DRAFT GUIDELINES
FOR AREAWIDE
WASTE TREATMENT
MANAGEMENT
l.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
MAY 1974
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DRAFT
DRAFT GUIDELINES
1 1 2 4
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 Hater 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. Silvicultural Activities
6. Mining Activities
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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 Si tuition
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
VI
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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 locafly 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. _Iderrtj_fy__ 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. I d e n t i f y __cons_ tra 1 n t s. Both technical and management constraints
would be identified.
C. Identify possible solutions to problems. All reasonable regulatory
and management control methods would be identified.
D. Deyejog_alj_e^najtjj^^l_ans_. 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, arid 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.
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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 cosfs 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.
1-4
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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 3Q3(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
2-2
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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 Haste 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.
2-3
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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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AREAWIDE HASTE MANAGEMENT PLANNING - PLANNING PROCESS FLOW CHART
3.3 TECHNICAL PLANNING
A-B. see text
C. Inputs
OUTLINE NUMBERS CORRESPOND TO TEXT
D. 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 Employment, 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-Hans 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
Manager.ient 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 fleeting Standards
If WLA's Cannot be Predicted
to Result in Meeting Standards,
Choose another Set of WLA's
1
Development of AJternative
Management Plans
1. Review and Assess 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
I __
C. Compare Alternative Plans and
Select Final Plan
1. Effects of Alternative Plans
2. Vary Alternatives if
Necessary for Final Plan
Selection
D. 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 on 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 Water Management Information
Much of the information necessary for developing an effective
208 plan is available from related water management programs and
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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 runoffs critical
conditions will be rainfall related, but may occur under
a variety of flow conditions.
(1) Dry Weather 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 or 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 c.~ 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 Chapters ).
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 £2^^l£LL9IL?J-i!li£]-fi.yj]g.rJ.^. s'.rcd Laud Use Over the
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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 Waste 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 5).
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
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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 poiht 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. Hater 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 rnea? res 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.
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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 general, 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 Waste 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
The number of options of control under each subplan is
numerous. Thus3 the number of possible subplans may be so
great as to imoede 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 A1_1_ocatjons_
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(c7T2T~a"nd related provi\sj_ons__o_f_the_Ac_t. 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 structure.The
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 plans 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-
ti ves.
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 process 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
il01(b)s 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
1. 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 locations 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
. Shore!ands.
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iis 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 plans 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
o 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 adjust4-
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 capabil ity. 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 qua!ity.
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
quality?
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-pians.
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CHAPTER 5
DETAILED CONSIDERATIONS FOR POINT SOURCES
5.1 I ntro d u ct 1 jm
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 njrMasteivater Fai1b_es_
A. jjrtroduc^inon
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 upon 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 Waste 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 Waste 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 iand
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
1ines.
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 variations9 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 (NH»-N), total solids
(TS), suspended solids (SS), toxics, and both total and fecal coliform
counts.
C. Estimate Future Waste 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 Reductuw
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 noripoint 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 Waste 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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Where 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 particulars the analysis
will cover those industries desiring municipal service but not so
served when facilities planning is initiated.
4. Pretreatment and Cqsjt_Recoyejry_
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 sol ids, 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 options9 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, 6enerallys 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 wasteload 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
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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. Hhere 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
m.
IV.
v.
Reliability and flexibility of each alternative and
subsystems included in each alternative
Significant environmental effects of each alternative
consistent with NEPA including a specific statement on
future developmental environmental impact.
Contribution of each alternative to other water-
related goals of the planning area.
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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 controlability. 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.
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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.
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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 Nonpcn'nt 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.
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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 or Pollutants," EPA 430/9-73-014
Additional guidance on prediction models and techniques
for nonpoint sources is 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 nonpomt 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.
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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.
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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.
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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. Hydrograohic 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. Water 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
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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
(y-i) Requisite equipment and emergency procedures
(5) Monitoring well and aquifer response
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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
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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-F3-013
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
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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
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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.
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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 i 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 i208(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, §208 (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
be 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.
B. 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. i208(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.
7. i208(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 hhere legal authority is open
to interpretation, it may also be helpful to solicit and include in the
plan submittaJ 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 waste!oad 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 takeru 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 terms 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.
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 uses stormwater runoff,
and nonpoint source controls. A survey of the literature
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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.
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Inter!ocal 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. l208(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
K §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 siasy 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
specifically covered in 35 CFR, Subpart E, of the grant regulations.
Industrial cost 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
always be segregated and accounted for separately. In instances where
industrial users must make long term binding 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
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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!oca! 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 inter!oca! 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 (mount 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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10-3 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 alternativesay a
small treatment plant were to be scrapped and the land soldtheir
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'
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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 becter 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 qua!ity
b. water quantity
c. water uses
d. flood hazards;
6. Biology:
a. rare and endangered species
b. wildlife 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
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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
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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, however5 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 informationwhich 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
12-3
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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. jnitial 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
12-4
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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 2Q8 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
'I' -
I One-Way
j Output
-y
I One-Way
2 Input
Two-Way
Interaction
Mechanisms for Sec. 208
(In
DESIGNATION
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
environmental imoact.
I
(g.) Screen subplgns to
select leading alternative
subplans
(MANAGEMENT PLANNING
a.) Definition of objective
b.) Background inventory
c.) Conduct management
t analysis
d.) Develop and screen alter-
native management
plans.
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12-6
-------
SUGGESTED PUBLIC
INVOLVEMENT
Mechanics for Section 208
Planning
One -Way
Output
Two-Way I One-Way
Input 9 Interaction
r
208 PLANNING STEPS
(a.) Evaluation and selection
of combined technical
and manpower plans
(b.) Evaluate alternative area-
wide plans:
1 . Cost effectiveness
2. Social environmental
impact.
TECHNICAL-MANAGEMENT
PLANNING
(c.) Select areawide plan
to implement:
1. Technical feasible
2. Management feasible
3. Public acceptance
(d.) Develop detail for plan
output and revise.
(e.) Outputs
If.) Report*
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-------
12.5 Program Evaluation
An important part of any public involvement program 1s 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 Agricultures
Army, and Interior. Notice of Final Agreements was published in
the Federal Register, Vol. 385 No. 225, November 23S 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 fol'iowing
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
I
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 healths 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-? 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
Signlficant 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
jM 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 SUBMIT!AL, 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.)
Mithin 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
The Act - 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 Waste 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)
-------
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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Land use - The physical mode of utilization or conservation of a given
land area at a given point in time.
Land use 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
in the Act.
sec. 101(a) and elsewhere
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
which cannot be located as to specific
Section 304(e) of the Act.
into a
spurce,
water body
as outlined
in
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 'pollutant' 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." (Acts sec. 307(b)(l)). "Not
later than July ls 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 pub!ish...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).
Haste 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
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Council of State Governments. 1971 Suggested State Legislation
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Fox, Irving K., et.al. Institutional Design for Water Quality Management:
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CHAPTER 4
Bosselman, Fred and David Callies. The Quiet Revolution in Land Use Control.
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Leopold, Luna B., et.al. A Procedure for Evaluating Environmental Impact.
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University of Delaware Water Resources Center. Water Resources As a Basis
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CHAPTER 6
American Public Works Association. Water Pollution Aspects of Urban Runoff.
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I 3 I O
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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
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Washington, D. C.
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U.S. Environmental Protection Agency. The Control of Pollution from
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U.S. Environmental Protection Agency. Urban Runoff Characteristics,
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CHAPTER 7
Bailey, James R., et.al. A Study of Flow Reduction and Treatment of Waste
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CHAPTER 8
U.S. Environmental Protection Agency. Institutional Arrangements for Water
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CHAPTER 10
Fifer, C. Lee. Effluent Charge Systems: Analyses and Legislation. Center
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Grant, Tugent L. and W. Grant Ireson. Principles of Engineering Economy,
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i
CHAPTER 12
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