SUMMARY OF PUBLIC HEARINGS ON POSSIBLE ADMINISTRATION
    PROPOSALS TO AMEND THE FEDERAL WATER POLLUTION CONTROL
    ACT (P.L. 92-500) AS IT RELATES TO THE MUNICIPAL WASTE
    TREATMENT CONSTRUCTION GRANTS PROGRAM
                           Prepared by

           THE OFFICE OF WATER AND HAZARDOUS MATERIALS

                 ENVIRONMENTAL PROTECTION AGENCY

                        Washington, D.C.


                           July, 1975
CONTENTS



Background 	    1

Reduction in the Federal Share 	    5

Limiting Federal Funding of Reserve Capacity to Serve             13
  Projected Growth 	

Restricting the Types of Projects Eligible- for Grants             21
  Assistance 	

Extending the 1977 Deadline for POTW's to Meet Section 301        32
  Requirements  . -.'•. •'-.	
                     ',
Delegating Greater Program Responsibility to the States. ...    36

List of Witnesses	    38

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     SUMMARY OF PUBLIC HEARINGS ON POSSIBLE ADMINISTRATION
     PROPOSALS TO AMEND THE FEDERAL WATER POLLUTION CONTROL
     ACT  (P.L. 92-500) AS IT RELATES TO THE MUNICIPAL WASTE
     TREATMENT CONSTRUCTION GRANTS PROGRAM ]_/
 Background
      These  hearings derived in part from a letter received
 from  the  Office of Management and Budget which suggested several
 issues  that could be discussed relative to the municipal con-
 struction grants program.  The need for such a public discussion
 was based on two factors:  (1) experience with the program
 gained  by all  parties  in the past few years, and (2) the
 results of  the most recent EPA-State survey which indicated
 a  need  under the current law to fund eligible projects in excess
 of $350 billion.  The  magnitude of the indicated need is well
 beyond  the  capability  of the Federal budget to fund with 75
 percent grants in any  reasonable future time.  The 1972 Amendments
 authorized,  and the Administration has allotted to the States,
 $18 billion  in construction funds.  These grant funds, at the
 rate  of 75  percent Federal funding will support $24 billion  in
 total  eligible costs.
      The  hearings considered alternative means of funding those
projects  that  are absolutely essential to attaining required
treatment levels without negating major water quality objectives
of the Act.   The hearings related to changes to be made in any
  I/ This is a summary of the oral testimony received by EPA.
     The statements received for the record which didn't close
     until July 7, are still being reviewed in detail.  A quick
     review indicates no significant departure from the general
     tone of comments actually received at the hearings.

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future funding that Congress may make available after the current
$18 billion is expended.  Any possible amendments emanating from
this hearing procedure will  not pertain to changing the provisions
under which grants are to be made with presently available funds.
     Five issues were addressed at the hearings including:
     1.  a reduction in the  Federal  share
     2.  limiting Federal funding of reserve capacity to serve
         projected growth
     3.  restricting the types of projects eligible for Federal
         grant assistance
     4.  extending the 1977  deadline for publicly-owned treatment
         works to meet the requirements of Section 301(b) of the
         Act.
     5.  delegating a greater portion of program responsibility
         to the States
     The purpose of these hearings was to receive public comment,
views, and information on the above five issues.  The first four
of the five issues were contemplated as possible subjects for an
Administration proposal to amend PL 92-500.  The information
derived from these hearings  provided EPA with a better understanding
of the issues and their potential impact.  Should specific legis-
lative proposals be formally submitted to Congress, the information
generated at the hearings will be useful in preparing the required
draft environmental impact statement.

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                                -  3  -
      For the fifth issue,  delegating  greater  responsibility
 to the States, EPA has endorsed HR  2175  and HR 6991.  These
 hearings filled the purpose  of giving EPA  a better  understanding
 of the capacity of the States  to  accept  greater delegation and
 provided views and information concerning  administrative  pro-
 cedures that might be used to  accomplish more timely  delegation.
      Background papers were  prepared  for the  public's use before
 the hearings as an aid in  focusing  discussion at  the  hearings.
 The discussion papers did  not  cover all  possible  alternatives
 nor did they indicate any  predetermined  course of action  already
 selected by EPA.^,  -In addition  to  being published  in the Federal
                       i-
 Register, about 2,300 copies of the papers were distributed  to
 the public.   The hearings  were announced through  the  Federal
 Register, national  and regional press releases, industry  and
 environmental  newsletters  and  journals and by other methods.
 Dates.  Locations,  Attendance
     A  series  of four public hearings were held:  June 9, 1975
 (Atlanta,  Georgia);  June 17, 1975 (Kansas  City, Missouri); June 19,
1975 (San  Francisco,  California); and June 25, 1975 (Washington, D.C.),
     Each hearing was  conducted by  a  panel  of EPA personnel.
The panelists for each hearing were as follows:
     Atlanta:  Alvin Aim, Chairman,  Assistant  Administrator
               for Planning and Management

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                               - 4 -
               Jack Ravan, Regional  Administrator, Atlanta
               Jack Rhett, Deputy Assistant Administrator for
               Water Program Operations
     Kansas City:  James Agee, Chairman, Assistant Administrator
                   for Water and Hazardous Materials
                   Jerome Svore, Regional  Administrator,  Kansas  City
                   Jack Rhett, Deputy Assistant Administrator for
                   Water Program Operations
     San Francisco:  James Agee, Chairman
                     Jack Rhett, Deputy Assistant Administrator  for
                     Water Program Operations
                     Paul DeFalco, Jr., Regional  Administrator
     Washington, D.C.:  John Quarles, Chairman, Deputy Administrator
                        Gerald Hansler, Regional  Administrator,  New York
                        James Agee,  Assistant Administrator for
                        Water and Hazardous Materials
                        Alvin Aim, Assistant Administrator for
                        Planning and Management
                        Jack Rhett,  Deputy Assistant  Administrator
                        for Water Program Operations
     EPA heard testimony from 105 witnesses and received  statements
for the record from an additional 126 people and organizations.
(See attached list.)  Approximately  600 people attended the

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                               - 5 -

hearings.  Transcripts were made of each hearing.  These along

with the statements for the record will be published as a complete

set and made available to the public.  Inquiries concerning

these  hearings should be directed to:

                        Mr. David K. Sabock
                        Environmental Protection Agency
                        401 "M" Street, S.W.  (WH-556)
                        Office of Water and Hazardous Materials
                        Washington, D.C.  20460



REDUCTION  OF THE FEDERAL SHARE

The  hearing dealt with the issue of whether P.L. 92-500 should
be amended to reduce the Federal share for construction grants
from the current level of 75 percent to a level  as low as 55 percent.



Summary of Testimony

     At all of the hearings the witnesses were generally opposed

to this proposal for several reasons including,  in the opinion

of the witnesses:

     A.  The inability of the localities and States to assume

any greater financial burden in the construction of POTW's, given

the present economic and financial climate.  Since local tax

revenues are not increasing as fast as demands for them, additional

local  funding of treatment facilities would necessitate either

local  tax  increases, sewerage rate increases, or cutbacks in

other local services.  Even under the present grant rate, diffi-

culties are encountered in arranging the financing for many projects.

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     B.  The inequity of lowering the Federal  share after some
communities have received grants at the 75 percent rate.   Thus,
reductions would tend to discriminate against those localities
who may be ready to proceed but are further down the priority
list.
     C.  "Hedging" on the part of the Federal  Government.  Is
the purpose of the program to attain the goals specified  in
P.L. 92-500, or is the Federal Government backing away from its
previous commitments in the interest of saving money?
     Specifically, in many cases, effluent and water quality
standards are either set or required by the Federal  Government,
or are based on the assumption of 75 percent funding, and are
higher than are warranted in terms of local or State self-interest
Hence, the Federal Government should, according to the witnesses,
continue the 75 percent rate to provide the incentive to  attain
the standards.
     D.  The program has started to build momentum—over  $6
of the $18 billion has been obligated.  Since the program is
starting to work, it should be kept as stable as possible.   Any
change in the grant rate would inevitably cause delays in the
implementation of long-range programs, and thus in the attain-
ment of the national water quality goals.  Some States would
have to legislate new grant programs and the priority lists
would be shifted due to some municipalities dropping out.

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State Officials
     States opposed the reduction.   States,  like municipalities,
are generally in strained financial  conditions, and  increases  in
State funding would necessitate either higher  taxes  or  commensurate
reduction in other programs.  Some  States,  such as  California
and New York, have grant programs which could  theoretically  be
expanded; others (Kentucky, Tennessee, Georgia, Florida)  have
only loan programs.  In these States, passage  of  a  grant  program
is unlikely, and the local financial burden of the  grant  reduction
would be shifted to the municipalities.

Local Officials
     Municipalities were universally opposed to the reduction
of the Federal share—almost all of them stressed that their
financial conditions were already strained  and it was pointed
out that the major governmental  financial problems are at the
local level.  Given the constraints on budgets, it is very
difficult to ask for, or get support  for, new expenditures,
and there are also difficulties  in marketing large bond issues.
     It was stated that reduction in  the grant rate would delay
programs.  In some cases, communities are in the first phase
of long-term programs where commitments have been made contingent
on a 75 percent rate.   It was pointed out that reducing the

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grant rate is a drastic proposal when billions of dollars are
awaiting obligation because of regulatory requirements.
     Several representatives pointed out the need to maintain
the grant rate in light of the present requirements, and that
if the grant rate is reduced, requirements should be reduced
also.  For example, one Georgia county official  said that the
Act has caused considerable expenditure of local  funds for projects
without direct benefits and without cost-effective evaluation.
Another county official from Georgia pointed out that the stringent
State effluent requirement was based on 75 percent funding.
     Also rejected by the witnesses was the premise that high
Federal funding rates result in overdesign of facilities.  A
spokesman from Painesville, Ohio, said that current overdesign
practices result not from the 75 percent rate, but from the  long
delays in the application process—as long as 10 years from
initial application to construction completion.   A witness from
Fulton County, Georgia, emphasized this saying,  "I have never
seen a sewer line that was too big."
     Some localities, especially Tampa and Hollywood, Florida,
expressed interest in a "sliding scale" grant rate for various
types of facilities.  (See Alternative Approaches below.)

Professional Groups
     With very few exceptions, these witnesses also opposed  the
reduction for the reasons cited above.  They particularly rejected

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the notion that a larger local share would lead to greater
accountability on the part of the locality and ensure cost-
effective design, stressing that facilities were already designed
in a responsible and cost-effective manner.  They also emphasized
need for program stability and warned against procedural delays.

Environmental Groups
     These groups were also opposed, with several exceptions.
A  few groups proposed alternative reduction schemes  (see Alternative
Approaches below).  They cited the inability of localities to
bear the  additional financial burdens and the possibilities of
delaying  achievement of national water quality goals.  The Con-
servation Foundation position was that without funding to provide
incentives for communities to meet the high Federal water quality
standards, the standards might well be revised downward to levels
which require less expensive treatment processes.

Alternative Approaches
     Of the small minority of witnesses who favored  reduction
of the Federal share, none felt that it should arbitrarily be
reduced to a given level; rather, they proposed several alternative
reduction schemes based on various other criteria:
     a.   NRDC stated that the criterion should be the level of
Congressional appropriation, and each eligible project specified

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in the Needs Survey should get a share of the total  on a pro-rata
basis.  This proposal would appear to lead to an arbitrary grant
rate, based on neither financial need nor required incentive.
     b.  The Mayor of Hopkinsville, Georgia, stated  that the
75 percent grant rate for treatment plants and interceptors
should be retained, but that for collectors Federal  grants should
be inversely related to the per capita income of the locality,
so that only the poorest group of communities would  receive
75 percent.
     c.  A representative of DeKalb County, Georgia, stated that
grant percentages should be based on the amount of pollution
abatement that could be obtained (i.e., repairs to a continually
overflowing storm sewer should be funded at a higher rate than
additions to treatment plants to meet projected growth).  A
related suggestion was that the 75 percent rate be used for
capacity to serve existing population needs, and a 50 percent
rate for capacity to serve projected needs—basically an urban
suburban differential.
     Most of the testimony on this issue dealt with  the reasons
the grant rate should be retained.  However, a recurring theme
was the desirability of reducing requirements.  The  main areas
in which spokesmen felt requirements could be reduced without
a significant sacrifice in water quality goals were  the following:

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     • A number of people at the San Francisco meeting discussed
the savings possible through not having to meet secondary standards
for ocean outfalls, although a representative of the Oceanic Society
urged caution.
     9 A few witnesses suggested that secondary treatment pro-
cesses be permitted, even though EPA secondary standards were not
met, so that waste-stabilization ponds and trickling filters not
designed to meet current removal rate standards would become
acceptable.  An engineering representative pointed out that in
Georgia, some 200 publicly-owned waste stabilization ponds are
expected to be abandoned as a result of EPA's definition of
secondary  treatment.

Discussion Topics
1.  Would  a reduction in the Federal share make the Federal
    funds  cover more projects and thus result in more total'
    construction?
2.  What is the ability of State and local governments to increase
    their  financial participation in the program?"
     The reaction to these questions is indicated in the previous
discussion.   In summary, the first question was seldom addressed.
The overwhelming concern was with the increased difficulty of
financing projects and the instability that a change in the
grant rate would introduce.  Although the change is not proposed
to take place until after the obligations of present funds, many

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references were made to the long-term process of obtaining

financial commitments among communities and governmental  bodies,

and the difficulties of increasing revenues under current economic

conditions.

3.  Would a reduction in the Federal share tend to increase
    State and local incentives to develop cost-effective  projects?

4.  Does the 75 percent Federal share of capital construction
    tend to induce capital intensive projects with low annual
    operating costs?  Would this relative emphasis be affected
    by lowering the Federal share?  What would be the effect
    on annualized cost?

     The prevailing opinion was that the grant rate did not affect

the cost-effectiveness of projects or the capital-O&M ratio--

municipalities and engineering representatives frequently com-

mented that engineering practices are not sensitive to the

municipality's cost share.  Moreover, State and EPA reviews

encourage careful analyses.

     However, it is interesting to note that a number of  commenta-

tors said that various State standards and local plans were

contingent upon 75 percent funding, and that a change in  funding

rate would entail changes in plans.

5.  What would be the effect of varying the grant rate according
    to different priority projects or features of projects,
    such as 75 percent for capacity^to handle existing population
    and 50 percent for excess_capacity to handle population growth.
    Another possible combination might be:

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                               -  13  -
              Treatment plants and  interceptors     75%
              Combined sewer  overflow               60%
              Collector sewers                      45%
              Storm'water  discharges                zero
     This question  was  asked at the  meetings,  rather than  in
the discussion papers,  and  hence  the reactions were  rather
indefinite.   When the question was discussed,  there  was tentative
approval to the  general concept.  There were many indications
of differences in priorities among the  categories, as  discussed
under Issue 3.
     On July 1,  1975, EPA,  via a  letter to all State agencies,
the witnesses, and those  people and  organizations submitting
statements for the record,  asked  for their reaction  to this
question.  Replies are  still  being received.
LIMITING FEDERAL FUNDING OF RESERVE CAPACITY TO SERVE PROJECTED
GROWTH
The hearing dealt with the issue of whether P.L.  92-500 should
be amended to limit the amount of reserve capacity of facilities
that would be eligible for construction grant assistance.
Summary of Testimony
     The concensus of opinion in the public hearings on this
issue was that the Act should not be amended to limit the amount

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of reserve capacity eligible for grant assistance.   Most witnesses,
especially public officials and consulting engineers, preferred a
flexible approach to plant sizing based on case-by-case cost-
effective analysis, and said that the Federal  government should
help fund the total capacity of cost-effective designs.
     Some witnesses acknowledged that excess reserve capacity
has been a problem, but others argued that system overloading
was a more critical problem.  The witnesses were almost all  opposed
to funding of capacity for backlog only.   The  idea  of funding
ten years of growth in treatment plants and roughly 20 years
of growth in interceptors and outfalls had more support, especially
among witnesses from California.  Many persons said that Federal
funding of 10 years of growth in treatment plants would be
suitable, but that sewers should be funded for 50 years or for
the ultimate population.

State Officials
     Almost every state official who testified was opposed
to changing the Act with respect to Federal  funding of reserve
capacity.  Most State witnesses preferred general  Federal
guidance with flexibility.  Most said that present practice,
including 201 and 208 planning, is sufficient to limit excess
capacity.  They also said that the extent of Federal  participation
in a project does not alter local accountability.

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                              - 15 -
     Although representatives of Georgia, Florida,  Missouri,
California and Pennsylvania said that excess reserve capacity
had been, or might be, a problem, speakers from Nevada, Georgia,
New York, and Virginia said that plants and sewers were not
oversized in their States.
     The speaker from Nevada said that EPA and the States should
focus attention on population projections, sewage flow projections,
and cost-effectiveness instead of limiting Federal funding of
reserve  capacity.
     A witness from Pennsylvania said that limiting Federal
funding  of  reserve capacity could lead to local sewer moratoria
which  can aggravate urban sprawl by encouraging leapfrogging
and  private development of treatment systems.
      California  certifies construction grant applications for
only ten years of  growth  in treatment plants and 20 years in
 interceptors and outfalls.  The State Water Resources Control
Board  provides the population  projections for each grantee.
A representative of the Board  testified  that the California
plan employs several  other methods  to limit eligible capacity,
including low population  growth allowances  in critical air
quality  basins,  low allowances for  capacity to handle  infil-
tration  and inflow, and low allowances for  capacity to serve
new  and  second home communities.

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                              - 16 -
Local Officials
     Most of the witnesses representing cities and counties
were also opposed to changing the Act with respect to Federal
funding of reserve capacity.  Most supported the current program.
     Opinion was split on whether the present practice allows
excess capacity.  The speaker from Houston said that overloading,
not overdesign, was the problem.  However, an environmental
analyst from  Newark, N.J., testified that EPA policies con-
tribute to sprawl and urban decay by providing capacity for
population growth.
     Several witnesses from California, including speakers
from Orange County and San Diego County, said the State's plan
which limits grant assistance to 10 years of growth in treatment
plants and 20 years in interceptors was a good middle ground
between no funding of growth and funding of unlimited capacity.
     At least two speakers representing municipalities said
that funding of 10 years of growth in a treatment plant would
be sufficient, given that the plants were designed for modular
construction, but that 20 years of growth in interceptors was
not enough because of large economies-of-scale and the disruption
caused by sewer construction.
     A councilman from Livermore, California, supported Federal
funding of capacity to serve the existing population only.

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     Most of the witnesses who supported limits on Federal
funding of reserve capacity said that such limits should be
applied with discretion, taking local conditions into account.

Professional Groups
     None of the professional groups represented at the hearings
supported a change in the Act with respect to Federal funding
of reserve capacity.  With few exceptions, professional engineering
groups supported EPA's present program of case-by-case cost-
effective analysis and no limits on Federal funding of cost-
effective designs.
     Speakers from engineering groups in Iowa and Nebraska
and  from the Association of Metropolitan Sewerage Agencies
(AMSA) said that funding of only 10 years of growth in treatment
plants might be advisable, given modular construction, but
that sewers should be designed and funded for 50 years or
for  ultimate capacity.  Other representatives of professional
groups were opposed to limits on Federal funding of capacity
on the grounds that limits would cause delays, would contribute
to non-cost-effective designs, and would be a poor approach
to the broader issue of land use controls.

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                             - 18 -
Environmental Groups
     All of the witnesses from environmental interest groups
supported some limits on Federal funding of reserve capacity.
     Environmentalists from California approved the State's
plan of limiting eligible reserve capacity, especially the
feature of the plan which further limits funding of capacity
in critical air quality basins.  In general, the environmental
interest groups were interested in limiting suburban sprawl,
which they felt was spurred by funding of reserve capacity.
     The speaker from the Natural Resources Defense Council
said that the Federal government should not fund plant and
sewer capacity needed to serve population growth expected
after 1983.

Alternate Approaches
     Several witnesses suggested alternative methods for dealing
with the problems implicit in this issue.  These problems are
cost inefficiencies and secondary environmental impacts associated
with provision of too much treatment capacity.
     A speaker from the Kentucky Council of Consulting Engineers
said that instead of limiting Federal funding of reserve capacity,
EPA could review local population projections for technical
justification.  He also suggested the use of sound local land

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use planning coupled with sewer designs to eliminate secondary
environmental impacts of sewers.
     Another witness said that increased awareness of the
need for local initiatives in water pollution control would
be valuable.  He suggested that the Congress choose a specific
objective for nationwide wastewater treatment, provide the
funds needed to accomplish that objective, then turn funding
of construction over to State and local governments.  Such
a policy would include a policy of one-time-only Federal grants
to communities for any given type of facility.

Discussion  Topics
1.   Why should the Federal taxpayers'^funds be used to sub-
     sidize  the cost of growth in particular communities, as
     is now  the case?
     Many witnesses felt that it is important to design cost-
effective systems and that local governments need a high level
of Federal  participation in the cost of cost-effective designs.
These witnesses said limiting Federal financing of reserve
capacity is  similar to reducing the Federal share, and said
local governments have great difficulty raising local matching
funds even  under the current program.
     Those  witnesses who supported  limitations on Federal funding
of reserve  capacity were, in fact,  opposed to subsidizing growth
in particular communities.

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2-  For a given level of Federal funds, would a limitation
    in funding for future population result in the funding
    of more projects?'

     A few witnesses said that a reduction of this type in

the level of Federal participation would allow more projects

to be funded.  However, many witnesses said that such a reduction

would place a financial burden on local governments and cause

delays in the construction grants program.  Such delays would

nullify the fund-spreading effect.

3.  If Federal assistance were limited to serving only existing
    population, would this enhance or detract from the authority
    of local governments to manage land use?

     On the basis of the testimony, this type of limitation

would neither enhance nor detract from local land use authority.

One witness testified that sewer moratoria in one area cause

leapfrogging development and environmental degradation in another

area.  Local land use legislation in conjunction with local

wastewater management planning would be useful, another witness

said.
4.  Does the construction of excess capacity for population
                                   " charges, and ultimately
    higher taxes and inducements for development of subdivisions,
growth tend to force higher user
highei~~~
etc.?
     Several witnesses said that population projections tend

to be self-fulfilling.  But the construction of excess  capacity

for population growth would not necessarily force higher user

charges.  As one witness testified, the opposite could  be true

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when  new development is spurred by the project, bringing more
users  into  the service area and driving down the average user
charge.


RESTRICTING THE  TYPES OF PROJECTS ELIGIBLE FOR GRANT ASSISTANCE
The  hearing dealt with the issue of whether P.L. 92-500 should
be amended  to restrict the types of projects eligible for con-
struction grants funding.

Summary of  Testimony
      Most of the testimony rejected any reduction in current
eligibilities,  arguing that any change would be highly arbi-
trary  and would:  (a)  distort cost-effectiveness analysis toward
eligible facilities; (b)  discriminate against particular areas
of the country; and (c)  reduce the likelihood of achieving
the goals of the Act.  On the other hand, there was some support
for eliminating collector sewer eligibility and maintenance-
type work such as infiltration/inflow correction.  Several
advocates  of such restriction, however, favored retaining
statutory eligibility and relying on administration of the
program to preclude EPA funding of all but the most necessary
facilities  of this  type which could not be locally-financed.

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                              - 22 -
State Officials
     State officials tended to emphasize two points:   (1)   many
needed facilities were beyond local  financial  capability,  and
a reduction or elimination in Federal  grants would preclude
construction of such facilities; and,  (2)  priority systems
developed by the States were the proper way to insure wise
choice in construction of facilities.   Representatives of
Georgia, Nebraska and Virginia, among  others,  stated  that
their priority systems had strictly  limited funding for facili-
ties other than treatment plants and interceptors.
     For the most part, State officials specifically  encouraged
retention of eligibility for rehabilitation and for infiltration/
inflow correction when these were shown to be  cost-effective.
Representatives of Florida, Nevada and Wisconsin,  among others,
made this comment.
     Representatives of such States  as Georgia, Nebraska,  Texas,
New York, New Jersey and Pennsylvania  stated specifically  that
collector systems should remain eligible, as these were a
considerable need for financial assistance in  certain munici-
palities.  A representative of Virginia indicated  that assistance
for collector systems is targeted to areas where public health
problems have manifested themselves  as a result of individual
disposal systems.  None of those testifying suggested what specific
criteria might be used to limit EPA  funding of collectors.

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                              - 23 -
     On the other hand, witnesses for Florida, Wisconsin  and
Nevada raised some support for a statutory elimination of col-
lector eligibility.  A representative of the State of Missouri
suggested that if EPA were serious about eliminating collector
eligibility, it should insure that other Federal  or State
assistance programs were available and adequate.
     There was also support, from such States as  Virginia,
Nevada and Wisconsin, for eliminating stormwater  treatment
and control from eligibility, at least within the Title II
grant program.  An official from Guam, however, insisted that
stormwater was perhaps that island's major water  pollution
problem.  He recommended that stormwater facilities remain
eligible.

Local Officials
     Local officials stressed wide variability across the nation
in pollution problems and in types of needed facilities in
arguing for continuing the current eligibility structure.
One person asserted that any restruction would be "crippling",
while another said reductions would place an "unbearable burden"
on local  governments in meeting the goals of the  Act.  Several
officials noted that a change in eligibilities would severely
limit or preclude construction of certain facilities even when
they were the most cost effective.  Several speakers argued

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 that  is eligibilities were restricted, water pollution control
 requirements  of  local governments should similarly be reduced.
      While spokesmen favored the present priority system as
 a means of allocating available funds among projects within
 States, some  criticized any "national standard priority system"
 as "unworkable."  Without considerable Federal financial support,
 a Nashville,  Tennessee, official argued, local governments'
 priorities would shift away from treatment and control of
 present flows and overflows toward acquisition of a broader
 revenue base  through extension of collector systems.
     Those few speakers who specifically addressed the categories
 of infiltration/inflow correction and sewer rehabilitation
 generally urged that they remain eligible as at present.
     Many of the comments from local officials related to
 collectors of wet weather overflows from combined sewers.
 Opinion was divided on eligibility for both types of facilities.
 Wet-weather-related water pollution problems are critical,
 one of California's local officials testified.   Elimination
 of eligibility, another said, would have a "disastrous effect"
 on cities with combined sewers.  Local officials from Tennessee
 and Kentucky  stated that without Federal  financial assistance
 their combined overflow problems would not be corrected.  One
 official, however, testified that costs of overflow treatment
and control are enormous, while the benefits are negligible,

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                              - 25 -
and thus considerable restriction of funding this category
might be warranted.  An official  for a Missouri  municipal
sewer district recommended a lower grant rate for treatment of
combined overflows and no grant for separation of a combined
sewer system.
     With regard to collector sewers, many local officials
testified that elimination of eligibility was acceptable,
particularly if other grant programs would be utilized.   Those
who favored eliminating collectors made several  points:   (1)
collectors should be a local responsibility; (2)  there  is
adequate local incentive to install collectors when they are
needed; (3)  cities which have always locally-financed collection
systems consider it inequitable for other similar cities to
receive grants; (4)  director cost-to-service relationships,
benefits to property value, and special financing mechanisms
make it much easier to charge residents the costs of collectors
than of other pollution-control facilities.
     One speaker recommended lowering the grant rate for col-
lectors to 33 percent.  Another official asserted that if EPA
were interested in eliminating collector eligibility, it should
be done in the very near future,  since many communities  delayed
needed investment in hopes of receiving a grant.

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                              - 26 -
Professional Groups
     Most witnesses for engineering firms or societies urged
continuation of present eligibilities, and reliance on cost-
effectiveness analysis for selection of the best means to solve
particular water pollution problems.  The tone of comments
generally was that "diverse problems need diverse solutions"
and "different projects meet goals by different means."   The
Water Pollution  Control Federation representative stated that
flexibility in eligibility was needed to allow the program to
be tailored to different State and local needs.
     "Intelligent cost-effectiveness analysis is a proper device
for determining funding," one speaker asserted.  Another person
argued that the present range of eligibilities was most cost-
effective because "all alternatives are funded alike."  A
representative of the National Society of Professional Engineers
said that denying aid for one or more elements in a pollution
control systems would in some cases encourage the grant recipient
to take action other than that most cost-effective.  Local
officials favor elements eligible over those not eligible,
one person suggested, despite possible relative ineffectiveness
of eligible elements.
     Speakers praised the current priority list system as
"rational and efficient" and as "a good management philosophy."

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                              - 27 -
     Among comments supporting a limit on eligibilities, several
of the persons testifying favored a reduction in share or elimi-
nation of eligibility for stormwater treatment and/or control.
One such speaker also favored elimination of eligibility for
correction of combined overflow problems in order to allow an
"orderly" funding program.  Another person who specifically
addressed eligibility for collector sewers said there was a
need for Federal financial assistance for such facilities in
some areas.

Environmental Groups
     Not all of the environmental groups that testified addressed
themselves to the question of eligibilities.  Among the groups
who appeared, opinion was divided but tended to oppose restrictions
in eligibility.  Speakers opposing restrictions included those
representing the National Resources Defense Council, the Georgia
Fish and Wildlife Federation, the Conservation Foundation, and
the San Francisco Bay Oceanic Society.
     A spokesman for the California chapter of Friends of the
Earth, however, said a restriction to categories I, II, and
IVB "sounds reasonable."  Arguing the Federal assistance should
not be for "frills" or to make up for "local mismanagement," a
spokesman for the California chapter of the Sierra Club said
that infiltration/inflow correction, sewer rehabilitation, and

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                              - 28 -
separation of combined sewers should be a local  responsibility.
Interceptors and collectors, he added, should be eligible for
Federal assistance when they were part of a regional  system.
     A representative of the Georgia Fish and Wildlife Federation
said that while all current categories should remain  eligible,
allocations among States should be made only the basis of needs
for categories I, II, and IVB.
     The Morris County (New Jersey) Conservation Coalition,  which
said that a broad range of options should be kept open for funding,
nevertheless took the position  that some stormwater problems should
be dealt with "before the fact" to minimize recourse  to capital-
intensive construction techniques.

Alternative Approaches
     1.  Make allocations to States only on basis of needs in
categories I, II, and IVB, but  let States set own project priorities
with current eligibilities.
     2.  Lower the grant rate for certain types  of projects,
particularly stormwater.
     3.  Make legal and engineering fees ineligible project
costs.   The present regulations dealing with these items result  in
project delays too long to make the amounts in question worth
inclusion in the grant program.

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                              - 29 -
     4.   Institute a separate grant program for stormwater
 treatment and/or control, rely on 208 planning to determine
 project eligibility-

 Discussion Topics
 1.   Since collector sewer construction has been^a traditional
     local responsibility, and since Federal assistance for
     sewer construction is now available through the Farmers
     Home  Administration and the HUD block grant program, why
     should EPA continue to provide assistance for sewer
     construction?
     A number of persons commented that collectors should not
 be  funded through the Title II grant program although several
 speakers  added that EPA did not now fund collectors even though
 they were eligible under the Act.  Speakers favoring elimination
 of  eligibility stressed that financing collectors has historically
 been the  responsibility of local governments, and officials
 encountered relatively little resistence from residents in
 paying the full cost of local residents in bearing the full
 cost of collectors.  One or two persons referred to the need
 for  a strong Farmers'  Home Administration type assistance program
 for  financially hard-pressed communities; no one referred specifi-
 cally to  utilization of the HUD program as a source of collector
 funding.
     Other speakers, however, said EPA should continue to provide
assistance for collectors because alternative sources of funding

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                              - 30 -
were inadequate  in some cases.  By retaining the flexibility
to fund collectors, these speakers tended to argue, EPA would
insure more rapid progress in the water pollution control program.
2-  For a given  level of Federal funding, what types of projects
    are of highest priority for pollution abatement?
     Very few speakers answered this question directly.  Most
of those who answered it implicitly, however, tended to discredit
the attempt to generalize.  Several people recommended that
treatment plants, interceptors, major rehabilitation and cor-
rection of combined sewer overflows specifically remain eligible.
A Tampa, Florida, official suggested priorities roughly in the
following order:   sewage treatment plants; interceptor sewers;
collector sewers; correction of combined sewer overflows; and
stormwater treatment and control.   But he cautioned, "I can see
. .  .  that may not work for every State."
     Wet-weather-related problems  were generally accorded lowest
priority, although in certain States these problems were a
major concern and spokesmen argued that facilities to correct
such problems should be high priority items.   Collector sewers
nere accorded high priority only where they were needed to replace
failing septic tanks.
3.  Is  it inequitable to provide Federal assistance for combined
    sewer overflow and stormwater projects in some communities
    before meeting secondary treatment needs  in others?

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                              - 31 -
     No one indicated such a perceived inequity among communities
within the same State.  Indeed, much of the testimony supported
a strong State role in apportioning funds among its communities
according to its perception of greatest needs, regardless of
the type of facility that might meet that need.
     However, a number of those persons who testified complained
that the most recent Congressional allocation of funds among States
was inequitable, tending to reward those States which cited high
needs for correction of combined sewer overflows or treatment and/
or control of stormwaters.  The suggested correction for this
inequity was not statutory elimination of eligibility for these
facilities, but rather allocation of funds among States only on
the basis of needs for facilities in categories I, II, and IVB
of the 1974 Needs Survey.
4.  Would a restriction of project eligibilities result in a
    greater local incentive for non-structural pollution control
    techniques (in contrast with capital intensive), as might be
    provided by 208 planning?

     Virtually no one addressed this question explicitly or
implicitly.  Several  speakers suggested "broadening" eligibilities,
but not specifically to non-structural alternatives.  One pevou.i
said municipalities undertake most pollution control activities
because "they are required to do so," coupled with the fact
that financial assistance is available for required actions.  If
this is true, elimination of eligibility itself would accomplish

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                              - 32 -
little in the way of encouraging non-structural  techniques.
Another person said stormwater should be handled "before the
fact", presumably by a management strategy, but did not link such
handling to any incentive in the current grant program.
EXTENDING THE 1977 DATE FOR THE PUBLICLY-OWNED TREATMENT WORKS
TO ACHIEVE COMPLIANCE WITH SECTION 301  OF THE ACT
The hearing dealt with the issue of whether P.L.  92-500 should
be amended to extend the date by which  publicly-owned treatment
works are to achieve compliance with requirements of Section 301
of the statute.
Summary of Testimony
     Widespread support was expressed for this amendment.   The
principal  factor identified as responsible for a need to extend
the July 1, 1977 treatment deadline was the unavailability of
Federal funds when needed for construction or because of an
inadequate projection of needs which has resulted in insufficient
funding.  One witness quoted the National Water Quality Commission
as estimating a need for $105 billion to achieve secondary
treatment requirements of the Act.
     Another factor frequently mentioned was the delay caused
by the lead time needs associated with the design and con-
struction of large facilities.  Mention was also made of the
time consuming requirements EPA has developed for the approval
of grant applications.

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                                - 33 -
     Response at the hearings emphasized three options:  (1)
a case-by-case extension of the July 1, 1977 requirements of
the law based upon funding capabilities; (2)  an across-the-
board extension of the deadline - time generally ranging from
two to five years; and (3)  the elimination of the July 1,
1977 deadline for municipalities with compliance required
for the 1983 statutory deadlines instead.
     Approximately a third of the participants favored the
extension of the July 1, 1977 secondary treatment requirements
without indicating a preference for any given extension pro-
cedure.  An insignificant number of participants were either
not affected by a deadline extension or were against an exten-
sion under any circumstances for equity or environmental reasons.
Another insignificant number of participants favored eliminating
the July 1, 1977 compliance deadline while enforcing the 1983
compliance deadline of the Act.  The remaining participants
indicated support of specific procedural options.  Public agencies
strongly favored a case-by-case extension of the  deadline  as
did industry and professional groups.  In most cases the extension
was to be based upon the availability of funding (not limited
to Federal  grants) and good faith efforts of the facility-
Environmental  groups were evenly divided between a case-by-case
extension of the deadline and an across-the-board extension of
the deadline.   However, environmental groups were generally

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                               - 34 -
against an explicit funding link for compliance and supported
instead a judgment based upon the facilities' good faith efforts
to comply, taking the construction grants delay into consideration
as well.

Related Topics
     Other topics related to or affected by this amendment were
introduced at the hearings.  The issue of reimbursement was one.
If an applicant commences construction prior to a Step III grant
award, the applicant cannot be reimbursed for such costs.   This
limitation has aggravated construction delays, so it was felt,
by some witnesses, that the law's  restriction should be amended
to allow for reimbursement of construction costs.
     Another suggestion was made to amend the secondary treat-
ment regulations and make them responsive to different types
of facilities as well  as local conditions.  It was also recommended
that water quality standards should be the determining factor
of compliance, with secondary treatment required only in those
cases where water quality standards have been violated.
     The question of what factors  should be taken into considera-
tion when granting a compliance extension to a facility was
also discussed at the hearings.  In addition to funding and
good faith efforts some individuals believed that if funding

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                               -  35 -
of current eligibilities  was  to be modified,  the treatment
deadline should reflect the change.  Also,  environmental  groups
felt that the extension should be justified by the discharger.
     An interesting point was raised by a consultant supporting
the extension of the July 1,  1977 treatment deadline for  munici-
palities.  Apparently, municipal  pollution  abatement has  not
been as effective as industrial pollution abatement, even when
taking into consideration rates of financial  expenditure.  One
reason for this is because the current funding system provides  an
incentive to build very large and complicated POTW's which over
estimate needs and are essentially inefficient when dealing
with current loads.  Another is that EPA criteria excludes some
waste treatment systems which may, in some  cases, be more effective
in improving water quality than those currently accepted  by our
regulations.  Essentially the consultant recommended that the
law's requirements be delayed to allow for the efficient  design
and construction of facilities based on a technically reasonable
analysis of the needs of the community.

Professional Groups
     The issue of industrial  compliance was also raised at the
hearings.  Industrial representatives questioned EPA policy
regarding those industrial facilities which were going to or

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                               - 36 -
are currently discharging into a municipal facility and the
municipal facility is granted a compliance extension - current
EPA policy requires industrial facilities to comply with pre-
scribed treatment requirements by July 1, 1977, including pre-
treatment requirements.  Industrial groups wanted to be granted
an extension commensurate to the municipal extension.  Witnesses
for the industrial groups felt they were subject to similar
economic and technological pressures as were the municipalities,
notwithstanding Federal support of municipal construction.
Furthermore, many industrial facilities which contemplate using
offsite joint treatment systems are dependent upon the successful
construction of municipal plants to complete their treatment
requirements.  These industrial facilities do not want to be
required to construct a treatment plant to be only utilized  for
a short time while awaiting construction of a POTW.
DELEGATING A GREATER PORTION OF THE MANAGEMENT OF THE CONSTRUCTION
GRANTS PROGRAM TO THE STATES
Summary of Testimony
     The record strongly supports greater delegation of program
responsibility to the states  but only with  the  recognition  that
States need additional  funding  and manpower and that delegation
should be done in such  a way  as not  to  slow down the program.

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                               -  37  -
Several  witnesses encouraged EPA  to  take  quick  action  on  establish-
ing the guidelines for greater delegation,  in anticipation  of  the
passage of enabling legislation.
     In response to questions  from the  panel, States indicated
that they would need a relatively short time to  assume greater
program responsibility—perhaps 3-12 months.  The record  also shows
that support was widespread  for the concept of phasing-in of State
responsibility concurrent with the availability  of State  resources.

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                                -38-





APPENDIX



THE FOLLOWING LISTS INCLUDE THE NAMES OF THE WITNESSES APPEARING AT



EACH HEARING PLUS THE STATEMENTS RECEIVED FOR THE RECORD.  ALTHOUGH



THE RECORD OFFICIALLY CLOSED ON JULY 7, 1975, ANY STATEMENTS RECEIVED




BY THE ENVIRONMENTAL PROTECTION AGENCY AT ITS WASHINGTON, D.C.



HEADQUARTERS BY JULY 15, 1975, HAVE BEEN INCLUDED.

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                            PUBLIC HEARING
                        Atlanta, Ga.,  June 9, 1975
Witnesses

Julian Bell
City Hall (204)
Chattanooga, Tenn

Linda Billingsley
The Georgia Conservance
3376 Peachtree Rd. NE, Suite
Atlanta, Ga.

T . P . Calhoun
P.O. Box 2207
Hollywood, Fla. 33022
Howard Frandsen
Fulton Co. Public Works
165 Central Av. ,  SW
Atlanta, Ga. 30303
                        Dep't.
J. Leonard Ledbetter
Georgia Department of Natural Resources
270 Washington St. SW
Atlanta, Ga. 30334

Jim Longshore
B. P. Barber £ Associates, Inc.
Box 1116
Columbia, S.C. 29202

Jim Morrison
Georgia Wildlife Federation
Woburn Drive
Tucker, Ga. 30084
Harold Pickens, Jr.
Carolinas Branch Associated General Contractors
P.O. Box 854
Philip Searcy
Florida Institute of Consulting Eng.
7500 N.W. 52nd St.
Miami, Fla. 33166

Robert Sutton, Jr.
Board of Commissioners, Cobb County
P.O. Box 649
Marietta, Ga.

Jim Tarpy
Metro Dep't of Water and Sewer Services
Stahlman Bldg. 8th Floor
Nashville, Tenn. 37201

Dale Twachtmann
Water Resources Coordinator
Tampa, Fla.

W. Edward Whitfield
Sewerage and Water Works Comm.
101 N. Main St.
Hopkinsville, Ky.  42240

John Wilburn
Louisville and Jefferson Cty.
  Metro Sewer District
400 South 6th St.
Louisville, Ky.

Wes Williams
P.O. Box 1010
Georgia Water Pollution Control Ass'n
Duluth, Ga. 30136
Anderson, S.C. 29621

David Presnell
Vollmer-Presnell-Paulo, Inc.
100 East Library St.
Louisville, Ky. 40202

Howard Rhodes
Florida State Dep't of Pollution Control
2652 Executive Center Circle
Tallahassee, Fla.
                                             Maury Winkler
                                             Dep't of Water and Sewers
                                             DeKalb County
                                             P.O.  Box 1087
                                             Decatur, Ga.

                                             Andrew Gravino
                                             President, Consulting Engineers of Ga.
                                             210 Bona Allen Bldg.
                                             133 Luckie St.
                                             Atlanta, Ga.  30303
                                 A-l

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                           PUBLIC HEARING

                       Kansas City, Mo. June 17
Witnesses
Frank Weaver
Region VII Contractors, AGC
1130 Cheyenne
Kansas City, KS 66105

Robert Elsperman
Municipal Utility Contractors
Associated General Contractors
  of America
424 Nichols Rd., Suite 200
Kansas City, Mo. 64112

Frank Eaton
Consulting Engineers of Kansas
803 Merchants
Topeka, KS  6612

Ken Karch
Missouri Dep't of Natural Resources

Bruce Gilmore
Nebraska Consulting Engineers Ass'n
P.O. Box 565
Columbus, Neb. 68601

R.W. Grant
Iowa Consulting Engineers Council
4931 Douglas, Suite C
Des Moines, Iowa 50310

Paul Haney
Black 6 Veatch Consulting Engineers
1500 Meadow Lake Pkwy
Kansas City, Mo. 64114

Horace L. Smith
City of Houston
City Hall Annex
600 Bagby
Houston, Texas

Charles B. Kaiser, Jr.
Metropolitan Sewerage District
2000 Hampton St.
St. Louis, Mo. 63139
Sue Hoppel
Natural Resources Comm.  of Nebraska
Terminal Bldg. 7th Floor
Lincoln, Neb. 68508

Paul Trout
Container Corp. of America
500 E. North 10th St.
Carol Stream, 111. 60187

F.L. Endebrock
City Hall (204)
St. Joseph, Mo. 64501

Melville Gray
Kansas Division of Environment
Topeka, KS. 66620

Richard Cunningham
League of Kansas Municipalities
Kansas City, Mo.

Esther Woodward
MO-KAN Coalition for Water Quality
League of Women Voters
2209 W. 104th St.
Leawood, KS  66206

David Snider
City Hall
Springfield, Mo. 65804

Oliver D. Williams
Wisconsin Dep't of Natural Resources
P.O. Box 450 University Av.
Madison, Wis. 53701

James Shaffer
Little Blue  Valley Sewage District
1700 Traders Bank Bldg
1125 Grand Av.
Kansas City, Mo. 64106

Dan Drain
Nebraska Dep't  of Environmental Control
P.O. Box 94653, State House Station
Lincoln, Neb. 68509
                                 A-2

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                           PUBLIC HEARING
                   SAN FRANCISCO, June 19, 1975
Witnesses
Robert Mendelsohn
Supervisor, City and County
  of San Francisco
Hotel Clarmont
Berkeley, Ca.

Wendell McCurry
Nevada Dep't of Human Resources
1209 Johnson St.
Carson City, Nev. 89701

Ralph Bolin
President, Bay Area Sewage Services
  Agency
Hotel Clarmont
Berkely, Ca.

Layton Landis
Mayor
City of San Leandro, Ca.

John &mmbie
Ventura Regional Sanitation District
181 S. Ash St.
Ventura, Ca.

Arnold Joens
City Hall
Salinas, Ca. 93901

Fred Harper
Orange County Sanitation District
P.O. Box 8127
Fountain Valley, Ca. 92708

John Harnett
General Manager, East Bay Municipal
  Utility District
2130 Adeline St.
Oakland, Ca. 94603

Michael Herz
Oceanic Society
Bldg. 240
Fort Mason
San Francisco, Ca. 94123
 George Hagevik
Environmental Resources Division,
  Ass'n of Bay Area Gov'ts
Hotel Clarmont
Berkely, Ca. 94705

Walter Garrison
California Ass'n of Sanitation Agencies
1955 Workman Mill Road
Whittier, Ca.

Peter Gadd
2302 Sunset Drive
Visalia, Ca. 93277

Robert Fleming
Texas Water Quality Board
11510 Whitewing
Austin, Texas 78753

Donald Evenson
Consulting Engineers Ass'n of Calif.
710 South Broadway
Walnut Creek, Ca. 94596

Lila Euler
Livermore/Amadore Valley Water
  Management Agency
8787 Bandon Dr.
Dublin, Ca. 94566

Henry Eich
Chairman, Conference of Local
  Environmental Health Administrators

'Bill Dendy
California State Water Resources
  Control Board
1416 9th St.
Resources Bldg.
Sacramento, Ca.

Pete Zars
Siecra Club
2410 Beverly Bldg.
Los Angeles, Ca.
                               A-3

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Mayor Stan Daily
Camarillo Sanitary District
Camarillo, Ca.

Bob Burt
California Manufacturers Ass'n
P.O. box 1138
Sacramento, Ca. 95805

Granvilie Bowman
County of San Diego
5555 Overland Av.
San Diego, Ca. 92123

Jack Beaver, 3?res.  Water Quality Brd.
Redland, Ca.

Herman Alcalde
City and County of San  Francisco
770 Golden Gate Av.
San Francisco, Ca. 94102

Jerry Wager
Environmental Protection Agency
P.O. Box 2999
Agana, Guam 96910

Edward Bohn
The Planning and Conservation League
200 N. Spring St.
Los Angeles, Ca.

Edward Simmons
California Water Resources Agency

Jack Port
Contra Costa County
64-  Administration Bldg.
Martinez, Ca. 94553

Connie Parrish
Friends of the Earth
529 Commercial St.
San Francisco, Ca. 94111

Alinda Newby
Municipalities of Metropolitan  Seattle
600 First Av.
Seattle, Wash.   98104
Donald Miller
Councilman, City of Livermore
City Hall
Livermore, Ca.

Gordon Magnuson
Engineering Science, Inc.
600 Bancroft Way
Berkely, Ca. 94710

E.L. MacDonald
North Bay Water Advisory Council
City Hall
Ridgemond, Ca.

Lawrence Taber/Herbert Stone
Canners League of California
1007 L St.
Sacramento, Ca.

Donald Tillman
City of Los Angeles
Los Angeles, CA.
                                    A-4

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                           PUBLIC HEARING
                   WASHINGTON, B.C.  June 25, 1975
Witnesses
Mayor Frederick Knox
411 Ridgedale Avenue
East Hanover, New Jersey 07936

George Tomko
4-5 Canfield Road
East Hanover, New Jersey 07936

Robert Davis
Virginia State Water Quality Board
P.O. Box 11143
2111 N. Hamilton St.
Richmond, Va. 23230

Richard Dougherty
Metropolitan Waste Control Comm.
350 Metro Square Bldg.
7th and Roberts Sts.
St. Paul, Minn. 55101

Alfred Peloquin
New England Interstate Water
  Pollution Control Commission
607 Boylston St.
Boston, Mass 02116

Seymour Lubetkin
Passaic Valley Sewerage District
600 Wilson Av.
Newark, N.J. 07105

Bill Marks
Dep't of Engineering
Room 408 City Hall
Newark, N.J.

Martin Lang
New York City Environmental
  Protection Administration
2364 Municipal Bldg.
New York, N.Y. 10007

Eugene Seebald
Dept; of Environmental Conservations
50 Wolf Road
Albany, N.Y. 12233
James Huffcut
New York State Water Pollution Control
  Ass 'n
1405 Canal Road
Lockport, N.Y. 14094

Wesley Gilbertson
Deputy Secretary for Environmental
  Protection and Regulation, Dep't of
  Environmental Resources
P.O. Box 2063
Harrisburg, Pa. 17120

William Markus
McCandless Township Sanitary Authority
Allegheney County
Pennsylvania

Robert Martens
Deputy Commissioner, Dep't of
  Environmental Quality
134 West Eagle Street
Buffalo, N.Y.

Larry Snowhite
New Jersey Governor's Office
419 New Jersey Avenue, SE
Washington, D.C.

Sam Warrington
Water Pollution Control Federation
3900 Wisconsin Av NW
Washington, D.C.

J.G. Speth
Natural Resources Defense Council
917  15th Street NW
Washington, D.C. 20036

Lynn Goldthwaite
Tourne Valley Coalition
One Sunset Road
Mountain Lakes, N.J. 07046
                                  A-5

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Peter Gadd
Kings River Water Association
2302 Sunset Drive
Visalia, Cal. 93277

Peter Inzero/David Shevock
815  15th St. NW
National Utility Contractor's Ass'n.
Washington,  B.C.

Billy Sumner
American Consulting Engineers Council
1155  15th St. NW
Washington,  B.C.

Warren Gregory
National Solid Wastes Management Ass'n
1730 Rhode Island Avenue, NW
Suite 800
Washington,  B.C.

Tom Walker
Browing-Ferris Industries
Suite 800
1730 Rhode Island Av. NW
Washington,  B.C.

H, Neal Troy/L.S.  Watson
National Ass'n of Manufacturers
1776 F St. NW
Washington,  B.C.  20006

Bart Lynam
Lee White.
Association  of Metro Sewer Agencies
1156 15th St. NW
Washington,  B.C. 20005

Jay Lehr
National Water Well  Ass'n
500 West Wilson Bridge  Rd.
Worthington,  Ohio 43085

Richard  Rosen
Energy Resources Co.,  Inc.
185 Alewise Book Pky
Cambridge, Mass 02138
 Morris  Wiley
 American Petroleum Institute
 P.O.  Box 509
 Beacon,  N.Y. 12508

 J ame s Rom an o
 National Society of Profession
  Engineers
 2029 K  St.  NW
 Washington, B.C.

Clem Rastatter
Conservation  Foundation
1717 Massachusetts  Av. NW
Washington,  B.C.  20036

Charles Samowitz
Commissioner, New York City  Dep't
  of Water  Resources
                                A-6

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            LIST OF STATEMENTS RECEIVED FOR THE RECORD *
Ernst Mueller
Commissioner
Department of Environmental Conservation
Pouch 0
Juneau, Alaska  99811

James R. Anderson
James R. Anderson 6 Co.
6842 Van Nuys Blvd.
Van Nuys, CA. 91405

Robert A. Allsion
4299 MacArther Blvd.
Suite 104
Newport Beach, CA.  92660

E.M. Allgeier
Allgeier, Martin & Associates
2820 Range Line
P.O. Box 2277
Joplin, Mo.  64801

David A. Kirk
Butler Area  Sewer Authority
125 Pittsburgh Road
Butler, Pa.  16001

A.P. Black
City Administrator
P.O. Box 362
Barnwell, S.C. 29812

F.A. Eidsness
Black, Crow  6 Eidsness, Inc.
1700 S.W. 12th Av., P.O. Box 1300
Boca Raton,  Fla. 33432

Joseph Bouquard
Bouquard Engineering Co., Inc.
Third Floor, Park Tower
117 East Seventh St.
Chattanooga, Tenn.  37402

Paul Clark
Department of Public Works, Streets and
     Airports
Chattanooga, Tenn.  37402
Steve Cloues
Associate Director
Central Midlands Regional Planning
     Commission
Dutch Plaza, Suite 155
Dutch Square Blvd.
Columbia, S.C. 29210

Mayor-Connie Smith
715 Washington St.
Chillicothe, Mo. 64601

Donald Canney
Office of the Mayor
3rd Floor City Hall
Cedar Rapids, Iowa 52401

Michael D. Curry
3 Shady Lane
Herrin, 111. 62948

R. Marvin Townsend
City Manager
302 South Shoreline
P.O.Box 9277
Corpus Christi, Texas 78408

William D. Engler, Jr.
Office of City Attorney
102 N. Madison St.
Chilton, Wis.

John D. Parkhurst
County Sanitation Districts of
     Los Angeles County
1955 Workman Mill Rd.
P.O. Box 4998
Whittier, CA. 90607

Lowell Weeks
General Manager
Coachella Valley County Water District
P.O. Box 1058
Coachella, CA. 92236

Henry J. Graeser
Dallas Water Utilities
500 S. Ervay
Dallas, Texas 75277
        addition to those witnesses appearing in person

                                    A-7

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Ms. Penelope J. Evans
1262 Bordeaux Dr.
Lexington, Ky. 40504

Mayor Wesley Cox
P.O. Drawer 700
El Reno, Okla.  73036

Stan Weill
President
Georgia Water and Pollution
     Control Ass'n.

Julian Bell
Tennessee Municipal League

A.B. Anderson
GM Assembly Division
CMC
Van Nuys, CA. 91409

Kazu Hayashida
Chief Engineer
Department of Public Works
City and County of Honolulu
650 South King St.
Honolulu, Hawaii 96813

Ervin Brenner
Board of Supervisors
County of Humboldt
Eureka, CA. 95501

Lee C. Kruase
Howe11, Howe11, 6 Krause
Honesdale, Pa. 18431

Ralph Pickard
Stream Pollution Control Board
1320 West Michigan St.
Indianoplis, Indiana 46206

M.L. Forrester
Department of Public Works
220 East Bay St.
Jacksonville, Fla. 32202

Stuart Pyle
Kern County Water Agency
1415 18th St. Rm. 418
Bakersfield, CA.  93301
Finely Laverty
1400 Cresthaven Drive
Pasadena, CA. 91105

H.W. Stokes
General Manager
Las Virgenes Water District
4232 Las Virgenes Road
Calabasas, CA. 91302

Mrs. Julian Hall
League of Women Voters of Missouri
2133 Woodson Rd.
St. Louis, Mo. 63114

Rex Layton
City Clerk
Rm. 395 City Hall
Los Angeles, CA. 90012

Mayor Robert Smith
Lake View, S.C.

William Meadows
1025 Turkeyfoot Rd.
Lexington, Ky. 40504

Mayor Marion Reed
P.O.Box 10570
Midwest City, Okla. 73110

Warren Ringer
Massachusetts Construction Industry
     Council
One Gateway Center, Rm.  416
Newton Corner, Mass.  02158

Governor Brendan Byrne
New Jersey

David Bardin
Department of Environmental Protection
P.O. Box 1390
Trenton, N.J. 08625

Resolution
U.S. Conference  of Mayors

Bob Fuller
Milwaukee River Restoration Council, Inc,
461 Hillcrest Rd.
Grafton, Wis. 53024

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John B. Daly
Assemblyman
138th District
New York

John Kemper
Office of the Director of Utilities
City Hall
Norfolk, Va. 23501

Louis S. Clapper
National Wildlife Federation
1412 16th St. NW
Washington, D.C. 20036
                            Arthur Berger
                            7 Richmond St.
                           Painesville, Ohio 44-077

                           Sanford Paris
                           1880 Century Park East
                           Los Angeles, CA.  90067

                           Jon Olson
                           District Manager
                           Sanitary District of Rockford
                           3333 Kishwaukee  St.
                           P.O. Box 918
                           Rockford, 111. 61105
George Bentley                              William Korbitz
New Bedford Industrial Wastewater Committee Rocky Mountain Water Pollution Control
c/o Continental Screw Co.                        Ass'n.
New Bedford, Mass.                          3100 East 60th Av.
                                            Commerce City, Colo. 80022
K.W. Riebe
City Manager                                S. Friedman
City Hall                                   Spaulding Fibre Co., Inc.
Newberry, S.C. 29108                        Tonawanda, N.Y. 14150
E.0. Pendarvis
Mayor
P.O. Box 641
Orangeburg, S.C.
29115
John Karanik
Department of Drainage and Sanitation
125 Elwood Davis Rd.
North Syracuse, N.Y. 13212

Congressman Richard Ottinger
U.S. House of Representatives
24th District, New York

Mayor Patience Latting
200 North Walker
Municipal Bldg.
Oklahoma City, Okla.  73102

Charles Newton
Oklahmoa State Department of Health
Northeast 10th St. £ Stonewall
Oklahoma City, Okla.  73105

L.W. Maxson
Olin Brass
East Alton, 111. 62024
Charles Schimpeler
1429 S. 3rd St.
Louisville, Ky. 40208

Edwin Mitchell
Spartanburg Sanitary Sewer District
200 Commerce St.
Spartanburg, S.C. 29301

Dick Brown
Board of Supervisors
County of San Diego
1600 Pacific Highway
San Diego, CA. 92101

R.W. King
City of San Diego
202 C St.
San Diego, Ca. 92101

Donald Tudor
Santee-Wateree Regional Planning
     Council
4th Fl. City-County Bldg.
P.O. Box 1837
Sumter, S.C. 29150

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John Jenkins
South Carolina Dep't of Health
     and Environmental Control
2600 Bull St.
Columbia, S.C. 29201

R.A. Boege
Union Sanitary District
4-057 Baine Av.
Fremont, Ca.  94536

Lincoln Ward
5400 Van Nuys Blvd.
Van Nuys, Ca. 91401

Richard Senitte
West Sacramento Sanitary District
1951 Sotuh River Rd.
West SacHamento, Ca.  95691

M.L. Wickersheim
City Hall
715 Mulberry St.
Waterloo, Iowa  50705

Paul Sisson
Washington Surban Sanitary Commission
4017 Hamilton St.
Hyattsville,  Md.  20781

Ralph Purdy
Michigan Department  of Natural Resources
Stevens T. Mason Bldg.
Lansing, Mich. 48926

John Spencer
Department of Ecology
State of Washington
Olympia, Washington  98504

Mary O'Dell
Chairman, Metropolitan Denver Sewage
  Disposal District No. 1
3100 East 60th St.
Commerce  City, Colo.  80022

Paul Gleason
Business  Administrator
Borough  of Lincoln Park
Municipal Bldg.
34  Chapel Hill Rd.
Lincoln  Park,  N.J. 07035
Governor Michael S. Dukakis
Evelyn F. Murphy, Executive Office
  of Environmental Affairs
Commonwealth of Massachusetts

Harry Morrison
Vice President
Western Oil and Gas Ass'n
609 South Grand Av.
Los Angeles, Ca. 90017

Jane 0. Baron
Water Resources Division
Northern California Regional
  Conservation Commission
Mills Tower
San Francisco, Ca. 94104

E.J. Weathersbee
Department of Environmental Quality
1234 SW Morrison St.
Portland, Ore. 97205

Brain Landergan
National Association of Home Builders
15th and M Streets NW
Washington, D.C. 20005

David Goldberg
New Jersey Alliance for Action
219 East Hanover St.
Trenton, N.J.

Bob Bruton
President
Consulting Engineers Council of Okla.
P.O. Box 51186
Tulsa, Okla. 74151

David Hansen
Director of Public Works
7377 Church St.
P.O. Box 66
Gilroy, Ca. 95020

Carl Carlson
Howard G. Moore Co., Inc.
2122 South Stewart
Springfield, Mass. 65804

Donald Ringler
Director
Oakland County Dep't of Public Works
Pontiac, Mich, 48054

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Thomas Kirkwood
Missouri Society of Professional Engineers
210 Monroe St.
Jefferson City, Mo. 65101

Duane Kiihne
Peninsula Manufacturing Ass'n
3921 East Bayshore Rd.
Palo Alto, Ca. 94303

Charles Goodwin, Jr.
Chairman, Humboldt Bay Wastewater Authority
P.O. Box 14-49
Eureka, CA. 95501

Metropolitan Council
Leagues of Women Voters—St. Louis and
  St. Louis County
5600 Oakland Av., Rm. G330
St. Louis, Mo. 63110

Donald Hillbricks
President, Nebraska Water Pollution
  Control Ass'n
P.O. Box 565
Columbus, Meb. 68601

William Konrad
Envirex
Water Quality Control Division
P.O. Box 1067
Waukesha, Wis. 53186

Dean Hunter
Lexington Fayette Urban County Gov't
136 Walnut St.
Kexington, Ky. 40507

Stephen Leeds
69 Mountain Heights Av.
Lincoln Park, N.J. 07035

Frank Farinella, Jr.
President, New Jersey Builders Ass'n
P.O. Box M
Ramada Inn
East Brunswick, N.J. 08816

Ronald Beckman
Public Works Administrator
1200 Elm Av.
Carlsbad, CA. 92008
   William Kane
   Associated General Contractors of
     Massachusetts Inc.
   220 Boylston St.
   Chestnut Hill, Mass. 02167

   Adrian Fondse
   Chairman, Board of Supervisors
   222 East Weber Av., Rm 701
   Stockton, CA 95202

   Donald Evenson
   Consulting Engineers Association of
     California
   1308 Bayshore Hwy
   Burlingame, CA. 94010

   C. D. Hudson
Illinois Environmental Protection Agency
   2200 Churchill Rd.
   Springfield, 111. 62706

   Jack Cooper
   National Canners Association
   1133 20th St. NW
   Washington, D.C.

   Art Vondrick
   Water and Sewers Director
   215 E. McDowell Rd.
   Phoenix, Arizona 85004

   R.N. Line
   City Manager
   1000 Throckmorton St.
   Ft. Worth, Texas 76102

   Don Busch
   City Manager
   830 Booneville Av.
   Springfield, Mo. 65802

   Carmen Guarino
   Commissioner, Water Department
   1180 Municipal Services Bldg.
   Philadelphia, Pa. 19107

   V.H. Sussman
   Director, Stationary Source Environmental
     Control, Ford Motor Co.
   One Parkland Bldg.
   Dearborn, Mich. 48126
                                     A-U

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Laurence Brennan
6009 West 90th St.
Overland Park, Kansas 66207

Mayor John Hutchinson
P.O. Box 2749
Charleston,  West Virginia 25330

Hal Wood
Sanitation Department
County of Sonoma
Rm 117A Administration Bldg.
2555 Mendocino Av.
Santa Rosa,  CA. 95401

E. Cedroni
Acting Director
Detroit Metro Water Dep't
Water Board Bldg.
Detroit, Mich. 48226

Howard Hoffman
No Address

Glenn Hackett
Twon of Wheatfieid New York
P.O. Box 726 Falls Station
Niagara Falls, N.Y. 14303

Peter Gove
Executive Director
Minnesota Pollution Control Agency
1935 West County Rd. B2
Roseville, Minn. 55113

William Adams
Commissioner
Maine Separtment of Environmental
  Protection
State  House
Augusta, Maine 04330

Edward Treat
Secretary-Myerstown Borough
515 South College  Street
Myerstown, Pa. 17067

F.C. Gibbs
Associated Constructors, Inc.
Box 9871
Jackson, Miss. 39206
Louis Allen, Jr.
Assistant Executive Director
Association of California Water Agencies

Neil Cline
Secretary-Manager
Orange County Water District
10500 Ellis Av.
P.O. Box 8300
Fountain Valley, CA. 92708

Frank Meyer
Chairman, Vista Sanitation District
P.O. Box 188
200 W. Broadway
Vista, CA. 92083

J.A. Chittenden
National Independent Meat Packers Ass'n
734 15th St. NW
Washington, D.C. 20005

William Pitstick
Executive Director
North Central Texas Council of Gov'ts
P.O. Drawer COG
Arlington, Texas 76011

Lewis R. Martin
Director, Division of Environmental Mgm't
North Carolina Department of Natural and
  Economic Resources
Box 27687
Raleigh, N.C. 27611

David Howells
Water Resources Research Institute
University of North Carolina
124 Riddick Bldg
Raleigh, N.C. 27607

George Miller
U.S. Congressman
Seventh District,  California

Lewis Ritter
President, Water Pollution Control
  Ass'n of Pennsylvania
P.O. Box 587
State College, Pa.  16801
                                       A-lJL,

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Herman Maskell
Utility Contractors Ass'n of
  Connectucut, Inc.
416 Highland Av.
Cheshire, Conn. 06410

Walter Fritz
Vice-President
Michaels- Stiggins, Inc.
3025 South St.
Orlando, Fla. 32803

John Hornbach
City Engineer
Grand Rapids, Mich. 49502

Stanley Dolecki
Harland Bartholomew and Associates
165 N. Meramec Av.
St. Louis, Mo. 63105

Ronald Gori
Chairman, Board of Commissioners
Township of Bethletoem
2740 Fifth St.
Bethlehem, Pa. 18017

Karl Rothermund
Executive Vice-President
Ohio Contractors Ass'n
                                   A-lJ

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