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
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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.
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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;
i
• 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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