WQM FRAMEWORK MANUAL
U.S. Environmental Protection Agency
      Water Planning Division
    Program Evaluation Division

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CHAPTER          TITLE                                                  PAGE


                 INTRODUCTION 	 	     1

  1              PROBLEM ASSESSMENT 	     7

  2              STRATEGIES	    19

  3              WQM PORTION OF THE STATE/EPA AGREEMENT	    37

  4              WORK PROGRAMS	    49

  5              ASSISTANCE IN THE IMPLEMENTATION OF WQM PLANS
                 & EXECUTION OF WORK PROGRAMS	:   77

  6              EVALUATION OF PROGRESS 	    91

  7              IMPLEMENTATION INFORMATION SYSTEM (RESERVED) ....

                 APPENDICES

                   PUBLIC PARTICIPATION WORK PROGRAMS

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Introduction
Water Quality Management Program

Since 1973 the Water Quality Management  (WQM) Program has been an
evolving one.  It started as three  separate programs under Sections 106,
208, and 303(e) of the 1972 Federal Water Pollution Control Act amend-
ments.  In 1975 the planning under  Sections 208 and 303(e) was combined
and in May, 1979 regulations were published, formalizing the integration
of Sections 106, 208 and 303(e)  into the WQM Program.

The Water Quality Management Program is  one of several programs that
contribute to the achievement of the water quality goals of the Clean
Water Act including, "protection and propagation of fish, shellfish
and wildlife and provision of recreation in and on the water by 1983
wherever attainable..."  The relationship of the water quality manage-
ment program to the problem solving process is described in Chapter 4
of the Supplemental Water Quality Management Program Guidance for FY 1981
(June, 1980).

The certified and approved Water Quality Management Plan (authorized
under Section 208) forms the basis  of the Water Quality Management
Program.  The plan is a key aspect  of the management process, and is
intertwined throughout the process.  Information from the initial WQM
plans supplemented as appropriate with additional information from
monitoring, intensive surveys, etc. serve to identify additional
planning requirements.  The institutional and financial components of
the plans lay the groundwork for implementation of plan recommendations.
Evaluation of the implementation of the  WQM plan may lead to the
identification of weaknesses in-the program, the need for additional
208 planning to strengthen the program and to recertification of the
plan.  Areas which need to be strengthened should be incorporated into
the annual update of the State's five year problem solving strategy,
the State/EPA Agreement and the  work programs.  The work programs define

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activities necessary to develop the control programs to solve water
quality problems, carryout other WQM activities such as plan revisions,
monitoring, enforcement, permitting, management of the construction
grants and nonpoint source control programs and evaluation of the
performance of management agencies.

A comprehensive WQM plan directs a State action program that effectively
controls pollution problems from both point and nonpoint sources.  The
WQM Plan should identify control needs and any conditions to be included
in NPDES permits; should identify the regulatory and other programs to
implement the controls and the financing of control programs; should
identify the management agency(s) with adequate authority and capability
to implement the plan's programs; and should assess the environmental,
social and economic impacts for the following program elements:

          •    Total maximum daily loads and wasteload
               allocations;

          •    Dredge and fill programs;

          •    Nonpoint source control needs;

          •    Municipal and industrial needs;

          •    Urban storm water needs;

          •    Residual waste control needs;

          •    Water quality standards revisions; and

          •    Water conservation practices

Once certified and approved according to the process described in
40 CFR 35.1523, the plan becomes the official State program to solve
the priority geographical and categorical water pollutant problems.  As
part of the certification process the State assures that the plan will
be implemented and appropriate sections will be used for setting
permit conditions, nonpoint source controls, schedules of compliance
and requirements for municipal waste water treatment systems.  In
addition, Federal properties and facilities are required to be in com-
pliance with State, interstate and local substanstative and procedural
requirements included in certified and approved water quality management
plans.

The initial plans submitted during the three year planning period were
not comprehensive because the plans did not include programs to control
both point and nonpoint sources.  In the first phase (FY 73-75), area-
wide agericies concentrated on cost-effective municipal treatment
processes.  During this period, States conducted basin planning under
Section 303(e) of the Act using their own or 106 program funds.  The

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basin plans were used to set effluent limits, develop water quality
standards and rank municipal waste water construction treatment needs.
Following promulgation of the "130/131" regulations and opening 208
funding to States in 1975, 303(e) basin planning was to be integrated
with 208 WQM planning.

Many States opted to take over the planning for the control of nonpoint
source pollutant problems but did not integrate their 303(e) basin
plans with the nonpoint source program elements and develop a com-
prehensive water quality management plan.  A few States have updated
their basin plans as the point source element of their WQM plan.  The
plan will be taken through the certification and approval process
which raises the status of the 303(e) basin plans and makes them an
official part of the State's WQM program.

However, the primary gap in most of the WQM plans was the absence of
control programs for nonpoint source pollutant problems.  Therefore,
EPA is directing 208 funds toward problem solving projects designed
to identify cost-effective controls for nonpoint source problems.
At the same time, EPA is emphasizing the importance of moving beyond
planning to the implementation of control programs.  To be eligible for
208 funding in FY 80 and beyond, grantees are to define with the
Regional Office the implementation which is to occur over the next
year in order to be eligible for 208 funding the following fiscal
year (for "Significant Implementation Agreements," see 40 CFR
35.1533-3(b)).

As solutions to specific pollution control problems are defined and
programs to control the pollutant problems developed, the WQM plan
should be updated and taken through a similar certification and
approval process as the initial plan.  This is not necessarily an annual
requirement but is required as plan revisions occur and should be
included in State/EPA Agreements and State and areawide work programs.

In addition, the framework for State management of the WQM Program,
the Continuing Planning Process (CPP) description, should be revised
to reflect changes in State and Federal laws, State organization,
procedures and processes for developing and implementing solutions
to water quality problems.

In FY 81 and beyond, State and areawide agencies will move from non-
point source planning into management of nonpoint surce control
programs.  At the same time, EPA will shift its emphasis from
individual grant programs (e.g., 208) into a consolidated process
which combines all aspects of the overall problem-solving process.
The WQM program has made much progress in cleaning up the nation's
water and, in FY 81-83, will continue to fill gaps in 208 plans,
build an information base, and move to implementation of controls.
With adequate funding (at $50M per year), EPA anticipates completion

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of the 208 grant program in FY 83.  Without adequate funding, EPA
will request reauthorization of 208 funding to complete WQM planning.
To ensure WQM activities continue after FY 83, EPA has begun to develop
recommendations for a restructured WQM program, in conjunction with
the upcoming 1990 construction grants strategy.

WQM Framework

The WQM Framework provides a systematic approach for managing the WQM
program on an annualized basis.  The Framework prescribes an assertive,
style of management by which Regional Offices assist States exercise
their responsibility of coordinating local political action to transform
areawide plans into comprehensive water quality management programs.
The Framework provides the management structure to promote vigorous
implementation of WQM plans.  Although the configuration of the WQM
program varies in Regional Offices because of different organizational
alignments, the Framework is flexible enough to allow each Regional
Office to adopt the principles of the Framework and still meet its own  .
unique requirements.

The WQM Framework builds the foundation for an integrated WQM program
from the separate sections of the Clean Water Act (106, 208, 303(e))
and includes both the regulatory requirements and the demands of good
process management for the WQM Program as a whole.  The elements of
the WQM Framework include:

          •    Assessment of the water quality problems to
               be used to select the WQM program priorities
               and activities.

          •    Development of Strategies in which goals,
               objectives and priorities are set and a cohesive
               sequence of activities are defined to develop
               and implement solutions to the water quality
               problems.

          •    Development of the WQM portion of the SEA to
               document the mutual commitment of EPA and the
               State to solve priority environmental problems,
               based on water quality problem assessments
               and strategies.

          •    Development of work programs to identify and
               manage priority tasks to solve the water quality
               problems.

          •    Assistance by Regional Offices in the implementation
               of WQM plans and execution of work programs as
               the key to make the WQM process work - the
               development and implementation of WQM plans,
               effective and efficient administration of
               operational control programs and the improvement
               in water quality.

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          •    Evaluation of progress to keep management, planning
               and implementation moving in the right direction.

Figure I shows a timeline of the activities included in the WQM Framework.

Purpose of the Manual

The WQM Framework Manual serves as an introduction to the Water
Quality Management Program and as a guide to improve the management of
the WQM Program.  The Manual is written for Regional Office personnel
directly or indirectly involved in the program.  It describes the operation
and effective management of the program.  The loose-leaf format allows
Regional Offices to supplement chapters and appendices with procedures
and forms specific to the Region.

Each Chapter of the Manual discusses the activities required to manage
the WQM program and suggest ways to carry out the activities.  There
is also a description of the products to be completed and the criteria for
judging the quality of the products.  The appendices which correspond
to each chapter provide examples of the tools to manage the framework
element or includes analyses of innovative features of these tools.

Finally the Manual defines what is expected of the Regional Office in
managing the WQM Program.  It will be used as a basis of the WQM Pro-
gram Review of the Regional Office.

          Chapter 1:  describes the problem assessment and
          its use as the basis of WQM program activities.

          Chapter 2;  discusses how strategies are developed
          to plan State and Regional program activities.

          Chapter 3;  lists the activities in the preparation
          of the WQM portion of the State/EPA Agreement.

          Chapter 4;  focuses on the work program as an
          essential tool in the management of WQM program
          activities.

          Chapter 5;  explores the technical and managerial
          assistance to be provided or arranged for State
          and local agencies to carryout their work programs
          or implement the WQM plans.

          Chapter 6:  discusses the various types of evaluations
          which establish the feedback look to keep planning,
          implementation and management moving in the right
          direction.

          Chapter 7;  defines goals and objectives of an
          implementation information system to be piloted in
          FY 1981 for agriculture.

          Appendices

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                                                                      Figure  1
                                                                  WQM  FRAMEWORK
                                                               2 Year Time Line
                                                                                                                                                       -.l-t
                                                I
PROBLEM ASSESSMENT

  Monitoring Strategy Guidance  Issued

  Priority Federal Data Requirements Issued
  Incorporation of Monitoring Strategy Into
   Seat* 5-Year Strategy
  titled quartern Modifications to FY 82 303(b)
   Report Guidance
  R.O. Outdance on preparation  of  FY 62
   305 (b) Report*
  Assist States prepare FY 80 305{b) Reports
  FY 80 305(b) Reports Due
  Regional Overview of the WQ Problems Prepared

STRATEGIES

  HQ's Draft WQM 5-Year Strategy
  HQ'B WQM 5-Year Strategy Issued
  Draft R.O. Source Control /Fund Ing Strategy
  R.O. Source Control/Funding Strategy Issued
  R.O. Guidance for preparation of State
   5-Ycar Strategy
  Assist States prepare 5-Year  Strategy
  Sta ; 5-Year Strategy Finalized

UQM PORTION OP SEAs

  Annual Agency Guidance Issued

  Work with States to develop a SEA
  Draft SEAs Issued
  Public  Meetings Held
  SEAs Signed                                   |/fCO


WORK PROGRAMS

  Agency Appropriation
  VPD Work Program Published
  R.O. Issue Work Program Guidance
  States Provide Framwork for Areavlde 208
   Work Programs

  Draft Work Programs Due
 •206 P oject Proposals forwarded  to RQ
   for  cvltw
  State  have 65 days to comment on Areawlde
   208  roject Proposals
  R.O.  5 days to comment on Stace Work
   Prog ran a
  106 Work Programs Approved/106 Funds
   Obligated
  208 Work Programs FlnalU«d/208  Funds
   Obligated

ASSISTANCE

  Draft R.O. Ar,nlstance fork Plan
  Finally R.O. Amlsranc* Vork Plai
  Quarterly Rc[x>rt  on  CMntee Activities
  Mld-Y.-nr Kvaluxtlon
  RvaliinMon Of the Im|.lMi'-nt of Wf\ H.,n
at!

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Chapter  1
Problem Assessment
                              INTRODUCTION
 How should the  task of managing the 106 and 208 grant programs  and
 the WQM process be approached?  Start  by asking some questions. What
 are the water quality problems?  How serious are the problems?  Where
 are the problems?  What are the causes of the problems?  A water
 quality problem assessment should answer these questions.  It is the
 first step of the WQM process.

 The purpose of  the water quality problem assessment is to direct the "
 WQM program activities.  Whatever document is used as the "problem
 assessment" it  should be used by all Regional personnel.  Those
 working with States on Five Year Strategies, State/EPA Agreements and
 work programs or individuals preparing Regional source control  and
 funding strategies need a common starting point.  A major criterion
 for evaluating  the activities funded under WQM Program grants is
 whether the activities relate to solving either categorical pollutant
 problems or severe water quality problems in particular geographical
 areas that have been identified in the problem assessment.

 A problem assessment identifies, evaluates and prioritizes the  water
 quality problems.  The difference between water quality data and a
 problem assessment is the analysis and evaluation of the data that
 is in an assessment.  The problem assessment should include infor-
 mation on whether streams meet or will meet State water quality
 standards, goals or their designated uses and the appropriateness of
 existing standards and stream classifications.  Particularly important
 is the assessment of toxics problems and nonpoint sources of pollution
 and a determination of the relative projected pollutant loadings
 attributable to nonpoint sources versus point sources.  The assess-
 ment should also discuss current and projected pollutant abatement
 schedules as an element in the determination of future problems.

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One of the most useful parts of an assessment is the ranking or
prioritization of stream segments especially if the type, location
and severity of the contributing sources of the pollutants are identified<
Prioritization of stream segments or pollutant sources is done to
focus limited resources on solving the most critical water quality
problems first.  Ranking the priority stream segments and classification
of lakes simplifies the development of State Five Year Strategies
discussed in the following Chapter.  There are many different meth-
odologies for ranking water quality problems.  Whatever methodology
is used, Section 303(d) of the Clean Water Act requires priorities
for control actions to take into account the severity of the pollution
and the uses of the water impaired.  This requirement may be met by
including such factors as frequency and severity of violations and
the severity of the pollutant problem in terms of population impacted,
need for protecting the quality of the water for drinking, fishing,
recreation, etc.  It is recommended that the metholdology used, be
brought before the public for review and comment.

An assessment should also contain an evaluation of the effectiveness
of existing pollution control programs and recommendations for future
modifications to those programs.  As implementation of WQM plans,
nonpoint source control and clean lakes programs proceed, this
section of a problem assessment becomes more important.  WQM Project
Officers should direct States to evaluate nonpoint source control
as well as point source control programs.

The 305(b) Report (if prepared according to the March, 1979 guidance)
should be used to document the State's water quality problems.  It
should include the problem assessment of the State and areawide WQM
Plans.  State/EPA Agreements and work programs include an assessment
of the water quality problems as do Regional and/or State environ-
mental profiles.  These should be based on and consistent with the
305(b) Report.

The data collection and assessment activities that are eligible for
106 and 208 grants are identified in this Chapter.  The Chapter also
discusses the activities that WQM Coordinators and/or Project Officers
should become involved with to ensure the assessments are sufficiently
detailed to serve as a basis for the preparation of State Five Year
Strategies, State/EPA Agreements and work programs or program plans.
Guidance is provided on judging the adequacy of water quality problem
assessments as the basis of WQM Program activities.  Exhibit 1-1 is
a matrix showing the roles and responsibilities of Regional Office
personnel for the problem assessment activities.  Exhibit 1-2 shows
Regional Office activities in relationship to State and Headquarters
activities.

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                           DOCUMENT CITATIONS

Basic Water Monitoring Program, Revised May, 1978 (EPA 440/9-76-025)

40 CFR 35.1511.1, and 35.1537(d)

Guidance for State 305(b) Report Preparation, March 8, 1979

208 Project Selection Criteria for FY 81.  Information Memorandum:
INFO 80-69


                             POLICY SUMMARY

This section provides a summary of the current policy on funding data
collection and assessment activities out of 106 and 208 grants.

Each State is required by Section 106 of the Clean Water Act to con-
duct monitoring activities for surface and ground waters.  The components
of a State ambient water monitoring program are described in the
Basic Water Monitoring Program (BWMP) revised in May, 1978.

A critical criterion for determining the eligibility of assessment
activities for funding is whether the proposed activities build on
existing information.  There may be data available that have been
collected through State sponsored special studies and intensive
surveys, or by EPA and other Federal agencies such as the U.S. Geo-
logical Survey, Fish and Wildlife Service, other agencies in the
Department of the Interior, agencies in the Department of Agriculture,
TVA, Bonneville Power Administration or by interstate commissions
etc..  There may never be enough data for some, but limited resources
require a Project Officer to take a hard look before funding additional
data collection activities for the assessment of water quality problems.

Headquarters guidance stresses the need for improved toxics monitoring
capability.  There has not been enough emphasis on the identification
of toxics and their transport, fate and impact on our water ways to
control local "hot spots."

Except where otherwise determined by the Regional Administrator, State
water quality assessment activities are funded primarily by Section
106 grants.  Limited amounds of 208 grant funds may be used for
monitoring and sampling if tied to specific 208 projects that lead to
the implementation of controls.

Water quality assessments for water quality standards revision or for
Clean Lakes studies are not eligible for 208 grants.  Financial
assistance equal to 70 percent of the cost, up to a maximum of
$100,000, is available under Section 314 of the Act for each State to
classify its publicly-owned fresh water lakes according to trophic
condition and need for restoration or protection.

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                       WQM ASSESSMENT ACTIVITIES
 t
Although the preparation of a problem assessment is primarily a State
activity, EPA does have a role in problem assessments including
monitoring, evaluation and prioritization of toxic problems, supporting
intensive surveys, defining priority data requirements, assisting
States improve the quality of the 305(b) Reports and monitoring
strategies, and providing information from special studies such as
National Urban Runoff Program, groundwater and agriculture monitoring
and evaluation projects.

The 305(b) Report is the primary reporting mechanism for the State
water quality problem assessment.  If inadequate as a problem assess-
ment (particularly for toxic and nonpoint source problems), it should
be improved to meet the March, 1979 guidelines.

Although WQM plans, State Five Year Strategies, State/EPA Agreements,
Regional and/or Environmental profiles may contain adequate problem
assessment, States should integrate the various problem assessments
and review data from all relevant sources such as approved WQM plans,
303(e) Basin Plans, Clean Lakes Assessments, Open Dump Inventories
and Surface Impoundment Assessments and incorporate them into a single
water quality problem assessment that can be used as a basis of the
State's WQM program activities.  The 305(b) Report is the logical
source to document the water quality problem assessment activities
as the Report is mandated biannually and its preparation is funded
by the 106 grant program.  The 106 program plans (see Chapter 4)
should be carefully reviewed to determine whether the State has
included activities that will lead to the improvement of their 305(b)
Report and the State's monitoring program.

Timing

State 305(b) Reports are due to Headquarters April 1 of even numbered
years.  Recommendations for modifications in the State's monitoring
strategy and supplemental problem assessment activities need to be
made early in the fiscal year for States to use in preparing the
annual update of their Five Year Strategy, State/EPA Agreements and
work programs for the following fiscal year.  Priority Federal data
requirements to be included in the monitoring strategy should be
forwarded to States by February 1.

Coordination with S&A Division on Monitoring Strategies and 305(b) Reports

The most likely areas WQM Coordinators and Project Officers will
need to work with the S&A Division, the Waste Load Allocation (WLA)
Coordinators and the States to improve the State's monitoring strategy
is the Identification and assessment of toxics and nonpoint source
pollutant problems.
                               10

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Priority Federal data requirements, suggestions for intensive surveys
and other improvements in the State's monitoring strategy should be
agreed to in the Regional Office and communicated no later than
February 1 to enable the State to adjust its monitoring strategy
for the following fiscal year.

The lead responsibility for working with the States on monitoring
strategy is not critical.  It may be the Water Division, the S&A
Division or the activities may be coordinated through a water media
task force.  However, it is critical that WQM Coordinators and Project
Officers be knowledgeable of the monitoring activities and get involved
in setting priorities.  Are the locations of the Federal as well as the
State's water monitoring stations, the requirements of the Basic Water
Monitoring Program (BWMP), the schedule for compliance surveys, haz-
ardous waste sites investigations, intensive surveys known?  Has the
State completed its classification of publicly-owned fresh water lakes?
Intensive surveys are particularly important for construction grants,
toxics and nonpoint source pollutant control.  Nonpoint source
intensive surveys do not receive priority ranking in comparison with
intensive surveys for new facilities or permits although nonpoint
source pollutants may be included in wasteload allocation studies.

Priority data needs and recommendations for the location of intensive
survey(s) should be communicated to the S&A Division and/or the water
media task force.  Some States require assistance in the design and
conduct of intensive surveys.  Work with the S&A Division to ensure
States improve their capability to conduct intensive surveys.

The S&A Division should be involved in the development and review
of 208 funded assessment activities, particularly for quality assurance
controls.  They should also be involved in the review of completed
assessments.  It may be necessary to resolve inconsistencies among
the various problem assessments.  For example, if an areawide WQM
plan identifies nutrients as a major factor in the water quality
problems of particular stream segments and identifies agriculture as
the source, but the State 305(b) Report does not recognize agriculture
as the cause of the nonpoint source pollutant problem, the reasons
for the inconsistency should be identified.  In some cases the problem(s)
may be political — the importance of a particular industry such as
agriculture, mining, etc. in the State or in an area.  The State's
monitoring strategy should include data that will determine the
cause, the source, the severity and relative impact of any particular
pollutant source on the water quality.  The State monitoring strategy
is a key element in setting State priorities.  The 106 program
plans should identify activities to improve the 305(b) Report as a
water quality problem assessment.  There may also be a need to work
with the S&A Division and the States to improve the analysis in the
Report by providing examples of methodologies to make point versus
nonpoint source impact analyses.
                                 11

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Preparation of a Regional Overview of Water Quality Problems

Some Regions have found it useful to summarize the problem assess-
ments of their States and provide an overview of the priority problems<
The Regional. Overview of the water quality problems should include
elements other than water quality data.  Regional perceptions of the
major water quality management problems should be based on Regional
evaluations of the effectiveness of control programs, institutions,
etc.  The Overview is a valuable tool to use in the preparation of
the Regional,environmental profile to make the water quality portion
of the profile a more useful document.  The Overview is also an
essential component of the Regional source control and funding
strategies.  It provides the justification for allocating limited
resources to priority problems.

      GUIDELINES FOR JUDGING THE ADEQUACY OF A PROBLEM ASSESSMENT

This section lists criteria to determine the adequacy of the water
quality problem assessment as a guide for WQM program activities.
To assist the reader, Figure 1   should be used in conjunction with
this section to determine what needs to be done if there are
deficiencies found in the assessment.

You will want to determine if the water quality problem assessment:

     •  Includes Information from other assessments including 303(e)
        Basin Plans, WQM Plans, Clean Lakes classification, Open
        Dump Inventories, Surface Impoundments Assessments, special
        studies, intensive surveys.

     •  Contains data adequate to determine the full range of
        pollutant problems including the data elements identified in
        the Basic Water Monitoring Program, guidance on priority
        Federal data requirements, toxics.

     •  Identifies the nature and severity of water quality problems
        for each segment.

     •  Compares the water quality of each segment to the State's
        water quality standards/goals for that segment and identifies
        the uses impaired.

     •  Identifies groundwater problems and the probable cause(s).

     •  Identifies the source(s) of the pollutant problems.

     •  Identifies nonpoint pollutant sources and estimates the
        relative loadings of nonpoint source pollutants to point
        source pollutants.

     •  Identifies the priority of the segments based on the severity
        of the pollution and the uses of the water impaired including
        the population impacted and the need for protecting the
        quality of the water for drinking, recreation, fish, etc.
                                12

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                                                      Figure  1

                                        PROBLEM ASSESSMENT REVIEW CRITERIA
State WQ Goals, Standards,-
designated Uses
->[ Draft Problem Assessment
                                     Are other assessments——
                                     Included?
                                                I
                                     Contain data in BWMP?
                                     problems identified?
                                              V  I
                                     Are  priorit
                                                 es set?J
                                     Are priorities consist en6-5-
                                     with other assessments?

                                               'i
                                     Future impacts identified?-1
  -State Monitoring Program*
	BWMP and Fed'l
      Data Requirements
                                                                          -^Assistance  to  integrate
                                                                            assessments
-V-Methodology  to  prioritize
  categorical  of  geographic
  problems
 -^Identify/resolve
  inconsis tencies
                                                         H
 ->Revise problem  assessment
                                                                                                                  to  revise  mon-
                                                                                                               itoring strategy
i o
segment classification?
of problems?
WQS/designated uses?
vl

identified?
V t
r



k i* ^


                                     Is effectiveness ol
                                     control programs evaluated?

                                    | ADEQUATE PROBLEM ASSESSMENT*"")

*NOTE:  Changes necessary to have a completely adequate problem assessment may not  be  feasible within the time frame of
        reviewing a State's assessment.  Deficiencies should be noted and corrected actions  Included  in 106  program plan.

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•  Identifies and ranks categorical pollutant problems as well
   as identifies geographical areas where problems are concentrated,

•  Identifies and ranks pollutant problems or segments consistent
   with other analyses or problem assessments such as WQM plans,
   Five Year Strategies, State/EPA Agreements Headquarters
   ranking of toxic "hot spots;"

•  Identifies future water quality problems.

•  Evaluates the effectiveness of existing control programs.
                          14

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                                               EXHIBIT  1-1
                                 REGION ACTIVITIES:    PROBLEM ASSESSMENT (1)

ACTIVITY
DEVELOP MONITORING STRATEGY GUIDANCE
Review All Appropriate Problem Assessments
Become Familiar with State Monitoring
Activities
Meet with S&A and Determine Monitoring
Needed (Intensive Surveys) and Possible
Means of Meeting These Needs
[Jiscuss Regional Suggestions for
Monitoring Strategy with State Agency
Prepare and Send Guidance Letter to State
Aeencv
ASSIST GRANTEE DEVELOP MONITORING STRAGEGY
Review Letter with State Agency
Assist in Coordinating and Integrating
Monlrnrlng Arl-1 vl MPS
REVIEW MONITORING STRATEGY
Review Monitoring Strategy Against
Guidance Letter
POSITIONS RESPONSIBLE
D.D.





*





WQM
P.O.'s

*
*
*
^
*

*
*

*
WQM
TECH.
STAFF

S
S
v/







OTHER
PROGRAM
OFFICES

*


*
*

*
*

*

OTHER
FEDERAL
AGENCIES











TIMING
SEP


OCT
^

NOV

S/5'

DEC

<&

JAN

^^

FEB

•££.

^IAR

^

APR

 LEGEND
 * - Primary Responsibility
 /- Participate If & as appropriate
 D.D. - Division Director
 w - Water Division
£ - OIRPA
S&A - Surveillance & Analysis
WQM P.O.'s - 106 & 208 Project Officers
 or W.Q.M. Coordinators
WQH Tech. Staff - Environmental Scientists
 NFS Coordinators, WLA Coordinators,
 etc.
Other Program Offices -
 201, RCRA, Water Supply,
 etc.
Other Federal Agencies -
 USDA, USDI, TVA, EDA; .
 COE
(1) Regional Office organizational alignments differ; therefore lead responsibilities may not exactly track table.

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          EXHIBIT  1-1
(CONTINUED)
REGION ACTIVITIES:   PROBLEM ASSESSMENT
ACTIVITY
Define Regions Concerns with Monitoring
Strategy
Meet with Agency to Resolve Region's
concerns and Document Resolutions
DEVELOP REGIONS SUGGESTIONS FOR 305(b)
REPORT PREPARATION
Review Current 305(b) Report Guidance
and Previous State 305(b) Reports
Forward 305 (b) Report Guidance to State
Discuss Information and Analysis Needs
For 305(b) Report
Discuss 305(b) Report Preparation with
State Agency
ASSIST STATE AGENCY DEVELOP 305(b) REPORT
Work with State Agency to Ensure Needed
Information and Analyses are Included
in 305 (b) Report
DEVELOP REGIONAL OVERVIEW OF. WATER
QUALITY PROBLEMS
Summarize State Problems
Consolidate all States Priority Water
Quality Problems and Prioritize
Forward Assessment of' Region Priority
Water Quality Problems to Grantees
POSITIONS RESPONSIBLE
D.D.





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WQM
TECH.
STAFF













OTHER
PROGRAM
OFFICES
*
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*
*
*
*

*
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OTHER
FEDERAL
AGENCIES














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GUIDANCE AND
EXPLANATION OF
REQUIREMENTS
Provide Regions
guidance on:
. Basic Water
Monitoring Pro-
§ram
05(b) Report
Preoaratlon
riority Federal
data require-
raents
. Ranking of local
toxics hot spots
. Environmental
Profile
. Quality assurance
requirements
NURP, Agriculture
and Ground Water
data collection,
monitoring and
evaluations
activities
Provide States:
. Priority Federal
data requirements
. Suggestions for
intensive surveys
. Quality assurance
requirements



Provide local
agencies:
. System for Inclu-
sion of local
agencies' data
collection and
analysis
. System for parti-
cipation of local
agencies in spec-
ial studies and/or
intensive surveys
. Quality assurance
requirements





DOCUMENTS
PREPARF.D
. 305(b) Report to
Congress
. Basic Water
Monitoring
Program

















. Overview of water
quality problems
. Environmental pro-
file
. Status reports on
local toxics control



. Develop/ revise
monitoring strategy
. Prepare 305(b)
Report
. Integrate water
?uality assessments
rom 305(b) Report,
WQM Plans, Clean
Lakes assessments,
open dump inven-
tories surface Im-
poundments assess-
ments, Intensive
surveys] special
studies and HQ
ranking of toxics
not spots


DOCUMENTS
REVIEWED
AND EVALUATED
.' 305(b) Report


















. 305(b) Report &
other assessments
(review for adequacy
as a basis for
State 5 Year strategy.
SEA and work programs)
. Adequacy of monitoring
strategy
















ACTIVITIES TO BE PERFORMED DURING MONITORING AND PROBLEM ASSESSMENT
PREPARATION AND/OR REVIEW
PROGRAM
COORDINATION
AND INTEGRATION
Assist in coordin-
ation of activities
with:
Solid Waste
Drinking water
Enforcement
OWRS
OWPO














. Recommend inte-
gration of problem
assessments with
WQM plans, Clean
Lakes assessments,
open dump inven-
tories, surface
impoundment assess-
ments, special
studies, intensive
surveys
. Integration/coordi-
nation with agencies
preparing assessments











COORDINATION & IN-
VOLVEMENT WITH OTHERS
FEDERAL AGENCIES
Assist Regions, States
and Local Agencies
obtain data from appro-
priate Federal agencies

















Assist States and Local
Agencies obtain data from
appropriate Federal
agencies



Coordinate with:
. Local Agencies
. USDA
. TVA
. USDI (GS.BLM.WRDS
etc)









MANAGERIAL AND
TECHNIQUES
ASSISTANCE
Provide or arrange
for appropriate
assistance Intensive
survevs and:
. NURP data col-
lection activities
. Agriculture mon-
itoring, evaluation
& assessment
. Ground water assess-
ments











Determine need for
assistance to States
In developing:
. Monitoring
strategy
. 305(b) Report
. Integration of
pr"oi>'n assessment

























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-------
 Chapter  2
Strategies
                               INTRODUCTION
  Long  term strategies are an essential  component of the WQM program.
  A  strategy outlines the approach to  be used to solve priority water
  quality problems.  It defines not only what needs to be done but also
  how it will be done.

  The development of a strategy is a culmination of a process which
  focuses on defining what is to be accomplished each year to solve the
  water quality problems.  Goals, objectives and priorities are set
  and a cohesive sequence of activities  are outlined that maximize
  the use of resources to develop and  implement programs to solve the
  water quality problems.

  Strategies take time, imagination and  discipline to complete.  However
  once  completed, strategies expedite  the processes necessary to solve
  priority WQM problems.  A strategy shows that an agency is in control,
  knows what needs to be done and how  it will get done.  There is no
  more  effective document than a strategy in selling the WQM program
  to top management and legislators.

  Every year, in January, Headquarters publishes its WQM Five Year
  Strategy to assist Regions, States,  and areawide agencies and the
  participating public with program planning.  The Strategy is the
  document that directs the development  of WPD's work program, sets
  program and budget priorities and justifies to Congress, OMB, and the
  public that the WQM program has direction, is developing solutions
  to complex water quality problems, and is solving the problem.
                                  19

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Regional Offices should prepare nonpoint source control and funding
strategies to set priorities for the funding of activities and to
ensure effective control programs are developed, implemented, and
administered.  The content of these strategies is discussed later in
the Chapter.

States are to prepare and annually update (usually by March) a
strategy for controlling water pollution problems from point and non-
point sources.  Strategies are to emphasize solving particular
pollutant problems in specific geographic locations.  They are also
to address how the programs are to be managed.  Activities funded
with 208, 106 and 314 grants — such as planning, implementation,
monitoring, permitting, enforcement, and administration — should be
explained in terms of how these activities contribute to the solutions
of priority water quality problems.  The purpose of the State Five
Year Strategy is to direct the preparation of work programs and
program plans.

The Strategy Chapter lists the documents and policies which should
be consulted, the content of a State Five Year Strategy, Regional
Office involvement in the development of State Five Year Strategies,
and the development of Regional Office nonpoint source control and
funding strategies.

Exhibit 2-1 presents in matrix form the activities of the Regional
Office in the development of State Five Year Strategies and Regional
nonpoint source control and funding strategies.  Exhibit 2-2 shows
the relationship of Regional Office activities to those of Head-
quarters and the States.

                           DOCUMENT CITATIONS

40 CFR 35.1511-2

Supplemental Water Quality Management Program Guidance for FY 81,
June, 1980

National Urban Runoff Program, November, 1978

Agriculture Nonpoint Source Strategy, October, 1979

Water Quality Mangement Ground Water Stragegy, April, 1980 (Draft)

                             POLICY SUMMARY

The policy summary for State Five Year Strategies is excerpted from
40 CFR 35.1511-2.
                                 20

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              §35.1311-2  State strategy.
               (a] General. The State shall prepare
              and annually update as an activity
              under its work program a strategy for
              controlling water pollution problems
              bom point and nonpoint sources. The
              strategy delineates priority water
              quality problems (in relation to the
              seriousness of pollution) and activities
              to control these problems in a five-year
              time frame. The strategy shall address
              the problems, solutions and priorities in
              certified and approved WQM plans;
              other problems identified in the
              assessment process; and needs   '
              identified during management agency
              performance evaluation. The strategy
              may be used lo recommend revisions in
              WQM plans, and may be used to
              establish priorities for plan revision
              activities of areawide agencies. The
              strategy shall include:
             .  (1) Goals for a five-year period, and
              estmated costs of activities to control  "
              priority water quality problems;
               (2) An identification of governmental
              entities  expected to be responsible for
              conducting the activities; and
               (3) A summary of anticipated Federal
              and other funds for the strategy period.
  (b) Role of areawide agencies. Since
the State strategy is used in the Regional
Administrator's review and approval of
the areawide agency's work program
(see 5 35.1513-7), the State shall involve
each affected areawide agency in
development of the strategy, and shall
consider priorities suggested by the
areawide agency. The State shall
forward a summary of areawide
participation and State response to
comments received from areawide
-agencies to EPA with the strategy.
  (c) Submission. Each year, the
strategy should be submitted to the
Regional Administrator for review and
comment in time to provide guidance in
work program development and
assistance in negotiating the State/EPA
Agreement.            .     ^"
  (d) Integrated strategy. An integrated
strategy covering more than one EPA
program submitted under the State/EPA
Agreement may be used, if the Regional
Administrator determines the integrated
strategy meets the requirements of this
section.
                            FIVE YEAR STRATEGY CONTENT

The content  and  format of  & Five Year Strategy will vary depending  on
whether  the  Regional  Administrator  and/or the State wants  to develop
a  comprehensive,  integrated strategy and include  the  drinking  water
and solid waste  programs in addition to  the  208,  106,  201,  205(g)
and 314  grant programs.  At a minimum, State Five Year Strategies
are to  include:

            •   An  assessment and  prioritiEation of  the  State's
                Water Quality problems:

                -   The assessment  should be consistent with the
                    problem assessment  described in the previous
                    chapter.   The methodology used to select the
                    priorities is critical.   The selection of
                    priorities should result from a number of
                    different  considerations including:   the rank-
                    ing of stream segments and/or categorical
                    pollutant  problems  based on  the severity of
                    violations; severity of  the  pollutant impact
                    on public  health and the environment;  class-
                    ification  of publicly-owned  fresh water lakes
                    accorded to trophic condition; recommendations
                    of certified and approved WQM Plans (including
                                         21

-------
      those of areawi.de agencies); evaluations of
      operational programs and management agencies'
      performance; concerns expressed by the public
      and local governments; Headquarters annual
      program guidance; and the legislative mandates
      of the Clean Water Act.

   -  The priorities should be identified as speci-
      fically as possible.  For example, the priority
      pollutant problems may be identified in terms of
      a stream segment, lake, geographical area or
      for categorical pollutant problems (agriculture,
      urban runoff) where the impacts may be localized
      but occur in several areas of the State, the
      areas should be ennumerated to the extent possible.

•  Goals and objectives of the Five Year Strategy:

   The goals of the State Stragegy are to be compatible
   with the goals of the Clean Water Act and include the
   achievement of water quality standards or designated
   uses wherever attainable.  The objectives should be
   more specific.  What is the State to accomplish over
   the next five years — develop a state cost share
   program?  Reduce agriculture nonpoint soure pollutant
   loadings to the stream by 60 percent?  Eliminate toxic
   discharges to the stream?  The objectives set out what
   the State is to accomplish and therefore direct pro-
   gram grant activities.  Without clearly defined
   objectives set forth in a five year strategy, work
   program activities lack purpose or direction.

•  A discussion of the program activities:

   -  How are the problems to be solved?  What
      approach is to be taken and why?  This is
      an essential component of the strategy.
      The approach is the link between the
      objectives and the program activities.  Is
      the approach to include revision of the
      water quality standards, development of
      regulatory or voluntary control programs
      or, an evaluation of existing control
      programs?  The question you will need to
      ask is whether the approach is logical and
      appropriate given the nature and extent of
      the problem.

   -  Program activities should relate directly
      to the priority problems and be discussed
      along program lines.  For example, how will
      planning, permitting, enforcement, and
                       22

-------
administration relate to urban runoff,
agriculture or industrial point source
problems?  This is also applicable to
geographical priorities.  Major sources
of the pollutant problems (agricultural,
urban runoff, etc.) may be identified for
the particular stream segment, publicly-
owned fresh water lake or geographical area;
the approach is defined and then program
activities are tied to the development, imple-
mentation, administration of any number of
control programs necessary to solve the water
quality problems in that stream segment, lake
or geographic area.

The existence of or the need for additional
programs and control measures and how the
various control measures and programs will
be used together is another component of
the strategy.  Control programs for point
and nonpoint sources include administration
and enforcement of the NPDES and 404 programs,
pretreatment programs, administration of the
construction grants program, facilities
operation and maintenance, training, agri-
culture cost share programs, construction,
permitting and on-site disposal inspection
and licensing programs are but a few of
the programs States may use or develop to
control priority problems.  Proposed or
existing control measures should be des-
cribed in connection with the control
programs in the strategy and may include
BMPs, Regional facility planning, permits,
emergency response programs, Clean Lakes
projects, user charges and other techniques
and/or programs.

The planning section of the Strategy should
address those problems not covered in the
initial WQM plans or, based upon an
evaluation of the implementation of the WQM
plan other problems which are identified.
The big question is whether additional
planning is really needed or whether all the
necessary controls are available and only
administrative procedures need to be
developed?  If additional planning is
essential, the Strategy should propose pro-
jects for funding and show how the infor-
mation from the projects will be used to
                 23

-------
      develop comprehensive control programs.  Up-
      dated WQM plans will need to be taken
      through the certification and approval
      process.

   -  The Strategy should identify the agencies
      responsible for completing the activities
      or carrying out the program.  It is important
      for State strategies to incorporate the
      priorities of areawide agencies and identify
      areawide agency activities in terms of con-
      trolling a categorical and/or geographical
      pollutant problem.  Many programs require
      the cooperation of State, county, municipal,
      or Federal agencies.  For example, an area-
      wide planning agency may conduct monitoring
      and develop controls for on-site disposal
      programs; the State develops legislation to
      regulate on-site disposal systems; country
      governments enforce the program; and State
      and counties cooperatively develop methods
      of financing the control programs.  Other
      examples are Clean Lakes projects where
      municipal treatment requirements and NPDES
      permits must be in place and nonpoint source
      controls (BMPs) identified consistent with
      the WQM plan prior to receiving section
      314 phase I or phase II awards.  To assist
      land owners implement the BMPs USDA cost
      share and technical assistance programs need
      to be focused on priority watersheds or lakes.

   -  The Strategy should identify the cost of the
      activities and the year the costs and activities
      will occur.  Cost information should include
      the amounts to be obtained from 106, 201,
      205(g), 208 and 314 grants as well as State,
      local and other Federal sources.  Most States
      find the matrix format the simplist, most
      easily understood way of presenting the infor-
      mation.

   -  Where possible, alternative approaches and
      different levels of effort should be identified
      and analyzed in terms of the impact on resources,
      and the timing of anticipated results.

•  Public Participation

   The public participation requirements for the Five
   Year Strategy can be met by combining the public
   participation activities of the Five Year Stragegy
                       24

-------
             with those of the State/EPA Agreements and work           '
             programs.  It is important to remember that the
             public advisory groups required under 40 CFR
             35.1507 of our regulations should be involved in
             the early stages of developing the strategies.

           REGIONAL OFFICE INVOLVEMENT IN THE DEVELOPMENT OF
                       STATE FIVE YEAR STRATEGIES

This section of the Chapter describes the timing and activities of the
Regional Office in the development of State Five Year Strategies and
how the Regional Office should review the strategies.

The amount of time, direction and assistance Regional Offices need to
provide States in the development of a Five Year Strategy will depend
on a number of factors including:

     •  whether States have previously developed strategies in con-
        junction with both 106 and 208 grant programs;

     •  the quality of previous State strategies;

     •  whether new program initiatives are necessitated by changes
        in program emphasis (e.g., completion of control programs
        for agriculture and initiation of urban runoff program
        planning; or initiation of a toxic monitoring program);

     •  whether Regional source control and/or funding strategies
        have been developed and are accepted by the States; and       ;

     •  whether the Regional Administrator requires State WQM Strategies
        integrated with drinking water and solid waste strategies;
        the number of State agencies involved; and their relationship
        to one another.

Timing

Annual State Five Year Strategies are to be used as a basis of 208
work programs and 106 programs plans.  Depending on Regional Office
policy, the State Five Year Strategy may be included or referenced
in the State/EPA Agreement.  Five Year Strategies should therefore
be completed no later than the end of the second quarter of the fiscal
year (March, 1980 for FY 1981).

Prepare Guidance Letter

Based on a review of State water quality problem assessments, the
Regional Overview of the priority water quality mangeraent problems
and/or the Regional nonpoint source control strategy, there may be
elements that the Region wants included in all State strategies such
as the development of State agriculture cost share programs, con-
struction runoff regulatory programs or toxic monitoring programs.
                                 25

-------
To save time and energy and frustrations later on, early in the
process, Regional suggestions for the development of the strategy
should be discussed with the State.  Even for States that have not
yet developed a WQM Strategy, it is not as formidable a project as
might be expected.  All States participated in the Needs Survey.
Without much additional effort the State can develop an initial WQM
Strategy.  Other States found the Needs Survey so valuable that they
are designing their Five Year Strategy around the Needs Survey.

Following the initial discussions on the Strategy, a guidance letter
should be sent to the State outlining Regional Office expectations
for the Five Year Strategy including the priority problems to be
addressed.  The Region's procedural guidance such as formatting,
the timing of draft and final submittals, and review procedures, etc.,
should be included in the guidance letter.

Assist States Prepare Strategy

An area Project Officer should be actively involved in assiting a
State develop its Strategy is in seeking commitments from and defining
the roles of other Federal agencies.  Another area Project Officers
may need to assist is in reconciling areawide and State priorities.
Regulations require States to incorporate the priorities of areawide
agencies into their Five Year Strategy and to the extent possible
this should be done.

Review of State Five Year Strategies

Figure 2-1 (page 26) outlines the questions Project Officers should
think about in reviewing a State's Five Year Strategy.  Without
getting bogged down in too much detail, remember the purpose of a
Five Year Strategy is to provide a framework for solving priority
water quality problems and show how the pieces fit together.  If
after reading the Strategy you think the State is in control, knows
where it is going and has outlined a logical approach and sequence
of activities to solve the priority water quality problems, it probably
is a good strategy.

The State Five Year Strategy should come as no surprise to the Project
Officer.  However, there may be areas of the Strategy which need to
be strengthened.  The Project Officer and the State need to work
together to revise and strengthen the document.  The strategy should
be reviewed by appropriate Regional Office personnel.  It is the
State's "best shot" and should be factored into the program plans of
the Regional Office.

Some Regions incorporate the strategy into the State/EPA Agreements;
others, reference the document.  Whichever approach is used, the State
Five Year Strategy is to direct the development of WQM work programs
and program plans.
                                 26

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Problem Assessment, WQM	
Plans, Evaluations, public
concerns

Needs Assessment
                                                       Figure  2-1

                                          FIVE YEAR STRATEGY REVIEW CRITERIA
Draft Five Year Strategy|4-
Are goals
        1
                                       , oo
-_jective priorities set?—
                              Is there a methodology for selecting
                              priorities?
                                       ^ •&                   U
                              Are Nat'l priorities addressed?	
                              Are Nat'l priorities included?-
                              Is there a logical approach for each-
                              problem? «  ,
                                         ^r                       tt
                              Do activities relate to priorities?—
Are activities identified
program lines?
Do activities lead to or improve?-	
control programs?

Do activities remove conditions-	
to WQM plans?

The information transfer mechanisms
reported?
           ^                    »)
Are agencies identified that will	
carry out strategy?
                              Is year cost and activities to
                              occur identified?
                                        * +
                              Does strategy include at least
                              106 & 208?  ,
                                       Y ^                .,
                              Does strategy include public
                              response summary?
                                        1 4r                 »
                              Is strategy consistent with RO
                              with RO expectations?

                              ADEQUATE FIVE YEAR STRATEGY ~}
  RO's Source Control
  Strategy

—RO expectations of 5-
  Year Strategy


-^Revise Strategy
                                                               -WQM Five Year Strategy
                                                                Operating Year
                                                                Guidance
                                                                         ->RO TA and managerial
                                                                           assistance
                                             RO expectations for
                                             5-Year Strategy
                                           -^Provide RO source con-
                                             trol strategies
                                                                         -^Revise to resolve
                                                                           Inconsistencies
                                                                         -^Revise Strategy
                                                                              RO source control
                                                                           strategy
                                                                         -^Revise Strategy
                                           -^Coordinate RO activities
                                           •4Revise Strategy
                                           ->To RO exp. for 5-Year
                                             Strategy

-------
           REGIONAL NFS SOURCE CONTROL AND FUNDING STRATEGIES

A Regional NFS source control and funding strategy is the primary
management tool for Regional Offices to focus limited grant funds
and personnel on solving the most significant problems in those areas
where water quality is most adversely affected.  Regional agriculture
NFS control strategies are required, but, other nonpoint source
pollutant problems such as groundwater, on-site systems, etc., would
benefit from the development of Regional strategies and the identi-
fication of a cohesive sequence of activities that lead to the
implementation of control programs.  Preparation of funding strategies
in conjunction with NFS control strategies will maximize the use of
limited resources and provide the rationale necessary to make the
difficult funding decisions.

The content and format of the strategy will vary depending on the
type of strategy (agriculture, groundwater, on-site disposal, urban
runoff) and the magnitude of the effort necessary to develop operational
control programs.

Define the Pollutant Source and Scope of the Strategy

The first step in the development of a strategy is to define the
problem.  The Regional overview of the priority water quality manage-
ment problems is a start.  Is agriculture, for example, the major
source of the Region's nonpoint source pollutant problems?  What is
the magnitude and extent of the problem?  What are the beneficial
uses precluded because of the pollutants?  What are the pollutants-
sediment, nutrients (fertilizers, animal wastes), pesticides?

The next step is a survey of the State programs to determine what is
required to have fully operational programs implemented.  The questions
that should be asked are:

     •  Do the State programs address all or only part of the
        pollutant problems (e.g., sediment, when water quality data
        indicate that nutrient and potentially pesticides are also
        contributing to the water quality problems)?

     •  Do the States have a strategy and a logical sequence of
        activities identified which will lead to fully operational
        control programs?

     •  Have the States and/or Regional Offices evaluated the
        operational control programs, management agencies, BMPs?

     •  What type of control programs are in place or proposed —
        regulatory or nonregulatory?

     •  Are, or should national controls, e.g., TSCA be used to
        control the problem.

     •  Are the States'  approaches (such as a nonregulatory programs)
        working?
                                 28

-------
     •  Are there backup legal authorities if the nonregulatory
        approach fails to ensure compliance?

     •  Are the BMPs identified in the WQM plan being applied?

     •  Are there adequate information/education/technical assistance
        programs?

     •  Have financial management aspects been considered?  What
        arrangements are available, or have been made, to support
        the management/administration of the programs (i.e., State
        financing for conservation district staff)?  Do the States
        have, or are they working toward developing cost share
        programs of their own?

     •  Are other appropriate agencies, Federal/State/local/private
        programs acting on the priority problem areas?  Is there
        technical assistance support?

     •  Are there candidates for prototype projects (FMAP, ground-
        water, RCWP, silviculture, agriculture, monitoring and
        evaluation, or Clean Lakes projects)?

     •  Are there critical elements necessary for fully operational
        control programs common to all the States in the Regions?

An important factor to keep in mind when surveying a State program is
the political and institutional climate.  The manner in which a non-
point source control program was developed is a significant factor
in developing a favorable climate and the support needed to implement
the control program and apply the best management practices.  Early
and continued involvement of key publics — which depending on the
situation could be viewed as farmers, interest groups, local officials,
State legislators and State and Federal personnel — frequently
determines the success of the program.  Even though all the pieces
may be in place, without the support of key publics the program will
not be implemented.  A critical element of the Regional Strategy may
be the development of the support necessary to ensure the implement-
ation of the control programs.

Draft the Strategy

Once the survey has been completed and the information analyzed, the
requirements for fully operational control programs can be determined.
This is the starting point of a strategy, defining what needs to be
done.  Then how it will be done and how much it will cost can be
determined.
                                 29

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Involve other program offices, State, local and Federal agencies
impacted by the strategy in its development.  No one individual
develops and implements a strategy.  The best way to have those
affected by the strategy buy into and support the strategy is to
have them define their roles in the strategy.

Some other concepts to keep in mind in developing the source control
and funding strategy are:

     •  Problem identification has a low priority.  Most States
        identified at least the general sources of their nonpoint
        source water quality problems in their initial WQM plans.  A
        variety of planning techniques were used to identify those
        problems, ranging from sophisticated land use models to field
        examination.  In many States the information developed was
        sufficient to identify the critical problem areas.  Further
        problem identification studies and the development of pri-
        ority listings for every area in the State with agriculture
        problems are not necessary since implementation resources
        are likely to be only sufficient to initiate control programs
        in a few of the highest priority problem areas.  For other
        categories of nonpoint source pollutant problems such as
        urban runoff (except for the NURP projects) silviculture,
        mining, construction, etc. use good judgment.

     •  The initial planning process resulted in the development of
        numerous BMP handbooks and substantial amounts of information
        material such as brochures, slide shows, movies, etc.  208
        funds should not be used to produce similar material which
        would duplicate what has been produced previously.  Funding
        for material of this type should be limited to innovative
        approaches for which handbooks and other informational or
        educational material have not been developed.

     •  Technical and management assistance requirements of the
        States and the activities of the Regional Office in meeting
        those needs should be identified in the strategy.  Regional
        Project Officers are the key to assisting States in Imple-
        menting their NFS control programs.  The umbrella and
        individual agreements between EPA and Federal agencies should
        be used by Project Officers to focus Federal resources on
        State priorities.  Agencies in the U.S. Department of Agri-
        culture, U.S. Department of Interior and the Tennessee Valley
        Authority can effectively assist States with NPS control
        programs.

     •  The strategy should identify ways to develop better commun-
        ication among State water quality agencies, designated manage-
        ment agencies, and Federal agencies.  Methods of improving
        communication including work shops and advisory groups will
        be discussed in greater detail in Chapter 5.
                                 30

-------
     •  Training assistance is another key element necessary for
        designated management agencies to accelerate the implement-
        ation of controls (BMPs).  The type, number and participation
        in training work shops should be identified.

     •  Prototype projects are being used to excelerate implementation
        of control programs in areas with the most critical water
        quality problems.  Regional strategies should identify the
        potential for prototype projects.  Since financing is often
        the critical factor determining whether technical solutions
        are implemented, fiscal management analyses should be a top
        priority of the Strategy.  Through the Financial Management
        Assistance Program (FMAP) technical assistance is available
        from Headquarter's expert consultants.  The 208 planning
        agency or the designated management agency does not
        necessarily have to be selected as an FMAP prototype project
        to receive technical assistance. On a selected basis within
        existing resource constraints, technical assistance may be made
        available.  Headquarter's FMAP Project Officers should be
        consulted for ideas and suggestions.  The case studies and
        FMAP tools should also be consulted for ideas on innovative
        approaches other agencies have used.

        The USDA cost share programs and Title V Regional Development
        Commission funds are two examples of other Federal financial
        resources available to assist in the implementation of non-
        point source programs.  These and others should be sought out.

     •  The Strategy should identify the support other divisions,
        offices, and EPA organizational elements will provide whether
        in the form of grant assistance (106, 201, 208, 314, RCRA),
        contract funds, laboratory assistance for monitoring and
        evaluation, or Headquarters' technical assistance.

     •  The Strategy should identify the mechanisms that will be used
        to transfer the information and approaches developed to other
        States and agencies.  Workshops or Regionwide forums on
        particular problems are frequently used.  Regional Offices
        may also wish to consider using State and/or areawide agency
        personnel as consultants to other State or local agencies
        with similar problems.  Be innovative.

Review and Finalize Strategy

Don't hide the Strategy.  Make sure it is widely distributed not only
within the Regional Office but to State and areawide agencies, Head-
quarters, other Federal agencies and State Policy Advisory Committees.
The more interests involved, the more support there will be to imple-
ment the strategy within the Regional Office and in the States.
                                 31

-------
                                              EXHIBIT  2-1

                                REGION ACTIVITIES:   STRATEGIES

ACTIVITY
PREPARE STATE FIVE YEAR STRATEGY GUIDANCE
LETTER
Review Guidance
Develop Common Elements of Guidance for
all States
Discuss Suggestions & Expectations with
States
Prepare and Send Guidance Letter
ASSIST STATES PREPARE FIVE YEAR STRATEGY
Discuss Guidance Letter with States
Work with States to Determine Elements re-
quiring Technical and/or Managerial asst.
Coordinate and/or Provide Assistance in
Development of Strategy
REVIEW DRAFT STATE STRATEGY
Determine Need for Strategy Revision
POSITIONS RESPONSIBLE
D.D.


*
(w,o)

*
(w,o)






WQM
P.O.'s

*
*
*
*

*
*
*

*
WQM
TECH.
STAFF

^
^








OTHER
PROGRAM
OFFICES












OTHER
FEDERAL
AGENCIES











TIMING
SEP


OCT

NOV

DEC
m

JAN

^

FEB

H

MAR

APR

LEGEND
* - Primary Responsibility
•S~ Participate if & as appropriate
D.D. - Division Director
w - Water Division
£ - OIRPA
S&A - Surveillance & Analysis
WQM P.0/s - 106 & 208 Project Officers
 or W.Q.M. Coordinators
WQM Tech. Staff - Environmental Scientists
 NPS Coordinators, WLA Coordinators,
 etc.
Other Program Offices -
 201, RCRA, Water Supply,
 etc.
Other Federal Agencies -
 USDA, USD!, TVA,
 COE

-------
          EXHIBIT 2-1
(CONTINUED)
REGION ACTIVITIES:   STRATEGIES
ACTIVITY
Submit Comments to Project Officer
Prepare Regional Comments on State
Strategy
Meet with State and Review Regional Com-
ments; Document Meeting Results for Files
AGREE ON STATE STRATEGIES
Review Redrafted Strategy
Meet with States if Problems with
Strategy Still Exist
Assist in Revising Strategy if Revision
is Necessary
Incorporate Strategy into SEA As
Appropriate
DRAFT REGIONAL SOURCE CONTROL AND
FUNDING STRATEGY
Define Pollutant Source for Strategy &
Scope of Strategy
Review Regional Overview of WQ Problems;
Obtain Input from WQM, Project Officers
on Their State's Problems
Survey State Strategies to Determine
Problems & Proposed Solutions

D.D.







(w,o)




POSITIONS RESPONSIBLE
WQM
P.O.'s

*
*

*
*
*
*


S

WQM
TECH.
STAFF




^




*
*
*
OTHER
PROGRAM
OFFICES




^





--

OTHER
FEDERAL
AGENCIES




^







TIMING
SEP




OCT

%

NOV

f'

DEC

JAN

FEB

MAR

M

APR


-------
          EXHIBIT   2-1    (CONTINUED)




REGION ACTIVITIES:  STRATEGIES
ACTIVITY
Develop Ideas & Outline Strategy; Work
with Grantees & Appropriate State & Fed.
Agpnrlps
REVIEW AND FINALIZE REGION STRATEGY
Review and Comment on Strategy
Revise Strategy if Required
Forward Strategy to Appropriate State ,&
Federal Agency Personnel








POSITIONS RESPONSIBLE
D.D.
a.

(w%)

*
(w,o)








WQM
P.O.'s


^










WQM
TECH.
STAFF
*

^~
*









OTHER
PROGRAM
OFFICES


^










OTHER
FEDERAL
AGENCIES


•^










TIMING
SEP



OCT

NOV

DEC

^

JAN

FEB

MAR

APR


-------



(QUARTERS

3C
NAL OFFICE
REGIO
HL
°£

||
£


GUIDANCE AND
EXPLANATION OP '
REQUIREMENTS
Provide Regions
. State 5 Year Strategy
guidance
. National NPS Control
strategies
. EPA operating year
guidance
. WQM 5 Year Strategy
Provide guidance on:
. National priorities
to be addressed
. Regional initiatives
. Integrated strategy-
208, 106, RCRA, SOW


Provide areawide
agencies:
• Framework for State
5 Year strategy and
integration of area-
wide priorities into
State strategy



DOCUMENTS
PREPARED
. WQM 5 Year Strategy
. Naclonal NPS control
strategies
. National area by area
toxics control
strategy


. NPS control strategies
. Toxics control
strategies
»

. State 5 Year Strategy
and public respon-
siveness
summaries





DOCUMENTS
REVIEWED
AND EVALUATED
. Agriculture & other NPS
strategies reviewed in
conjunction with 208
project proposals
. Regional Toxics Control
strategies


. State 5 Year Strategies


Areawide agencies'
priorities for and comment
on State 5 Year Strategy



-
ACTIVITIES TO BE PERFORMED DURING STRATEGY PREPARATION AND/OR
REVIEW
PROGRAM
COORDINATION
AND INTEGRATION
Assist in obtaining:
. Commitments/ support from
ORD, etc., for activi-
ties related to proto-
type projects and
Regional strategies


Assist in coordinating and
Integrating:
. Other program offices
support of activities
in State 5 Year strategy
. At R.A. discretion WQM
strategy Integrated with
drinking water and
solid waste

. Obtain support of
appropriate State
agencies activities
Identified in 5 Year
strategy
. Integrate, if
appropriate, WOM
strategy with drinking
water and solid waste
COORDINATION & IN-
VOLVEMENT WITH OTHER
FEDERAL AGENCIES
Use umbrella agreements with
individual Federal agencies
to assist State and area-
wldes Implement WQM plans


Obtain comnitments from
other Federal agencies for
management and technical
assistance to support
State 5 Year strategies &
Regional NPS control
strategies

Obtain commitments
of and support for activi-
ties in 5 Year strategy




MANAGERIAL AND
TECHNICAL ASSISTANCE
Assist In Regional
source control
strategy, development


Determine need for
and provide as ap—
Fropriate assistance
or:
. State 5 Year
strategy develop-
ment
. Integrating area-
wide priorities
Into State strategy






-------
 Chapter 3
WQM  Portion of  the State/EPA Agreement
                             INTRODUCTION

 The State/EPA Agreement documents the mutual commitment of EPA and
 the State  to solve priority environmental problems.  The State/EPA
 Agreement  (SEA) process forces top management in the Regional Office
 and in the State to select and agree on which priority environmental
 problems to address;  to make the decisions and commitments necessary
 to solve the priority problems; and to evaluate how well the decisions
 and commitments are being carried out.  The purpose is to ensure that
 EPA grant  funds produce tangible results by maximizing the use of a
 variety of grant programs to solve priority environmental problems
 that separate grant programs can not handle alone.  The State/EPA
 Agreement  is an administrative mechanism to give EPA additional
 flexibility to integrate the grant programs and coordinate the
 delivery of services to the States.

 The State/EPA Agreement is also a vehicle States find valuable to
 integrate  and coordinate programs and activities kof different agencies,
 and/or organizational elements within a single agency, and to focus
 their programs on solving priority environmental problems.

 No subject is more sensitive with States than whether State/EPA
 Agreements are just another "vehicle" for imposing EPA's require-
 ments on the States.   The Agreement should be a result of a true
 negotiation between the States and the Regional Office.  Commitments
 are not just for the States to make.  Regional Offices must be
 willing to state, in specific terms, what they will do to help
 achieve the Agreement's objectives.
                              37

-------
All EPA programs are covered by the State/EPA Agreement, which means
that potentially additional resources and program authorities can be
used to solve priority WQM problems that 208 or 106 funds can not do
alone, such as the use of Clean Lakes projects to assist in the con-
trol of nonpoint source pollutants or the use of RCRA or SDWA funds
to attack groundwater problems.  That is why it is essential for
WQM Coordinators and Project Officers to become actively involved in
the process and agressively seek wyas to incorporate WQM priorities
into the State/EPA Agreement.

Because there is so much guidance on the activities, timing and
priorities in the SEA process, this Chapter discusses only those
aspects of the SEA process of particular importance to the WQM
program.  The Documents section lists the most recent documents and
only those that directly relate to the WQM Program.  The Policy
section includes policies related to the SEA process in general.

The content and suggested format of the Agreement are outlined and
the time frame for the preparation of the SEA is provided in this
Chapter.  The activities of Project Officers are included in the
text of the Chapter but are set forth in greater detail in Exhibit
3-1.  Exhibit 3-2 shows the relationship of the Regional Office
activities to State and Headquarters activities.

                           DOCUMENT CITATIONS

40 CFR 1507 funding for the State's WQM work program.

FY 80 State/EPA Agreement Guidance, February, 1979.

Annual Report State/EPA Agreement, October, 1979.

EPA Operating Year Guidance (FY 81), February, 1980.

Handbook for FY 81 State/EPA Agreements, February, 1980.

State/EPA Agreements — Administrator's Policy Statement for FY
81, February 28, 1980.

Supplemental Water Quality Management Guidance for FY 81, June,
1980.

                                 POLICY

General SEA Guidance

          •  Regional Administrators are to continue to
             make State/EPA Agreements a high personal
             priority.
                               38

-------
          •  Regional Administrators should stay personally
             involved in negotiating the Agreements and
             make sure States receive any help EPA can give
             them.

          •  State/EPA Agreements are to focus on those
             issues which need top-level policy attention.

          •  For FY 81 and beyond it is EPA policy that all
             EPA programs be considered for negotiation in
             SEA's.  Where possible, States and EPA should
             integrate activities to solve pressing environ-
             mental problems — problems which do not respect
             the boundary lines of EPA legislation or
             programs.

          •  State/EPA Agreement priorities and policy level
             commitments are to drive grant negotiations.
             Agreements are to include a section showing how
             specific grant activities contribute to achieving
             State/EPA priorities.

          •  Agreements are to reflect national priorities to
             the maximum extent possible.

                    CONTENT OF A STATE/EPA AGREEMENT

The key to SEA success is flexibility and accommodation of individual
State environmental problems and resource capabilities.  Keeping this
in mind, the Regions and States have flexibility in designing
an appropriate format for how priorities, work plans, grants, summaries,
and signature pages are incorporated or appended.  Regardless of what
format is used, the Agreement should deal with a manageable number of
priorities and should be streamlined so that it is useful to top
EPA and State managers.

The Agreements must have some uniformity of content to enhance their
use as management tools.  With this in mind, Agreements should include
the following:

          o  An executive summary (if the SEA is longer than 25
             pages).

          o  A clear identification of priority problems —
             Priority problems are to be based on problem
             assessment and multi-year strategies.  The WQM
             problem assessessment process and the State
             Five-Year Strategy will provide a clear identi-
             fication of the priority problem.
                               39

-------
•  Annual grant work plans, which may be
   appended — Once priority problems are
   selected, steps need to be taken to make
   sure that commitments are actually ful-
   filled.  This is done by using the State/
   EPA Agreement priorities and policy level
   commitments to "drive" grant negotiations,
   and by tracking how well the Regional
   Office and State are doing together in
   meeting the commitments made in the Agree-
   ments.  Grant work plans should be consistent
   with SEA priorities and implement the policy
   level commitments.

•  Documentation of tasks and resources needed
   to meet SEA priority commitments — Agree-
   ments are to include a section showing how
   specific grant activities contribute to
   achieving State/EPA priorities.  This will
   help meet both the management and coordin-
   ation goals of SEA by making sure that
   grant awards and cooperative agreements
   provide the resources needed to meet State/
   EPA Agreement commitments.

•  A description of public involvement — Although
   the States and EPA have principal responsi-
   bility for negotiating the Agreements, the
   involvement of the public and other interested
   parties is important to the development and
   implementation of the SEA.  Federal regulations
   require EPA and the States to (1) notify
   the public about the goals and scope of the
   Agreement; (2) provide information to help
   people participate in the Agreement process;
   and (3) schedule ample opportunities for
   participation.  Specific procedural require-
   ments for public involvement, including
   those for public meetings or hearings, are
   contained in the public participation
   regulations (40 CFR 25).  In addition to the
   general public, EPA and the States should
   work closely with regional planning and
   implementing agencies, as well as interstate
   agencies and local governments to agree on
   cooperative strategies, priorities, and
   responsibilities.

•  A procedure for management tracking — A
   general criticism of State/EPA Agreements by
   both States and EPA is that many commitments
                      40

-------
                in the Agreement are so loosely worded that
                tracking progress (verification of specific,
                measured steps toward the stated objectives)
                is difficult.  To help improve SEA tracking,
                Regions may wish to (1) give each program
                office a check list of SEA tasks and output
                dates for which it is responsible (this should
                assist in tracking commitments at all manage-
                ment levels; (2) use the SEAs as the basis
                for State/EPA mid-year reviews where commit-
                ments by EPA and the State are evaluated;
                and (3) assign State and Regional project
                officers to each priority.  In addition,
                priority commitments made in the SEAs should
                be tied to managers' performance agreements.
                In all aspects of the SEA process, top manage-
                ment must support and be held accountable for
                implementation and evaluation of meeting of
                the SEA commitments.  Where commitments are
                not being met, the Regions and States must
                take corrective actions.

   WQM COORDINATORS & PROJECT OFFICERS INVOLVEMENT IN THE SEA PROCESS

Work programs and program plans are developed at approximately the
same time as the SEAs.  No 106 or 208 grants may be awarded until
there is a signed EPA Agreement.  Therefore, it is essential to get
the State/EPA Agreement signed by October 1.

Timing

The following is a general calendar for FY 1981 SEA development.  It
is similar to the schedules in several Regions.
MONTH          ACTIVITY                           RESPONSIBLE PARTY

1979

October        Award FY 80 grants                 Regions

November       Initiative review of FY 80 SEAs    HQs/Regions/States
               to determine strengths and
               weaknesses

December       Prepare FY 81 SEA schedules and    Regions/States
               "scope of work" for development
               of SEA

               Review environmental problem       Regions/States
               assessments
                                   41

-------
MONTH
ACTIVITY
RESPONSIBLE PARTY
1980

January


February



March
April
May
June
July

August
September
Begin FY 81 SEA priorities
planning

Prioritize problems based on
problem assessments and State
5 Year Strategies

Prepare program priorities for
SEA negotiation based on Agency
Operating Guidance

Begin SEA priority negotiations

Issue public notice Re: SEA
development

Public meetings/workshops/
questionnaires for SEA
priorities

Mid-year review of FY 80 SEA

Complete SEA negotiations for
draft FY 81 SEA

Distribute FY 81 SEA draft
for review

Prepare summaries for public

Solicit public comments on
SEA draft

Final SEA negotiations

Complete FY 81 SEA, reflecting
public comments

Prepare public responsiveness
summaries and distribute as
appropriate

Sign FY 81 SEAs
Regions/States


Regions/States



Regions



Regions/States

Regions and/or States


States/Regions/locals



Regions/States

Regions/States


Regions/States


Regions or States

Regions and/or States


Regions/States

Regions/States


Regions/States



Regions/States
                                   42

-------
Develop Regional Position on SEA Priorities

State problem assessments, the prioritization of the State's water
quality problems, the State Five-Year Strategy, and national and
Regional priorities are the primary tools needed to select and
negotiate the WQM priorities for the State/EPA Agreements within the
Regional Office and with the States.  What really are the problems
— not just those activities being addressed by the WQM program?
Are there groundwater, toxics, acid rain problems which impact a
number of program areas?  Are there 208 planning activities which
could support the SEA priority problems?  What about 106 program
priorities?  Are there State WQM problems which track national
priorities that the State would be willing to address?  Are there
WQM related problems which should be included as a SEA priority?
What other program authorities need to be and can be focused on a
particular WQM problem?

Unless Project Officers take the initiative to propose priorities
for the SEA, prepare the analyses and justification, suggest approaches
and coordinate with other program offices, no one else will and the
WQM problems will not be addressed in the Agreement.  Since all
States have critical water quality programs which the 208 and 106
programs can effectively impact, the State/EPA Agreement should have
a WQM element which is either supported by other program authorities
or supports Regional Office SEA priorities.  The attention of top
management should be sought out — not avoided.  With the support
of the Regional Administrator, programs may move more quickly to
completion, stumbling blocks within the Regional Office may be
removed, and a sudden willingness to cooperate may be noted where
previously the typical response was "I'll get around to it" - next
month, next year, or, never.

Assist States Draft WQM Portion of SEA

Regional Office priorities should not come as a "surprise" to the
States as the SEA negotiations begin.  Whether by formal letter or
staff discussions the priorities of the Regional Office should be
discussed with the State.  The expanded SEA process requires more
coordination to ensure all appropriate State agencies are involved
in the negotiations and to the extent possible, ensure State agency
jealousies do not hamper the negotiation process.

An important component of the Agreement is the commitment that the
State and EPA make to meet the goals and objectives of the Agreement.
EPA in some cases has been justifiably criticized for not making
commitments other than awarding a grant.  The WQM Coordinator and/or
Project Officer should suggest areas of technical and managerial
assistance that (s)he can provide or arrange for the State.  This
will be discussed later in Chapter 5 of the Manual.
                                  43

-------
A major Agency priority for the State/EPA Agreement Is to strengthen
the State/EPA Agreement as a management tool.  In FY 81 a management
evaluation and tracking system is to be included as an integral part
of the SEA process and incorporated into the text of the Agreement.
Some Regions use the SEA as the basis of the mid-year review and
some States are using the SEA process as a tool to better manage
their own programs — even those that are not funded by EPA.

Review and Complete Draft WQM Portion of SEA

The review of the State's SEA draft should focus on the proposed
WQM related priorities and whether they are justified based upon the
problem assessment and Five-Year Strategy.  Do the State's priorities
reflect national and regional priorities, the priorities of the area-
wide agencies, if appropriate, or those identified in certified and
approved WQM plans?

It is important to keep on top of the SEA negotiations and the
priorities to be included in the Agreements as work programs and SEAs
are developed on approximately the same time schedule.  Since Agree-
ments drive grant negotiations, the SEAs must show how specific grant
activities contribute to achieving State/EPA Agreement objectives.

Assist States With Public Involvement Activities

Public involvement efforts have been disappointing in many Regions
and States.  How do you get people excited, educated and willing
to become involved?  The case study section of the Handbook for FY 81
State/EPA Agreements describes several successful approaches.  Four
principles prevail:

          •  Obtain early public involvement;  To maximize
             public participation and meaningful input,
             the public should be involved early and
             continuously in SEA development process.

          •  Use target groups;  Target groups have an
             established membership which can be used
             to funnel information and feedback to and
             from State and EPA officials.

          •  Use Regional and interstate agencies;
             Regional planning and implementing agencies,
             as well as interstate agencies, can be
             used to serve as prime contact points with
             local interest groups.  These agencies
             carry out activities which encourage public
             participation, such as establishing
             advisory groups and conducting meetings,
             hearings and workshops in conjunction with
             the State and EPA.
                               44

-------
          • . Consolidate/coordinate public participation
             activities;  Wherever possible, the States
             and Regions should combine the public parti-
             cipation requirements of the programs (such
             as water quality management and solid waste
             management) covered by the Agreement.
             Possible areas for consolidation and coordi-
             nation include advisory committees, public
             information programs, and public hearings or
             meetings.

Even though the Region's SEA Coordinator has primary responsibility
for the Regional Office's participation in public meeting(s) on the
Agreement, the WQM Project Officers should, if possible, attend the
meeting(s) with their State counter-parts.  The willingness of the
Project Officer to participate stimulates cooperation and the feeling
of "we're in this together."

In addition to the general public, project officers and States should
work closely with Regional planning and implementing agencies as
well as interstate agencies and local governments to agree on mutual
priorities and cooperative responsibilities.

Finalize Agreement

Recommended changes in the Agreement based on public comment on the
draft should be accommodated to the extent possible.
                                                             I
As the Agreement is finalized so too are the program plans, work
programs and the commitments EPA has agreed to in the SEA.  As in the
case of the Regional Office, those negotiating the Agreement for the
State may not be in the same organizational unit as those developing
the State 106 program plan or the 208 project proposals or the 314
application.  In the rush, it is too easy to forget to keep everyone
informed of what is happening or what has changed.  Therefore, it is
recommended that a "For the Record" memorandum be prepared by the SEA
Coordinator following each SEA negotiating session and be distributed
to all participants in the meeting as well as to those preparing the
program plans, project proposals for grant funding and implementation
assistance work plans.  Then, maybe all State and EPA commitments
will be documented and not lost or forgotten in the maze of paper.
                                45

-------
                                               EXHIBIT 3-1




                                REGION ACTIVITIES:  WQM PORTION OF SEA (1)

ACTIVITY
DEVELOP WQM PRIORITIES FOR SEA
Review Guidance
Discuss Suggestions and Expectations with
States
Meet with SEA Coordinator, Other Program
Project Officers & Others to Discuss
Suggestions and Expectations
Discuss WQM Priorities With State
Prepare Draft SEA WQM Content and Forward
Suggestions to State
WORK WITH STATES TO DRAFT WQM PORTION OF
SEA
Discuss WQM Priorities with State
Negotiate State, Region & HQ Commitment;
Document Commitments
REVIEW AND COMPLETE DRAFT WQM PORTION OF
SEA
Review Draft
POSITIONS RESPONSIBLE
D.D.





(w.o)


(w.o)

(w,o)
WQM
P.O.'s

*
*
*
*
*

*
*

*
WQM
TECH.
STAFF



v^




^


OTHER
PROGRAM
OFFICES



^




N^-



OTHER
FEDERAL
AGENCIES



v^







TIMING
NOV

)EC

JAN

FEE
-
1AR
%

APR
'4,

MAY

JUNE


LEGEND
* - Primary Responsibility 0 -
/- Participate If & as appropriate S&A
D.D. - Division Director WQM
w - Water Division

OIRPA
- Surveillance & Analysis
P.O.'s - 106 & 208 Project Officers
or W.Q.M. Coordinate
WQM Tech. Staff - Env
NFS Coordinators, WL
etc.
re
ironmental Scientists
A Coordinators,
Other Program Offices -
201, RCRA, Water Supply,
etc.
Other Federal Agencies -
USDA, USDI, TVA, EDA, .
COE
(1) Regional Office SEA development processes differ;  therefore not all lead responsibilities may  tract  the  table

-------
          EXHIBIT   3-1    (CONTINUED)




REGION ACTIVITIES:  WQM PORTION OF SEA (1)
ACTIVITY
Submit Comments Through SEA Coordinator
to State and Discuss with State
Meet & Resolve State or Region Concerns
Working with SEA Coordinator as Necessary
document results
Assist State Coordinate & Complete Draft
SEA in Conjunction with SEA Coordinator
ASSIST STATES WITH PUBLIC INVOLVEMENT
ACTIVITIES
Assist State Plan for & Participate in
Public Participation/Review Activities-
Document Public Meeting Results








D.D.
(w,o)

(w,o)









POSITIONS RESPONSIBLE
WQM
P.O.'s
*
*
*

*







WQM
TECH.
STAFF
V^
^
^









OTHER
PROGRAM
OFFICES
V^
^f
^









OTHER
FEDERAL
AGENCIES












TIMING
NOV

)EC

JAN

FEB
•iF.r

MAR
'

APR

MAY

JUNE


-------














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GUIDANCE AND
EXP' VNATION OF
REQUIREMENTS
. Provide Regions:
- Program Guidance
- SEA Guidance
- Operating Year
Guidance
- Case studies




. Provide State;
- Regional recommend-
ations for SEA










. Provide -Regioni State
recommendations for
SEA















DOCUMENTS
PREPARED
. Guidance




-


. Draft SEA










. Draft SEA
















DOCUMENTS
REVIEWED
AND EVALUATED
. Final SEA







. Draft and final SEA










. Draft and final SEA















ACTIVITIES TO BE F?RFW*tED TO&ING SEA PREPARATION AND70R REVIEW
PROGRAM
COORDINATION
AND INTEGRATION







. Develop Regional
Commitments
. Evaluate prior year SEA
progress & negotiate
improvement plans
. Negotiate State
priority commitments to
be Included in work
programs
. Consult with Assist,
Adra. R.A. on potential
conflicts between SEA
& National program
priorities
. work with State on
public participation
. Obtain public input &
negotiate with Region
responses to public
needs
. Negotiate State & Reglor
priorities & commitments
. Negotiate other State
agency commitments
. Evaluate prior year
SEA progress and
negotiate improvements
. Negotiate with Local
agency its priorities




COORDINATION & IN-
VOLVEMENT WITH OTHER
FEDERAL AGENCIES
. Provide forum for Infor-
mation exchange







. Meet to develop priorities
and potential assistance
. Integrate delivery of
services to states









. Identify opportunities for
integrating resources S
activities.
. Request integration ' .
coordination assistance
from Region
. Develop mechanisms to
integrate work programs









MANAGERIAL AND •
TECHNICAL ASSISTANCE
. Develop methods
to consolidate
and streamline
paperwork






. Streamline State
and Region SEA
development
processes
. Develop innovative
approaches to
integrate programs
to solve problems.
. Provide or arrange
for appropriate
assistance




. Identify assist-
ance requirements
























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PI


















-------
 Chapter  4
Execution  of Work Programs
Work  Programs
                             INTRODUCTION
 Work programs are the most important tool the Project Officer can
 use to manage the WQM program.  AH WQM grants require work programs
 as part of the grant application — they assure Federal dollars are
 used efficiently and effectively to solve priority water quality
 problems.

 Quite simply good work programs serve to stimulate a disciplined
 approach to managing the work to be accomplished by identifing the
 activities necessary to solve priority water quality problems and
 providing a mechanism to track whether those activities are being
 accomplished.  Work programs not only document grant applications
 but also serve as a basis for evaluating grantees.

 Work programs are to reflect the problem-solving emphasis of the WQM
 program. WQM grants are based on actual needs rather than on arbitrary
 formulas.  The priority problems addressed in the work programs should
 be those reflected in the problem assessments, prioritized in the
 State's Five Year Strategy and agreed to in the State/EPA Agreement.
 Project Officers must know what the agencies are doing and be able to
 judge the adequacy and the feasibility of achieving the expected
 results in relationship to the nature of the water quality problems,
 authority, organization and past performance of the agency(ies)
 involved and their resources.  Work programs are to stress quantifi-
 able objectives and outputs so that EPA, the public and the grantees
 themselves can access progress, oversee the accomplishment of the
 activities, and thereby manage the program.
                              49

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Work programs should not be overly long, obscuring important
objectives and outputs.  There are many types of acceptable work
programs — integrated work programs, non-integrated State subplans,
project level State or areawide work plans.  Integrated work programs
for all State and areawide agencies' activities are encouraged under
the State/EPA Agreement.

There are a number of systems management techniques useful in the
development and presentation of work programs.  These are outlined
in Chapters 4 and 5 of the draft Work Program Handbook for Water
Quality Management, August, 1980.  After review of the draft Hand-
book is completed the most useful techniques will be incorporated into
Appendix 4 to the Manual.

Included in this Chapter Is a summary of the documents and policies
to which Project Officers should refer before initiating the work
program development process, and a description of the content of work
programs.  The documents, activities and thought processes the Project
Officer needs to go through to assist agencies develop the type of
work programs Project Offices and the grantees themselves need to
manage the WQM program, are outlined in this Chapter.  Exhibit 4-1
summarizes the activities necessary in the work program development
process and Exhibit 4-2 shows the relationship of Regional Office
activities to those of Headquarters and the States.  Exhibit 4-3
lists the State WQM program fundable activities, Exhibit 4-4, 208
project selection criteria, and Exhibit 4-5 national 106 priorities
for FY 81.

                           DOCUMENT CITATIONS

Sections 106 and 208 of the Clean Water Act

40 CFR 35.1513; 40 CFR 35.1507; 40 CFR 35.1509; 40 CFR 25

EPA Operating Year Guidance, February, 1980

Water Quality Management Five Year Strategy, January, 1980

WQM Policy Memorandum A-2:"  FY 81 & 82 WQM Funding Policy - Section
106 and 208, June, 1980; Amendment, INFO: 80-89, July, 1980

208 Project Selection Criteria for FY 81, INFO: 80-69, May, 1980

Work Plan Guidelines for the Nationwide Urban Runoff Program, July 1976

Work Plan Guidelines for the WQM Advanced Treatment Planning Projects,
June, 1979

WQM Ground Water Strategy, April, 1980 (Draft)

Agriculture Monitoring and Evaluation Projects, April, 1980 (Draft)

Work Program Handbook for Water Quality Management, August, 1980 (Draft)
                               50

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                   POLICY SUMMARY

•  Draft work programs are to be submitted no
   later than June 1 of each year.  Comments
   are to be provided to the grantee within
   45 days of receipt of the work program.

•  The Regional Administrator shall not
   approve a work program unless satisfied
   that the applicant has provided adequate
   opportunities for interagency involvement
   and that the proposed work is in compliance
   with applicable requirements of other Federal
   programs.

•  FY 1981 106 program priorities include:
   building WQM capability, conduct priority
   waste load allocations, hazardous waste and
   toxic monitoring, environmental emergency
   response and pretreatment programs, State
   compliance and enforcement activities and
   protection of sensitive ecosystems.

•  The 208 program priorities emphasize the
   development of implementable nonpoint
   source programs for the highest priority
   problems and the establishment of a reason-
   able cause-effect technical data base with
   a minimum of duplication.  This is to be
   carried out through problem-solving proto-
   type projects.  The information obtained will
   be transferred nationwide.  The highest
   priority problems are:  agriculture and
   silviculture, groundwater and urban runoff.

•  Regional Administrator shall not approve an
   areawide agency's work.program if, based on
   the Regional Administrator's review and
   advice of the State, the Regional Administrator
   determines the work program is incompatible
   with the State Strategy, State/EPA Agreement
   or EPA guidance.

•  After fiscal year 1979 no funds under section
   208 of the Act will be available to any
   planning agency which developed a certified,
   and approved plan, unless a significant
   portion of the plan is being implemented.
                     51

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          •  Prior to grant award, each State or areawide
             agency must have an approved, or conditionally
             approved, work program which identifies
             specific outputs the 208 funds will produce,
             including public participation elements.

          •  The State is primarily responsible for
             evaluation of management agency performance
             and it shall provide a description of its
             evaluation process in its work program.

          •  All FY 1981 funds are to be obligated by
             March 1, 1981 (50% of the funds must be
             obligated within 30 days of the advice of
             allowance); funds not obligated revert to
             Headquarters for redistribution to Regions
             with fundable projects.  No funds are to
             be carried over from one year to the next.

                          WORK PROGRAM CONTENT

Work programs and program plans both in draft and final (with the
final in greater detail) are to include for each task or program
element:

          •  Executive Summary;  If longer than 25 pages

          •  Direction of State WQM Program (Summary of the
             approach to solving the priority water quality
             problems):

             -  the existing or potential water quality
                problems, the severity of the problems, the
                beneficial uses impacted, the geographic ex-
                tent of the problems, and the source and
                adequacy of the data used to define the
                problems.

             -  the criteria used to select priorities and
                its status in the WQM plan, State's Five-
                Year Strategy, Continuing Planning Process
                and SEA.

             -  previous years work or how the problem was
                addressed in previous planning efforts.

             -  policy framework for incorporating areawide/
                local agency priorities into State WQM
                program.
                               52

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   -  anticipated changes and a schedule for
      making the necessary changes in the
      continuing planning process document and
      the WQM plan.

•  Program Element/Task Description
      objective of the program element:   this
      should describe the issue or problem to be
      solved and reflect the priority of these
      problems (WQM plan, Five Year Strategy, SEA
      commitment).

      work to perform/tasks:  show how they will
      lead to the achievement of the objectives.

      methodology to be employed;   what  approach
      will be used to solve the problem.

      outputs:  either in terms of units to be
      completed or control programs developed,
      ordinances or legislation passed,  etc.

      milestones:  key products to be produced,
      decisions to be made or actions to be taken
      for each output.

      future commitments:  depending on  the program
      element or task might include maintenance
      of effort, i.e., number of Class II inspections;
      or in terms of the development of  the develop-
      ment of NFS control programs passing of an
      ordinance which may lead to future tasks of
      obtaining funding for inspectors or the develop-
      ment of a Phase II Clean Lakes application.

      person years:  for each program element and/or
      task.

      agency(s) responsible:  for each program element
      or task.

      funding source(s):  EPA grant, other Federal
      sources, State and local funds to  be used  to
      accomplish each program element/task.

      estimated costs:  allocated to each task in-
      cluding any special costs such as  laboratory
      and equipment and a disbursement schedule.
                     53

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-  schedule:  when each task is to be completed
   and their dependency on other tasks.

-  assistance required:  technical and/or man-
   agerial assistance required to complete the
   task.

Public Involvement process to be included for each
appropriate task and/or program element as well as
a separate work program element which incorporates
all the public participation items.  The element
should include:

-  a schedule indicating when key decisions will
   be made and what opportunities exist for public
   participation in the key decisions.

-  major public participation activities and ob-
   jectives related to key decision points and
   tasks (i.e., sequence of distribution of infor-
   mation, workshops and meetings, hearings, etc.)

-  the major publics that will be involved.

-  budget by category, (i.e., publications and
   media campaigns, hearings, work shops, etc.)

-  indication that a public participation respon-
   siveness summary will be prepared which
   describes measures brought before the public
   at key decision points, the public response,
   and the Agency's response as to how the plan
   was affected by significant input.

-  description of the membership, meeting schedule,
   and general responsibilities of advisory com-
   mittees.

-  brief description of how the public was involved
   in selecting this program element/task and
   developing the work plan (in some cases, the
   5-Year Strategy development process could be
   referenced here to meet this requirement).

Schedule Chart(s);  Submit a scheduling chart (PERT,
CPM, or other) which clearly shows the significant
work tasks in sequence and the relationship between
tasks (see draft Work Program Handbook for Water
Quality Management, August, 1980).
                  54

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          •  Implementing Agencies;  For 208 grants, list the
             expected implementing agencies for each major plan
             output and their involvement in the'development of
             the program.

          •  Agency Commitments;

             -  provide documentation that each agency with a
                significant responsibility for producing,
                adopting, and implementing the outputs, under-
                stands and is committed to its outputs and
                schedule, as described in the work plan.  This
                documentation must be in the form of a written
                commitment from the highest appropriate
                official (policy) level.

             -  significant implementation agreements (208
                grants).

             -  information to be included in the quarterly
                reports.

             -  data to be provided for information systems.

             -  evaluations of management agencies that State
                will perform and a description of the process.

          •  Other Involved Organizations;  Identify all
             individuals, agencies, organizations, consultants,
             etc., other than the grantee and implementing
             agencies listed above, whose participation is
             necessary to carry out the work plan.  Describe
             the specific responsibilities for each organization.

          •  Other Related Programs;  Describe other related
             programs (e.g., air quality, HUD 701, coastal zone
             management, etc.) and the procedures for coordinating
             these with the WQM project/task/program.
Timing
State and areawide work programs are developed in tandum with the
State/EPA Agreements. A great deal of coordination and communication
takes place within Regional Offices, within States, between States
and areawides and between the Regional Offices and the States
because the priorities in the State/EPA Agreements are to be re-
flected in the work programs.

The policy framework for the work programs is based on the State's
Five Year Strategy and is to include priorities for areawide agencies'
208 activities.  The significant elements of the policy framework
are to be communicated to the areawide agencies no later than April 1.
                                55

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States have 45 days to comment on areawide agencies' work programs
if submitted directly to the Regional Office.  Draft work programs
are due to the Regional Office in June and proposed 208 projects
are forwarded to Headquarters in June or July.  The activities to be
funded are finalized by September and incorporated or referenced in
the State/EPA Agreement.  Without a signed State/EPA Agreement no
grant awards can be made to State and areawide agencies.

Preparation of the Regional Guidance Letter

Expectations for State and areawide programs should be outlined in
a guidance letter to the States no later than April 1.  The mid-year
evaluation of the State agency's WQM program is an excellent forum
for the development of ideas for the letter with the State agency.
When finalized, the letter should be discussed with the grantee.

A number of topics need to be addressed in the guidance letter:

          •  Funding target;  Every agency wants to know
             its funding target for 106 and 208 grants.
             Although the target is not an entitlement or
             a commitment on the part of the Regional
             Office, it will assist grantees define the
             scope of their activities based on the pro-
             bability of resources available and the
             agencies' needs.

          •  Ineligible agencies;  Letters should go to
             those agencies previously funded for which
             208 funding is unlikely to occur in the next
             fiscal year — for whatever reason.  Although
             limited resources is the most likely reason,
             failure to have a certified and/or approved
             208 plan, mismanagement of grants and not
             completing agreed to outputs are justifications
             for refusing to consider continued funding
             for an agency.  It is a difficult but necessary
             task for Project Officers to recommend that an
             agency's funding be terminated.  If resources
             can be better utilized elsewhere they should
             be.

          •  New initiatives;  A key item in the letter is
             the identification of new programs and projects
             based on national and regional initiatives and
             funding priorities.  Guidance on new national
             initiatives and funding priorities can be
             obtained from the items listed in the documents
             section above.
                               56

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   Initiatives may be based on national priorities,
   the Regional Administrator's priorities, State/
   EPA Agreement priorities, Regional source con-
   trol strategies, State Five Year Strategies,
   conditions for approving WQM plans, water
   quality problems identified in the States'
   problem assessments, the Region's overview of
   the assessment or the environmental profile.

•  Ideas for possible 208 projects;  These may be
   found in a review of the conditions approving
   WQM plans and an evaluation of the implementation
   of WQM plans.  Concepts which are compatible
   with the current nonpoint source emphasis should
   be suggested as possible projects.  Headquarters
   provides managerial and technical assistance in
   the development of work programs for NURP,
   groundwater, financial management and for
   agriculture monitoring and evaluation Category
   1 projects.

•  Format!  Examples of the format and a discussion
   of the level of detail necessary for draft
   and final work program submissions should be
   provided in the Guidance Letter.  It simplifies
   the process if grantees know of new require-
   ments prior to preparing their draft programs.
   The degree of Regional Office program inte-
   gration (106, 208, 314, RCRA, SDWA, etc.) will
   impact the formating of program submissions.
   A common format for all work program sub-
   missions and the integration of work programs
   is encouraged and is used successfully in
   some Regional Offices.

•  Procedural Guidance;  The Guidance Letter should
   also outline the procedures for internal work
   program review, the timing of submittals and the
   review and approval schedules.  It is important
   to leave enough time not only for the development
   of work programs but also for their review and
   revision.

•  Quarterly Reports;  The letter should identify
   the information to be included in the quarterly
   reports such as expenditures, summary of acti-
   vities against the projected outputs, etc.   This
   is explained in more detail in Chapter 6.
                       57

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          •  Information System;  Requirements for data in-
             puts into a Regional and/or Headquarters Infor-
             mation System should be identified (Note: a
             pilot test of an Agriculture Implementation
             Information System is to be initiated in FY 1981.

          •  208 Areawide Agency Funding Policy;  If the
             Regional Office has not already forwarded its
             policy on the funding of areawide agency 208
             activities — either directly or through State
             agencies — it should be included in the work
             program guidance letter to State and areawide
             agencies.

          •  Revisions of Continuing Planning Process Document
             and/or the WQM Plan;  Required revisions to the
             Continuing Planning Process description and or
             revisions to theQM Plan should be identified for
             inclusion in work programs.

          •  Significant Implementation Agreement;  Each 208
             work program is to include WQM plan implement-
             ation activities necessary to meet the require-
             ments of 40 CFR 35.1533-3(b).  This regulation
             states that a significant portion of the WQM
             plan must be implemented prior to future 208
             grant awards.  The activities in the agreement
             must be completed during the fiscal year in
             order for the 208 planning agency to be
             eligible for funding the following fiscal year.
             Regional Offices should identify those imple-
             mentation activiites they expect to be
             accomplished over the next fiscal year.

          •  Evaluation;  The letter should reference or out-
             line the Region's program review process for
             grantees (mid-year evaluations, implementation
             reviews, etc.) and the expected evaluations of
             management agencies States are to perform.

Review and Revision of Draft Work Programs

There is much for the Project Officer to consider in reviewing draft
work (programs and project proposals.  Only criteria applicable to
the WQM program in general are listed within the text of this Chapter,
Criteria for funding 208 nonpoint source control projects and 106
program priorities may be found in Exhibit 4-4 and 4-5 respectively.
                                58

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Some general guidelines for the review of draft work programs are:

             •  Do the programs/projects reflect national
                and Regional program priorities and
                initiatives?

             •  Do the programs/projects address the priority
                water quality problems addressed in the pro-
                blem assessment?  Just because there is a
                national problem does not mean the States
                within the Region have the problem.

             •  Are the programs/projects consistent with
                the State's Five Year Strategy, the State/EPA
                Agreement and the Region's control strategies?

             •  Are the activities and outputs clearly defined?
                Do 1 understand what is going to be accomplished
                and when?

             •  Is there adequate funding to accomplish the
                tasks?  It is better to fund a few projects
                completely than under fund many projects that
                will not produce implementable programs.

             •  Are 'the public participation work elements
                tied to the major tasks and decisions in the
                work program?  Have the public participation
                objectives and target publics been clearly
                identified?  Do the specific public partici-
                pation mechanisms (newsletters, public
                meetings, ad hoc advisors, etc.) relate back
                to the identified objectives?  Is the budget
                adequate to implement the public partici-
                pation work elements?  Is there a separate
                public participation work program?

             •  Do the 208 projects address removing the
                conditions to the approval of WQM plans?

             •  Are 208 projects limited to solving nonpoint
                source control problems?  Point source
                control activities are ineligible as 208
                projects in FY 80 and FY 81.

             •  Do the 208 projects fit Category 1, 2, and 3
                criteria?  Are there projects targeted for
                208 funding which are ineligible but have
                merit and could be funded from other sources,
                such as 201 or 314?
                                59

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             •  Are the outputs of the 208 projects part of
                an overall implementation plan?  Will they
                lead to operational NFS control programs?
                This is a must.  The intent is to assure
                that projects lead to decisions on the
                establishment of operational control programs
                as opposed to studies which involve no
                commitment to implement.

             •  Is data collection proposed which is not
                essential to problem solutions and implement-
                ation?

             •  Are integrated approaches to solving multiple
                nonpoint source problems proposed?  From more
                than one funding source (201, 314, RCRA, SDWA,
                etc.)?

             •  Will the projects be initiated in a timely-
                fashion?  In other words will projects funded
                in a particular fiscal year be well under way
                in that same fiscal year?

             •  Are the appropriate agencies identified for
                the project activities?  A local agency is not
                the logical agency to develop State legislative
                proposals.

Some of the factors to keep in mind when evaluating the 208 submissions
as a whole for the Region include:

             •  Are projects duplicative of one another?  Is
                there one project addressing a particular
                problem which is more likely to produce hard
                outputs transferable to the other States
                within the Region?  If so, that one project
                should be selected as a prototype for the
                Region and the information gained transferred
                to the other agencies.

             •  Are there potential Category 1 projects within
                the Region?  If so, work with Headquarters
                and the State on the proposal.

Grantee performance — past and anticipated is to be used in the
evaluation of work program activities.  Some of the things to
remember are:
                                60

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Grantees, other than new designations, must
have certified and approved plans to be
eligible for 208 funds.  Partial or con-
ditional approvals meet this criteria.

No Section 208 funds will be available to
any agency with a certified and approved
WQM plan unless a significant portion of
the plan is being implemented.  (See CFR
35.1533-3(b)'and CFR 1537-4(c)).

Regions should have reached a written agree-
ment with each Grantee as to what implement-
ation outputs were to be achieved prior to
the FY 80 Grant Award.  An evaluation of
implementation must be undertaken for each
Grantee and the Implementation Agreement
updated to reflect those implementation
activities to be accomplished during FY 81
before an award of FY 81 Grants can be made.

Grantees must be likely to be successful
in their efforts, and meet the other eligi-
bility criteria in CFR 35.1537-3(b).

There can be no award of a 208 grant where
the Regional Administrator determines that
(1) funding is to compensate for administrative
mismanagement, (2) the proposed work would
be duplicative of another grant agreement,
or (3) other funds are available and more
appropriate to the task.

No projects may be funded if agencies do not
have sufficient management, technical, and
grant-matching ability to perform the pro-
jects.  In making such decisions, the Regions
must consider an agency's past performance,
its present staffing and funding, and the
amount of work — possibly large — the agency
must complete under the terms of previous
FY 78, 79, and 80 grant awards.

A determination is to be made that State ex-
penditure of non-Federal funds for recurrent
106 program expenditures will not be less
than such expenditures during the fiscal year
ending June 30, 1971.
               61

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             •  Determination that the State has complied
                with the provisions of 40 CFR 35.1537-4(d)-(h)
                including monitoring requirements, 305(b)
                Report preparation, emergency response pro-
                grams, adequate level of funding for legal
                expenses related to enforcement and any
                Federally assumed enforcement actions under
                Section 309(a)(2) of the Act, in order to be
                eligible for 106 grants.

State and areawide work programs should be reviewed and commented
on by other appropriate program areas and offices in the Regional
Office.  This may include the State/EPA Coordinator to assure work
programs are tracking the SEA priorities, enforcement, S&A, con-
struction grants, etc.  Work with other program coordinators to see if
projects can be improved.  Are there areas which should be better
coordinated within the State?  Are there other program activities
which could be utilized to improve the outputs?  Are there new
initiatives that should have been included in the State's program
plan?  Is the program funding level adequate?

While reviewing the work programs, keep in touch with your State
counter-part on an informal basis.  Let the State explain and justify
its activiites.  Make sure you fully understand what it is trying
to accomplish.  Talk over your concerns — maybe it is just a matter
of phraseology.  The trust and rapport built during the negotiations
of work programs and projects may make suggestions for future work
programs and projects more willingly accepted.

208 projects will have to be ranked.  The needs are great and the
resources so limited that more projects will probably be submitted
than can be funded.  The ranking of 208 projects proposals is much
easier if the Region has prepared a nonpoint source control and
funding strategy that sets forth the Region's priorities.  The Strategy
provides the rationale for selecting those projects that will lead to
operational control programs.

Preparation of 208 Project Proposal Summaries for Headquarters Review

The purpose of Headquarters review of proposed 208 projects is to
assure 208 funds are allocated to areas with the greatest need.
Individual projects will not be approved or disapproved.  However,
unless the Regional Office can demonstrate their needs based upon
sound project proposals, funds will be reallocated to Regions with
fundable proposals.

In forwarding 208 project proposals to Headquarters, anticipate the
questions that may be raised.  For example, do the projects fit into
an overall Regional strategy?  How do the projects fit into the State's
                               6?

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Five Year Strategy?  Stress outputs and how the projects will lead to
operational control programs and/or removal of conditions to the
208 plan.  Is there a mix of projects addressing both national
and Regional priorities?  Recommendations for Category 1 projects
and technical and managerial assistance requirements should be
identified.

If project proposals are submitted to Headquarters by July adequate
time is available for any modifications necessary to incorporate or
reference the work programs in the State/EPA Agreement.

Finalize Work Programs and Make Grant Awards

The more clearly defined the work program outputs, the easier it will
be to manage the program.  Overly long and complicated work programs
obscure the objectives and outputs and inhibit program management.
In a well managed program, outputs are tracked, slippages identified
and issues resolved before the program is jeapordized.

Changes may be necessary in State work programs activities when the
appropriation act is passed and the State/EPA Agreement is finalized.
Difficult as changes may be, it is an accepted process familiar to
State agencies.  It is important to keep the State agencies abreast
of the potential changes that may be necessary - so no one is
surprised.

As soon as possible after the State/EPA Agreement is signed and advice
of allowances are transferred to the Region, work programs should be
finalized and grant awards made.

The letter accompanying the grant award should clarify the Regional
Office's understanding of any outputs in question, conditions to
the grant and how the work programs will be tracked.  This is a key
document in the mid-year evaluations.

Assistance in the Execution of Work Programs

It is important for Project Officers to recognize that the success
of the WQM program may be dependent on the technical and managerial
assistance that the Regional Office provides or assists the grantee
in obtaining.  Assistance to State and areawide agencies is a critical
activity for the Program Officer.

During the development of work programs, State and areawide agencies
and the Regional Office should identify the areas of managerial and
technical assistance that may be necessary to assure execution of
the work programs and the commitments made in the State/EPA Agree-
ment.  Project Officers or other experts within the Regional Office
                               63

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may be able to provide the grantee the assistance required.  Head-
quarters consultants are available for Category 1-208 projects and
for Category 2-208 projects as time and resources allow.  Headquarters
project officers should be consulted early to determine whether the
type of assistance can be provided when it is needed.  Assistance
may also be obtained from other Federal agencies through interagency
agreements or personal contacts.

The preparation of an assistance work plan will help Project Officers
anticipate, coordinate and schedule the managerial and technical
assistance necessary for State and areawide agencies.  A Regional
assistance work plan identifies those activiites of an agency's work
plan that will require either technical or managerial assistance, the
type of assistance needed, when it will be needed and who will
provide it.  The next Chapter describes in greater detail Regional
assistance work plans.
                               64

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                                               EXHIBIT   4-1
                                REGION ACTIVITIES:     WORK PROGRAM
ACTIVITY
PREPARE REGIONAL GUIDANCE LETTERS
Review HQ Guidance, Develop Work Program
Ideas & Discuss with States & Areawides
Develop the Major Common Elements of
Region Guidance to States and Areawides
Prepare and Send Guidance Letter
ASSIST GRANTEE DEVELOP WORK PROGRAMS
Review Guidance Letter with Grantee
Assist in Coordinating States and Area-
wides
REVIEW AND REVISION OF DRAFT WORK PROGRAMS
Review Draft Work Programs
Identify Potential Technical or Management
Assistance Requirements
Request Review of Work Program Elements
from Appropriate Program Offices
POSITIONS RESPONSIBLE
D.D.

*•
*
*
(w,o)







WQM
P. O.'s
*
*

*

*
*

*
*
*
WQM
TECH.
STAFF











OTHER
PROGRAM
OFFICES












OTHER
FEDERAL
AGENCIES











TIMING
MAR
///



n

^

MAY

^

JUHE


-------
          EXHIBIT  4-1
(CONTINUED)
REGION ACTIVITIES:
                      WORK PROGRAM
ACTIVITY
Review & Comments on Draft Work Programs
Prepare Regional Comments on Work Program
Meet with Grantee to Discuss Region Com-
ments & Potential Assistance to be provide
Develop and Prioritize 208 Project
Proposals
Review and Submit 208 Project Proposals
and National Assistance Requests to HQ
Finalize HQ, Region and Other Agency
Assistance to be Provided
Document Region HQ and Other Agency
Assistance Agreements
Assist Grantee Finalize Work Programs
Based on HQ Comments and Assistance
Commitments





POSITIONS RESPONSIBLE
D.D.


I
*
*
(w)
*
(w,o)







WQM
P.O.'s

*
*
*


*
*





WQM
TECH.
STAFF
^
^











OTHER
PROGRAM
DFFICES
^












OTHER
FEDERAL
AGENCIES
^












TIMING
MAR


APR

MAY

JUNE

rULY

AUG
-T
SEP

OCT


-------
          EXHIBIT  4-1
(CONTINUED)
REGION ACTIVITIES:    WORK PROGRAM
ACTIVITY
FINALIZE WORK PROGRAMS AND MAKE GRANT
AWARDS
Review State & Areawlde Final Work pro-
grams Against Region Comments, Under-
standings and SEA
Meet with Grantee to Resolve Work Pro-
gram Problems as Appropriate
Prepare Grant Award and Cover Letter
Documenting Conditions
Submit Grant Award & Cover Letter to R.A.
for Approval







POSITIONS RESPONSIBLE
D.D.

*
(w,o)


*
(w,o)







WQM
P.O.'s

*
*
*








WQM
TECH.
STAFF












OTHER
PROGRAM
OFFICES












OTHER
FEDERAL
AGENCIES












TIMING
OCT
^

1QV
n

DEC
M

JAN


FEE
^

MAR

APR

MAY


-------






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GUIDANCE AND
EXPLANATION OF
REQUIREMENTS
Provide Regions:
. EPA Operating
Year Guidance
. WQM Funding
Policy for
Section 106 & 208

Provide States &
areawldes:
. Guidance letter
. Significant im-
plementation
agreement require
ments
. Formats and
schedules for
work program
submissions

States provide
areawides:
. Policy framework
for areawide
agency's 208
activities












DOCUMENTS
PREPARED





. 208 project
summaries in-
cluding requests
for Headquarters
technical
assistance






. 106, 208 work
programs
. WQM plan signi-
ficant imple-
mentation agree-
ments' activit-
ies
. Public partici-
pation summaries
. Grant applica-
tions






DOCUMENTS
REVIEWED
& EVALUATED
. Summaries of 208 pro-
ject proposals and
request for Head-
quarters technical
assistance


. State/areawlde 208,
106 work programs
. Significant imple-
mentation agreements








. State review of area-
wide agency's 208
work programs











ACTIVITIES TO BE PERFORMED DURING WORK PROGRAM
PREPARATION AND/0

PROGRAM
COORDINATION
&. INTEGRATION
. Initiatives for
integrated work pro-
grains and conmon
work program grant
formats


• Appropriate program
office review
. Identify appropriate
sources of funding
for activities
. Develop conmon for-
mats, schedules and
integrated work
program submissions



. Integrate State and
areawide work pro-
gram activities
. Develop WQM plan
with agencies
designated to
Implement the plan







R REVIEW

COORDINATION & IN-
VOLVEMENT WITH OTHER
FEDERAL AGENCIES
. Agreements to assist
State and Local
agencies




. Identify critical
work program elements
that will require
assistance and
coordinate appropriate
groups






. Seek commitments for
appropriate assist-
ance












MANAGERIAL AND
TECHNICAL
ASSISTANCE
. Category 1-208
projects
. Category 2-208
projects as time
and resources
allow


. Identify critical
work program
elements that
require assist-
ance and coordi-
nate appropriate
groups





. Identify require-
ments
. Request asslst-
• ance












FINALIZE WORK
PROGRAMS AND
MAKE GRANT
AWARDS





. Process grant
applications
. Prepare grant
award and cover
letter







.- Complete work
program


















EXHIBI
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-------
                               EXHIBIT 3

                           STATE WQM PROGRAM

                          FUNDABLE ACTIVITIES
Activity*

CONSTRUCTION GRANTS MANAGEMENT


PERMITS (includes NPDES, 404 and
 Other State Permit Programs)
Administration
Compliance Evaluation
Enforcement

GENERAL & POINT SOURCE WQM PLANNING
Water Quality Standards
Wasteload Allocations
Municipal Facilities Planning
208 Dredge and Fill Regulatory
 Programs

NONPOINT SOURCE PLANNING AND
 IMPLEMENTATION

MONITORING
Equipment and Facilities
Ambient and Compliance Monitoring
General/Point Source Intensive
 Surveys

MUNICIPAL FACILITIES OPERATIONS &
 MAINTENANCE TRAINING

EMERGENCY RESPONSE

PRETREATMENT

314 CLEAN LAKES

OTHER PROGRAM ACTIVITIES
Funding Source

106 to the extent not fundable
under 205(g)

106, 205(g)

106, 205(g)
106, 205(g)
106, 205(g)

106, 208, 205(g)
106
106, 201, 205(g)
106, 201, 205(g)
208, 106, 205(g)
208, 106
106
106
106, 208
106
106, 205(g)


106

106

314

106, 208
*Refineraent of elements shown in 40 CFR 35.1513-5(c)(l-18)
                                   69

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                               EXHIBIT 4

                208 PROJECT SELECTION CRITERIA FOR FY 81
A.   General

     1.  The major objective of these criteria is to foster development
         of 208 projects which produce hard outputs and solve problems
         other than those which are construction grants or point source
         oriented.

     2.  All projects must be part of a State WQM Strategy.

     3.  All projects must have fiscal/financial management components.

     4.  Each project must include c6mplete public participation in
         accordance with the public participation regulations (40 CFR
         Part 25) and the WQM regulations (40 CFR 35 Subpart G).

B.   Category I Projects

     1.  NURP:  No new projects.

     2.  Agriculture:  Three to five new intensive M&E projects on the
         effectiveness of BMPs and water quality impacts.

     3.  Silviculture:  About three new projects which demonstrate inte-
         gration of State Forest Resource/208 Planning with training
         and implementation.

     4.  Ground Water:  About 10 additional projects in a range of settings
         focusing on development of comprehensive, implementation-oriented
         management programs with monitoring strategies and legal/
         institutional analyses.

     5.  Financial Management:  Up to one additional project per Region
         on nonpoint source control financing and institutional arrange-
         ments with direct relationship to plan implementation; emphasis
         is on the development of tools which can be transferred to other
         areawides for use in small flow system management, agriculture,
         NPS pollution abatement, urban runoff control, and ground water.
                                70

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C.   Category II Projects

     Subject            "DO"
                              "DON'T"
1.   Urban Storm
     Runoff
2.   Agriculture
develop implementable
programs to solve known
WQ problems with known
practices

set up programs which
give full and early
consideration to finan-
cial and institutional
arrangements and are
self-sustaining

emphasize funding items
to maximize operational
status of WQM plans
                         refine critical area de-
                         signations to impacted
                         water courses as opposed
                         to entire drainage basins
                         where priorities have
                         been established for
                         implementation, develop
                         implementable programs
                         to solve known WQM
                         problems with known
                         practices

                         support on-going RCWP
                         projects for monitoring
                         and evaluation
   evaluate BMPs

   do problem assessments
                                                          monitor for toxic
                                                          pollutants
— fund RCWP applications
   or identification/prior-
   itization of potential
   RCWP projects

— fund BMP handbooks
                                 fund problem-identifi-
                                 fication studies
3.   Small Systems
use State Cooperative
Extension Service funds
to match 208 funds
where possible, to assist
with information, education,
testing, integrated
pest management, and manage-
ment-oriented BMPs (See
INFO 80-30)

develop implementable
programs to solve
identified WQ  problems
   use 208 funds to solve
   problems which are
   eligible for facility
   planning grants under
   201
                                    71

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     Subject
6.   Ground Water
"DO"
7.   Construction
     Runoff
8.   Mining
9.   Hydrologic
      Modification
10.  Residual Waste
   refine the effect and
   degree of known WQ
   problems, and develop
   impleraentable programs
   to solve these problems
   with known practices
                         fund comprehensive State
                         or aquifer-wide ground
                         water management programs
                         consistent with the al-
                         ready established surface
                         WQM programs
   participate in hazardous
   waste programs to ensure
   ground water protection

   fund development of State
   legislation and imple-
   mentation of local ordi
   nances, modification of
   existing regulatory
   programs, and resolution
   of financial issues nec-
   essary to develop an
   implementable plan for
   solving identified WQ
   problems

   fund development of non-
   coal, regulatory programs
   to solve identified WQ
   problems

   fund proposals which focus
   on quality/quantity relation-
   ships , if they have a
   significant impact on WQ

   fund proposals which lead
   to implementation of re-
   gulatory programs to en-
   hance or maintain WQ

   fund NFS residuals pro-
   posals which will lead
   to an implementable plan
   to solve identified WQ
   problems
"DON'T"

— fund aquifer mapping

— fund monitoring and
   data collection unless
   they clearly lead to
   an implementable con-
   trol program

— attempt to determine
   whether a problem
   exists
                                 — fund ground water modeling
                                    in general (NOTE: This
                                    is a Category II criterion)
   fund BMP handbooks

   fund development of non-
   regulatory programs
   fund planning for coal
   mining-related WQ pro-
   blems
   fund general solid waste
   planning
                                 72

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     Subject          "DO"                             "DON'T"
11.  Recreation       — in identified 208 projects,   — fund recreation planning
      Open Space         identify recreation
                         opportunities or potential
                         areas that may result from
                         the projects by upgrading
                         WQ through NFS controls
                                73

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                          EXHIBIT 5

              NATIONAL 106 PRIORITIES FOR FY 81



Improve Management of the Construction Grants Program

EPA stresses improved State management of obligations, outlays,
project completion, priority lists, and facility plans.  An
additional priority is State assumption of pretreatment authority
and 205(g) funds to minimize the burden on 106 funding from
construction management assistance.

Develop a Framework for Toxics Control

States should place priority on incorporating toxic criteria
in their water quality standards.  States with NPDES authority
should control toxic substances by issuing second-round permits
to primary industries, major secondary industries, and major
POTWs, by implementing the pretreatment program and by enforcing
pretreatment regulations.

Build Water Quality Management Capability

States should develop their toxic analytic capability, including
the purchase of laboratory equipment.  Quality Assurance
procedures are mandatory in all projects in which participants
gather environmental data.  States should also develop operational
control programs for nonpoint source problems with EPA technical
assistance, especially for ground water, agriculture, and urban
runoff, with special attention to the financial management aspects.

Conduct Effective Permit and Enforcement Programs

In addition to permit and enforcement efforts aimed at strengthen-
ing the framework for toxics control, States should simplify the
permit process through the consolidated permit program; process
selection 301(h) marine waivers; issue energy-related permits;
implement the National Municipal Policy and Strategy; conduct
inspections in support of enforcement cases and emergency situations;
and implement Discharge Monitoring Report (DMR) quality assurance
programs.

Conduct Waste Load Allocation/AWT Reviews

Using EPA guidance (see, for example, INFO 79-98), the States
should establish programs for waste load allocations.  States
should prepare priority lists of wasteload allocations necessary
to substantiate inadequate AST/AWT effluent limitations in
accordance with WQM policy memorandum B-8 (PRM 79-11).
                           74

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Respond to Major Environmental Emergencies

To receive a section 106 grant, each State must have an emergency
response program consistent with section 504 of the Act, including
a contingency plan, necessary response capability, authority to
establish a contingency fund and a program to prevent emergencies
from occurring.  For further guidance, see WQM Policy Memorandum
B-5.

Protect Sensitive Ecosystems

To protect sensitive wetland areas, States should develop their.
section 404 dredge and fill programs as resources allow and work
toward assuming 404 program delegation.  In the 404 program,
States should focus on the most environmentally sensitive projects,
emphasizing pre-perrait applications, planning, and analysis.
States should also operate a Clean Lakes program to protect or
restore publicly-owned fresh water lakes, in accordance with the
314 Clean Lakes section.
                           75

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 Chapter 5
 Assistance in  the  Implementation of
WQM  Plans  and
                             INTRODUCTION
Regional Offices are evaluated  on their ability to make the WQM
process work — the development and implementation of water quality
management plans, effective and efficient administration of operational
control programs and the improvement in water  quality.  The essential
tools to manage the WQM program have been discussed - strategies, work
programs and SEAs.  This Chapter concentrates  on the assistance
necessary to assure work program outputs are completed and WQM plans
implemented.  A significant portion of the WQM Program Review focuses
on these activities as an important indicator  of the ability of the
Regional Office to organize and direct its resources to make the WQM
program work effectively to solve water quality problems.

The specifics of the assistance required depend on the individual
needs of the program or agency  and the ability of the State to
identify and arrange for assistance to agencies involved in developing
solutions to the remaining priority water quality problems (for
example 208 nonpoint source control planning activities) and to
agencies involved in the implementation and administration of water
quality management programs.

A case could be made that the discussion of assistance should be
separated into two distinct elements.  The first would concentrate
on those activities necessary to assure that the 106/208 work programs
are executed - toxic monitoring, pretreatment, and enforcement
programs carried out and WQM plans developed.  There is a direct
relationship between the Agency (grantee) and  EPA.  The agencies
— primarily State agencies except for areawide agencies carrying
out 208 planning activities —  are funded by grants and therefore
must comply with the conditions of the grants.
                               77


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The other part would involve a discussion of the assistance necessary
to assure that planned problem solutions are implemented and evaluated.
Many of the agencies designated to implement portions of the WQM
plans are not grantees of EPA (other Federal agencies, conservation
districts, etc.) and therefore, if failure occurs all EPA can do to
the Agency is de-designate that agency.  It can not hold the grant
as hostage to make the agency comply with its letter of commitment to
implement the WQM plan.  Even finding out what assistance a particular
implementing agency needs assumes an extensive tracking system
- which does not now exist.

Why then is the Assistance Chapter not broken into two parts or even
two chapters?  First, too many similar activities and needs exist
to make a clear distinction between what is needed to develop and
what is needed to implement and administer a water quality management
program.  Second, as the initial WQM plans are approved and the 208
planning effort focuses on filling in the gaps, the clear distinction
between planning and implementation gets lost.  As FY 1984 approaches
and a restructured WQM program is formulated, planning, implement-
ation and administration will be integrated into a cohesive WQM
program managed by the States.  Therefore, the focus of the Assistance
Chapter is on helping the State manage the WQM process whether the
assistance needed is by a State or areawide agency.

Furthermore, Project Officers and WQM Coordinators need to think
about the WQM program as a whole and get actively involved in making
sure the WQM process works whether it relates to planning, imple-
mentation, operation or administration of the component parts of
the WQM Program.

This Chapter therefore, includes examples of the type of assistance
Project Officers should provide or assist States to arrange, sources
of assistance, and the delivery mechanisms.  There is also discussion
of a tool — the Regional assistance work plan — to aid in the
planning, organization and coordination of assistance to meet the
priority needs.  Exhibit 5-1 shows in a matrix format the activities
of Regional Office personnel and Exhibit 5-2 shows the relationship
of Regional Office and Headquarters in assisting grantees execute
their work programs and agencies implement the WQM plans.

                     REGIONAL ASSISTANCE WORK PLAN

An assistance work plan (or an assistance element of a overall work
plan) will aid Project Officers plan, organize, coordinate and meet
the priority assistance requirements of the State or Region.  The
idea of the work plan is to anticipate as much as possible the
assistance that will be required over the year and to prioritize
the needs.  Unforeseen requests for assistance will occur but the
preparation of the work plan should keep these to a minimum and
assure the highest priority needs are met.
                                78

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Timing

Assistance is provided throughout the year.  The work plan should
be drafted and finalized simultaneously with the SEAs and work
programs.

Preparation/Content

The content of the Regional assistance work plan follows the logical
process Project Officers would use to provide or arrange for assist-
ance to an agency.  Therefore, the plan should include a discussion
of:

               •  Problems for which assistance will be
                  needed;  Ideas for technical or managerial
                  assistance come from a variety of sources
                  including State and local agency requests,
                  Regional source control and funding
                  strategies, State Five Year Strategies,
                  State/EPA Agreements, work programs,
                  quarterly reports, mid-year evaluations,
                  implementation reviews and tracking
                  reports.

               •  Priorities for Assistance;  There are
                  probably more requirements for assis-
                  tance than there are resources available
                  to meet the need.  How are priorities
                  to be set?  By the severity of the
                  pollutant problem?  Conditions to the
                  approval of WQM plans?.  Court decrees?
                  Applicability elsewhere in the Region?
                  State/EPA Agreement commitments?  State/
                  EPA commitments must be honored.

               •  Approach to be used to meet the particular
                  assistance need;  Will Headquarters'
                  expert consultants be used for urban
                  runoff, groundwater or financial manage-
                  ment problems, waste load allocations/
                  toxics controls or for their expertise
                  in silviculture, agriculture or septic
                  systems?  Will Regional Office personnel
                  be used or are there other State or
                  local agency personnel who have been
                  involved with similar problems?  Are
                  workshops more appropriate to enable a
                  number of agencies to talk about their
                  their approaches to resolving the
                  problems?  Or, should the approach be
                  primarily one of information exchange
                  and the use of prototype summaries?
                                 79

-------
•  Delivery mechanisms to be used;  Sponsoring
   workshops, attending public meetings and
   forums, participating in public advisory
   committee meetings, working on interagency
   or intra-agency committees, directing and
   coordinating an information exchange on
   prototype projects, research on cost-
   effective BMPs, economics of control, etc.
   are all effective technical and managerial
   assistance delivery mechanisms.  In many
   cases the best approach is sitting down
   with the agency and talking out problems.
   This is especially valuable in working
   out institutional problems and trying to
   find ways of better coordinating Regional
   Office programs.

•  Agencies to receive assistance;  Which
   agencies are to be the recipient(s) of
   the assistance?  Who will be involved in
   workshops or forums on a particular topic?

•  Sources of assistance;  Who will be providing
   the assistance - Project Officers, WQM
   Coordinators, Water Division Director,
   other Regional Office personnel, Head-
   quarters consultants, Headquarters
   personnel, State, local or other
   Federal agency personnel, other experts?
   Who is responsible for ensuring the
   assistance is provided on a timely
   basis?  The sources of assistance will
   be discussed in greater depth later in
   the Chapter.

•  Timing of assistance;  Workshops require
   substantial lead time.  Regional and
   Headquarters personnel and consultants
   have other demands which may limit their
   availability to assist an agency; how-
   ever, the timing of assistance to an
   agency may be critical.

•  Budgetary impact;  Budget constraints are
   a fact of life.  Look for assistance that
   is close and free.  Will some other
   agency absorb the cost?  Should the con-
   sulting assistance be included as an
   eligible grant cost?  How many trips do
   you need to make?  Is there a cheaper
   way for you to travel?  No matter how
                 80

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                  difficult a particular pollutant or
                  source control problem, institutional
                  or financial issue may be, finding
                  cheap, innovative ways of providing
                  assistance to State and local agencies
                  may be the most challenging part of the
                  process.

A matrix is a useful method of structuring and organizing the assistance
a number of agencies may require.  Categories of assistance for each
program area (agriculture, urban runoff, etc.) might include:

               •  Agreements on institutional responsibilities

               •  Review/strengthening State program approaches

               •  Water monitoring activities

               •  BMPs/controls for a particular pollutant
                  or source problem

               •  Financing BMPs and control programs

               •  Sanctions/incentives

               •  Grantee failures

The categories will depend on the strengths and weaknesses of the Region's
agencies, the priority problems to be addressed, and the program to be
developed and/or strengthened.

The other axis of the matrix chould be either the sources of the
assistance or the recipients of the assistance.  A cut both ways is
useful.  From the matrix the assistance can be categorized and summa-
rized for the work plan; the "type" of assistance to be provided,
who provides what type of assistance to which agency, and the type and
source of assistance each agency is to be provided.

Preparation of the work plan needs to be coordinated through the
Division Directors since various parts of the WQM Program are scattered
throughout the Regional Office as are the personnel who can provide
the assistance.  WQM Coordinators and Project Officers will have to
prepare their own work plan for the overall assistance work plan.  The
work plan should guide most of their activities and be the basis of
their performance agreements.

The Regional assistance work plan or appropriate portions thereof
should be forwarded to the grantees and agencies receiving assistance
as well as to agencies providing the assistance.
                                81

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                TYPES OF TECHNICAL/MANAGERIAL ASSISTANCE

There are many activites — some very simple, others more spectacular
which smooth the WQM process.  Some of the activities and approaches
suggested below may be more appropriate to one problem or agency
than another.  They are neither mutually exclusive nor all inclusive.
A combination of activities and approaches will have to be developed
to meet a particular agency's needs, based on commitments made in
the State/EPA Agreements, special requests, or just common sense.

Agreements on Institutional Responsibility

The first step for State and areawide agencies in implementing
solutions to water quality problems is developing agreements on
institutional responsibilities.  State and areawide WQM plans identify
agencies with the authority and capability to implement all aspects
of the plan, and the Governor designates these agencies as WQM
management agencies.  The planning agency and the management agency
develop a long-term agreement detailing the steps each agency will
take to implement the plan, and a schedule for doing so.

Generally, different institutions handle different problems.  States,
Cities, special service districts, or interjurisdictional compact
agencies normally handle municipal waste treatment problems, while
soil conservation districts or county governments are more likely
to handle rural nonpoint source problems.

No single entity needs to have all the authorities, resources and
capabilities to carry out the program.  A combination of agencies
may meet the requirements.  However, as the number of agencies
multiply the coordination linkages become more important.  Greater
care must be taken in the development of the management agency
implementation agreements to ensure that the program as developed
and approved is implemented.  The prerogatives and jealousies of
competing levels of government will make this task a challenge.
The simpler the structure the easier it will be to work out the
agreements on the roles and responsibilities of the agencies.  These
agreements are particularly important because the commitments and
milestones outlined in the agreements should be included in the
Significant Implementation Agreements.  They are the criteria for
evaluating whether WQM plans are being implemented.

Review/Strengthen State Program Approaches

Regional Offices are involved in assisting States in the develop-
ment, review and revision of their antidegradation policy and water
quality standards; inclusion of toxics and wet weather flow criteria
in water quality standards revisions; development, review and revision
                                 82

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of wasteland allocations; review of the consistency of 201 grants
to the certified and approved facility portion of a-WQM Plan; review
of Clean Lakes applications and review and/or issuance of permits.

Enforcement is generally the responsibility of the permit-issuing
agency, and is a critical part of implementation.  As with other
aspects of the process, it is necessary to set enforcement priorities.
As a rule, enforcement aims first at chronic violators, major dis-
chargers, and potential dischargers of toxic substances.

In addition to permit based regulatory programs for point source,
there are other regulatory and non-regulatory approaches for non-
point- sources.  Such programs are generally State or local initiatives,
and many states and local governments are planning such programs
through the WQM planning process.  For EPA to approve a nonpoint
source regulatory program in a WQ  M plan, such as a permit, license,
or bond program there must be adequate authority to control the
problem, monitor activities, and enforce the program.  The designated
management agency must have adequate expertise, staff, funding, and
authority to run the program.

In the absence of regulatory programs voluntary compliance programs
may work (or already by working) to control pollution.  Such pro-
grams usually depend on education, citizen involvement, self-
monitoring and other programs to assist in the implementation of
controls.  Clean Lakes projects, in conjunction with USDA cost-
share and technical assistance programs, have effectively stimulated
implementation of agriculture nonpoint source control programs.
For EPA to approve a non-regulatory program in a WQM plan, the
Regional Administrator must determine that there is a reasonable
degree of certainty that it will result in implementation of needed
controls and achievement of water quality goals.  Usually a period
of time is given — three to five years — to evaluate whether the
non-regulatory approach will work.

Water Monitoring Activities

Most State water quality monitoring programs are directed toward
point source pollutant problems.  Less is known about toxics and
nonpoint source pollutant problems — their transport, fate and
impact on instream and riparian biota.  Standards and criteria
generally are applied to low flow conditions while nonpoint source
pollutant problems are primarily connected with storm events and
have their greatest impact in the first flush.  This Manual will not
tell you how to design a nonpoint source or toxics monitoring pro-
gram, conduct an intensive survey nor how to make point and nonpoint
source tradeoffs.
                                 83

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Some guidance is available and more is being developed.  The proto-
type projects in agriculture monitoring and evaluation and urban run-
off will provide valuable information on the design of less costly
monitoring techniques.  As information becomes available it should be
facotred into a State's monitoring strategy.  In many cases States
could do a better job of identifying and determining the source and
impact of their toxics and nonpoint pollutant problems.  Project
Officers should make States more aware of the need for toxics and
nonpoint source pollutant monitoring data and analysis and ensure that
the S&A Division and Headquarters assist States improve their cap-
abilities.

BMPs/Controls

Although cost-effective BMPs exist for some problems, such as con-
struction runoff and failing septic systems, structural and non-
structural BMPs for such problems as urban storm runoff, ground-
water contamination, and agricultural runoff are not fully tested.
For this reason, designated State and areawide WQM planning agencies
are testing BMPs in prototype or pilot projects.  Some of the BMPs
being tested are detention basins and street sweeping, irrigation
systems which reclaim waste water and erosion control barriers.
When complete, the prototypes will provide a technological basis
or control which EPA can then transfer to States and areawides
nationwide.

The prototype projects also test the financial, institutional, and
political aspects of controls.  State, areawide, and local planners
work with local elected officials and the public on institutional
arrangements, public support, and sources of funding for selected
controls.

Although there are many non-structural solutions to water quality
problems, in some instances construction is appropriate.  The 1977
Ammendments to the Clean Water Act provided an incentive for
innovative and alternative treatment works, by raising the Federal
share of the cost of such projects from 75 to 85 percent.  Innovative/
alternative projects are those which reuse or reclaim wastewater,
recover nutrients and other pollutants in wastewater or sludge, or
conserve or recover energy.

The Agency needs to emphasize alternatives to building waste treat-
ment plants and has developed a Strategy to improve the performance
of small and alternative wastewater systems to meet the total waste-
water needs, not just specific requirements of the 201 and 208 programs.

Funnelling information on what has worked and what has not worked
and why, is valuable assistance to State and local agencies.  What
are the most cost effective BMPs?  How did an agency approach a
particular problem?  Project Officers should keep abreast of the
prototype projects and disseminate the information obtained from
these projects to State and local agencies within the Region.
                                 84

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Financing BMPs and Control Programs

Fiscal management analyses and how the BMPs in the WQM Plan are to
be financed are prevalent problems.  BMPs will not be accepted and
may be counterproductive, if they are too burdensome on the person
or entity required to implement them.  Little fiscal management
analysis was included in the initial water quality management planning
effort.  State and areawide planning agencies need to identify
taxpayers, develop sound plans to defray the costs, and attempt to
motivate community action to implement the plan.  Ad hoc requests for
funding, or over-reliance on Federal funding are not suitable long-
term substitutes for effective financial planning.

In response to the need for improved financial planning and analysis
for water quality management at all levels of government, the
Financial Management Assistance Program (FMAP) through expert con-
sultants, assists State and local agencies develop systematic
approaches to financial management and budgeting to implement con-
rols.  The consultants assist agencies develop the true costs of
implementing controls in order to set user charges or permit fees.
The case studies of the prototype projects selected for intensive
FMAP assistance should be widely distributed to agencies with similar
problems.

Several States have cost-sharing programs to assist farmers apply
agricultural BMPs, as in Kansas, Illinois, Iowa, Nebraska, Wisconsin,
Minnesota, Ohio, South Dakota, and Washington.  These programs should
be studied to assist State personnel develop legislative proposals
or a cost share program where none exist.

Financing the education information and technical assistance necessary
or an agricultural WQM program may also be a problem.  USDA agencies
do not always have sufficient field personnel to adequately cover
all the needs.  Some States have provided additional funding to
conservation districts to hire staff to provide the technical
assistance.  These approaches should be brought to the attention
of State agency personnel especially if continued funding is a
condition of approval of the WQM plan.  You may have to collect the
information, and arrange for agencies that have used a particular
approach to talk with your State as well as prepare a draft proposal
for the State to consider, review, modify and potentially adopt as
its own.

Sanctions/Incentives

Where attempts to solve water quality problems have failed, EPA or
a State may wish to apply sanctions.  Sanctions may be against a
single discharger, a local or areawide agency, or the State itself.
                                85

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If a municipal or industrial discharger violates its NPDES permit,
the resulting sanction is a fine or withdrawal of a permit.  Dis-
chargers may be subject to both civil and criminal penalties for
polluting.  (Note that EPA or the States will not usually impose
sanctions aganist municipalites that are too far down the priority
list to receive construction grants to correct their problems).

Here we are more concerned with seeking incentives as alternatives
to sanctions.  One example is the "payment in lieu of a fine", where
a discharger/operator faced with a fine may contribute to the
solution of an environmental problem in lieu of, or in addition to,
a fine.  Other examples are Small Business Administration (SBA)
loans, accelerated tax write-offs for industrial/commercial
pollution control, awards and honors, and grants from discretionary
funds as rewards for superior performance.  EPA's 75 percent Federal-
share construction grants program is an incentive for implementation
of solutions to municipal waste treatment problems, as are Section 314
Clean Lakes grants for lake restoration and USDA's cost-share programs
for agricultural nonpoint source controls.

Failure to carry out elements of a work program which do not con-
stitute a grantee failure (covered below) needs to be identified
through the quarterly report and/or mid-year evaluations and
corrected.  Sanctions for failure might include withholding a portion
of the grant or reducing the following year's grant.

If a management agency designated to implement a certified/approved
WQM plan fails to carry out its agreed-upon duties, the State may
withdraw the management agency designated and transfer the authority
to another aency or the State itself.  In extreme cases, EPA could
rule an agency not deserving of public trust, which would exclude
it from all federal funding.

Finally, if a Regional Administrator feels a State is not implementing
its certified and approved WQM plan, he or she may rule that the
State's Continuing Planning Process is inadequate and withhold
State assistance or revoke its NPDES delegation, if any.

Grantee Failures
This Chapter assumes that technical and managerial assistance will
be concentrated on issues generic to the pollutant problems or
sources.  Nevertheless, there may be occasions where an Agency's
technical and managerial needs will be so great as to question the
capability of the agency to fulfill the obligations of the grant.
If this problem does occur, efforts should be made to assist the
Agency complete as many outputs as possible so as not to threaten
the integrity of the grant.  However, the Agency should not be funded
again and the criteria used to evaluate the capability of an Agency
to accept a grant should be tightened.
                                  86

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                         SOURCES OF ASSISTANCE

In addition to Regional Office and Headquarters expertise, the
resources of other Federal agencies and private industry should be
used in developing an assistance package.

Umbrella agreements as well as individual agencies agreements open
the door to the financial and technical resources of the U.S. Department
of Agriculture and U.S. Department of the Interior, Tennessee Valley
authority, U.S. Army Corps of Engineers and Economic Development
Administration.  All of these agencies have been involved in and
have supported WQM activities.  The most successful examples of
cooperation have been those where the WQM Coordinator or Project
Officer is actively involved with the Federal and State agency,
such as preparing applications for special project funding.  Federal
agencies should be encouraged to seek designation as the management
agency for WQM activities on their own lands.  Headquarters can
encourage Federal agencies to seek designation but the grouncl work
must be laid by the Regional Office.  Some examples of the WQM
activities in which Federal agencies have participted are listed
in Table 5-1.

The private sector especially large corporations may be willing to
cooperate in special projects if they are made aware of the project
and asked to participate.  Mining companies have joined in Category
1 groundwater projects and the forest industry in testing various
BMPs on its lands.  More should be done with the construction in-
dustry.  Companies are required to widen roads, donate lands for
open space as a condition of development.  Why not involve them in
testing different types of sediment basins, different configurations
of basins to minimize O&M costs after the development has been
completed, and the development of alternatives to sediment basins?
                                 87

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                          TABLE  5-1

              FEDERAL WQM ASSISTANCE ACTIVITIES
U.S. Department of Agriculture;

-    Agriculture Conservation and Stabilization Service:  ACP fund-
     ing  for BMPs; Special ACP Projects; Model Implementation
     Program (MIP); Rural Clean Water Program (RCWP).

     Extension Service:  Integrated Pest Management (IPM) program1
     technical assistance in the development and implementation
     of BMPs.

-    Forest Service:  Technical assistance in planning for a
     silviculture element of a WQM plan, and in the implement'
     atloa of BMPs; development of BMP handbooks; training; and
     designation as the management agency responsible for BMPs
     on national forest lands.

-    Soil Conservation Service:  Technical assistance in the develop-
     ment and implementation of WQM plans; technical assistance
     in ACP special projects, Model Implementation and Rural Clean
     Water Program projects.

U.S. Department of the Interior;

-    Bureau of Land Management:  Delegation as the planning agency
     for  sane of BLM lands; coordination and assistance in the.
     preparation of UQM plans; development of BMP handbooks;
     Inclusion of BMPs as a condition of leases; designation as
     the  management agency for BLM lands; water quality monitoring
     and  participation in STORET.

     Bureau of Mines:  Coordination and information on mining
     activities Including economic analyses.

     Fish and Wildlife Service:  Instream flow and water quality
     reqjalrements for acquatlc and riparian biota; assistance to
     States to develop State operated 404 programs.

     Geological Survey:  General monitoring and data collection •
     for  both surface and ground waters; acquifer mapping;
     technical assistance for urban runoff data collection,
     analyses, and modeling, etc.

-    Heritage Conservation and Recreation Service:  Recreation
     benefits of Improved water quality; urban recreational
     initiatives including requirements under section 201(g)(6)
     of CWA and use of State Outdoor Recreation Plans.

     National Park Service:  Innovative waste treatment
     facilities for isolated park areas; coordination of .-ark
     planning activities with the development of WQM plans.

-    Water and Power Resources Services (Bureau of Reclamation):
     Irrigation scheduling; Improving water delivery efficiencies;
     retrofitting dams to improve water quality below dams (DO
     levels; supersaturation problems); modification of
     operations at dams to relieve surface and ground water
     problems.

Tennessee Talley Authority;  Technical assistance In rural and
urban naepolnt source control; designation as the management
agency for TVA dams, reservoirs and lands; development and test-
ing of cost effective BMPs to control water quality problems
(DO) below TVA dams; inclusion of BMPS as a condition of a lease.

U.S. Array Corps of Engineers;  Contract with EPA to oversee the
design aatd inspection of the construction phase of waste water
treatment plants; evaluating the impact of their dam operations
on down stream water quality; urban studies.

Economic  Development Administration;  Title V EDA funds have been
used to supplement ACP funds in special projects.


                                   88

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                                               EXHIBIT  5-1
                                REGION ACTIVITIES:  ASSISTANCE
ACTIVITY
PREPARE REGIONAL ASSISTANCE PLAN
Identify and Prioritize Assistance Require-
ments During Development of Strategies,
Work Programs and SEA' 8
Determine Sources of Assistance
Coordinate and Participate in Discussions
and Meetings to Define and Negotiate
Assistance to Grantee
Review and Approve Region Assistance Plan
and Incorporate Appropriate Plan Elements
into. Performance Agreement
Provide Appropriate Portions of Regional
Assistance Plan to Grantee and Other
Federal Agencies
IDENTIFY AND PROVIDE OR ARRANGE AND
COORDINATE UNFORESEEN ASSISTANCE DURING THE
YEAR
Initiate Appropriate Assistance to Grantee
Based on Review of Quarterly Reports, Mid-
Year Evaluation & Designated Management
Agency Evaluation
Respond to Request for Assistance From
Grantee
POSITIONS RESPONSIBLE
D.D.



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(w,o)


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P.O. 'a

*
*
*
*
*

*
*
WQM
TECH.
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PROGRAM
OFFICES



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FEDERAL
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TIMING
FFY
1'st
QTR

^^:

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2'nd
QTR

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FFY
3'rd
QTR
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4'th
QTR
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LEGEND
* - Primary Responsibility
y^- Participate  If 4 as appropriate
D.D. - Division  Director
v - Water Division
0 - OIRPA
S&A - Surveillance & Analysis
WQM P.O.'B - 106 & 208 Project Officers
 or W.Q.M. Coordinators
WQH Tech. Staff - Environmental Scientists
 NPS Coordinators, WLA Coordinators,
 etc.
Other Program Offices -
 201, RCRA, Water Supply,
 etc.
Other Federal Agencies -
 USDA, USD!, TVA, EDA, .
 COE

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                      ACTIVITIES TO BE PERFORMED IN DETERMINING & PROVIDING ASSISTANCE
        PREPARE
        ASSISTANCE
        DOCUMENTS
                                 PROGRAM
                                 COORDINATION
                                 AND INTEGRATION
    COORDINATION AND IN-
    VOLVEMENT WITH OTHER
    FEDERAL AGENCIES
      MANAGERIAL AND
      TECHNICAL
      ASSISTANCE
 en
 at
 w


 1
 w
Institutional responsi-
bilities
Program approaches
Monitoring activities
BMP's
Financing of BMP s and
control programs
Incentives
                                      Provide technical and
                                      management assistance
                                      Provide information
                                      exchange
Develop and monitor
umbrella agreements
Technical and manage-
assistance to Regions
and Grantees on pro-
totype projects:
NURP
Agriculture
Silviculture
Ground Water
Financial management
assistance
                                                                                                               w
                                                       00
                                                       H
                                                       H
         Regional assistance work
         plan
                             Identify assistance needs
                             and provide or coordinate
                             Conduct and/or partici-
                             pate in work shops
                             Coordinate national
                             assistance
                             Direct and coordinate
                             information exchange
Assist Grantees obtain
assistance
Coordinate federal agency
assistance
Assist States designate
federal agencies as manage-
ment agencies
Assist State develop
or improve:
- Institutional
  responsibilities
- Program approaches
- Monitoring
  activities
- BMP's
- Financing of BMP's
  and control pro-
  grams
- Incentives
CO
w
PW
MH
HO*
Hen
                                      Request assistance
                                      Negotiate assistance
                                                         Request assistance
                                                         Negotiate assistance
                              Request assistance
                              Negotiate assistance

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Chapter 6
Evaluation  of  Progress
                              INTRODUCTION
 Evaluation is a key element of  the management of the WQM  program.
 Evaluation establishes the feedback loop in the WQM problem-solving
 process  to keep management, planning and implementation moving in
 the right direction.  Regions must evaluate:  (1) progress against
 work programs ({106 and 208 WQM activities); (2) progress in imple-
 menting  WQM plans (and designated management agencies, if appropriate)
 and significant implementation  agreements; (3) the adequacy of the
 WQM plan and State Continuing Planning Process; (4) the consistency
 of State actions (permits, construction grants, etc.) with WQM plans
 and problem assessments, State  strategies, and State/EPA  Agreements;
 (5) internal Regional performance and the support of Headquarters
 for the  WQM program.  State and areawide agencies must evaluate
 similar  elements.  Theoretically, evaluation is the comparison of
 actual performance or status against clearly stated goals, objectives,
 output measures and cost limits.  Thus, evaluation depends on an
 understanding of what is required and desirable.

 Evaluation activities weave through the problem-solving process,
 and break down into the following general areas:  evaluation of out-
 puts, water quality trends, institutional aspects, and internal
 performance.

 This Chapter discusses the elements to be evaluated and the tools to
 manage the evaluation activities, such as the quarterly report, mid-
 year evaluation and the WQM program review.  Exhibit 6-1  shows
                                  91

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Regional Office evaluation activities for each of the elements to
be evaluated and Exhibit 6-2 shows the relationship of Regional
Office activities to Headquarters and State evaluations.

                           DOCUMENT CITATIONS

40 CFR 35.1513-8

40 CFR 35.1521, 1523, 1525, 1527

Supplemental Water Quality Management Program Guidance for FY 81,
June, 1980.
                        •
                             POLICY SUMMARY

•    Each year the Water Planning Division is to conduct a program
     review of the Region's management of the WQM Program.  The
     Report documenting the program review will be forwarded
     to the Regional Administrator from the Assistant Adminstrator
     for Water and Waste Management.

•    At an appropriate mid-point in the program year, EPA (Regional
     Office) shall conduct an evaluation meeting with each State
     and areawide agency to review and evaluate the program
     accomplishments and to discuss work projected for the coming
     year.

•    EPA (Regional Office) shall prepare a written report of each
     evaluation, forward a copy to the grantee (and the State where
     the grantee is an interstate or areawide agency) and notify the
     public of the availability of the report.

                       WQM EVALUATION ACTIVITIES

Evaluating Outputs

There is a distinction between "review" for day-to-day management
purposes and the "evaluation" of WQM management activities.  Permits,
construction grants, WQM plans, facility plans, Clean Lakes
applications and other plans (such as State Implementation Plans
for air quality) are reviewed to ensure they are consistent with
each other and with all relevant laws and regulations.  There are
different ways of reviewing outputs.  The construction grant pro-
gram uses the Corps of Engineers to conduct inspections at con-
struction sites, to evaluate plans and specifications and to monitor
construction progress which eases the burden on EPA.  Program
activities are reviewed so outputs are consistent not only with
the Clean Water Act, but also with Presidential directives and other
major environmental legislation.*  Many laws have built in consistency
requirements, such as the requirements of sections 176(c) and 316
*For example:  Clean Air Act, Safe Drinking Water Act, Resource Con-
 servation and Recovery Act, Toxic Substances Control Act, National
 Environmental Policy Act, Wild and Scenic Rivers Act.
                                   92

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of the Clean Air Act and sections 208(d) and (e) of the Clean Water
Act.  These are essential activities for program management pur-
poses.  Evaluation, however, is the determination of whether a pre-
determined standard has been met.

Regions are required to meet annually with the States and areawide
agencies to determine how all parties have performed against the
commitments they made in their work plans and State/EPA Agreements.
These reviews focus on completion of quantifiable outputs, and lead
to midcourse corrections or adjustments to subsequent years' work
plans.  The mid-year evaluation must include a review of the agency's
compliance with its public participation work program and the
requirements of 40 CFR Part 25, especially 25.12(a)(2).  In con-
junction with mid-year evaluations, Regional Offices may wish to
conduct an implementation review site visits to determine how well
WQM plans are being implemented and commitments in the Significant
Implementation Agreements are being met.  There is also a need to
look at whether the program designed in the 208 planning process is
adequate to control the problems for which it was prepared or whether
additional 208 planning efforts are needed to prepare a fully
operational control program.  Identified weaknesses should be incor-
porated into a State's Five Year Strategy, the State/EPA Agreement
and work programs in order to resolve the problems.

Quarterly reports are effective tools to monitor progress through-
out the year and to prepare for mid-year evaluations.  The timing,
content and format of the quarterly reports should be determined
during the development of the work program and incorporated into the
work program.  The Quarterly Report should contain:

          •  Expenditures to date

          •  Summary of project or program activities
             against the projected outputs (for example,
             Class II inspections completed, permits
             issued, BMPs, tested, etc.)

          •  Identification of the causes of the variances
             and the impact of the problems on completing
             the projected outputs

          •  Summary of the technical or management assistance
             provided

          •  Identification of technical or management
             assistance required

          •  Changes in roles, responsibilities, authorities,
             resources of the agency which may impact
             progress
                                  93

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          •  Progress of designated management agencies in
             meeting their projected outputs agreed to in
             the management agency letter of commitment

          •  Progress in meeting the commitments agreed to
             in the Significant Implementation Agreement
             (part of 208 work program)

Using the quarterly reports, Project Officers should prepare for mid-
year reviews by working with State and areawide agencies on the
timing and procedures for the evaluation, scheduling slippages, and
the reasons for them, prior to the meeting.

Documenting the mid-year evaluations is a report prepared ,by the
Regional Office and sent to the grantee (and the State where the
grantee is an interstate or areawide agency).  The objective of the
Report should be to assist grantees improve their management of the
program or project.  The Report should be written in such a way as
to identify the issue, identify the affect or impact of the issue
(e.g., problem created), and identify potential solutions to the
problem or issue (its preparation might be considered a self-evalua-
tion.  The Division Director, Headquarters and others will evaluate
these as well as the performance reported on).

The problems, issues and solutions identified in the mid-year
evaluations are to be factored into the design of the strategies,
State/EPA Agreements, work programs and assistance plans for the
following year.  If an approach is not leading to the implementation
of a control program or the solution to a problem, it needs to be
changed.

Project Officers should work with their States to ensure that States
have an internal process or procedure to evaluate their WQM pro-
gram activities.  Given the WQM program's emphasis on implementation
of controls for specific problems, evaluation of designated manage-
ment agencies is a key component of a State's evaluation system.
Management agency evaluation is a State responsibility and should
be included in work programs.  Management agency evaluations start
with a comparison of management agency letters of commitment to
actual progress or outputs.

Evaluating WQM in Terms of Water Quality Trends

The ultimate test of any environmental program is whether it meets
its overall objectives of environmental protection.  For water
programs, this means protecting or improving water quality in such
a way that problems aren't simply transferred to other media — the
air and the land.
                                  94

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Through monitoring and other observations, EPA, the States, area-
wide agencies, local agencies, and the public continuously evaluate
water quality.  Is water quality improving, staying the same, or
going downhill?  Are numerical criteria being met?  Are designated
stream uses justified — or are they too optimistic or pessimistic?
Is stream biology healthy?  Is ground water being protected from
overdrafting and contamination?  Are residuals properly disposed
of, recycled, or reused?  And finally, where problems exist, what is
causing them?

Because pollution is a dynamic problem trend analysis is a key part
of evaluation.  One key variable in trend analysis is population and
economic growth or decline.  It is possible that, in some instances,
population and economic growth could cancel out improvements in
water quality achieved through the problem-solving process.

State, areawide, and local agencies should evaluate the impacts
of population/economic growth on domestic waste generation, in-
dustrial waste generation, sediment production and transport,
pollution from nutrients and pesticides, ground cover, land use,
water demand and withdrawals, and any other factors.  The build-up
of toxic pollutants in the environment and in aquatic life, partic-
ularly fish and shellfish, is a trend which should be monitored.
Conclusions reached should be documented in the State's 305(b) Reporti
Conclusions from water quality monitoring should be factored into
the "problem assessment" and priorities for WQM activities in such
a way that evaluation of WQM against improvements in water quality
can be made.  Headquarters will be looking for such provisions in
work plans and State strategies as well as in mid-year evaluation
reports.

Evaluating Institutional Aspects

When assessing the causes of water pollution and developing and
implementing solutions to the problems, it is some times impossible
to separate the technical problems from the related institutional
and political problems.  Thus EPA and agencies must evaluate the
institutional aspects of the WQM programs and the framework for
managing the WQM program.  Mid-year reviews of State and areawide
agencies are an excellent forum for evaluating and if necessary
recommending solutions to institutional problems.

Two areas on which the Region may wish to focus are the Continuing
Planning Process description and the designated management agencies.
WQM regulations 40 CFR 35.1509 and 40 CFR 35.1521-3(c) and 40 CFR
35.1527 provide guidance and criteria for evaluating the adequacy
and effectiveness of the Continuing Planning Process and the
designated management agencies.

Does the Continuing Planning Process (CPP) description reflect
changes in State or Federal laws, State organization, procedures
or framework for managing the WQM program?  Is there sufficient
                                  95

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authority to control the pollutant sources?  Is there adequate fiscal/
financial expertise.  Are salary scales, staffing and training pro-
grams adequate?  Is the monitoring and enforcement programs
satisfactory?  Are activities coordinated?  Do the responsible
agencies understand the laws and regulations?  Is EPA guidance
appropriate?  Is the agency encouraging and providing for public
participation?  Is the public involvement broad-based and does the
public support the agency's actions?

Questions such as these set the tone for institutional evaluations.
Depending on the answers, the agencies involved should revise the
Continuing Planning Process description and take corrective action
in the areas of management, planning, legislation, and training.
Progress should be tracked to ensure that the corrective actions are
implemented.

Evaluating Internal Performance

Although regulations do not require it, each State and areawide agency
should conduct an internal review to determine where to raise skills,
improve efficiency or change the distribution of resources.

Regional Offices also need to conduct internal program reviews.  How
well is the program being managed?  To ensure that EPA's management
of the WQM program effectively supports the activities of the State
and areawide agencies, Headquarters has recently initiated a WQM
program review.  The review will cover progress toward implementation
of WQM plans, development of operational nonpoint source control
programs, and improved management of the 106 grants.  It will provide
a qualitative evaluation of the effectiveness of Headquarters and
Regional Office management, identify problems and issues, recommend
alternative solutions, and disseminate information on problems,
issues, and solutions to other Regions.

Evaluation is not an end.  The recommended improvements must be
implemented, programs and priorities adjusted, products improved,
control programs perfected.  Evaluation as a process is incomplete
unless factored into each step of WQM process and WQM Framework.
                                  ,Problem-
                                 Assessment
               Evaluating
               Progr ss
               Implement
             Work Programs
               WQM plar
  Jevelop
Stratigies
  Make A
Commitment
   (SEA)
                                   Prepare
                               'Work Programs
                                    96

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                                               EXHIBIT  6-1
                                REGION ACTIVITIES:  EVALUATE PROGRESS
ACTIVITY
EVALUATING OUTPUTS
Review Outputs, Quarterly Reports, Mid-Year
Evaluations & Management Agency Evaluations
Determine Causes for Variances Between Plan
& Outputs with Grantee & Subcontractors
If Appropriate meet with Grantee to deter-
mine Solutions to Variances & the Impace on
Present & Future WQM Activities
Prepare for Mid-Year Evaluation with
Grantee
Conduct Mid-Year Evaluation
Prepare Mid-Year Evaluation Report for RA
to Send to Grantee
Discuss Report -With Grantee
EVALUATE TRENDS
)btaln and Review Monitoring Reports and
Reports on Trends as they Become Available
Discuss Report Results with Appropriate
Region Personnel and Grantee
POSITIONS RESPONSIBLE
D.D.





*
(wto)
^



WQM
P.O.'e

*
*
*
*
*
*
*

*
*
WQM
TECH.
STAFF


v^

^




*
^
OTHER
PROGRAM
OFFICES










^
OTHER
FEDERAL
AGENCIES










^
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1'st
QTR
1

=%%

2'nd
QTR
I
<£^

3'rd
WTR
'^
'
-------
          EXHIBIT   6-1
(CONTINUED)
REGION ACTIVITIES:  EVALUATE PROGRESS
ACTIVITY
Based on Monitoring Reports and Trend
Analysis Discuss with Grantee the Direc-
tion of Future Strategies, work programs
and SEA - Document for Region Files
EVALUATE INSTITUTIONAL ASPECTS
Review Mid-Year Evaluations, Management
Agency Letters of Commitment, Management
Agency Evaluations and Quarterly Reports
Discuss suggestions, Ideas, and Recom-
mendations Regarding the Institutional
Problems of the WQM Program with Grantee
Determine with Grantee Solutions for
Problems and Required Assistance and
include in Mid-Year Evaluation as
Appropriate, Document for Region Files





D.D.




*
' (w,o)




POSITIONS RESPONSIBLE
WQM
P.O.'s
*

*
*
*




WQM
TECH.
STAFF




^




OTHER
PROGRAM
OFFICES
*



vS




OTHER
FEDERAL
AGENCIES




-




TIMING
1'st
QTR

2'nd
QTR

3'rd
QTR

4'th
QTR


-------
                                               EXHIBIT  6~1  (Continued)

                                REGION ACTIVITIES:    EVALUATE PROGRESS
ACTIVITY
EVALUATE INTERNAL PERFORMANCE
Assist States as Appropriate in Performing
& Review State Internal Evaluation
Review Regiona WQM Personnel on Basis of
Performance Agreements
Evaluate Regional WQM Activities and HQ's
Assistance and Support To Regions as Part
of WQM Program Review
Implement Recommended Solutions on Internal
Regional and/ or HDQ WQM Program Reviews







D.D.

*
(w,o)
(w,o)
(w,o)
(w,o)






POSITIONS RESPONSIBLE
WQM
P.O.'e

*

v""
*






WQM
TECH.
STAFF



^
*






OTHER
PROGRAM
OFFICES











OTHER
FEDERAL
AGENCIES











TIMING
1'st
QTR

2'nd
QTR

3'rd
QTR

4'th
QTR

LEGEND
* - Primary Responsibility
/- Participate  If  4  as appropriate
D.D. - Division  Director
v - Water Division
£ - OIRPA
S&A - Surveillance & Analysis
WQH P.O.'s - 106 & 208 Project Officers
 or W.Q.M. Coordinators
WQH Tech. Staff - Environmental Scientists
 NFS Coordinators, WLA Coordinators,
 etc.
Other Program Offices -
 201, RCRA, Water Supply,
 etc.
Other Federal Agencies -
 USDA, USDI, TVA, EDA, .
 COE

-------







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DOCUMENTS
PREPARED
. Region WQM Program
Review Report









. Mid~year evaluation
. Internal evaluation









. Quarterly reports
. Management agency
evaluations
. Internal evaluation







DOCUMENTS
REVIEWED
AND EVALUATED
. For two States:
- Problem assessment
- 5 Year Strategy
- SEA's
- Work Programs
- Mid- year evaluatio
- Mgmt. agency
evaluations
. Regional overview of
WQM problems
. Source control
strategies

. Quarterly reports
. Management agency
evaluations
. Mid-year evaluation
. State internal
evaluation








. Management agency
evaluations
. Mid-year evaluation
. Internal evaluation





ACTIVITIES TO BE PERFORMED DURING STRATEGY PREPARATION AND/OR
REVIEW
PROGRAM
COORDINATION
AND INTEGRATION
. Determine methods for
increasing Region
program office inte-
gration









. Determine methods for
increasing State
agency coordination
and integration









. Provide input to
Region for increasing
regional program office
inteeration





COORDINATION & IN-
VOLVEMENT WITH OTHER
FEDERAL AGENCIES
. Identify problems and
.determine solutions to
increase Federal agency
coordination









. Identify problems and
determine solutions to
increase Federal agency
coordination with Grantees
and Region and in WQM
implementation involving
federal agencies








. Determine problems and
solutions in WQM plan
implementation with
designated management
agencies and involved
FpHeral agencies




MANAGERIAL AND
TECHNICAL ASSISTANCE
. Assist Regions to
improve program
management









. Assist Grantees:
- Determine methods
for program manage-
ment Improvement
- Identify and correct
program activity
problems
- Identify & correct
management agency
performance
problems



. Determine methods for
improving performance
of management
agencies





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Appendices

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APPENDIX

WQM PUBLIC PARTICIPATION WORK PROGRAMS
This appendix provides guidance on public participation work programs.
Work programs are the primary means for WQM agencies to outline,
organize, and manage public participation activities.  The material
that follows includes background on public participation work program
requiremnts, some basic information on what makes a good work program,
and a few examples of effective public participation work program
elements.  This is not intended as a strict set of guidelines for
producing public participation work programs.

Good water quality planning often requires more than just professional
or technical competence.  A State or community's economic, social,
and political environment must also be considered.  This requires
active public involvement in all stages of the planning process.
Public participation is not always easy, and it does not guarantee
that a program's goals will be met.  Experience has shown, however,
that if public support is needed to implement a pollution control
program, citizens must be involved in the planning and decision-
making .

Work Program Requirements

Public Participation Work Programs are required both by EPA's Office
of Water and Waste Management's public participation regulations
(40 CFR Part 25, "Public Participation in Programs under the Resource
Conservation and Recovery Act, the Safe Drinking Water Act and the
Clean Water Act") and by the WQM program regulations (40 CFR Part
35.1507, "Grants for Water Quality Planning, Management, and Imple-
mentation").  For WQM grants, a requirement for separable public
participation work programs complements requirements that public
participation activities be integrated into and coordinated with
technical program activities.

A public participation work program has several functions.  It
describes the various public participation activities proposed for a
given project.  It links these activities to the project's schedule,
particularly major decision points.  It gives citizens a better under-
standing of what to expect from the project.  Lastly, it provides a
mechanism for managers to consider program implementation needs.
Because work programs are public information documents, they should
be made easily available.

Work programs must be of sufficient scope and detail to indicate the
adequacy of proposed public participation activities.  They must also
be a working guide for carrying out the activities.  For example,
rather than simply mentioning that "consultation" shall take place
at a specific point, the work program should indicate which consultation
techniques will be used, each activity's purpose and target audience,
planned publicity, descriptions of information tools (fact sheets,
newsletters, etc.), and approximate completion dates.
                                  102

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Specifically, the WQM regulations require that public participation
work programs contain the following information:

     •  a schedule indicating when key decisions will be made and
        what opportunities exist for public participation in the key
        decisions.

     •  major public participation activities and objectives related
        to key decision points and tasks (i.e., sequence of distri-
        bution of information, workshops and meetings, hearings, etc.)

     •  the major publics that will be involved

     •  budget by category, (i.e., publications and media campaigns,
        hearings, work shops, etc.), including resources available
        to the advisory committee      '

     •  indication that a public participation responsiveness summary
        will be prepared which describes measures brought before the
        public at key decision points, the public response, and the
        Agency's response as to how the plan was affected by significant
        input

     •  description of the membership, meeting schedule, and general
        responsibilities of advisory committee

     •  training of advisory committee

WQM agencies can be flexible in developing work programs, because the
detail needed to effectively manage public participation will vary.
Work programs are not static documents; they grow and change with
time and project phases.  The key is adaptability.  Planners must
adjust work programs to fit changing situations.  While there are
basic requirements for public participation work programs, the overall
goal is that agencies and their advisory groups remain sensitive to
public needs and strive towards common sense public participation
programs.

Budgets and Schedules

Budgets and schedules are particularly critical elements of public
participation work programs.  The public participation budget requires
WQM agencies to show the costs and resources associated with each
activity, including those of advisory groups.  This commits specific
resources to specific activities and provides a mechanism for evaluators
(including the public) to assess whether those resources are adequate.
There are many ways to present public participation budgets.  Exhibit 1
shows one good format.
                               103

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Work programs also require a schedule indicating when key decisions
will be made, what opportunities exist for public participation in
these decisions, and when responsiveness summaries will be prepared.
Schedules allow people to plan ahead.  WQM agencies need to know
at what point they should begin to solicit public input and develop
information materials.  Interested citizens should know when their
input is required so they can be properly prepared.  Exhibits 2 and
3 together show one good way to prepare public participation schedules.

Appropriate Public Participation Activities

Choosing public participation activities which are appropriate for a
particular project in a particular State or community situation may
well be the most difficult aspect of developing good public partici-
pation work programs.  It is also the most logical place to start.
The following step-by-step approach has been shown to be effective.

     •  Key Decisions — Each agency, in coordination with its
        advisory group and interested and affected publics, should
        identify the key program decisions to be made in the planning
        period.  These might include recommending a new septic system
        management program to a town council, selecting management
        agencies responsible for implementing a control program, or
        applying for a Rural Clean Water Program grant.

     •  Outputs — For each decision, outputs such as draft or final
        reports, data findings, or recommendations should be
        identified.

     •  Public Participation Objectives — Based on the decision to be
        made and the identified outputs, one or more public participation
        objectives can be developed.  A public participation objective
        might be to inform the general public of the nature and scope
        of the issue or to solicit public input on recommended control
        programs.

     •  Target Publics — The next step is to target specific people
        or groups for information and/or involvement.  Target publics
        could include the general public, business associations, public
        interest groups, or elected officials.  In determining these
        targets publics, several questions should be asked.  Who
        are the decision-makers involved?  Is voter approval required
        to implement the project or project recommendations?  How
        much public consensus is needed?  What groups can provide
        additional expertise?

     •  Specific Public Participation Techniques — There are many
        different public participation techniques.  Some, such as fact
        sheets, newsletters, and seminars, provide information to the
        public.  Others, such as public meetings, surveys, and advisory
        groups, are consultation techniques which facilitiate the
        flow of information from the public to the agency.  The
        choice of appropriate techniques for any particular situation
                               104

-------
        Is based directly on the public participation objectives and
        target publics previously identified.  Other factors which
        may influence the appropriateness of individual techniques
        are the time and money involved, available personnel, and the
        receptiveness of the State or local community to certain
        techniques.

One example of how this planning process has been used is shown by
Exhibit 4, a Nationwide Urban Runoff Program (NURP) Public Partici-
pation Planning Matrix.  Note that the public participation techniques
or tools at the top of the chart are basically informational.  This
corresponds to the fact that decisions made at the beginning of the
NURP program require little public consultation.  An emphasis on
information materials is more appropriate at this stage.  Later on,
decisions relate to implementing a control program and require
public input.  At this point, consultation techniques are added to the
basic program.
                              105

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                               Exhibit 1

                       Public Participation Budget

1.  Staff Time and Overhead
        a.  Direct Salaries:
               Public Participation Coordinator
                        92.5 days @ $104         $9,620.00
               Technical Staff
                        18 days @ $67. 68          1,218.00
               Support  Staff
                        56.5 days @  $42. 80      2.418.00
        b.   Benefits and Overhead:
                        0. 73 of Direct Salaries

        Total

2.  Travel
        a.  4 Roundtrips, New Orleans to Dallas @ $130 each
        b.  Per Diem:   4 @ $30

        Total

3.  Advisory Group
        a.  Reimbursement of out-of-pocket expenses;
           20 members, 6 meetings
        b.  Training

        Total

4.  Mailings
        CAC meeting notices: 120 letters
        Public meeting notices:  500 letters
        Public hearing notice: 125 letters
        Miscellaneous: Reports to EPA,
           news releases, etc. =100 letters

        Total @ $0.15 each,  845 letters

5.  Printing/Copying

4.  Phone Calls: Long  Distance

5.  Advertisements In Newspapers for
    Public Meetings and Hearings

6.  Miscellaneous
$13,256.00
  9,677.00
             $22,933.00
    520 00
    120.00
               $640.00
    970.00
    400.00
             $1,370.00
               $127.00

               $420.00

                $50.00


               $400.00

               $100.00
                                                           TOTAL    $26,040.00
Total Project Cost: $348, 850
                                                This sample budget combines infor-
                                                mation from a number of sources.
                                      106

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                                             Exhibit 2

                          SCHEDULE  FOR PUBLIC PARTICIPATION ACTIVITIES
   Activity

   1)  PAC  Meeting
   2)  Public  Meeting
      Lake  Providence
o  3)  Field Trip  -
      Lake  Providence
   4)  PAC  Meeting



   5)  PAC  Meeting


   6)  Public  Meeting



   7)  Workshops
Objective

To inform the PAC of the goals
of the FY80 Work Plan

To inform the community and
parish citizens of the scope of
the 1980 Work Plan.  Seek public
input through panel discussion

To show the interested public
what agricultural BMP's are, how
they vary, and proper installa-
tion.  Two test sites will be
visited, one with BMP's the
other without.
Targeted Public

PAC, TAG and general
public

local parish citizenry
agricultural and soil
conservation community,
lake recreation community

PAC,TAG, local and regio-
nal officals agriculture
community and all inter-
ested public.
Time Schedule

June  1980
July  1980
January-March
    1981
Status of BMP installation slide  PAC,TAG, interested public  February 1981
show and discussion of techniques
used.

Discussion df initial results of  PAC,TAG, interested public  June,  1981
data collected.

Presentation of data and discus-  local & regional officials  July   1981
sion of results                   agricultural community,
                                  lake recreational community

LDA present 3 workshops on usage  Agricultural & recreation-  September 1981
and disposal of pesticides and.    al communities
their containers.  Discussior. on
alternative vector control.

-------
 Exhibit 2
 Page 2
 Activity

 8) PAC Meeting


 9) Workshops
10) Public Meetings
11)  PAC Meeting
12)  Public Hearing
Objective

Data presentation and discus-
sion of results

SWCC will present 3 workshops
on effective soil conservation
practices based on the Lake
Providence results.

Three  (3) meetings will be held
discussing the final results of
the Lake Providence study.  In-
put will be solicited as to the
public perception of the results
and need for increased controls
or legislative powers for agri-
chemicals and soil erosion con-
trols.

Discussion of #10 Meetings and
final results of study.  Recom-
mendations to lead agency on
pesticide, soil and legislative
controls needed.

Solicite final comments on Lake
Providence Study and PAC recom-
mendations in Lake Providence
and Baton Rouge.
13)  Newsletter Articles Dissemination of Information
                        through the utilization of an
                        existing mailing list.
Targeted Public

PAC,TAG & interested
public

Agricultural & recrea-
tional communities
Agricultural & recrea-
tional communities,
State, regional and
local officials
Time Schedule
December 1981
April    1982
June
1982
                                                                                                     CO
                                                                                                     o
PAC,TAG,State, local
and regional officials,
agricultural & recrea-
tional communities, in-
terest public.

All interested publics
                                  All interested publics
July    1982
September 1982
                            See Exhibit 3

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Exhibit 2
Page 3
Activity

14)  Fact Sheets
15)  Responsiveness
     Summaries

16)  Notices
Objective

To dissiminate the necessary
facts to the  public.
To inform EPA of public
volvement
To inform  the  Public of Me-
etings and hearings for the
Lake Providence  Study.
Targeted Public

All interested publics


EPA


All interested publics
Time Schedule

See  Exhibit 3


See  Exhibit 3


See  Exhibit 3
 Source:  Exhibits 2 &  3
        FY 80  208 Work Plan
        Lake Providence Project
        Louisiana Department of Natural Resources

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                       Exhibit 3
         FY80 PUBLIC PARTICIPATION SCHEMATIC
           Article
Public Meeting Notice
newsletter Article
News
Trip
Release for Field
                        I960
                       - M
                       - J -
                         J -
                         A
                         S
                       - 0
                         N
•PAC  Meeting
Public Meeting
4'duu oueeu 	

Public Meeting Notice



Woikshop No Lice '


Public Hearing Notice ~


u 	
F ^^^
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A
M
J. „,
j
. .. A
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0
D-
1982
J
F
A
M'

J. . ,, 	 _„
I


0
N
                                      Field Trip-BMP
                                      Installation
                                      PAC Meeting
                                      PAC Meeting
                                      Public Meeting
                                      Workshop-Pesticides
                                      and Alternative
                                      PAC Meeting
                                      Workshop-Effect Soil
                                      Conservation Methods
                                      Series of Public
                                      ings
                                      PAC Meeting
                                      Public Hearing
Summary

*Proposed starting date, will be  adjusted  as necessary.
                        110

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                                                          Exhibit 4




                                                NURP PUBLIC PARTICIPATION PLANNING MATRIX
STAKES
I. Project Proposal/
Initiation
II. Problem Assess-
ment; Source
Identification
III. BMP Evaluation
(Including costs);
Cost/Benefit
Analysis
IV. Bff Selection; •
Management Plan
Adoption.
V. Implementation
DECISIONS
Agency willing to
participate?
Proposal acceptable?
Runoff problems
serious? wide-
spread?
Controls necessary?
Would controls be
utilized?
Feasible control al-
ternatives 1n this
situation?
Short-, long-range
Implications?
l-'ost cost-effective
controls?
BMP(s) most feas-
ible for this
situation?
t'ost effective plan
achievable?
Costs(socio-eco-
nomlc, political)
justifiable and
• bearable?
OUTPUTS
Project outline
Proposed work-
plan
Report and data
summary
Recommendations
with respect
to controls.
Report and data
Simula ry
Recommendations
for specific
controls
Urban runoff
management
plan.
Ordinances,
regulations;
Institutional
changes ;
Uater quality
Improvement.
OBJECTIVES
Create general understanding
of project goals and
objectives.
Communicate nature/ex-
tent of problem(s),
implications for fu-
ture;
Explain need for controls.
stimulate and gather
feedback;
Prepare testing area.
Explain findings ;
Communicate need for con-
tinuation of study,
formulation of manage-
ment plan;
Stimulate feedback from
all publics.
Communicate rationale
for plan;
Assure public participa-
tion in decision on
management plan
Document, publicize re-
sults;
Assure continuing feedback
for plan Improvement.
TARGET PUBLICS
Agency Policy Board
Agency staff
Agency Advisory Committee
General Public
Same as above plus:
Key Individuals/or-
ganizations;
Impacted publics
(testing areas)
Same as above.
Same as above plus:
Elected Officials
Same as above.
PUBLIC PARTICIPATION TOOLS
Program Summaries
Meetings w/Agency staff
Press Release
Newsletters-
Same as above plus:
Fact Sheets
Displays
Media Programs (articles,
Inserts)
Mailings
Meetings w/key Individuals
and organizations.
Some as above plus:
Public meetings
1
Same as above plus:
Kndla blitz (Interviews,
talk shows);
Workshops
Same as above minus:
Media blitz
Workshops
Source:   EPA, Water Planning Division

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