LIJBIJ
January 1973
Improving
Water Quality
Management  Planning
In IMonmetropolitan Areas
Office of Air and Water Prograr
U.S. Environmental Protection Agency

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                                                EPA 68-01-0194
                                                  January 1973
                   IMPROVING
WATER QUALITY MANAGEMENT PLANNING
        IN NONMETROPOLITAN AREAS
                     Project Officer
                   Joseph Amaral, Jr.
                     Prepared for

       OFFICE OF AIR AND WATER PROGRAMS
     U.S. ENVIRONMENTAL PROTECTION AGENCY
              WASHINGTON, D.C. 20460
     For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402
               Price 95 cents domestic postpaid or 70 cents QPO Bookstore

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                     ACKNOWLEDGEMENTS
This report was written by E. Evan Brunson, with assistance
from John D. Leslie and Edwin W. Webber.  The following
individuals participated in the conceptualization of the
study and review of the information presented:
  Joseph Doherty, Ben White; Department of Agriculture, FHA
  Robert Cox, Eldon Rickey; Department of Commerce, EDA
  James Brennan, Frank Price; Planning Standards Branch, HUD
  Lee Schoenecker; Office of Management and Budget
  Joseph Amaral, Jr.; Air and Water Programs, EPA

The author expresses appreciation for information and
assistance provided by officials and staff of areawide
and State planning agencies and water pollution control
authorities in the States of Oregon, South Carolina and
Wisconsin.

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                                     CONTENTS

Section                                  Title                                    Page

I         INTRODUCTION   	1

          Background  	1
          Method of Approach   	1
          Report Organization   	1

II         EXECUTIVE SUMMARY   	3

          Introduction	3
          Nonmetropolitan Water Quality Planning Practices	3
          Institutional Trends	4
          Recommendations   	5

III        CURRENT WATER QUALITY MANAGEMENT PLANNING PRACTICES   .... 9

          Introduction	9
          Background  	9
          Federal Water Quality Programs	10
             Environmental Protection Agency   	10
             Department of Housing and Urban Development	10
             The Farmers Home Administration	10
             Economic Development Administration	11
          Federal Planning Coordination   	11
             Implementation of EPA-HUD Joint Agreement	13
             Farmers Home Administration	14
             FHA-EPA Planning Coordination	15
             Economic Development Administration	17
          State Institutional Arrangements   	18
             State Agency Roles   	19
             Differing State Roles	21
             Interim Planning   	22
          State A-95 Clearinghouses   	23
             Environmental Inputs   	24
             Constraints to the Effective Administration of "A-95"   	25

IV        NONMETROPOLITAN AREAWIDE PLANNING	27

          Introduction	27
          Evolution	27
          Comprehensive and Functional Planning   	29
             Areawide  Comprehensive Planning	29
             Areawide  Certification	30
             Related Functional Planning   	32
                                        111

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                                    CONTENTS (Cont'd)

  Section                                   Title                                     Page

  IV Cont'd  Areawide Planning Coordination	33
            Conclusions	34

  V         DISCUSSION OF FINDINGS AND CONCLUSIONS  	37

            Impediments	37
               Federal-Level Impediments   	37
               State-Level Impediments   	37
               Nonmetropolitan Area Level Impediments	38
            Institutional Trends	39
            Conclusions   	40
               Substate Districts   	41
               A Flexible Approach	41
               Improved Intergovernmental Coordination	42
               Designing a Flexible Approach	42

  VI        RECOMMENDATIONS   	45

            Recommended Actions   	46
               Plan Content  	46
               Planning Responsibility	48
               Planning Coverage	48
               State Agency Role	49
               Assessing Capabilities	50
               Assessing Water Quality Problems   	51
               Determining Planning Readiness  	51
               Coordination of Federal Programs   	53
               Strengthening the A-95 Process   	55
               Planning Grants for Nonmetropolitan Districts	55
               Recommendations for an Information Program	56

Appendix A  Framework for Assessing the Character and Extent of Water Quality
             Problems in Nonmetropolitan Areas	59
Appendix B  The A-95 Process and Water Quality Management Planning   	69
                                            IV

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                                    I. INTRODUCTION
BACKGROUND

In many, if not most, of our nation's nonmetropolitan areas, water quality has been a relatively
recent concern and planning of any type a relatively primitive process. These areas are characterized
by  many  pollution problems  common to  urban  areas-plus additional  ones associated with
agriculture and rural based industry-and a lack  of resources and institutional capabilities  to cope
with them in compliance with emerging planning requirements.

The Environmental Protection Agency contracted with the National Area Development Institute of
Spindletop Research, Inc. to examine water quality management planning in nonmetropolitan areas
and recommend improvements reflecting both national policy and  the diverse problems of these
areas. The direct objective of the study was to assist EPA in adapting its requirements more closely
to  nonmetropolitan  problems and to prescribe appropriate roles  for  other Federal and  State
agencies and substate planning and development organizations in the process.

METHOD OF APPROACH

The field survey method was  chosen as the best  way to provide maximum insights into a complex
situation. Three States -  Oregon,  Wisconsin and South Carolina - were  selected, each containing
several nonmetropolitan substate districts, and representing different intergovernmental approaches
to  water  quality management planning and a significant amount of program activity by the four
Federal agencies involved.  They  also presented sufficient commonality to provide valid general
conclusions.

EPA,  the Economic  Development  Administration, the Department  of Housing and  Urban
Development and the Farmers Home Administration formed an ad hoc interagency committee to
help guide the effort. Selected regional, State  or area offices of all four agencies  were contacted as
part of the study, as were their Washington-based  officials.

REPORT ORGANIZATION

Following this introductory section, the report contains an executive summary, sections on current
water  quality  management  planning  activities  of  Federal,  State and  regional  agencies,  the
nonmetropolitan organizational setting in which  the process occurs, a discussion of conclusions and
recommendations.

LEGISLATIVE REFERENCES

The study's field work, report preparation and publishing arrangements were completed prior to
passage of the Federal Water Pollution Control Act Amendments of 1972. Therefore, the references
to legislation and related regulations in this report refer to various sections of the Federal Water
Pollution Control Act prior to the 1972 amendments.

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                               II. EXECUTIVE SUMMARY
INTRODUCTION

This report describes the results of a study conducted by the National Area Development Institute
for the Environmental Protection Agency on ways to improve water quality management planning
for nonmetropolitan areas.

The findings and recommendations set forth in this report are based on a field survey of three
states, interviews with officials of EPA, HUD, EDA and FHA, and observations made by the project
team in connection with other NADI research and related activity in support of nonmetropolitan
area development.

The research focused on the four agencies' programs related to water quality management planning,
EPA's planning guidelines, the EPA-HUD Joint Agreement on unified planning requirements and
other attempts to devise a coordinated approach. Needs of nonmetropolitan areas to cope with both
urban-type pollution problems and nonpoint sources peculiar to the  rural setting were analyzed in
terms of the capabilities of existing and emerging institutions.

NONMETROPOLITAN WATER QUALITY PLANNING PRACTICES

Water quality  management planning,  in the dimensions of the truly intergovernmental  process
envisioned in the EPA Guidelines, is virtually nonexistent in nonmetropolitan America. Interviews
with Federal, State and substate district officials revealed the:

       •  Absence of  a  coordinated intergovernmental  approach  to  planning  among Federal
       agencies with programs related to water quality.

       •  Lack of understanding of the concept of water quality management planning, particularly
       as it relates to areawide cost effectiveness considerations.

       •  Low   level  of  financial   support  for  water  quality  management  planning  in
       nonmetropolitan areas.

       •  Difficulty  in applying the  uniform planning  requirements  of  the "EPA-HUD Joint
       Agreement" in the diverse nonmetropolitan situations.

       •  Almost total reliance of State water quality agencies on regulation and  enforcement
       rather  than on a balance in emphasis  between regulation, enforcement and  management
       planning to achieve water quality goals.

       •  Conflicts over priorities resulting from basic differences between the primary objectives
       of areawide planning agencies and those of basin-oriented State agencies.

On the other hand, the survey disclosed some  activities which suggest the elements of a workable
framework for coordinating water quality  management  planning in nonmetropolitan areas.  The
most promising instances were found where:

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       • Regional EPA representatives are working with other Federal and State officials to design
       and implement a strategy for relating areawide comprehensive and  functional planning to
       the needs of water quality management planning.

       • State A-95 Clearinghouse agencies strongly support water quality management planning
       and play an active role in the coordinative process.

       • Nonmetropolitan areawide planning agencies have developed a coordinated approach to
       areawide planning by linking comprehensive planning and functional water/sewer planning
       funded by HUD and FHA with EPA's requirements for water quality management planning.

       • EPA, HUD, FHA and EDA Regional, State and Area Office officials are attempting to
       coordinate  with one another the planning requirements and  project  grants of four Federal
       programs supporting planning and construction of water, sewer and waste disposal facilities.

INSTITUTIONAL TRENDS

In addition, it is becoming increasingly clear that:

       • Planning  and  development  activities being undertaken  by  nonmetropolitan  district
       organizations will have an important influence on water quality management, and in turn,
       will be equally influenced by water quality considerations.

       • Regional  offices  of  Federal agencies are playing  an increasingly  significant  role in
       grant-in-aid program planning and administration.

       • The States are assuming increased responsibility in  the planning and administration of
       Federal grant-in-aid  programs.

       • Substate  District Planning  Agencies,  now serving nonmetropolitan areas  of some 40
       States, are  rapidly  blanketing the nation and are being used increasingly by the States for
       planning and  administration of  Federal  and State  programs and  as  Regional  A-95
       Clearinghouses.

       • Federal reliance  on guidelines tends to place more  emphasis on  procedure rather than
       performance. When mandatory provisions are unrealistic, the whole approach is discredited.
The  survey findings in combination with observations on institutional trends form the basis for
concluding that  water quality  management planning  for  nonmetropolitan  areas can  best  be
accomplished  by designing an  overall  planning strategy to coordinate water  quality planning
activities systematically with other related areawide planning programs at the substate district level.
It was further concluded that:

       • State designated  substate district planning agencies constitute a major resource for the
       accomplishment of water quality management planning in nonmetropolitan areas.

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       • State designated water quality agencies are in the best position to provide liaison between
       substate  district planning agencies and EPA regional offices with respect to water quality
       management  planning.  They are  also  in  the  best  position to  serve  as a  statewide
       clearinghouse for water quality oriented technical assistance.

       • A-95 Clearinghouse agencies at  the State and  regional levels can play  a key role in
       coordinating  water quality  management planning with comprehensive  and other related
       planning activities within the state.

       • EPA Regional Offices are the logical focal point for coordination among HUD, FHA and
       EDA (Regional, State or Area offices), the States and their substate districts in putting into
       effect an areawide water quality management planning process in nonmetropolitan areas.

       • Timetables  for  the  completion  of areawide  water quality management planning in
       nonmetropolitan areas  would be more effective if scheduled  on the basis of a realistic
       assessment of  areawide planning agency capabilities,  accomplishments  and  anticipated
       progress.

Finally, nonmetropolitan  water quality  management planning will proceed  slowly at best until
funds are made available to support the required effort.

These conclusions, when considered in light of the goals and objectives of EPA, reveal the following
broadly stated needs which must be met if improved water quality management planning is to be
accomplished in nonmetropolitan areas:

       • Better understanding of the purposes and benefits of water quality management planning
       on the part of other Federal agencies and the States.

       • A Coordinative  approach  to  water quality management planning  throughout the full
       range of the intergovernmental decision-making process.

       • A Stronger role for  nonmetropolitan  substate district planning organizations as active
       participants with  State and Federal agencies in  the  intergovernmental  decision-making
       process.

       • More  flexible  planning   guidelines   for  water  quality  management  planning for
       nonmetropolitan areas.

       • Increased funding for water quality management planning in nonmetropolitan areas.

RECOMMENDATIONS

The  following recommendations represent  a  significant  modification of the  current approach to
guideline administration and to unifying planning requirements of four Federal agencies. It is based
on the conclusion that because of  the diverse situations which exist in nonmetropolitan areas, a
coordinative planning approach focused at  the substate district level would be more effective than
an approach  which places primary reliance on Federal  level interagency agreements  on detailed
uniform planning requirements.

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Coordinative planning on an areawide basis would place water quality considerations in the context
of systematic decision-making at the operational level. The nonmetropolitan agencies recommended
to play a key role here reflect increasingly the involvement of State governmental authority  to
which EPA looks for enforcement. The substate district entity thus represents the internal discipline
of multifunctional planning relevance and legitimate authority.

Concededly, substate regionalism is at an early stage in its evolution. Funds to support planning are
scarce. And  much time and  manpower will be  required  to undertake the  coordinative process
recommended.

The  coordinative  process   offers  the  opportunity  to  negotiate  the  conduct  of  areawide
comprehensive  and functional planning  so  that  the  fulfillment  of  one  agency's  planning
requirements meets those of others. The flexibility inherent in tailoring requirements to actual needs
should reduce expenditure of resources for irrelevant exercise and generate respect for requirements
imposed. And to  the extent that substate regionalism represents great potential for genuine program
coordination, horizontal and  vertical, EPA can both contribute to and benefit from its emergence.

In order for the concept of coordinative planning to be fully operative on behalf of water quality
management in nonmetropolitan  areas, it  is recommended that the Environmental  Protection
Agency lend all possible support and encouragement to State actions:

         1. Requiring   Nonmetropolitan  Areawide  Water  Quality  Management   Plans  for   all
           nonmetropolitan areas which are served by a State-designated substate district planning
           agency.

         2. Assigning  responsibility  for  the  development  of  Nonmetropolitan Areawide Water
           Quality Management Plans to  officially   designated substate district planning  and
           development agencies unless such action is clearly unwarranted.

To permit the varying  levels of detail necessary to reflect the diversity of problems and institutional
capabilities in nonmetropolitan areas, it is recommended that EPA-OWP:

         3. Establish flexible  planning  requirements for Nonmetropolitan Areawide Water Quality
           Management  Plans  designed to  insure  realistic  consideration  of nonmetropolitan
           areawide water quality  problems and maximum  utilization of related planning activities.

To reinforce and  otherwise  support  the  role  of  substate districts in  areawide  water quality
management planning for nonmetropolitan areas, it is recommended that EPA:

         4. Correlate the  deadlines  for  completion  of initial Nonmetropolitan Areawide Water
           Quality Management Plans  with the availability of water quality management planning
           funds  and  with implementation schedules established  in  the  water pollution control
           amendments of 1972.

         5. Include planning status and performance assessments in interim criteria for facility grant
           eligibility pending satisfactory completion of each district's Nonmetropolitan Areawide
           Water Quality Management Plan.

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        6. Prepare technical handbooks and other information on nonmetropolitan water quality
          problems for use by substate planning agencies in developing Nonmetropolitan Areawide
          Water Quality Management Plans.

        7. Establish a nontechnical information and educational program to build understanding of
          the purposes of, and the need for, cost-effective water quality planning on the part of
          local officials.

        8. Encourage maximum involvement of State A-95 Clearinghouse agencies in all aspects of
          water quality management planning.

And finally, if water quality management planning is to be accomplished in nonmetropolitan areas
quickly enough to affect expenditures in the time frame envisioned in the water pollution control
amendments of 1972, it will have to be funded on an accelerated basis.

Therefore, it is strongly recommended that:

        9. Every effort be made to stimulate and fund water quality planning grant applications
          from State-designated substate district planning agencies.

       10. Federal  and State  agencies supporting  water quality related  planning should  be
          encouraged to  increase their technical and financial support for such planning, and to
          coordinate  their  implementation  timetables  and  planning  requirements  whenever
          possible.

Actions  to  implement these  broadly stated  recommendations  for improving  water  quality
management planning in nonmetropolitan areas  are presented in detail in the last section of the
report.

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         IE. CURRENT WATER QUALITY MANAGEMENT PLANNING PRACTICES
INTRODUCTION

This chapter traces  the increasing involvement  of the Federal government in water  quality
management as reflected in four agencies' programs for facilities and planning. Response to the need
for coordination in terms of cost-effectiveness and resolution of interprogram conflicts are analyzed
in relation to the HUD-EPA agreement and the unified Guidelines for Water Quality Management
Planning. Problems in unifying planning requirements identified in the field survey are discussed and
related to the operations of agencies not covered by the interagency agreement.

State approaches to  water quality management are reviewed with emphasis  on their  varying
relationship to other environmental concerns and their regulatory focus as opposed to management
planning.  The advantages  and disadvantages of  the  different institutional roles identified are
discussed  in  relation to the balanced approach implicit in the Guidelines.  Also  included  is a
discussion of OMB Circular A-95 as to its relevance to water quality management.

BACKGROUND

Water  pollution  problems have been  of concern to the States, municipalities and the  Federal
government for some  time. Historically,  the approach to  these problems has been to  set in-stream
water quality standards for river basin  hydrologic systems and to construct facilities to treat liquid
wastes which flow into these systems to achieve established water quality standards.

Traditionally, the costs of constructing and maintaining waste water treatment systems have been
the  responsibility of  State and local  governments. However,  as  it became apparent that their
resources  were inadequate to cope with the ever-increasing costs  of water  pollution control, the
Federal government  began supporting the construction of municipal waste water collection and
treatment facilities. The Federal Water Pollution Control Act of 1964, as amended, (P.L. 84-660)
made "the prevention, control, and abatement of water  pollution" to "enhance the quality and
value of  ... water  resources"  a national goal. With creation of the Environmental  Protection
Agency in 1970, this goal  was  made the primary mission of EPA's Office of Water Programs
(EPA-OWP).

The major tool available to EPA-OWP  is its construction  grant program. Section 8 (a) of P.L. 660
authorizes grants "for the construction  of necessary treatment works to prevent the discharge of
untreated or inadequately treated sewage  or other waste into any waters and for the purpose of
reports, plans, and specifications in connection therewith."

Since the enactment  of Section 8, massive Federal financial support  has been provided  for the
construction  of  municipal waste  treatment facilities. Nevertheless, it became apparent that the
continued massive investment of Federal funds would not be sufficient to meet national goals for
clean water unless steps were taken to assure that these  construction grants were based on sound
cost-effectiveness principles.

To maximize cost-effectiveness of Federal investments, Congress required that "no grant  shall be
made for  any project .  .  . unless such project shall have been approved by the appropriate State

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  water pollution control agency .  .  . and unless such project is included in a comprehensive program
  . .  . and .  .  is  in conformity with the State  water  pollution control plan .  .  ." This provision
  resulted in the promulgation of regulations requiring that EPA construction grants be awarded only
  for those  projects included in current and effective River  Basin and  areawide water quality
  management plans.                                           ;

  FEDERAL WATER QUALITY PROGRAMS

  Presently four Federal agencies provide grants  or loans for planning and construction  of water,
  sewer  and/or waste water treatment facilities. EDA  and FHA administer grant and loan programs
  primarily serving  nonmetropoli^an  areas,  while HUD  and EPA operate grant  programs for  both
  metro and nonmetro areas.

  Environmental Protection Agency

*The programs administered by EPA's Office of Water Programs (OWP) are primarily concerned with
  encouraging the construction of adequate waste water treatment  facilities. The basic  construction
  grant program, authorized by Section 8 of P.L.  660, provides Federal funds ranging from 30 to 55
  percent of the cost of municipal waste water treatment facilities.

*OWP administers  the basic  planning grant program under Section '3c' of P.L. 660 supporting the
  development  of  comprehensive  river basin and areawide  water quality management plans. Fifty
  percent of the cost of the planning must be provided by State and local governments.

* Annual State Program grants under Section 7 of P.L.  660 are also administered by OWP. These
  grants provide basic support to State water quality agencies to assist them in prevention and control
  of water pollution.

  Department of Housing and Urban Development

  HUD  makes grants to  assist and encourage communities to construct  adequate basic  water and
  sewer  facilities to promote orderly development. This program applies primarily to urban areas of
  greater than 5,500 population. Grants cannot be made for the construction of "treatment works"
  which are  eligible for assistance from EPA. HUD grants generally  cover 50 percent of the approved
  project cost, but can, under certain circumstances, cover up to 90 percent.
                                                          i
  Planning for these programs is supported by  HUD's  '701'  Comprehensive Planning  Assistance
  Program and is tied into HUD's Areawide Certification Requirements.

  The Farmers Home Administration

  FHA administers two grant  programs which bear directly on water quality management planning in
  nonmetropolitan areas:

         • Comprehensive Areawide  Water and Sewer Planning Grants for Rural Communities; and

         • Water and Waste Disposal  Systems Grants and Loans for Rural Communities.

* In the  order mentioned above, thejegislative references are superseded by Title II and Title I, Sections
  102 and 106, under the 1972 Amendments of the Federal Water Pollution Control Act, P. L79

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Both programs have been limited to rural areas and towns up to 5,500 population.

FHA has not formally entered into an agreement with HUD and EPA on unification of planning
requirements.

Eligible applicants for FHA planning grants include any municipal government and public bodies
such as regional and local planning commissions, provided they are broadly based and representative
of rural interests, and propose a plan that is supported by local officials and public and private
agencies interested in water/sewer facilities development in the area. Until recently, grant recipients
must have had authority to prepare official comprehensive plans.

FHA planning grant  assistance is  usually for the  total cost of the project. To receive a planning
grant,  the applicant agency has been required to submit evidence of authority to prepare official
comprehensive plans, and evidence that resources are not available to finance the planning effort.

FHA facilities grants and loans can be awarded to public or quasi-public bodies and not-for-profit
corporations. Grants  and loans for waste disposal systems may be used for the installation, repair,
improvement or expansion of sewer lines, waste collection, and treatment of all wastes in rural areas
and towns up to 5,500 population. Grant assistance  is limited to one-half of the project cost. Loan
and grant assistance may  cover the total  project cost if the applicant is financially  unable  to
contribute a part  of the cost. To be eligible for grant assistance, the project must be consistent with
a comprehensive area wide water and sewer plan for the area.

Economic Development Administration

EDA  makes  basic and supplemental grants and  loans for the construction of public works and
economic development facilities in designated geographic areas with high unemployment and low
per capita incomes. The basic EDA grant is for 50 percent of the project cost, but may be increased
up to 80 or even 100 percent in severely  depressed areas  that  cannot match Federal funds.
Long-term loans may be made when reasonable financing terms are not otherwise available from
private lenders.

EDA  supplemental grants are made to increase  the  total Federal share of the project cost in
designated areas. The applicant must apply  for all available assistance from other Federal agencies
before EDA will make a supplemental grant.

Throughout  the history of the EDA program, approximately 70 percent of total public facilities
grants  have involved  water and sewer projects. EDA can support such facilities provided the project
improves opportunities for industrial or commercial  development, otherwise assists in the creation
of  additional  long-term  employment  opportunities, primarily  benefits the  unemployed  or
low-income families, or furthers the objectives of the Economic Opportunity Act of 1964.

FEDERAL PLANNING COORDINATION

This portion of the report deals with the planning requirements and the coordinative efforts of the
four Federal  agencies which fund  water quality improvement facilities. Each agency (EPA, HUD,
FHA  and EDA)  operates  under its own  Congressional  mandate  and,  until recently,  each  has
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approached the question of planning requirements in its own way. Although all four agencies have
been discussing ways to improve coordination of planning, only two-EPA and HUD-have reached
joint agreement.

The signing of this "Joint Agreement for Interagency Coordination in Planning and Development"
on  June  7, 1971, represented a  significant step in implementing planning unification. This
agreement provides for "coordinated administration of comprehensive and functional planning and
construction grant  requirements."  Grants awarded by  HUD and  EPA "must  meet  the  same
administrative and regulatory requirements with  respect to comprehensive and functional planning,
and programming of waste water collection and treatment systems."

In  January 1971 EPA  issued  "Guidelines-Water  Quality Management Planning,"  to implement
EPA's regulations 18CFR 601.32 and 33 published on July 2,  1970. The regulations state that "no
grant shall  be made  unless the project is included in an  effective  current basin-wide plan for
pollution  abatement." The regulations further provide that "a grant for a project shall not be  made
"unless .  .  . such project is included in an effective metropolitan or regional plan .  .  . and certified
by  the governor or  his designee  as being the official  pollution abatement plan .  .  . for the
metropolitan area or region . .  ."

The Guidelines call for both the basin and areawide metropolitan/regional plans to be completed
and in effect by July 1, 1973.

Finally, the Guidelines  envision the  creation of an intergovernmental management system to
accomplish  the  most  cost-effective  solution  to  local   water  quality   management.   The
intergovernmental planning process involves the development  of water quality management plans on
two distinct but related geographic scales:

        1.  Basin hydrological systems; and,

        2.  Metropolitan/Regional (M/R) planning areas.

River Basin plans define the total water discharge  allowable  from each metropolitan/regional area
and for the M/R plans to define the most cost-effective solution for achieving this permissible level.
Thus, the M/R Plan must allocate each waste discharge according to the most cost-effective regional
system, consistent with the overall strategy defined in the basin  plan.

To  support implementation of this kind of planning process at the M/R level, the Guidelines also
call for M/R planning organizations to concentrate on the institutional arrangements necessary to
implement the Metropolitan/Regional Plan and the Basin Plan. Finally, the Guidelines envision the
effective  application  of the "A-95"  Clearinghouse function at  the M/R level  in  establishing
coordinative relationships between  institutions to  assure that Federal planning and construction
grants  are  consistent with areawide comprehensive  planning  and  water  quality management
planning.

To  date, EPA and the States  have concentrated on water quality management planning for river
basins, carried out primarily by the States, and for metropolitan areawide planning. Little attention
has been given nonmetropolitan areas.
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Implementation of EPA-HUD Joint Agreement

The  tri-State survey found  that  little progress has been  made  in implementing unification of
HUD-EPA planning requirements.

The  major problem  appears to be  the relationship between HUD-required areawide functional
water/sewer facilities plans and EPA-required areawide Water Quality Management Plans.

Chapter 1, Paragraph 6, B. of the EPA Guidelines for Water Quality Management Planning States:

       "Areawide  (Metropolitan/Regional) Plans. These  areawide plans are subsets of the Water
       Quality Management  Plan for a river basin and are the functional waste water collection and
       treatment (sewerage)  plan elements of the comprehensive areawide Plan  as set  forth in the
       HUD Areawide Planning Requirements." (emphasis added)

This language appears to be clear enough. EPA Areawide Water Quality Management Plans and HUD
areawide water/sewer facilities plans are to be the same. One plan should be prepared  to meet the
requirements of both agencies.

This interpretation is supported by  the language of Paragraph 4, B. of the EPA Supplementary
Guidelines issued in September, 1971:

       "HUD certifies metropolitan/regional water quality management plans, after EPA has found
       them acceptable, as meeting the functional planning and programming criteria for water and
       sewer facilities as set forth in HUD's Circular Series MPD 6415 (July 31, 1970)."

Yet, not State or areawide planning  official interviewed during survey felt that a HUD water/sewer
functional  plan  element  and an EPA areawide Water Quality Management Plan were the same.
Similar responses, with one notable exception, were expressed by those EPA and HUD Regional and
Area office personnel interviewed,

Several factors  which were  identified in the survey help account for  problems in implementing
unification:

       1.  The type of areawide water/sewer plans approved by HUD to meet the requirements for
           functional waste  water collection and treatment  systems planning (Certification III)
           varies greatly.  Some  are  primarily a  facilities inventory. Others are approved as
           preliminary  plan elements with an action program for implementation. Some deal with
           water supply, sewers, storm drainage, and treatment systems, while others only cover
           some of  these facilities  systems.  Some approved  water/sewer  plan elements  include
           interim programs for  sub-areas  of HUD-designated Areawide  Planning Jurisdictions
           (APJs).  Others include action programs for the  entire APJ. This diversity makes it even
           more difficult, to unify  HUD and EPA requirements.

       2.  There is  no  consistency in the  geographic  coverage  of HUD and  EPA plans. EPA's
           interim procedures allow for designation of sub-APJs for the purpose of awarding EPA
           construction grants. Under this procedure, interim  water quality management plans are
           often prepared for a municipality and its environs to meet EPA's planning requirements.
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          However, HUD generally requires areawide water/sewer functional plans for larger APJs.
          Often the larger API is the entire area served by the Areawide Planning Organization.

       3.  For communities to remain eligible for HUD facilities grants, a HUD-approved areawide
          water/sewer plan element was required as of July 1, 1972. Although the HUD deadline
          has since been moved back, "fully developed" plans to  meet EPA's requirements are not
          required until  July  1,  1973. In the  meantime, EPA is operating under "modified"
          interim procedures. Thus, in order to  meet the earlier  HUD deadline, the survey found
          that HUD offices were  approving  water/sewer plan elements  with little consideration
          given to EPA's water quality planning requirements.

These factors all contribute to the  confusion concerning the required content of the two agencies'
plans and the standards employed to evaluate them. Most of the HUD and EPA Regional and Area
Office  officials interviewed feel that both the  planning procedures and objectives of the two plans
are significantly  different. They point out that HUD water/sewer plans are service-oriented, while
EPA plans are concerned with the technical performance of the sewerage facility. Priorities for HUD
facilities grants are based on areawide or local considerations set forth in the areawide water/sewer
plan element. Priorities for award of EPA construction grants are  determined  on the basis of basin
and interbasin considerations. In addition,  the Guidelines for Water Quality Management Plans call
for planning standards and procedures which are  more rigorous and technically oriented than those
required by HUD for areawide water/sewer planning.

The survey found only one area where a real effort was being made to satisfy both HUD and EPA
requirements through one planning process based on one set of  planning procedures-the  unified
Guidelines. This effort was funded  by an EPA '3c' grant to an areawide planning agency which had
not  undertaken  a  HUD-supported water/sewer planning element.  However, HUD officials were
ambiguous  when asked if such an  approach would meet HUD's  functional water/sewer planning
requirements.

In another area, the areawide planning agency was applying for a '3c' grant from EPA to expand its
on-going HUD water/sewer planning to meet  EPA's areawide water quality management planning
requirements.  However, there was no  evidence  that this approach has been frequently used in
nonmetropolitan areas.
Farmers Home Administration

The survey found that FHA's approach to comprehensive rural water/sewer planning is undergoing
substantial change to meet the need for coordinated areawide water/sewer/water quality planning
and programs. In the past, FHA has usually funded single-county comprehensive water/sewer plans
in rural areas.  FHA contends that the failure of many States to adopt legislation establishing
substate planning agencies often prevented funding of areawide or multicounty water/sewer plans
due to the statutory mandate that FHA planning  grants must be awarded to organizations with
authority  to prepare official plans. According to FHA officials, it has always been their policy to
fund areawide planning agencies whenever the agency has the legal basis to prepare official plans.
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Single County Plans. The survey found that FHA plans, prepared and completed on a single-county
basis, are often criticized by Federal, State and local planning officials as being deficient in several
respects. Typical of the comments obtained:

       • They were usually prepared by consultants with little local input in the form of citizen
       participation or guidance from local officials;

       • They often represented no more than a "needs" study, but with a system designed for
       every small town regardless of the actual need;

       « The goal of these FHA plans was often merely to justify FHA facilities grants and loans;

       • They often failed to establish priorities for implementation;

       • They often were not coordinated with HUD and EPA planning for the same areas; and

       • The bulk of the planning  effort  was usually devoted to the "comprehensive" component
       dealing with general background information about the area, with  less emphasis placed on
       the design of physical systems.

Areawide Planning. The survey found that FHA's areawide approach to rural water/sewer planning
is resulting in better coordination with other Federal and State programs  related to water quality
management. In all three States, FHA State Office officials are taking the initiative in coordinating
both FHA planning and facilities  grants and loans with EPA, HUD and EDA water/sewer programs.

In some States, areawide  planning  agencies are being funded simultaneously with HUD and FHA
grants. In these instances, nonmetropolitan planning agencies can integrate water/sewer planning for
the entire  area  using HUD funds for urban areas not  eligible to be included in FHA plans. In
addition, the "comprehensive" planning data  required by HUD can  be used to meet FHA planning
requirements and vice-versa. Finally, one set of plans, covering land-use, population and economic
studies, and areawide rural-urban water/sewer facilities, can be developed to meet both FHA and
HUD requirements.                                              ,

However, this approach to HUD-FHA coordination has not been widely utilized to date. In many
areas, the problems of integrating on-going HUD  areawide water/sewer planning with completed
FHA single-county water/sewer plans for rural areas and smaller towns is proving  to be a difficult
task.
     f
FHA-EPA Planning Coordination

In all  three  States  surveyed,  FHA was  attempting to  build into  its  planning  contracts with
nonmetropolitan areawide planning agencies  some of EPA's  areawide water  quality management
planning requirements. Most  commonly, the  elements include a  preliminary land-use sketch plan,
location of waste discharges,  applicable water  quality standards,  identification  of where  these
standards are not being met, an evaluation of the adequacy of existing treatment facilities to meet
long-term  water quality standards and water  uses, opportunities  for regionalizing  municipal waste
treatment facilities, future treatment  facilities needs and the anticipated impact on water quality
standards, and an assessment of the plan's impact on the environment.
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Some FHA planning contracts  also require the development of a general abatement program for
water pollution control in the  planning area,  and a detailed abatement program for waste water
disposal for each community in the area under 5,500 population.

On July 17,  1972, FHA informed its State Directors that all FHA funded water and sewer plans
must be reviewed  by the appropriate State water pollution control authority to determine if the
proposed plan is consistent with applicable water quality standards. The survey found that such
reviews had previously been required by  some FHA State Offices to assist areawide planning
agencies with EPA  water quality planning requirements.

While this procedure may  be of some benefit to areawide planning staffs in terms of advice and
technical assistance concerning EPA requirements, it does  not assure coordination between FHA
areawide water/sewer planning and on-going river basin planning conducted at  the State level. In the
past, most FHA contracts left the local planning agency with the burden of assuring that adequate
coordination is accomplished. The survey found that this approach did not result in adequate river
basin - FHA planning coordination. New FHA directives issued in 1972 appear to call for FHA State
Offices to play a stronger role in assuring intergovernmental planning coordination for waste water
collection and treatment systems.

With regard to FHA grants for construction of water and waste disposal facilities, the survey found
little relationship between FHA water/sewer projects and FHA comprehensive water/sewer plans,
even though the statutory provisions for this program require that projects must be consistent with
a comprehensive water or sewer development plan for the rural area. Furthermore, FHA grants and
loans for rural water systems are usually made without any direct coordination with the State water
quality agency concerning water  quality  considerations. In some  cases where construction of a
water system is tied in with the construction of a collection system, the State water quality agency
must approve the  project.  Ordinarily, however, plans for FHA-funded rural water system  projects
are not reviewed by State water quality agencies unless an increase in  treatment is required. For
those water systems that involve disposal through septic tanks, State Departments of Health usually
serve as the agency responsible for plan review and approval.

Where  FHA grants and loans are made for construction of collection and/or treatment systems, the
survey found  that procedures for linking  these projects with water quality planning are evolving.
Some  State  water quality planning agencies  review and approve all  engineering  plans  for the
construction  of collection  and  treatment  systems. In one State, FHA  has even  set up a priority
system for waste disposal  system construction grants and loans based on the State's priorities for
municipal waste treatment needs, as set forth in the State's Section 7 Annual Program Plan for EPA.
In this instance, joint funding of rural treatment projects among FHA, EPA or State water quality
program funds is the usual procedure. This joint funding  of  FHA projects  provides a means of
coordinating  FHA sewerage projects with  EPA water quality management planning, since an EPA
Section 8 grant can only be awarded if the project is included in a River Basin and areawide Water
Quality Management Plan and is included in the State's list of annual priorities.

In summary,  the survey revealed that FHA State Office officials are using a variety of techniques to
coordinate  FHA funded water/sewer planning projects with  other Federal agencies involved in
water/sewer planning and  with State water quality planning agencies.  While some deficiencies in
coordination  still exist, the progress being made in intergovernmental coordination is encouraging.
Although the  standards for FHA  comprehensive  rural water/sewer planning requirements do not
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meet EPA standards for water quality management planning, an attempt is being made on the part
of FHA officials to coordinate FHA planning requirements with those of EPA.

Economic Development Administration

EDA requires  that the  area for which an EDA supported project is  to be undertaken have  an
approved  Overall Economic Development Program (OEDP) and that the  proposed project  be
consistent with it. The OEDP is the basic locally developed comprehensive planning document for
all EDA programs. OEDP's are prepared on the basis of single-county redevelopment areas or for
multicounty Economic Development Districts (EDDs). An OEDP contains basic physical, economic
and demographic data for the area, an analysis of the area's natural and community resources,  goals
and objectives for  the area and a detailed strategy for economic growth, a work program setting
forth planning and project priorities, and the designation of cities and towns in the area as economic
growth centers. EDA is currently developing guidelines  for the preparation of an environmental
assessment which will be part of the OEDP process.

EDA also  requires that the initial project application must show how the project will contribute to
the economic  development of the  area. This requirement is satisfied through an estimate of the
number of persons that will benefit from  the project, either directly, or indirectly as employees of
firms using the facility.

Planning  Coordination. Although EDA provides both basic and  supplemental grants for a  large
variety of public works projects, the survey indicated that EDA sewerage facilities grants are often
used to supplement basic grants from FHA, HUD or EPA. In some cases, as many as three agencies
provide grant  assistance  for a collection and treatment system project. In the case of  EDA
supplemental grants,  the applicant must comply with  the  planning requirements  of the agency
providing the basic grant support. Where two or more agencies jointly fund a project, a lead agency
is  usually  selected  to assure that the appropriate  planning requirements  are met. This procedure
provides for coordination of EDA's sewerage facilities grants with  the planning requirements of
other Federal agencies.

The survey showed that EDA does not  often  make the basic grant for a  sewerage facility unless
FHA, HUD  and  EPA cannot or  will not  fund  the project. When  EDA makes the basic grant, the
project is  not  ordinarily included in the water  quality management  plan for  the area. Only where
the State  water  quality planning agency has  approval  authority over plans  for  collection and
treatment systems projects and uses it to assure that EDA projects are consistent with appropriate
water quality management plans, are EPA's planning requirements met.

The survey showed that EDA most often supplements FHA grants or loans for water and sewer
facilities. Here again, there is no assurance that the project will be consistent with water quality
management planning for  the area. Only where EPA jointly funds a project  with EDA is  there
reasonable assurance that the project will be consistent with the appropriate water quality plans.

EDA Areawide Comprehensive Planning and Organizational Requirements. A more serious obstacle
to unified planning requirements results from the  differences between EDA's requirements for an
Economic Development District organization and HUD's district  organization requirements.
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EDA  does not  require EDDs to meet certification  requirements  similar to HUD's regarding
organizational, and comprehensive and functional Areawide Planning Requirements. As a result, a
significant number  of EDDs across the country have not been certified  by HUD. Most of these
uncertified EDDs are not likely to meet HUD's Areawide Planning Requirements for Certification
until and unless they receive HUD '701' Comprehensive Planning Assistance grants.

The main conflict between EDA and HUD planning requirements centers  on the type of planning
which HUD requires.  EDA does not require a land-use plan, a housing element, or a functional
water/sewer plan element as does HUD. Since EPA has adopted HUD's organizational and planning
requirements, many nonmetropolitan counties and  municipalities  served by non HUD-certified
EDDs will not be eligible for EPA Section 8 Construction Grants for waste water treatment facilities
once the EPA-HUD Guidelines  for Water Quality Management Planning are  fully implemented.'

STATE INSTITUTIONAL ARRANGEMENTS

The provisions  of PL 660 give the States prime responsibility for developing the most effective
internal institutional arrangements for achieving water quality objectives.

The States rely on several administrative devices to achieve their objectives:

       •  Designation of  appropriate  State agencies to administer the  State's water pollution
       control activities and to accomplish the  requirements for river basin planning;

       •  Preparation of the Annual State Program Plan, covering all aspects of  water pollution
       control  for the  coming year, including goals, planned activities, funding sources, budget
       levels,  and  legal  authority; and State's strategy  and schedule  for accomplishing EPA
       requirements for River Basin and Metropolitan/Regional Water Quality Management Plans;
       and one  and five-year schedules of priorities for Section 8 construction grants to meet the
       State's "Municipal Waste Treatment Needs;"

       •  Designation, in cooperation with EPA and HUD, of areawide planning organizations to
       accomplish the necessary areawide Water Quality Management Plans, and;

       •  Certification that the State's areawide and River Basin Water Quality Management Plans
       are consistent and conform with State programs.

Through these management devices, a pattern  for water quality management is evolving geared to
each State's particular experience, problems  and existing institutional arrangements. In response to
the goals of various  Federal programs,  and  to the administrative procedures and regulations
promulgated to implement them, the management systems in each of the States have certain similar
characteristics.  All function  within  a framework of intergovernmental  cooperation  to achieve
certain national  goals. And all utilize similar administrative processes, e.g., State program plans,
water quality standards, discharge permits, etc.

In many States,  separate agencies have been  established to deal with water supply, water pollution
control, water use,  and other natural resources. When all water-related planning and programming
are considered, there are few State agencies whose programs do not have an impact on, or will not
be directly  or   indirectly  affected by  water  quality management  planning. The most obvious
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examples include agencies whose mission concerns economic development, community services, and
comprehensive State planning.

State Agency Roles

From the findings of the survey and a cursory review of designated State agencies, it appears that
more and more States are consolidating environmental control activities (air, water and solid waste)
into a  single agency.  Two  dominant characteristics  were identified  in these environmental
protection agencies:

       » Most are relatively new, representing consolidation of  formerly fragmented activities
       administered through different functional agencies.

       • Most have a legislative mandate to combat pollution through a strong regulatory function.

In effect, many States have only recently made pollution control and environmental enhancement a
priority mission of State Government. The result has been two-fold:

       1. Pollution control  agencies  have  adopted  a regulatory approach  to water  quality
          problems in reaction to increasing public demands to clean up the environment.

       2. This  approach  has reflected  a need  to  institutionalize their  role  and to gain the
          confidence of legislators, governors, Federal agencies and the public.

Thus they employ two basic policy tools:

       1. Regulatory  controls, such  as  establishment of  water quality standards,  inssuance of
          discharge permits, permits  for construction of waste water  treatment facilities, and
          authority to issue cease-and-desist orders and to recommend civil  penalties for polluters;
          and

       2. Maximization  of Federal grants  and  State funding for  municipal  waste treatment
          construction to clean up polluted waters as quickly  as possible.

Throughout the brief experience of most of these agencies, they have had little time, funds, staff
resources, or a legislative mandate to establish a planning function that meets the rigorous standards
envisioned by EPA in  the Guidelines. Instead, priority has been placed  on building both public
confidence  and the institutional capability to carry out their statutory responsibilities. As a result,
the planning function has received a low priority in most States.

These factors have made many State water quality planning agencies reluctant to undertake river
basin water quality management  planning or to  encourage substate district agencies to become
involved in areawide water quality management planning as called for in the Guidelines.

State water quality agencies  have  several  complaints to  justify  their  lack  of progress in
institutionalizing a State-Areawide planning process. Depending on their particular circumstances,
they complain of:
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       • The lack of adequate Federal planning funds under Section '3c' of P.L. 660 to support
       required river basin and areawide water quality management planning;

       • The lack of flexibility in the  Guidelines to allow for the establishment of a planning
       process to  fit the needs of the State in terms of legal authority, water pollution problems,
       existing capabilities, and on-going planning efforts:

       • The failure of the Guidelines  to clearly distinguish between the requirements for river
       basin and areawide water quality management planning;

       • The volume and  technical quality of EPA-required in-stream data, which some  States
       assert is not currently available;

       • The "arbitrary and unrealistic" time schedules for completion of fully developed river
       basin and areawide plans;

       • The inability of areawide planning  agencies, particularly those  serving nonmetropolitan
       areas, to develop areawide plans which meet the Guidelines' specifications.

Some of these complaints  may  well be legitimate,  others provide  an excuse for bureaucratice
inaction. During field interviews the areawide agencies blamed State and Federal agencies; the States
blamed the "Feds" and the areawide agencies, and so on in a pattern of diffused responsibility.

A major problem inhibiting the States' efforts to institute water quality management planning
concerns the  unfamiliarity  of State water quality agencies with  the  concepts and purposes of
management planning. This  results in a corresponding failure to appreciate its  long-range value. The
field survey clearly indicated that many officials responsible for water quality management planning
fail to appreciate the need for:

       • A  dual  planning  function for river  basin  and areawide  water  quality management
       planning;

       • The necessary planning linkages between water quality management planning and other
       related functional planning activities (such as water resource planning, often carried out by a
       different State agency);

       • Relating  water quality management  planning to comprehensive  State and  areawide
       planning and development activities; and

       • A management planning process to assure maximum public benefit through the efficient
       and effective utilization of scarce resources.

Nevertheless, through  incentives  such as water quality management planning grants  ('3c'  grants)
from EPA, and through the  threat of losing eligibility for Federal construction grants under Section
8, the States have slowly moved to comply with EPA's planning requirements.
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Differing State Roles

Two basic but different  strategies for meeting the requirements for water quality management
planning at the State and areawide levels appear to be emerging:

       1.   A strong role  for State water quality agencies in developing River Basin and areawide
           Water Quality Management Plans;

       2.   A strong role for substate areawide planning organizations in the development of River
           Basin and areawide Water Quality Management Plans.

By contrast, the EPA Guidelines clearly envision the establishment of a "balanced" State-areawide
approach with clearly defined roles for State agencies concerned with water resource management
and  for substate areawide planning organizations, with coordinative mechanisms  linking water
quality management planning with other State and areawide planning and development activities.
Just as clear, however, is the failure to date of many States to put into effect a balanced approach
and, in many instances, to even conceptually grasp its necessity.

A Strong  State Role.  The States perceive  certain advantages in the strategy  they employ to
accomplish EPA's  planning requirements. The strategy selected usually reflects existing planning
capabilities within  the State. Where a strong State role is stressed, it is usually regarded as the most
expedient  approach  to  meeting EPA's requirements,  maintaining  continued  eligibility  of
communities for EPA  construction grants,  and  avoiding  complex  problems of State-areawide
planning coordination.  Such  an  approach does  not  tax  the limited  capabilities and funds of
nonmetropolitan planning agencies and is most likely to be used where State water quality  agencies
have established some planning  capability, and substate agencies are still new and have relatively
weak planning programs.

However, the survey revealed that  foreclosure of areawide planning agencies from full participation
in the  planning process has certain disadvantages. In effect,  a key link in the intergovernmental
management system envisioned by the Guidelines is left out. As a result, the necessary coordination
of water quality planning with comprehensive development planning  at the areawide level is not
likely to be achieved. In  addition, coordination of  water quality planning with related areawide
functional planning for water and sewer facilities supported by HUD and FHA is much less likely to
be accomplished.

Finally, water  pollution  problems prevalent in nonmetropolitan  areas  such  as soil  erosion,
agricultural run-offs,  irrigation,  mine  drainage,  septic tank drainage, animal wastes and  natural
weathering, are not likely to receive adequate attention in the planning process.

A Strong Role for Substate Agencies. On the other hand, the survey found indications that some
States do accord their substate district  agencies a major role in water quality management planning.
This approach usually occurs in States where a strong district program has been in operation for
some time.

This approach also has its  drawbacks, however. The major disadvantage concerns the likelihood that
the State water quality  agency will tend  to play a passive role in the planning process. If the State
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encourages  its   areawide  planning  agencies   to   set  their  own  priorities  and  determine
cost-effectiveness in a planning vacuum, implementation strategies and allocation decisions will be
focused separately on each areawide planning jurisdiction.

Thus  the  States need to take an active role in influencing priorities by examining alternatives for
each  river basin, and establishing a management system that provides a framework  for rational
allocation of their resources among the several river  basins. This can only be accomplished through
an active State role in both river basin and areawide planning.

The survey also found that this approach is likely to result in the continued reliance of the States on
their  regulatory powers in  water quality management rather than developing a strong planning
function.  While  this strategy may result in pollution abatement,  it provides no assurance of
cost-effectiveness, which is the prime concern of management planning.

Finally, the survey found that a passive  State role  in  the water quality planning process further
inhibits  the  establishment  of  the  coordinative mechanisms necessary  to link water  quality
management  planning with other State planning and  policies in such areas as land-use and economic
development, health (water supply), and the development and conservation of natural resources.

Interim Planning

It should  be emphasized that these approaches are those which the States can be expected to utilize
in meeting the Guidelines' requirements for fully-developed River Basin and areawide Water Quality
Management  Plans. In some States these approaches  are now being applied in initial efforts toward
meeting EPA's requirements  for fully-developed plans. Other states have made little progress in
establishing a planning  process to comply with the  fully-developed planning requirements by the
July 1,  1973 deadline.

At present, the States are complying with EPA's planning requirements by developing interim plans
(provided  for in  the  Guidelines)  in line with supplemental guidelines  contained  in an EPA
Memorandum dated  September 20,  1971.  This joint EPA-HUD  supplemental communication
stresses the need for flexibility, particularly for nonmetropolitan  areas, in meeting the  unified
planning requirements through interim plans.

The field  survey revealed that  the States are also using diverse approaches to interim planning. Some
States are relying on interim basin  plans to maintain eligibility of their communities to  receive
construction  grants under Section 8. These interim basin plans are usually geared to previous or
on-going  State  planning  efforts such  as "pollution investigation  surveys"  and "water  quality
implementation  plans," which consist  of a  statewide compilation  of existing  discharge permits,
water quality determinations and schedules for construction of new facilities.

Other States are relying  on  interim areawide plans, which  often  consist  of  merely defining a
sub-areawide planning jurisdiction for the applicant community and its environs based on a "logical
service  area" concept. These interim plans usually include basic population and demographic data
and projections,  available in-stream  water quality  data, which is  often extremely  sketchy and
incomplete, and preliminary engineering reports prepared by a registered professional engineer.
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Both  approaches to interim  planning are based on  the States' regulatory powers and  are often
developed for the primary purpose of  maintaining  eligibility for Section  8  construction grants.
Neither approach reflects a management  planning process as envisioned by the Guidelines, but relies
heavily on "grantsmanship" and State enforcement powers.

In some areas, however, water quality planning grants under Section '3c' have been awarded to both
State  and areawide agencies in an attempt to institute a dual State-areawide planning process. These
grants are usually awarded after direct negotiation  between the applicant agency  and the EPA
Regional Office. Since, in most instances, the negotiations for each planning  grant have not been
timed to coincide, State  and areawide water quality planning agencies have no clear mandate for
coordinating on-going areawide water quality planning with river basin planning conducted at the
State level.

In other words, the mere establishment  of a dual planning function at the State and areawide levels
may result in serious conflicts between State river basin  planning and  areawide planning  if the
planning tasks undertaken at both levels are  not closely coordinated  within an overall policy
framework of broad water quality goals  and specific planning objectives to be accomplished at each
level.

STATE A-95 CLEARINGHOUSES

In all  three States surveyed, State Clearinghouses are  functioning pursuant  to  OMB Circular A-95.
The survey found that these  State  Clearinghouses are using the Project Notification and Review
System  (PNRS)  called for in Circular  A-95 to improve  communication  among agencies whose
missions directly relate to water quality management.  All of these States had established procedures
under  PNRS  to notify the  appropriate  State  agencies  of  applications  for Federal grants  for
water/sewer, and waste treatment planning and construction.

State  Clearinghouses  are  attempting to  coordinate functional  planning for water/sewer and
treatment facilities with comprehensive  planning through  the PNRS system.  For instance, State
water quality agencies are usually notified  when a HUD '701' comprehensive planning grant to an
areawide agency will be used  to  develop a functional water/sewer planning element. Usually,
however,   State   Clearinghouse   personnel  are  responsible    for   analyzing   these
functional-comprehensive planning linkages. For example, one State Clearinghouse was attempting
to assure, through PNRS, that FHA water  and sewer  planning would be coordinated with areawide
or local land-use planning.

In general, the survey found these agencies particularly active in attempting to coordinate Federal
water/sewer-water quality planning and projects,  either through the Clearinghouse function or
through their role as the official State Comprehensive Planning Office. Some of the techniques that
have been devised include:

       • The preparation by one State  of a planning manual for water quality management which
       includes detailed step-by-step procedures for areawide water/sewer functional planning and
       areawide water quality management planning;
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       ® An attempt by one State Planning Office to define a stronger role for nonmetropolitan
       areawide planning agencies in the water quality management planning process by means of a
       specific work element in a HUD-funded Demonstration District program;

       • The development, by one State Planning Office  in conjunction with the State  water
       quality  agency,  of  a  set  of  guidelines  to help  local  communities  determine  when
       regionalization of waste water treatment facilities is feasible; and the review of local project
       grant applications and  interim  basin plans through PNRS to  determine if the criteria
       developed in these guidelines have been followed;

       « The formation of a committee, composed of personnel of State agencies whose missions
       relate to water quality, to coordinate river basin planning efforts among State agencies;

       • The organization of a river basin planning advisory committee composed of directors of
       all areawide planning agencies within the State to provide inputs into river basin planning
       being conducted by the State.

In addition  to these formal procedures, the survey found numerous examples of more informal
coordination efforts being employed by State Clearinghouse personnel. Since the State Planning
Offices are usually responsible for administration of HUD '701' grants to nonmetropolitan areawide
planning agencies, Clearinghouse personnel often  provide liaison between these areawide agencies
and  State water  quality agencies.  In  some States, Clearinghouse agencies are taking the lead in
providing technical  assistance  and planning guidance to  nonmetropolitan planning agencies
concerning linkages needed to coordinate HUD or FHA supported water/sewer planning with EPA's
water quality planning requirements.

In another instance, the formal PNRS  procedures  for water/sewer-water water quality projects are
being augmented  by informal  communications between personnel of the State Clearinghouse and
the State water quality agency. In the same  State,  the State Clearinghouse is double-checking all
applications for EPA Section 8  construction grants to determine if the State water quality agency
has reviewed them for conformity with interim  river basin  plans. If any conflicts are noted,  the
planning section of the State water quality agency is alerted. In effect, the State Clearinghouse is
attempting to establish communication linkages between the subdivisions within the State  water
quality agency.

Environmental Inputs

The  survey found that State Clearinghouse agencies  are seriously involved in attempts to anticipate
the long-range,  secondary or indirect effects of development projects on comprehensive planning,
State  and Federal policies, and  on  qualitative considerations of community and  economic
development. These effects of current plans and projects have particular significance with respect to
water/sewer and waste treatment planning.

The  most convenient procedure available  to  State Clearinghouses for examining these  secondary
effects is through the provision of Circular A-95  calling for  State and Regional Clearinghouses to
secure the required  State and local inputs to support the preparation of environmental impact
statements required by Section  102 of the National Environmental Policy Act. State Clearinghouses
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often take the initiative in requiring the project applicant and the  appropriate State agencies to
prepare an environmental assessment of proposed water/sewer and waste treatment projects. These
environmental  assessments are  then reviewed by the State Clearinghouse  and, if  appropriate,
additional comments on their long-range and secondary effects are prepared.

Constraints to the Effective Administration of "A-95"

The survey found that personnel of State Comprehensive Planning Offices  are more knowledgeable
of  the roles,  relationships  and  planning  linkages  necessary  to  implement  a water  quality
management  planning process  than  personnel of most other agencies involved in water quality
activities, including, in many instances, Federal agency representatives.

Yet several constraints were  identified in some States which inhibit  the effective use  of the A-95
process. With specific reference to problems of coordinating water quality management planning,
one State Clearinghouse was attempting to strengthen the role of Regional Clearinghouses in the
PNRS  process. However, since  in this State, the  State water  quality agency had not involved
areawide planning agencies in developing water quality management plans, the State Clearinghouse
felt the regions could not  perform an adequate review of water-related projects in their area for
conformity with the applicable water quality management plans.

Another problem is the  reliance of  State Clearinghouse personnel on the adequacy  of the A-95
review conducted  by other  "interested"  State  agencies, on which  they  depend for a thorough
analysis of proposed projects. However, they have no direct means of assuring that these agencies
Consider all  the project's ramifications. For  instance, personnel  of one  State Clearinghouse are
particularly concerned over what they view as the indifference expressed by the State water quality
agency  concerning grant  applications for construction of  water  systems.  Although  all  such
applications are routed to the water  quality agency for review, often  no interest is expressed unless
the capacities of the existing collection or treatment systems are involved. As a result, Clearinghouse
personnel often feel that adequate consideration is not given to the long-range or secondary effects
of the proposed water system.

Other problems identified which tend to inhibit the general effectiveness of A-95 include:

       1.   A  severe shortage of funds  and staff needed to effectively follow through on PNRS
           procedures to assure appropriate  action is  taken.  All State  Clearinghouses strongly
           advocated that Federal grants which support State comprehensive planning allow the
           administration of the A-95 function to be included as an eligible cost reimbursable with
           Federal funds.

       2.   In some States, Clearinghouse personnel feel that there are no statewide plans or policies
           to provide a coordinative framework within which all local project applications can be
           evaluated. As a  result, they feel that the Clearinghouse process cannot  be  used to
           influence priorities  and implement development objectives. This  is particularly true
           regarding  the  assessment of secondary, indirect or  long-range effects of plans  and
           projects.

       3.   Clearinghouse personnel in States that have begun to  formulate statewide policies for
           balanced growth  and  development complain of the  lack of statutory  authority to
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           influence Federal agency decisions concerning funding of local projects. They assert that
           there have been few instances where Federal agencies have held up project  grants to
           local applicants pending resolution  of problems identified through the  review and
           comment procedure.

In  summary, a  hierarchy of  problems  associated  with  the  effective   administration  of  the
Clearinghouse process was identified. In some States, no plans or policies for evaluation of projects
exist; in other States where they may have been developed, there is no legal or political authority to
apply the planning criteria; and in States where  adequate  criteria and some leverage are available,
funds and staff to administer the Clearinghouse process adequately are insufficient.
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                     IV. NONMETROPOLITAN AREAWIDE PLANNING
INTRODUCTION
This chapter is designed to portray the institutional setting in which planning related to water
quality management occurs. Evolution of multijurisdictional substate organizations with broad or
narrow  functional purposes in  response  to  Federal  and State initiatives  is traced  in  terms of
principal Federal programs involved. Capabilities of district organizations, their varying  relationships
with other agencies and constraints on their functioning, stemming from their mixed  heritage, are
discussed in relation to the objectives of EPA's planning requirements.

Background  observations are related to specific findings of the survey as  pertinent  points arise.
Following are  conclusions, emphasizing  the  role  of  OMB  Circular A-95  in improving  the
intergovernmental process outlined in the chapter.

EVOLUTION

Over the past decade, comprehensive planning and development activities in nonmetropolitan areas
have  increasingly become  the  responsibility  of various  types of multijurisdictional substate
development districts or similar organizations.

Although the  creation  of substate districts has,  for the most  part, been in response to specific
Federal  programs calling for areawide planning, the organization of multicounty districts had been
initiated in a few States such as Georgia and Kentucky several years before the Federal government
began to promote their establishment.

By the  mid 1960's, several Federal programs called  for intergovernmental efforts supported by
multijurisdictional areawide planning to solve the pervasive economic and social problems afflicting
many communities throughout nonmetropolitan America.

Beginning  with the passage of the Appalachian Regional Development program in 1965, Congress
endorsed this concept by calling for the establishment of multicounty Local Development Districts
(LDDs)  to assist the Appalachian States and the Appalachian Regional Commission in planning a
comprehensive development program for the region.

The Public  Works and Economic  Development  Act of 1965  provides for the establishment of
multicounty Economic Development Districts (EDDs) to perform areawide economic  development
planning in certain depressed nonmetropolitan areas. By 1966, the Office of Economic  Opportunity
had also begun to encourage the formation of multicounty community action agencies to plan and
administer various components of rural community action programs.

The Department of Agriculture also began promoting multijurisdictional  districts in the 1960's
through the  support of Resource Conservation and Development Project areas. In addition, several
States began  to  administer their  agricultural  extension service  programs  on a  multicounty
"extension district" basis.
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In 1968, Congress took another major step toward advancing the district concept by amending
Section 701 of  the  Housing  Act  of 1954 to provide  comprehensive  planning assistance for
nonmetropolitan  district agencies. These amendments also called for the Department of Agriculture
to provide technical assistance in establishing these districts and to support their planning.

In addition  to these multipurpose planning and development programs, Congress has authorized the
formulation of single-purpose or functional  areawide planning agencies in nonmetropolitan areas
such as areawide comprehensive health planning agencies  and regional law enforcement planning
councils.

The  evolution of areawide  planning and  development  agencies in nonmetropolitan areas was
influenced by several factors. Initially, districts were organized in economically declining rural areas
to provide  for increased cooperation  and for merging of financial  and  technical resources of
hard-pressed local governments to promote economic development.

The  States  and the Federal government  soon realized the potential of development  districts to
undertake the planning of development activities that could only be successful if applied on a larger
areawide or regional scale. Finally, the multijurisdictional district agency has been recognized as a
potential key governmental mechanism to solve a growing array of problems-such as environmental
pollution-which transcend the boundaries of any single jurisdiction.

Since  1965, nine Federal programs affecting nonmetropolitan areas and calling for an  areawide
planning  function have  been  put  into  operation.  Eight  have  sponsored the formation  of
multijurisdictional planning agencies  to perform areawide planning. At least three have sponsored
comprehensive areawide planning organizations-LDD's, HDD's and HUD's nonmetropolitan districts
(NMDs). The other Federally  sponsored multijurisdictional planning  organizations operating in
nonmetropolitan  areas  administer special-purpose planning programs with more  narrow objectives
such as health care, law enforcement and resource conservation.

The  proliferation of these  Federally supported  districts-often overlapping many special-purpose
districts used by  State agencies  to administer certain programs-created an urgent need  for a single
set of areawide planning jurisdictional boundaries. In the late 60's, the Federal government began to
recognize the need to establish a uniform system of substate districts  with consistent geographic
boundaries to plan and manage  both  Federal and State programs requiring  areawide consideration.
Bureau of Budget Circulars A-80 (in  1967) and A-95  (in 1969) require Federal agencies, whenever
possible, to  use State-designated planning and development districts in administering programs with
areawide planning requirements. This Federal action has encouraged  the official designation of
statewide systems of substate districts in over 40 States as of mid-1972.

Each  Federal  program  providing  basic support for  nonmetropolitan  districts has  its  own
requirements for organizational structure, planning procedures, funding arrangements  and citizen
participation.  In  addition, the  States with a system  of substate districts usually  have their own
requirements for  district planning and development activities, set forth in legislative acts, executive
orders, or regulations and guidelines issued by the State agency responsible for managing the State's
district program.  In  some  States, district  organizations  have been  established under interlocal
cooperation statutes. In these instances, the participating local governments determine the functions
of the district agency.
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COMPREHENSIVE AND FUNCTIONAL PLANNING

The three State survey indicated that nonmetropolitan planning and development organizations are
not yet actively involved in the water quality management planning process. Of the 20 such agencies
currently operating in the States surveyed, only two are currently funded with '3c' planning grants
from  EPA. In  one instance, the grant is for the preparation of a Metropolitan Water Quality
Management  Plan,  where one  SMSA  fringe  county falls within the planning jurisdiction of a
nonmetropolitan planning agency. There  is little  doubt that this pattern of '3c' funding exists
nationally, given the limited funds available and the current emphasis on metropolitan water quality
planning.

However,  many  nonmetropolitan agencies are engaged in  comprehensive and functional planning
activities which directly relate to water quality management. The field survey concentrated on four
aspects of current planning efforts in nonmetropolitan areas to indicate the problems and potentials
of involving them in the formulation of fully-developed areawide Water Quality Management Plans:

       1.  Comprehensive planning  activities currently  being undertaken  by nonmetropolitan
          areawide planning and development organizations.

       2.  The current status of these agencies in meeting HUD's Areawide Planning Certification
          Requirements.

       3.  Their involvement in related  functional planning such  as  water/sewer and natural
          resources planning.

       4.  Their role in coordinating Federal and State planning and development activities carried
          out within their planning jurisdiction.

In most States, State policy  has been directed toward creating district organizations to serve as the
single  areawide agency to administer Federal  and  State niultijurisdictional  planning  and
development  programs. As a result, many of these  organizations administer several comprehensive
and functional planning programs, funded in part by Federal planning grants.

Areawide Comprehensive Planning

Planning grants  under EDA's Economic Development  District (EDD) program  and HUD's '701'
Comprehensive Planning Assistance Program  to nonmetropolitan districts (NMDs)  are the most
common in nonmetropolitan areas.* They support  comprehensive planning and are used primarily
to employ professional planning staffs and consultants  to accomplish the planning required under
each program.

Most  well-established  EDDs and  NMDs have  been able to  receive and/or coordinate  additional
functional planning grants through the  staff capability "bought" with their basic EDA or HUD
planning grants.


 *In the Appalachian Region, nonmetropolitan planning is also supported by planning grants from the Appalachian
  Regional Commission to support the activities of Local Development Districts.
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Economic  Development  Administration  Under  the  Economic District Development Program,
areawide planning and development districts are  organized with a governing board composed of
local elected officials and  representatives of the area's major economic interests including  the
unemployed, minorities, business, labor and civic groups. To be designated an EDD, the district
organization must prepare an Overall Economic Development Program  (OEDP) approved by  the
State and EDA.

A district's initial OEDP, once approved by EDA, must be updated annually, listing priority projects
to be undertaken to help accomplish the goals and objectives set forth. Subsequent EDA grants arid
loans to the area for public facilities must be consistent with the OEDP and have a demonstrable
effect on reducing unemployment or otherwise alleviating poverty in the district.             '

Department of Housing and Urbari Development The planning  requirements for nonmetropolitan
areawide planning  under the HUD '701' Comprehensive Planning Assistance Program are  more
complex. Initially, a HUD NMD must satisfactorily complete an  Overall Program Design (OPD) and
an Annual Work Program.

The OPD consists of a three-to-five-year overall program of work  to assure that work elements relate
to overall planning objectives, that staff, time, and financial resources are effectively programmed,
and that planning tasks are undertaken in logical sequence.

The Annual Work Program includes a schedule  of specific planning activities to be undertaken
during the current funding period.

Areawide Certification

In  order to continue  to receive '701'  Comprehensive Planning  Assistance grants and in order  for
communities within the Areawide Planning Jurisdiction to be  eligible for HUD water and sewer
facilities grants, areawide planning agencies must make satisfactory progress toward meeting HUD
Certification or Areawide Planning Requirements.

The satisfactory accomplishment of HUD's Areawide Planning Requirements is a key feature of the
unification of EPA and  HUD planning requirements. In  an  attempt to achieve coordination of
areawide water quality management planning with areawide comprehensive and functional planning
funded under the HUD '701' program, the Guidelines require  that projects funded by HUD  for
water  and sewer facilities  and  by EPA for  waste  treatment facilities  conform  to  the  same
requirements for both comprehensive and functional planning. To implement unification,  the
Guidelines  call |for  Areawide  Planning  Organizations  to meet  HUD's  Areawide  Planning
Requirements prior to the award of an EPA or HUD grant for waste water collection or treatment
facilities. If fully implemented, the HUD-EPA unified Guidelines  will require that no facilities grants
be  awarded by either agency until an API has been defined and an APO has been designated and
fully certified by HUD.

HUD determines that planning agencies have met its areawide planning requirements by certifying
their planning accomplishments and competence at three levels. Level I concerns certification as the
official Areawide Planning Organization, (APO); Level II indicates that the areawide agency has met
HUD's comprehensive planning requirements; and Level III indicates  that the agency has received
HUD certification for areawide functional  waste water collection  and disposal systems planning.
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The Guidelines envision that in awarding Certification III, HUD and EPA will determine if the APO
has met both EPA's water quality management planning requirements and HUD's requirements for
functional water/sewer planning and programming.

The current status of HUD Certification of nonmetropolitan areawide planning organizations varies
greatly  from  district  to  district  and  State to State. The survey  indicated that,  while a  few
nonmetropolitan  districts  have  completed  the  necessary  planning  tasks  to  receive  HUD
Certifications I  through  III,  others  have not  as  yet  received Certification I.  In  addition,
nonmetropolitan areawide planning agencies in several States are  not involved in the HUD '701'
Comprehensive  Planning  Assistance Program  and, as  a result,  do not  expect to receive HUD
Certification in the near future.

Although the administration  of HUD's areawide planning requirements varies somewhat from State
to State,  HUD  generally requires the  following planning  tasks be  accomplished to receive
Certification II and III:

       • Preparation of a comprehensive areawide land-use element;

       • The establishment of areawide goals and objectives;

       • The compilation of basic population, demographic and economic data and projections;

       • The completion of  a preliminary water/sewer planning element.

The capability of existing NMDs to complete the  necessary planning  tasks for HUD  Certification
varies considerably depending on:

       1.  The level of HUD funding.  The larger the '701' grant, the more staff the district can
          employ to undertake HUD's planning requirements.

       2.  The  total  level  of  all Federal planning assistance  supporting comprehensive  and
          functional  planning  administered  by  the  district agency.  In districts  that receive
          planning  funds from both  EDA  and  HUD,  more  staff resources  are  available to
          undertake the required planning.

          However, the timing of the two planning grant programs is important here. For instance,
        !  if  a  new nonmetropolitan planning organization received concurrent planning grants
          from  HUD  and  EDA,  the  district would be hard-pressed  to meet  their planning
          requirements simultaneously since the requirements of both agencies differ  significantly.
          The  field survey indicated  that the most  successful districts, in terms  of planning
          accomplished,  first received an EDA grant  and  completed the  preparation  of an OEDP.
          Subsequently,  these  districts received HUD '701' planning grants  and were able to
          combine  these funds with  continuing  planning  funds from EDA to  satisfy  HUD's
          planning requirements.

       3.  The physical, demographic and political characteristics of the planning area. In the most
          rural or sparsely  populated  planning areas, district boards are sometimes reluctant to
          undertake some HUD-required planning, which some feel is geared more to  the problems
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          of  urban  or rapidly growing areas.  This is particularly  true  concerning HUD's
          requirements for an areawide Land-Use Element, which is often resisted by some rural
          interests. Even where there is no overt opposition to land-use planning and zoning, local
          officials in sparsely settled rural areas are often reluctant to commit the necessary funds
          and staff resources to the Land-Use Element which they feel is not an urgent planning
          priority.

       4.  The  existing problems and  planning priorities  of  the  nonmetropolitan  planning
          agency. In  many nonmetropolitan areas,  the  district planning  agency was created
          primarily to promote economic development. As a result, they may be reluctant to meet
          HUD's Areawide Planning Requirements, especially if they are not receiving HUD  '701'
          planning assistance.

       5.  The  total  staff  and technical planning assistance resources  available  to  the district
          organization from State and other Federal agencies involved in related planning and
          development. In  some nonmetropolitan  areas, the district organizations  receive the
          active support  of Rural Development Committees organized under the  auspices of
          USDA. Other districts which  have been successful in gaining the active support of
          Extension  Service agents and Soil  Conservation Service County Agents are in a much
          better position  to undertake HUD planning requirements. In some nonmetropolitan
          areas, USDA has supported establishment of multicounty Resource Conservation and
          Development project areas coterminous with nonmetropolitan districts.  These RC&D's
          represent  a potential source  of additional staff assistance  which, through proper
          coordination, can support the planning objectives of the district agency.

          Finally, in  some States,  a program  of State technical staff  assistance is  available to
          areawide organizations which can be used to support district planning objectives.

Related Functional Planning

The survey revealed that nonmetropolitan  district planning agencies are currently engaged in several
kinds of functional planning directly related to  water quality management.

       1.  Areawide   land-use  planning,  usually  undertaken  with Comprehensive   Planning
          Assistance  Grants from HUD;

       2.  Areawide water and sewer facilities planning supported  with HUD '701' planning funds
          and/or planning grants from the Farmers Home Administration;

       3.  Economic  and industrial development planning,  usually directly related to the OEDP
          planning process and public facility  grants and loans from EDA.

The relationship of areawide land-use  planning to water quality management is obvious and direct.
The Guidelines call for areawide water quality management plans to provide the main input on land
use, which is to be integrated  into river basin plans. All nonmetropolitan districts  receiving  HUD
'701'  funds  are required to prepare a Land-Use Element. While progress in this area varies greatly
from  district to district, most HUD-supported  districts will usually  complete at least a preliminary
Land-Use Element within a  year after receiving  their initial HUD planning grant.
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The majority of the districts contacted in the survey had recently completed, or were in the process
of completing, an areawide water  and sewer plan. The  remainder were anticipating undertaking
areawide water/sewer planning as soon as planning funds became available from HUD or FHA.

Economic and industrial development planning in nonmetropolitan areas invariably relates, directly
or indirectly, to water quality management planning. In EDDs, a large percentage of project activity
is  centered around public  facilities grants and loans from EDA  to attract new industry. These
projects  often involve  construction of  water, sewer and waste treatment facilities  with Federal
grants from EDA, FHA, HUD and EPA. Even when EDA projects do not directly  involve these
types of facilities, the  planning associated with economic or industrial development projects will
usually need to address water quality considerations  for either the immediate or long-range future.

AREAWIDE PLANNING COORDINATION

It  is now the policy of most  States,  that, wherever possible, all  Federal and  State supported
multijurisdictional planning  and development  programs should be  administered  directly by, or
coordinated under the organizational  umbrella  of,  officially  designated  substate planning and
development organizations. Nevertheless, the extent to which areawide programs currently conform
to this policy varies considerably from State to State. In some cases, the geographic boundaries of
multijurisdictional programs are still not coextensive with  substate district boundaries.  In  other
instances, special functional planning  structures have evolved independently from the official
substate district organization.

Those districts responsible for and/or actually administering  functional planning programs  are
usually in a position to play a stronger role in establishing the arrangements necessary to effectively
relate comprehensive and functional planning. In  some States a wide variety of functional planning
programs, supported by Federal agencies, are administered through nonmetropolitan districts. These
include  planning grants for law enforcement (LEAA), transportation and highway safety (DOT),
comprehensive  health  and  human  resources (HEW), historic preservation  (Interior), manpower
(Labor), and planning supported by the Council on Aging.

In addition, in some  areas nonmetropolitan district agencies are working closely with Community
Action Agency staffs supported by OEO. In some States, OEO is directly funding nonmetropolitan
district   agencies   to   administer   Community  Action  Program  components   through special
demonstration programs.

In nonmetropolitan areas served by areawide planning organizations, OMB Circular A-95 is the key
mechanism for strengthening the institutional arrangements necessary to manage comprehensive and
functional planning activities on an areawide and statewide basis.  To bolster the  role of areawide
planning and development agencies in coordinating Federally supported planning and development
activities, most States  which have officially delineated  substate districts and recognized district
organizations have designated them as Metropolitan or Regional (Nonmetropolitan) Clearinghouses
to review and comment on applications for Federal assistance.

This Clearinghouse function is probably the single most important management  tool available to
nonmetropolitan  planning and  development organizations. It  has  bestowed on nonmetropolitan
districts  the necessary legitimacy to  take a leadership  role in comprehensive planning and
development.
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The field survey indicated that most planning officials in nonmetropolitan agencies understand the
purpose of the Clearinghouse function and recognize its potential for improved management of
planning and development efforts. The Clearinghouse role has been welcomed enthusiastically by
district officials who recognize its potential as a management tool for accomplishing their, mission,
and a source of legitimacy  advancing district  acceptance as the  "lead" agency  in areawide
comprehensive planning and development.

The effectiveness of A-95  at  the  areawide  level is directly related to the progress the district has
made in its overall planning and  development program. The  older, more mature districts, with a
significant  portion of  their  initial areawide planning efforts accomplished, have  been able to
effectively use the Clearinghouse function to help implement these plans. In the newer districts, the
review and comment procedure is used primarily to establish the necessary  communication linkages,
to provide a mechanism for identifying obvious waste and duplication of efforts, and to strengthen
the district's role and  institutional capability to perform areawide comprehensive planning and
coordination.

CONCLUSIONS

In  evaluating the efforts of nonmetropolitan planning and development  organizations, the  most
outstanding feature is the vast  diversity from State to State and district to district. These differences
extend to organizational accomplishments, funding levels, staff capabilities, and planning progress.
For instance, in some areas district organizations are well established, funded and staffed, and have
completed  a significant portion of their basic planning tasks. In  other areas,  while  a substate
multicounty district may have been delineated, no planning organization has yet been formed, often
due to political resistance on  the part  of local officials or conflicts over district boundaries. Often,
this uneven pattern of organizational progress can be found within the same State.

Even in States where all nonmetropolitan districts have been organized, staffing capabilities, funding
levels  and  planning accomplishments  often vary  considerably.  The  survey found  district
organizations with staffs ranging in size from one to ten professionals. As would be expected, those
with  the larger staffs  were  receiving more Federal funds and had completed more of their Federally
required planning.

Some similar characteristics of nonmetropolitan substate district agencies can be identified however.
In most States,  they have a sound legal basis under existing interlocal cooperation statutes or by
specific act of the State Legislature. Almost all districts  are organized through the voluntary
participation of local governments. Few, if any, State laws grant district organizations the powers to
implement their plans. The districts must persuade their participating local governments to officially
adopt district plans.

District governing boards are usually representative bodies, composed of a majority of local elected
officials with special provisions to assure citizen participation and representation of major economic
and social interests. In some States, nonmetropolitan planning organizations have been organized as
Councils of  Governments,  whose governing boards are composed  exclusively  of elected  local
officials. In  these instances, special  arrangements  have  been  designed  to encourage  citizen
participation.
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District staffs are usually not large, averaging three or four professionals. Annual budgets range from
around  $40,000  to  over $200,000.  A  small  percentage  of these  funds comes from local
contributions, usually not more than 35 per cent of a district's annual budget. More than 20 States
now support their  substate district organizations with regular grants appropriated  by  the State
Legislature. However, the  level of State support is usually quite low. In two of the States surveyed,
district organizations received only  around $5,000 annually in  State  support in the form of a
"block" grant for general planning and development purposes.

Most  nonmetropolitan district organizations have been designated A-95 Regional Clearinghouses
and practically all are authorized to undertake comprehensive planning and to coordinate functional
planning with area wide comprehensive planning.

Functional planning in nonmetropolitan areas can be generally classified into three categories:

       1.  Physical planning, including land-use, natural resources, transportation,

       2.  Economic development planning, including industrial development, manpower training
          and provision of public facilities.

       3.  Human resource planning, including health, education, housing and community services.

The  overlap  of these  functional  planning components is obvious. It  is in this area of planning
coordination that nonmetropolitan districts have made the best use of their Clearinghouse  role.

A prime  tool for coordination of water quality management planning in nonmetropolitan areas is
the A-95 Clearinghouse function. Although the administration of the A-95 review and  comment
function  is criticized  by some as a pro forma paper-shuffling exercise, the survey indicated that
district planning officials  understand its  potential and  are  eager to  employ  the Clearinghouse
function  to further the planned development of their areas. As nonmetropolitan agencies become
accepted, complete their basic planning tasks, and receive more State and Federal funding support,
they  will  be able  to use their Clearinghouse  role to more effectively coordinate  all types of
functional planning  and development activities, including plans and projects which relate to water
quality management.
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                    V. DISCUSSION OF FINDINGS AND CONCLUSIONS


Water quality management  planning will have a significant impact  on nonmetropolitan areawide
planning and development  activities. Conversely,  the planning and development activities being
undertaken by nonmetropolitan district organizations will have an  important influence on water
quality management. These  activities include land-use, natural resources, housing, water/sewer and
economic development planning.

IMPEDIMENTS

A major role for nonmetropolitan substate district agencies in the water quality planning process
should result in improved areawide planning coordination, enable the States to improve the quality
of river basin planning efforts, and facilitate implementation of water quality management plans at
the  areawide level. However, the field survey identified some major impediments to be overcome
before a realistic management planning process can be put into effect  in nonmetropolitan areas.

Federal-Level Impediments

One potential deterrent to  coordination of water quality management planning is the lack of a
comprehensive tie-in of all four federal agencies' grant programs for planning and construction  of
water and sewer systems. FHA and EDA which have a major role in funding water/sewer planning
and projects in nonmetropolitan areas, have not entered into an agreement with HUD and EPA to
unify planning requirements for Federally supported waste water collection and treatment systems
projects. If a coordinated approach  to these Federal water/sewer and water quality planning and
construction programs  is not  established  at  all intergovernmental levels, the  prospects  for  an
effective water  quality  management planning  process in nonmetropolitan areas  will be seriously
diminished.

However, the survey showed that even a limited attempt at  unification of  requirements of two
Federal agencies at  the Washington level-the HUD-EPA joint agreement-has not taken effect in
many  areas. Confusion over  the  relationship  between  HUD-required  areawide   functional
water/sewer planning and areawide water quality management planning required by EPA proved the
chief problem.

State-Level Impediments

Although the States are using a variety of approaches in attempting to comply with EPA's planning
requirements, most  State water quality planning agencies are  not familiar with the concepts and
purposes underlying water quality management planning and do not  fully appreciate the need for a
management planning process.  As a  result of  past  emphasis on their  regulatory  and enforcement
function, these agencies often view EPA's planning requirements as another unnecessary exercise to
perform in order for municipalities to remain eligible for Federal facilities grants.

To  meet Federal  planning  requirements in an expeditious manner, some States have pursued a
strategy of minimum involvement of areawide  agencies in  the water quality management planning
process. Their rationale seems to be that if fewer agencies and levels of government are involved, less
time needs to be  spent in establishing coordinative processes and planning linkages, enabling the
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State to  devote its limited funds and staff to meeting EPA's planning requirements as quickly as
possible.

Illustrative of the thinking behind this approach is the statement in one State's Section 7 Program
Plan that "... increased interagency coordination is generally equated with a decrease in work
accomplished .  . .  ."

In those  few States that contemplate a major role for substate district agencies in the water quality
management planning process, expediency in  meeting EPA's requirements again appears  to be a
major influence. This approach is most likely to be followed in  States where little or no planning
capability  exists  within the  State  water quality planning  agency, and  where substate planning
agencies are relatively well established with strong planning programs.

Nonmetropolitan Area Level Impediments

The survey revealed several impediments to full participation of nonmetropolitan substate district
agencies in the water quality management planning process.

Local Resistance.  Planning  officials and staffs of nonmetropolitan planning agencies are for the
most part unaware  of the need for  water quality management planning. It is not enough that  water
quality management plans are now  a Federal requirement for eligibility for EPA and HUD grants.
Coping  with, and  at times  circumventing,  Federal requirements is a way  of life for  many
nonmetropolitan district staffs.

This antipathy will persist  until planning staffs and local  officials become  aware of the future
impact water quality management planning can have on their on-going planning efforts and on the
overall missions of their agencies. Incentives, both in the form of rewards and  penalties, must be
clearly presented to encourage their  full involvement.

Nascent Institutions.  Even if nonmetropolitan district planning agencies fully accepted the need for
water quality management planning, many would not now be in a position to meet EPA's current
requirements for areawide Water Quality Management Plans. An already taxing work load  and a
shortage  of qualified professional staff in many  agencies will serve as a major constraint to the
development of areawide Water Quality Management Plans in many nonmetropolitan districts.

Even if the staff capability  were available, however, most district agencies would not be ready to
undertake planning as called for in  the Guidelines. Many are still in the process of institutionalizing
their role  and  completing  certain  basic  planning tasks fundamental to  the  mission  of  a
nonmetropolitan planning and development district agency. Some are still groping with the problem
of  gaining full cooperation  and support from local officials and citizens. Others are still in the
process  of  preparing OEDP's, initial Land-Use Elements, preliminary  water/sewer plans,  and
establishing their A-95 role in areawide planning coordination.

Lack of Planning Grants.  The general lack of Federal water quality planning grants ('3c'  grants) for
nonmetropolitan areas  has  further  diminshed  the  prospects  for  motivating nonmetropolitan
planning staffs  to become involved in the water quality  planning process. District  officials have
adapted their programs and priorities to the realities of Federal categorical grants, which heavily
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support both planning and project activity in nonmetropolitan areas. This has resulted in planning
priorities being determined, to a large extent, by the availability of Federal planning funds. This
phenomenon has engendered an attitude to the effect that functional plans will not be undertaken
unless supported by a categorical Federal grant for a specific planning activity.

Weak  Communication   Linkages.  Communication linkages  between nonmetropolitan  district
agencies and Federal and State agencies responsible for water quality management planning have
not been well established. This has resulted in considerable confusion on the part of district officials
concerning specific requirements for water quality management planning, the respective roles of
State and substate district agencies in the planning  process, and the relationship between on-going
HUD and FHA supported planning and EPA's planning requirements.

Nonmetropolitan district agencies are often caught in the middle of rapidly changing patterns of
Federal-State-regional communications. On matters concerning project implementation, district and
local officials often  deal  directly  with  EPA regional officials. For  purposes of water  quality
management planning, however, State  water quality  agencies  have  been delegated a  key role.
Nevertheless, the field survey indicated that these designated State  water quality planning agencies
have not taken the initiative to inform  district agencies  of State policy for implementing EPA's
planning requirements and for setting priorities for municipal waste treatment facilities needs. In
addition, little effort has been made by State  water quality planning agencies to provide technical
planning assistance to districts involved in water quality or related planning.

The communications problem is further aggravated when State water quality agencies are engaged in
policy  disputes with EPA Regional offices over standards, priorities and  planning approaches. Where
such conflicts exist,  the  flow of  communications  concerning policies,  technical  planning
requirements, and  intergovernmental relationships is short-circuited. At best, ad hoc patterns of
communication often develop which fail to facilitate the intergovernmental coordination necessary
to establish a unified management  planning system. Often, however, no effective communication
linkages are established, resulting in even more confusion.

In short, the impediments identified in the field survey can be  classified into two major problem
areas.

    1.  Nonmetropolitan district agencies  are not currently active participants in the water quality
       management  planning process as defined in the EPA  Guidelines, and State water  quality
       planning agencies are not actively fostering their participation.

   2.  Administration of Federal programs  and planning requirements related to  water  quality
       management  in nonmetropolitan areas varies significantly across the nation, resulting in a
       fragmented and often confusing approach to intergovernmental coordination.

INSTITUTIONAL TRENDS

The  survey findings  also revealed  that certain recent institutional  trends in the  planning and
administration of Federal programs will have a significant impact on water quality management
planning.
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       • Regional  offices of  Federal  agencies  are  playing an increasingly  significant role in
       grant-in-aid program planning and administration.

       • The States are assuming increased responsibility in the planning and administration of
       Federal grant-in-aid programs.

       • Substate district  planning agencies, now serving nonmetropolitan areas of some 40 States,
       are  rapidly blanketing the nation and are being used increasingly by the States for planning
       and administration of Federal and State programs and as Regional A-95 Clearinghouses.

CONCLUSIONS

When the impediments to nonmetropolitan water quality management planning are viewed in light
of recent trends, several major  conclusions can be  drawn concerning ways to improve the  process:

       • The  objectives of  management planning can best be achieved by designing  an overall
       planning strategy to  coordinate  water quality planning requirements systematically with
       other related areawide planning programs on a district-by-district basis.

       • State-designated  substate district planning agencies constitute  a major resource for the
       accomplishment of  such planning on an areawide basis.

       • Timetables  for  the   completion of  areawide  water quality  management plans  in
       nonmetropolitan  areas  would be more effective if scheduled on the basis  of a  realistic
       assessment of the institutional capabilities of substate district planning agencies their, overall
       planning accomplishments and anticipated planning progress.

       • State and regional A-95 Clearinghouse agencies can play a key  role in accomplishing the
       intergovernmental  and  interagency  coordination  needed  for  effective water  quality
       management planning.

       • Designated State water quality (planning) agencies, in addition to their other duties, are
       in the best position to serve as a clearinghouse for technical assistance to areawide planning
       agencies for water quality management planning.

       • EPA Regional Offices are the logical focal point for coordination among EPA,  HUD,
       FHA, EDA, the States and their substate district agencies for putting into effect an areawide
       water quality management planning process in nonmetropolitan areas.

       • Nonmetropolitan water quality management planning will proceed slowly at best until
       funds are made available to support the required effort.

The above conclusions led to the identification of the need to:

    1   Bring State-designated nonmetropolitan substate planning and development  districts into
       active   participation   with  State  and   Federal  agencies  in   the  intergovernmental
       decision-making process.
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    2.  Design  flexible  planning  guidelines  for   water  quality  management  planning  in
       nonmetropolitan areas to make maximum use of existing planning institutional capabilities
       and on-going areawide planning activities.

    3.  Develop a coordinative  approach to water quality management planning throughout the full
       range of the intergovernmental decision-making process.

    4.  Promote a better understanding of the purposes and benefits of water quality management
       planning on the part of other Federal agencies, the States and substate district officials.

    5.  Provide increased  funds for water quality management planning in nonmetropolitan areas.

Substate Districts

The need  for  a  strong role for nonmetropolitan substate district agencies in the water quality
management planning process is summarized below:

       • Water quality problems in rural  areas are not receiving  adequate  attention through
       existing water quality management planning undertaken primarily at the State level;

       • Planning efforts and  priorities  at the State level are often geared to the pressing demands
       and problems of urban areas;
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       • Nonmetropolitan  substate district  organizations  are evolving as an integral part of the
       governmental structure in the great majority of States;

       • The planning and development activities being undertaken by them will have a significant
       impact on water quality management;

       • Conversely, the water quality management planning process, when fully implemented, has
       the potential to profoundly influence nonmetropolitan planning and development programs;

       • Although the concept of water quality management planning is not well understood, lack
       of  understanding stems in part from the failure of nonmetropolitan district agencies to  be
       involved in  the planning process; and

       • The  most effective method of analyzing  nonmetropolitan water quality management
       problems  and  linking  water quality  management  planning  to  other  planning  and
       development  activities  is  through the  active participation  of  nonmetropolitan district
       agencies in the preparation of areawide water quality management plans.

A Flexible Approach

Realistic recommendations  for improving water quality management planning in nonmetropolitan
areas must be based on a recognition that the current status of nonmetropolitan substate district
agencies varies greatly across  the country.  This uneven progress has  resulted in differences in
quantity and quality of their completed and on-going areawide planning efforts.
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To effectively implement the rigorous, technically oriented planning process required by EPA in its
Guidelines for Water Quality Management Planning, flexible approaches and planning requirements
need to be devised. Variables which need to be considered include:

       • the organizational status of nonmetropolitan district planning agencies;

       • the planning capabilities of nonmetropolitan district planning agencies;

       • the  required content of areawide Water Quality  Management Plans for nonmetropolitan
       areas;

       • timetables  for  meeting   water  quality   management  planning  requirements  in
       nonmetropolitan areas.

EPA's short-range objectives should be  to  directly involve nonmetropolitan  district agencies in
areawide water quality management planning. The strategy should revolve around an incremental
approach  designed  to support the building of their institutional capability. The long-range goal
should be the eventual achievement of realistic areawide Water Quality Management Plans for most
nonmetropolitan areas.

Improved Intergovernmental Coordination

The  need  for improved  coordination  at  all levels  is closely related to  the need for flexible
approaches to planning requirements. The survey found that national agreements between Federal
agencies do not assure that interagency coordination  will be accomplished.  The failure to date to
implement unification of the HUD-EPA planning requirements illustrates the  need for improved
communication and coordination at all levels.

Flexibility  in  Federal requirements  is  also  needed  to improve  intergovernmental  planning
coordination.  Since the several Federal agencies supporting  nonmetropolitan planning have their
own  areawide organizational and planning  requirements, as do  many  of the States,  planning
strategies  based  on  flexible  requirements geared  to the  problems  and existing  institutional
capabilities of nonmetropolitan district agencies need  to be worked out at the Federal Region and
Statewide levels.

Designing a Flexible Approach

The following considerations require examination in designing a flexible approach:

    1.  The overall mission and related planning and program priorities of the district agency;

   2.  The institutional capabilities and planning accomplishments of the district organization; and

   3.  The nature and severity of water quality problems in each nonmetropolitan district.

In assessing the overall mission and related planning and program priorities of nonmetropolitan
district agencies, particular emphasis should be placed on the impact their missions may have  on
certain  EPA  and HUD  organization and planning  requirements. The planning priorities  of
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nonmetropolitan  district  agencies usually involve economic development projects,  manpower
training,  and planning for the provision  of certain basic services,  both to serve as economically
disadvantaged population and to simulate economic development.

On the  other  hand,  the planning  priorities of  most  existing areawide planning  agencies in
metropolitan areas  reflect  physical planning  needs  related  to areawide  land-use, housing,
transportation and open-space planning.

As a consequence of these differences, some nonmetropolitan agencies, particularly those that are
underfunded and understaffed,  sometimes find  it  difficult to accommodate  HUD's planning
priorities, with their development-oriented missions. This problem can have a significant impact on
the accomplishment of  EPA's areawide  water  quality  management  planning  requirements in
nonmetropolitan  areas  since  EPA  now  requires areawide  planning  agencies  to meet  HUD's
organizational and planning requirements.

These problems can be illustrated through analyzing the difference in the objectives of functional
water and sewer planning between metropolitan and nonmetropolitan areas. The planning of water,
sewerage  and treatment facilities is seen  as a prime  tool  to control  and influence growth in
metropolitan areas.  Consequently, these functional planning efforts must be closely coordinated
with land use, transportation  and open-space planning.

Conversely, nonmetropolitan agencies often view planning for the provisions of water and sewerage
facilities  as a  prime  tool   to   stimulate growth.  Thus, functional   water/sewer  planning  in
nonmetropolitan  areas is often  tied closely  to  economic or  industrial development planning
accomplished through the OEDP  process. Detailed land-use planning is not a major  priority for
these areas, especially those with a sparse and scattered population.

On the other hand,  the capacity of planned waste collection and  treatment systems is significant in
the nonmetropolitan setting. To  both stimulate  and anticipate  future  growth,  nonmetropolitan
sewerage  facilities plans often provide for systems with capacities larger than needed to serve the
existing population. However, this "over-design" conflicts with  EPA's  cost-effectiveness planning
strategy.

A  final solution to  these problems cannot be provided for  in any framework for evaluating the
institutional capabilities of nonmetropolitan district agencies. Nevertheless, they must be taken into
account in devising flexible approaches to water quality management planning in nonmetropolitan
areas.
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                                VI. RECOMMENDATIONS
The findings and conclusions from the survey form the basis for a recommended approach by which
the Environmental Protection Agency can provide the  leadership  to bring about improved water
quality  management planning practices in  nonmetropolitan areas. Furthermore,  the  following
recommendations are designed to allow for incremental improvements in problem assessment and
planning capability.

It is recommended that EPA-OWP, in recognition of the potential of substate district planning and
development  agencies for institutionalizing  the  water  quality management planning process in
nonmetropolitan areas, lend all possible support and encouragement to State actions:

        1. Requiring  Nonmetropolitan  Areawide  Water  Quality  Management Plans for  all
          nonmetropolitan areas which  are served by a State-designated substate  district planning
          agency.

        2. Assigning responsibility  for  the  development  of Nonmetropolitan Areawide  Water
          Quality  Management Plans  to  officially designated substate  district  planning  and
          development agencies unless such action is clearly unwarranted.

To permit the varying levels of detail necessary to reflect the diversity of problems  and institutional
capabilities in nonmetropolitan areas, it is recommended that EPA-OWP:

        3. Establish flexible  planning requirements for  Nonmetropolitan Areawide Water Quality
          Management  Plans designed  to  insure realistic  consideration  of nonmetropolitan
          areawide water quality problems and maximum utilization of related planning activities.

To  reinforce  and  otherwise  support  the role  of substate  districts in  areawide  water  quality
management planning for nonmetropolitan areas, it is recommended that EPA:

        4. Correlate  the deadlines for  completion of initial Nonmetropolitan  Areawide Water
          Quality Management Plans with the availability of water quality  management planning
          funds and with implementation schedules established  in the water pollution control
          amendments of 1972.

        5. Include planning status and performance assessments in interim criteria for facility grant
          eligibility pending satisfactory completion of each district's Nonmetropolitan  Areawide
          Water Quality Management Plan.

        6. Prepare technical  handbooks  and other information on nonmetropolitan water quality
          problems for  use by substate planning agencies in developing Nonmetropolitan Areawide
          Water Quality Management Plans.

        7. Establish a nontechnical information and educational program to build understanding of
          the purposes  of, and the need for, cost-effective water  quality planning on the part of
          local officials.

        8. Encourage maximum involvement of State A-95 Clearinghouse agencies in all aspects of
          water quality  management planning.
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And finally, if water quality management planning is to be accomplished in nonmetrbpolitan areas
quickly enough to affect expenditures in the tune frame envisioned in the  water pollution control
amendments of 1972, it will have to be funded on an accelerated basis.

Therefore, it is strongly recommended that:

        9. Every  effort be made to  stimulate and fund water quality planning grant applications
          from State-designated substate district planning agencies.

       10. Federal  and  State  agencies  supporting water quality  related planning should  be
          encouraged to increase their technical and financial support for such planning, and to
          coordinate  their  implementation  timetables  and planning  requirements whenever
          possible.

RECOMMENDED ACTIONS

The following actions to implement the above general recommendations were designed to allow for
incremental  improvements in problem  assessment  and planning capability as  well as for  major
improvements should more planning funds become available.

Plan Content

To assure that nonmetropolitan areas are covered by areawide water quality management plans and
to avoid confusion over required plan coverage, it is recommended that the current language of the
Guidelines calling for areawide "Metropolitan I Regional" plans be changed to specifically require
areawide plans for Nonmetropolitan areas.

All Nonmetropolitan Areawide Water  Quality Management Plans should reflect consideration of
certain basic elements. The detail accorded each element should be appropriate to the extent of the
area's water quality  problems and their relationship to other area plans. The appropriate level of
detail should be determined in the design of the overall water quality planning program for the area.

The following  elements  should  be addressed  in every  Nonmetropolitan Areawide  Water Quality
Management Plan:

       • A  statement of water  quality objectives and how  they relate  to  areawide goals and
       objectives.

       • A  description  of the location, type and extent of  municipal, industrial and nonpoint
       sources of water pollution in the area.

       • A  description of existing physical systems for collection, transmission and treatment of
       waste water.

       • A description of the water resources within or available to the area.

       • A land-use inventory which identifies present urban concentrations, major use generators
       and trends,  major land uses  in  the nonurban areas and their  generators, and anticipated
       changes which would have significant impact on water quality management.

       • An economic and social analysis of the area which considers the size, economic base and
       present and anticipated growth rate of the area and its urban places.
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       • A statement of current water quality standards and identification of river reaches where
       these standards are not currently being met.

       • Estimates of volume, type and location of future waste inputs which would result from
       anticipated population, industrial and agricultural growth.

       • A statement of the strategy selected to achieve water quality objectives for the area based
       on  analyses  of  water  pollution  problems,  abatement alternatives,  cost  effectiveness
       considerations, area priorities and financial and manpower constraints.

       • A statement of the environmental impact of the alternative selected.

       • A statement of the extent of public participation in the planning process.

       • An analysis of the legal, regulatory and jurisdictional factors related to implementation of
       the areawide management plan.

       • A description of the procedures to be followed in updating the plan.

Planning Work Study Design. Whenever a Federal grant is  awarded  to support areawide water
quality  management planning,  a detailed  work study design  should be the  key mechanism for
coordinating interagency and  intergovernmental planning  efforts.  Its  preparation  should  be
undertaken as the first phase of the areawide plan and should be considered an eligible planning cost
by  EPA. The full grant award  should be  conditioned upon the grantee's preparation, and EPA
Regional Office approval, of the  work study design within sixty to ninety days after the initial grant
agreement has been signed.

The work study  design should also develop in detail arrangements for accomplishing each functional
component  of the  plan, including  specific provisions for interagency  cooperation  through data
sharing, staffing  support and joint  funding; and procedures for coordination among the areawide
agency, the State water quality  planning agency, the State Comprehensive Planning Office, other
State agencies, and Federal agencies conducting related programs. It should also spell out in detail
how areawide water quality planning efforts will be linked with previous or on-going HUD, FHA or
EDA-funded planning involving  land use,  water needs,  or  water and  sewer  facilities.  Particular
emphasis should be placed on  linking the areawide planning efforts with  on-going river basin
planning conducted at the State level.

Finally, the work study design should identify recognized sources of technical planning capability
available to the areawide planning agency such as SCS County Agents, Extension Service personnel,
Resource Conservation and Development agencies,  and State agency field personnel, and  describe
arrangements for utilizing these technical resources.

In short, the work study design  should establish clear channels of on-going areawide-State-Federal
communications  that remain functional throughout the period of the planning grant and beyond. In
many instances, it may be desirable to employ professional consultants to prepare the work study
design, through a subcontract with the applicant areawide planning  agency. To avoid any potential
problems with interagency conflicts, the consultant  should perform the role of neutral arbitrator in
resolving problems concerning who  does what, when, where and how throughout the period of the
planning grant.

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 Planning Responsibility

 To achieve maximum  effectiveness, nonmetropolitan substate district agencies must have a direct
 programmatic role in water  quality management planning. This  is particularly necessary  since
i pollution control problems in  rural areas are often substantially different from urban problems and
 can best be examined at the planning level closest to the problems, in conformity with the overall
 strategy set by the State.

 It  is  therefore   recommended  that State-designated  substate  district agencies  be assigned
 responsibility for development of Nonmetropolitan Areawide Water Quality Management Plans for
 their  respective  areas  unless it  can be clearly  demonstrated that some other agency should be
 assigned the responsibility.

 Since requirements for  comprehensive or coordinative planning and organizational arrangements
 vary among Federal agencies  supporting nonmetropolitan planning, and since  several States have
 their  own  planning and organizational requirements for substate districts,  EPA should adopt a
 flexible  approach to  unification  of  Federal  planning requirements  by  requiring  only  that
 nonmetropolitan agencies designated as responsible for water quality management planning be the
 official substate district organization and the regional Clearinghouse designated pursuant to Circular
 A-95.  Where no  district agencies have been designated or organized,  this requirement should be
 waived and the nonmetropolitan areas covered in the appropriate river basin plans.

 In nonmetropolitan areas where full scale areawide water quality management  planning is supported
 by a  Federal grant, the areawide planning agency also will, in all probability, need to subcontract
 with  consultants,  or other agencies with recognized capabilities, for discrete  parts of the planning
 effort. In all cases, however, the  district agency  should play the key role in the development of the
 plan  through close monitoring of the consultant's progress,  and by providing the main inputs on
 areawide  goals  and  objectives,  economic  and  demographic  data  and  projections, and  plan
 relationships. The details for these arrangements should be spelled out in the work study design.

 Planning Coverage

 It is recommended that EPA-OWP modify agency guidelines and directives relating to water quality
 management planning to require that a  "Nonmetropolitan Areawide Water  Quality Management
 Plan" be prepared for all areas outside SMSA  boundaries served by a State designated substate
 district planning agency. An  exception would  be a small nonmetropolitan  area included  in the
 Metropolitan Water Quality Management Plan  for an adjacent SMSA. Those areas not presently
 served by  a substate  district agency should be  included in appropriate detail in river basin plans
 covering the area.

 The geographic scope of sub-area water quality management plans should  be worked out  on a
 district-by-district basis instead of relying solely on HUD designated APIs. The survey found that
 APJs  and  substate districts  are often  not coterminous.  However,  if  areawide  water quality
 management planning  proceeds on  the basis of officially delineated substate districts, where district
 organizations  have been established,  the geographic  scale and  organizational  arrangements for
 planning sub-areas can  be worked out for each district.
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This procedure should allow for increased flexibility over the current approach which is geared to
HUD's planning certification procedures. The district agency would have prime responsibility for
establishing water quality management systems within the region. Initially, it would establish the
necessary organizational arrangements for developing  plans  for geographic sub-areas within the
district. For example, in some districts more detailed plans may be necessary for the larger cities
and  towns of the district,  while other planning sub-areas may need to be defined for rural areas
where nonpoint source problems are prevalent. In other districts, a unified plan may be required for
the entire area to include both rural and urban components.

In some  districts,  an  agency such as a county planning commission or water and sewer authority
may be delegated responsibility for preparation of a water quality management plan for a "Problem
Analysis  Sub-Area". In all  cases, however, the planning activity should be conducted under the
organizational umbrella of  the  substate district agency. After a management planning process has
been implemented for  the entire  area, the district agency's  prime responsibility would involve
coordination of the area's individual water quality management systems into a coordinated areawide
management system.

These determinations  should be reached  through consultation and negotiation among the district
agency, the State water quality planning agency and the  State Planning Office, and spelled out in the
planning work study  design phase of the plan's preparation. The EPA Regional  Office should
approve the planning  arrangements for each district by reviewing the work study design prior to
authorizing  further planning expenditures under the district's Federal water quality management
planning grant.

State Agency Role

It is recommended that EPA  require the  States to pursue the following general procedure to
implement water quality management planning in nonmetropolitan areas;

     1. Conduct an assessment of the water quality problems in nonmetropolitan areas throughout
       the state.

     2. Conduct an assessment  of  the planning accomplishments and capabilities of designated
      substate district planning agencies throughout the state.

     3. Identify the most critical water quality problems in nonmetropolitan areas and designate
       them for inclusion in a special problem analysis element of either a river basin plan or a
       Nonmetropolitan Areawide Water Quality Management Plan.

     4. Identify those  substate district planning  agencies which are  "ready" to undertake  the
      preparation of their Nonmetropolitan Water Quality Management Plan, and assist them in
      preparation of a  Federal planning grant application.

     5. Assist those substate planning agencies not yet "ready" to undertake formal preparation of
       their Nonmetropolitan  Water  Quality Management Plan in  identifying modifications  to
       current planning work programs which  can be accomplished (within current funding levels)
       to support the  development of a water quality management plan at some future time.
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     6. Establish a timetable for completion of current and anticipated planning programs which
       will  inhance  each  district agency's capability  to develop  an areawide  water quality
       management plan.

     7. Establish,  in  conjunction with  the EPA  Regional Office, planning progress indicators for
       each substate district to assist in determining EPA construction grant eligibility.

The  State water quality planning agency should be responsible  for coordinating these procedures
with the State comprehensive planning office and each substate  district director. In addition, close
communication should be maintained with the following agencies:

       • EPA Regional Offices

       • HUD Regional and Area Offices

       • FHA State Offices

       • EDA Regional Offices and State Economic Development Representatives in States where
       at least one EDD has been established

Assessing Capabilities

The  State Planning Office  (in conjunction with representatives  of State Departments of Local or
Community Affairs,  where  they exist as separate agencies) is the appropriate agency to prepare an
assessment of the current status of areawide planning in  each  State-designated nonmetropolitan
district. This assessment should provide the latest information concerning:

       • the  type  of areawide planning organizational  designations for each nonmetropolitan
       planning agency (EDD, NMD, LDD, COG, State-designated substate district,  RC&D, etc.);

       • the organizational progress of the State-designated district agency (staff, governing board,
       Clearinghouse designation,  functional committees, HUD  organizational certification, water
       quality planning designation, etc.);

       • the current and anticipated funding levels of the agency (EDA, HUD, FHA, State, local,
       etc.);

       • the current status of completed and on-going planning efforts (OEDP, statement of goals
       and  objectives, level  of HUD planning certification,  including  Land-Use  and Housing
       Elements, HUD and/or FHA water and sewer functional planning, etc.)

       • the sources of other technical assistance and planning support available to the planning
       agency (Rural  Development Committees, Extension Service, SCS, RC&Ds, Forest Service
       programs and personnel; and State field personnel, etc.)
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Assessing Water Quality Problems

More attention needs to be devoted in river basin and areawide water quality management planning
efforts to analyzing water quality  problems in rural  or nonmetropolitan areas, and to identifying
and examining alternatives for achieving water quality  objectives in these areas.

A functional water quality management planning process is a  particularly urgent  need in  those
nonmetropolitan  areas where  the existence of dispersed  water pollution sources often makes the
construction of additional waste treatment facilities an inefficient or infeasible alternative.

The  survey  found that such problems  as soil erosion, agricultural wastes and run-offs, subsurface
drainage,  and pollution associated with rural-based  industries  such as logging  and mining, are
receiving  practically  no  attention through  the  water  quality management planning process.
Correspondingly,  such alternatives  as joint disposal, improved soil conservation practices, disposal
lagoons for  agricultural wastes, aeration stabilization  ponds,  septic  tank maintenance, and natural
aeration  processes  are  also receiving little consideration in on-going water quality management
planning.

These problems should be examined through assessment of existing and potential water quality
problems  for  all  nonmetropolitan areas  in  each State.  This  assessment should  be  the prime
responsibility of  the  State water quality planning agency, and should categorize  nonmetropolitan
water quality problems in terms of industrial, municipal and nonpoint sources. The focus of this
effort  should  be the identification of significant water quality problems which prevail in each
nonmetropolitan district. (Further discussion of this assessment can be found in Appendix A.)

In preparing this  assessment,  the  State water  quality planning agency should  rely on existing
planning documents and supporting data that has been generated by each nonmetropolitan district
agency, and on  advice and  technical  assistance  from  such agencies  as  the SCS, Agricultural
Stabilization and Conservation Service  (ASCS), U.S.  Forest Service, local health  departments, the
Corps of Engineers, river basin planning commissions, and State agencies with responsibilities for
water supply, agriculture and natural resources programs.

Determining Planning Readiness

On the basis of these assessments, the State water quality planning agency, in conjunction with the
State Planning  Office and EPA, can  determine which district agencies are  "ready" to apply for a
Federal grant to  support areawide  nonmetropolitan water quality management  planning. This
determination should be based on:

       • The  existence  of special  water  pollution  problems  which should  receive priority
       consideration in the planning process and the delineation, where  necessary, of planning
       sub-areas within substate districts as "Problem Analysis Areas" where special organizational
       arrangements, accelerated planning schedules, or more rigorous and detailed water quality
       management plans need to be developed.

       • The extent of completed and on-going district planning  activities related to the  water
       quality management planning process.
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       • The availability of completed and on-going planning activities of other agencies within the
       district which may be related to water quality management planning.

       • Agreed  upon  modifications in  the  district  agency's  work program  that  can  be
       accomplished within current staffing and funding levels and which would contribute to the
       development of the district's Nonmetropolitan Areawide Water Quality Management Plan.

       • The availability  of other technical and planning resources to the district planning agency.

If the EPA Regional Office approves the State's determination that the district agency is "ready," an
application for a Federal  planning  grant should be prepared. If the district planning agency is not
considered "ready" by the State and the EPA Regional Office, or a Federal planning grant is not
available, the following steps should be taken:

       • The future planning activities to be undertaken by the district agency should be reviewed
       to determine their relationship to the  development of a Nonmetropolitan Areawide Water
       Quality Management Plan for the district;

       • Planning  progress indicators which will  be considered in determining EPA construction
       grant eligibility should be negotiated.

Establishing  Planning  Timetables.  These  progress indicators should be  geared to  timetables for
meeting Federal planning requirements, particularly those of HUD and EPA.  This schedule should
be based on a realistic assessment of when nonmetropolitan district agencies will make the necessary
institutional  progress,  in  terms of organization, staffing,  funding  and accomplishment of basic
comprehensive and functional planning tasks, to undertake EPA's planning requirements.

The preparation  of schedules and  timetables for meeting Federal planning requirements  in
nonmetropolitan areas on a district-by-district basis can serve as an indicator for establishing EPA
and HUD policies concerning planning requirements and grant eligibility. This procedure, if based
on  a realistic assessment of the existing situation in nonmetropolitan areas,  will no doubt involve
waiving some of the EPA  requirements  for "fully developed" areawide plans  considerably  beyond
the current July  1, 1973 deadline.

Furthermore, if such a procedure is followed in each of the twelve Federal Regions, it will provide
EPA headquarters with a composite national picture of the current status of areawide planning in
nonmetropolitan areas and  the progress that can be expected  in  accomplishing  water  quality
management  planning for these  areas.

Delivering Technical Assistance. The States should also prepare a statewide program design for the
provision  of technical assistance  to  support  substate  district agencies  in  the development  of
areawide water  quality management  plans.  Emphasis should  be placed  on the  coordinated
management  of  all technical  resources  within  the  State capable of providing  assistance  to
nonmetropolitan district organizations. This program design should be the joint responsibility of the
State Comprehensive Planning Office and  the State water quality agency. It should identify sources
of technical  assistance from  Federal and  State agencies  and require substate agencies to  develop
coordinative  procedures and working arrangements for technical support from field personnel of
such agencies as  the Soil Conservation Service, the Federal-State Extension Service, the U.S. Forest
Service and the Corps of Engineers.
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Coordination of Federal Programs

To  support  the States and  their  nonmetropolitan  planning  and  development  agencies  in
implementing a water quality management planning process for nonmetropolitan areas, EPA should
continue to work toward improved coordination of the Federal planning requirements of HUD,
FHA and EDA, and in addition, should strengthen coordinative  procedures at the Federal Region,
State and areawide levels.

The following actions are recommended to further improve planning coordination.

       • EPA should recognize,  and encourage HUD to recognize, State designation of an agency
       for  substate district planning  purposes and for A-95  Clearinghouse responsibilities as the
       only requirements for areawide  organritional and coordinative planning certification for
       water quality planning in nonmetropolitan areas.

       • EPA should support a study to analyze in detail existing planning requirements of Federal
       agencies supporting  water quality related  planning in nonmetropolitan  areas to identify
       those planning activities which are useful to areawide water quality management planning.
       The study should also identify (1) commonalities in  terms of nomenclature, procedures,
       requirements and standards, and (2) differences among existing requirements which result
       from law, legislative  intent, basic agency  policy, as well as those which seem to result from
       agency preference.

       • EPA should help EDA design the environmental assessment element of the OEDP to be of
       maximum value to water quality management planning as well as to other environmental
       planning required by EPA.

       • EPA should encourage  its Regional offices to  work with HUD and the States to allow
       scheduling, where appropriate, of a water quality  management planning element as a phase
       of functional areawide water/sewer planning supported  through '701' grants.

       • EPA Regional offices should  work with  FHA  State offices and the States to build  into
       FHA planning grant agreements additional EPA requirements for water quality management
       planning.

Functional  Planning Requirements.  The study of FHA, EDA, HUD and EPA planning requirements
should be based on an analysis  of the specific planning activities  required by each agency for
functional plans related  to  water quality. These requirements, or planning inputs,  should then be
compared with completed plans  funded and approved by each agency on the basis of their  own
requirements.  Such a comparison of  planning  inputs  (requirements) and planning outputs
(completed plans) should help clarify the additional planning inputs EPA considers necessary for
adequate water quality management planning.

For instance, EPA planning  officials should examine EDA-approved OEDPs to determine if any of
the information developed  therein provides some basis for the development of a water quality
management plan. Once this determination  is made, EPA can work with EDA to determine  how
nonmetropolitan districts can build upon the information developed in their OEDPs to provide a
sounder basis for an  areawide water quality management plan at a future date.
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Since EDA is currently developing guidelines for the inclusion of an'environmental assessment as
part of the OEDP process, it is suggested that EPA aid EDA in developing these guidelines so that
they  can  be  of maximum  value  to  water quality  management'planning as well  as  to  other
environmental planning.

Improved coordination of EPA-HUD functional planning can'be'achieved by  scheduling a  water
'quality' management  planning element as part of HUD's areawide water/sewer planning. This
schedule should be negotiated among HUD and EPA Regional offices, the State Planning Office, the
State water quality planning agency and the district planning agency involved.  The, EPA  Regional
Office  should  play  a leading role in  this effort  by reviewing all  completed HUD  areawide
water/sewer plans for each nonmetropolitan area and all current Annual Work Programs for  those
district planning agencies receiving HUD  "701' funds. This review can provide  the basis for an
analysis of those water quality planning elements which have hot been adequately accomplished for
the area.

On  the basis  of this review and the  assessment  of planning institutional  capabilities and
nonmetropolitan water quality problems previously described, negotiations should be undertaken
with  HUD,  the  State Planning  Office,  the  State  water  quality planning  agency, and  each
nonmetropolitan district  planning staff, concerning a work plan for a water quality  planning
element.

It would be nearly impossible to  set forth a standard format for such a  water  quality  planning
element due to vast differences in  plan content of HUD-approved  functional water/sewer plans, in
the institutional capabilities  of substate district planning agencies, and in thp nature and severity of
water quality problems in nonmetropolitan areas. The advantage of this approach is that it provides
a flexible framework for dealing with this  diversity while at the same time accomplishing  at least a
portion of  EPA's areawide water quality planning requirements through the HUD '701' program.

EPA-FHA  planning should  continue  to be coordinated by building  water quality  management
planning requirements  into FHA rural water/sewer planning requirements. The survey revealed that
FHA officials in each  State were including certain water quality planning requirements into  FHA
grant agreements with  planning agencies in nonmetropolitan areas. The specifics of these  planning
tasks varied  depending on  the quality and quantity of available information and State Office
interpretations of FHA's grant authority.  In some  States, FHA rural  water/sewer plans  are
submitted  to the State water quality planning office  for review with respect to EPA's  planning
requirements. Recent FHA directives require this procedure to be  followed for  all FHA water and
sewer plans.

This type of Federal coordination can have a significant impact on accomplishment of at least some
of EPA's planning requirements in rural areas. EPA Regional Offices should continue to  maintain
close communication with FHA in order to improve the water quality aspects of FHA planning.

EPA Regional offices^  along with State comprehensive planning offices and water quality  planning
agencies, should also promote the  coordination of FHA and HUD areawide water/sewer planning.
Coordination should take the form of a single planning document, jointly funded, to meet  the
comprehensive planning requirements of both HUD and FHA. In other words, areawide  land  use
elements, population and economic studies, and goals and objectives ordinarily prepared to meet
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HUD's  '701' Areawide Planning Requirements should also be used to  satisfy  FHA and  EPA
requirements. In addition, whenever possible, HUD and FHA water/sewer planning should be timed
to coincide,  allowing the areawide planning agency to prepare a single areawide water/sewer plan to
satisfy both HUD and FHA requirements.

The cost of  developing the planning document should be shared by both HUD and FHA whenever
both agencies have awarded planning grants to the same areawide planning agency. The cost to each
agency should be prorated with FHA funding water/sewer planning for rural areas and communities
under 5,500 population, and HUD funding planning for the remaining urban areas in the district not
eligible for FHA funding.

These and other opportunities for interagency planning coordination should be carefully examined
by the  interagency committee working  to unify Federal  planning requirements for functional
water/sewer-water quality planning. Such an approach should enable EPA to work with HUD, EDA
and  FHA to  build on existing planning efforts  rather  than  requiring  the  States  and  their
nonmetropolitan  district agencies to ignore existing plans and begin developing an entirely new
planning process to meet EPA requirements.

Finally, efforts  to  unify Federal  planning requirements should also identify ways to present
planning incentives to district agencies and their member local governments. For instance, all four
Federal agencies  should work  to design planning programs which  provide for establishment  of
locally determined priorities through the planning process, and which give assurance that these  local
priorities will influence the setting of priorities by State and Federal agencies.

Strengthening the A-95 Process

To effectively involve nonmetropolitan substate district agencies in the water quality management
planning process and to improve Federal-State-areawide communication, it is recommended that
EPA and the States encourage maximum involvement of State A-95 Clearinghouses and/or State
comprehensive planning offices (SPOs) in all aspects of water quality management planning.

To more effectively employ the A-95  Clearinghouse process at the State and areawide levels, it is
recommended that EPA,  in  cooperation with  OMB, support a study to  develop  criteria and
guidelines which define and describe the optimal role of Clearinghouse agencies in influencing water
quality  management planning  in nonmetropolitan  areas.  Such criteria  and  guidelines for the
effective use of the A-95 process in water  quality management planning should  be based  on
evaluations of the experience  of State and nonmetropolitan Clearinghouse agencies in administering
the A-95 process. (See Appendix B for a more complete discussion of how the A-95 process can
strengthen water quality management planning.)

Planning Grants for Nonmetropolitan Districts

If water quality  management planning is to be accomplished in nonmetropolitan areas quickly
enough  to affect expenditures in the timeframe envisioned  in pending water quality legislation, it
will have to be funded on an accelerated basis. Therefore, it is strongly recommended that:
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       • Every  effort be made to stimulate and fund Federal planning grant applications from
       State designated substate district  planning  agencies for nonmetropolitan areawide  water
       quality management planning.

       • Federal agencies supporting -water  quality-related planning should be encouraged to
       increase their  technical support for such planning, as well as to coordinate their planning
       requirements and implementation timetables whenever possible.

In determining priorities for Federal  funding, EPA Regional offices should carefully examine all
nonmetropolitan  areas ori a State-by-State basis, relying on the assessments of district  planning
readiness and nonmetropolitan water quality problems.

In those nonmetropolitan areas with specific problems distinct  from the usual water quality
management planning problems associated with population  growth,  allocation of waste loads, or
opportunities for regionalization of municipal treatment facilities, EPA should consider funding a
"special  problem area study" on a  priority  basis.  Special problem area  amenable to  such an
approach might include pollution problems associated with  agricultural, surface mining or timber
production, solid waste disposal, outdoor recreation, or climatic and geological conditions. This
type of functional water quality planning could be  funded with a small Federal grant, or perhaps
through other EPA categorical grants for research and planning.

In addition, EPA should explore the possibility of joint funding with other Federal program agency
sources, such as SCS, the Corps of Engineers, ASCS, the U.S. Forest Service, or through cooperation
with university Water Resources Research Institutes receiving Federal research grants frorn the
Water  Resources Council. In some instances, EDA Technical  Assistance Grants can be  used to
examine  water quality problems in eligible areas where industrial development or expansion is held
back due to industrial pollution problems.

Recommendations for an Information Program

It is recommended that EPA  support the overall objectives of water quality management planning
by establishing a nontechnical information program designed to build understanding of the purposes
and need for cost-effective  water quality  planning and  to prepare  a technical  handbook on
nonmetropolitan  water quality problems for use by substate planning agencies in developing the
Nonmetropolitan Areawide Water Quality Management Plans.

State  and areawide agencies  should not continue to view water quality management planning as
another requirement that must be accomplished in an expedient manner in order to receive Federal
construction grants. Any specific recommendation  for improving or implementing water quality
management planning in nonmetropolitan areas must be supported by  a concerted effort on the
part of Federal agencies to inform the responsible State and local officials of the benefits which can
result from effective management planning.

C;' '-effectiveness is a difficult concept to  sell State and local governments accustomed to  working
with Federal categorical grant programs.  The existing system has promoted  an almost  universal
attitude of "grantsmanship"  whereby State and local officials attempt to maximize their Federal
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project  grants. However,  the States can  benefit from management  planning  by applying the
cost-effectiveness approach to State funds  budgeted to match  Federal construction grants under
Sections of P. L. 660.

The  States can  also employ an effective management  planning process to complement existing
regulatory and enforcement responsibilities of State water quality agencies. The survey produced
numerous examples of the need to link water  quality management planning with other on-going
planning and development activities at the State level. The most  obvious examples include planning
for industrial  development, housing, water and waste  disposal systems, outdoor recreation and
natural resource  conservation and development. If water quality management planning is not linked
now to planning for these and other related activities, the States will find their future policy options
for water quality management seriously circumscribed. The States must realize that if the present
trend of reliance on  regulatory controls and enforcement prevails, their  funding priorities will
continue to be geared to remedial solutions designed to maintain water quality standards.

Management  Planning  Problems in  Nonmetropolitan Areas. Officials  of most  nonmetropolitan
planning organizations  also need  to be convinced of  the desirability and necessity of their
participation in  the water quality  management planning process. They should  be aware of the
potential impact water quality management planning has on every aspect of their overall missions.
Many nonmetropolitan planning staffs do not realize the impact water quality considerations will
have on the future economic growth and development of the area, and the impact water  quality
management planning can have on many  of their current plans and programs.

In addition, nonmetropolitan planning officials need to recognize the implications of their failure to
develop areawide  Water Quality Management Plans.  If they  abdicate  their role in developing
areawide plans, water quality planning for their area will be accomplished, but by the State through
the required river basin plans. The prospects for achieving meaningful local inputs and for accurately
linking areawide  planning and priorities  with river basin planning will be seriously diminished when
substate district agencies do not have a major role in the planning process.

Finally, other incentives for planning need to be presented to nonmetropolitan planning agencies. In
essence, the need for comprehensive and functional planning has been sold to local officials on the
grounds that  areawide  goals and objectives  should be  determined at the local  level, and that
priorities  for  project  implementation  will be  locally  determined to  achieve  these goals and
objectives.

However,  the overriding  goal of water quality management  planning is the maintenance or
achievement of water quality standards which are set at a higher level of government-either State or
Federal. The  immediate  objective is  the  determination of cost-effectiveness of Federal  funds.
Although  local   funds   must  also be committed  to  support  project  costs,  priorities for
implementation  are not locally determined. In the words of one EPA Regional Office Planning
Chief:

       Implementation  schedules depend on basin  and interbasin priorities, local funding
       capabilities, State  assistance (if available)  and anticipated  Federal  revenues,
       primarily from Section 8 of P. L. 84-660 as amended  .... Water quality standards
       are  the initial basis for designing facilities  and a cost-effective implementation of
       Section 8 funds should be the focus of the planning process, (emphasis added)
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This type of planning function may be less difficult to sell to metropolitan planning staffs whose
overriding mission often involves the regulation and control of growth rather than the stimulation
of growth  and development. Even  in  these areas, however, the planning function, to be totally
effective,  must  make provisions  for  local  determinations  on planning strategies and  project
priorities.

Again, quoting from the same source on HUD planning procedures and objectives:

       Implementation periods (for HUD grants) are determined locally and are a function
       of local growth characteristics . .  . Typically, all communities  who have complied
       with the HUD functional planning requirements are of equal priority and funds are
       allocated until monies are unavailable.

There  is no easy answer to this dilemma. Clearly,  EPA planning must be concerned with broad
water  quality goals  for entire river basins, often at  the expense  of local priorities.  To develop
effective areawide Water  Quality Management Plans  for  nonmetropolitan areas, however, some
accommodation with local priorities needs to be made. Until local communities and their areawide
planning staffs feel they have at least equal influence with State and Federal agencies in a balanced
intergovernmental management planning  system, it is doubtful that an  effective  water  quality
planning process can  be fostered in nonmetropolitan  areas.

On the contrary, whenever local  officials and planning staffs view the planning  process as a tool
which  primarily benefits Federal and State agencies in making allocation  decisions within a larger
statewide, regional or national context, incentives for a realistic, locally oriented planning function
are removed and the planning process often becomes a sterile exercise in grantsmanship.
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                  Appendix A

Framework for Assessing the Character and Extent of
 Water Quality Problems in Nonmetropolitan Areas
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INTRODUCTION

The  nonmetropolitan  regions  of  the  nation have  the same water quality problems  as the
metropolitan areas. In addition, some water quality problems are inherent to nonmetropolitan areas
only. Unfortunately, because  of the dispersion of the problems, design and implementation of
effective water  quality control measures  is very difficult. The limited technical  and financial
resources of nonmetropolitan areas further complicates water quality management.

Along  with discharges from municipal  and industrial sewage plants, man's agricultural activities
increase the waste  load carried by  the waterways. Sediment loads are increased by failure to utilize
soil conservation techniques in the production of crops. Nutrients derived from native soils, crop
residues, fertilizers and livestock wastes  enter waterways and accelerate the eutrophication process.
Pesticide, fungicide and herbicide residues enter the water environment where they are concentrated
in the tissues of living animals.

Mineral resources  are extracted in some rural areas. Runoff from active  and abandoned mines
contains sediment  and chemical leachates which cause extensive problems in some areas. Some oil
reservoirs produce  large quantities  of saltwater (chlorides) along with oil and gas. Often, saltwater
escapes into streams causing appreciable problems.

Leachates from  septic tanks and  landfills  cause serious problems of a localized nature. Other
problems of concern to the nonmetropolitan area include sediment from construction and forestry
operations; thermal discharges  from power and  other industrial plants, and saltwater intrusion into
fresh water supplies.

These nonmetropolitan water quality problems must be assessed and considered as part of a  logical,
systematic water quality management planning process.

PLAN REQUIREMENTS

The  assessment of  water quality problems in nonmetropolitan areas must proceed in a manner that
permits incorporation of the assessment into applicable areawide water quality management plans.
Basically, these plans require the following coverage:

       • Objectives-statement of water use goals to be achieved.

       • Problem  Statement-analysis of the nature of the water pollution problems with regard to
       impact of water quality, geographic extent, social and  economic forces, waste loads and
       technical considerations for handling these loads, and rates of change in the problems.

       • Planning Premises-statement  of premises upon which the plan is based. This includes
       legislative  authority, local conditions, institutional  arrangements  and  problems,  and
       resources.

       • Alternative Solutions-analysis  of strategies to reach the stated objectives.
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       • Water Quality Management Strategy-presentation  of a strategy for achieving the water
       objectives based on an evaluation of the merits of the alternative solutions.

The framework described herein is primarily concerned with  development of information required
in the Problem Statement and the Alternative Solutions sections of the plan. In recognition of the
limited capabilities of most nonmetropolitan area staffs, emphasis is placed, on sources of technical
assistance for assessment  of nonmetropolitan  water quality problems and promulgation  of
alternative solutions to these problems.

FRAMEWORK FOR ASSESSING NONMETROPOLITAN  WATER QUALITY PROBLEMS

The  water quality  management  plan deals with the quality of water in  bodies  which  receive
pollution loads. All nonmetropolitan water quality problems  must be identified and evaluated with
regard  to their present and projected effect on stream quality. The basic factors to be considered
include:

       • Descripiton of planning area characteristics.

       • Identification of all pollution sources and determination of the quantity of discharge or
       waste load of each pollutant and present treatment  for each pollution source.

       • Assessment of the effect of each pollution source on the quality of .the receiving stream
       and a determination of the required degree of treatment.
                                                                    i
       • Alternative methods  for correcting water  quality problems and  maintaining  stream
       standards.

Planning Area Characteristics

The water quality management problems of a nonmetropolitan area are related to the growth and
economy of the  area. Pollution loads from municipal sewage  plants, industrial plants, construction
activities, and domestic sources increase if the area population increases. Intensified agricultural
operations  can  increase  sediment, nutrient and pesticide  levels  in receiving  streams.  The
socio-economic factors relating to growth and water quality problems of the area must be evaluated.
Specific tasks to be accomplished in this evaluation include:

       • Evaluation of population and economic trends and projection of anticipated population
       and economic growth. The rural farm and rural nonfarm population sectors  are of specific
       importance.

       • Description of the physical and natural resources of the area. The present and projected
       impact of resource recovery  operations on water quality problems  of the area should  be
       evaluated.

       • Evaluation of land-use  trends and factors affecting land  use. Many nonpoint pollution
       sources are strongly related to land-use trends (i.e., agricultural and mining sources). The
       effect of land use changes on these sources should be considered.
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       • Growth areas should be delineated. Existing or projected water quality problems due to
       municipal, industrial and individual-domestic waste loads should be evaluated.

Identification of Pollution Sources

All sources of pollution must be identified and evaluated with regard  to  their effect on  stream
quality. Specific items to be accomplished in this evaluation include:

       • Identification of all wastewater discharges including point sources and runoff transporting
       waste loads from areal sources.

       • Determination of the volume of quantity of discharge of  the effluent  and present
       treatment , for  each pollution  source.  This  determination is usually  very  difficult  for
       nonpoint sources. A determination of the areal extent of nonpoint sources and the degree to
       which these sources are controlled is needed.

Effect of Pollution Sources on Water Quality

An assessment of the effect of each pollution source  on the quality of the receiving stream and a
determination of the required degree of treatment should be made. An evaluation of stream quality
in the planning area is essential to determine the type and degree of treatment required. This data is
collected and evaluated during the course of the river basin studies. The low-flow characteristics and
assimilative capacity of the receiving stream dictate allowable waste loadings to maintain  stream
standards. Assignment of allowable waste loadings for the planning area should be performed by the
state water quality agency.

A comparison of present and allowable waste loadings with recommendations as to the degree of
treatment required to maintain stream standards is needed. The projected waste loadings over a 10
year period should also be considered. A degree of treatment is usually  not specified for nonpoint
sources. Rather, a technique for controlling discharges from the areal source is developed.

Few nonmetropolitan areas possess the staff capability required for proper analysis of their water
quality  management problems. Consultants  will  generally be utilized  for preparation  of water
quality  management plans. Numerous Federal, State  and local agencies are actively  dealing with
nonmetropolitan water quality problems. The  expertise  and financial resources of these agencies
should be utilized in developing a water quality management plan. Table 1 lists agencies which may
provide technical assistance in assessing water  quality  problems  of  particular importance  to
nonmetropolitan areas. Also listed are  agencies  which may  provide funds for control of these
problems.

Alternative Methods for Control of Water Quality Problems

In addition  to conventional municipal  sewage plants,  control of rural water quality  problems
requires  utilization  of  land-treatment measures,  stabilization  ponds,  controlled  agricultural
practices, flow augmentation and other treatment measures. Table 2 presents alternative  pollution
control  measures which can be implemented  for management of nonmetropolitan water  quality
problems. The water quality management plan selected for the area  must  include a cost-effective
combination  of  pollution control measures  which reduce the  waste loads sufficiently to maintain
stream standards.

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     Waste Load Source

Municipal waste treatment
 plants
Industrial waste treatment
 plants
Agricultural Operations

 Erosion and sedimentation
 Nutrient control (fertilizers,
 livestock wastes)
 Pesticides, fungicides, herbicides
         Table 1

       Technical Assistance

EPA--Water Quality Office
State Water Quality Agency
U.S. Army Corps of Engineers
Department of Interior-Bureau
of Reclamation
State Planning Office

EPA--Water Quality Office
State Water Quality Agency
U.S. Army Corps of Engineers
Department of Interior-Bureau
of Reclamation
USDA-Extension Service
        Forest Service
        Soil Conservation
         Service
State Department of Agriculture
U.S. Army Corps of Engineers
Department of Interior-Bureau
of Reclamation
Tennessee Valley Authority

USDA-Extension Service
        Forest Service
        Soil Conservation
         Services
State Department of Agriculture
State Water Quality Agency
EPA-Water Quality Office
Tennessee Valley Authority

USDA--Agricultural Research
         Service
        Extension Service
EPA-Water Quality Office
Department of Fisheries and
 Wildlife
State Department of Agriculture
State Water Quality Agency
      Sources of Funds
   For Corrective Measures

EPA-Water Quality Office
USDA-Farmers Home Adm.
Department of Commerce-EDA
Department of Commerce-EDA
Private Sector
USDA-Agricultural Stabilization
        & Conservation Services
        Farmers Home Adm.
        Soil Conservation Service
U.S. Army Corps of Engineers
USDA-Agricultural Stabilization
        & Conservation Services
        Farmers Home Adm.
        Soil Conservation Service
USDA--Extension Service
        Soil Conservation Service
U.S. Army Corps of Engineers
 (aquatic plant control)
Mining and Drilling

 Mining
Department of Interior-Bureau
 of Mines
State Natural Resources or
 Mining Agency
State Water Quality Agency
Appalachian Regional Commission
EPA-Water Quality Office
Department of Interior-Bureau of
 Mines
Appalachian Regional Commission
Private Sector
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      Waste Load Source

Mining and Drilling (Cont'd)

 Oil and Gas Recovery
Forestry
 (erosion, sedimentation,
  sawing wastes)
Private waste disposal systems
 (septic tanks, drain fields,
   privies)
Solid Waste Disposal
Building and Construction

 Highways



 Structures
Power Generation
 (waste heat)
   Table 1 (Cont'd)

           Technical Assistance
Department of Interior-Bureau of
 Mines
State Natural Resources Agency
State Water Quality Agency
EPA-Water Quality Office
USDA--Extension Service
        Forest Service
State Department of Forestry
Tennessee Valley Authority

Local Health Agency
State Health Agency
USDA--Soil Conservation
 Service
State Water Quality Agency

EPA-Solid Waste Management
 Office
State Solid Waste Management
 Agency
USDA-Soil Conservation Service
Department of Transportation--
 Federal Highway Administration
State Department of Highways

Local Planning and Zoning
 Commission

Federal Power Commission
EPA~Water Quality Office
U.S. Army Corps of Engineers
Tennessee Valley Authority
Department of Interior-Bureau
 of Reclamation
State Water Quality Agency
       Sources of Funds
    For Corrective Measures
Department of Interior-Bureau
 Mines
Appalachian Regional Commission
Private Sector
USDA-Agricultural Stabilization
        and Conservation Service
        Farmers Home Adm.
        Forest Service

USDA-Farmers Home Administration
Private Sector
EPA-Solid Waste Management Office

Department of Housing and Urban
 Development
USDA-Farmers Home Adm.
State Highway Funds
Entity Responsible for Construction
Private Sector

Power Generating Entity
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     Waste Load Source

Storm Drainage
Water treatment plants
Saltwater Intrusion
   Table 1  (Cont'd)

    Technical Assistance

EPA~Water Quality Office
Department Housing and Urban
 Development -Community
  Development
State. Water Quality Agency

EPA--Water Quality Office
State Department of Health
State Water Quality Agency

EPA--Water Quality Office
State Department of Water
 Resources
State Water Quality Agency
U.S. Army Corps of Engineers
Department of Interior-Bureau
 of Reclamation
USDA-Extension Service
        Soil  Conservation
         Service
       Source of Funds
   For Corrective Measures

Department Housing and Urban
 Development-Community
  Development
USDA-Farmers Home Adm.
Department of Commerce-EDA
USDA--Farmers Home Adm.
Department of Interior-Bureau of
 Reclamation
USDA-Soil Conservation Service
Private Sector
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                                                Table  2
            Waste Load Source

Municipal waste treatment plants
Industrial waste treatment plants


Agricultural Operations

  Erosion and sedimentation

Nutrient control
  (fertilizers, livestock wastes)
Pesticides, fungicides, herbicides
Mining and  Drilling

  Mining
  Oil and Gas Recovery
             Alternative Correction Measures

Closer regultion of existing treatment. Increased treatment
of wastewater. (advanced treatment, additional plants,
regionalization of wastewater  systems).  Relocation ot
discharge points. Spraying sewage on land surfaces.
Diversion from basin. Flow regulation. In-stream modification.
Control of wastewater quantities through planned  growth.

Water reuse.  Discharge to municipal system. (Same measures
as municipal  treatment  plants).

Sediment retention reservoirs. Protective vegetation. lined
drainage channels. Improved tillage methods. Contouring
and terracing. Soil stabilization with chemicals.
Maintenance  of buffer zones between cultivated or live-
stock containment areas and streams.

Establishment of fertilizer management and education program
to develop proper fertilizer application techniques.

Disposal lagoons  and holding  ponds for livestock and poultry
wastes.

Facilities for winter  storage of animal wastes. Disposal by
spreading in  the  spring.

Regulation of commercial sprayers.

Development of education programs  for controlled use of
pesticides.

Maintenance  of buffer zones and  windbreaks between
cultivated areas and  streams.
Land treatment and reclamation measures for erosion
prevention in mined areas.

Lagoons and settling ponds for solids removal.

Permanent or portable  chemical treatment  facilities.

Closing and sealing abandoned  mines.

Underground injection  of wastes into contaminated strata.

Capping and sealing old wells.
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      Waste Load Source

Forestry
 (erosion, sedimentation, sawing wastes)
Private waste disposal systems
 (septic tanks, drain fields, privies)
Solid Waste Disposal
Building & Construction
 (Highways and structures)
Power Generation
 (Waste heat)
Storm Drainage

Water Treatment Plants



Saltwater Intrusion
Table 2 (Cont'd)

                   Alternative Correction Measures

       Management of selected cutting and harvesting practices.

       Sediment retention structures.

       Protective vegetation.

       Vacuuming or mechanical clean-up of mill residue.
       Regulation and establishment of criteria for private disposal
       system installation and operation. Disposal of septic tank
       pumpage at municipal facilities. Use of small neighborhood
       sewage treatment facilities.
       Installation of leachate collection and treatment facilities.
       Regulation of landfill location and construction. Induced
       leaching at existing landfills to accelerate refuse
       decomposition.

       Temporary sediment retention structures. Maintenance of
       buffer zones between construction sites and streams.

       Mechanical or chemical soil stabilization. Sodding to minimize
       exposed soil surfaces.

       Installation of cooling towers.

       Off-stream storage.

       Low-flow augmentation.

       Temporary holding and settling structures.

       Discharge sludge and backwash to municipal sewage plants.

       Construction of lagoons and holding ponds for disposal.

       Regulation of fresh water withdrawal.

       Construction of recharge wells or reservoirs.
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                    Appendix B




The A-95 Process and Water Quality Management Planning
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The  overall objectives of water quality management  planning can be  supported and the role  of
nonmetropolitan  district  organizations  in  the  planning  process  strengthened  through the
involvement  of  State Comprehensive Planning Offices (SPO)  in  all  aspects  of water quality
management  planning.  On the  basis  of the  survey,  a broad framework for increasing the
effectiveness  of these offices and the A-95 process in water quality management planning can  be
identified.

Through their designation as State Clearinghouses  under OMB Circular A-95,  and through their
overall State  planning mission and  responsibilities,  SPOs can support  water  quality management
planning objectives by:

       • improving coordination of related functional planning;

       • improving the linkage between functional planning and State and areawide comprehensive
       planning; and

       • supporting the integration of water quality management plans into  State Program Plans.

The survey indicated that SPOs have the potential to vastly improve the water quality management
planning process. Clearinghouse  personnel are usually experienced, highly  motivated professionals
who,  due to the nature  of their responsibilities,  are knowledgeable of all the implications and
subtleties involved in establishing an effective water quality management planning process.

However, Clearinghouse personnel are often  hampered  due to the absence of statutory authority
and State plans  and policies to  support the  Clearinghouse role. In addition, State Clearinghouse
agencies are usually so understaffed and underfunded  that they cannot adequately perform all the
responsibilities involved in administering the A-95  process as well as  the other components of a
State planning  function.  The  failure of the States to  develop  State  plans and  policies and the
shortage of staff and funds necessary to effectively administer A-95, can be partly resolved through
increased financial support to Clearinghouse agencies from State and Federal sources.

The lethargy  sometimes evident in the administration  of A-95, which results, in part, from the lack
of statutory  authority  for and political  support  of the review and  comment  process, can  be
alleviated through the legitimatization of the  SPO's role in all aspects of water quality management
planning. To date, the involvement of SPOs in water quality management  has not been heavily
promoted in many States. If a  conscious but low-keyed effort is made to activate SPOs in the
planning process, this lethargy  will largely disappear. As "trouble shooters" in matters related  to
water quality management, SPOs can vastly improve water quality management planning through a
role as conciliator, negotiator, technical advisor and promoter of cooperation and coordination.

SPOs, through their Clearinghouse and general State planning functions, can play a key role both in
implementing and coordinating a management  planning process and influencing the outcome  or
result of the planning process on State programs  and policies. In the former instance, SPOs can
influence planning inputs to facilitate efficiency through the resolution of institutional conflicts and
through the avoidance of waste and duplication  of efforts. In terms of  overall outcomes which can
be influenced by  a coordinated planning process, SPOs must be involved to insure that planning and
policies are linked.
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Planning Coordination

The SPO's role in the management process should focus on planning coordination. Coordination
should  be effected  horizontally-or among related activities of State or Federal agencies-and
vertically-or between the different levels of government involved in an intergovernmental planning
and management system.

Horizontal coordination involves linking the various activities of State agencies whose missions
relate to water quality management; or the programs of Federal agencies such as FHA, EDA, HUD,
and EPA with a direct role in water quality management.

Vertical coordination involves linking the efforts of nonmetropolitan planning agencies, State water
quality  planning agencies and  the same Federal  agencies into a unified approach to management
planning.

The  crucial  ingredient  necessary  to  effect  this  "input"  or "process"  coordination  is  the
establishment  of routine and operational communication linkages. Many SPOs are now providing
the  necessary communication   between  HUD   and  nonmetropolitan  districts  through  the
administration of the '701' Comprehensive Planning Assistance Program. In one State, for example,
the SPO reviews all HUD water and sewer plans prepared by nonmetropolitan districts prior to HUD
approval.  This review allows SPO personnel to provide technical assistance to district planning staffs
concerning compliance with HUD's  requirements, and to communicate  to HUD the planning
objectives of district organizations and the problems that nonmetropolitan planning staffs must deal
with in  meshing HUD's planning requirements with areawide goals and objectives.

At the State level, horizontal coordination can be promoted by SPOs through the maintenance of
communication among State  water  quality planning agencies, health departments  and water
resources planning agencies to support  river basin water quality management planning.

Other examples identified in the survey where SPOs had worked to improve communication and
coordination in areas related to water quality management include the encouragement of HUD-FHA
coordination  of  water/sewer  planning grants,  and  communication between  nonmetropolitan
planning staffs and State water quality planning staffs concerning local planning inputs into river
basin planning.

There are other techniques that, through the leadership of the SPO, can be used to improve the
planning process. To support river  basin-areawide  coordination in the water quality management
planning process, SPOs can take the  lead  in organizing nonmetropolitan  water  quality planning
advisory committees composed of executive directors of district agencies. This kind of effort can be
augmented by the organization of State or  areawide technical task forces consisting of Federal and
State agency technicians to assist nonmetropolitan planning  staffs in developing areawide water
quality  management plans. Since, through their Clearinghouse role, SPOs are required to deal with
all Federal development agencies, they are in a good position  to promote this type of cooperative
arrangement.
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Federal agencies such as EDA should also support SPO efforts in the coordination of water quality
management  planning. When problems arise  over  HUD-EPA organizational  and  planning
requirements for EDDs, SPOs should be involved in negotiating an agreement.

Finally,  and perhaps  most importantly, the overall  goal  of  SPOs in regard to water  quality
management planning in nonmetropolitan areas should be directed toward strengthening the overall
institutional  capabilities  of  nonmetropolitan  planning  organizations  in  comprehensive  and
functional planning and in  the performance of Regional Clearinghouse activites called for in Circular
A-95. Through support of an overall upgrading of the planning and coordinative capabilities of these
agencies, SPOs will be in a position to promote a stronger role for nonmetropolitan district agencies
in the water quality management planning process.

Policy Planning

The  overall  goal of water quality management planning can be defined as a process to influence
policies,  priorities  and outcomes. This goal  implies a broader concept than the coordination of
inputs to assure efficiency and avoid  waste  and duplication. Here again, SPOs can play a major
supporting role.

The  key measures  for  achieving this outcome-oriented goal through the planning process involve
the development of State and areawide comprehensive plans and development  policies and the
integration  and accomodation of the  goals and objectives of functional planning into the  overall
policy planning process. To influence the ultimate outcome of water quality management planning,
it must be closely linked with land-use goals and policies for housing, development and conservation
of natural resources, transportation, and balanced economic growth and development.

The States, usually supported by Federal grants, are experimenting with a number of techniques to
help  formulate goals and  policies in these areas. For water quality management planning to be
effective, it must be linked,  from its inception  with these efforts. The survey identified  several
on-going efforts in the States that can help link water quality  management planning with State
policies for  growth  and development. Some of these efforts include:

       • State "regional" investment or development plans supported by  multistate regional
       commissions such as Appalachia, the Coastal Plains and the Upper Great Lakes;

       • The development, in one State, of  a statewide investment plan supported by a Technical
       Assistance grant from EDA;

       • Studies,  funded  through HUD  '701' grants, to support the  formulation  of  a  balanced
       metropolitan-nonmetropolitan growth policy in one State;

       • The implementation of a HUD-supported Demonstration Program to support planning
       and development activities in nonmetropolitan districts; and

       • The creation, in  one State, of a State task force to recommend a strategy for formulating
       State land-use policies.
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These and other  techniques can provide the basis for linking water quality management planning
with State and areawide comprehensive planning within an overall statewide policy framework for
balanced growth and development. For instance, if water quality management inputs are integrated
into the development  of statewide land-use  policies, future  policy conflicts may well be avoided
through the coordinated development of:

       •  The Section 7 State Program Plan;

       •  State priorities for Section 8 Construction Grants;

       •  State land-use policies, and

       •  River Basin and areawide Water Quality Management Plans.

Such a process would provide a role for the SPO  in setting priorities for Section 8 grants based on
its role in developing overall State policies for growth and development.

In short, EPA and the States should strive to involve State and areawide water quality management
planning agencies in  these efforts. Only through the active participation  of  State water quality
planning agencies, supported  and augmented by SPOs, can those responsible for water quality
management planning  influence,  and be influenced by, State policies which directly or indirectly
effect their mission.

The Clearinghouse Process

The formulation  of State and areawide plans and  policies related to water quality planning can also
be improved through a general upgrading of the A-95 process at the State and regional levels. Until
State water quality planning agencies  develop the necessary planning capabilities to relate water
quality  management planning to comprehensive planning, they will be totally dependent on their
relationship with  the State Clearinghouse to identify and analyze these linkages.

The only reliable communication linkage that now exists between State Clearinghouses and water
quality  management agencies is the review  and comment process  of A-95. However, the ability of
State Clearinghouses to adequately support State water quality planning agencies in linking water
quality  planning with comprehensive planning depends on the Clearinghouse's ability to deal with
the  technical aspects of water quality  planning.  To  effectively cope with  this level  of technical
detail, the State Clearinghouse must depend on the capabilities of Regional Clearinghouses and the
quality of their inputs through the PNRS and environmental assessment procedures.

The field survey  found that State Clearinghouses are relying on the environmental input process
instead  of PNRS to cope with the  secondary and long-range effects of projects related to water
quality. The requirement for an environmental input places the burden of proof on the applicant to
demonstrate that the proposed project will have no detrimental effects. Under PNRS, the burden of
proof is placed on the Clearinghouse, and without State plans, policies or laws to support adverse
comments on  project  applications, the Clearinghouses are  reluctant to take a  strong negative
position on the basis of hurried projections of the probable consequences of a specific project.
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 Futhermore, the environmental inpact statement is not a planning tool. It is usually prepared after
 planning for a project has been completed. At this point, whatever action taken as a result of the
 preparation of an environmental impact statement  will be negative. Either the project will  be
 disapproved, held up until certain problems are resolved, or approved after a significant amount of
 time and resources are committed to preparation of an environmental assessment which concludes
 that the project will have an insignificant impact on the environment.

 The  entire PNRS and environmental input  process can be  improved by requiring preliminary
 environmental assessments in the initial planning process. At  the  time project applications  flow
 through the  PNRS  procedure,  this preliminary environmental assessment  should be included.
 Regional Clearinghouses should review and,  if necessary, update the preliminary assessment. The
 State Clearinghouse should review the project through PNRS  to determine if this environmental
 review was satisfactorily performed by the Regional Clearinghouse and if any additional secondary
 or long-range effects can be identified.

 This procedure  has  particular implications  for water quality management planning. The  EPA
 Guidelines require environmental assessments to be included  in River Basin and  areawide Water
 Quality  Management Plans. All regional PNRS reviews of applications for Section  8 grants should
 include an environmental assessment based on the applicable water quality management plan. The
 State Clearinghouse should then review the  areawide environmental input and identify any other
 long-range or secondary effects through PNRS  early warning  procedures, as well as reviewing the
 project for consistency with the applicable river basin plan and the listing of annual priorities in the
 State Program Plan.

 Two problems must  be  overcome to improve the role of SPOs and the performance of the A-95
 process  in nonmetropolitan areas. The greatest threat  to unified  comprehensive and functional
 planning derives from the tendency of Federal agencies and their State agency counterparts to treat
 complex problems as a single problem with a single solution  in the form of the agency's  own
 program. EPA must strive to avoid this myopic approach to water quality management. The reliance
 on SPOs to play a key role in  water quality management planning within each State should lessen
 this threat.

 Correspondingly,  SPOs must make every effort to assure nonmetropolitan planning organizations
 that they understand their problems and support their planned goals and objectives for growth and
 development. The survey found that in some  States, nonmetropolitan planning staffs and officials
 believe that their problems and planning objectives are not receiving adequate attention and support
 in terms of State policies, priorities and funds. This is particularly true in States where problems
 associated with urban growth have taken priority. If nonmetropolitan planning agencies do not feel
 that they can look to their SPO  and State water quality planning agency for support, the prospects
 for  establishing  an effective water  quality management planning process in these areas will  be
 seriously diminished.
4U.S. GOVERNMENT PRINTING OFFICE:1973 514-153/194 1-3          75

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