NATIONAL PROFILE
OF SECTION 208
AREAWIDE MANAGEMENT
PLANNING AGENCIES
JULY 1975
ENVIRONMENTAL PROTECTION AGENCY
Washington,D.C. 20460
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NATIONAL PROFILE
OF SECTION 208
AREAWIDE MANAGEMENT
PLANNING AGENCIES
JULY 1975
PROJECT DIRECTOR - MICHAEL L. FRANKEL
PROJECT STAFF - CONSTANCE L. CASTLE
CHERYL J. DINNEEN
PATRICIA C. HIGGINS
CAROLYN M. HOCK
JEAN A. LYNCH
DAVID H. MECKLER
JANE M. NOWAK
ADAM POE
STEPHEN G. PRESSMAN
PREPARED UNDER CONTRACT NO. 68-01-3195
ENVIRONMENTAL PROTECTION AGENCY
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PREFACE
This report summarizes a national profile of local planning
agencies designated under Section 208 of the Federal Water Pollu-
tion Control Act Amendments of 1972. The project was conducted by
Centaur Management Consultants, Inc. during July and August of 1975
under an EPA contract (No. 68-01-3195) to the Areawide Management
Branch.
The nine-member project staff was recruited from the urban
and regional planning schools of George Washington University,
Georgia Institute of Technology, Harvard University, Johns Hopkins
University, Stanford University and the University of North Carolina
at Chapel Hill.
The national profile prepared by this staff represents a
literature review of grant applications and designation packages
from all 149 designated planning agencies and personal interviews
with 136 local planning agencies. However, the project was not a
research effort. The facts and figures gathered through the inter-
views were not verified. Information in the designation packages
and grant applications was not always complete, and often supple-
mented with an "estimate" by the interviewee. Consequently, the
data is most useful as a general profile of 208 agencies and their
activities. It should be viewed as the local 208 staffs' best ap-
proximation of information at this time.
The project staff appreciates the guidance and support pro-
vided by the Water Planning Division of EPA and the time and advice
given by the EPA Regional 208 coordinators. The staff also thanks
the local 208 agency staffs who gave their time for the interviews.
Finally, the staff extends its gratitude to Ken Regelson for his
tireless efforts in seeing to the technical and administrative day-
to-day needs of the project staff.
Michael L. Frankel
Project Director
Second Printing
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TABLE OF CONTENTS
Page
INTRODUCTION vi i
Project Methodology vi i
Major Issues ix
CHAPTER I - AGENCY PROFILE
Findings 1
Physical Characteristics of 208 Areas 2
Type of Agencies Designated 3
Experience of Agencies 4
Staffing of Agencies 5
CHAPTER II - ENVIRONMENTAL ASPECTS
Findings 7
Current Water Qua!1ty Problems 7
Lack of Water Qua!i ty Data 9
The Impact of 208 on Achieving the 1983 Goals 11
CHAPTER III - LAND USE ASPECTS
Findings 13
Land Use Consideration 1n the 208 Planning Process 13
Relationship of Nonpoint Source Pollution and Land Use... 16
CHAPTER IV - MANAGEMENT/INSTITUTIONAL ASPECTS
Findings 17
Designated Agencies' Capabilities in Management
Planning ...» 18
Major Issues 19
CHAPTER V - PUBLIC PARTICIPATION
Findings 25
Who is the Public? 25
A Shift in Approach 26
Experience with Public Participation Programs 26
Budget and Staff 27
Commi ttees 28
Public Education 29
Public Input and Feedback 31
Problem Areas 32
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TABLE OF CONTENTS (CONT'D)
Page
CHAPTER VI - BUDGET
Findings 35
Grant Awards 35
Work Plan Budget 37
Contracts 41
Contract Activities 42
Type of Contracts 43
CHAPTER VII - TIMING AND FINANCIAL PROBLEMS
Findings 45
Timing and the Two-Year Planning Period 46
Financially Self-Sustaining Planning Process 49
CHAPTER VIII - DESIGNATION AND GRANT APPLICATION
Findings 51
Why Enter 208 Planning? 51
The Designation Process 51
Preparation of Designation Package and Grant Application. 52
Problems in the Designation and Grant Application
Process 52
Resolutions of Intent 54
Cost of Grant Application 55
Assistance and Coordination 56
CHAPTER IX - COORDINATION
Findings 57
Coordination Between 208 and 303(e) Basin Planning 57
Coordination Between 208 and the NPDES 58
Coordination Between 208 and 201 Municipal Facilities
Planning 58
Coordination with Other Environmental Programs and
Other Areawide Planning Programs 59
Coordination Between 208 and State 59
Means of Coordination 59
11
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TABLE OF CONTENTS (CONT'D)
Page
CHAPTER X - EVALUATION AND GUIDANCE
Conclusions and Findings 63
208 Draft Guidelines 63
Designation and Work Plan Handbooks 63
Workshops 64
OBERS Projections 65
Technical Guidance 65
Management/Legal/Institutional Seminars 67
Other Suggestions 69
APPENDIX A - STATISTICAL DATA
APPENDIX B - PLANNING AGENCY DIRECTORY
APPENDIX C - REGIONAL 208 MAPS
m
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LIST OF TABLES
Table Title Page
1 Partial and Total SMSA's within 208 Boundaries 2
2 Type of Agency Designated 3
3 208 Agencies' Experience in Planning 4
4 Other Planning Functions Performed by 208 Agencies 5
5 Factors Responsible for Designation 8
6 Problem Parameters in 208 Areas 10
7 Achievement of the 1983 Goals 12
8 Reasons for not Meeti ng the 1983 Goal s 12
9 Percent of the Budget Allocated for the Land Use
El ement Under 208 15
10 Substantial Nonpoint Sources 16
11 Who Will Do Legal/Management/Institutional Work
Element of 208 Plan? 18
12 When Will Management Alternatives Analysis Begin? 19
13 Experience in Public Participation Programs 26
14 Percent of Budget Allocated for Public Participation 27
15 Responsibility for Public Participation Programs 28
16 Requests for Briefing on 208 Program 29
17 Discrepancies Between Requested and Awarded Grant
Amounts ^ 36
18 Summary Table: Sample Budget Allocations 40
(Regional Averages)
19 Anticipated Problems During the 2-Year Planning Period ... 47
20 Response on Ability to Attain Legal Powers for Manage-
ment Agency Prior to 2-Year Deadline 48
IV
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LIST OF TABLES (CON'TO)
Table Title Page
21 Total Time of Designation Process 52
22 Major Problems in the Designation and Grant
Application Processes 53
23 Cost of Grant Applications 56
24 Number of Agencies Which Mentioned the Methods of
Coordination Used in Relation to the Organiza-
tions Listed 61
25 Workshop Attendance by Agency 64
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INTRODUCTION
At the end of FY 1975, a total of 149 local planning agencies
had been designated and awarded planning grants under Section 208 of
the Federal Water Pollution Control Act Amendments of 1972. A nation-
al profile of these local planning agencies was conducted during the
first two months of FY 1976 in order to characterize the 208 agencies
and their preliminary activities towards areawide management planning.
The purpose of this report is to summarize this national profile. It
must be emphasized that this report is based on available information
at this point in time in the first month of the planning process. The
data is a reflection of the local perspective of 208 planning, and
does not address the state or federal viewpoint.
Project Methodology
The project staff met in Washington, D.C., the first two weeks
of June to review the 208 program and develop a set of questions and
issues for the interviews. During this time they met with staff from
EPA Headquarters, private consultants, and pre-tested the profile on a
local 208 agency. Over the next 8 weeks staff members were then as-
signed to a Regional office, where they met with the EPA Regional
Coordinators to review tiie office 208 files. They subsequently inter-
viewed the designated agencies within the Region. When the interviews
were completed, the staff returned to Washington to analyze the data
and prepare this report.
The review of designation packages, grant applications and work
plans was conducted along the lines of a structured profile. This in-
formation was then reviewed with the local 208 planning agency staff to
corroborate the information and to supply additional information not
covered in the available documentation. The structured profile con-
sisted of approximately 175 items of information under the following
headings:
Area Description
Designated Agency Description
Coordination Activities
Designation Process
Grant Application Process
Work Plan
Public Participation
Land Use
Legal/Institutional/Management Issues
Financially Self-Sustained Planning
Evaluation of Technical Aids
VI 1
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136 of a possible 149 interviews were completed. Of the 13
agencies not interviewed, 9 were in Region IX. In some cases, how-
ever, information was unavailable, or agencies were unable to answer
the questions as asked. Thus, the total responses to each question
does not always add up to 136. Whenever possible available docu-
ments were studied to try to answer some of the profile questions
when no interview was done, thus, in some cases the number will be
14y the total number of 208 agencies.
Whenever a dash (-) is used in a table, it means that the
question was asked and the response was negative, or that it was not
a factor. Whenever a blank appears, it means that there was no re-
sponse. This is due to any of three factors, the net result being
no information. The factors are:
1) The interviewee did not have the background to
answer the question.
2) The question was not asked due to lack of time.
3) The information was not available at that time.
The number of agencies for which there was no information for that
particular question is totaled by region in the "no answer" column.
For some questions, agencies were asked to check several
items when more than one answer applied. In these cases, total re-
sponses will add to more than 136.
Interviews generally took 3-4 hours. They were made with
one person ("lead interview"), although other staff were often in-
volved in answering some of the questions. Of the 136 agencies
interviewed, 81 of the "lead interviews" were with the 208 project
directors. When a 208 project director was either not yet hired or
was not available, lead interviews were conducted with directors of
the parent agency (27), with staff who wrote the original applica-
tions (16), with acting directors (4), and with other program direc-
tors of the parent agencies (5). Many interviews involved more than
one person and over 86 other people were involved in part, including
water quality engineers, planners, public participation specialists,
citizens groups, and representatives of Indian organizations.
Section 208 of the Federal Water Pollution Control Act Amendments of
T977
Section 208 areawide planning and management is a comprehen-
sive program established to bring about environmental quality on the
nation's waterways by 1983. The program is designed for areas with
substantial water quality control problems due to urban-industrial
concentrations or other factors.
VI 1 1
-------
This program ties together the various federal water pollution
abatement requirements including municipal, industrial, residual waste,
runoff, and groundwater pollution abatement. The responsibility for
planning and implementing these provisions rests with regional and
local agencies.
Major Issues
Several key issues were consistently expressed in the review
of local planning agency documents and in the interviews with local
208 project staffs. These issues, discussed in more detail in the
following chapters, are summarized below.
Two-Year Planning Period Evan though the agencies
understood 24 months was the allotted planning period,
they consistently asked for relief. Those interviewed
claimed that two years was too short to accomplish
all the analysis, planning, evaluation and approval
required for the 208 plan. Staff recruitment, adminis-
trative organization, and the need for detailed work
plans cut into the beginning of the 24-month period.
Requirements for public participation and local review
and approval were consistently reported to be very
time-consuming and cut significantly into the planning
period.
Management/Institutional -- There is a strong commit-
ment on the part of the designated agencies to develop
and implement a management system, but at this time in
the planning process, it was unclear what that system
will look like, how it will be created and what powers
it should exercise. Most agencies, however, did fore-
see a single planning agency and several management
agencies as the probable framework. The majority will
opt for modifications of existing arrangements rather
than major institutional changes. The general insist-
ence on "local autonomy" by jurisdictions within the
208 areas will be a serious constraint on innovative
regional management alternatives.
Financially Self-Sustaining Planning Process -- Most
208 agencies expressed serious doubts about their
ability to continue planning on a financially self-
sustaining basis after the 24-month period expires.
Local governments will not be able to raise enough
money on their own. Furthermore, they don't consider
themselves bound by their resolutions-of-intent to pay
for 208 planning after the termination of the grant,
and presently are not showing financial commitment to
IX
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the continuing planning process. Federal and state
financial assistance is therefore essential if 208
is to be the ongoing program it was intended to be.
State Water Quality Information -- A major deficiency
exists in the State 303(e) Basin Plans. Generally,
303's, in particular waste load allocations were
either incomplete at this time, or inadequate because
they were based on insufficient data (e.g. based only
on dissolved oxygen content or incorrect sampling
methods.) This places an extreme burden on 208 agen-
cies which necessarily rely on the availability and
quality of such data in the early stages of the plan-
ning process. It additionally places economic hard-
ship and time delays on those agencies which must
undertake the monitoring, modeling, and analysis ef-
forts themselves.
Budgets -- Budgets were generally inconsistent in
format and incomplete in preparation at the time of
interview. This was due to a lack of budgetary
guidance (or its late delivery), and a lack of staff
and expertise in price and cost analysis. If EPA
should choose to assemble this data nationally, it
will be very difficult to either analyze the direc-
tion (foresight), or evaluate the progress (hind-
sight) of the 208 program.
Public Participation -- 208 Agency expenditures for
public participation generally concentrate on a one-
way flow of information to the public. This is
necessary as a first step, but is certainly not
sufficient. Mechanisms for feedback resulting from
such efforts are necessary. If the general public
is not accounted for except in the committee struc-
ture, it may create potential problems with plan
acceptance. Furthermore, a major benefit in terms of
public awareness will be lost to 208.
Technical Guidance There is a serious delivery
problem with EPA guidance between the Federal levels
and local 208 planning agencies. A significant num-
ber of agencies never received the Handbooks, while
over half of the agencies received them too late to
be useful. The needs for technical guidance are
similar throughout the country. The greatest demand
was consistently for nonpoint source analysis, moni-
toring (point and nonpoint), urban storm water, and
combined sewer analysis. The most requested manage-
ment/legal/institutional seminar is for state speci-
fic legislation to enable alternative management
structure.
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AGENCY PROFILE
Findings
An examination of the characteristics of designated 208 plan-
ning shows several interesting and potentially significant aspects.
Although each agency must respond to unique environmental conditions
and a unique political institutional setting, there are many similar-
ities which make comparisons beneficial. Furthermore, it is useful
to identify unusual circumstances and approaches that may suggest
improvements for the program as a whole. Some of the most significant
findings are:
Most 208 agencies are under the auspices of a
parent agency' that has been in existence for
several years and that conducts a variety of
planning functions. A small number of agencies
have been newly created and should be given
high priority for additional guidance in their
208 effort. The starting point of these agen-
cies is considerably behind that of established
agencies. Those agencies with no water quality
experiences should also be a high priority for
special guidance and assistance.
When in full operation, over 800 persons will
be working full time on 208 staffs and another
800 "borrowed" from other agencies on a tempor-
ary basis. In addition, somewhere between 400
and 1,000 man-years of consultant time will be
spent on 208 planning through contracts.
Physical Characteristics of 208 Areas
The 208 area boundaries cover 390,562 square miles, or over
one-tenth of the country.2 In population, the program serves
95,403,219 people, or just under one-half of the country.3 In re-
sponse to the initial legislative intent to address urban/industrial
water quality problems, 90 SMSA's are totally included in 208
1
Parent agency refers to the larger organization of which 208 planning
is only one function. It is generally the RPA, COG or EDO, and the
official recipient of the grant.
2
Total area including Alaska, Hawaii and territories is 3,628,066.
3
Total population of the U.S. in 1970 was 203,235,298.
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boundaries and 49 more SMSA's are partially Included.4 The follow-
ing table Indicates the number of SMSA's that are either partially
or totally Included 1n 208 areas. (Table 1)
208 1s also Institutionally complex because 1t Involves so
many levels of governmental units, making coordination a key Issue.
Only eight states (Hawaii, Alaska, Vermont, Connecticut, Minnesota,
Louisiana, Nebraska and New Mexico) have no 208's. Three states are
Included only through Interstate 208 areas, and have no ongoing 1ntra-
state 208 planning. 385 counties are fully Included within 208
boundaries and 111 more are partially Included.
Table 1
PARTIAL AND TOTAL SMSA'S WITHIN 208 BOUNDARIES
No. of
SMSA'S
0
1
2
3
> 3
No answer
Total 17 11 12 28 25 9 5 22 10 10 149
REGION
1
5
10
2
2
2
7
2
3
3
8
1
4
3
21
2
5 6
1
12 7
9 -
3 1
789
2 13 2
3 8 4
3
_ _
10
3
7
-
_
4
On April 5, 1974 there were 269 SMSA's in the country. The number
of partially included SMSA's is overstated due to the double count-
ing resulting from one SMSA being in more than one 208 area.
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Type Agencies Designated
The following table indicates the type of agencies designated
to do 208 planning.
Table 2
TYPE OF AGENCY DESIGNATED
~~Water Quality
Agencies or
COG, RPA County Sanitation Inter!oca! Not
or EDO Government Districts Agreement Other Available Total
113 9 5 778 149
In the majority of cases (113 or 84%) this meant a regional
government, usually called a Regional Planning Agency (RPA) or a
Council of Government (COG) or an Economic Development District.
There is not a meaningful distinction between these three; the differ-
ences in name were generally explained by choice of wording 1n state-
enabling legislation.
In some cases the traditional regional planning agency was
not the designated 208 agency. The 16% non-COG type agencies repre-
sent a range of governmental units with varying powers. Nine desig-
nations were to county governments or county planning boards and five
are to water quality agencies or sanitation districts. These agencies
may have considerably more implementing powers and therefore may be
able to provide a smoother transition to the management phase and on-
going planning process than the typical COG.
In a few instances, non-regional agencies were designated.
Rhode Island State Office of Planning is a case of statewide 208 plan-
ning. Special arrangements were made to conduct 208 planning in Guam
and in Puerto Rico. In New York City, the Environmental Division is
the designated agency, while the Delaware River Basin Commission is
doing planning for three 208 agencies.
Seven 208 designations were made to two agencies jointly
through a consortium or an interlocal agreement. In most of these
cases, both agencies had originally applied for 208 designation in
the same or in adjoining areas. The nature of the water quality prob-
lem was such, however, that a joint approach made more sense. In
these instances a lead agency was chosen and a Joint Working Task
Force formed. Formal working agreements and work outlines were re-
quired as a condition of ,designation either by the Governor or by EPA.
3
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Experience of Agencies
208 agencies' experience 1n planning 1s presented below.
Table 3
208 AGENCIES' EXPERIENCE IN PLANNING
New
Agency
Less than
2 Years
2-5
Years
5-10
Years
Over
10 Years
Not
Available
Total
17
14
16
55
34
13
149
Only 17 agencies were newly created to do 208 planning. About
half of these were in Region VIII. All other designated 208 agencies
already existed, nearly 65% within an agency that has been 1n exist-
ence for five years or more. This previous agency experience will be
a valuable asset to 208 planning, particularly in light of the short
time 208 has to begin producing outputs. Such agencies cannot only
offer familiarity and Informal contacts within the designated areas,
but also have data, offices and staff that can be shared. 98 of the
208 agencies are physically located in the same place as the parent
agency.
Coordination is another advantage to this parent-208 relation-
ship. Only fifteen of the agencies conducted just 208 or one other
kind of planning. 80 of the parent agencies conduct at least five
other kinds of planning functions. The most common were HUD 701,
noted as a prime function of at least 109 agencies and areawlde trans-
portation planning which was a responsibility for 92 agencies. This
situation provides an excellent opportunity for coordination and for
joint efforts. 84 programs are A-95 review agencies. This fact will
become more important during the implementation phase of 208.
As for other environmental planning responsibilities, 62
parent agencies conduct solid waste planning, 29 do air quality plan-
ning, and 32 do Coastal Zone Management work. Thus, there is a high
potential for inter-media coordination.
The following table presents the breakdown of the various
other planning functions performed by 208 agencies.
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Table 4
OTHER PLANNING FUNCTIONS PERFORMED BY 208 AGENCIES
Planning Program
Number of Agencies
DOT
Coastal Zone Management
HUD 701
Air Quality Maintenance Area
Solid Waste
Areawide Transportation
Corps of Engineers
Forest Service
Soil Conservation Service
A-95 Review
32
119
29
62
92
21
14
22
84
As for water-related planning experience, only 30 agencies had
no previous experience. 28 had direct experience, many having com-
pleted a 3-C plan. 69 had related experience either in-house or
through consultants. Thus, nearly three-quarters are at least partially
familiar with the water quality and their related institutional problems.
Staffing
By the time of the interviews (July 1975) 325 professionals and
97 non-professionals were working in 208. Anticipated nationwide totals
are for 653 professionals and 184 non-professionals. In addition 208
agencies expect to "borrow" from parent agencies and other agencies an
additional 834 persons. These would most often be legal, financial,
public participation, land use planners, executive directors and secre-
taries, who will spend most of their time on other projects, but will be
available to 208. Thus,-in 136 agencies nearly 1,700 staff people will be
involved in 208 in some way, once 208 is in full operation. These 1,700,
however, will not necessarily be newly hired. Many, perhaps the
majority, will be switched either from the parent agency or an agency
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dealing with water quality planning. Consultants form another signi-
ficant manpower resource for the 208 planning effort. Based on the
percentage of grants for outside contracts (see Budget), it 1s esti-
mated that between 400 and 1,000 consultant man-years will be employed
during the two year planning period. This estimate is based on the
average value of contracts and average consulting man-year costs.
75 agencies indicated that staffs were only being hired for
the two year planning period due to the uncertainty of future funding.
This may have unfortunate consequences to 208 during the ongoing
period following the Initial two years. The earlier 1974 programs
experienced some problems in staff hiring because 208 was still unheard
of. More recent programs have had no trouble hiring planners, but some
problem hiring experienced people. This was mentioned in connection
with the unattractiveness of a limited two year job for upper level
engineers.
Given the dual technical/management nature of 208 it is inter-
esting to look at the backgrounds of those who will be chiefly respon-
sible for the final end-products. 98 of the 208 Project Directors had
been hired by the time of the interviews. 65 are planners by disci-
pline, 18 are public administrators, and 34 are sanitary or civil
engineers. The rest all have backgrounds in various disciplines.
Thus, the disciplines of the directors would seem to reflect a recogni-
tion of the planning/management aspects of 208.
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EWIROflOTAL ASPECTS
Findings
A review of the environmental problems facing 208's around the
country uncovered the following major issues:
The water quality factors most often cited as
critical to designation as a 208 agency were water
quality limited segments, substantial industrial
pollution, and urban storm drainage.
The water quality parameters considered critical
to meeting1 the 1983 goals were coliform bacteria,
dissolved oxygen and nutrients - these turn out to
be the most often and easily measured.
Water quality data essential to 208 plans was
often incomplete or unavailable because the states
are not producing the required 303(e) outputs.
Many agencies are therefore placing great emphasis
on their own monitoring efforts.
The two major problems in monitoring and analysis
are 1) regional differences in the administration
of EPA monitoring/modeling policy, 2) scheduling
monitoring activities within the 24-month period.
The primary reasons for not achieving the 1983
"fishable, swimmable" goal are 1) lack of tech-
nology for nonpoint source control and 2) lack
of public funds for structures to control urban
storm water.
Current Hater Quality Problems
The following table lists those water quality factors mentioned
as reasons for areawide designation.
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Table 5
FACTORS RESPONSIBLE FOR DESIGNATION
FACTORS
Water quality limited segments
Preservation/Protection of high
quality waters involving --
unique resource impaired by
growth
complex institutional setting
complex sources of pollution
state preservation statement
(non-degradation)
Municipal waste management by
two or more local governments
Substantial industrial pollution
problems
Substantial urban storm drainage
Substantial nonpoint sources
agriculture
silviculture
mining
construction
septic fields
benthic (sludge)
combined sewer overflow
urban storm water
fecdlots
other
Groundwatcr Pollution
contaminated groundwater of
major water source
groundwater pollution con-
tributes to surface \Mter
problem
complex groundKuter problem
state or area grcundwater goal
saltwater intrusion
other
1
15
14
11
15
15
16
13
13
13
6
5
13
IS
13
11
13
6
2
13
11
11
12
2
2
2
M
5
4
5
3
8
9
9
4
-
2
8
7
6
5
8
3
-
5
5
5
3
4
-
3
9
5
6
6
3
8
8
6
9
5
3
9
8
5
5
8
5
1
4
3
4
2
4
-
R
4
22
7
5
6
5
20
20
20
20
6
4
19
19
3
6
18
9
-
6
7
7
3
6
-
E G 1
5
21
10
11
7
7
11
20
15
17
3
3
8
11
7
21
15
5
7
12
2
2
1
1
1
0 N
6
5
1
3
2
-
5
5
2
2
-
1
2
2
-
-
3
2
-
-
-
1
-
-
-
7
4
4
5
5
1
5
4
4
3
-
2
2
4
2
3
4
1
1
2 '
1
1
-
-
.
8
15
9
8
5
6
9
11
12
7
6
14
13
7
_
3
10
9
1
11
4
4
-
-
_
T
3
3
-
2
3
1
3
2
1
1
4
4
.
1
5
2
1
4
-
1
1
-
-
_
~TO~
9
7
5
6
4
2
5
-
9
7
4
9
6
4
3
8
2
-
-
-
-
-%
_
Total
103
65
58
59
47
85
98
83
76
26
38
74
74
45
59
79
40
16
40
34
35
18
16
3
Discharge fror v:astewatcr treat-
ment plants
11
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Lack of Uater Quality Data
An essential ingredient for a successful 208 program is the
availability of water quality data which accurately defines problems
in such a way that control strategies and alternatives can be devel-
oped. Incomplete and often unavailable water quality information
was causing considerable problems for 208 agencies. Many agencies
expressed concern that this would delay the completion of their plan.
The agencies reported that the 303(e) Basin Study outputs are not
sufficiently developed, and sometimes not readily available to satisfy
the needs of the 208 agencies (see Chapter on Coordination).
About one-half of the agencies have waste!oad allocation infor-
mation available. However, many of those agencies feel that the allo-
cations will need revaluation. The most often cited reasons for re-
evaluation were insufficient data, faulty modeling, and a lack of
confidence in the results. The other half of the 208 agencies did not
mention having wasteload allocation information. This is due to one
of three reasons: The states have not developed wasteload allocations
yet, the programs have not contacted the states for the wasteload
allocation information, or the fact that some areas do not have water
quality limited segments and, therefore, wasteload allocations are not
applicable. Regardless of the source of the problem, the lack of
availability of useable data will delay the program.
The lack of available information has generated great concern
about monitoring and analysis. 83 agencies stated that monitoring
will definitely be conducted in their areas; 10 stated that they might
do it. The most often cited reasons for doing monitoring were ranked
as follows: to determine the spatial and temporal extent of the prob-
lem, to determine whether certain problems exist, to measure the magni-
tude of nonpoint source loads, and to collect, calibrate or verify
data for nonpoint source analysis. The interviewees stated that the
credibility and acceptance of 208 pollution control strategies would
depend upon sufficient data to demonstrate the cause/effect relation-
ship between land use and water quality in their particular areas.
They feared that incomplete information might result in delay of plan
approval and court action by impacted localities and industries.
The 208 agencies anticipated two major problems in monitoring
and analysis. One problem occurred in getting monitoring activities
approved by the Regional EPA office. Some Regions interpreted the
Program Guidance Memorandum, AM-8 to mean little or no monitoring and
modeling should take place, while other Regions assessed the monitor-
ing and modeling requests on a case-by-case basis. Those agencies
that are not monitoring anticipate problems establishing control
strategies. In several instances, monitoring was not permitted in
water supply areas despite the fact that they were prime areas for
residential growth.
-------
The presence of water quality limited segments was the major
reason for areawlde designation in 103 areas. Industrial pollution
(98 mentions), municipal waste by two or more local governments (85
mentions), and substantial urban storm drainage (83 mentions) are
other nationally significant water quality problems.
In the area of nonpoint sources, the predominant problem is
urban storm water in 79 areas. 76 agencies stated both construction
and septic fields as nonpoint source pollution problems.
Where groundwater pollution was a problem, it was considered
a major and difficult task 1n water quality management. The most
important groundwater problem mentioned was the contamination of
major groundwater drinking supplies (40 mentions). 35 agencies
stated they had a groundwater problem, and 34 said their groundwater
problem contributed to surface water pollution problems.
Important water quality parameters (and the number of agencies
that mentioned them) are presented in the following Table 6. The table
totals the number of responses for each parameter by Region. The ex-
tent of these problems Is not really known, particularly with regard
to groundwater
Table 6
PROBLEM PARAMETERS IN 208 AREAS
REGION
Dissolved Oxygen(D.O.)
Nutrients
Col i form bacteria
Suspended Solids
Pesticides/Herbicides
PH
Heavy metals (specify)
Toxics (specify)
Temperature
Total dissolved
solids (TDS)
Benthic deposits
1
1
1
1
1
1
1
1
1
3
3
6
5
1
4
9
0
5
0
2
2
8
8
7
7
3
1
4
3
6
2
6
3
10
9
9
8
5
3
7
4
5
5
5
4
17
17
18
9
10
5
6
5
2
3
3
5
22
16
18
17
15
6
14
4
10
9
4
6
5
4
4
3
1
1
1
-
-
2
7
5
4
4
3
3
1
2
3
2
3
1
8 9
8
7
12
14
2
2
12
12
3
14
1
10
8
7
10
7
3
2
2
3
8
4
4
Total
96
85
98
83
53
25
57
44
41
52
36
10
-------
Another problem in monitoring and analysis involves the time
it takes to collect data. In many cases, other tasks are dependent
on the availability of that data. Moreover, there are only two sum-
mers in which to collect low flow data for 208; this means that scopes
of work must be prepared and contracts let very quickly. Most agen-
cies will have only one summer to do sampling, as the low flow period
has passed for the first year of the planning period. Laboratory over-
loads, and in some places their distance from sampling stations, are
also anticipated as problems in a monitoring program. The two year
planning period therefore puts severe constraints on the development of
pollution control strategies where data is not available.
In addition to a lack of stream monitoring data, there is also
a lack of point source discharge information. Agencies have reported
that the data from the NPDES permits does not provide the type of in-
formation necessary for modeling purposes; others have said they had
difficulty getting the data that was available. Some agencies had to
pay for the permit information while others were invited to search
state files to obtain it. Industrial and domestic point source data
was occasionally nonexistent. At the time of interviews, only 53% of
208 agencies interviewed had obtained list of point source discharges.
The Impact of 208 on 1983 Goals
208 agencies were asked to indicate whether the 1983 goals
could be met as a result of implementing the plan. The results are
presented in Table 7.
61 of the agencies said part of their area could meet the goals;
24 said all of their area; 12 said none of their area; 31 did not know;
5 said their whole area already met the goals.
Reasons for not achieving the 1983 goal are listed in Table 8.
The most often cited reasons for not achieving the T983 goals were: lack
of technology for nonpoint source control; lack of public funds for
structures to control urban storm water, and irreversible or slowly
reversible water quality problems. Some agencies, in responding to the
question, said that "fishable and swimmable" had not been sufficiently
defined. Others felt that the delay in getting the 208 plan approved
would result in a delay in achieving the '83 goals. Finally, a few
agencies stated that the 1983 goals will be met, but that the water
quality level would not be sustained due to increases in population and
the limits of present abatement technology.
11
-------
Table 7
ACHIEVEMENT OF THE 1983 GOALS
1 2 3
REGION
456789
10
Total
Will the 1983 goal be met everywhere or anywhere in the
planning area as a result of implementing the study?
Everywhere
Some places
Nowhere
Don't know
Already meets 1983 goals
No
TOTAL
REASONS
REASONS
Table 8
FOR NOT MEETING
3 - 1
4 10 3
6 -
8
4 1 -
_
17 11 , 12
THE GOALS
1 2 3
3 3 2 - 71
18 12 3 - 6 -
31- 2 -
57226-
______
3 -
26 25 8 5 21 1
REGION
456789
4
5
-
1
-
-
10
10
24
61
12
31
5
3
136
Total
Irreversible or slowly reversible water quality
problems
Lack of best available technology for
control
Lack of technology for nonpoint source
Lack of public funds for structures to
urban storm water
point source
control
control
8 -
3 1 2
622
9 1 1
5711-
28211
7 12 - 32
8 1C 2 4 2
4
1
6
3
26
21
40
40
Difficulty of the required analysis and probable
lack of confidence in results
Inability to show cost-effective control alternatives
4 - - 1
3 - 1
513-
5311-
3
3
17
17
*Total is greater than 136 due to multiple responses.
-------
LAND USE ASPECTS
Findings
The information gathered on land use revealed the following
issues:
The EPA time limit for Interim Outputs places a severe
burden on some agencies whose land use elements are
less advanced and will require significant data collec-
tion and updating. Some agencies stated that not meet-
ing the 9-month deadline would not necessarily hinder
other 208 planning activities.
Where available, most HUD 7Q.1 data was out-dated
and incomplete, although there were some cases where
it provided an adequate base for 208 planning.
Agencies are often unable to identify, quantify and re-
late nonpoint source pollution to land use and water
quality.
Land Use Considerations in the 208 Planning Process
Land Use Projections
It was originally envisioned that most designated agencies would
be able to use HUD 701 or local data for their land use plans and pro-
jections. Unfortunately, many areas have not found this feasible. Even
where there was a great quantity of information, many 208's felt that
existing 701 data was less than complete and often outdated. 28 of the
responding agencies with existing land use plans available indicated
that existing 701 would require extensive development or updating for
their 208 project. Therefore many agencies felt that they would have
to undertake additional land use tasks that were not originally en-
visioned under 208 planning. While 93% of the 208 agencies have 701
planning ongoing in their respective areas, only 78% were actually doing
this planning themselves. 42 agencies plan to contract out either all
or part of their land use element.
The need to do additional land use work should not be construed
as an insurmountable roadblock in the 208 planning process. Many parent
agencies were already engaged in updating their land use plans or work-
ing in conjunction with their 208 divisions to revise the existing in-
formation. The data developed through these efforts will help lighten
the burden on the 208 program.
13
-------
EPA - HUD Agreement
The agreement between EPA and HUD, clarified in AM-9, has not
reached many 208 agencies. Those agencies that were familiar with
AM-9 were rarely able to directly follow the specified funding pro-
cedure. This is not to imply that there is a complete absence of
coordination. In areas where a strong 701 program is under way,
an equitable division of costs is usually reached under locally de-
signed arrangements. In a number of areas where 701 funds are dry-
ing up, 208 is assuming the major cost of land use elements. In no
case was the work of one program being repeated in another.
In short, the agreement has fostered locally tailored
coordination between the 701 and the 208 programs. Although not
directly in line with the AM-9 Memo, this has been a step toward
elimination of duplication of Federal efforts in local areas. It
has additionally evolved a process of dividing costs, an important
aspect of improving coordination among Federal grants for local
jurisdictions.
Budgets
The following table depicts the percentage of their grant to be
spent on land use. (See Table 9)
44 of the agencies Interviewed plan to spend from 8-15% of
their total budgets on collecting and analyzing their land use data.
19 will spend over 16% on land use, while 49 did not have their land
use budgets developed yet. Since there was no standardized budget
guidance from EPA, and subsequently no clear definition of land use for
all the agencies to follow, land use expenditures were often hidden 1n
nonpolnt source analysis budgets. In addition, there was often no
breakdown 1n the budgets between point and nonpoint sources of pollu-
tion, thus making it difficult to determine the total amount of money
spent on land use.
Interim Outputs
87% of the agencies interviewed Indicated that they would be
able to meet the nine-month Interim Output deadline. 29% have computer-
ized data banks that Include land use information, while another 43%
have non-computerized land use data available 1n a variety of forms.
The remainder feel they will be able to gather the Information required.
However, 13% Indicated they will not be able to gather the needed Infor-
mation on time. This problem was primarily attributed to a lack of land
use plans within their jurisdictions.
By establishing time limits for Interim Outputs, EPA has put
these agencies at an early disadvantage. Those agencies that must de-
vote a large amount of time to the development of land use information
14
-------
often have less time to devote to other key planning issues, such as
management and analysis, during the initial stages of the project.
Table 9
PERCENT OF BUDGET ALLOCATED FOR THE LAND USE ELEMENT UNDER 208
NUMBER OF 208 AGENCIES
"/
lo
of grant
to be spent
on land use 1
0- 3%
4- 7%
8-10% '6
11-15% 7
16-20% 3
> 20% 1
No
Answer
REGION
2 3 a.
1
1 2 4
1 2 7
3
1 2
2
968
567
4 - 1
2 - 1
3 - 1
1 1 1
1
-1
14 7 -
8 9
-
3 -
2 -
6 -
3 -
5 -
2 1
10
2
3
2
1
-
-
2
Total
8
16
24
20
10
9
49
Total
17 11 12 26 25
21
1 10 136
15
-------
Nonpoint Source Pollution and Land Use
Nonpoint source pollution is a major reason for areawlde waste
treatment management planning. However, many agencies expressed con-
cern over their present inability to identify and quantify nonpoint
source pollution and their subsequent difficulty in relating land use
to nonpoint sources and water quality.
The following table indicates nonpoint source pollution prob-
lems in 208 areas.
Table 10
SUBSTANTIAL NONPOINT SOURCES
Nonpoint Source Mentions by 208 Agencies
Agriculture 76
Benthic (sludge) 45
Combined Sewer Overflow 59
Construction 74
Feedlots 40
Mining 38
Silviculture 26
Septic Fields 74
Urban Storm Water 79
Other 16
One means of determining nonpoint source pollution is the develop-
ment of conversion factors that would relate land use to water quality.
While few agencies have actually undertaken this endeavor, almost half
the agencies interviewed said they will develop these figures at the ap-
propriate time. Although not asked in the interview, five agencies indi-
cated they plan to use published conversion factors and would like some
guidance from EPA concerning this matter.
16
-------
MANAGBefT/ir^STITUTIONAL ASPECTS
Findings
Management is the structure and process by which a 208 plan
will be implemented. It is a system of actions and institutional
arrangements necessary to achieve and maintain water quality goals.
The major findings related to the management and implementation of
208 plans are as follows:
The majority of 208 agencies do not feel they have
the in-house capability to deal with the management/
institutional issues and are contracting for this
work. Fully a third of the agencies have yet to de-
cide whether they or consultants will complete this
element of the plan. This may be a problem in view
of the time it takes to let out contracts and the
importance of considering management from the outset
of 208 planning.
There is a strong commitment on the part of the
designated agencies to develop and implement a man-
agement system, but considerable uncertainty at this
point in the process, as to what that system will
look like, how it will be created and what powers it
will exercise.
Local 208 personnel are uneasy and uncertain about
EPA's enforcement powers; if the Agency is consider-
ing real sanctions, it should make them known.
A single planning agency and several management
agencies is the institutional arrangement for 208
management foreseen by most of the interviewed agen-
cies. There will be very few "super agencies."
Most 208's will opt for modifications of existing
arrangements. Rather than major institutional
changes, the general insistence on "local autonomy"
will be a serious constraint on management alterna-
tives.
The concept of a lead management agency and the
relationship of the planning agency to the manage-
ment agency are not understood.
17
-------
Designated Agencies Capabilities in Management Planning
There are few generalizations that can be made about the exist-
ing institutional arrangements in 208 designated areas. One charac-
teristic shared by most 208 areas was municipal waste management by
two or more local agencies. This kind of fragmented approach to
treating waste is the reason for 208's areawide approach, and 69% of
the agencies interviewed said it was a factor in their designation.
More than half the agencies responding said the protection or
preservation of high quality waters was made difficult by a complex
Institutional setting. 208's mission is to create order from chaos
through one integrated waste management system, (though that may be
composed of several different management agencies and many plants).
Table 11 describes who will be undertaking the management work
element in each of the agencies interviewed.
Table 11
WHO WILL DO THE LEGAL/MANAGEMENT/INSTITUTIONAL
WORK ELEMENT OF THE 208 PLAN?
REGION
Consultant
In-house
No answer
Total
1
6
2
9
17
2
6
5
-
11
3
7
2
3
12
4
18
4
4
?6
5
0
4
21
?5
6
6
-
2
8
7
3
-
2
5
8
15
-
6
21
9 10
1 9
-
1
1 10
Total
71
17
48
136
The majority of 208 planning agencies did not feel they had the
in-house capability to deal with the management/institutional issues
alone. Only 17 are doing it all in-house; many more will share this
responsibility with consultants, 71 are contracting for at least a
part of this planning and analysis. 48 agencies have yet to decide
whether they or consultants will do the work. This is a potential
problem area considering the time it takes to let out contracts and
the importance of considering management from the outset of 208 plan-
ning. When asked when they planned to undertake the analysis of man-
agement alternatives, agencies responded with the range of day-one to
as late as the 18th month in the planning process. Table 12 presents
the results.
18
-------
Table 12
WHEN WILL MANAGEMENT ALTERNATIVES ANALYSIS BEGIN?
REGION
0 - 1 month
2 - 6
7-12
13-18
19-24
Don't know
No answer
Total
1234
6 - 2
10 2 - 5
7
3
_
6
1 9 12 3
17 11 12 26
5
6
6
6
1
-
6
-
25
6
1
5
1
-
-
1
-
8
789
3 1
1 8 -
1 3 -
2 -
_
2 -
33-
5 21 1
lo
4
2
4
-
-
-
-
10
Total
23
39
22
6
-
15
31
136
The notion of a statewide model for a management system has been
considered in several states. Most of the 208 agencies in Texas will
let a joint request-for-proposals for their management/institutional
planning. In Maine, the designated agencies have agreed to jointly
finance either one consultant or one selected agency which will re-
search some of the common management institutional questions facing all
of them.
Major Issues
Commitment
There 1s clearly a strong commitment on the part of the designa-
ted agencies to develop a management plan that will be both effective
and capable of implementation, though that commitment is hard to quan-
tify. The most obvious evidence of such a commitment is that 12% of
their grants is the average amount agencies will spend on their legal/
management/ institutional work elements. 15 of the agencies have, or
will soon have., lawyers on their staffs to deal with implementation
issues and any other legal problems; 46 will have public administra-
tion or management specialists.
19
-------
One particular situation should be-carefully watched. One of
the earliest funded 208 agencies does not Intend to tell Us consti-
tuent jurisdictions what is the best Institutional arrangement for
208 implementation. This agency sees its role as going no further
than the presentation to Its local governments of alternative manage-
ment systems - the decision as to which alternative to implement
being left to the locals. This will be a problem 1f locals do not
feel compelled to choose an alternative, and the management system
becomes shelved with other planning programs. This situation should
be carefully watched to insure that Implementation is an integral
aspect of the plan.
Regarding those agencies that are_ commi tted to selecting one
management arrangement, it is not clear to them how to achieve a
system that is both effective and can be implemented. Certainly,
some compromises will have to be made by all agencies to ensure local,
state and federal approval.
Agencies' Knowledge/Understanding of Management/Institutional
Aspects
Most agencies are aware of the particular emphasis of 208 on
management and implementation. They know that only the most appro-
priate and innovative management systems will be effective and that
EPA will not accept the designation of a management agency if it does
not have the authority to carry out the plan.
208 personnel are confused, however, about EPA's enforcement
powers. For example, it is unclear whether permits or construction
grants will be denied in order to encourage completion or approval
of a plan. Many agencies voiced the fear that EPA was a "paper
tiger"; if the Agency is considering real sanctions, it should make
them known. This would spur 208 agencies to make the kind of commit-
ment to management and Implementation that will be necessary to develop
a worthwhile system.
Although aware of the need for an areawide management system that
will "meet the requirements of the Act", the agencies are unsure what
that system will look like, how it will be created and what powers it
will exercise. For example, 89% of the agencies Interviewed said they
would find management/legal/lnstltutional seminars useful. Their com-
ments in response to this question demonstrate a great desire for
state-specific guidance as to legislation needed and how to go about
getting it; and for innovative institutional and financial arrangements.
22% of the agencies could not make an educated guess as to who the
management agency would be and as mentioned above, several agencies said
it was not their responsibility to select a management agency. About
one-third of the responding agencies were not familiar with the required
authority of a management system set forth in Section 208(c), and many react
with Incredulity to the suggestion that their management agency be able
to do such things as Incur indebtedness and refuse wastes from publics
not complying with the plan, both of which are required by Section 208(c)(2)
20
-------
Optional Management Systems
*
Section 208 allows states and localities great flexibility in
designing areawide waste management systems, and EPA encourages 208
agencies to find the best institutional arrangement to deal with its
own water quality and financial needs. Possible 208 management sys-
tems can be placed in 3 categories: single agency for both planning
and management; single planning agency and a single management agency;
and single planning agency and plural management agencies.
"In some situations, when a single governmental jurisdiction
already exists and encompasses the entire 208 area, it may be assigned
both the planning and management responsibilities."1 Of the 136 agencies
interviewed, however, less than 20 have any management capability at all,
i.e., are something other than COG's with virtually no implementation
authority. Furthermore, most of these agencies only have limited
implementation capability, and could not serve as the sole management
agency. Only 3 of the agencies interviewed thought that they would
be the 208 management agency.
Another option is to designate one management agency, separate
from the planning agency. This arrangement will not appear very often,
judging by the'present thinking of the designated planning agencies.
Only 11 of those interviewed expected there to be a single management
agency.
The third option, single planning agency and plural management
agencies, was definitely preferred by designated planning agencies.
"This option would allow those management agencies already providing
waste treatment service to continue doing so with a minimum effect
upon their internal administration."! Coordination between planning
and management will suffer in this type of arrangement, but individual
local governments will "retain their own waste treatment agencies and
other authority,"1 a consideration uppermost in the minds of those
agencies searching for a plan that will win local approval. 68 agen-
cies, or just over half of those interviewed, felt there would be
several management agencies in their areas. There was an even split
among the 68 agencies between those expecting there to be several
management agencies with a high degree of regional authority and
those expecting several management agencies with much local autonomy.
8 other interviewees volunteered that management would be solely by
local governments. There are only 19 agencies that predicted the
creation of a new agency to manage and implement 208. 32 would not
make a prediction as to the structure of their management system.
1
Draft Guidelines, May,1974.
21
-------
In discussing expected management organizations with 208 person-
nel , it became clear that most had done little thinking about the sub-
ject. Those that had seriously considered it were rather confused
about the relationship of the planning agency to the management agency.
Almost all of them expected to do the ongoing 208 planning themselves,
but were not clear on just what that would entail and how it would
relate to the implementation or management of the program.
An equally confusing concept is that of a lead management agency.
EPA's Draft Guidelines state that "whatever approach is taken, the
essential consideration is that coordinative authority capable of
facilitating the resolution of conflicts and implementation of the plan
be a central component of the management system." This has done little
to clarify the situation 1n the minds of 208 project directors. They
don't know whether they must have a lead agency or what authority the
lead agency should have.
Compounding the difficulty in selecting a management agency are
the political situations 1n which 208 planning proceeds and which it
cannot Ignore. More than a third of the agencies experienced delays
1n obtaining resolutions of intent from local governments and 22
said there was public disinterest or hostility toward 208 planning.
55 agencies expect local review and approval to be a problem.
Whatever management systems are chosen will undoubtedly leave a
great deal of management authority 1n the hands of local governments.
Most responses to questions about 208 implementation centered on the
fear local jurisdiction of losing autonomy and control. Many inter-
viewees spoke of the "ramifications" of management. One agency took 9
months convincing its local jurisdictions to participate in 208 because
of their fears regarding the prospective management structure.
Methods of Organization
If a plan does nothing to change existing Institutional arrange-
ments and leaves the bulk of authority with local governments it will
be considerably simpler and easier to Implement. Even where local
ordinances or contracts are the only legal arrangements to be made,
plans to obtain them. Many of the agencies responding said that a
contract would have to be negotiated between the designated management
agency and local governments or that some kind of joint establishment
between the management agency and the local governments would be likely.
Most interviewees believed that new state enabling legislation or
changes in State law would be required.
22
-------
Required Authority and Regulatory Controls
Section 208(c) (2) states that an areawlde management system
must be able to:
t design, construct and operate waste treatment works
accept and utilize grants
t raise revenues and assess waste treatment charges
Incur Indebtedness
t require participating communities to pay proportionate
share of treatment costs
t refuse wastes from publics not complying with the plan
t accept industrial wastes and set pretreatment standards
Many 208 agencies are not yet aware of the Act's requirement
of these powers. They are not thinking of one management system
that will have all these capabilities. This may be attributed to the
early stage of the program in most areas.
When asked what regulatory controls would be used, many agen-
cies were unable to answer, again because they had not begun to con-
sider the subject. The most oft-cited method was metering of waste-
water flow, then building and housing codes and subdivision regula-
tions, discharge permits, zoning, planned unit developments, and
finally differential tax assessments. Discharge permits will be more
heavily relied upon than this rank-order shows, since most agencies
will be relying on the state and Federal governments to administer
the permit program.
The responses to the potential regulatory methods naturally
vary considerably from state to state. In a few areas, the notion of
land use control is feared by the locals, and 208 agencies are strug-
gling with ways to get around local practices and beliefs. There is
a rule for the states to play in this area, where legislation could
mandate a change in local unwillingness to accept any form of land
use controls.
23
-------
PUBLIC PARTICIPATION
Findings
ono Jt thls tjme, 1t 1s too early to judge the effectiveness of
208 public participation efforts. Most agencies are in the early
stages of their projects and only a few have begun any significant
public participation work.
The profile study did, however, reveal a number of patterns
and issues which appear to be developing across the country:
The majority of agencies are designing public
participation programs in compliance with EPA
minimum guidelines (40 CFR 105).'
Agencies generally recognize the importance of
securing public approval of 208 if the plans
are to be accepted and implemented.
208 agencies expect to experience various forms
of opposition from citizen groups and individuals.
208 agencies' public participation expenditures
are generally used to develop a one-way flow of
information to the public. This is a necessary
first step, but mechanisms for feedback are
essential. Plan acceptance will be jeopardized
if the general public is only included in 208
planning through committees; furthermore, an
excellent opportunity to involve the public in
pollution control will be lost.
Who is the Public?
"Publics" potentially affected by the 208 program can be broken
into three levels to facilitate differentiating among the various
groups that are part of the planning process.
1
Public Participation in Water Pollution Control
25
-------
Level I 1s composed of governmental agencies linked
to environmental management, and private businesses
which depend directly on the use of environmental
resources.
Level II Includes special Interest groups and organ-
Nation? concerned about environmental management.
Level III 1s the general public whose attention 1s
unlikely to be focused on environmental planning
unless a crisis has alerted them to their dependence
on sound environmental policies.
A Shift in Approach
Most 208 agencies recognized the need to include the public
throughout plan development. Past experience with other water
quality programs has convinced them that waiting to "sell" the
public a completed plan usually fails. This was particularly true
with regard to state 303(e) plans where the public felt left out
of the planning process. In fact, many agencies said it was neces-
sary to disassociate themselves from 303(e) plans because of the
hostilities created during that process.
Experience with Public Participation Programs
Table 13 indicates the experience of the 208 agencies with
public participation programs.
Table 13
EXPERIENCE IN PUBLIC PARTICIPATION PROGRAMS
Experience
in Public REGION
Participation
Yes
No
Total 17 11 12 26 25 8 5 21 1 10 136
1
17
-
2
9
2
3
12
-
4
24
2
5
23
2
6
7
1
7 8 9
5 13 1
8 -
10
10
-
Total
121
15
26
-------
121 agencies had previous experience with public participation
programs. Some of these agencies had developed environmentally con-
cerned constituencies, which would be rallied again for the 208 pro-
gram.
15 agencies had no previous experience with public involvement.
Over half of these are located in the more remote areas of the West
where planning itself is a relatively new activity. A number of inex-
perienced agencies voiced some concern over their ability to get an
effective program working early enough in the planning process.
Budget and Staff
The following table depicts regional allocation for public
participation programs.
Table 14
RANGE OF THE % OF BUDGET ALLOCATED FOR PUBLIC PARTICIPATION
REGION
Allocation
Low (%)
High (%)
Average(%)
1
5
20
9.4
2
3.5
10
7.5
3
3
20
9
4
2
14
6.8
5
2
20
10
6
3
10
5.3
7
17
9
2
.3
.1
8
1.5
9
4
9
10
10
10
10
1
13
4.1
Budget allocations for public participation ranged from 1% to
20% of total grant awards with an average allotment of 8%. This wide
range was experienced because some regions advised their 208 agencies
to allocate a uniform dollar amount for public participation rather
than a percentage of their budget. This statistic also does not reveal
all monies that will be spent on public participation. For example,
funds to be spent on committees, plan approval, and other coordination
activities are often included in other budget categories.
Table 15 indicates how the agency will delegate responsibility
for the public participation programs.
27
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Table 15
RESPONSIBILITY FOR PUBLIC PARTICIPATION
PROGRAMS*
Public ___ REGION
Participation 123456789 TD~ Total
Public
Participation
Coordinator
Other
Consul
* Does
Staff
tant
not equal
8
13
3
136,
1
7
1
as
5
5
2
some
12 19
11 3
2 -
agencies
52713
1 3
2 -
Indicated
13 - 8
7 -
joint work
63
64
17
144
Part of the public participation money will be used directly to
hire In-house staff and consultants. 63 agencies Indicated they would
hire a staff member specifically for the purpose of coordinating the
public participation program. 17 agencies Intended to hire a public
participation consultant to help design and implement a public involve-
ment strategy. In 64 agencies, various staff members will conduct the
public participation activities. In a few cases, project directors
will be directly in charge.
The majority of agencies had not yet formalized an internal
communications system to insure proper transmission of input gathered
through the public participation.
Committees
All of the 208 agencies have or will be setting up committees
with representatives from all levels of the public to assist with the
development of the 208 plan. Some of the more established 208 agencies
have extensive networks of committees in operation, while many new or
single purpose agencies only have an agency governing board at the
present time.
For the purposes of 208 planning and implementation there seems
to be three basic types of committees which will be in operation in most
208 areas. These are the general planning advisory committees, techni-
cal committees and sub-committees, and citizen advisory committees. The
planning advisory committees (also called policy advisory committees,
water quality task forces) are quite consistent across the nation. They
usually constitute the formal link between the program and the parent
organization, reporting to the parent organization's governing body on
the progress of the program. These committees will revise the work plans
and review results of data collection, and management analysis.
28
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Membership on these committees primarily includes government
and business representatives (Level I) with additional representation
of interest groups (Level II) and private individuals (Level III).
At the time of the interviews there were 65 planning advisory
committees in operation, with the balance yet to be established.
Eight of these committees are joint task forces composed of repre-
sentatives from two agencies in dually designated 208 areas. The
average size of these committees is about 25, although there was a
range of 3 to 90 members.
The technical advisory committees (1n some cases, sub-committees
to the areawide 208 planning committees) assist in the development and
review of technical elements in the program. Although representatives
from all levels of the public exist, government staffs and business
representatives predominate. Most members are sewer district managers,
city managers, and representatives from various water and sewer authori-
ties, as well as State and Federal agencies. There are currently 59
technical committees in operation throughout the country. Most have a
membership of approximately 20, although the numbers range from,7 to 64.
The citizen advisory committees are the principal avenues for the
Level II and III publics' input into the planning and decision making
process. 45 of these committees were already formed at the time of
interviews. Their average membership 1s 35 with a range of 5 to 250
members.
The majority of the 208 areas have opened committee membership
to any Interested individuals. Some agencies qualified this condition,
however, by specifying that only approved members could vote. In one
state, for example, the Governor issued an executive order specifying
that he would have final approval over the planning advisory committee
membership. This situation has restricted public accessibility to the
program, and has delayed some 208 program start-ups.
Public Education
Table 16 indicates whether 208 agencies have received requests
for briefing on the 208 program.
Table 16
PUBLIC REQUESTS FOR BRIEFING ON 208 PROGRAM
Total
REGION
Requests
Yes
No
1
1
0
7
2
5
6
3
4
8
4
12
14
5
17
8
6
5
3
7
4
1
8 9
7 1
14
10
7
3
Total
72
64
17 11 12 26
21
1 10
29
135
-------
At the time of the Interviews, 72 agencies had already received
requests from various groups for briefings about the program. Among
the aspects agencies Indicated the public would find difficult to grasp
were:
0 the nature of the 208 program Itself;
the concept of nonpolnt sources of pollution;
the relationship between land use and water quality;
technical terminology;
the management aspects of the program;
coordination with other water programs such as Sections
106, 201, 208, 209, 303, and 402;
the need for another planning program.
In response to this need, agencies were generally setting up
public Information programs similar to the one that appears 1n the
Interim Output Handbook. At the time of the Interviews 1t was Impossi-
ble to obtain any meaningful data on how these techniques would be
received by the public.
t Mailing Lists - Of the agencies Interviewed, 121 have
already begun to establish mailing lists of interested
Individuals and groups 1n their regions. In some
cases, these lists are nothing more than the parent
agencies normal mailing lists with a few additions.
In other areas separate mailing lists for those people,
groups, and agencies concerned with the 208 program are
being established. The remaining agencies will be com-
piling mailing lists as soon as they get underway.
Newsletters - 60 agencies at the present time have
newsletters which are carrying articles about the
208 program. Several of these newsletters will be
solely for 208, while the majority of the 208 agen-
cies will utilize the parent agency's newsletter.
The agencies that have not already prepared articles
for newsletters intend to do so.
Planning Brochures - 25 agencies currently have a
planning brochure describing the 208 program, and
another 77 agencies intend to publish one at a
future date.
30
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Briefings for the Public - Public meetings and hearings
will be used extensively throughout the 2-year process.
Each agency was required to hold a public hearing on the
designation of the area, and since that time, 70 agen-
cies have already held public meetings to discuss other
aspects of the program. 53 project directors or other
senior staff members have already given speeches before
a wide variety of public and private organizations. To
assist at these briefings, 19 agencies have developed
slide-show, movies, and multi-media presentations, and
an additional 92 agencies have indicated that they in-
tend to utilize some form of audio-visual aids in making
presentations about 208. 15 exhibits have been devel-
oped thus far, while an additional 61 agencies said that
they would be developing them in the future. A few agen-
cies have also recognized the advantage of having contact
with citizens in an informal atmosphere as well. For
example, one agency currently has brown bag lunches week-
ly to which any interested person is invited to come and
have lunch with the 208 staff.
Media^Relations - Certainly one of the primary mechanisms
by which the Level III public and others will be kept
abreast of the development of the 208 program will be
through the mass media (newspapers, radio and television).
87 of the agencies have already received some newspaper
coverage, 51 agencies have been covered on the radio, and
35 agencies have had exposure on television. One COG uses
its own weekly radio show; several television stations
have expressed interest in preparing documentaries on
local 208 programs.
t Documentation and Depositories - Presently, 18 agencies
have established 208 depositories for public use. 61
additional agencies said that they intended to establish
such a system in their areas.
Miscellaneous - Several areas are currently offering tours
of their regions for the public, while others have formed
speaker bureaus.
Public Input and Feedback
Some agencies indicated their intentions to create public input
and feedback systems. However, only a limited number of them were
underway at the time of the interviews. This can be understood in light
of program start-up delays being encountered across the country. De-
spite this fact, however, there was a noticeable lack of commitment
31
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directed toward planning and decision-making feedback when compared
with the information dissemination systems. Without including
effective mechanisms for obtaining feedback, some public participa-
tion efforts will be noticeably weak. This would result in diffi-
culties with plan implementation, as well as the loss of an oppor-
tunity to increase public awareness of water quality problems.
The techniques most often cited for obtaining public input
and feedback are:
committees
liaison with citizen groups
public meetings and hearings
surveys
seminars
t workshops
Initial feedback from the public has uncovered several issues
which will have to be dealt with by the 208 agencies. These are:
t the role of the citizen in decision-making process
t the extent to which economic interests will be considered
(I.e. agricultural interests, logging, etc.)
t the potential loss of local autonomy by local governments
the nature and extent of land use controls (i.e.
regulation v. private property rights)
the relationship between 208 and 201
who is going to pay for cleaning up existing nonpoint
sources
what is public acceptance of the plan
Problem Areas
A program of the nature and extent of 208 will not go unattacked
by all elements of society. 208 programs will be opposed in a number
32
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of areas* by ultra-conservative groups, home-rule advocates and
economic interests that feel threatened by the implications of the
program.
A large portion of the initial opposition can probably be
attributed to a lack of understanding about the program. This was
true in the case of several states who initially opposed the program.
Hopefully, many of the groups that are now in opposition to the pro-
gram will become aware that they can have a role in the process and
input into the final plan system. Other groups will undoubtedly
remain in opposition to the program, throwing up obstacles before
the 208 agency at every available opportunity.
In addition to vocal opposition to the 208 program, there are
a few major problems which will have to be dealt with. First, public
participation will be a very time-consuming activity. Second, travel-
ling distance will be a problem in some areas. In a few remote 208
areas, committee members might have to miss two working days in order
to attend a routine advisory committee meeting.
Finally, devising effective techniques for combatting public
apathy is sure to present problems for many of the 208 agencies.
This chapter has described many public participation techniques, but
their mere use does not insure effective public participation.
*The question of the role of environmental groups in 208 clanning was
not addressed, and did not arise in the discussion of potential opposi-
tion to 208 planning. Whether this is because there is not opposition
at this time by environmental groups or that it was not considered in
the context of the "opposition" question is not clear.
33
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BUDGET
Findings
Information on 208 agency budgets was difficult to obtain at
the time of interviews because most projects were in early stages
of planning at that time and because EPA had not stipulated or dis-
seminated guidance for standardized budget preparation. However,
several important issues did emerge during the course of the study:
EPA Regional guidance on funding adjustments resulted
1n indiscriminate cutbacks across agency budgets in
some areas. Such action was a source of conflict be-
tween several 208 agencies and their respective EPA
Regional offices.
Misinterpretation of EPA Headquarters directives on
funding eligibility sometimes resulted in bans on
particular work tasks, particularly modeling and moni-
toring.
On a national average, 208 agencies Intend to contract
out below the 75% ceiling suggested by EPA.
Should EPA need to perform a nationwide study of 208
budgets, it will have difficulty in doing so due to the
Inconsistent format of individual agency budgets.
Grant Awards
EPA was authorized by Congress to obligate a total of $250
million for 208 planning in FY 1974 and FY 1975. Headquarters
succeeded in committing$163 million within the given deadline, but
not always according to 208 agency requests. Table 17 indicates
the number of agencies with discrepancies between grant amount re-
quested and awarded.
35
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Table 1 7
DISCREPANCIES.BETWEEN REQUESTED AND AWARDED GRANT AMOUNTS
Number of Agencies Registering Discrepancies
IncreasesDecreases
Amount Over Request rrom Kequesi
$ 0- 1,999
2- 9,999
10- 49,999
50- 99,999
100-999,999
> 1 million
1
6
5
1
5
-
1
7
15
9
35
7
Total 18 74
Over 60% of funded agencies received less than their original
grant requests while 15% were awarded sums in excess of their requests.
Increases were generally small, clustering within a median range of
$10,000 to $50,000. Decreases were generally far more substantial,
with 35 agencies registering cutbacks of $100,000 to $900,000 and 7
agencies with reductions in excess of $1 million. 57 agencies received
the amount of grant requested.
Reasons for discrepancies between requested and awarded grants
seem to follow two general patterns. The first reflects a Regional
policy decision to fund a number of smaller planning efforts rather
than concentrate money in a few major programs. This can be seen as
an attempt on the part of the Regional office to achieve an equitable
distribution of funds. The second is that Regional staffs made adjust-
ments to original grant estimates after reviewing work plans and
budgets.
Three out of the ten Regions tended to resolve funding Issues
through general cutbacks across the board. In the majority of cases,
however, line items were either reduced or eliminated to comply with
regional policy stands. Among those line items most frequently af-
fected were water quality and land use data collection and municipal
facilities related work. Resolution of discrepancies reflect regional
office interpretations of EPA Headquarters directives.
36
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Most local agencies were able to adjust to funding changes
without difficulty. In a few isolated cases, however, reductions
generated feelings of animosity toward Regional EPA offices. This
occurred when local agencies felt EPA misled them to believe that
their original grant request would be forthcoming, only to find
that line items or grants were later cut back to a point where the
208 agencies felt they could no longer undertake an effective plan-
ning program.
More EPA sensitivity to local problems and/or a better expla-
nation of federal policy are needed to alleviate misunderstandings
in the future.
Work Plan Budget
Of the 136 agencies interviewed, 121 agencies had budgets
available for review and discussion. They were generally prepared
by 208 staff with EPA and/or state guidance. The 15 remaining
agencies did not have budgets available at the time of the profile
study; some were revising due to budget cuts. Half of these 15
were clustered in one region with the remainder spread out among
three other regions.
The available budget information was nationally inconsistent
in format due to the absence of standardized budgetary guidance
from EPA. In a few areas where states took it upon themselves to
circulate model budgets, there was a noticeable increase in budget
format consistency. Uniform budget format would make comparisons
among agencies and across regional lines much more feasible with-
out restricting the 208 agencies' choice of goals, etc. This may
be a valuable asset to EPA for overall program evaluation, both at
the beginning and end of 208 and similar planning programs in the
future.
A much more serious problem that arose in 208 budgets can be
traced back to the procedure by which a number of designated agen-
cies determined their grant requests.
In order to promote equitable national distribution of auth-
orized funds, EPA Headquarters established a grant guidance formula
based on the applicant agency's area population. This system was
intended to be used as an estimate of total national funding - not
as a formula for individual agency budgets. Some agencies, however,
misunderstood EPA program guidance and relied on the population
formula to determine their grant request, rather than making a con-
certed effort to identify program goals by task and dollar amounts.
This situation suggests that some agencies did not have a clear
37
-------
understanding of their local water quality goals at the' time of grant
award - a condition which has contributed to delays 1n program start-
ups and could possibly jeopardize chances of reaching highest program
goals.
Having recognized these possible trouble spots, EPA has Issued
a request for project control plans (PCP's) which will tie Itemized
workplans to specific tasks by dollar amounts. Regional offices
generally expressed the hope that PCP's will check most potential
problem situations before they get out of hand.
More detailed guidance from EPA Headquarters, stricter policy
enforcement by EPA Regional offices and an advance on grant awards
or a retroactive allotment of funds for budget preparation during
the grant application period would help eliminate these budgetary
problems in future EPA programs.
Almost all local agencies indicated that their budgets were
either scheduled for 1ntra-agency revision and/or possible modifica-
tion through PCP's. Among the reasons cited for the tentative or
incomplete status of budgets was first, insufficient time between
designation and grant award 1n which the 208 agencies were to prepare
detailed work plans itemized by tasks and cost. Another reason was
the uncertainty of designation approval which caused some agencies to
delay budget preparation until such time when they could be assured
of funding and a return on their investment of staff time and agency
funds. Funding the preparation of the budget was also a problem for
many 208's since this expense had to be covered with general agency
funds. Many agencies suffered from lack of available staff and the
absence of agency expertise in cost and price analysis. Finally, con-
fusion on funding eligibility of such line Hems as infiltration/
inflow analysis and water supply studies, delayed budget decisions
1n some agencies.
In an attempt to compare budgetary allotments across the nation
where standard budgetary categories do not exist, the study group
delineated eight broad categories into which agencies were asked to
translate their budgets. The categories were as follows:
Program management
Point and nonpolnt source monitoring and sampling
Waste load allocations modeling
Technical sub-plan formulation and review
Municipal facilities related functions
Analysis of alternative management systems
Land use
Public participation
38
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Interpretation of the categories listed was left to the discretion of
the interviewee. Results, therefore, are not consistent.
Only 46 of the 121 agencies with available budgets were able to
translate those budgets into the categories presented in the inter-
view schedule. Seven agencies were able to make a partial transition
by combining point and nonpoint source monitoring, modeling and tech-
nical sub-plan formulation and review into one aggregated item which
they termed "water quality analysis and review."
Regional and weighted national averages for the available data
are presented in Table Is.
Program management, monitoring, municipal facilities planning
and land use seemed to receive equal weight in our partial survey,
each averaging between 11 and 14% of total agency budgets.
Elsewhere in the interview schedule, agencies were asked for
budget information OP individual line items. These questions met
with a higher response rate. Results showed an average of 12% of
total budgets would be spent on management/institutional studies, 14%
on land use and 8% on public participation.
Once again, the reader must be warned that the agencies inter-
preted the budget categories for themselves. The information gathered,
therefore, may be inconsistent, with some extraneous expenditures hid-
den within major budget categories listed in the interview schedule.
With these caveats in mind, the discrepancies between these figures and
the standardized category tally can be explained by the broader sample
represented in the itemized tallies. A number of agencies who were
unable to use the standardized categories were able to quote figures on
these particular budget items. The range of variation between the two
sets of figures is minor, however, this suggests that either set dives
a reasonable estimate of average budget allocations.
A few regional and/or state policies are revealed through patterns
of budget allocations. The strongest patterns emerge in regards to
monitoring and modeling, where it appears that a number of regions took
Headquarter funding guidance too literally. Rather than temper efforts
in these areas, some regional EPA offices tended to disallow them al-
together.
In one area where Regional or state guidance was given on "reason-
able" budget allocations by item, a consistent dollar amount was set
aside for public participation programs. This later situation suggests
that 208 agencies were willing if not eager to follow reasonable,
locally sensitive guidance, particularly in non-controversial areas.
The same sentiment was expressed with regard to items requiring famil-
iarity with cost and price analysis.
39
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Table 18
SUMMARY TABLE: SAMPLE BUDGET ALLOCATIONS
(Regional Averages)
o
Number of agencies with
budget
Program management
Monitoring
Modeling
Sub-plan formulation/review
[Water Quality]
Management analysis/
selection
Municipal facilities
Land use
Public participation
1
15
13
-
15
-
37
11
15
13
11
2
1
10
8
24
15
47
18
-
3
2
3
1
5
10
15
17
42
19
10
19
5
4
8
13
14
17
15
46
17
11
10
6
R E
5
6
13
15
7
24
46
11
12
6
9
G I 0
6
1
9
9
5
37
51
20
2
11
7
N
7
5
16
-
6
-
41
13
10
10
9
8
8
17
-
5
-
38
12
9
19
5
9
1
20
8
-
23
31
29
-
7
7
"TO
9
11
8
3
34
45
15
9
7
7
Weighted
National
Average
13
12.5
8
22.5
[42]
14
11
11
8
Regional and National Averages are average percentages of individual agency budgets.
Water Quality is an aggregated category.
-------
The study team's general impression on budgets was that products
would have been much more satisfactory, in terms of status and content,
if better guidance and more funds had been available to the 208 agencies
early in the grant application period. Well-formulated budgets at the
time of grant award would have eliminated start-up delays and perhaps
contributed to a better understanding of goals and scope of work at the
project's initial stages.
Contracts
A 1975 Headquarters directive suggested a 75% total budget ceil-
ing on contract work to be carried on outside the 208 agencies. This
celling excludes services contracted between or among 208 agencies. At
the time of interviews, an intended national contract average of 58%
was identified by 208 agencies - a figure well within the suggested
limit set by EPA. There were, however, a significant number of agen-
cies with contracts in excess of this mark.
Only 1/3 of the 136 agencies interviewed had detailed contract
lists. Most of these were still subject to change contingent upon
possible workplan revisions. 10% of the 136 agencies had not begun out-
lining a contract list. Reasons given for the preliminary status of
contract lists include the status of workplans, and difficulty in cost/
price analysis. In at least one case, there was a sensitive political
situation wherein member jurisdictions perceived a threat to their self-
determination in the face of a strengthened regional planning agency.
Only 2% of intended contracts had been let at the time of inter-
views. These contracts generally involved minor program tasks with a
scattering of contracts for workplan revisions. Regional EPA offices
were generally delaying finalization of contract agreements until PCP's
were completed; agencies were clear on their goals and the scope of
work before they begin spending their money.
In most instances, decisions on whether to do work in-house or
by contracts were made by the 208 agencies themselves. Outcomes gener-
ally reflect technical expertise within the agency itself. Some guid-
ance on contracting was usually provided by EPA or the state, especially
in the case of new or small agencies with little or no past experience
in water quality planning and analysis. Guidance was also provided in
instances where agencies had difficulty in cost and price analysis on
contract arrangements. In some cases, states encouraged joint contracts
among 208 agencies with common problems.
15 agencies indicated that they would be contracting out
over 75% of their total budget; with 2 agencies planning for more than
90% contract work. Size did not seem to be a controlling factor in
contract decisions. Two agencies with similar large grant awards, for
example, chose directly opposite approaches. One committed 90% of its
budget to contract work; the other only 10% of its total.
41
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The decision on whether to contract out appeared to depend on
the 208 agency's expertise In the type of work 1t chose to undertake
rather than its size. Faced with highly technical, water-related
tasks, local 208's tended to go outside their agency since experienced
personnel were difficult to find and equipment was often prohibitively
expensive to acquire. Land use on the other hand was usually left In-
house since most regional planning agencies, COG's, etc., have had
prior experience in this field.
Contract Activities
53 agencies indicated that they would contract for facilities-
related work. No differentiation was made between direct municipal
facilities planning and 201/208 coordinating activities. The general
trend, however, was to contract out for technical/engineering Infor-
mation and then coordinate policy planning in-house.
58 agencies indicated that they would issue contracts for
monitoring and sampling. Although many regional planning agencies
and COG's do water resource planning, water quality planning is
traditionally within the realm of state agencies or consultants. For
many 208's, therefore, contracting out for monitoring and sampling
was the most reasonable approach since staffing and equipping 208's
would be both expensive and would not necessarily insure more accurate
results.
50 agencies indicated they would contract for modeling-related
work, with state water quality boards and the USGS cited as the most
likely choices. Preliminary budget information indicated that only
a small amount of individual agency budgets would be spent on modeling
in most cases. This suggests that most efforts are being concentrated
on the use of existing models - generally from the state with some use
of university systems. There were a few cases where strong disagree-
ment between local 208 agencies and their respective EPA regional
offices arose when EPA refused to fund extensive modeling efforts.
Some of these remained unresolved at the time of interviews.
22 agencies indicated that they would contract for at least
part of their public participation program. Options mentioned ranged
from major contracts (11) which entailed total program management to
small contracts for individual tasks such as public opinion surveys.
Although some agencies had not yet decided on the nature of their
public participation program, the general trend was to undertake as
much public participation work as possible in-house. This decision
was prompted by the agencies' familiarity with their member juris-
dictions.
42 agencies intended to contract for land use work. The
nature of contracts ranged from major areawide plan formulation to
supplementary data collection, graphics and aerial photography.
Many 208 agencies indicated their intention to contact local or county
governments since land use data was already available there or 1n the
process of being collected.
42
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70 agencies were seeking outside assistance in management and/or
institutional literature searches, plan development and analysis. In
several states, 208 agencies were either directly entering joint con-
tracts for such services or were contributing to the state management
and coordination funds to carry out such projects.
At least 18 agencies noted that they intended to hire lead con-
tractors who would have responsibility for subcontracting elements of
major program tasks. This is not to imply that all 18 were relinquish-
ing total program management to a consultant.
Some did issue substantial lead contracts which represented a
transfer of program management, particularly in technical areas, to a
contractor. In a few cases, lead contracts were issued for workplan
and budget revisions, a most influential task-affecting total program
scope and direction. However, most lead contracts involved only 3-4
subcontracts. In such cases, agencies simply found it more convenient
to rely on a major contractor rather than worry about complicated and
cumbersome minor contract arrangements.
Type of Contracts
Among over 300 tentative contracts mentioned, a total of 137
were intended for engineering type firms. Of these, 79 were specifi-
cally slated for architectural and engineering companies and primarily
involved facilities planning, storm water and combined sewer studies;
22 were intended for engineer/planning firms and 36 were labeled
environmental engineering contracts. The latter usually involved
broader water quality studies.
Planning firms were only mentioned in 37 contract proposals.
These were primarily related to population projections and land use.
Management consultants were noted in reference to 62 intended
contracts. Most of these involved management/institutional/financial
studies rather than program management. The latter contracts were
usually delegated to engineering firms since so much of 208 planning
involves highly technical work.
Seventeen individual lawyers and/or legal firms were cited as
were 11 public opinion-type contractors. About 29 undefined water
quality consultants - usually biologists, testing labs or environ-
mental research groups - were also listed as potential consultants or
contractors, including 6 contracts to universities.
A total of 82 contracts were intended for government agencies
or jurisdictions. Twenty state contracts - primarily for water qual-
ity monitoring and analyses, facility studies and management arrange-
ments - were to be arranged with water quality offices, labs, etc.
Nineteen contractual arrangements were outlined for 201/208 coordina-
tion, assistance, land use data and sub-plan formulation and capital
improvements planning. Thirty county contracts were also noted
43
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primarily In the West and South. These contracts were geared toward
tasks similar to those intended for local agencies, with the notable
exception of a higher preponderance of legal/management/Institutional
work. An explanation may come from the fact that many of these same
areas were considering regional management solutions, a subject area
in which county governments may have the most knowledge and under-
standing. Finally, at least 13 federal agency contracts may be
issued under 208 with the U.S.6.S., Soil Conservation Service, the
Army Corps of Engineers, and the Department of Agriculture Forestry
Service cited for water quality-related tasks.
In general, it appears that 208 agencies are being prudent 1n
their contract decisions. They recognize the need to strengthen
agency staffs in those areas which are essential for program conti-
nuity and plan updates. Yet with the forewarning of EPA regional
staff, they have generally recognized the advantage of limiting con-
tract work so as to retain control over program direction and work
scope. Outside consultants may be less interested in seeing a
program through, less able to view the program as an integrated
whole and less committed to plan implementation. This same situa-
tion exists with agencies that have hired staff for only 2 years.
For these reasons, EPA should continue to counsel 208's against
inordinate reliance on contractors, except in those cases where
contracting is more reliable and economical. In the latter case,
agencies must be particularly aware of that fine line at which
they are apt to lose control of the program and jeopardize its
success.
44
-------
TIMING AND FINANCIAL PROBLEMS
Findings
Most agencies thought that two years was too short a time to
adequately accomplish the tasks in their work plan. The most common
problems mentioned were:
Due to start-up time and the need to prepare a Project
Control Program, 3-6 months is lost at the beginning
of the 24-month planning period.
Evaluation and approval at all levels takes an addi-
tional 3-6 months at the end of the period.
When water quality or land use data must be newly
developed, agencies will have difficulty completing
other tasks that depend on that information.
There is confusion as to what outputs are due after
2 years and what tasks can be carried over into on-
going planning.
Few agencies have seriously begun to consider manage-
ment and implementation.
When management was seen to require establishment of
a new authority, lengthy delays to obtain legislative
authority were anticipated.
Furthermore, most agencies expressed serious doubts that they
could continue 208 planning on a totally financially self-sustaining
basis. Recurring comments were:
The local governments do not see a way to raise
enough money on their own to sustain 208 planning.
The local governments do not consider themselves bound
by their resolutions-of-intent to pay for 208 planning
after the grant runs out.
45
-------
t Federal and State financial assistance is essential
if 208 is to continue beyond two years.
Timing and the Two-Year Planning Period
All programs were asked "Is the two-year planning period
realistic?" The answer was a resounding "No." Programs were then
given a list of 30 work task elements and asked which ones were not
realistic within the two years, and how much more time would be
needed. The list and results are presented in Table 19. One addi-
tional response was added to the list because it continually arose.
Called the "Synergistic Effect", it refers to the situation that
any one work task taken alone could be completed, but not all of
therrTtaken together within the given time period. The total is
somewhat low given it was tabulated from isolated comments, and not
a direct question.
The most common complaint was that programs do not really
have two years. Over 2/3 of the programs mentioned that "start up"
has seriously cut into their two-year period, on the average of
about six months. This included such problems as hiring staff and
administrative organization as well as getting contracts approved.
All programs noted that the need for a detailed work plan and the
Project Control Program (PCP) takes a minimum of 3 months from the
24-month period. It is useful to note that some of those agencies
designated in FY '74 are no further ahead in this regard than the
FY '75 designations. Many programs appear resentful of the need to
prepare the PCP because they feel they already have an adequate work-
plan that cost them considerable time and money to develop at their
own expense.
Another common complaint about timing involves the building
block nature of the program. Data analysis depends on data acquisi-
tion. Developing point and nonpoint source control plans depends on
knowing the extent and sources of problems. Developing institutional
and management plans depends on defining water quality plans. Thus,
if one step does not meet schedule, all the others also fall behind.
Over 35% of the agencies answered that data acquisition and analysis
would be a problem, either because it is not available or 1t is not
useful. Because most of the grant awards were made at the end of the
fiscal year, agencies have lost badly needed data for summer low flow
conditions and this data cannot be available again for 12 months.
Such agencies therefore will have special problems in meeting the two-
year deadline.
13% of the programs anticipated problems in meeting interim
output deadlines both because data was not available and because of
the lengthy process involved in seeking public approval.
46
-------
Table 19
NUMBER OF AGENCIES ANTICIPATING PROBLEMS
DURING THE 2-YEAR PLANNING PERIOD
REGION
TASK
Analysis of water quality factors
Review of appropriate Institutions
Data acquisition
Data analysis
Review alternative controls
Alternative management agency
Selection of appropriate Institutions
Selection of appropriate management plans
Development of point source sub-plans
Development of nonpolnt source sub-plans
Plan evaluation
Plan review and adoption:
Local
Advisory corrrolttee
Certification by state
EPA approval
Municipal facilities
Identification of urban stormwater
controls
Construction priorities
Staffing
Administrative
Regulatory program
Identification of construction, operation,
and maintenance agencies
Control of residual wastes
Implementation of schedule
Selection of management agency
Synergistlc effects
1
4
-
3
2
1
2
3
3
-
2
4
7
2
2
1
1
1
-
2
3
4
1
3
4
3
-
2
2
-
9
5
-
-
-
-
-
1
1
2
-
2
2
-
1
-
4
3
2
1
1
2
1
2
3 4
2 5
-
3 10
2 3
1 7
5
2
1 10
1
8
15
2 13
1 5
6
5
2
1 5
4
5 8
3 7
5
5
-
8
1 12
1
5
3
3
11
6
4
6
3
5
2
8
7
13
5
3
2
3
5
1
1
5
4
3
3
3
4
3
6
_
-
3
2
1
-
1
2
1
2
-
3
3
3
2
-
-
1
5
2
-
-
1
1
1
2
7
-
-
1
-
1
-
-
-
-
1
1
2
1
2
-
-
-
-
2
1
1
-
-
2
1
-
8
3
1
6
3
2
2
3
2
1
6
3
5
1
3
1
1
1
2
10
6
1
-
1
2
2
-
9 10
1 3
-
1 3
1 4
2
2
4
- , 5
1
4
1 3
1 7
1
1 l
2
2
3
1
1 5
1 5
2
1
2
-
2
-
Total
23
4
50
28
19
17
16
28
6
32
35
55
19
23
15
9
17
9
43
36
19
11
11
22
27
8
Total
58 41 24 150 116
36
16 6B
65
582
47
-------
It is generally unclear what planning must be completed within
the initial two years and what planning elements can take place after
the two years. Most agencies believe that all outputs and plans will
be due at the end of two years and believe they will have considerable
difficulty achieving that goal. The local agencies seek EPA guidance
on minimum acceptable plans and on the content of the continuing plan-
ning process.
There are serious barriers to meeting the two-year deadline for
completion and approval of most plans even if the planning and analy-
sis proceed according to schedule. 55 agencies felt that local review
and approval of the plan would jeopardize meeting the 24-month dead-
line.
The development of a satisfactory management system will take
much time, thought and discussion. Ideally, the 208 planning process
should be producing interim management outputs throughout the two-
year planning period prior to the final selection of a system. How-
ever, most 208 programs are not generating these outputs yet. Few
agencies had seriously begun to consider management and implementation
when the interviews were conducted, although most interviewees said
they would begin management alternative analysis within the first year
of their planning effort. It should be noted that 10 of the 23 agen-
cies saying they would begin management analysis at day one were in
one particular region where the (fegional EPA office stressed the im-
portance of addressing this problem early in the process. 15 others
said they did not know when management analysis would start. Related
to this is the fact that agencies did not yet know whether this work
would be done in-house or by consultants.
Agencies were asked if the legal powers required of a manage-
ment agency could be acquired prior to the two-year deadline. Table
20 presents the results.
Table 20
RESPONSE ON ABILITY TO ATTAIN LEGAL POWERS
FOR MANAGEMENT AGENCY PRIOR TO 2-YEAR DEADLINE
Yes
No
Don't know
No answer
Total
1
1
12
-
4
17
2
4
3
-
4
11
3
1
3
-
8
12
R !
4
4
14
3
5
26
I G I
b
n
-
12
2
25
0 N
6 7
3 2
2 -
1 3
2 -
8 5
8 9 TO
9 1 7
2 - 1
-
10 - 2
21 1 10
Total
MB^BUMHI-
43
37
19
37
136
48
-------
44% of the agencies responding answered yes~; 39% answered no;
and 17% did not know. Acquisition of legal authority was felt to
depend on the controversiality of the plan and whether management
would be primarily by the local governments, in which case little
additional authority would be necessary. If the management system
foreseen would include any kind of institutional rearrangement, and
if, therefore, special state legislation would have to be passed,
delays of up to two years were predicted.
Most agencies felt they would be well into year two before a
management plan was devised and that at least two sessions of their
state legislatures would be required to secure legislation or consti-
tutional amendments. Many legislatures meet only once every two
years, and many were characterized as conservative by the 208 agen-
cies. There did not seem to be any distinction between agencies that
were COG's or RPA's and those that were other types of planning bod-
ies, such as county planning departments or economic development dis-
tricts. Even the one state planning agency designated felt that the
necessary legislation could not be obtained in two years.
Financially Self-Sustaining Planning Process
Section 208 provides funding for a two-year planning
period. It authorizes the Administrator to make grants to desig-
nated agencies for the costs of developing and maintaining an on-
going areawide waste treatment management planning process. How-
ever, since no funds have been allocated for the continuing process
as of this time, 208 agencies must find a way to totally finance
their own programs after the two-year period expires.
When the agencies were asked if they expected problems in
establishing a financially self-sustaining planning process, 92
responded affirmatively, and only 27 negatively. There were no mean-
ingful distinctions among the different types of 208 agencies in how
this question was answered.
The designated agencies were then asked which of the following
methods they were expected to use to fund a continuing 208 program:
contributions from participating agencies on local governments, gener-
al revenue fund allocations, user charges and general obligation
bonds.
Most did not expect success in obtaining increased funding
contributions from participating agencies or governmental units suffi-
cient to support continued planning. The other three methods suggested
were seen as only slightly more feasible for financing 208 planning.
Resolutions of intent were mentioned by several agencies as
signs of commitment on the part of their governments to an ongoing plan-
ning process. The locals do not view the resolutions as binding them
49
-------
to pay for 208 planning after the Initial two-year period expires.
In light of the budget crisis cited by many designated agencies, and
the fact that 107 of the 136 agencies Interviewed said they would
not have participated 1n 208 had there been only 75* funding, finan-
cially self-sustaining 208 planning may be totally unrealistic.
Federal contributions are felt by the designated agencies to
be absolutely essential if 208 1s to be the ongoing process it was
Intended to be. Some financial assistance from the states is hoped
for and at least one state has already agreed to provide it. If
financial aid 1s not forthcoming, the 208 agencies will be forced to
drastically lower their water quality goals or drop the program
altogether.
50
-------
DESIGNATION AND GRANT APPLICATION
Findings
The data gathered on the designation and grant application
processes provides an insight into some of the problems forthcoming
in the planning process. Additionally, it highlights problems to
avoid with next year's applications. Briefly stated:
Agencies have been either unwilling or unable to
produce detailed workplans before grant award.
Allocating a portion of the grant for workplan
development would greatly expedite the presently
overloaded planning process.
The requirement of obtaining resolutions of in-
tent has been administered inconsistently by the
Federal Regions. Many local governments are un-
willing to bind themselves to plan implementation
at this time.
Why Enter 208 Planning?
The desire to enter 208 planning can be attributed to several
factors. Local agencies were understandably enticed by a program
offering 100% Federal funding. Most saw this as an opportunity to
undertake planning efforts which they could not otherwise afford.
This was clear from the fact that the majority (79%) would not have
applied for the grant on the basis of a 75% Federal share.
An equally important factor was the desire to prevent the
state from undertaking such planning. Most localities, seeing this
as a possible alternative, chose to keep the planning locally based.
An additional incentive was the belief that future Federal grants,
in particular 201, would hinge on 208 planning.
The Designation Process
145 of 149 agencies were designated by governors. Four agencies
were self-designated. These are Charleston, West Virginia; Washington
Metro; Lakes Region, New Hampshire; and Salern-Rockingham, New Hampshire.
Self-designation has not proven an impediment thus far. There is a wide
range in total time taken for designation. The results are presented
in Table XXIV.
51
-------
Table 21
TOTAL TIME OF DESIGNATION PROCESS*
R E G ION
Time
< 1
1- 4
4- 8
9-12
12-15
7-15
No
month
months
months
months
months
months
answer
1
-
1
8
4
3
1
-
2 3
1
8 3
3
1 1
1 -
1 1
3
4
1
7
6
3
6
2
1
b
-
7
10
2
1
5
-
6 7 8 $
- - - -
4 - 8 -
2191
122-
1 -
2 -
1 - 1 -
TO
-
1
1
3
3
2
-
Total
2
39
41
19
15
14
6
Total 17 11 12 26 25 8 5 21 1 10 136
*In some cases could not be separated from grant application process.
Two agencies completed the process 1n less than one month, while 29
agencies took over one year. The majority of agencies (80) were desig-
nated in the range of 2 to 8 months. Although this is a reasonable
amount of time 1n the majority of cases, 1t 1s in part due to adminis-
trative expediency at the end of FY 1975. The 21 % which took over one
year were for the most part those who applied for designation early in
the process. They were generally held up either by lack of guidance at
the local level or by Indecision at the Federal level.
Preparation of the Designation Package and Grant Application
The designation materials were prepared by the agency staff 1n
120 cases. The remaining 16 were prepared either with or solely by
consultants. This breakdown is generally the same for the grant appli-
cation process. 101 agencies prepared the grant application in-house. Ten
were written by consultants, and twenty-five were developed jointly.
Problems in the Designation and Grant Application Processes
Designation and grant application requirements were often ful-
filled simultaneously, or in overlapping time periods. The following
figures represent difficulties encountered during both procedures.
Results are presented in Table 22.
52
-------
on
co
Table 22
AGENCIES WITH MAJOR PROBLEMS IN THE DESIGNATION AND GRANT APPLICATION PROCESS
R E G I
PROBLEM
Lack of local agency desiring to do 208 planning
Lack of interest or cooperation from the State
Lack of interest or cooperation from the
Regional office
Dispute over appropriate boundaries for 208 area
Absence of legal authority to do all or part of
208 planning
Delays in eliciting other local agencies to
cooperate with 208 planning
Delays in organizing interstate cooperation
(where applicable)
Delays in obtaining resolutions-of-intent from
local governments
Lack of technical knowledge about local water
quality problems
Lack of staff
Lack of funds
Confusion regarding the designation requirements
and/or estimated cost of the 208 study
Public disinterest in or hostility toward 208
planning
Others?
1
-
3
-
5
1
2
4
10
3
6
11
9
4
-
2
3
5
1
1
1
1
-
1
2
3
2
5
2
-
3 4
2
3 4
2 1
1 10
1
7
4
2 11
1 7
1 12
4 10
2 14
2 6
1 1
5
-
9
2
5
2
6
3
7
3
7
7
6
3
-
0 N
6 7
1 1
1 2
3
3 -
-
1 2
1 1
2 1
2
2 1
1 3
1 4
2
-
8 9
4 -
4 1
1 -
3 -
4 -
5 -
-
10 -
7 -
8 -
8 -
5 1
1
2 1
10
-
4
-
7
1
3
-
3
4
7
7
5
2
_
Total
11
36
10
35
10
27
13
47
29
47
53
52
22
5
*Total is greater than 136 due to multiple responses.
-------
The major problems resulted from the framework of the processes
themselves in addition to difficulties which general y accompany the
inception of a large Federal grant program. Diff culties resulting
from the framework are the development of a detailed workpan before
grant award and the legal aspects of the resolutions of intent.
The cost of developing a detailed work program was apparent
with TOO agencies,reporting difficulties resulting from lack of staff
or lack of funds.' Over one-half of these agencies (52) said they
were confused about requirements and/or estimated cost of the 208
study. The result of this has been a request for revisions of work
plans throughout the country.
It is understandable, even with adequate funds to prepare the
application, that an agency would be wary of a large investment with
no guarantee of a grant. At least 17 agencies applied for FY 1975.
funds and were not awarded grants.
An alternative policy of letting out a %of the grant after
designation (or retroactive payment) for thorough workplan develop-
ment would eliminate much duplication and wasted effort. This year's
experience has enabled EPA to^clear up the guidelines/requirements of
designation and grant application. These procedural improvements
should insure the planning process begins on receipt grant award.
Resolutions of Intent
The requirement of resolutions of intent from jurisdictions 1n
208 areas was met in varying degrees across the nation. The original
requirement of "all participating jurisdictions" was loosened to
"workable" for planning and implementation; a consensus on the defini-
tion did not emerge. In some cases, the resolution requirement was
filled by a letter from the governor guaranteeing the use of the police
power to implement the 208 plan.
29 agencies plan to acquire a total of 80 additional resolutions
not obtained prior to grant award. This figure veils a number of agen-
cies who feel that the grant award completes designation process and
therefore they need not pursue additional resolutions.
1
This figure may be slightly inflated due to dual responses.
54
-------
There was a significant difference in the administration of
this requirement by the Federal regions. Some Regions remained
stringent from 90 to 100% requirements. Interpretations include all
jurisdictions with population over 5,000, the major jurisdictions
and "anyone who would give them." In some cases, no resolutions were
obtained prior to designation, and had yet to be pursued at the time
of the interview. These cases were covered by letters from
the governor. Given the need for local approval of a 208 plan, this
approach seems to circumvent the purpose of obtaining resolutions.
EPA's attempt to get assurances that the local jurisdictions
are aware of 208 planning, and that local circumstances are favorable
to 208 planning and implementation of 2081 often was not fulfilled by
the requirement for resolutions. A common local reaction to requests
for resolutions was fear of giving blanket approval to a plan yet to
be made - a reasonable deduction from the resolutions' use of the word
implementation. Refusal in other cases was the reflection of local
political jealousies and problems that in the end had no direct bear-
ing on the planning and implementation of the 208 program. It is also
somewhat inequitable that some agencies were made to go to great
lengths to obtain the majority of resolutions, while in a few instances
the issue of resolutions was simply passed over.
Cost of Grant Application
The range of costs incurred by 208 planning agencies in prepa-
ration of grant application reflects the problems resulting from re-
quiring considerable expenditure prior to grant award. The results
are presented in Table 23. The cost2 ranged from less than $500 to
$75,000. The cost to the majority (56) of agencies was between
$1,000 and $10,000, although a significant number (34) spent over
$10,000 but less than $50,000. Once again, the difference of invest-
ment is apparent, and would be remedied by a % of the grant allocation
for workplan development. Aside from costs, however, 90 agencies
replied that grant applications requirements were reasonable in light
of their local situations.
1
AM-4, April 3, 1975
2
Designation costs could not be separated in some cases.
55
-------
Table 23
COST OF GRANT APPLICATIONS
Cost
<$ 500
500- 999
1,000- 4,999
5,000- 9,999
10,000-14,999
15,000-24,999
25,000-49,999
50,000-74,999
> 75,000
No answer
1 2
1 -
9 1
4 -
2 2
1 2
1
1
4
3
1
4
1
1
1
1
3
R E
4
2
12
5
1
-
6
G I
5
1
2
4
4
4
6
1
-
3
0 N
6 7
1
2
1 -
1 1
1
-
6 -
9 id
1 -
2 - 1
4 - 5
3 - 2
1 1 1
1
_
10 -
Total
1
5
28
28
14
10
12
4
2
32
Total
17 11 12 26 25
8
21
1 10 136
NOTE:These often would not be separated from designation preparation
costs.
It is interesting to note how some of the grant applications were
paid for*. In 8 regions, HUD 701 assumed at least part of the cost of
grant applications. In other cases, cost was assumed by private founda-
tions, states, consultants, or individuals devoting their own time. In
many cases, the funds were from contributing local jurisdictions.
Assistance and Coordination
In the designation process, 36 agencies reported a lack of inter-
est and/or cooperation from the state; while only ten had difficulties
with the Regional office. In the grant application process, 24 agencies
reported difficulties with the EPA Regions. Often this was the result
of disputes over level of funding. Only 26 agencies had difficulties
with the state. One problem was continual requests for revision of
documentsoften the fault of unclear guidance on allowable tasks; for
example, infiltration and inflow analysis and modeling. Another was
simply the slow process of establishing effective administrative rela-
tionships on the part of both the States and EPA regional. Apparently,
some Regions were inconsistent iii designation due dates which added
to the problems of designated agencies. Aside from administrative prob-
lems, actual assistance in the preparation of the applications was forth-
coming from both the states and the regions. This varied from minimal
assistance to actual development of applications. 113 agencies reported
assistance from the Federal Regions, while 81 agencies received help from
their states.
*This was not an interview question, but was continually referred to.
therefore, cannot be developed as a national statistic.
56
It,
-------
COORDINATION
Findings
Looking at the different planning programs and mechanisms of
coordination provides a brief overview of existing and potential
coordination between the 208 agency and other institutions or plan-
ning programs. Several key Issues surfaced:
The local 208 agencies need clear guidance on the
substance and timing of 208/201 coordination.
The role of state planning and the mechanisms for
state/local coordination need to. be clarified.
Those 208 agencies located within multi-functional
planning agencies have the greatest potential for
programmatic coordination.
Coordination Between 208 and 303(e) Basin Planning
The State 303(e) water management plans are an essential input
to the 208 planning process:
Water quality goals and standards
Definitions of critical water quality conditions
Waste load allocations
These inputs to the 208 planning process are to provide a sound base
upon which the 208 programs will be built, yet as of March, 1975, only
50 of the 500 303(e) plans were complete. It was apparent, however,
that those 208 agencies in areas where 303 plans were of poor quality,
behind schedule or non-existent, were at a disadvantage.
For example, some states viewed 208 planning as an alternative
method for developing the 303(e) information, and were waiting for
outputs from the 208 process for their 303(e) plans.
1
Complete information on the 303(e) Plans could not be obtained as
in many cases the agencies had not obtained or analyzed them.
Answers reflect general discussions on the status of 303(e) Plans
and could not be statistically tabulated.
57
-------
Another example of difficulties obtaining state water quality
information occurred in areas where 303(e) plans were non-existent
and agencies had to rely on 3C plans where available. To what extent
information generated under the 3C program could be substituted for
the 303(e) inputs was a question agencies in the State had only begun
to consider. Determining what information can be used and what new
information must be generated will slow down the 208 planning process.
Coordination Between 208 and the NPDES
Approximately 80% of the agencies interviewed had made at least
preliminary contact with the State NPDES agency. 53% of the agencies
had actually obtained lists but only 30% of the agencies had actually
reviewed the permits to see if they meet their 208 planning needs.
Specific plans for coordination between the 208 and 402 programs
were difficult to obtain, in part because of the variety of ways by
which the 402 program is administered. In some cases, 208 agencies
could deal directly with their respective states to obtain permit
information. In other instances, permits are administered by EPA
through the states. In such cases, agencies were uncertain whom to
contact. This is critical because the National Pollutant Discharge
Elimination System permit program will provide an essential tool for
the implementation of the 208 plans. Permits issued are to be in con-
cert with approved 208 plans.
Coordination Between 208 and 201 Municipal Facilities Planning
Agencies have indicated their intention to allocate an average
of 14 to 15% of their total budgets to carry on municipal facilities
planning and review to the best of their ability. Approximately 95%
of the agencies said that 201 municipal facilities planning and/or
construction was ongoing in their 208 area. Just under 80% stated
that they felt existing 201 plans were in concert with their antici-
pated 208 planning effort, but this finding must be interpreted with
caution. The response often appeared to be based on incomplete
knowledge of existing 201 planning efforts.
Most agencies interviewed were not sure of the programmatic and
timing relation between 208 and 201 municipal facilities planning and,
consequently were hesitant to make specific plans for coordination
until more guidance was available. Two observations seem to charac-
terize the situation of the locals. First, the original draft guide-
line did not detail the programmatic relationship between 208 and 201.
Secondly, more recent guidance cautioned the 208 agencies not to slow'
down the 201 construction process. Most agencies recognize the need
to avoid delaying the 201 process but more specific guidance on estab-
lishing coordination between the programs appears warranted.
58
-------
Coordination With Other Environmental Programs and Other Areawide
planning Programs
Various environmental programs in regional planning agencies
are provided with an excellent opportunity for coordination. Most
interviewed felt that the ease of in-house coordination would be
mutually beneficial to their ongoing programs.
29 of the 208 agencies interviewed stated that they either were
air quality maintenance areas or overlapped with them to some extent.
62 agencies have either completed or are currently working on solid
waste plans as providing them with background and experience to enter
the 208 planning process.
Coordination Between 208 Agency and the State
Nearly all the agencies said they had made contact with their
state's water quality office, yet only half of them indicated that
some sort of coordination plans were established. These were most
often in the form of a state coordinator or participation in the tech-
nical advisory committee. Some state personnel were to be supplied
to 208 agencies through coordination and technical assistance con-
tracts. Between 4 and 8% of the planning grant was available for this
type of contracting with the state. The content of the contract was
usually described in a general nature but ranged from extensive tech-
nical services, involving more contract money, to providing data format
specifications to standardize the input to the state planning program.
Means of Coordination with Other Governmental and Other Planning
Programs
Most agencies did not have well developed mechanisms for coordi-
nation with other agencies and related programs. At the time of the
interview, most established coordination focused around information
exchange. Coordination involving more specific work task elements was
usually in the planning stage.
The committee structure was the most commonly mentioned means
for achieving coordination. It serves a vital function by providing a
form of umbrella coordination, allowing direct communication among
representatives of many groups. Representatives of related programs
and interest groups hold seats on 208 advisory committees and in turn
208 staff occasionally hold seats on advisory committees of other pro-
grams. A parent agency often provided its 208 agency with a skeleton
of a citizen advisory or technical advisory committee, or at least
provided the channels for assembling them. Sometimes regional sub-
committees were formed in the larger 208 areas where long, difficult
drives might discourage regular attendance.
59
-------
Frequently mentioned mechanisms through which information was
exchanged with the 208 agencies are inter-program staff meetings,
newsletter exchanges, A-95 Clearinghouse review and comment proce-
dures, and accessibility of the in-house planning expertise in a
multiple function parent agency. The availability of a common data
base or common population and land use projections from other plan-
ning organizations was mentioned as a good opportunity for planning
coordination.
Contracts for specific tasks were often mentioned as providing
coordination between the contracting parties. For example, the Soil
Conservation Service has several contracts to provide 208 agencies
with soil analysis and will thereby become involved with the planning
process. In cases where studies are done over an area larger than the
208 area (e.g. aerial photography), the 208 agency contracts for only
that portion of the study relevant to the planning area. A benefit
seen is the potential for coordination with areas outside the 208 area.
Some 208 agencies are contracting with municipal facilities management
agencies and engineering firms in the facilities business to aid coor-
dination between the 208 and 201 programs.
Contracting was often said to be part of the coordination with
other 208 areas. 208 agencies in at least two states are joining with
the other 208 agencies 1n the state to hire a single consultant for
specific work tasks. In another instance, several 208 agencies have
contracts with a single 208 agency to provide them all with results of
a study on a common problem.
The following table is interesting because it shows the broad
range of programs and agencies that must coordinate 1n some manner
with the 208 program. All 208 agencies were asked to complete a table
listing agencies that had been contacted and methods of coordination.
Figures are understated for two reasons. First, the methods column
contained no cues, thus the answers were all volunteered and often
general. Second, no consistent distinction was made between methods
in existence and anticipated methods. Some respondents chose not to
answer 1f they were either uncertain or if no formal means of coordi-
nation had been established.
Although the figures are incomplete, the table is useful because
it shows both the large number of programs that must be coordinated
and it shows the relative frequency of methods of coordinating that
will be used.
60
-------
Table 24
NUMBER OF 208 AGENCIES WHICH MENTIONED THE METHODS OF COORDINATION
USED IN RELATION TO THE ORGANIZATIONS LISTED
T H
en
ORGANIZATION
Air Quality
Solid Waste
Transportation
Coastal Zone Management
Corps of Engineers
U.S. Forest Service
Soil Conservation Service
U.S. Geological Survey
Housing, Urban Development
National Park Service
EPA
Other Federal
State
Local
Regional
Contacted
but not
Specified
30
27
29
15
21
16
16
3
1
-
1
15
10
9
1
Cormri ttee
23
29
21
13
26
51
47
8
-
8
6
14
62
43
-
Contract Contract
from 208 to 208
2
4 1
2
3 1
4
2
2
5
1
-
1
3
3
4
_
Merros ,
Information Joint Agreement, Staff
Exchange Studies Correspondence Sharing
7
8
7
2
5
8
9
3
-
1
1
3
7
2
-
1
4
2
2
3
2
1
2
-
-
1
6
2
1
-
4
4
5
1
9
9
6
4
-
-
-
3
6
n
-
8
10
13
3
4
10
5
3
T
i
-
1
4
5
5
-
In-
A-95 House
8
- 21
1 21
6
1
1
2
\
-
_
.
2
3 1
1
-
Note: Methods are not mutually exclusive.
-------
EVALUATION AND GUIDANCE
Findings
The major findings on evaluation and guidance are listed below.
t There is a serious delivery problem with EPA guidance
to date. A significant number of agencies never re-
ceived handbooks while a fair proportion received
them too late to be useful.
Technical guidance needs are similar throughout the
country. The top four were consistently: nonpoint
source analysis, monitoring (point and nonpoint),
urban storm water, and combined sewer analysis.
The most requested management/legal/institutional
seminar is state-enabling legislation outlining alter-
natives for a successful management agency. Ideally,
this would be given by the states with proper guidance
from EPA.
Section 208 Draft Guidelines
The Guidelines were the only consistently available guidance for
those agencies seeking a 208 designation. They were considered useful
by 101 agencies. The value of the Guidelines was primarily for back-
ground information on the 208 process (educational), rather than effec-
tive program guidance.
Designation and Work Plan Handbooks
The need for timely guidance is evidenced by the variety of
problems previously discussed in both the designation and grant appli-
cation processes. It appears that the problem rests with the delivery
as opposed to the substance of such guidance. Thirteen agencies never
received the Designation Handbook while seven never received the Work
Plan Handbook.
63
-------
61 agencies received the Designation Handbook too late for it
to be useful in the process. 45 agencies received the Work Plan
Handbook equally lateJ This reflects a serious delivery problem
occurring at certain Federal Regions, as well as a wasted effort in
developing guidance for the majority of agencies able to make headway
on their own. Some agencies received the handbooks through informal
channels. Examples include "given by consultants", "copying another
agency's copy", and "picking it up on a trip to Washington, D.C."
An improved regional distribution system or a policy of direct mailings
should prove a useful step toward improving the delivery of guidance.
Workshops2
The EPA workshops were received with mixed reactions. The
figures available indicate the number of workshops attended by each
agency.
Table 25
WORKSHOP ATTENDANCE BY AGENCY
Number of Conferences
Number of Agencies Attended
19 0
52 1
43 2
9 3
11 N/A
2 Don't know
T3F
Unfortunately, the majority found the conferences only marginally
useful. Some stated that the information was not up-to-date or general-
ly not helpful. Others were further along in the process than the sub-
ject discussed. Reasons for not attending were that they were unaware
of workshops, or that the workshops were too far away. An indirect
1 ' ~~~
Does not include FY '74 agencies, as handbooks were not published.
2
All meetings on 208 will be discussed together, as most agencies
could not distinguish sponsors, or particular subject matter.
Therefore, the most that could be obtained was general impressions.
64
-------
benefit of the conferences which frequently emerged was the informal
contact with other 208 agencies. Exchange of information on that
level proved very beneficial.
OBERS "Series E"
As the use of OBERS was a directive from EPA Headquarters, it
will be discussed under the guidance section. 101 agencies reported
that they were not using OBERS projections, although frequently it
was consulted as a base for individualized projections. Persons
interviewed at thirteen agencies were not familiar with OBERS Pro-
jections.
The major reason stated for not using OBERS was that the agen-
cies believe they were too low. The political sensitivity to low
projections can be understood in light of potential future grants and
allocation among jurisdictions who have received a grant. Addition-
ally, areas subject to high seasonal influxes (tourism) did not feel
that element received adequate treatment in OBERS. 208 areas often
did not coincide with the boundaries of OBERS projections. As the
county is the smallest jurisdictional unit of OBERS, partial counties
in 208 areas of which there are 111 could not be properly estimated.
Nor do OBERS account for the secondary effects in energy, recreation,
mining, and other areas of expected population increases.
Certain states are developing and in some cases requiring the
use of their own population projections. The State of Utah has been
exempt from using OBERS. Some agencies are not willing to accept
state projections either.
Technical Guidance
The need for technical guidance was a major concern of the 208
agencies. EPA was most often chosen to provide this guidance. The
prioritized needs for such seminars was amazingly consistent through-
out the country. The following list ranks by significant number of
requests those seminars which are most wanted by those interviewed.
The most prevalent need is in the area of nonpoint source guidance.
Given regional variations, combined sewer analysis, point and non-
point source monitoring, and urban storm water seminars are consist-
ently a top priority throughout the country. Regional prioritized
requests with a significant number of mentions are listed below.
65
-------
Prioritized Regional Requests for Technical Workshops
Region 1
Nonpoint source analysis
Monitoring (point and nonpoint)
Urban storm water
Combined sewer analysis
Region 2
Nonpoint source analysis
Monitoring (point and nonpoint)
Urban storm water
Region 3
Urban storm water
Nonpoint source analysis
Monitoring (point and nonpoint)
Region 4
Urban storm water analysis
Nonpoint source analysis
Monitoring (point and nonpoint)
Region 5
Nonpoint source analysis/agriculture
Urban storm water
Combined sewer analysis
Monitoring 'point and nonpoint)
Simplified stream modeling
Region 6
Urban storm water analysis
Nonpoint source analysis
Region 7
Combined sewer analysis
Nonpoint source analysis
Monitoring (point and
nonpoint)
Region 8
Nonpoint source analysis
Monitoring (point and
nonpoint)
Urban storm water
Region 9
Nonpoint source
Region 10
Nonpoint source analysis
Urban storm water
Combined sewer analysis
Monitoring (point and
nonpoint)
66
-------
In the area of nonpolnt sources guidance, requests also show
the regional variation. These figures should be used as general
indicators, as often, those interviewed were not the technical water
quality staff. Additionally, 1t was somewhat early in the planning
process to have Identified major needs. Requests are listed below:
agriculture
construction
erosion
feedlots
mining
petroleum related
runoff modelings
sedimentation
septic tank analysis
Seminars on nonpoint sources should be carefully directed to remain
useful to the particularized need of 208 areas.
Management/Legal/Institutional Seminars
There are 110 agencies which expressed interest 1n attending
management/legal and institutional seminars. Only 10 agencies re-
ported they are not in need of guidance 1n this area, while four
indicated they were not sure they wanted to attend seminars.
The greatest demand for seminars across the country was for
state-specific legislative backgrounds. This would include authority
for institutional rearrangement, such as in the case of a new manage-
ment agency, as well as nonpoint source controls (land use). Most
Interviewed felt these would have to be given by the states, but
could be sponsored by and given direction from EPA.
The following list is based on regional summaries, with an
attempt to pull phrases from the interviews. It is useful not only
to pinpoint essential seminars, but also as a general indicator of
level of competence. For example, the fact that certain agencies
were not able to respond with specific needs usually Indicated a lack
of knowledge or understanding of the potential magnitude of 208. In
the same vein, the listing of the responses provides background as
well as direction in this area. Therefore, the following list merely
categorizes by subject those seminars which were most consistently
desired or were particularly necessary.
67
-------
The legal implications for interstate arrangements
Legal responsibilities in the consolidation of sewer
districtsoutstanding bonds and user fees
Legal implications of groundwater management
Land use enforcement (controls)
Water rights and law
Management
Management alternatives for small rural areas
Institutional arrangements for storm water control
Alternative management agency structures and systems
Nonpoint Source
Evaluation of nonpoint source controls
t Nonstructural management of nonpoint sources
Financial
Financing a management agency structure
Methods for funding the continuing planning process
Grant management
Political
Political aspects of 208how to work with political
conflicts
Political aspects of creating a management agency
Procedural
Evaluating technical and management proposals
Evaluating existing management agencies
Techniques in conflict resolution
Growth management techniques
68
-------
General 208
t Elaboration of the 201208303 relationship
Long range Federal involvement in 208
Coordination between the State and EPA
Other Suggestions
A variety of ideas emerged on how to expedite the 208 program.
One interviewee pointed out that it is essential to gear these semi-
nars to 208's agencies in the various stages of the planning process.
A major weakness of seminars to date is that they have been geared to
one point in time in the planning process.
An additional aid would be the preparation of a series of semi-
nars or packages geared to the local elected officials. The need for
education at this level was continually stressed, and would be a valu-
able aid to facilitate plan adoption.
In order to prevent the expensive and time-consuming effort
required in the development of individual 208 films, it was suggested
that the present 208 film from headquarters be modified and distrib-
uted. The study team suggests the development of a series of films
highlighting different aspects of the 208 process. This would range
from education on the 208 process itself to elements such as nonpoint
sources. It would also be necessary to highlight elements specific
to different parts of the country in order to remain relevant.
Another problem to date has been the lack of a central and com-
plete source of technical information. It was suggested that a hot
line providing expert guidance in tune with EPA policy would greatly
expedite the 208 process. The central 208 library being developed by
EPA Headquarters would certainly serve as such a base. Its success
would necessarily depend on the communications network set up to dis-
seminate this information. Although this may not be the best approach,
the need for strong technical guidance is paramount at this time.
There is a definite interest in the case study approach. Sug-
gestions include:
1) Nonpoint source research by other 208 agencies
2) A history of approaches in other areas
3) Case studies on constraints during plan implementation
It is felt that this approach would keep guidance less theoret-
ical , and more in line with the problems actually experienced in 208
planning. This could be easily handled by EPA Headquarters in the
"Newsletter" to ensure national coverage.
69
-------
APPENDIX A
STATISTICAL DATA
The following tables provide data to supplement statistics in
the text. 136 of a possible 149 interviews were completed. Of the 13
agencies not interviewed, 9 were in Region IX. In some cases, however,
information was unavailable, or agencies were unable to answer the
questions as asked. Thus, the total responses to each question does
not always add up to 136. Whenever possible, available documents were
studied to try to answer some of the profile questions when no inter-
view was done; thus, in some cases the number will be 149-- the total
number of 208 agencies. For some questions, agencies were asked to check
several items when more than one answer applied. In these cases, total
responses will add to more than 136.
Whenever a dash (-) is used in a table, it means that question
was asked and the response was negative, or that it was not a factor.
Whenever a blank appears, it means that there was no response. This is
due to any of three factors, the net result being no information. These
factors are:
1) The interviewee did not have the background to answer
the question.
2) The question was not asked due to lack of time.
3) The information was not available at that time.
The number of agencies for which there was no information for
that particular question is totaled by region in the "no answer" column.
A-l
-------
Number of 208
Agencies
Number of
Interviews
TABLE I
208 AGENCIES DESIGNATED AND INTERVIEWED
REGION
T
8
17 11 12 28 25
22 10
17 11 12 26 25 8 5 21
TO"
10
10
Tota"
149
136
TABLE II
LEAD INTERVIEW
REGION
1
208 Director 15
Parent Agency
Director
Application 2
Writer
Acting Director
Environmental
Director or
208 Supervisor
2 3 4
8 8 20
2
. w
2
342
5
15
7
_
1
_
6
3
1
4
-
_
789
5 15 1
_
3
1
2
10
5
1
1
3
_
. Total
95
11
10
7
11
Tota;
17 11 12 26 25
21
10
136
A-2
-------
TABLE III
OTHERS INTERVIEWED
REGION
Parent Agency Director
Engineers
Public Participation
Coordinator
Application Writer
Environmental Director or
208's Supervisor
Planning Director
Other Planners
State Water Quality
Land Use
Assistant Director
Acting Director
Consultant
Citizen Group
Indian Representative
1
3
4
1
2
-
-
-
-
-
-
-
-
-
_
23456789
31-1132-
6
131-3-
_______
3
________
1 - 6 - - - 5 1
2 - 4 - - 1 -
4
10 - - 1
1
1 - 3
1
1
10 Total
2 16
10
9
1 3
3
1 1
1 14
3 10
4
11
1
4
1
1
-------
TABLE IV
POPULATION OF 203 AREAS
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
1970
Census
6,004,220
16,671,827
10,424,972
11,437,670
26,597,479
6,721,865
3,578,296
3,359,544
7.453,980
3,153,366
Most
Recent
Estimates
(based on
diff. yrs.)
6,436,600
17,059,242
10,758,461
12,817,820
29,552,067
7,151,068
3,612,338
3,927,835
8,432,731
3,389,600
Projections*
(to 1985, 1990
or 1995)
6,534,200*
18,726,482
11,605,578
18,744,780*
37,530,416
9,275,428
4,784,687
4,089,028*
10,950,749
4,762,933
Total
95,403,219
103,137,762
127,004,281*
*Means not all programs answered
A-4
-------
en
TABLE V
COUNTIES IN 208 AREAS TOTAL AND PARTIAL
REGION
Number of Counties
Totally included
Partially included
NUMBER OF
SMSA's Relation to 208 Area
Totally included
Partially included*
1 2
Square Miles 7406 9883
1 2
27 24
10 2
3 4
66 51
29
TABLE VI
SMSA'S IN 208 AREAS TOTAL
1 2
7 8
7 3
SQUARE
3 4
12,915 51,572
R
3 4
9 18
10
TABLE VII
MILES OF 208
R E G I 0
5
73,218 19,
5678
97 15 17 69
19 21 4 1
AND PARTIAL
E G I 0 N
5678
23 8 1 9
15 2 2 -
AREAS
N
6789
765 9669 151,911 29,299
9 10 Total
6 13 385
17 8 111
9 10 Total
5 2 90
5 5 49
10 Total
18,103 390,562
*Th1s number 1s overstated due to the double counting resulting from one SMSA being
In more than one 208 area.
-------
3>
I
TABLE VIII
OTHER PLANNING FUNCTIONS PERFORMED BY SAME AGENCY
REGION
Planning Function
DOT - Transportation
CZM - Coastal Zone
HUD 701
AQMA - Air Quality
Solid Waste
Areawide Transportation
Corps of Engineers
Forest Service
Soil Conservation Service
A-95 Review
Other Federal
Other State
Other Local
1
15
9
17
3
16
17
2
-
12
16
17
16
17
2
7
6
10
3
4
6
1
-
-
9
-
-
-
3
6
3
9
3
5
4
-
-
-
9
-
-
-
4
21
9
26
4
12
25
4
5
1
20
8
5
1
5
18
5
25
4
13
17
6
5
5
6
11
11
5
6
1
-
8
-
3
7
1
-
1
-
5
5
_
7
3
-
4
2
4
3
3
-
-
3
5
1
4
8 9
11
-
13
8
2
5
1
3
-
13
8
13
11
16
6
-
7
2
3
8
3
1
3
2
10
10
10
Total
88
32
119
29
62
92
21
14
22
84
126
61
48
-------
TABLE IX
NUMBER OF PLANNING FUNCTIONS PERFORMED BY AGENCY
REGION
Function
Only 208
1 Other
2-5 Other
More than 5
No Answer
1 2
1
-
1
17 9
-
3
3
-
8
-
1
4
-
-
14
9
3
567
_
2
7
16 8 5
.
8 9
8
-
3
9
1 1
10
-
-
3
7
-
Total
12
2
36
80
6
Total
17 11 12 26 25
21
10
136
Total
TABLE X
AMOUNT OF WATER RELATED EXPERIENCE
REGION
Experience
Extensive
Some
None
No Answer
1
3
13
1
-
2
5
2
4
3
6
-
5
1
4
4
18
1
3
5
1
17
7
-
6
1
6
-
1
7
4
1
-
-
8 9
1
7
10
3 1
10
3
5
2
-
Total
28
69
30
9
17 11 12 26 25 8
21
10
136
A-7
-------
I
00
Staffing
Full and Part-time
professionals presently
employed
Number non-professionals
now on board (full and
part-time)
Anticipated total
professionals
Anticipated total
non-professi ona1s
Borrowed - part-time
or temporary
TABLE XI
AGENCY STAFFING
REGION
1 2
46 45
7
112 96
34
3
23
8
32
12
4
49
19
69
45
5
93
34
244
60
6
19
9
20
5
7
11
4
26
11
8 9
26 2
12
24
6
10
11
4
30
11
Total
325
97
653
184
78
32 62 41 413 22
53 64
69
834
-------
TABLE XII
DISCIPLINES OF DIRECTORS
REGION
Disciplines
Planner
Sanitary Engineer
Public Administration
Biologist
Geologist
Water Planner
Environmental Planner
Public Relations
Civil Engineer
City Manager
Geographer
Legal
Economist
Chemical Engineer
1 2
9 1
3 6
3 1
1
1
1
1
-
-
-
-
-
-
-
34 5 6 7 8 9
5 11 11 - 44
4 4 - - - 3
331-4
1
------
11-8
1 2
1 - - - - 1
344--
1
1
1
1
1
10
1
3
3
-
-
2
1
-
-
-
-
-
-
-
Total
46
23
18
2
1
14
5
2
11
1
1
1
1
1
-------
TABLE XIII
DIRECTORS HIRED IN 208 AGENCIES
No. of Directors Hired
No. of Directors to be
Hired
No Answer
Total
LENGTH OF STAFF
Was Staff Hired for
More than 2 Years?
Yes
No
No Answer
Total
12345
17 9 4 21 24
2851
-----
17 11 12 26 25
TABLE XIV
EMPLOYMENT DURING AND
12345
3 1 - 12 11
14 9 12 5 4
1 - 9 10
17 11 12 26 25
REGION
6
5
3
-
8
BEYOND
REGION
6
-
4
4
8
7 8 9 10
4916
18-4
4
5 21 1 10
PLANNING PERIOD
7 8 9 10
11-5
39-5
1 11 1 -
5 21 1 10
Total
100
32
4
136
Total
34
65
37
136
A-10
-------
TABLE XV
PHYSICAL LAY-OUT OF 208 AGENCY OFFICES
AGENCY
In One Office
Split Up in Different
Offices
No Answer
Total
LOCATION OF
With Parent Agency
Separate From
Parent Agency
No Answer
Total
1234
17 8 12 24
3-2
_
17 11 12 26
TABLE XVI
REGION
56789
25 7 4 17 1
........
114-
25 8 5 21 1
10 Total
9 124
1 6
6
10 136
208 AGENCIES IN RELATION TO PARENT AGENCY
1234
15 11 9 14
2-38
4
17 11 12 26
REGION
56789
25 8 4 14 1
7
1
25 8 5 21 1
10 Total
7 108
3 23
5
10 136
A-ll
-------
TABLE XVII
ANTICIPATED 208 MANAGEMENT AGENCIES
New Agency
208 Planning Agency
Single Management Agency
Several Management with
Regional Authority
Several Management with
Local Autonomy
No Answer
Will a constitutional amendment
be necessary to create a new
agency?
Yes
No
No Answer
REGION
1 2 3
lent agency:
4
1
:y 111
i
1 4 4
i
855
7 1 1
TABLE
MANAGEMENT SYSTEMS REQUIRING
(ndment
a DPW
1 2 3
1
12 - 1
5 11 10
4
9
-
4
5
7
8
XVIII
567
2
_
- - -
1132
10 1
253
8
*
3
1
4
2
8
5
9 10 Total
1 19
1 1 4
11
6 38
4 48
9 - 41
A CONSTITUTIONAL AMENDMENT
4
2
6
18
REGION
567
2 1
13 - 1
10 7 4
8
-
1
20
9 10 Total
1 - 7
34
10 95
-------
TABLE XIX
REGULATORY METHODS DESIRED IN A MANAGEMENT AGENCY*
REGIONS
METHODS
Metering Waste
Water Flow
Differential Tax
Assessment
Zoning
Building, Housing
1 2
4
7
7
7
3
9
7
7
6
4
14
4
3
9
5
16
8
9
9
6
6
5
7
8
7
1
1
1
8
13
3
12
15
9
-
-
1
1
10
5
3
6
8
Total
68
38
53
63
Codes & Subdivision
Regulations
P.U.D. and Density 43877-6- 5 40
Bonuses
Transfer of 2-3 -3-2 --10
Development Rights
Discharge Permits 2 21213 8 115 1 3 57
Don't Know 17 2 3 8 2 6 2 - 1 41
TOTAL 17 33 36 56 70 46 10 68 3 31 370
*Answers will not total 136 due to multiple responses to question.
A-13
-------
TABLE XX
TECHNIQUES FOR PUBLIC PARTICIPATION
Publ ic Meeti ngs
Newsletters
Planning Brochure
Speeches
TV Coverage
Newspaper Coverage
Radio Coverage
SI ide Shows
Exhibits
Depositories
in-use
intended
i n-use
intended
in-use
intended
in-use
intended
in-use
intended
in-use
intended
in-use
intended
in-use
intended
in-use
intended
in-use
intended
1
9
17
3
15
5
16
8
17
2
15
12
17
5
14
12
9
_
14
2
6
7
2
7
2
4
6
8
4
6
5
9
4
8
1
7
.
6
2
7
3
4
4
5
3
2
5
4
4
3
3
5
4
4
4
1
3
.
3
1
2
4
10
21
14
17
2
8
9
19
9
18
17
19
10
15
2
15
1
14
2
8
Region
5
16
13
19
11
9
14
12
16
7
16
17
14
12
16
5
17
6
13
8
15
6
4
4
3
5
.
6
1
5
1
4
1
6
_
2
7
2
.
2
7
2
5
5
_
4
1
5
2
3
2
5
2
4
1
4
4
.
3
8
8
11
4
7
2
5
6
6
2
9
9
10
6
9
2
8
2
6
2
6
9
1
3
1
.
2
1
2
1
1
2
1
1
1
1
1
1
10
9
7
7
6
3
6
8
6
5
6
9
8
7
7
6
8
6
3
3
3
Total
70
92
60
77
25
70
53
88
35
81
87
93
51
80
19
92
15
61
18
61
-------
TABLE XXI
PERCENTAGE OF GRANT AWARD TO BE CONTRACTED OUT
REGION
Contractors
Architectural and
Engineering
Environmental
Engi neeri ng/Planni ng
Planning
Legal
Management Program
Insti tuti onal/management/
financial
Public participation
Water Quality Research
and Analysis
University (non-profit)
Total
1
48%
2 3
55%
4 5
59% 55%
TABLE XXII
TYPE OF CONTRACTORS: FOR 208
1
28
10
8
9
2
2
5
5
1
2
72
^^* x
2 3
4
9
-
8
3
4
7
1
10
1
47
REG
4 5
6 8
10
5
4
-
3
14
2
11
2
54 11
6
62%
PLANNING
I 0 N
6
2
2
-
-
2
-
3
-
2
11
7
57%
7
6
1
2
2
2
1
2
-
3
_
19
8 9
67%
8 9
18
3
2
10
5
1
6
2
-
1
48
10
56%
10
7
1
5
4
3
1
9
1
2
1
34
Total
58%
National
Average
Total
79
36
22
37
17
12
46
11
29
7
296
-------
I
cn
Federal Agencies
State Agencies
Counties
Local Agencies
Total
Designated by Governor
Designated by Self
Total
TABLE XXIII
NUMBER OF INTENDED GOVERNMENT CONTRACTS
REGION
1
6
5
-
3
14
234
1
3 1
3
_ _
7 1
5
-
-
5
8
13
6 7
1
1
1
6
9
8 9
1
6
13
1
21
10
4
4
8
1
17
Total
13
20
30
19
82
TABLE XXIV
1
15
2
17
METHOD OF DESIGNATION
234
10 10 28
2
10 12 28
OF 208
R E G I
5
25
-
25
AGENCIES
0 N
6 7
9 5
-
9 5
8 9
22 10
-
22 10
10
10
-
10
Total
144
4
148
-------
TABLE XXV
PREPARATION OF GRANT APPLICATION
REGION
PREPARATION BY:
Staff
Consultant
Joint
Other
Don't Know
Total
1
8
2
7
-
-
17
2
10
1
-
-
-
11
3
7
-
2
3
-
12
GRANT
4 5
21 19
1 1
4 5
-
-
26 25
TABLE
6
6
-
1
-
1
8
7
3
-
2
-
-
5
8 9 10
13 - 10
5 -
2 1
1
_
21 1 10
Total
97
10
24
4
1
136
XXVI
AGENCY PERCEPTION OF
APPLICATION REQUIREMENTS
REGION
Reasonable
Not Reasonable
Don't Know
Total
1
15
2
-
17
2
3
4
4
11
3
4
5
3
12
4 5
22 18
4 2
- 5
26 25
6
8
-
-
8
7
4
1
-
5
8 9 10
15 -
4 -
2 1 10
21 1 10
Total
89
22
25
136
A-17
-------
TABLE XXVII
AGENCIES THAT DID NOT RECEIVE HANDBOOKS
REGIONS
Designation Handbook: 1
Did Not Receive Handbook -
No answer
Work Plan Handbook
Did Not Receive Handbook -
No answer
2345678910 Total
- - - 1 4 1 6 - - 12
- 7 - 1 8
- - - 1 - 1 4 - - 6
- 7 - 1 - - - - 10 18
TABLE XXVI 1 1
AGENCIES THAT RECEIVED HANDBOOKS TOO LATE TO BE USEFUL
1 2
Designation Handbook 11 3
Work Plan Handbook 7 3
AGENCIES
1 2
Designation Handbook 11
Work Plan Handbook 10 -
REGIONS
3456789 10
- 14 13 8 - 6 1 5
- 10 13 4 1 5 1 1
TABLE XXIX
THAT DID NOT USE HANDBOOKS
REGIONS
3456789 10
- 14 8 4 1 5 1 4
- 10 11 1 2 3 1 2
Total
61
45
Total
48
40
A-18
-------
TABLE. XXX
AGENCIES THAT WERE AWARE OF THE 208 BULLETIN
DURING DESIGNATION PROCESS
REGION
1 2
Yes 15 4
No 24
No answer - 3
Total 17 11
Useful
Not Useful
Insufficient Detail
Too Detailed
Sufficient Detail
Sensitive to Local
Situation
Insensitive to
Local Situation
Neutral
No answer
345678
5 12 8 2 33
2 12 16 5 2 16
5211-2
12 26 25 8 5 21
TABLE XXXI
AGENCY EVALUATION OF HANDBOOKS
208 Draft Designation
Guidelines Handbook
101 62
4 1
24 6
12 1
22 14
20 " 14
20 11
10 4
6 10
9 10 Total
6 58
4 63
1 - 15
1 10 136
Work Plan
Handbook
66
7
16
4
15
16
12
3
7
A-19
-------
APPENDIX B
PLANNING AGENCY DIRECTORY
As of July 1, 1975 the following one hundred and forty nine (149) areas
and aqency designations have been approved by the Administrator,
Environmental Protection Agency
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Region I
Portland, Me.
Southern Maine
Northern Maine
6-25-74
(770,000)
7-26-74
(488,000)
8-5-74
(207,900)
Lewiston-Auburn, Me. 12-19-74
(339,100)
Augusta-Cobbosse,
Maine
Berkshire County
Pittsfield, Mass.
Cape Cod, Mass.
12-19-74
(380,000)
2-19-75
(374,000)
2-27-75
(350,000)
Greater Portland
Council of Governments
169A Ocean Street
Portland, Maine 04106
Southern Waine Regional
Planning Commission
York County Courthouse
Alfred, Maine 04002
Northern Maine Regional
Planning Commission
McElwaine House
2 Maine Street
Caribou, Maine 04736
Androscoggin Valley
Regional Planning Comm.
34 Court Street
Auburn, Maine 04210
Southern Kennebec Regional
Planning Commission
154 State Street
Augusta, Maine 04330
Berkshire County Regional
Planning Commission
10 Fern"Street
Pittsfield, Mass. 01201
Cape Cod Planning &
Economic Development Comm.
First District Courthouse
Barnstable, Mass. 02630
Mr. Frederick Sheenan,
(207) 799-8523
Mr. Brian Chernack
(207) 324-2952
Mr. James Barresi
(207) 498-87J6
Mr. Craig Ten Broeck
(207) 784-0151
Mr. John Forster
(207) 622-7146
Mr. Gaylord Burke
(413) 442-1521
Dr. William Stanburg
(617) 362-2511
Ext 477
B-l
-------
Region and Area
Designation Date
fGrant Amount) Agency
Contact
Martha's Vineyard, 2-27-75
Massachusetts (216,000)
Lowell, Mass.
Brockton, Mass.
Boston, Mass.
Salem, N.H.
3-4-75
(456,840)
3-6-75
(650,000)
4-18-75
(2,292,000)
4-1-75
(270,300)
Worcester, Mass. 4-11-75
(1,035,000)
Fitchburg, Mass. 4-17-75
(377,000)
Southeastern, Mass. 5-20-75
(1,132,000)
Lakes Region, N.H. 6-3-75
(533,000)
Martha's Vineyard Land &
Water Commission
Box 1447
Oak Bluffs, Mass. 02557
Northern Middlesex
Area Commission
144 Merrimac Street
Lowell, Mass. 01852
Old Colony Planning Council
232 Main Street
Brockton, Mass. 02401
Metropolitan Area
Planning Council
44 School Street
Boston, Mass. 02108
Southern-Rock inahajn
Regional Planning
District Commission
19 Main Street
Salem, NH 03709
Central Massachusetts
Regional Planning Comm.
70 Elm Street
Worcester, Mass. 01609
Montachusett Reaional
Planning Commission
150 Main Street
Fitchburg, Mass. 01420
Southeastern Regional
Planning and Economic
Development District
7 Barnadas Road
Marion, Mass 02738
Lakes Region Planning
Commission
Humiston Building
Box 302
Meredith, New Hampshire
03253
Bill Wiocox
(617) 693-3453
Mr. Michael diGiano
(617) 454-8021
Mr. Robert MacMahan
(617) 583-1833
Mr. John Harrington
'617) 523-2454
Mr. John Gilmore
(603) 893-8233
Mr. James M. Arnold
(617) 756-7717
Mr. David Weir
(617) 345-7376
Mr. Alex Zaleski
(617) 748-2100
Mr. David G. Scott
(603) 279-6550
B-2
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Providence, RI 6-23-75
(2,300,000)
Region II
Puerto Rico
4-17-75
(1,396,000)
Nassau-Suffolk 4-24-75
Counties, Long (5,207,000)
Island, N.Y.
Mercer Co., N.J. 5-12-75
(974,145)
Camden, N.J.
5-14-75
(1,264,800)
.-Wlesex Co., N.J.5-14-75
(1,420,000)
Westchester, N.Y. 6-3-75
(1,080,000)
.e-Niagara, N.Y. 6-3-75
(1,825,000)
Rhode Island Statewide
Planning Program
265 Melrose Street
Providence, RI 02907
Commission for the Devel-
opment and Administration of
of Areawide Waste Treatment
Plans for the North Metro-
politan Area.-Puerto Rico
Environmental Quality Board
P.O. Box 11488
Santurce, Puerto Rico 00910
Nassau-Suffolk Regional
Planning Board
Planning Building
Suffolk County Center
Veterans Memorial Highway
Hauppauge, Long Island, NY
Delaware Valley Regional
Planning Commission
Perm Towers Building
1819 John F. Kennedy Blvd.
Philadelphia, Penn. 19103
Delaware Valley Regional
Planning Commission
Penn Towers Building
1819 John F. Kennedy Blvd.
Philadelphia, Penn. 19103
Board of Chosen Freeholders
of Middlesex County
Kennedy Square
40 Livingston Avenue
New Brunswick, N.J. 08901
Westchester County Government
Environmental Coordinating
Agency-Environmental Advisory
Council
c/o Westchester County
Planning Department
910 County Office Building
White Plains, New York 10601
Erie-Niagara Regional
Planning Board
2085 Baseline Road
Grand Island, N.Y. 14072
Patrick J. Fingliss
(401) 277-2656
Mr. Carlos M. Jiemenez
Barber
(809) 725-5140
Dr. Lee E. Koppleman
(516) 979-2922
11787
Mr. John Coscia
(215) 567-3000
Mr. John Coscia
(215) 567-3000
Mr. Douglas S. Powell
(201) 246-6062
Mr. Peter Q. Eschweiler,
(914) 682-2498
Mr. Leo J. Nowak, Jr.
(716) 773-7611
B-3
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Ocean Co. N.J.
6-3-75
(503,200)
New York City, N.Y. 6-5-75
(8,111,533)
Southern Tier Central 6-5-75
(Corning) N.Y. (808,000)
Central New York G-5-75
(Syracuse) N.Y. (1,271,000)
Ocean County Board of
Chosen Freeholders
Court House Square
Toms River, N.J. 08753
New York City Environ-
mental Protection
Administration
Municipal Bldg., Rm 2455
New York, New York 10007
Southern Tier Central
Regional Planning and
Development Board
53 1/2 Bridge Street
Corning, New York 14830
Central New York Regional
Planning and Development
Board
321 East Water Street
Syracuse, N.Y. 13202
Region III
New Castle County, 6-12-74
Delaware (1,200,000)
Hampton Roads, Va. 6-25-74
(1,600,000)
Roanoke, Va.
Richmond, Va.
6-25-74
(843,050)
6-25-74
(1,300,000)
New Castle County
Areawide Waste Treatment
Management Planning Agency
1 Peddler's Village
Newark, Delaware 19711
Hampton Roads Water
Quality Agency
Pembroke 3 Office Building
Suite 131
Virginia Beach, Va. 23462
5th Planning District
Commission
P.O. Box 2527
145 West Campbell Ave.
Roanoke, Va. 24010
Crater Planning District
Commission
2825 Crater Road South
P.O. Box 1808
Petersburg, VA 23803
Mr. Thomas A. Thomas
(201) 244-2121
Mr. Norman Nash
(212) 556-3641
Mr. William D. Hess
(607) 962-5092
Mr. Robert C. Morris
(315) 422-8276
Mrs. Merna Hurd
(302) 731-7670
Mr. Paul Fisher
(804) 499-5531
Mr. F. Ray Bailey
(703) 343-4417
Mr. Jerry Simmonoff
(804) 861-1666
B-4
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Fredericksburg, Va.
Sussex County, Del.
Southwest Virginia
Washington, D.C.
Baltimore, MD
Charlestown, WV
Pittsburgh, PA
Philadelphia, PA
1-7-75 Rappahannock Area Develop-
(350,000) ment Commission (RADCO)
913 Charles Street
P.O. Box 863
Fredericksburg, Va. 22401
1-30-75 Sussex County Council
(633,089) P.O. Box 507
Georgetown, Del. 19947
1-30-75 Cumberland Plateau-
(649,920) Lenowisco 208 Planning
Agency-Southwest Virginia
U.S. Highway 58-421W
Duffield, Va. 24244
3-27-75 Metropolitan Washington
(3,550,000) Council of Governments
1225 Connecticut Ave., NW
Washington, D.C. 20036
6-6-75 Regional Planning Council
(1,187,527) 701 St. Paul Street
Baltimore, Maryland 21202
6-6-75 B-C-K-P Regional Inter-
(801,000) Governmental Council
410 Kanawha Blvd. East
Charlestown, W.V. 25301
6-23-75 Southwestern Penn. Regional
(1,511,432) Planning Commission
564 Forbes Avenue
Pittsburgh, PA 15219
.fi-18-75 Delaware Valley R.P.C.
(3,852,032) Penn Towers Bldg.
1819 J.F. Kennedy Blvd.
Philadelphia, PA 19103
Mr. Ronald Rebman
(703) 373-2690
Mr. Roger Truitt
(302) 856-7701 x216
Mr. Paul E. Trammel
(703) 431-2206
Mr. Charles Spooner
(202) 223-6800
Mr. Tom Smith
(301) 383- 5840
Mr. Mike Russel
(304) 348-7190
Mr. James DeAanelis
(412) 391-4120
Mr. John Cpscia
(215) 567-3000
Region IV
Raleigh-Durham,
North Carolina
4-9-74
(947,500)
Triangle J. Council of
Governments
P.O. Box 12276
Research Triangle Park,
North Carolina 27709
Mr. Frank Chamberlain
(919) 549-0551
B-5
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Memphis, Tenn.
Knoxville, Tenn.
Chattanooga, Tenn.
Nashville, Tenn.
6-25-74 Miss-Tenn-Ark COG
(1,187,000) Memphis Delta Development
District Commission
125 North Main Street
Room 518
Memphis, Tenn. 38103
6-28-74 Knoxville-Knox County
(670,000) Metro Planning Commission
301 Locust Street
Knoxville, Tenn. 37902
10-10-74 Chattanooga Area Regional
(949,000) Council of Governments
413 James Building
735 Broad Street
Chattanooga, Tenn. 37402
11-11-74 Mid-Cumberland Council of
(868,700) Gov'ts/Development District
Suite 801
226 Capitol Boulevard
Nashville, Tenn. 37219
Mr. Hugh Teaford
(901) 362-1883
Birmingham, Ala. 3-25-75
(1,250,000)
Birmingham Regional
Planning Commission
21 Office Plaza South
2112 llth Ave., South
Birmingham, Ala. 35205
Tuscaloosa, Ala.
Columbia, S.C.
Louisville, Ky.
3-25-75 West Alabama Planning &
(601,000) Development Council
P.O. Box 86
Tuscaloosa, Ala. 35401
3-25-75 Central Midland Regional
(736,250) Planning Council
Dutch Plaza, Suite 55
800 Dutch Square Blvd.
Columbia, S.C. 29210
4-2-75 Kentuckiana Regional
(837,000) Planning & Development
Agency
208 South Fifth Street
Louisville, Kentucky 40202
Mr. Don Parnell
(615) 637-4663
Mr. Gordon Mellancamp
(615) 266-5781
Mr. Phil Armor
(615) 244-1212
Mr. Doug Haddock
(205) 325-3897
Ms. Nancy Landgraf
(205) 345-5545
Mr. Mike McAnnelly
(803) 798-1243
Mr. Larry Cox
(502) 581-6096
B-6
-------
Region and Area
Designation Date
(Grant Amount)
Agency
Contact
Orlando, Pla.
Volusia, Fla.
Breyard County,
Florida
Bay County
(Panama City), Fla.
Palm Beach, Fla.
Greenville, S.C.
Pensacola, FL
Sarasota-Ft. Myers
Florida
Mobile, Alabama
3-27-75
(909,400)
4-22-75
(730,000)
4-24-75
(736,000)
4-30-75
(538,000)
1-10-75
(984,000)
5-9-75
(1,139,520)
5-14-75
(848,000)
s-ifi-75
(949,000)
(1,143,000)
East Central Florida
Regional Planning Council
1011 Wymore Road, Suite 105
Winter Park, Fla. 32789
Volusia County Planning and
Development Department
125 E. Orange Avenue
County Courthouse Annex
Daytona Beach, Fla. 32014
Brevard County Planning
& Zoning Department
2575 N. Courtenay Parkway
Merritt Island, Fla. 32952
Northwest Florida Planning
& Development Council
5321 'B1 W. Highway 98
Panama City, Fla. 32401
Area Planning Board of
Palm Beach County
P.O. Box 3643
West Palm Beach, Fla. 33402
South Carolina Appalachian
Council of Governments
211 Century Drive
Greenville, S.C. 29606
Florida Regional
Planning Council
P.O. Box 486
Pensacola, Florida 32593
Southwest Florida Regional
Planning Council
2121 West First Street
Ft. Myers, Florida 33901
South Alabama Regional
Planning Commission
250 N. Water Street
P.O. Box 1665
Mobile, Alabama 36601
Mr. Arron Dowling
(305) 645-3339
Mr. Don Sikorski
(904) 255-0111
Mr. John W. Hannah
(305) 452-9480
Mr. Charles Shih
(904) 785-9581
Mr. Richard Stalker
(305) 683-9450
Mr. F.J. Forbes
(803) 242-9733
Mr. Dwaine Raynor
(904) 434-1026
Mr. Larry Pearson
(813) 334-7382
Mr. Don Pruitt
(205) 433-6541
B-7
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Broward Co. FL
Tanpa Bay, FL
Mr. Walter Keller
(305) 765-5535
5-23-75 Broward County Area
(863,000) Planning Board
1600 S.E. 10th Terrace
Fort Lauderdale, Fla.
33316
5-27-75 Tampa Bay Regional Planning Mr. Ron Armstronq
(1,500,000) Council (813) 821-2811
3151 Third Avenue North
Suite 540
St. Petersburg, Fla. 33713
Dade Co., FL
Tallahassee, FL
Beaufort, S.C.
Polk Co.
Charleston, S.C.
Waccamaw, S.C.
5-30-75
(1,077,000)
5-30-75
(510,000)
6-3-75
(680,000)
Kingsoort-Bristol, 6-5-75
TN (903,000)
6-6-75
(759,000)
6-6-75
(1,000,000)
6-6-75
(650,000)
Dade Cou ty
Planning Department
909 S.E. 1st Avenue
Miami, Florida 33131
Tallahassee-Leon County
Planning Department
P.O. Box 533
Tallahassee, Florida 32302
Mr. Ed Cahill
(305) 358-1400
Mr. -Tom Pierce
(904) 488-6133
Lowcountry Reqional Planning Mr. Charles Baggs
Council (803) 589-2751
P.O. Box 98
Yemassee, South Carolina
29945
First Tennessee-Virginia
Development District
1110 Seminole Drive
P.O. Box 2779
E.T.S.U.
Johnson City, TN 37601
Central Florida Reqional
Planning Council
P.O. Box 2089
Bartow, Florida 33830
Berkeley, Charleston,
Dorchester Regional
Planning Council
No. 2 Courthouse So.
County Office Bldg.
Charleston, S.C. 29401
Waccamaw Regional Planning
Council
P.O. Box 419
Georgetown, S.C. 29440
Mr. Bob Purcell
(615) 928-0224
Mr. Barry Chefer
(813) 533-4146
Mr. Ken Fujishiro
(803) 577-7800
Mr. Bob Barker
(803) 546-8502
B-8
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Asheville, N.C.
Region V
Cincinnati, Ohio
Toledo, Ohio
Dayton, Ohio
Youngstown, Ohio
Southeastern
Wisconsin
Detroit, Michigan
East St. Louis, II
Lake & Porter
Counties, IN
6-23-75 Land-of-the-Sky-Reqional
(481,000) Council
755 Merriman Avenue
P.O. Box 2175
Asheville, N.C. 28802
6-12-74 Ohio-Kentucky-Indiana
(1,913,000) Regional Council of Gov'ts
426 East 4th Street
Cincinnati, Ohio 45202
6-25-74 oledo Metropolitan Area
(1,175,000) Council of Governments
420 Madison Avenue
Suite 725
Toledo, Ohio 43604
6-25-74 Miami Valley Regional
(1,500,000) Planning Commission
33 West First Street
Dayton, Ohio 45402
6-28-74 Eastgate Development &
(950,000) Transportation Agency
1616 Covington Street
Youngstown, Ohio 44510
12-26-74 Southeastern Wisconsin
(2,607,000) Planning Comm. (SEWRPC)
916 S.E. Avenue
Waukesha, Wisconsin 53186
5-20-75 Southeast Michigan Council
(5,056,000) of Governments
1249 Washington, Blvd.
Detroit, Michigan 48226
5-20-75 Southeastern Illinois
(1,105,000) Metropolitan and Regional
Planning Commission
203 West Main Street
Collinsville, II 62234
5-20-75 Northwestern Indiana
(985,000) Regional Planning Comm.
8149 Kennedy Avenue
Highland, Indiana 46322
Mr. Dennie Martin
(704) .254-8131
Mr. Dory Montazemi
513-621-7060
Mr. Hintz Russelman
419-241-9155
Mr. Roger Riga
513-223-6323
Mr. Bill Fergus
216-746-4665
Mr. Bill McElwee
414-547-6721
Mr. Don Lamb
313-961-4266
Mr. Bill Ellman
618-344-4250
Mr. Ken Cypte
219-923-1060
B-9
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Dane County. WI
South Bend, IN
Canton-Akron, OH
Kalamazoo, MI
Cleveland, OH
Flint, MI
Muncie, IN
Jackson, MI
5-22-75 Dane County Regional
(598,000) Planning Commission
Room 312
City-County Building
Madison, Wisconsin 53709
5-23-75 Michiana Area Council
(862,000) of Governments
llth Floor
City-County Building
South Bend, Indiana 46601
5-23-75 Northeast Ohio Four County
(973,000) Planning and Development
Organization
19 North High Street
Akron, Ohio 44308
5-27-75 South Central Michigan
(810,000) Planning & Development Comm.
Conference Center,
Connors Hall
Nazareth College
Nazareth, Michigan 49074
5-27-75 Northeast Ohio Areawide
(3,209,000) Coordinating Agency
439 The Arcade
Cleveland, Ohio 44114
5-27-75 Gennessee, Lapeer, and
(848,000) Shiwwassee Counties
Region V Planning and
Development Commission
801 South Saginaw
Flint, Michigan 48502
5-27-75 Region 6 Planning and
(669,000) Development Commission
207 North Talley
Muncie, Indiana 47303
5-27-75 Region II Planning Comm.
(566,000) Jackson County Building
312 S. Jackson Street
Jackson, Michigan 49201
Mr. Charles Montemayor
608-266-4137
Mr. George L. Kruse, Jr.
219-287-1829
Mr. Robert Strantton
216-535-2644
Mr. Walt Forbes
616-343-1676
Mr. Tony Ma
216-241-2414
Mr. Thomas Haga,
313-766-8865
Mr. Dave Schoen
317-285-6252
Mr. Charles Mancherian
517-787-3800
ext. 256
B-10
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Indianapolis, IN
Chicago, IL
Bay City, MI
Muskegon, MI
Grand Rapids, MI
Tri-County, MI
Green Bay, WI
Terre Haute, IN
Southern Illinois
5-30-75
(1,301,000)
5-30-75
(7,343,000)
6-3-75
(1,040,000)
6-6-75
(620,000)
6-6-75
(1,012,000)
6-6-75
(704,000)
6-6-75
(772,000)
6-6-75
(477,000)
6-23-75
(1,200,000)
Indiana Heartland Coordi-
nating Commission
Suite 217
7202 N. Shadeland Avenue
Indianapolis, IN 46250
Northeastern Illinois
Planning Commission (NIPC)
10 South Riverside Plaza
Chicago, Illinois 60606
East Central Michigan
Regional Planning and
Development Commission
1003 Woodside Avenue
Essexville, Michigan 48732
West Michigan Shoreline
Regional Development Comm.
Torrent House
315 W. Webster Avenue
Muskegon, Michigan 49440
West Michigan Regional
Planning Commission
1204 People's Building
60 Monroe at lona
Grand Rapids, MI 49502
Tri-County Regional
Planning Commission
2722 E. Michigan Avenue
P.O. Box 2066
Lansing, Michigan 48912
Fox Valley Water Quality
Planning Agency
1919 North Lake Street
Neenah, Wisconsin 54956
Mr. Michael Robling
317-849-4629
Mr. Robert DuCharme
312-454-0400
Mr. David Gay
517-893-5561
Mr. Pat Tyson
616-722-7878
Mr. Robert Stockman
616-454-9375
Mr. Michael Scieszka
517-487-9424
Mr. Nathiel Malcoze
414-739-6156
West Central Indiana Mr. Charles Staats
Economic Development District 812-238-1561
P.O. Box 627
700 Wabash Avenue
Terre Haute, IN 47808
Greater Egypt Regional
Planning & Development Comm.
P.O. Box 3160
608 East College
Carbondale, Illinois 62901
Mr. Franklin Moreno
618-549-3306
B-ll
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Region VI
Tulsa, Oklahoma
Oklahoma City, OK
Dallas/Ft. Worth,
Texas
Beaumont-Port
Arthur, Texas
Houston, Texas
San Antonio, TX
Corpus Christi, TX
Lower Pio Grande,
Texas
Texarkana, TX
9-18-74
(1,210,000)
10-25-74
(1,500,000)
4-17-75
(2,321,620)
4-18-75
(843,000)
4-22-75
(1,798,300)
5-16-75
(1,162,112)
6-6-75
(643,500)
6-6-75
(775,000)
fi-23-75
(350,000)
Indian Nations Council
of Governments
630 West Seventh Street
Tulsa, Oklahoma 74127
Mr. Umesh Mathur
(918) 587-3178
Association of Central Mr. Bob Fritz
Oklahoma Governments (405) 848-8961
4801 Classen Blvd, Suite 200
Oklahoma City, OK 73118
North Central Texas
Council of Governments
P.O. Box 5888
Arlinaton, Texas 76011
Southeast Texas Regional
Planning Commission
3800 Hiqhway 365
Port Arthur, Texas 77640
Houston-Ga]veston Area
Council
3701 West Alabama
Houston, Texas 77027
Alamo Area Council of
Governments
400 Three America's Bldq.
San Antonio, Texas 78205
Coastal Bend Council
of Governments
International Airport
Corpus Christi, TX 78410
Lower Rio Grande Valley
Development Council
First National Bank Bldg.
Suite 207
McAHen, Texas 78501
Ark-Tex Council of Govts.
P.O. Box 5307
Texarkana, TX 75501
Mr. Herman Veselka
(817) 261-3331
Mr. Don Kelly
(713) 727-2384
Mr. Nick Aschliman
(713) 627-3200
Mr. Al Notzon
(512) 255-5201
Mr. Robert Weaver
(512) 884-3911
Mr. Richard Montedeoca
(512) 682-348]
Mr. Frank Goerke
(214) 794-3481
B-12
-------
Designation Date
Region and Area fGrnnt »mnimt) Agency
Contact
Region VII
Des Moinee, Iowa 6-10-74
(1,385,000)
St. Louis, MO
Centerville, Iowa
Joplin, MO
5-23-75
(2,243,000)
5-23-75
(325,000)
6-6-75
(429,500)
Kansas City, KS 6-13-75
(1,400,000)
Central Iowa Regional
Association of Governments
P.O. Box 3326
Des Moines, Iowa 50316
East-West Gateway
Coordinating Council
720 Olive Street
Suite 2110
St. Louis, MO 63101
Chariton Valley Regional
Services Agency
P.O. Box 591
Centerville, Iowa 52544
Ozark Gateway Regional
Planning Commission
303 E. Third Street
P.O. Box 1355
Joplin, MO 64801
Mid-America Regional
Council, Third Floor
20 West 9th Street
Kansas City, MO 64105
Dale Harrington
515-244-3257
Mr. Larry Zensinger
314-421-4220
Mr. Charles McCarty
515-856-2114
Mr. Peter Smith
417-781-3220
Mr. Tom Neal
816-221-0993
B-13
-------
Reaion and Area
Designation Date
(Grant Amount) Agency
Contact
Region VIII
Colorado Springs
6-26-74 Pikes Peak Area Council
(955,000) of Governments
27 East Vermigo
Colorado Springs, Col.
80903
Mr. Roland Gow
(303) 471-7030
Pueblo County, Col.
Denver, Col.
Provo, Utah
Uintah, Utah
Salt Lake County,
Utah
Middle Yellowstone,
Montana
Flathead & Lake
Counties, Montana
9 18-74 Pueblo Area Council of
(485,000) Governments
1 City Hall Place
Pueblo, Col. 81003
10-8-74 Denver Regional Council
(1,290,000) of Governments
1776 S. Jackson Street
Denver, Col. 80210
1-1-75 Mountain Association
(670,000) of Governments
160 East Center Street
Provo, Utah 84601
1-10-75 Uintah Basin Association
(380,000) of Governments
P.O. Box 867
26 W. 200 North
Roosevelt, Utah 84066
3-6-75 Salt Lake County
(1,046,000) Council of Cover men ts
2500 S. State Street
Salt Lake City, Utah S4115
4-1-75 Middle Yellowstone Areawide
(735,000) Planning Oroanization
3300 2nd Avenue North
Suite 200
Billings, Montana
4-2-75 Flathead Drainage
(495,000) 208 Project
P.O. Box 100
Kalispell, Montana 59901
Mr. Gene Fisher
(303)543-6006
Mr. Michael Smith
(303) 758-5166
Mr. George Scott
(301) 373-5510
Mr. Clinton Harrison
(301) 722-4518
Dr. David Eckhoff
(801) 328-7461
Mr. Allen Bond
(406) 245-6619
Mr. Dave Nunnallee
(406) 755-5521
B-14
-------
Region and Area
Designation Date
fQrant Amount) Agency
Contact
Region VIII
Ogden, Utah 4-2-75 Weber River Water
(Weber-Davis Counties) (827,000) Quality Planning Council
714 Municipal Building
Ogden, Utah 84401
Powder River, WX
Southeast, Utah
Yellowstone-Tongue
Montana
Rifle, Colorado
(Mesa/Rio Blanco)
4-4-75 Powder River Areawide
(415,000) Planning Organization
Box 204
Buffalo, WY 82834
4-17-75 Southeastern Utah
(380,000) Association of Govts.
143 So. Main Street
Helper, Utah
4-8-75 Yellowstone-Tongue
(540,000) Areawide Planning
Organization
Powder River County
Courthouse
Breadus, Montana 59317
4-24-75 Colorado West Area
(362,000) P.O. Box 351
Rifle, Col. 81650
Mr. Mike Minor
(801) 399-8401
Mr. Rich Douglass
(307) 684-7648
Dr. Courtney Brewer
(801) 472-3403
Mr. Floyd Irion
(406) 436-2483
Mr. Joel Webster
(303) 625-1723
Green River, WY
Five Counties, Utah
Northwest, Col.
Larimer-WeId, Col.
5-14-75 Southwestern Wyoming
(450,000) Water Quality Planning
Association
Lincoln County Courthouse
Kemmerer, WY.
5-14-75 Five County Association
(380,000) of Governments
P.O. Box 261
Cedar City, Utah 84720
5-14-75 Northwest Colorado
(530,000) Council of Govts.
P.O. Box 737
Frisco, Col. 80443
5-14-75 Larimer-Weld Council
(590,000) of Governments
201 East 4th Street
Room 201
Loveland, Col. 80537
Mr. Glenn Payne
(307) 789-3897
Mr. Neal Christensen
(801) 586-4842
Mr. Lee Woolsey
(303) 468-5445
Mr. Dick MacRavey
(303) 667-3288
B-15
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Black Hills, SD
Lewis & Clark, ND
Sioux Falls, SD
Jackson Hole, WY
Gallatin, MT
5-16-75 Sixth District Council
(375,000) of Local Governments
P.O. Box 1568
Paoid City, SD 57701
5-22-75 Lewis & Clark Resource
(400,000) Planning & Development
Council
Box 236
Mandan, ND 58554
5-27-75 South Eastern Council
(375,000) of Governments
8 E. 13th Street
.sioux Falls, SD 57105
6-4-75 Teton County-Section 208
(370,000) Planning Agency
P.O. Box 1727
Jackson, WY 83001
6-5-75 Gallatin County Commission
'475,000) Gallatin County Courthouse
Bozeman, MT 59715
Mr. Larry Finnerty
(605) 342-8241
Mr. Robert O'Shea
(701) 663-6587
Mr. John Norton
(605) 336-1297
Mr. William Ashley
(307) 733-4430
Mr. Walter Sales
(406) 587-7316
B-16
-------
Reqion and Area
Designation Date
(Grant Amount-) Agency
Contact
Reqion IX
Lake Tahoe
Interstate
Reno, NV
Carson City, NV
Tucson, AR
Ventura, CA
8-5-74
(702,000)
6-6-75
(372,530)
6-6-75
(140,510)
6-6-75
(962,230)
6-13-75
(928,000)
Clark Co., NV
Monterey, CA
San Diego, CA
Tahoe Regional Planning
Agency
P.O. Box 8896
So. Lake Tahoe
California 94705
Washoe Council of Govts.
417 Forest Street
Reno, Nevada 89502
Carson River Basin
Council of Governments
P.O. Box 1927
Carson City, NV 89701
Pima Association of
Governments
405 Transamerica Bldg.
Tucson, Arizona 85701
Ventura Regional County
Sanitation District
P.O. Box AB
181 So. Ash Street
Ventura, CA 93001
Clark County Soard of
County Commissioners
Clark County Courthouse
200 East Carson Avenue
Las Vegas, Nevada 89101
Association of Monterey
Bay Area Governments
AMBAG
1011 Cass Street
P.O. Box 190
Monterey, CA 93940
fi_lp_75 Coirprehensive Planning
(1,339,280) Organization of San Diego
County
Suite 524
Security Pacific Plaza
1200 3rd Avenue
San Diego, CA 92101
(773,880)
6-18-75
(829,500)
Mr. James Jordan
(916) 541-0246
Mr. Frank Freeman
(702) 329-6314
Mr. Robert Sullivan
(702) 885-4680
Mr. Paul Mackey
(602) 792-1093*
Mr. John A. Lambie
(805) 648-2717
Mr. Jack Petitti
(702) 451-1066
Mr. William Hood, Jr.
(408) 373-8477
Mr. Richard J. Huff
(714) 233-5211
B-17
-------
Reaion and Area
Designation Date
Agency
Contact
San Francisco, CA
Guam
Region X
Portland, Oregon
Salem, Oreqon
Eugene, Springfield,
Oregon
6-18-75 Association of Bay Area
(4,302,890) Governments
Claremont Hotel
Berkeley, CA 94705
6-18-75 Guam Environmental
(286,180) Protection Agency
P.O. Box 2999
Agana, Guam 96910
11-18-74 Columbia Region Assoc.
(1,110,000) of Governments
527 S.W. Hall
Portland, Oregon 97221
11-18-74 Mid-Willamette Valley
(446,400) Council of Governments
Civic Center, Rm 305
Salem, Oregon 97301
11-18-74 Lane Council of Govts.
(670,400) 135 6th Avenue East
Eugene, Oregon 97401
Pocatello, Idaho 3-25-75
(Bannock/Cariboo County)
(425,000)
Southeast Idaho
Council of Governments
209 E. Louis
Box 4169
Pocatello, Idaho 83201
Ada/Canyon County,
Idaho
Clark County,
Washington
Seattle, Washinaton
4-2-75 Ada/Canyon Waste
(414,300) Treatment Management
Committee
525 W. Jefferson
Boise, Idaho 83702
4-9-75 Regional Planning Council
(521,000) of Clark County
2400 T Street
Vancouver, Washington 98661
4-22-75 Municipality of
(850,000) Metrooolitan Seattle
Pioneer Building
600 1st Avenue
Seattle, WA 98104
Mr. Revan A.F. Tranter
(415) 841-9730
Dr. O.V. Natarajan
(Overseas Operator)
Mr. Tom Lucas
(503) 221-1646
Mr. Larry Frazier
(503) 588-6177
Mr. L. Douglas Halley
(503) 687-4283
Mr. Scott McDonald
(208) 232-4311
Mr. Georae J. Pattis
(208) 345-9510
Mr. Richard Hines
(206) 699-2361
Mr. Donald J. Benson
(206) 447-6666
B-18
-------
Region and Area
Designation Date
(Grant Amount) Agency
Contact
Panhandle District, 5-27-75
Idaho (485,000)
Medford, OR
Snohomish,
6-3-75
(318,000)
6-3-75
(950,000)
Panhandle Planning &
Development Council
P.O. Box 1154
Coeur d1 Alene, ID 83814
Rogue Valley Council of
Governments
33 N. Central, Suite 211
Medford, Oregon 97501
Snohomish County Metro-
politan Municipal Corp.
Snohomish County Admin.
Bldg.
Everett, Washington 98201
Mr. Bruce Thompson
(208) 667-4619
Mr. Jeff Gibbs
(503) 779-7555
George F. Sherwin
or
Hayden Street
(206) 259-9357
B-19
-------
o
I
LAKES REGIO
FITCHBURG
BERKSHIRE
REGION 1
MARTHA S VINEYARD
NORTHERN MAINE
LEWISTON - AUEURN
AUGUSTA - COBBOSSE
PORTLAND
SOUTHERN MAINE
CAPE COD
70
m
CD
-------
o
I
ro
REGION 2
ERIE-NIAGARA
SOUTHERN TIER CENTRAL
CORNING
NEW YORK CITY
MERCER CO,
CAMDEN AREA
CENTRAL NEW YORK
SYRACUSE
WESTCHFSTER
LONG ISLAND
MIDDLESEX CO,
BAN CO,
(PUERTO RICO)
-------
PHILADELPHIA
REGION 3
PITTSBURGH
o
I
CO
CHARLESTON
SOUTHWEST
RICHMOND
BALTIMORE
WASHINGTON^,C, - METRO
NEW CASTLE CO,
SUSSEX CO,
FREDRICKSBURG
HAMPTON ROADS
ROANOKE
UGH
-------
LOU ISVI LI
KNOXVILLE
NGSPORT BRISTOL
GREENVILLE
REGION 4
NASHVILLE
MEMPHI
CHATTANOOGA
BIRMINGHAM
TUSCALOOSA
MOBILE
TALLAHASSE
TAMPA BAY
11181
SARASOTA
HEW
LEIGH-
DURHAM
-WACCAMAW
PENSACOLA
BAY COUNTY
ASHVILLE
CHARLESTON
COLUMBIA
BEAUFORT, SC
LUSIA CO,
BREVARD CO,
POLK CO,
PALM BEACH
BROWARD CO,
DADE CO,
-------
GREEN BAY
\ V
KALAMAZOO
o
I
en
MUSKEAGON
REGION 5
BAY CITY
FLINT
DETROIT
TOLEDO
CLEVELAND
yOUNGSTOWN
CANTON-AKRON
JACKSON, MI
DAYTON
MUNCIE
CINCINNATI
SOUTHERN, IL\ INDIANAPOLIS
-------
o
I
en
REGION 6
BEAUMONT - PORT ARTHUR
HOUSTON
CORPUS CHRISTI
LOWER RIO GRANDE
-------
REGION 7
DBS MOINES
ST, LOUIS, MO
KANSAS CITY
Hill ISSlffi
-------
\MIDDLE-YELLOWSTONE
.YELLOWSTONE - TONGUE
REGION 8
FLATHEAD & LAKE
COUNTIES
LEWIS CIJ\R
BLACK
HILLS
JACKSON HOLE
GREEN RIVER
SOU IX
FALLS
LARIMER-WELD CO
WEBER - DAVIS COLORADO
(OGDEN) WEST
POWDER RIVER
NORTJHWEST
CO
SALT LAKE CO,
COLORADO
SPRINGS
'SOUTHEASTERN
FIVE COUNTIES, UT
-------
RENO
LAKE TAHOE
o
I
SAN FRANCISCO
MONTEREY
(GUAM)
\
CARSON CITY
VENTURA CO,
SAN DIEGO
BEfWIlE
REGION 9
TUCSON
-------
REGION 10
SEATTLE
PANHANDLE, ID
CLARK CO,
SALEM PORTLAND
/W^Xc"
EUGENE
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