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 ------- 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. ------- - 2 - 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. ------- - 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 ------- - 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 ------- - 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. ------- - 6 - 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. ------- - 7 - 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 ------- - 8 - 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 ------- - 9 - 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 ------- - 10 - 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: ------- - 11 - • 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 ------- - 12 - 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: ------- - 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 ------- - 14 - 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. ------- - 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. ------- - 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. ------- - 17 - 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. ------- - 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 ------- - 19 - 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. ------- - 20 - 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 ------- - 21 - 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. ------- - 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. ------- - 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 ------- - 24 - 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, ------- - 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. ------- - 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." ------- - 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 ------- - 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. ------- - 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 ------- - 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? ------- - 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 ------- - 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. ------- - 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 ------- - 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 ------- - 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 ------- - 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. ------- - 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. ------- -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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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, ------- 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 ------- |