA Regions to Identify for State review of distribution system significant leakage problems In leakage as part of sanitary surveys. sanitary surveys. The guidance will also Identify funding sources for correction. The guidance'wHl be issued by October 1979. 3. Economic Incentive: EPA underground Injection control regulations will Increase waste disposal costs and thereby provide an economic Incentive for water conservation. EPA will Issue final underground Injection control program regulations 1n January 1980. EPA Is presently issuing grants to States to develop and Implement State programs. 4. Protection; EPA underground Injection EPA will Issue final regulations in control program regulations will protect January 1980. EPA 1s presently issuing and thereby conserve ground water grants to States to develop and supplies. Implement State programs. ------- 5. Report to Congress: EPA Is preparing a Water Supply-Wastewater Coordination Study for submission' to the Congress. Thls^study could examine whether water supply shortages win occur, coordi- nated water supply-wastewater planning as a means of extending supplies, and, the availability and Implementation of water conservation measures. EPA will submit this report to Congress 1n December 1980 addressing these Issues xxvlli ------- Environmental Protection Agency Research and Development Program Option Implementation 1. Water Conservation: Section 104(o) of Due to budgetary constraints, no the Clean Water Act provides for water additional funds for water conservation conservation research and Issuance of an research can be committed at this time. annual report to Congress. EPA could Report to Congress will be Issued in the commit additional funds to water conser- fall of 1979. vatlon research and issue report to Congress. 2. Reclamation and Reuse: Section 105(d) of the Clean Water Act provides for wastewater reclamation and recycling research. EPA could commit additional funds for research and demonstration projects. Non-potable research funding is presently about $140,000/year. Primary EPA emphasis in this area 1s potable reuse. Due to budgetary con- straints, no additional funds can be committed at this time. 3. Agriculture; Section 105(e) of the Clean Water Act provides for research and demonstration projects to prevent, reduce and eliminate agricultural pollution. EPA could commit additional funds to research and demonstration projects for agricultural best management practices. Due to budgetary constraints no additional funds can be committed at this tlm.e xxlx ------- 4. Thermal Pollution; Section 104(f) of The most significant of the research the Clean Water Act provides for needs will be met. research and demonstration projects to evaluate methods, and their effects, for the control of thermal discharges. The effective utilization and conservation of fresh water is to be considered. EPA could commit additional funds for this research. xxx ------- Department of Housing and Urban Development Community Development Block Grant Program Urban Development Action Grants Small Cities Discretionary Grant Program Option 1. Eligibility; HUD regulations could be revised to specifically provide for the eligibility of water conservation activities. Implementation HUD will Implement this option, 2. Water Conservation Plans: HUD could request certification or assurance that water conservation plans would be adopted In those Instances 1n which HUD provides funding for water supply, water treatment or water collection i systems. HUD policy 1s to avoid the imposition of added certification or assurance not specifically mandated by law. Accordingly, this option will not be implemented. 3. Minimum Property Standards; HUD's Minimum Property Standards do not currently include water conservation standards for devices, applicances, plumbing, and fixtures. Where substantial rehabilitation and new construction is undertaken with block grant funds, HUD could implement Minimum Property Standard changes and recommendations of the Housing Task Force on Water Conservation. xxx 1 HUD will implement this option. ------- 4. Consistent Requirements; HUD Block Grant HUD will implement this option. funds are often used to supplement funding from other task force agencies. If the requirements of the agencies differ on water conservation, implementation will be impeded. Where HUD block grant funds are used to match funds to undertake water conservation activities principally funded by other agencies, the guidelines of those agencies will be followed to the extent they are not inconsistent with HUD statutory authority or regulations. xxx ii ------- Department of Housing and Urban Development Comprehensive Planning Assistance Program (701) Option 1. Planning^ Water and wastev/ater system planning is strongly influenced by comprehensive planning programs, such as 7Q1. HUD could encourage or require states, local or regional government to address water conservation needs in plan development. Implementation This matter is still under considera- tion. *U S GOVERNMENT PRINTING OFFICE: 1980 311-132/68 xxxiii ------- |