EPA 903-R-97-012
CBP/TRS 170/97
April 1997
Chesapeake Bay
Regional Action Plans
Development Guidelines
Baltimore Harbor
Anacostia River
*
Elizabeth River
Chesapeake Bay Program
PrifJfd on recycled paper
-------
Chesapeake Bay
Regional Action Plan
Development Guidelines
April 1997
Printed by the U.S. Environmental Protection Agency for the Chesapeake Bay Program
-------
CHESAPEAKE BAY REGIONAL ACTION PLAN
DEVELOPMENT GUIDELINES
Prepared under Contract 68-D3-0030
for
Chesapeake Bay Program Office
U.S. Environmental Protection Agency
410 Severn Avenue, Suite 109
Annapolis, Maryland 21403
1-800-YOUR-BAY
http://www.epa.gov/Chesapeake
-------
Regional Action Flan Guidance
TABLE OF CONTENTS
Page
CHAPTER 1. INTRODUCTION 1-1
References Cited 1-4
CHAPTER 2. OVERVIEW OF THE REGIONAL ACTION PLANNING PROCESS 2-1
References Cited * 2-9
CHAPTER 3. CONDUCTING THE REGIONAL ACTION PLANNING PROCESS 3-1
3.1 OVERVIEW OF THE LEAD AGENCY'S INVOLVEMENT 3-4
3.1.1 Assembling an Effective Regional Action Team 3-6
3.1.2 Identifying Regional Action Team Members 3-7
3.1.3 Identifying Regional Action Team Leaders 3-16
3.1.4 Obtaining Management Support 3-17
3.2 OVERVIEW OF THE REGIONAL ACTION TEAM'S INVOLVEMENT 3-19
3.2.1 Identifying Stakeholder Interests 3-20
3.2.2 Evaluating Environmental Problems and Establishing a Vision
Statement, Goals and Objectives 3-21
3.2.3 Evaluating Existing Management Programs 3-22
3.2.4 Determining Implementation Actions 3-23
3.3 DEVELOPING A WORK PLAN 3-25
3.4 CONDUCTING EFFECTIVE REGIONAL ACTION TEAM MEETINGS 3-29
3.5 APPROACHES TO BUILDING CONSENSUS 3-33
3.6 PUBLIC PARTICIPATION AND EDUCATION 3-35
References Cited 3-39
CHAPTER 4. DEFINING THE PLAN'S VISION, GOALS, OBJECTIVES, AND
MILESTONES 4-1
4.1 THE NEED FOR VISION STATEMENTS, GOALS, OBJECTIVES, AND
MILESTONES 4-2
4.2 DEVELOPING EFFECTIVE VISION STATEMENTS, GOALS,
OBJECTIVES, AND MILESTONES 4-4
4.2.1 Conducting Preliminary Background Research 4-5
4.2.2 Developing a Vision Statement 4-6
4.2.3 Establishing Goals, Objectives, and Milestones 4-11
References Cited 4-15
CHAPTERS. DEFINING THE PROBLEM . 5-1
5.1 IDENTIFYING AND RANKING ADVERSE AMBIENT EFFECTS 5-5
5.1.1 Identifying Adverse Ambient Effects 5-5
Using Regions of Concern Information 5-6
Reviewing Additional Sources of Information 5-7
5.1.2 Ranking Adverse Ambient Effects 5-12
-------
Regional Action Plan Guidance
TABLE OF CONTENTS (continued)
Page
5.2 IDENTIFYING AND RANKING CHEMICAL CONTAMINANTS AND
THEIR SOURCES 5-14
5.2.1 Identifying Chemical Contaminants 5-15
5.2.2 Identifying Contaminant Sources 5-23
5.2.3 Ranking Chemical Contaminants and Sources 5-26
Ranking Chemical Contaminants 5-27
Ranking Sources of Chemical Contaminants 5-30
References Cited 5-35
CHAPTER 6. EVALUATING EXISTING MANAGEMENT PROGRAMS 6-1
6.1 IDENTIFYING EXISTING REGULATORY AND NONREGULATORY
PROGRAMS 6-1
6.2 FOCUSING ON PROGRAMS THAT ADDRESS KEY PROBLEMS 6-2
6.3 EVALUATING THE EFFECTIVENESS OF PROGRAMS 6-7
6.3.1 Program Authority or Mission 6-8
6.3.2 Program Tools 6-9
6.3.3 Program Resources 6-10
6.4 SYNTHESIZING FINDINGS 6-11
6.5 PRESENTING THE EVALUATION IN THE REGIONAL ACTION PLAN
DOCUMENT 6-11
CHAPTER 7. APPROACH TO DEVELOPING IMPLEMENTATION ACTIONS TO
ACHIEVE THE GOALS OF THE REGIONAL ACTION PLAN 7-1
7.1 IDENTIFYING ALL APPLICABLE ACTIONS 7-2
7.2 EVALUATING AND SELECTING THE IMPLEMENTATION ACTION(S) 7-6
7.2.1 Relationship of me Action to me Problem 7-7
7.2.2 Technical Feasibility 7-7
7.2.3 Cost 7-11
7.2.4 Financing 7-15
7.2.5 Regulatory and Nonregulatory Incentives 7-18
7.2.6 Public Support 7-20
7.2.7 Indicators for Measuring Progress 7-21
7.3 ASSIGNING AND TRACKING COMMITMENTS 7-22
7.4 PRESENTING IMPLEMENTATION ACTIONS IN THE REGIONAL
ACTION PLAN 7-23
References Cited 7-27
Other Sources of Information 7-27
11
-------
Regional Action Plan Guidance
LIST OF EXHIBITS
Page
Exhibit 2-1. Steps Needed to Complete the Regional Action Planning Process (responsible
party) 2-2
Exhibit 2-2. Recommended Table of Contents for Regional Action Plan . 2-6
Exhibit 2-3. Key Considerations for Successful Regional Action Planning 2-7
Exhibit 3-1. Roles and Responsibilities 3-4
Exhibit 3-2. Key Elements to Establishing a Regional Action Team 3-8
Exhibit 3-3. Reasons Why Consensus Groups Fail 3-8
Exhibit 3-4. Example of Procedure to Identify Participants for the Regional Action Team 3-10
Exhibit 3-5. Example of a Stakeholder Category Table Used to Identify Participants for the
Regional Action Team 3-11
Exhibit 3-6. Overview of Potential Stakeholders Within me Chesapeake Bay Watershed 3-13
Exhibit 3-7. Team Leader Qualities 3-17
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process 3-26
Exhibit 3-9. Roles and Responsibilities—Regional Action Team Meetings 3-31
Exhibit 3-10. Basic Considerations for Conducting Effective Regional Action Team
Meetings 3-32
Exhibit 4-1. Overview of Steps Needed to Develop a Vision Statement, Goals, Objectives, and
Milestones 4-4
Exhibit 4-2. Example of a Relatively Specific Vision Statement for me Citizens' Desired
State of the Lower Green Bay and Fox River Ecosystem 4-7
Exhibit 4-3. Example of a General Vision Statement and Associated Goals Developed for
the Comprehensive Conservation and Management Plan for the San Francisco
Bay 4-8
Exhibit 4-4. Common Vision Sketch of the Desired Future State for the Chesapeake Bay
Basin 4-10
Exhibit 4-5. Example Questions for a Citizen Survey 4-11
Exhibit 4-6. Regional Action Plan Example—Vision Statement, Goals, Objectives, and
Milestones 4-13
Exhibit 5-1. Description of the Steps Required for Defining the Problems in a Regional
Action Plan 5-3
Exhibit 5-2. Potential Sources of Information 5-9
Exhibit 5-3. Example Goals/Beneficial Uses and Associated Adverse Effects 5-13
Exhibit 5-4. Summary Checklist of Factors To Be Considered During Initial Data Reviews .... 5-18
Exhibit 5-5. Example Calculation for Estimating Receiving Water Concentrations 5-22
Exhibit 5-6. Sample Evaluation to Determine Chemical Contaminants of Concern 5-28
Exhibit 5-7. Example Prioritization for Chemicals To Be Addressed in a Region of
Concern 5-31
Exhibit 6-1. Examples of Existing Programs mat Address Problems Encountered hi
Regions of Concern 6-3
Exhibit 6-2. Questions Regarding Program Scope and Mission 6-8
Exhibit 6-3. Questions Regarding Program Tools 6-10
Exhibit 6-4. Questions Regarding Program Resources 6-10
IV
-------
Regional Action Plan Guidance
LIST OF EXHIBITS (continued)
Page
Exhibit 7-1. Relationship of Goals/Objectives to Applicable Actions 7-3
Exhibit 7-2. Potential Implementation Actions for Improving Shad Fishery at Attaboy
Creek: Elevated Concentration of Lead in Fish Tissue 7-5
Exhibit 7-3. Summary of Evaluation of Implementation Actions 7-8
Exhibit 7-4. Questions for Evaluating the Relationship Between the Action and the
Problem 7-9
Exhibit 7-5. Questions for Evaluating Technical Feasibility 7-9
Exhibit 7-6. Example of Evaluating Technical Feasibility: Contaminated Sediment
Remediation 7-10
Exhibit 7-7. Questions for Evaluating Costs of Actions 7-11
Exhibit 7-8. Cost Categories 7-12
Exhibit 7-9. Overview of Economic Techniques 7-12
Exhibit 7-10. Primary Variables of Concern and References/Contacts for Key Source
Categories 7-14
Exhibit 7-11. Example Cost Comparison for Potential Implementation Actions for
Controlling Stormwater Runoff 7-16
Exhibit 7-12. Questions Concerning Financing 7-17
Exhibit 7-13. Questions Concerning Implementation Incentives/Disincentives 7-18
Exhibit 7-14. Questions Concerning Public Support 7-21
Exhibit 7-15. Recommended Format of Periodic Progress Report, With Project Example 7-24
Exhibit 7-16. Regional Action Plan Summary of Recommended Actions 7-26
-------
CHAPTER 1
INTRODUCTION
-------
CHAPTER 1
TABLE OF CONTENTS
Page
I. INTRODUCTION 1-1
References Cited 1-4
-------
Regional Action Plan Guidance Introduction
CHAPTER I. INTRODUCTION
The 1994 Chesapeake Bay Btulnwtde Toxics Reduction and Prevention Strategy emphasized using
a regional focus to address chemical contaminant-related problems in the Chesapeake Bay. Guided by
the objective,
Direct reduction and prevention actions toward region with known toxic problem as
well as areas where significant potential exists for toxic impacts on living resources and
habitats, and more directly involve the locally affected community and stakeholders,
the Chesapeake Bay Program is establishing a process for characterizing and designating areas of the Bay
as Regions of Concern (e.g., areas with known chemical contaminant-related impacts)1, and developing
Regional Action Plans to guide the cooperative efforts needed to restore and protect the designated
Regions of Concern. This guidance document presents an overview of the regional action planning
process and an approach for developing Regional Action Plans. A separate document (see Appendix
h—Chesapeake Bay Chemical Contaminant Geographical Targeting Protocol [Chesapeake Bay Program,
1995]) describes the process the Chesapeake Bay Program will use to identify Regions of Concern within
the Chesapeake Bay basin.
The first step in the regional action planning process is for the Chesapeake Executive Council to
designate an area as a Region of Concern. The Executive Council designated three areas (i.e., the
Elizabeth River in Virginia, Baltimore Harbor in Maryland, and Anacostia River in the District of
Columbia and Maryland) in the 1994 Chesapeake Bay Basinwide Toxics Reduction and Prevention
Strategy; subsequent areas will be designated after completion of the chemical contaminant geographical
targeting identification process (see Appendix A).
Once the Executive Council designates a Region of Concern, the next step is to develop and
implement a Regional Action Plan. A Regional Action Plan serves as the guidebook for reducing and
preventing chemical contamination problems in a designated Region of Concern. Prepared through an
active, iterative process involving major stakeholders and the general public, a Regional Action Plan
focuses multiagency cooperative efforts and public-private partnerships on planning and implementing the
Through the Region of Concern identification process, all Chesapeake Bay tidal areas will eventually be
clarified into one of four categories: (1) Region of Concern, (2) Area of Emphasis, (3) Area with Low Probability
for Advene Effects, and (4) Area with Insufficient Data. An area will be clarified as a Region of Concern when
the available data indicate both advene ambient effects and elevated concentrations of chemical contaminants above
thresholds associated win advene effects. In addition, the data must reveal strong evidence tor a causal relationship
between the observed chemical contaminant stresson and effects.
1-1
-------
Regional Action Plan Guidance Introduction
necessary assessment, reduction, remediation, and prevention actions to restore and protect the designated
Region of Concern.
The remaining chapters of this guidance document lead the reader, step by step, through the
process of developing a Regional Action Plan. The document describes the elements of a Regional Action
Plan, provides guidance on the planning process (e.g., developing stakeholder groups, which are referred
to as Regional Action Teams), identifies the information that should be presented in the Regional Action
Plan, suggests approaches for obtaining and analyzing the information needed to prepare the written plan,
and presents various formats for displaying the information. The information covered in this guidance
document is arranged according to the following chapters:
• Overview of the Regional Action Planning Process (Chapter 2)
• Conducting the Regional Action Planning Process (Chapter 3)
• Defining the Plan's Vision, Goals, Objectives, and Milestones (Chapter 4)
• Defining the Problem (Chapter 5)
• Evaluating Existing Management Programs (Chapter 6)
• Developing Implementation Actions (Chapter 7).
In addition, appendices to this document provide additional information.
This guidance was developed after an evaluation of other geographically based water quality
planning efforts. It presents a model for developing and presenting Regional Action Plans based on
lessons learned in other areas. The document promotes a common, bay-wide approach for addressing
region-specific issues and problems in the context of a Regional Action Plan, while at the same time
acknowledging mat each Region of Concern is unique, with she-specific conditions and problems
requiring tailored solutions. The information contained in this guidance document is intended to provide
helpful background information needed to conduct an effective regional action planning process and
prepare a well-developed Regional Action Plan. Readers desiring a quick summary of the types of
information that should be contained hi the final Regional Action Plan, including a recommended
checklist of requirements for each chapter of a Regional Action Plan, should turn to Appendix B,
Overview of Key Components to be Addressed hi a Regional Action Plan.
The jurisdictions charged with developing Regional Action Plans are not required to follow
verbatim the model proposed hi mis guidance document. Just as each Region of Concern has a special
1-2
-------
Regional Action Plan Guidance Introduction
set of circumstances (e.g., different chemical contamination problems) that caused its designation, each
Regional Action Plan 'will also be unique, with different goals and objectives.
\
The approach proposed for developing Regional Action Plans has been used successfully hi other
areas (e.g., Great Lakes Remedial Action Plans and Puget Sound Watershed Action Plans for Nonpoint
Source Pollution) to develop a targeted implementation approach for addressing the unique problems of
a specific location. These planning approaches were successful, in large part, because they secured the
commitment of stakeholders, particularly those with a vested interest in the Region of Concern, to assist
in developing and implementing the plan. In doing so, the plans extended beyond standard regulatory
approaches to pollution control and supplemented them with innovative actions that addressed site-specific
problems (Hartig and Zarull 1992; National Water Quality Evaluation Project 1992; Puget Sound Water
Quality Authority 1993; Wallin and Haberman 1992). The Chesapeake Bay Program envisions using a
similar, stakeholder driven process to develop Regional Action Plans.
1-3
-------
Regional Action Plan Guidance ' Introduction
REVERENCES CITED
Chesapeake Bay Program. 1995. Chesapeake Bay Chemical Contaminant Geographical Targeting
Protocol, Chesapeake Bay Basinwide Toxics Reduction and Prevention Strategy Commitment
Report.
Hartig, J. and M. ZaruU. 1992. Under RAPs—Toward Grassroots Ecological Democracy in the Great
Lakes Basin. Ann Arbor: University of Michigan Press.
National Water Quality Evaluation Project. 1992. Summary Report—Evaluation of the Experimental
Rural Clean Water Program. Raleigh: NCSU Water Quality Group, North Carolina Cooperative
Extension Service, North Carolina State University.
Puget Sound Water Quality Authority. 1993. Managing Nonpoint Pollution—An Action Plan for Puget
Sound Watersheds. Olympia: Puget Sound Water Quality Authority.
\
Wallin, P. and R. Haberman. 1992. People Protecting Rivers: A Collection of Lessons from Successful
Grassroots Activists. Portland: River Network.
1-4
-------
CHAPTER 2
OVERVIEW OF REGIONAL ACTION PLANNING PROCESS
-------
CHAPTER 2
TABLE OF CONTENTS
Page
2. OVERVIEW OF THE REGIONAL ACTION PLANNING PROCESS 2-1
References Cited 2-9
EXHIBITS
2-1. Steps Needed to Complete the Regional Action Planning Process (responsible party) 2-2
2-2. Recommended Table of Contents for Regional Action Plan 2-6
2-3. Key Considerations for Successful Regional Action Planning 2-7
-------
Regional Action Plan Guidance Overview
"""" r /
CHAPTER 2. OVERVIEW OF THE REGIONAL ACTION PLANNING PROCESS
In designating an area as a Region of Concern, the Chesapeake Executive Council members
commit their respective jurisdictions to the regional action planning process, including preparing a
Regional Action Plan. Each responsible jurisdiction designates a lead agency (e.g., typically the state
environmental office) to oversee plan development and implementation. Once designated, the lead agency
has a great deal of flexibility in choosing its approach for completing the plan, although experience gamed
from similar planning approaches conducted elsewhere shows that the most effective plans are developed
when the lead agency works closely with existing groups and/or stakeholders hi the Region of Concern.
Regardless of the approach implemented, the lead agency is ultimately responsible for ensuring that the
Regional Action Plan is delivered to the Executive Council on time, hi accordance with the schedule that
is determined when the area is designated as a Region of Concern.
This chapter recommends an ideal approach for developing a Regional Action Plan. Although
many approaches can be used and should be explored to suit site-specific needs, the steps described in
Exhibit 2-1 provide the foundation for a successful plan. This chapter provides an overview of each step
hi the planning process; subsequent chapters of the guidance lead the reader, step by step through the
process of developing a Regional Action Plan.
The overarching goal of each Regional Action Plan is to develop an implementable plan that
effectively addresses chemical contamination problems hi a Region of Concern. The plan should clearly
define the vision, goals, and objectives guiding the process; provide a realistic evaluation of the problems;
and summarize the necessary assessment, reduction, remediation, and prevention actions needed to
address identified problems. To be effective, the Regional Action Plan must have clearly stated, and
measurable, goals and objectives; involve key stakeholders and the general public from project initiation
through the planning process; and thoroughly define roles, responsibilities, and commitments for each
participant.
One key to developing a successful Regional Action Plan is to involve a representative and
balanced stakeholder group (referred to as the Regional Action Team) of interested and affected parties
in all stages of the plan development, beginning with defining the problem and establishing a vision
statement, goals, and objectives for the plan. It is especially important to involve individuals and/or
groups that will play lead roles hi implementing the Regional Action Plan, as well as those responsible
for completing plan recommendations. The group should comprise key decision-makers, subject matter
2-1
-------
Regional Action Plan Guidance Overview
Exhibit 2-1. Steps Needed to Complete the Regional Action Planning Process
(responsible party)
1. Designate Regions of Concern (Executive Council)
2. Identify Lead Agency (Executive Council)
3. Conduct Preliminary Background Research on Region of Concern (Lead Agency)
• Identify existing stakeholder groups, if applicable.
• Begin summarizing information on problems associated with chemical contamination.
•v
4. Establish Multidistiptinary Regional Action Team (Lead Agency, with input from existing groups)
• Include representatives of persons affected by or contributing to chemical contamination in the
Region of Concern, the lead agency, key decision-makers, and subject matter experts.
5. Determine Planning Approach (Lead Agency, with input from existing groups)
• Define roles and responsibilities.
• Develop work plan and schedule (including Regional Action Team meetings and deliverables).
'• Outline methodology for developing Regional Action Plan.
6. Obtain Commitments of Key Leaders -
7. Develop Preliminary Problem Statement (Lead Agency, with input from existing groups and
subject matter experts)
• Consult readily available information sources, including the Chemical Contaminant Geographical
Targeting Protocol, to develop a preliminary understanding of problems related to chemical
contamination within the Region of Concern (i.e., What makes the area a Region of Concern?).
Much of the information will most likely come from the chemical contaminant geographical
targeting process.
• Prepare summary background paper or fact sheet for distribution to the Regional Action Team.
8. Determine a Vision Statement and Identify Preliminary Goals and Objectives (Regional Action
Team)
• Use the preliminary assessment of problems as a starting point for determining the desired future
state of the Region of Concern. Use stakeholders, technical experts, and public participation to
define goals and objectives necessary to achieve the desired future state.
2-2
-------
Regional Action Plan Guidance Overview
Exhibit 2-1. Steps Needed to Complete the Regional Action Planning Process
(responsible party) (continued)
9. Further Define Problems in the Context of Preliminary Goals and Objectives (Lead Agency,
Regional Action Team, Existing Groups, Subject Matter Experts)
• Identify and rank adverse ambient effects (e.g., fish tumors) caused by chemical contamination.
• Identify and rank chemicals (e.g., polyaromatic hydrocarbons) and sources (e.g., urban runoff)
causing impacts.
• Prioritize impacts, chemicals, and sources so that effective, targeted, implementation actions can be
developed.
10. Assess Effectiveness of Existing Management Programs (Lead Agency, Regional Action Team,
Existing Groups, Subject Matter Experts)
• Identify key regulatory and nonregulatory programs affecting priority problems in the Region of
Concern.
• Evaluate programs to assess effectiveness.
• Determine where existing programs are not sufficient to reduce or prevent loadings or releases of
the chemical contaminants linked with the existing or potential adverse impacts in the Region of
Concern.
i
• Determine what additional or new actions, both regulatory and nonregulatory, must be taken to
effectively reduce the effects related to chemical contamination.
11. Revise Preliminary Goals and Objectives (Regional Action Team)
12. Develop Implementation Approach to Address Problems (Lead Agency, Regional Action Team,
Existing Groups, Subject Matter Experts)
• Identify specific implementation actions.
• Summarize the primary components of each action, including methodology and linkage to priority
problems.
• Determine the jurisdictions and entities responsible for completion of each step.
• Develop an aggressive, yet realistic completion schedule including milestones.
• Define the key monitoring actions, including monitoring frequency and responsible parties, needed
to verify the restoration of uses and the reduction/elimination of adverse living resources.
13. Compile final Regional Action Plan for Presentation to Executive Council (Lead Agency, Regional
Action Team, Existing Groups)
2-3
-------
Regional Action Plan Guidance Overview
experts, and representatives of persons affected by or associated with chemical contamination in the
Region of Concern.
The process of developing a Regional Action Plan involves many sequential and overlapping
tasks. Although outlined in this chapter as steps (Exhibit 2-1), the planning process is iterative; as more
knowledge of a Region of Concern is gained throughout the process, the initial problem statement, goals,
and recommendations might be enhanced, refined, or revised. The knowledge base for the plan will
continue to evolve during the plan's implementation. Therefore, the process should include periods of
re-evaluation to ensure that each part of the plan remains applicable and well-designed.
Obviously, the process begins with designation of a Region of Concern (Step 1). After
designation, the affiliated jurisdictions name a lead agency, which initiates the Regional Action Planning
process (Step 2). The lead agency then assembles available background materials on the Region of
Concern and develops a preliminary understanding of problems and current players in the Region of
Concern (Step 3). While assembling and evaluating background information, the lead agency might
discover that an existing stakeholder group is already active in the Region of Concern. The lead agency
may choose to team with this group or to delegate all responsibility for the Regional Action Plan to the
group. Regardless of the approach taken, the lead agency, working with existing groups, should name
an independent, multidisciplinary Regional Action Team to make decisions and to provide other support
for Regional Action Plan development (Step 4). The Regional Action Team should be assembled based
on an understanding of the problems, affected parties, and key decision-makers in the Region of Concern.
Chapter 3 describes techniques to select a balanced and representative Regional Action Team. A
representative from the lead agency should also be included as a member for the Regional Action Team.
Also in these early planning steps, the lead agency, in conjunction with its partner or designee,
should prepare a regional action planning work plan, which contains a methodology and timeline for
completing the other elements of the plan (Step 5). The work plan should also define an overall mission
for the group. The work plan should be distributed to the Regional Action Team hi advance of its first
meeting so that it can be reviewed and finalized when the group meets.
Prior to the first meeting, the lead agency should also work to secure the commitment of key
leaders (Step 6). High level management support is essential to ensuring the ultimate success of the
regional action planning process. Demonstrated management support might help to motivate the Regional
2-4
-------
Regional Action Plan Guidance Overview
Action Team and encourage participation from other entities in the Region of Concern. In addition, high
level management support is critical to obtaining staff and financial resources.
The next step in the process (described hi Chapter 4), which can be taken while identifying the
Regional Action Team members, is for the lead agency and/or its partner or designee to assemble readily
available background materials that address the Region of Concern. From these, a summary background
paper and/or fact sheet of problems and other issues in the Region of Concern (kept short and brief at
this point of the planning process) should be distributed to the Regional Action Team (Step 7). Using
these background materials and related presentations to initiate discussion, one of the first planning
meetings for the Regional Action Team should be devoted to developing a preliminary problem statement
(Step 7) and an overall vision for the Region of Concern and associated preliminary goals and objectives
to focus the planning process (Step 8). The process of developing goals and measurable objectives will
continue and become more refined (i.e., measurable objectives will be established) throughout the
planning process as more is learned about the Region of Concern. The purpose of investing time at the
beginning of the process to understand problems is to help focus limited resources on those areas of
greatest concern.
After developing preliminary goals and objectives, the next step (discussed in Chapter 5) is to
further define the problems (e.g., identifying the types and sources of chemical contaminants and their
effects on living resources), in the context of the goals and objectives (Step 9). In situations where there
is insufficient background information about the problems to identify preliminary goals and objectives,
the Regional Action Team may have to skip ahead to further defining problems (Step 9) before
completing the identification of goals and objectives (Step 8).
After evaluating problems and developing a vision statement and preliminary goals and objectives,
the regional action planning process focuses on developing an implementation approach. One important
aspect of the implementation approach is to assess the effectiveness of existing management programs that
address priority problems in the Region of Concern (Step 10). Before completing development of the
implementation approach, the Regional Action Team may want to refine or revise its preliminary goals
and objectives (Step 11) based on its expanding knowledge base about the Region of Concern. In order
to complete the implementation approach, the Regional Action Team must build from its understanding
of existing management programs to identify new implementation actions (discussed in Chapter 7), if
necessary, that will address problems in the Region of Concern (Step 12). These implementation actions
should address the targeted goals and objectives of the Regional Action Plan. During this step, the
— — -
-------
Regional Action man Guidance Overview
Regional Action Team should recruit commitments for implementation from the stakeholders, develop
implementation schedules, and make provisions to track implementation progress and identify measures
of success.
The information assimilated during each step of the regional action planning process must be
assembled into a single document representing the methodology, findings, and recommendations of the
Regional Action Team (Step 13). Exhibit 2-2 provides a sample table of contents that can be used as an
outline for the Regional Action Plan. After assembling the Regional Action Plan, the Regional Action
Team and lead agency present the document to the Chesapeake Bay Program Toxics Subcommittee for
review and the Executive Council for formal adoption. Concurrently, the lead agency, Regional Action
Team, and other key players (e.g., federal agencies) begin implementation of their commitments
according to the Regional Action Plan.
Exhibit 2-2. Recommended Table of Contents for Regional Action Plan
Executive Summaiy
1. Introduction
2. Overview of Regional Action Plan Development Process
3. Goals, Objectives, and Milestones
4. Definition of the Problem
5. Existing Management Programs
6. Implementation Actions
References
Appendices
Maps and Overlays
The remainder of this document provides more detailed information on the steps required to
conduct an effective regional action planning process. As mentioned previously, the guidance was
developed after an evaluation of other geographically based approaches to water quality planning.
Exhibit 2-3 lists the key considerations learned through the evaluation that should be followed to
encourage successful regional action planning.
2-6
-------
Regional Action Plan Guidance Overview
Exhibit 2-3. Key Considerations for Successful Regional Action Planning
Establishing a Regional Action Team
• Determine appropriate participants. Represent affected parties (i.e., persons whose use of the Region
of Concern is unpaired by chemical contamination and groups associated with chemical contamination),
subject matter experts, and key decision-makers. Involve representatives from groups potentially
responsible for implementing aspects of the plan.
• Select a Team that is balanced and representative of all affected parties. One group should not
dominate. In most cases, it is inappropriate for more than one individual from a single entity to
participate.
• Identify enthusiastic, open-minded, and energetic participants who are committed to the consensus-
building process and have time to devote to developing a Regional Action Plan.
• Avoid inviting people not affected by the objectives) of the Regional Action Plan. Also avoid
individuals not committed to the process (e.g., those who are disinterested, unreliable) and/or known
meeting "disrupters."
• Aim to have an adequate and balanced stakeholder group that is large enough to have the knowledge
and opinions relevant to the planning task, but strive for a manageable group size. For decision-making
activities, the optimal group size is 7 to IS participants.
Conducting the Regional Action Planning Process
• Utilize a participatory, team-driven process to develop the Regional Action Plan.
• Involve affected parties (i.e., stakeholders) at each stage of the planning process, including initiation.
Involvement in the planning process empowers stakeholders and leads to local ownership of the plan's
recommendations. Such involvement promotes long-term commitment and support from key citizenry.
• Identify a leader for each part of the process (e.g., someone to run meetings, someone to coordinate
meetings).
• Designate a staff person from die lead agency to coordinate plan development and implementation,
including project administration, coordination, and progress reporting.
• Designate core project staff from participating agencies.
• Have clearly defined roles and responsibilities for each part of the process.
• Streamline the planning process by focussing on priority issues.
• Develop a work plan, including a detailed schedule, to guide die planning process.
• Develop clearly stated and measurable goals based on a realistic assessment of die problem and die
feasibility of resolution. Throughout die planning process, develop more specific objectives, providing
realistic, quantitative targets for each goal. Rank goals and objectives according to priority for action.
• Develop short-and long-term goals. Short-term, achievable gods are important to demonstrate progress
to die public to ensure dieir continued support.
2-7
-------
Regional Action Flan Guidance Overview
Exhibit 2-3. Key Considerations for Successful Regional Action Planning (continued)
Conducting the Regional Action Planning Process (continued)
• Develop written milestones for achieving implementation actions and a system to monitor progress to
ensure momentum for plan implementation.
• Build local support through public participation and education.
• Build in mechanisms for plan re-evaluation and revision.
Defining Problems
• Focus problem definition investigations on priority goals and objectives. Obtain sufficient (but not
excessive) information to develop a sound implementation approach.
• Prioritize problems and focus regional action planning activities on the highest priorities first.
• Maintain discipline and focus when conducting research on problems. Use resources efficiently by
focusing on information relevant for decision-making.
• Ensure that the geographic boundaries for the Region of Concern are well defined to encompass the
major pollutant sources and "workable" hi size so that implementation actions are feasible.
Developing Implementable Solutions
• Focus implementation actions on priority problems and causes of those problems.
• Give top priority to projects with a high probability for reversing water quality impairment.
• Identify funding sources and commitments upfront.
• Ensure compatibility of proposed solutions so mat actions do not interfere with each other.
• Effectively use existing regulatory and resource management took.
• Obtain high level management commitment, including allocation of staff and financial resources.
• Encourage political will through public participation and establishment of citizen "watchdog" groups.
Effectively Measuring Progress
• Ensure that project goals and objectives are realistic, specific, and measurable.
• Require routine progress reports to track implementation status.
Sources: Hartig and Zarull (1992); Klemans (1993); National Rural Clean Water Program (1992); National
Water Quality Evaluation Project (1992); Wallin and Haberman (1992).
2-8
-------
Regional Action flan Guidance Overview
CITED
Hartig, J. and M. Zarull. 1992. Under RAPs—Toward Grassroots Ecological Democracy in the Great
Lakes Basin, Ann Arbor: University of Michigan Press.
Klemans, D. 1993. Strategies to Improve Michigan's RAP Process. Michigan Department of Natural
Resources White Paper.
National Rural Clean Water Program. 1992. Agriculture's and Related Private Sector's Consensus
Perspective on Lessons Learned from the National Rural Clean Water Program.
National Water Quality Evaluation Project. 1992. Summary Report—Evaluation of the Experimental
Rural Clean Water Program. Raleigh: NCSU Water Quality Group, North Carolina Cooperative
Extension Service, North Carolina State University.
Wallin, P. and R. Haberman. 1992. People Protecting Rivers: A Collection of Lessons from Successful
Grassroots Activists. Portland: River Network.
2-9
-------
CHAPTERS
CONDUCTING THE REGIONAL ACTION PLANNING PROCESS
-------
CHAPTERS
TABLE OF CONTENTS
Page
3. CONDUCTING THE REGIONAL ACTION PLANNING PROCESS 3-1
3.1 OVERVIEW OF THE LEAD AGENCY'S INVOLVEMENT
3.1.1 Assembling an Effective Regional Action Team 3-6
3.1.2 Identifying Regional Action Team Members 3-9
3.1.3 Identifying Regional Action Team Leaders 3-16
3.1.4 Obtaining Management Support • 3-17
3.2 OVERVIEW OF THE REGIONAL ACTION TEAMS INVOLVEMENT 3-19
3.2.1 Identifying Stakeholder Interests 3-20
3.2.2 Evaluating Environmental Problems and Establishing a Vision Statement, Goals
and Objectives 3-21
3.2.3 Evaluating Existing Management Programs 3-22
3.2.4 Determining Implementation Actions 3-23
3.3 DEVELOPING A WORK PLAN 3-25
3.4 CONDUCTING EFFECTIVE REGIONAL ACTION TEAM MEETINGS 3-29
3.5 APPROACHES TO BUILDING CONSENSUS 3-33
3.6 PUBLIC PARTICIPATION AND EDUCATION 3-35
References Cited 3-39
EXHIBITS
3-1. Roles and Responsibilities 3-4
3-2. Key Elements to Establishing a Regional Action Team 3-8
3-3. Reasons Why Consensus Groups Fail 3-8
3-4. Example of Procedure to Identify Participants for the Regional Action Team 3-1 1
3-5. Example of a Stakeholder Category Table Used to Identify Participants for the Regional
Action Team 3-12
3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed 3-13
3-7. Team Leader Qualities 3-17
3-8. Overview of Activities Comprising the Regional Action Planning Process 3-26
3-9. Roles and Responsibilities— Regional Action Team Meetings 3-31
3-10. Basic Considerations for Conducting Effective Regional Action Team Meetings 3-32
-------
Regional Action Plan Guidance Conducting the Process
CHAPTER 3. CONDUCTING THE REGIONAL ACTION PLANNING PROCESS
Regional Action Plans should be developed through a coordinated, consensus-building process
overseen by the designated lead agency in the Region of Concern1 and supported by a stakeholder group,
i referred to as the Regional Action Team. Although the lead agency has considerable flexibility in its
approach to conducting the regional action planning process, the Chesapeake Bay Program expects the
lead agency to:
• Develop and deliver a Regional Action Plan to the Chesapeake Executive Council within a
designated timeframe
• Use a regional action planning process that considers all stakeholder interests
• Identify and work in consultation with the Regional Action Team throughout the planning
process, particularly when identifying priorities, determining an overall project vision, setting
goals and objectives, and developing implementation actions and milestones
• Work with the Regional Action Team to include the public in the planning process.
This chapter presents background information useful for conducting the regional action planning
process. The chapter describes the anticipated activities of the lead agency and the Regional Action Team
in developing a Regional Action Plan, presents information on conducting Regional Action Team
meetings and building consensus, and discusses the importance of public participation and education.
This information is presented in the following sections of the chapter:
• Overview of the Lead Agency's Involvement
- Assembling an Effective Regional Action Team
- Identifying Potential Regional Action Team Members
- Identifying Regional Action Team Leaders
- Obtaining Management Support
• Overview of the Regional Action Team's Involvement
- Identifying Stakeholder Interests
- Evaluating Environmental Problems and Establishing a Vision Statement, Goals and
Objectives
- Evaluating Existing Management Programs
- Determining Implementation Actions
'Lead agencies are designated by the jurisdiction^) containing a Region of Concern.
—
-------
Regional Action Plan Guidance Conducting the Process
• Developing a Work Plan
• Conducting Effective Regional Action Team Meetings
• Approaches to Building Consensus
• Public Participation and Education.
Although the guidance recognizes that each Region of Concern is a unique location, with site-
specific considerations, the suggestions presented in this chapter apply to most situations and will help
determine an efficient and successful regional action planning outcome. Three overarching considerations
that apply to all aspects of the planning process include:
Someone must coordinate the entire regional action planning process. The process
involves many different steps and participants. In order to keep the process on track, in an
orderly and efficient manner, one person should be responsible for mapping each step of the
process, assigning roles and responsibilities, and ensuring that tasks get completed on time.
This Regional Action Plan coordinator should be affiliated with the group responsible for
writing the final plan and delivering it to the Executive Council (generally this group is the
lead agency).
Roles and responsibilities for each step of the planning process must be clearly defined.
Regional action planning involves many different tasks, including conducting background
research, preparing written materials, providing logistical support for Regional Action Team
meetings, running Regional Action Team meetings, facilitating decision-making, and writing
the final plan. Because different people will be involved hi each of these steps, it is essential
to clarify, upfront, the roles and responsibilities of each participant. This will clarify the
overall approach, ensure efficient participation, and avoid duplication of effort.
Each step of the planning process must have a leader. In addition to the overall plan
coordinator, each step of the process must have a discrete leader. Absence of a leader can
lead to confusion about roles and responsibilities, cause the process to get off-track, and
frustrate participants who are unclear about the best way to participate.
The rationale for having an overall coordinator, defining roles and responsibilities, and identifying
leaders for the regional action planning process is simple and straightforward. Regional action planning
must occur in an orderly, efficient, and timely fashion so that momentum is maintained, participants'
commitment and enthusiasm to the planning process remain high, and goals and objectives are achieved.
Defining roles and responsibilities early in the process helps to establish the road map necessary to ensure
effective planning. Poorly organized efforts, without a clearly stated mission and understanding of
individual and group responsibilities, often fail to achieve the ultimate goal of the regional action planning
3-2
-------
Regional Action Plan Guidance Conducting the Process
process—to develop an implementable plan, representative of the diverse interests in the Region of
Concern, that will reduce and prevent problems associated with chemical contamination.
Stakeholder involvement from the early stages is critical to the ultimate success of the Regional
Action Plan. Stakeholders are represented through a well-selected Regional Action Team comprised of
a diverse group of participants interested in, affected by, or contributing to chemical contaminant-related
issues hi the Region of Concern. Potential stakeholders for inclusion on the Regional Action Team
include representatives from local, state and federal governments; industrial and commercial sectors;
citizen and environmental groups; and academic institutions.
Involving stakeholders in the decision-making process leads to local ownership of the Regional
Action Plan and a sense of stewardship for the Region of Concern. The coalitions built through an
effective stakeholder process will strengthen the Regional Action Plan by elevating the priority given to
certain implementation actions, obtaining commitments (e.g., staff resources, funding) for
implementation, and engendering trust among diverse interests. In addition, stakeholder commitment is
necessary because of the level of political, legal, and behavioral change necessary to achieve some
regional action planning goals and objectives. Because of the variety of political bodies and agencies
potentially involved in the watersheds linked to a Region of Concern, governmental commitment is also
key to affecting change. Most of the implementation actions needed to address a Region of Concern,
whether regulatory or nonregulatory, are beyond the conceptual, institutional, and financial reach of any
single agency or group and require intra-agency collaboration, public-private partnerships, and
stakeholder commitment.
In addition to the Regional Action Team directly involved in plan development, the sustained
Interest and involvement of the general public is necessary to maintain momentum. The general public
can be influential in ensuring that actions are pursued. They can help keep the process focused and, by
serving as citizen "watchdogs," can achieve greater accountability from those charged with implementing
specific plan recommendations. The general public can also provide technical input to plan development
by contributing information and opinions to define problems, assessing existing programs, and
determining implementation actions. Citizen groups can also be established to contribute directly to plan
implementation by establishing citizen monitoring networks, promoting cleanup days, or initiating other
actions. An informed public can provide valuable resources to the regional action planning process, and
efforts should be taken, from the start, to ensure public participation.
3-3
-------
Regional Action Plan Guidance
Conducting the Procen
Exhibit 3-1. Rol« and RespondWJttfc*
Stakeholder
Role/lntcnfts
/Other
Lead agencies
Manage plan development in
cooperation with stakeholders
6.e., Regional Action Team) and
form institutions with public
involvement and commitment
Protect water quality and
develop and implement a
Regional Action Plan
PttiHifh and
coordinate the team
and provide technical
and financial resource*
Responsible agencies
(federal, state, and local)
Support plan development and
pursue various public interests
Assist lead agencies and commit
technical and fJHffff**f resources;
participate in relevant
implementation action*
Exercise jurisdiction
over resources or
management decisions
Industry and local
businesses
Ensure business interests are
represented in the plan
Contribute technical expertise,
lime, and funding; participete in
relevant implementation actions
Educate the public and
inform constitu
of progress and ii
Citizen/environmental
groups
Ensure environmental protection
issues are represented in the pun
Attend meetings, perform
outreach, serve as watch dog for
planning process, panirtpaf* in
plan implementation
Educate the public and
inform constituencies
of progress and issues
Educational institutions
Ensure that scientific and other
educational information is
Provide subject area expertise
and perform outreach, technical
research, and momtoring
Make grants available
to support such
General Public
Attend public meetings/bearings
and other events about the Region
of Concern, Contribute ideas,
opinions, and information.
Become informed and serve as
•watchdogs'for plan
implementation. Maintain
political pressure. Take
personal responsibility tor
actions mat will improve
conditions in the Region of
Concern (e.g,, recycle,
use of hazardous
us).
Informing the public
early on and
throughout the process
is « good way to
majBtfiHi momentum
and pressure to ensure
implementation.
Exhibit 3-1 provides an overview of the types of key players likely to be active in the regional
action planning process. The exhibit outlines major roles and responsibilities and describes the interests
of these stakeholders, including lead agencies, other government agencies, industry and local business,
citizen/environmental groups, and educational institutions. Later sections of mis chapter describe a
process for selecting a balanced and representative Regional Action Team from these types of groups,
3.1 OVER VIEW OF THE LEAD AGENCY'S INVOLVEMENT
The lead agency is designated by the jurisdiction^) having a Region of Concent to oversee the
regional action planning process, including plan development and implementation. The lead agency's
responsibilities include establishing and coordinating the Regional Action Team, providing technical and
financial resources, and offering leadership for the regional action planning process. It if very important
that the lead agency be committed to die regional action planning process and work with the Regional
Action Team to gather support from elected officials.
3-4
-------
Regional Action Plan Guidance Conducting the Procen
The lead agency has a great deal of flexibility in choosing an approach for implementing the
regional action planning proem. Bearing in mind that the ultimate responsibility of the lead agency is
to deliver a Regional Action Han to the Chesapeake Executive Council by an established deadline, the
lead agency can use, or modify, one of several approaches depending on the level of public and
stakeholder commitment required to develop and implement me Regional Action Plan, and available
funding and other resources:
Maintain full responsibility for plan development, using the Regional Action Team in an
advisory capacity (e.g., reviewing and commenting on materials prepared by the lead agency)
Share responsibility with the Regional Action Team (e.g., Identify the various tasks needed
to complete the plan and divide responsibilities according to expertise and ability/willingness
to contribute)
Delegate all authority for plan development to the Regional Action Team (e.g., lead agency
may provide technical support, but Regional Action Team has full control in guiding the
planning process and making recommendations).
Regardless of the approach taken, it is essential to clearly define roles and responsibilities at the outset.
If the lead agency chooses to delegate some or all of its authority to an existing group, it might want to
develop a formal or informal memorandum of understanding clearly stating roles, responsibilities, and
expectations of the groups involved. If such clarification of roles and responsibilities is not offered early
in the planning process, involved parties, including Regional Action Team members, might become
confused, frustrated, and disillusioned with the process.
Experience suggests that the most effective approach is one of shared responsibility between the
lead agency and the Regional Action Team (Chesapeake Bay Program 1990; Davidson 1994; Harris 1994;
Schramik 1994; Shuyler 1994; Swiniiich 1994; Hartig et al. 1994), This approach is often successful
because it utilizes the technical and financial resources of the lead agency, while seeking the energy,
creativity, support, and commitment from the stakeholders who will ultimately determine the plan's
success. Regardless of the approach used by the lead agency, it is important mat adequate time be
allocated for plan research and development in order to generate a sound, credible, and implementable
plan. The lead agency, working with the Regional Action Team, should try to identify and seek
involvement from all significant stakeholders ami thoroughly understand stakeholder interests. The
Regional Action Team should also be given sufficient time and resources to conduct the decision-making
process needed to develop a sound implementation approach (e.g., identifying a complete range of
implementation actions, such as nonpoint source control techniques, pollution prevention plans, legislative
3-5
-------
Regional Action Plan Guidance Conducting the Process
changes, funding, public involvement). By following this process, it is more likely that the solutions
developed will be more acceptable to the team and innovative than a plan produced by a single agency.
3.1.1 Assembling an Effective Regional Action Team
One of the most important early responsibilities of the lead agency is to assemble an effective
Regional Action Team. Although many factors determine team effectiveness, it is of utmost importance
that the team be balanced and representative of key stakeholders in the Region of Concern. When
assembling the team, the lead agency may want to start with existing stakeholder groups (e.g., the
Anacostia Watershed Restoration Committee, the Elizabeth River Project) or develop a new group,
drawing members from existing stakeholder groups. As one of its first steps in the planning process, the
lead agency should conduct enough background research on the Region of Concern to identify groups
and/or individuals already active in the Region of Concern. Depending on the situation in the Region
of Concern, the lead agency should coordinate with existing stakeholder groups or active individuals, or
invite other involved parties (e.g., local governments) to join an initial selection committee (formal or
informal) to assemble the Regional Action Team. The lead agency, in conjunction with its partners hi
the Region of Concern (e.g., selection committee) should determine the size and structure of the Regional
Action Team and identify affected parties (i.e., persons/groups associated with or affected by chemical
contamination in the Region of Concern), key decision-makers, and subject matter experts to include as
participants on the Regional Action Team. When identifying groups and/or individuals to assist in the
Regional Action Team selection process, and again when identifying potential team members, it is
important to have the participation of individuals who adequately represent the wide variety of interests
of those affecting and being affected by chemical contamination problems hi the Region of Concern. It
is especially important to involve individuals and/or groups that will play lead roles in implementing the
Regional Action Plan. Section 3.1.2 of this guidance provides more specific direction on a process that
can be used to identify and select Regional Action Team members.
Although it is critical to include representative stakeholders on the Regional Action Team, it is
also important to keep the group size manageable—no more than 15 to 20 members are suggested
(optimal size is 7 to 15). This smaller number gives the group flexibility and allows it to operate in an
efficient manner. It also enhances the consensus-building process, which is essential to the ultimate
success of the Regional Action Plan. Although larger groups are possible, it becomes harder to ensure
equitable involvement from all team members, and the decision-making process may be more unwieldy.
If a group larger than 15 or 20 individuals is required, it may be necessary to form subcommittees (e.g.,
by source of pollution/land use category). To make drafting the Regional Action Plan workable, a
-------
Regional Action Plan Guidance Conducting the Process
drafting subcommittee, including approximately five members, may be formed. Alternatively, if
resources are available, it may be possible for the lead agency to provide staff and/or contractor support
to assemble background materials needed to develop the Regional Action Plan. If such "outside" sources,
or even a drafting subcommittee of the Regional Action Team, are used to prepare sections of the
Regional Action Plan, all stakeholders comprising the Regional Action Team should agree on the input
using a consensus-based approach. Section 3.5 hi this chapter ("Approaches to Building Consensus")
provides an overview of several approaches to building consensus.
Regional Action Team members should be enthusiastic and energetic about the planning process,
have leadership abilities, and be committed to the consensus approach to decision-making. Ideally, the
members should have technical familiarity with the issues facing the Region of Concern, but be involved
in management to the extent that they can influence the decision-making processes of the organizations
they represent. The members should also be able to speak with confidence about the feasibility of putting
the proposed implementation approach to work. It is important to involve both those who can contribute
to the planning process and those who can contribute to the implementation of the Regional Action Plan.
While it may be tempting to include only supporters of the regional action planning process on
the Regional Action Team, it is crucial to select team members representing all affected parties, especially
those that might be responsible for implementing a particular plan recommendation. By including
representatives from potentially resistant groups (e.g., a major contributor of chemical contamination)
in the early stages of the planning process, it may be possible to allay fears, build trust, and develop an
implementable plan that avoids potential pitfalls from the lack of cooperation and resistance that could
occur if affected parties feel excluded from the planning dialogue. When seeking to include members
from potentially resistant groups, it is helpful to identify individuals from those groups who will give the
process a chance, agree to use a consensus-based approach, and are willing to participate.
Exhibit 3-2 summarizes selected issues key to assembling an effective Regional Action Team.
If these concerns are considered and a strong commitment to a consensus-based process using stakeholders
is pursued, then it should be possible to develop a sound, implementable plan. However, there is no
guarantee that any one team will succeed. Participants should look for warning signs and avoid pitfalls,
such as those listed in Exhibit 3-3.
3-7
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-2. Key Elements to Establishing a Regional Action Team
Determine appropriate participants. Represent affected parties (i.e., persons whose use of the Region
of Concern is unpaired by chemical contamination and groups associated with chemical contamination),
subject matter experts, and key decision-makers. Ideally, participants should be able to represent groups
of affected parties (e.g., trade associations, coalition of several environmental organizations) rather than
individual entities (e.g., a single facility). Involve representatives from groups potentially responsible
for implementing aspects of the plan.
Select a team that is balanced and representative of all affected parties. One group should not dominate.
In most cases, it is inappropriate for more than one individual from a single entity to participate.
Identify affected parties and other potential Regional Action Team members by initially examining
available information on the nature of problems in the Region of Concern. After gaming a preliminary
understanding of problems in the Region of Concern, identify the types of affected parties associated
with each problem. Seek out existing organizations and/or individuals active in the Region of Concern
for advice on potential Regional Action Team members.
Identify enthusiastic, open-minded, and energetic participants who are committed to the consensus-
building process and have time to devote to developing a Regional Action Plan.
Avoid inviting people not affected by the objectives) of the Regional Action Plan. Also avoid
disinterested, unreliable individuals, and/or known meeting "disrupters."
Aim to have an adequate and balanced stakeholder group that is large enough to contain the knowledge
and opinions relevant to the planning task, but strive for a manageable group size. For decision-making
activities, the optimal group size is 7 to 15 participants. If more participants are needed, consider
establishing smaller subgroups.
Seek continuity of process and a balanced and representative group at all times by having team members
designate an alternate in case they are unable to attend a meeting.
Exhibit 3-3. Reasons Why Consensus Groups Fail
Failure to produce a plan that represents the interests of all significant stakeholders. This is often
caused when certain stakeholders, such as environmental groups, do not join the team. Groups who
do not join the team usually attack what they do not like in the draft plan when it is presented for lead
agency review or review by the governing body. Therefore, it is important to make every effort to
involve each significant stakeholder group in the process directly or indirectly (e.g., by becoming a
corresponding member who receives meeting notes and is contacted regularly for ideas and opinions).
Members walk away from the process or do not commit to the process. This is usually because team
members believe their interests can be represented better in another way (e.g., in court, directly with
elected officials). ~
The team fails to deliver a Regional Action Plan that is adequate to guide implementation. Without
clear goals and objectives and strong leadership, teams tend to produce vague plans that do not resolve
major issues (e.g., specific implementation tools, such as farm pollution prevention plans to control
urban and agricultural runoff).
The team loses momentum, thereby causing key members to abandon the process. Loss of momentum
is usually caused by inefficient and poor process management and getting bogged down on difficult
issues.
3-8
-------
Regional Action Plan Guidance Conducting the Process
3.1.2 Identifying Regional Action Team Members
Stakeholder groups, such as the Regional Action Team, should be balanced and represent key
decision-makers and affected parties (i.e., persons/groups associated with or affected by chemical
contamination) in the Region of Concern. To determine which stakeholders should participate in the
Regional Action Team, it is necessary to examine the nature of the chemical contamination problems in
the Region of Concern. The lead agency, La conjunction with a formal or informal selection committee,2
should assemble and analyze readily available information (e.g., written documentation, personal contact
with knowledgeable individuals) to develop a preliminary overview of problems in the Region of
Concern. This understanding of problems is the necessary first step for identifying parties affected by
or contributing to beneficial use impairment and/or other adverse effects of chemical contamination.
After understanding the problems, it is possible to link candidate stakeholder groups and individual
representatives of those groups to the problems. Each step of the process to identify Regional Action
Team members is summarized below:
Assess Nature of Problems—Lead agency, working with existing stakeholder groups and/or
individuals active in the Region of Concern, conducts preliminary investigations to determine
the nature of chemical contamination problems in the Region of Concern. Readily available
written material (e.g., technical reports, newspaper articles), supplemented by discussions
with informed groups or individuals, should be assembled and summarized.
Identify Stakeholder Categories to be Represented on the Regional Action Team-
Information on problems and sources of problems provide the basis for identifying the types
of stakeholders that should be represented on the Regional Action Team. The lead agency,
in consultation with other key groups and/or individuals, develops a generic list of
stakeholder categories (e.g., fishing industry, property owners, chemical industry,
environmental groups) that should be included.
Identify Actual Representatives from Generic Stakeholder Categories—The lead agency,
in consultation with other key groups and/or individuals, analyzes background information
to match specific names with stakeholder categories. A review of the literature, but more
likely personal knowledge/recommendations from groups and/or individuals already involved
hi the Region of Concern, will help to identify specific persons associated with each generic
stakeholder category. Efforts should be made to identify individuals that represent groups
of stakeholders (e.g., an industry association or business group that captures multiple
business/industry groups in the Region of Concern). It is important to avoid
duplication—there is no need for two or more representatives from any particular stakeholder
category; certainly not from the same location/facility/group.
*The lead agency may want to coordinate with existing groups and/or individuals (e.g., an existing stakeholder
group such as the Elizabeth River Project or the Anacostia Watershed Restoration Committee) active in the Region
of Concern, as well as other involved parties (e.g., local governments) to form a Regional Action Team Selection
Committee.
3-9
-------
Regional Action Plan Guidance Conducting the Process
Exhibits 3-4 and 3-5 provide an example of the process of identifying Regional Action Team members.
Exhibit 3-4 illustrates each step of the process, while Exhibit 3-5 displays a hypothetical list of
stakeholder categories developed from the example in Exhibit 3-4.
In addition to the lead agency, the likely stakeholders to be involved in the process include other
relevant local, state, and federal agencies; industry and other business organizations; citizen/environmental
groups; and educational institutions. Other organizations and individuals that may be stakeholders include
commercial and recreational fishing groups, landowners, homeowner associations, and community
organizations, such as civic groups and churches. Ethnic and minority group participation should be a
priority.
The ideal candidate for a Regional Action Team is enthusiastic, energetic, and committed to a
consensus-building planning process; has leadership abilities; is technically familiar with issues in the
Region of Concern and is a key decision-maker and/or connected to management so that he or she can
speak with some reliability and commitment about the organization's resources and ability to participate;
is willing to contribute to the planning process and/or plan implementation. It is important to match up
a region's problems with appropriate team members. For example, if contaminated dredging materials
are a problem in one area, the Regional Action Team should probably include representatives from local
ports and the U.S. Army Corps of Engineers. If urban nonpoint source runoff is a concern, the team
should probably include city planners, developers, and property owners. For regions affected by
agricultural runoff, agricultural stakeholders should be invited to join the team. Exhibit 3-6 lists potential
stakeholders representing various interests and matches them with associated problems.
If the lead agency is uncertain about whether to include certain stakeholders, it is possible to rank
potential stakeholders by their expected level of impact on the planning process, as well as by process
impacts on them. For instance, certain stakeholders may have more influence on the process than others.
Similarly, the outcome of the process (e.g., specific cleanup and funding commitments) may affect
stakeholders differently. Other ranking or selection factors include anticipated commitment to the process
and the expertise and skills the team requires. Because the regional action planning process occurs over
an extended period of time, may require participation in meetings and materials preparation, including
possibly drafting portions of the plan, it is important to select members—public and private—who have
the tune and resources to make this commitment. Because the Regional Action Plan will be a technical,
as well as a policy, document, the team should include scientists and engineers.
3-10
-------
Regional Action Flan Guidance Conducting the Process
Exhibit 3-4. Example of Procedure to Identify Participants
for the Regional Action Team
Assess Nature of Problems—Attaboy Creek was designated by the Executive Council as a Region of
Concern. The state Department of Environment was designated as the lead agency but is sharing
responsibility with an existing group, "Friends of Attaboy Creek." The Department of Environment,
working closely with Friends of Attaboy Creek leaders, assembled and reviewed all readily available
background materials. Reports developed by several State agencies and a local university documented
many ways that chemical contamination has affected the aquatic living resources in the Attaboy Creek
Region of Concern—straining the fish and shellfish populations, causing physical deformities, and
destroying the fishing industries. The background information, supplemented by several conversations
with university professors and State officials, suggests that most of the chemical contaminants are heavy
metals and organics. Given the land use and industrial base of the area, experts suggest that the
identified problems are most directly a result of industrial and manufacturing discharges, shipyard
discharges, and nonpoint source runoff from commercial and industrial areas. Preliminary research
summarized in the background material also suggests such linkages between problems and sources.
Identify Stakeholder Groups to be Represented on the Regional Action Team—After assessing the
background materials, the state Department of Environment and its partner, Friends of Attaboy Creek,
objectively identified the groups being harmed by chemical contamination (e.g., fisheries) and the
groups contributing to or responsible for sources contributing to chemical contamination (e.g.,
shipyards, municipal planners responsible for storm water control). The Department of Environment
and Friends of Attaboy Creek leaders compiled these stakeholder categories into a table (see Exhibit
3-5) to use as the basis for identifying actual representatives, (i.e., individual names) from the
stakeholder groups.
Identify Actual Representatives from Generic Stakeholder Group Categories—The lead agency in
consultation with other key groups and/or individuals, analyzes background information to match
specific names with stakeholder categories. A review of the literature, but more likely personal
knowledge/recommendations from groups and/or individuals already involved in the Region of Concern,
will help to identify specific persons associated with each generic stakeholder category. Efforts should
be made to identify individuals that represent groups of stakeholders (e.g., an industry association or
business group that captures multiple business/industry groups in the Region of Concern). It is
important to avoid duplication—there is no need for two or more representatives from any particular
stakeholder category; certainly not from the same location/facility/group. For example, John Doe may
represent an association of shipyards in the Region of Concern. Because he represents multiple
shipyards, he would be a good candidate for the Regional Action Team.
Available sources on potential stakeholders are extensive, including surveys of existing
stakeholder groups active in the Region of Concern; the Chesapeake Bay Program Directory, published
annually by the Chesapeake Bay Program Office; local Chamber of Commerce directories; industry
directories; lists of government agencies in the area; lists of individuals who have participated hi relevant
meetings/hearings organized by agencies (e.g., National Pollutant Discharge Elimination System [NPDES]
public hearings on draft permits, Chesapeake Bay Program Tributary Strategy hearings); and lists of
members of the environmental and conservation community (e.g., annually published National Wildlife
Federation Conservation Directory). Local planning documents, environmental impact studies, and
directories of local planning and economic development commissions may also be useful sources of
—
-------
Regional Action Plan Guidance
Conducting the Process
Exhibit 3-5. Example of a Stakeholder Category Table Used to Identify
Participants for the Regional Action Team
Stakeholder
Reason for Inclusion
Business/industry
Industry and manufacturing are the primary causes of the toxics problems
within the Attaboy Creek Region of Concern. Businesses are affected directly
by the success of industry. Involving these interests in the planning process
may help to develop a more easily accepted plan and may reduce opposition.
The main businesses and industry active in the Attaboy Creek Region of
Concern are marinas and shipyards, chemical manufacturing plants, and
petroleum refineries.
Citizen/environmental
groups
Citizens are affected daily by the conditions in which they live.
Environmental organizations exist to protect the interests of the citizens and
wildlife affected by the health of the environment. The primary citizens
groups are the Rotary Club, Jaycees, local garden clubs, and local Parent
Teachers Associations. The most active environmental organizations are the
Sierra Club and Friends of Attaboy Creek.
Federal government
Federal Government involvement is beneficial in the implementation of the
Regional Action Plan. The government has the ability to create and enforce
regulations, if necessary, as well as provide financial support for the effort.
The U.S. military plays the largest Federal role in the Attaboy Creek Region
of Concern, including the presence of the largest U.S. Naval shipyard. The
U.S. Army Corps of Engineers, U.S. Coast Guard, and U.S. Fish and
Wildlife Service also have large roles in the Attaboy Creek Region.
State government
State government is important in both the planning and implementation phases
of the Regional Action Plan. It has the primary responsibility for developing
the Regional Action Plan and also has the authority and financial resources to
facilitate implementation.
Fisheries
The fisheries and fishery industries have been the group most severely
affected by the chemical contamination problem in the Attaboy Creek Region
of Concern. The stress put on the fish populations has been excessive, and it
is the most obvious indicator of the problems existing.
Land owners/
home owners
Land owners and home owners are financially, physically, and aesthetically
affected by the health of Attaboy Creek. They also may be affected by
proposed actions to protect the river.
Local government
The local government represents individuals living in proximity to Attaboy
Creek. The government has control over zoning regulations and other
potential actions. There are four cities and two counties in the Attaboy Creek
Region of Concern.
Recreational/tourism
Attaboy Creek is attempting to develop a tourism industry that would greatly
benefit from the restoration of Attaboy Creek. Recreational users (i.e.,
pleasure boaters, sport fisherman, and swimmers) would also benefit from
cleaner and healthier waters.
Scientists/educators
Faculty from area colleges and universities may have knowledge and
information that would be useful in the development of the Regional Action
Plan. They can also assure that decisions are being based on accurate data.
3-12
-------
Exhibit 3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed
V
Restrictions on fish and wildlife consumption
Degradation of fish and wildlife populations
Degradation of phytoplankton/zooplankton populations
3ird and/or animal deformities or reproductive problems
Tainting of fish and wildlife flavor
Loss of fish and wildlife habitat
Restrictions on drinking water consumption
Restrictions on dredging activities
Sediment contamination
Water column contamination
Groundwater contamination
Added costs to agricultural/Industrial water use consumption
Beach closings
Aesthetics degradation
Sediment transport/erosion
Stormwater runoff/Combined Sewer Overflows
Urban runoff
Agricultural runoff
Atmospheric deposition of contaminants
Industrial discharges exhibiting acute/chronic toxlclty
Municipal discharges exhibiting acute/chronic toxlclty
Superfund sites
Hazardous waste transfer/storage facility
-------
Exhibit 3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed
Potential Problem
r
5.
^
I
Ci
FtshWte
RrtfaMheMshfe
FMehtumm
CJOIUBlR iDODOVJf
tostrichonson tthwid
yfcphrtaonttoatfrtiinn paputetens
BMi
LOSS ol fed «rfi
r us» consumption
SMrmwABr ftmoBConttinMl Sever Overflows
Utwn runoff
Wnosphenc daposto" o'
Industal dacha
acaWtftrorHc toxicity
Mu
— —*•
-------
Exhibit 3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed"'
Potential Probtem
Rsntdte
Fnfist»'s.l>et!fisf' its&je oonwninaton
Fin!is>i tumors
ms on shaKsn harv»siing
Degradation of banthic community
WatBr cofcjmn loxoty
Sediment Knot?
ftsti and t
Degractanon o! ftsh and i
of ptyiopliniaorvzoapianidDn poputamns
3rtJ aneWir wvnal detanntoes or reproduOi
Tamtng of fen and wfldSte tavor
Loss o» fcsh and wMHte habnai
ons on dnntang «Mar consumption
Wwer column oonaminMon
Added casts to agrioAiraMndiatrid
)SK£I closings
Kfcmann
sport*
runotVComtxfwd SvwwOwrthms
jvbv) njnofi
Aimosphenc deposition of contaminants
d»cfiaro*a er^tnp
diseharpes
aana'cfronic Pacity
sites
fantter'ao-aoe
-------
Regional Action Plan Guidance Conducting the Process
potential stakeholders. Interviewing key stakeholders or community leaders for recommendations is
another way to identify stakeholders.
3.13 Identifying Regional Action Team Leaders
It is critical to identify and cultivate leaders for a Regional Action Team. The most important
role for the team leaders is to work with the lead agency and its partner or designee to determine an
overall approach for the regional action planning process, including defining roles and responsibilities for
the Regional Action Team and establishing a schedule for completing each step of the process. It is
essential that the team leaders understand the goals and objectives of the regional action planning process
and are able to convey them to the Regional Action Team. The team leaders are also responsible for
running Regional Action Team meetings (e.g., ensuring the meeting agenda is followed and topics are
covered in a timely fashion), although they may be supported by other parties (e.g., professional
facilitator, lead agency.)
In a consensus-based process, like that envisioned for regional action planning, team leaders
should orchestrate, but not dictate, the process. Leaders contribute to the process by providing ideas and
information, offering approaches for continued progress, ensuring that the process stays on track and
encouraging enthusiastic participation and commitment. They should enjoy respect from the other team
members and not show bias when leading meetings, regardless of the interests they represent. In some
cases, if the team leader is qualified, he or she may also facilitate the decision-making and/or consensus-
building, portions of Regional Action Team meeting. However, if a leader wants to negotiate or
otherwise represent his or her interests, then facilitation responsibilities should be given to another team
member or outside facilitator.
Leaders for the Regional Action Team can be provided by the lead agency, selected from the
Team's membership, or obtained from an outside source. They all should be required to commit
substantial tune to the process and be enthusiastic about their commitment. Exhibit 3-7 summarizes
additional qualities of the team leaders.
To remove any perceptions of bias and to provide objectivity to the planning process, it may be
advantageous to use a professional facilitator for the decision-making and/or consensus-building portions
of Regional Action Team Meetings (e.g., developing evaluation criteria to select implementation actions).
Although some stakeholders may object to a facilitator because of concerns that a facilitator may inhibit
team members (e.g., hi terms of influencing the process or applying their own leadership skills),
3-16
-------
Regional Action Plan Guidance Conducting the Process
Exhibit3-7. Team Leader Qualities
• Is a significant stakeholder, but able to remain objective
• Is committed to a consensus-based process, not an autocratic one; is not overly directive in the effort
to reach agreement
• Makes time commitment to plan process and goals
• Is organized and energetic to help maintain momentum
• Contributes expertise and skills
• Offers leadership
• Has experience managing and facilitating meetings
/
• Is willing to contribute resources of organization (may not be possible for each member)
experienced facilitators, involve team members in leading and managing the process. For example, a
professional facilitator can periodically assign facilitation responsibilities to a team member. This may
give the facilitator a chance to evaluate the approach taken to date and plan the next step in the process.
The facilitator should have experience in applying a consensus-based approach to solving environmental
problems. Although specific knowledge of the technical issues regarding watershed restoration is not
necessary, the facilitator or facilitation team can also contribute to the process by providing briefings on
background information, such as concept papers or fact sheets, and organizing meeting notes. If a team
does not have access to a professional facilitator, a facilitator could be chosen from the team or provided
by the lead agency. The ideal candidate has leadership abilities, experience successfully facilitating
similar meetings, and an understanding of the regional action planning process. If a non-professional
facilitator is used (e.g., someone is appointed from the team), it is recommended that the facilitator and
as many team members as possible attend a training workshop on consensus-based decision-making. This
training should be sponsored by the lead agency.
3.1.4 Obtaining Management Support
The goal of any regional action planning effort is to develop an implementable plan mat will
effectively reduce and prevent problems associated with chemical contamination in a designated Region
of Concern. To be successful hi meeting this overall goal, a plan must have a committed management
and staff. Individuals believing in the concepts of regional action planning and the proposed
implementation approach must exist at all levels, from top management to the staff person(s) who are
ultimately responsible for implementing the plan recommendations. The lead agency must provide this
level of commitment because it is responsible for initiating the regional action planning process, ensuring
—
-------
Regional Action Flan Guidance
Conducting the Process
development of the plan, and providing long-term oversight of the implementation actions. Committed
management can ensure continued involvement throughout the regional action planning process by
directing staff and financial resources; obviously, interest and commitment from the highest levels of
management can have the greatest impact. Ideally, the senior agency official responsible for the Regional
Action Plan should attend the initial meeting to explain the purpose and importance of the regional action
planning activity, the role of the Regional Action Team, and the commitment of the lead agency. Better
yet, demonstrated support from elected officials will lend credibility to the process. Team members will
be more likely to commit to the planning process if they know that h has the support and commitment
from the lead agency's management and/or elected officials. This type of high-level support will lend
credibility to the planning process; give team members a heightened sense of purpose that their efforts
are important, needed, and will be considered; and may foster greater involvement and cooperation from
team members.
Because proposed implementation
actions are likely to involve multiple groups
(government agencies, affected parties such as
industry), management and staff support and
commitment from these groups are also
critical. Another key role of the lead agency,
supplemented by the Regional Action Team,
is to provide education and outreach to these
groups to ensure mat they have a clear
understanding of the overall goals of the
Regional Action Plan and their roles and
responsibilities in implementing proposed
actions. The groups should be trained in the
importance of the regional action planning
process and the implementation actions to
which they are charged.
Importance of Government Cc
rifa
it
Remedial action planning in the Gteat Lakes' Ash tabula
River, Ohio, benefited greatly from demonstrated
support from top level agency management and elected
officials. After years of perceived Inaction addressing
severe environmental problems, demonstrated by the
lack of actual cleanup actions, the public greeted the
first public meeting of the remedial action planning
process with cynicism. However, Olio EPA continued
to stress the importance of public involvement at all
stages of the planning process. As well, Ohio EPA and
Ohio State Senator Robert Boggs invited community
memoes to a wfttfag to discuss envtfonmental
problems of the AshtabnJa Area of Concern, the
remedial action planning guidelines, ""** its plan to
establish local input at the earfy stages. The
involvement of the well-respected local government
official, plus the demonstrated commitment of Ohio
EPA, influenced the eventual active participation of
many local citizens and community leaders (Lettethos
1992).
In a geographically based approach to chemical contamination prevention and reduction such as
that envisioned for Regions of Concern, many different actions, focused on a variety of pollutant types
and sources, often occur simultaneously. To ensure smooth, consistent implementation of the plan, it is
helpful to have an enthusiastic plan coordinator. The Regional Action Plan coordinator should be
3-18
-------
Regional Action Plan Guidance Conducting the Process
affiliated with the group responsible for writing the final plan and delivering it to the Executive Council
(generally this group is the lead agency). An ideal coordinator will be an enthusiastic, organized, and
knowledgeable community member, who has the authority to make the recommended changes and who
is provided the financial and technical resources to complete his or her job.
3 J, OVERVIEW OF THE REGIONAL ACTION TEAM'S INVOLVEMENT
As described in Section 3.1, the type and level of the Regional Action Team's involvement in the
regional action planning process will vary depending on the planning approach selected by the lead
agency. If the lead agency chooses to maintain full responsibility for plan development, then the Regional
Action Team's role is somewhat limited to reviewing and commenting on material prepared by the lead
agency. On the other hand, the lead agency may delegate all authority for plan development to the
Regional Action Team. In mis scenario, the Regional Action Team is responsible for assembling and
evaluating background materials and developing draft chapters of and recommendations for the plan.
The Chesapeake Bay Program recommends an approach of shared responsibility between the lead
agency and the Regional Action Team. This type of approach, involving participation of both parties,
is successful because it draws upon the technical and financial resources of the lead agency, while still
involving stakeholders in decision-making and consensus-building so that buy-in and commitment to the
plan is achieved. One way to implement mis approach of shared responsibility is to have the lead agency
develop relevant background materials and options papers to be used as the foundation for a facilitated
consensus-building process involving the Regional Action Team. Background papers provide an overview
of the issue, while options papers suggest choices of language for the plan and/or plan recommendations
(e.g., implementation actions). Section 3.5 of this chapter describes this process hi more detail.
It is essential for the Lead Agency and the Regional Action Team to decide early in the planning
process how they want to approach development of the Regional Action Plan, including defining
appropriate roles and responsibilities for each step of the process. The approach should be mutually
decided and understood by all parties in order for the planning process to proceed effectively.
Recognizing mat the exact approach to conducting the regional action planning process will be unique
to each Region of Concern, the Regional Action Team should be involved hi the development of the
Regional Action Plan at least to the following extent:
• Evaluating background materials
• Providing expertise and input for the plan (e.g., technical materials, recommendations for
sources of material and contacts)
3-19
-------
Regional Action Han Guidance
Conducting the Process
• Supporting the decision-making process required for effective plan development.
The Regional Action Team's most important role is that of participating in the decision-making process.
As discussed throughout this guidance document, the regional action planning process, and final plan,
must be streamlined and focused on priority issues so that limited resources are effectively used.
Therefore, many of the steps needed to complete the plan involve decision-making about priorities (e.g.,
What are the most important adverse ambient effects? What chemical contaminant types and sources are
the greatest concern? What implementation actions should be pursued first?). The Regional Action Team
should be involved in all decision-making aspects of the plan. In fact, many of tasks toward developing
the Regional Action Plan should be accomplished in a consensus-building framework, where the affected
parties (stakeholders) are represented by the Regional Action Team.
The remainder of this section further describes the anticipated involvement of the Regional Action
Team hi the planning process. The information is presented in the following subsections:
• Identifying stakeholder interests
• Evaluating environmental problems and establishing goals and objectives
• Evaluating existing management programs
• Determining implementation actions.
3.2.1 Identifying Stakeholder Interests
The interests of stakeholders participating on the Regional Action Team should be identified as
soon as possible, perhaps as early as the initial team meeting. The information gained in this process will
help team members understand each other's motivations, as well as the interests that lie behind any
positions that might be taken in the planning process. This information can foster an open and honest
dialogue.
It is important that team members not
judge or evaluate interests—every interest
represented by a stakeholder should be welcomed
and recorded. The interests generally pertain to
human health and the environment, as well as to
economic and social issues. The team should
make every effort to represent non-human
environmental interests.
, v,^
Positions represent A group's at
UL ucvtatuu ouvuirou. ipauo, wupremt tiitcreBiasmp UIB
underlying concerns that helped form the1 position;
For example, a group's position coufdlbe lhat feey
want to ban new industries from being allowed W
directly discharge to a Region of ConcercL: while
their Interest is
fishery (fisher and XJiy
3-20
-------
Regional Action Plan Guidance ' Conducting the Process
Planning processes can deteriorate at this early stage because people may try to alter or question
other stakeholder interests or because they do not have the patience to spend a few hours or a day
identifying and understanding interests. If the team moves through this step efficiently, however,
participants will have valuable information for later in the process. When negotiating recommendations,
for example, it is necessary to consider the relationship between a stakeholder's position and his or her
interests. If the position a stakeholder chooses threatens team consensus, team members should consider
whether the position is consistent or inconsistent with the stakeholder's interests. If it is inconsistent,
team members should ask the stakeholder to consider whether his or her interests can be satisfied in a
different way. For example, if a stakeholder's position is that it is necessary to ban new industries from
directly discharging to the Region of Concern but their interest is in restoring a recreational fishery,
perhaps the interest could be achieved through a means other than a ban (e.g., modification of existing
NPDES permit limits to be more stringent). This kind of situation underscores the importance of
understanding stakeholder interests early in the process.
During each Regional Action Team meeting, information such as stakeholder interests, common
interests, and conflicting interests, as well as the agenda for the next meeting, should be recorded on flip
charts and distributed as notes between meetings.
3.2.2 Evaluating Environmental Problems and Establishing a "Vision Statement, Goals and
Objectives
/»
During this initial i^poblem identification stage, the
team and lead agency could sponsor activities to
educate and seek input from the public at large on
the nature and scope of the
/?Ibese activities should include
discussions, and citizen surveys, such as
or telephone surveys to assess the public's
atvarawss aiulperceptionSiof ihe issues involved.
The early stages of the regional action
planning process should focus additional
investigations on priority problems. An effective
Regional Action Plan will be streamlined and
targeted on the primary sources of chemical
contamination identified as contributing to priority
problems. In order to prioritize problems for
action, the Regional Action Team must have a sense of the vision, goals, and objectives it hopes to
achieve in the Region of Concern. The process of identifying and prioritizing problems, including
sources, and determining a vision statement, goals, and objectives is iterative—as the Regional Action
Team develops its information base on problems, goals and objectives might become apparent. Likewise,
achievement of goals and objectives might clearly require focus on specific problems and chemical
sources.
3-21
-------
Regional Action Flan Guidance Conducting the Process
The Regional Action Team should be involved in all phases of the decision-making processes to
identify and prioritize problems, including chemical contaminant types and contributing sources. The
team is also integral in establishing the plan's vision statement, goals, and objectives. The results of this
process will not only guide plan development, but will provide much of the written portion of the final
plan. Early consensus by the team on these topics can be developed from a general understanding of die
problem (i.e., why the area was designated as a Region of Concern), supported by readily available
information, including written materials (e.g., newspaper articles, research documents, and other technical
reports), consultation with individuals familiar with die Region of Concern, and material? acquired and
generated by me Chesapeake Bay Program when identifying the particular Region of Concern. This base
level of information will provide the necessary background needed to stimulate the team to further
characterize the problem and begin establishing goals. madditk)ntoparti(^>atmgmthedeciskmHnaking,
the team is expected to evaluate materials and provide technical support, as necessary. Chapters 4 and 5
of this gniHaiyy- document provide more detailed information on establishing the plan's vision statement,
goals, and objectives (Chapter 4) and evaluating environmental problems (Chapter 5).
3.2.3
The most successful actions to reduce the impacts of chemical contamination in Regions of
Concern are often developed by evaluating and modifying existing approaches. Therefore, the thorough
evaluation of existing management programs, including regulatory and nonregulatory approaches (e.g.,
NPDES permit compliance, pollution prevention) is an important and essential prerequisite for developing
an implementation approach. The Regional Action Team should play an integral role in identifying and
management programs.
Chapter 6 of this gokfanre defines an approach for evaluating existing management programs.
The lead agency would likely spearhead these evaluations, supported by Regional Action Team members.
The investigations must include an assessment of regtilatory and nxmregulatory approaches and activities
taken by government agencies and non-governmental organizations. A weft-selected Regional Action
Team could provide the majority of information needed for these investigations. It is expected that
Regional Action Team members representing different stakeholder groups (e.g., government, industry,
environmental organizations) could report on key programs and/or provide a list of additional contacts
for consultation. The Regional Action Team would also determine the criteria to guide the evaluation
(Le., die basis for measuring effectiveness). Once the evaluation b complete, me Regional Action Team
would review the results, determine if ad^frVmai investigations were needed, and consider which existing
management measures should be considered as potential implementation actions.
_
-------
Regional Action Plan Gtadojice _ Conducting the Process
The git""**? effectiveness of a Regional Action Plan hinges on developing effective
implementation actions. Chapter 7 of this guidance outlines a procedure to identify and select
implementation actions. The Regional Action Team plays a critical role in determining these actions.
Because of their importance in determining overall plan effectiveness, it is essential that sufficient time
be allocated to identify, research, and rank potential implementation actions; generally, me Regional
Action Team needs at least 2 fidl meeting days to evaluate and select implementation actions.
Although the lead agency may assemble die background materials needed to evaluate potential
actions, the Regional Action Team wfll be involved in most steps of the process— brainstorming about
potential actions, providing background information, volunteering to conduct additional research if
needed, and developing criteria to evaluate die suitability of actions.
One of the first steps involves developing an organized inventory of potential implementation
actions. The facilitator/team leader should first poll the team on suggested approaches for organizing
actions. Tndnthk, Jrm^heanpinntiMefiwtfagti^ Attirm Wan
and to structure the actions accordingly (e.g., by pollution source category).
Once the team identities a loose structure for the implementation actions, team members should
"brainstorm" to identify actions within each category (e.g., point source actions, nonpoint source actions,
actions directed at urban areas, actions directed at marinas). The team should develop as many actions
as possible without jading them. When developing actions, it is important for die team to be innovative
and creative in attempting to address stakeholder interests. In addition, it is important to carefully
evaluate existing management approaches in the Region of Concern, as well as proposing new ones, ft
is especially important to consider existing laws and policies; a priority of the planning process should
be to evaluate compliance and enforcement effectiveness. The team should al«n ufofrify. gaps hi grating
laws, programs, and policies so that effective new solutions can be developed.
After developing a list of potential implementation actions (this may take a few meetings), the
Regional Action Team most former refine and organize these options. The team may want to establish
specific criteria, such as *?**T"r?> feasibflky, cost, financing, and public acceptability, to determine
whether an action is appropriate and, therefore, a candidate for further evaluation (see Chapter 7). The
Regional Action Team should work closely with the lead agency to identity evaluation criteria. These
criteria must be well understood by all team members. Although each Regional Action Team may
_ ___
-------
Regional Action Plan Guidance _ Conducting tke Process
develop its own evaluation criteria, it is important that the selected criteria enable die team to narrow its
comprehensive list of potential actions to a manageable size for former consideration.
Regional Action Team members or subgroups/workgroups of me Regional Action Team, working
with the lead agency, can be charged with further evaluating and detming promising actions between team
mrrrmgs. Meetings will be more productive and time efficient if the team members have this background
prior to the
Daring this phase, the Regional Action Team should also evaluate implementation actions with
respect to identified stakeholder interests. The team should try to move toward me action that best meets
its diverse interests, reminding fitakfholdm mat the option is probably better than the alternatives that
would result if an agreement could not be reached,
Strong leadership is essential to timely and complete closure on an issue. Closure entails a mil
and accurate transcription of recommendations and commitments, as well as assurance that each
commitment can be fulfilled. Recommendations should be as thorough as possible and should be related
to specific evaluation criteria. The Regional Action Team should work with the lead agency and other
responsible groups to ensure that final impiementatkm actions are fully described and address the
following questions:
• Who is responsible for implementation?
• What actions are necessary to implement the plan?
• Where should the implementation activities be targeted?
• When should actions be taken?
• How should actions be implemented?
^
The team should organize its final recommendations ii*o me format of me Regional Action Plan.
The lead agency (and responsibie agencies, if possible) should be prepared to assist the team m compiling
the plan. The draft plan, including implementation actions, should be made available to the team for
review and comment before submittal to the general poMic and any governing agency (e.g., Chfsapfakf
Executive Council) for review, comment, and adoption,
3-24
-------
tbgumal Action Plan Guidance _ Conducting the Process
33 DEVELOPING A WOBK PLAN
h u important that the approach to regional action p4anningandcoittCJmi*-baildirigbeestaWtsbed
near Ac beginning of the planning process, ideally before the fimmeetmg of the Regional Action Team,
so mat it can be thoroughly described to all participants in the planning process. In addition, the roles
and responsirilitie* of the lead agency, team leaden, team members, and other participants (e.g., a
facilitator) should be clarified.
Frequently, planning activities, including ittafrfJMdf meetings to build consensus, suffer from
a lack of focus and an unspecified game plan. A perception of disorganization and a lack of clearly
defined goals and objectives can severely hurt the regional action planning process and die development
of an tmpienientabie plan. In the early stages of the regional action planning process, k is important to
clarify the overall purpose of the planning activities, identify an approach to the planning process,
determine a sdifdnlr and planning milestones, and define the roles and responsibilities of participants.
The lead agency, in conjunction with an existing stakeholder group Of applicable, should the lead agency
choose to delegate some or an of its authority to such a group), and Regional Action Team leaden, may
want to draft a work plan to guide the planning process. At a minimm^ the work plan should:
• Provide an overview of me approach mat win be used to conduct the planning process (e.g.,
use of a professional facilitator, mrthod* used to make decisions and build consensus)
• Identify roles and responsibilities for doe planning process
• Outline potential meeting agendas, including anticipated decision pomts, for the Regional
Action Team
• Present a srhrdnlr for planning activities (je.g., proposed mrrrings, draft matfrials, and plan
completion).
A work plan provides the basis, or road map, for the regional action planning process. It ensures that
all participants understand the anticipated process from the beginning, and contains a schedule to keep
the process moving in a timely manner. The work plan is intended to serve as a guide only— it is not
cast m stone, and should be reviewed throughout the process and revised as necessary. Exhibit 3-8
actJvftiCT that sfagnld occur during the- dfvftopmfnt of the Regional Action Plan and
should be addressed in the work plan. These activities are tied to hypothetical Regional Action Team
minings. The exhiritpresentt information on proposed agendas for each meeting, as well as suggestions
for background material* needed to prepare the Regional Action Team for the meeting and «"gg»f*V*tt
^prodoct^oitfcomestobegerieratedfromthenieetings. This information is presented as guidance and
3-25
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process
Materials Distributed in Advance
• Agenda
• List of team members
• Background materials (summary materials describing planning process, Region of Concern; draft work plan; fact
sheet summarizing existing information on problems; draft language on vision statement, preliminary goals and
objectives)
Suggested Agenda Topics {Responsible Party]
• Welcome [Lead Agency]
• Introductions, including statement of participant's interests, and personal goals and objectives for the process [Team
Leaders]
• Background Presentations
- Overview of the Planning Process [Lead Agency]
- Roles and Responsibilities [Lead Agency, Team Leaders]
- Preliminary assessment of problems [Lead Agency, Invited Speakers]
- Overview of existing activities, including assessment of current actions by representative
stakeholders (e.g., success stories) [Lead Agency, Invited Speakers]
- Meeting ground rules [Lead Agency, Facilitator]
• Present work plan and describe approach for Regional Action Team. [Lead Agency, Team Leaders]
- Procedures (e.g., use of a facilitator; development of background papers)
- Roles and responsibilities
- Desired final product
- Anticipated schedule
• Seek agreement on work plan and team approach. [Lead Agency, Team Leaders]
• Discuss need for public participation. Seek volunteers to develop public particq>ation strategy. [Lead Agency, Team
Leaders]
• Review presentations and other existing background information on problems with goal of beginning prioritization. If
materials are distributed in advance of meeting (at least one week), it may be appropriate for group to reach
faMH»at««i consensus on problem statement and prioritization of problems for consideration. If advance distribution is
not possible, use meeting to introduce materials and prepare Regional Action Team for next meeting. (Team
Leaders, Facilitator]
• Present draft language on vision statement, preliminary goals, and objectives. If distributed in advance of meeting (at
least 1 week), it may be appropriate for group to reach facilitated consensus on preliminary goals and objectives. If
advance distribution is not possible, use meeting to introduce materials and prepare Regional Action Team for next
meeting. [Team Leaders, Facilitator]
Products To Be Generated From Meeting
• Problem definition and prioritization Of materials distributed in advance and adequate time allowed to discuss)
• Vision statement, preliminary goals and objectives (if materials distributed in advance and adequate time allowed to
discuss)
• Summary of participants interests and desired outcomes
• Finalized work plan
• Meeting evaluation
3-26
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process
(continued)
Meeting #2
Materials Distributed in Advance
• Agenda
• Meeting highlights
• Background materials (background reports on sources of problems, existing management approaches)
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. [Team Leaders]
• Seek consensus on problem definition and prioritization. [Facilitator]
* Seek consensus on preliminary goals and objectives. [Facilitator]
* Present more detailed problem definition, including chemicals of concern and sources of concern. Present evidence,
to date, linking sources to problems. If evidence is sufficient, and/or if team has had time to review materials,
begin to prioritize sources for action. Develop criteria for identifying priority sources.1 [Team Leaders, Lead
Agency, Facilitator, Invited Speakers]
• Present results of evaluation of existing management measures. [Team Leaders, Lead Agency, Facilitator, Invited
Speakers]
Products To Be Generated from Meeting:
• Products mat must be completed from first meeting:
Final problem definition and prioritization
Vision statement, preliannary goals and objectives
• Preliminary ranking of priority source categories.
* List of action items for next meeting.
• Meeting evaluation.
Meeting #3
Materials Distributed in Advance
• Agenda
• Meeting Highlights
• Background materials (final report summarizing sources of chemical contamination; preliminary list of
implementation actions based on preliminary ranking of source categories).
Suggested Agenda Topics
* Conclude unfinished business from previous meetings. [Team Leaders]
• Present additional information linking sources of chemical contamination to priority problems. Discuss sources of
chemical contamination. Develop final ranking of sources based on evaluation criteria. [Team Leaders, Lead
Agency, Invited Speakers, Facifitator]
• Evaluate preliminary goals and objectives. Modify as needed to reflect new information. [Facilitator, Team
Leaders]
ft if important to remember mat die Regional Action Flan's ultimate goal is to pram m nnpkmeatatian approach for addressing problems
caused by chemical cootaminatioa in a designated Region of Concern. The analyses conducted for the planning process should always bear mis got! in
mind so that limited resources can be utilized effective^. It is useful to streamline the planning approach by focusing on priority problems and sources
of problems. Once priority problems and sources are identified, farmer jnvestigatkau should be fbcuaed oo mosc areas.
3-27
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process
(continued)
• Review work plan. Determine if work plan needs to be modified. [Facilitator, Team Leaden]
• Report of approach and results for identifying implementation actions.2 [Lead Agency, Team Leaden, Invited
Speakers] '
Products to Be Generated from Meeting
• Final ranking of priority source categories
• List of action items for next meeting
• Meeting evaluation. ^
Meeting** %V 4.
Materials Distributed in Advance
• Agenda
• Meeting highlights
• Background materials (reports presenting comprehensive list of implementation actions by source category, including
qualitative information needed to evaluate and prioritize actions)
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. [Team Leaden]
• Present research on implementation actions. [Lead Agency, Team Leaden, Invited Speakers]
• Select implementation actions to be pursued further. [Lead Agency, Team Leaden, Invited Speakers]
Products To Be Generated from Meeting
• Short list of implementation actions to be evaluated in more detail.
• Meeting evaluation
Meeting 15
Materials Distributed in Advance
• Agenda
• Meeting Highlights
• Background materials (final report on implementation actions, outline and materials prepared to date for final plan)
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. [Team Leaden]
• Review status of implementation actions. Seek implementation commitments. [Team Leaden, Invited Speakers,
Facilhaton]
• Discuss presentation of final plan (it is appropriate throughout the planning process for the lead agency and/or a
drafting subcommittee from the Regional Action Team to prepare draft chapters of the plan for distribution, review,
and comment). (Team Leaden, Lead Agency]
• Determine schedule for additional meetings, if necessary. {Team Leaden]
Products to Be Generated from Meeting
• Approach, including assigned responsibilities, for preparing final plan and securing commitments for implementation
actions.
• List of remaining action items and next steps.
• Meeting evaluation.
2Whea developing implementation actions, it if important to focus on priority problem* tod source*. Abo, the level of detail needed in the
——meat shoakl be limited to that required for sound decjrioo-makmg(e.t., a qualitative analysis may be all that is needed for the purpose of narrowing
list of potential onplementatioa actions to those that should be pursued in more detail for me final plan). Excess analysis should be avoided.
3-28
-------
Regional Action flan Guidance _ Conducting the Process
should be modified to suit the unique needs of the Region of Concern. As discussed in more detail in
Section 3.4, it is important to set aside sufficient time during the meetings to adequately cover each
agenda topic.
3.4 CONDUCTING EFFECTIVE REGIONAL ACTION TEAM MEETINGS
Successful regional action planning depends largely on effective stakeholder involvement so that
parties affected by and contributing to chemical contamination problems in the Region of Concern feel
an important part of the process, gain a sense of ownership to the plan, and commit to the proposed
implementation actions. Since the Regional Action Team is the main forum for involving stakeholders,
it is important to conduct effective Regional Action Team meetings. The efficiency and effectiveness of
Regional Action Team meetings depends on an organized approach with clearly defined roles and
responsibilities for all participants, a well-planned meeting schedule that accounts for all phases of plan
development, and clearly articulated meeting agendas and approaches to developing me plan. Without
these elements, the chances of conducting a successful regional action planning process are greatly
reduced, as:
Confusion over roles and responsibilities may result in a duplication of efforts and/or gaps
in responsibilities.
Meetings may lose focus, become rambling discussions, or are side-tracked, so that concrete
action items are not developed.
Participants may become disinterested and discouraged because they feel mat they are not
accomplishing anything (not a part of the process) or they lose sight of the overall purpose
and end goal of the planning process.
The resulting plan may lack focus and/or may not adequately represent stakeholder groups.
It is important to ensure that the overall meeting schedule, and individual meeting agendas, allow enough
time for the consensus-based process to occur. The Regional Action Team must reach consensus on
many issues throughout the planning process— vision statement, goals, and objectives; problem definition
and prioritization; and implementation action selection. In order for the team to feel a legitimate part of
the planning process, it is necessary for them to have time to review background materials, formulate
their ideas, and discuss their opinions in a facilitated process. The amount of time needed for these
activities varies, depending on the complexity of issues being addressed and the size of the Regional
Action Team. In general, a facilitator needs at least 2 to 3 hours per issue (e.g., identifying goals and
objectives) to effectively work with the Regional Action Team. The length of each team meeting should
-------
Regional Action Plan Guidance Conducting the Process
be adjusted to reflect the number of issues being addressed. In many situations, it works well to have
the Regional Action Team meeting run from mid-morning to early afternoon (e.g., 10:00 a.m. to 3:00
p.m.), with a break for lunch. This structure enables the morning session to cover background material,
gives the team members time to discuss information and formulate opinions during the lunch break, and
saves sufficient time for facilitated decision-making in the afternoon. The lead agency and team leaders
should work closely with the facilitator to block off appropriate amounts of tune for each topic.
The importance of clearly defining meeting roles and responsibilities, in terms of who is
responsible for which parts of the meeting and how the meeting will be conducted, cannot be
overemphasized. An effective Regional Action Team meeting must have a designated team leader or co-
leaders and a balanced and representative group of participants (i.e., team members) representing key
stakeholders. In addition, it is recommended that a facilitator conduct portions of the meeting and a
meeting recorder provide notetaking and other support for the meeting. The appropriate roles and
responsibilities for participants in Regional Action Team meetings (i.e., team leaders, team members, lead
agency, facilitator, and recorder) are defined in Exhibit 3-9. The lead agency can remain active hi the
planning process by providing technical support and/or facilitation expertise, if possible. Frequently, it
helps to have an outside facilitator to build trust among all meeting participants, so they do not perceive
a hidden agenda. For this reason, it is also advisable that the Regional Action Team leader(s) be someone
other than the lead agency. However, the lead agency is a valid stakeholder in the planning process and
should appoint a member to the Regional Action Team.
Just as it is important to have clearly defined roles and responsibilities among planning
participants, it is also necessary to have clearly articulated meeting agendas and approaches. The lead
agency, its partner or designee (e.g., existing groups), team leaders, and the facilitator should work
together to develop effective meeting agendas and approaches. Sometimes this process can be guided
through the joint development of a work plan to guide the planning process (see Section 3.3). Regional
Action Plans are developed from the evaluation of different types of information, as well as substantial
input from the Regional Action Team and the general public. To effectively synthesize the information
in a timely and efficient fashion and to ensure that all parties are adequately represented requires an
organized meeting approach. Without an organized approach, meetings and/or the planning process can
get side-tracked, result in time-consuming, unfocused discussions, and potentially not achieve the goals
of the planning process.
3-30
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-9. Roles and Responsibilities—Regional Action Team Meetings
Team Leader or Co-Leaders
Establish meeting objectives and plans and are responsible for the overall direction of the meeting
Clarify participants' roles and responsibilities
Start meeting on time
Provide introductions, summarize meeting objectives and agenda items, and define roles and responsibilities
Work with facilitator to ensure meeting agenda is followed in a timely manner
Participate as group members
Summarize key decisions and actions
Team Members
Generate ideas, analyze information, provide technical input, make decisions, and implement action plans
Review agenda and other meeting materials before attending meetings
Conduct enough pre-meeting background research to participate effectively in the meeting
Know purpose of meeting ahead of time and do "homework" if necessary to prepare
Confirm attendance and delegate an alternate if cannot attend
Attend meeting on time
Keep an open mind, avoid premature judgment, and try to understand other perspectives
Help facilitator "liir""**" distractions and encourage active involvement
Speak up; share useful ideas
Support ground rules and other meeting guidelines
Participate in a timely fashion
Volunteer for tasks only if capable of following through
Agree to particyate in consensus-building exercises
Lead Agency
Provides technical and financial support
Schedules meetings
Prepares draft agenda
Provides background materials for the meeting
Participates as a team member
Facilitator
Manages how people work and communicate in the meeting
Is responsible for flow of the meeting
Coordinates with Regional Action Team leaders and lead agency to acquire any needed background or other
preparatory information
Reviews planned agenda and action items
Ensures meeting runs smoothly
Reviews team's ground rules
Focuses the group
Monitors and regulates participation
Evaluates effectiveness of process and suggests alternative methods and processes as necessary
Protects people from "attack" and deals with problem people
Remains neutral at all times, particularly during disagreements
Recorder
Keeps track of important information throughout the meeting, prepares flip charts and other necessary visual
aids during the meeting, and prepares post-meeting summaries and action Hems.
Prepares necessary meeting summaries, highlights, and other materials.
Captures ideas visually without editing or paraphrasing.
Checks to ensure that appropriate information has been recorded; obtains clarification from the participant if
needed.
Helps leader and facilitator keep track of information.
Produces meeting summaries, highlights, and other materials.
Source: Adapted from Chang and Kehoe (1994)
3-31
-------
Regional Action flan Guidance Conducting the Process
Many references exist that summarize the elements of productive meetings, including preparing
the meeting, conducting the meeting, and evaluating the meeting (Chang and Kehoe 1994; Doyle and
Straus 1976; Fisher and Ury 1991). Exhibit 3-10 summarizes some basic considerations for conducting
effective meetings in the context of regional action planning.
Exhibit 3-10. Basic Considerations for Conducting Effective Regional Action Team Meetings
• Determine appropriate participants (e.g., subject matter experts, key decision-makers, and affected
parties, not unaffected parties and known meeting "disrupters").
• Ensure continual and balanced representation. Primary team member should select alternate if he/she
cannot attend.
• Clearly define and reach agreement on roles and responsibilities for all meeting participants, including
meeting leaders, meeting facilitator, recorder, Regional Action Team members, and lead agency.
Define and maintain roles and responsibilities from the beginning to end of the process.
• Fully consider each stage of meeting development: (1) Preparing for the meeting, (2) Conducting the
meeting, and (3) evaluating the meeting. No stage should be ignored or minimized.
• Develop a well-thought out agenda providing the following information: meeting objectives, logistics,
anticipated attendee list (defining leader, facilitator, recorder), roles and responsibilities, action items
(i.e., list of items that must be covered to achieve meeting objectives), and allocated time.
• Reach agreement on approach to planning process, including meeting schedules, ground rules, and
guidelines.
• Distribute necessary background materials to meeting participants sufficiently in advance of the meeting
• Keep meetings focused on priority issues. When wolfing decisions, develop a variety of options from
which to prioritize using a consensus-based set of objective evaluation criteria.
• Allow sufficient time to cover the subject adequately and build consensus, if necessary.
• Avoid getting bogged down in details. Investigations are designed to support the development of sound
implementation actions. Detail beyond that needed for the purpose of developing implementation actions
may be superfluous.
• Ensure open and balanced participation from all participants.
• Strive toward consensus-based decision-making.
• Produce meeting summaries and progress reports to ensure that the overall planning process remains
focused toward its end goal.
• Evaluate the meeting to ensure that participants are satisfied with the approach.
Sources: Chang and Kehoe (1994); Fisher and Ury (1991); Chechile and Carlisle (1991); Doyle and Straus (1976)
3-32
-------
Regional Action Plan Guidance Conducting the Process
3.5 APPROACHES TO BUILDING CONSENSUS
An effective Regional Action Plan will be developed using a consensus-based process involving
major stakeholders represented through the Regional Action Team. This type of process, which ensures
that all parties are heard and the actions are not dictated, but mutually agreed upon, typically leads to a
greater sense of ownership to the plan, commitment to its recommendations, and a better chance that it
will last over the long run. There are many techniques that can be used to develop plans based on a
consensus-approach, depending on the size of the group involved and the particular situation hi the
Region of Concern. As mentioned previously, the optimal group size for this type of process is no more
than 7 to IS participants; if more people are needed, it may be necessary to break into smaller subgroups.
In an ideal planning situation, a trained facilitator (especially one having some technical
familiarity with the issues facing the Region of Concern) will provide the skills needed to guide the
Regional Action Team. If it is not possible for the Regional Action Team to have a professional
facilitator, the team leader, or someone from the lead agency, could perform these duties if the team
agrees to that approach and the chosen facilitator is able to remain objective. Alternatively, the lead
agency may want to offer facilitation training as part of its overall technical assistance to the regional
action planning process. Many organizations offer facilitation services and/or training. Regardless of
the approach used to obtain a facilitator, care should be taken in the selection process because die
facilitator has a great deal of influence on the overall success of the planning process. Selection criteria
include experience with similar planning situations, familiarity with a variety of approaches used to build
consensus, familiarity with the ground rules and procedures to conduct efficient meetings, enough
technical background to have some familiarity with Region of Concern issues, experience working with
groups of a similar size and composition, and ability to remain neutral (not representing any interests).
,'
While it is beyond the scope of this document to provide a thorough discussion of the consensus-
building approach to decision-making, two key elements are essential (Fisher and Ury 1991; Doyle and
Straus 1976):
• Generating a wide variety of possibilities and alternatives before making a decision
• Measuring the possibilities against previously agreed upon, objective evaluation criteria to
determine final outcome.
When evaluating candidates for the facilitator's role, it would be useful to ensure they have familiarity
with this kind of approach.
. —
-------
Regional Action Han Guidance Conducting the Process
Facility-based pollution prevention planning provides one example of using this approach.
Typically, the facilities determine at the outset of the planning process the environmental problems or
issues of greatest concern. Using those priorities as the basis for further investigations, the facilities
identify a broad range of pollution prevention opportunities that will address targeted environmental
problems. This broad list of opportunities is then compared against predetermined evaluation criteria
(e.g., liability, regulatory compliance, implementation considerations, costs, environmental impacts) to
determine final choices (Chechile and Carlisle 1991; Gaunt et al. 1994; SAIC 1993). Chapter 7 and
Appendix D of this guidance document provide more information on decision-making using evaluation
criteria.
In order to provide effective input to the planning process, participants need to have enough
background information to form the basis for sound decision-making. Ideally, Regional Action Team
members will have some technical familiarity and understanding of the issues concerning a Region of
Concern. The preparation of background materials in advance of planned meetings can also help. An
approach that was effective in conducting the Chesapeake Bay Program's Nonpoint Source Evaluation
Panel (Chesapeake Bay Program 1990) is briefly summarized below and may be applicable to the regional'
action planning process: ,
• Identify topics for investigation—Overall purpose of the planning process is defined by Lead
Agency and Regional Action Team, and discrete topics needing additional information are
identified. For example, the Regional Action Team may want to learn more about the
effectiveness of existing management approaches.
• Prepare background and options papers—Lead agency (or volunteers from the Regional
Action Team) prepares background materials (e.g., short overview papers) on identified
topics. In addition, options papers, outlining specific choices the group may want to use as
the basis for its decision-making process, may be prepared. For example, the background
paper would summarize the effectiveness of existing management programs, while the options
paper would make suggestions on ways to modify/improve the existing programs.
Suggestions made in the options paper could be included by the Regional Action Team as
potential recommendations hi the final plan. Background and options papers should be
distributed to team members in advance of the planned meeting so they can have time to
review the information (e.g., at least 1 week). The background and options papers may also
be supplemented by a presentation at the meeting.
• Facilitate decision-making—Using the background and options papers as the basis for
dialogue at the meeting, a facilitator guides the group through a consensus-building process
to reach agreement on choices (e.g., which options paper recommendations to include hi the
final plan).
• Prepare plan—Using the decision-points generated from the options papers, supplemented
by additional input, the lead agency, or a subcommittee of the Regional Action Team,
_
-------
Regional Action Plan Guidance Conducting the Process
prepares sections of the final plan. Each section, and the completed draft plan, are
distributed to the group for review, comment, and approval.
f
The length of time for this process obviously varies depending on the situation. It is necessary to give
team members adequate time to review materials before the scheduled meetings, so drafts should be
distributed at least a week hi advance. As well, it is important to allocate sufficient time at the meetings
to fully discuss issues and reach consensus. It may be necessary to discuss some issues over the course
of several meetings. As outlined in Exhibit 3-8, the regional action planning process should plan on at
least the following schedule (Note: Schedule assumes meetings will be conducted for most of a day [e.g.,
10:00 a.m. to 3:00 p.m.]):
Defining vision, goals, and preliminary objectives—One early meeting, but to be modified
and refined throughout the process
Developing a problem statement—One meeting
Reviewing the efficacy of existing measures—Half of a meeting to one meeting. Could be
coupled with a preliminary overview of proposed implementation actions.
Developing implementation actions—At least two meetings.
3.6 PUBLIC PARTICIPATION AND EDUCATION
A public participation and education program should be implemented throughout the regional
action planning process. The Regional Action Team, in conjunction with the lead agency, should take
responsibility for defining a public participation approach. Because the Regional Action Team may be
consumed with developing the Regional Action Plan, a subset of the team, or a new group designated by
the Regional Action Team and/or lead agency, should take responsibility for involving the public. In
addition, the Regional Action Team should include ongoing public participation and education as an
implementation action for the Regional Action Plan.
The public participation and education program recommended for regional action planning is
different from, and moves beyond, stakeholder involvement on the Regional Action Team. Although
specific segments of the public are represented on the Regional Action Team, the extent and level of
public participation envisioned for the regional action planning process is much broader than the
representation provided by the Regional Action Team. In addition, the roles and responsibilities of the
Regional Action Team are very different than what is needed for public participation and education. The
Regional Action Team is a small group tasked with developing a Regional Action Plan, whereas the
—
-------
Regional Action Plan Guidance Conducting the Process
public participation and education approach is intended to build support for the Plan's implementation by
informing and enthusing the general public about the Region of Concern.
t
The public includes all citizens who live in the area—those represented by specific stakeholder
groups (e.g., Regional Action Team, civic groups, business associations, environmental organizations)
and citizens who may not be so represented (e.g., homemakers, subsistence fishers). Some examples of
specific sectors of the public that should be included in a public participation and education approach are
private businesses, homeowners associations, garden clubs, civic groups, schools and colleges, churches,
educational nonprofit organizations, and groups that represent racial and ethnic minorities. The broad
involvement of these groups is necessary to ensure successful plan implementation. Only when the public
understands and embraces the plan, will they be able to support implementation.
The importance of including the general public cannot be overemphasized. Public involvement
is a critical link between plan development and implementation. During this era of severe constraints on
both government and private sector funding, recognizing the value of the public as a resource is essential
to achieving the goals and objectives of Regional Action Plans. Likewise, public involvement hi planning
will generate more commitment and volunteerism during implementation. An educated and motivated
public can provide much of the expertise, time, effort, and leadership needed to protect and monitor the
Region of Concern. Two factors are crucial for encouraging public involvement: (1) education about
the Region of Concern, including how the individual is a part of the problem and solution, and (2)
inclusion La the planning process, even if it is just to be kept informed. People work for that which they
understand and are committed, and people are committed to that which they help create. The public's
talents, energy, and technical and financial resources can be a cost-effective way of solving many of the
Region of Concern's problems.
One of the cornerstones of successful action planning efforts is the building of coalitions among
government agencies, parties affected by or contributing to problems in the Region of Concern, and an
informed, committed general public. Citizens are important in keeping the regional action planning
process focused and moving towards its goals. As well, citizens groups may be active participants in the
process—serving as watchdogs, conducting volunteer cleanup and monitoring activities (e.g., schools and
churches can sponsor an "adopt a watershed" program, contribute to "Bay or river watch" computer
bulletin boards, or help with a speaker's bureau and with periodic conferences and workshops). The
resident of a Region of Concern will work harder to secure his or her own future than other, more
transient entities (e.g., distant government employees) (Hartig and Zarull 1992; Law and Hartig 1993).
3-36
-------
Regional Action Plan Guidance Conducting the Process
Because the development and implementation of Regional Action Plans is a long-term, ongoing process,
continued public involvement and a long-term commitment to regional action planning is essential.
Continued effective involvement can only be maintained, however, if all participants are
convinced that the time spent on regional action planning is productive. If the public does not see short-
term progress in remediation, they may become disillusioned and abandon the process. Short-term,
focused projects must be organized that are of interest to and achievable by the public. Building a record
of such successes is one mechanism of sustaining public involvement.
Two important components to any public participation program are to define the elements of
effective public participation and to design a public participation program that will produce the support
needed for Regional Action Plans. Critical elements to every public participation program are trust,
communication, opportunity, and flexibility (Law and Hartig 1993). Trust must be established between
those directly involved in the regional action planning process and the public. Although it is the most
difficult of the four elements to attain, trust is also the most essential element in a successfully
implemented Regional Action Plan. To establish trust the following must occur: communication must
be open between participants, opportunities must exist for public input, and flexibility must be maintained
in the planning process to accommodate both new information and necessary changes in the program.
To build broad-based community support, effective public participation in the regional action
planning process should be encouraged throughout the entire planning process. Public involvement
should be initiated at the outset of the planning process with the distribution of information (e.g., press
releases, public meetings) about the planning process, including goals and objectives, approach, and
timeframes and milestones. Opportunities for continued public involvement should also be outlined at
that time. Actions to inform and involve the public should occur throughout the life of the planning
process, especially at critical stages, such as defining the problems, developing goals and objectives, and
brainstorming about implementation actions. The public should also be involved in monitoring the Plan's
implementation until restoration is complete. It is not intended that the public become part of the
Regional Action Team. Rather, the public participation and education approach provides opportunities
for the general public to provide input to the Regional Action Team. Such citizen involvement will
provide the Regional Action Plan with invaluable local knowledge, the continuous and vigorous public
oversight needed to overcome bureaucratic inertia, and the political will accomplish goals and objectives
(Hartig and Zarull 1992; Law and Hartig 1993).
3-37
-------
Regional Action Plan Guidance Conducting the Process
To maximize its effectiveness, the public outreach should compliment existing user groups and
avoid costly duplication of other groups' efforts. The Regional Action Plan's public participation
programs most useful role may be coordinating between and filling gaps in existing programs There are
may ways to achieve these objectives; however, the following scenario is presented for example. First,
the Regional Action Team or its public participation subgroup should identify the Regional Action Plan's
educational priorities. Second, existing public education and outreach programs in the Region of Concern
should be surveyed. This investigation may demonstrate that many public and private groups in the
Region of Concern are addressing issues that the Regional Action Plan deems important. Once the list
of major education organizations is complied, the list can be analyzed for specific geographic areas or
focus on a specific issue. The Regional Action Plan represents many interests throughout the Region of
Concern and may serve a unique role as coordinator of a network of complementary, overlapping
interests. Gaps of information can be filled by sharing and disseminating information and resources.
Not all user groups are the same and the Regional Action Plan should determine the audience's
level of knowledge and involvement with the Region of Concern. The Regional Action Plan's public
participation program should provide a foundation for a true understanding of issues related to the Region
of Concern. Accordingly, the public participation program should devise a public education strategy that
provides for different levels of involvement. First, the Regional Action Plan may promote existing
programs. Second, the Regional Action Plan may seek to change existing programs or broaden their
focus to incorporate Regional Action Plan messages. Third, the Regional Action Plan should encourage
the creation of new programs when appropriate. For example, if another group is addressing an issue
adequately, the Regional Action Plan may help to promote and publicize its efforts. Whereas, if a second
group needs financial or logistical assistance, the Regional Action Plan may try to provide the resources
necessary for the group to organize its work. As a last resort, if the Regional Action Plan identifies an
educational need that no one else is addressing, then the Regional Action Plan should initiate a new
program.
Once it defines areas needing additional involvement, the team should implement a range of
public participation and education tools. In addition, the team should coordinate with any existing
communications activities that support the Chesapeake Bay Program. Throughout the planning process,
the public should be given regular updates through newsletters, fact sheets, and press releases. It is
important to communicate possible planning options to the public before they are narrowed or selected.
It may also be appropriate to publish a newsletter for each Region of Concern. Team members should
periodically speak to organizations that represent sectors of the general public. Among other activities,
—
-------
Regional Action Plan Guidance
Conducting the Process
the team should establish contacts with the media
and encourage regular stories and news clips.
The media should be encouraged to take
responsibility for educating the public at large by
contributing staff and other resources to
educational video spots and public service
announcements, along with other actions.
Depending on the public's involvement in the
Region of Concern, it may be useful to consider
establishing a nonprofit organization that could
promote public education and participation during
plan development and implementation or to build upon the efforts of an existing organization.
Public Participation and Education Tools „
> , v '
Public meetings and hearings - >
Public workshops and forums
Public roundtables
Speakers' bureau
Outreadt to schools, fludraa teachers* guides
and curricula
Citizen surveys
Citizen monitoring and/or watchdog groups
Newsletters, videos, :«nd television programs
Annual progress reports
Computer bulletin boards
Nonprofit educational groups
Cleanup days and other special events
3-39
-------
Regional Action Plan Guidance _ Conducting the Process
Chechile, R. and S. Carlisle. 1991. Environmental Decision Making: A Midtidistiplinary Perspective.
New York: Van Nostrand Reinhold.
Chang, R. and K. Kehoe. 1994. Meetings that Work! Irvine: Richard Chang Associates, Inc.
Chesapeake Bay Program. 1990. Report and Recommendations of the Nonpoint Source Evaluation
Panel. CBP/TRS 56/91.
Davidson, C. Personal communication with 'Carla Davidson, Southeast Michigan Council of
Governments, in June 1994.
Doyle, M and D. Straus. 1976. How to Make Meetings Work! New York: Berkley Books.
Fisher, R. and W. Ury. 1991. Getting to YES: Negotiating Agreement Without Giving In. New York:
Penguin Books.
Gaunt C., K. Palmer, K. Allman, and G. Childs. 1994. Opportunities for Community-Based Pollution
Prevention Planning hi the Chesapeake Bay Basin— The TIPPP Example. Prepared for the
Chesapeake Research Conference, June 1994.
Harris, V. Personal communication with Vicky Harris, Wisconsin Department of Natural Resources, in
June 1994.
Hartig, J., N. Law, and G. Wever. 1994. Applying TQM to Remedial Action Planning in the Great
Lakes. E2M. Spring 1994.
Hartig, J. and M. Zarull. 1992. Under RAPs— Toward Grassroots Ecological Democracy in the Great
Lakes Basin, Ann Arbor: University of Michigan Press.
Law, N. and J. Hartig. 1993. Public Participation hi Great Lakes Remedial Action Plans. Plan
Canada. March 1993.
Letterhos, J. 1992. Dredging Up the Past: The Challenge of the Ashtabula River Remedial Action Plan.
In: Hartig, J. and M. Zarull. 1992. Under RAPs— Toward Grassroots Ecological Democracy
in the Great Lakes Basin. Ann Arbor: University of Michigan Press.
Schramik, R. Personal communication with Roy Schramik, Michigan Department of Natural Resources,
in June 1994.
Science Applications International Corporation (SAIQ. 1993. Fort Eustis/Fort Story Pollution
Prevention Program Plan. Prepared for Directorate of Engineering and Housing, Environmental
and National Resources Division, U.S. Army Transportation Center-Fort Eustis. AEPI Contract
Number DAC 88-92-D-002.
Shuyler, L. Personal communication with Lynn Schuyler, Chesapeake Bay Program, in June 1995.
Swiniuch, R. Personal communication with Rich Swiniuch, New York State Department of
Environmental Conservation, in June 1994.
_ —
-------
CHAPTERS
CONDUCTING THE REGIONAL ACTION PLANNING PROCESS
-------
CHAPTERS
TABLE OF CONTENTS
Page
3. CONDUCTING THE REGIONAL ACTION PLANNING PROCESS 3-1
3.1 OVERVIEW OF THE LEAD AGENCY'S INVOLVEMENT 3-4
3.1.1 Assembling an Effective Regional Action Team 3-6
3.1.2 Identifying Regional Action Team Members 3-9
3.1.3 Identifying Regional Action Team Leaders 3-16
3.1.4 Obtaining Management Support 3-17
3.2 OVERVIEW OF THE REGIONAL ACTION TEAM'S INVOLVEMENT 3-19
3.2.1 Identifying Stakeholder Interests 3-20
3.2.2 Evaluating Environmental Problems and Establishing a Vision Statement, Goals
and Objectives 3-21
3.2.3 Evaluating Existing Management Programs 3-22
3.2.4 Determining Implementation Actions 3-23
3.3 DEVELOPING A WORK PLAN 3-25
3.4 CONDUCTING EFFECTIVE REGIONAL ACTION TEAM MEETINGS 3-29
3.5 APPROACHES TO BUILDING CONSENSUS 3-33
3.6 PUBLIC PARTICIPATION AND EDUCATION 3-35
References Cited 3-39
3-1. Roles and Responsibilities 3-4
3-2. Key Elements to Establishing a Regional Action Team 3-8
3-3. Reasons Why Consensus Groups Fail 3-8
3-4. Example of Procedure to Identify Participants for the Regional Action Team 3-11
3-5. Example of a Stakeholder Category Table Used to Identify Participants for the Regional
Action Team 3-12
3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed 3-13
3-7. Team Leader Qualities 3-17
3-8. Overview of Activities Comprising the Regional Action Planning Process 3-26
3-9. Roles and Responsibilities—Regional Action Team Meetings 3-31
3-10. Basic Considerations for Conducting Effective Regional Action Team Meetings 3-32
-------
Regional Action Plan Guidance Conducting the Process
CHAPTER 3. CONDUCTING THE REGIONAL ACTION PLANNING PROCESS
Regional Action Plans should be developed through a coordinated, consensus-building process
overseen by the designated lead agency in the Region of Concern1 and supported by a stakeholder group,
referred to as the Regional Action Team. Although the lead agency has considerable flexibility in its
approach to conducting the regional action planning process, the Chesapeake Bay Program expects the
lead agency to:
Develop and deliver a Regional Action Plan to the Chesapeake Executive Council within a
designated timeframe
Use a regional action planning process that considers all stakeholder interests
Identify and work in consultation with the Regional Action Team throughout the planning
process, particularly when identifying priorities, determining an overall project vision, setting
goals and objectives, and developing implementation actions and milestones
Work with the Regional Action Team to include the public in the planning process.
This chapter presents background information useful for conducting the regional action planning
process. The chapter describes the anticipated activities of the lead agency and the Regional Action Team
in developing a Regional Action Plan, presents information on conducting Regional Action Team
meetings and building consensus, and discusses the importance of public participation and education.
This information is presented in the following sections of the chapter:
• Overview of the Lead Agency's Involvement
- Assembling an Effective Regional Action Team
- Identifying Potential Regional Action Team Members
- Identifying Regional Action Team Leaders
- Obtaining Management Support
• Overview of the Regional Action Team's Involvement
- Identifying Stakeholder Interests
- Evaluating Environmental Problems and Establishing a Vision Statement, Goals and
Objectives
- Evaluating Existing Management Programs
- Determining Implementation Actions
'Lead agencies are designated by the jurisdiction^) containing a Region of Concern.
3-1
-------
Regional Action Plan Guidance Conducting the Process
• Developing a Work Plan
• Conducting Effective Regional Action Team Meetings
• Approaches to Building Consensus
• Public Participation and Education.
Although the guidance recognizes that each Region of Concern is a unique location, with site-
specific considerations, the suggestions presented in this chapter apply to most situations and will help
determine an efficient and successful regional action planning outcome. Three overarching considerations
that apply to all aspects of the planning process include:
• Someone must coordinate the entire regional action planning process. The process
involves many different steps and participants. In order to keep the process on track, in an
orderly and efficient manner, one person should be responsible for mapping each step of the
process, assigning roles and responsibilities, and ensuring that tasks get completed on time.
This Regional Action Plan coordinator should be affiliated with the group responsible for
writing the final plan and delivering it to the Executive Council (generally this group is the
lead agency).
• Roles and responsibilities for each step of the planning process must be clearly defined.
Regional action planning involves many different tasks, including conducting background
research, preparing written materials, providing logistical support for Regional Action Team
meetings, running Regional Action Team meetings, facilitating decision-making, and writing
the final plan. Because different people will be involved in each of these steps, it is essential
to clarify, upfront, the roles and responsibilities of each participant. This will clarify the
overall approach, ensure efficient participation, and avoid duplication of effort.
• Each step of the planning process must have a leader. In addition to the overall plan
coordinator, each step of the process must have a discrete leader. Absence of a leader can
lead to confusion about roles and responsibilities, cause the process to get off-track, and
frustrate participants who are unclear about the best way to participate.
The rationale for having an overall coordinator, defining roles and responsibilities, and identifying
leaders for the regional action planning process is simple and straightforward. Regional action planning
must occur hi an orderly, efficient, and timely fashion so that momentum is maintained, participants'
commitment and enthusiasm to the planning process remain high, and goals and objectives are achieved.
Defining roles and responsibilities early in the process helps to establish the road map necessary to ensure
effective planning. Poorly organized efforts, without a clearly stated mission and understanding of
individual and group responsibilities, often fail to achieve the ultimate goal of the regional action planning
3-2
-------
Regional Action Plan Guidance Conducting the Process
process—to develop an implementable plan, representative of the diverse interests in the Region of
Concern, that will reduce and prevent problems associated with chemical contamination.
Stakeholder involvement from the early stages is critical to the ultimate success of the Regional
Action Plan. Stakeholders are represented through a well-selected Regional Action Team comprised of
a diverse group of participants interested in, affected by, or contributing to chemical contaminant-related
issues in the Region of Concern. Potential stakeholders for inclusion on the Regional Action Team
include representatives from local, state and federal governments; industrial and commercial sectors;
citizen and environmental groups; and academic institutions.
Involving stakeholders in the decision-making process leads to local ownership of the Regional
Action Plan and a sense of stewardship for the Region of Concern. The coalitions built through an
effective stakeholder process will strengthen the Regional Action Plan by elevating the priority given to
certain implementation actions, obtaining commitments (e.g., staff resources, funding) for
implementation, and engendering trust among diverse interests. In addition, stakeholder commitment is
necessary because of the level of political, legal, and behavioral change necessary to achieve some
regional action planning goals and objectives. Because of the variety of political bodies and agencies
potentially involved in the watersheds linked to a Region of Concern, governmental commitment is also
key to affecting change. Most of the implementation actions needed to address a Region of Concern,
whether regulatory or nonregulatory, are beyond the conceptual, institutional, and financial reach of any
single agency or group and require intra-agency collaboration, public-private partnerships, and
stakeholder commitment.
In addition to the Regional Action Team directly involved hi plan development, the sustained
interest and involvement of the general public is necessary to maintain momentum. The general public
can be influential hi ensuring that actions are pursued. They can help keep the process focused and, by
serving as citizen "watchdogs," can achieve greater accountability from those charged with implementing
specific plan recommendations. The general public can also provide technical input to plan development
by contributing information and opinions to define problems, assessing existing programs, and
determining implementation actions. Citizen groups can also be established to contribute directly to plan
implementation by establishing citizen monitoring networks, promoting cleanup days, or initiating other
actions. An informed public can provide valuable resources to the regional action planning process, and
efforts should be taken, from the start, to ensure public participation.
3-3
-------
Regional Action Plan Guidance
Conducting the Process
Exhibit 3-1. Roles and Responsibilities
Stakeholder
Role/Interests
Responsibility
Comments/Other
Considerations
Lead agencies
Manage plan development in
cooperation with stakeholders
(i.e., Regional Action Team) and
form institutions with public
involvement and commitment
Protect water quality and
develop and implement a
Regional Action Plan
Establish and
coordinate the team
and provide technical
and financial resources
Responsible agencies
(federal, state, and local)
Support plan development and
pursue various public interests
Assist lead agencies and commit
technical and financial resources;
participate in relevant
implementation actions
Exercise jurisdiction
over resources or
management decisions
Industry and local
businesses
Ensure business interests are
represented in the plan
Contribute technical expertise,
time, and funding; participate in
relevant implementation actions
Educate the public and
inform constituencies
of progress and issues
Citizen/environmental
groups
Ensure environmental protection
issues are represented in the plan
Attend meetings, perform
outreach, serve as watch dog for
planning process, participate in
plan implementation
Educate the public and
inform constituencies
of progress and issues
Educational institutions
Ensure that scientific and other
educational information is
disclosed
Provide subject area expertise
and perform outreach, technical
research, and monitoring
Make grants available
to support such
projects
General Public
Attend public meetings/hearings
and other events about die Region
of Concern. Contribute ideas,
opinions, and information.
Become informed and serve as
"watchdogs" for plan
implementation. Maintain
political pressure. Take
personal responsibility for
actions (hat will improve
conditions in the Region of
Concern (e.g., recycle,
minimize use of hazardous
chemicals).
Informing the public
early on and
throughout the process
is a good way to
maintain momentum
and pressure to ensure
implementation.
Exhibit 3-1 provides an overview of the types of key players likely to be active in the regional
action planning process. The exhibit outlines major roles and responsibilities and describes the interests
of these stakeholders, including lead agencies, other government agencies, industry and local business,
citizen/environmental groups, and educational institutions. Later sections of this chapter describe a
process for selecting a balanced and representative Regional Action Team from these types of groups.
3.1 OVERVIEW OF THE LEAD AGENCY'S INVOLVEMENT
The lead agency is designated by the jurisdiction(s) having a Region of Concern to oversee the
regional action planning process, including plan development and implementation. The lead agency's
responsibilities include establishing and coordinating the Regional Action Team, providing technical and
financial resources, and offering leadership for the regional action planning process. It is very important
that the lead agency be committed to the regional action planning process and work with the Regional
Action Team to gather support from elected officials.
3-4
-------
Regional Action Plan Guidance Conducting the Process
The lead agency has a great deal of flexibility in choosing an approach for implementing the
regional action planning process. Bearing hi mind that the ultimate responsibility of the lead agency is
to deliver a Regional Action Plan to the Chesapeake Executive Council by an established deadline, the
lead agency can use, or modify, one of several approaches depending on the level of public and
stakeholder commitment required to develop and implement the Regional Action Plan, and available
funding and other resources:
• Maintain full responsibility for plan development, using the Regional Action Team hi an
advisory capacity (e.g., reviewing and commenting on materials prepared by the lead agency)
• Share responsibility with the Regional Action Team (e.g., identify the various tasks needed
to complete the plan and divide responsibilities according to expertise and ability/willingness
to contribute)
• Delegate all authority for plan development to the Regional Action Team (e.g., lead agency
may provide technical support, but Regional Action Team has full control in guiding the
planning process and making recommendations).
Regardless of the approach taken, it is essential to clearly define roles and responsibilities at the outset.
If the lead agency chooses to delegate some or all of its authority to an existing group, it might want to
develop a formal or informal memorandum of understanding clearly stating roles, responsibilities, and
expectations of the groups involved. If such clarification of roles and responsibilities is not offered early
hi the planning process, involved parties, including Regional Action Team members, might become
confused, frustrated, and disillusioned with the process.
Experience suggests that the most effective approach is one of shared responsibility between the
lead agency and the Regional Action Team (Chesapeake Bay Program 1990; Davidson 1994; Harris 1994;
Schramik 1994; Shuyler 1994; Swiniuch 1994; Hartig et al. 1994). This approach is often successful
because it utilizes the technical and financial resources of the lead agency, while seeking the energy,
creativity, support, and commitment from the stakeholders who will ultimately determine the plan's
success. Regardless of the approach used by the lead agency, it is important that adequate time be
allocated for plan research and development hi order to generate a sound, credible, and implementable
plan. The lead agency, working with the Regional Action Team, should try to identify and seek
involvement from all significant stakeholders and thoroughly understand stakeholder interests. The
Regional Action Team should also be given sufficient tune and resources to conduct the decision-making
process needed to develop a sound implementation approach (e.g., identifying a complete range of
implementation actions, such as nonpoint source control techniques, pollution prevention plans, legislative
3-5
-------
Regional Action Plan Guidance Conducting the Process
changes, funding, public involvement). By following this process, it is more likely that the solutions
developed will be more acceptable to the team and innovative than a plan produced by a single agency.
3.1.1 Assembling an Effective Regional Action Team
One of the most important early responsibilities of the lead agency is to assemble an effective
Regional Action Team. Although many factors determine team effectiveness, it is of utmost importance
that the team be balanced and representative of key stakeholders in the Region of Concern. When
assembling the team, the lead agency may want to start with existing stakeholder groups (e.g., the
Anacostia Watershed Restoration Committee, the Elizabeth River Project) or develop a new group,
drawing members from existing stakeholder groups. As one of its first steps in the planning process, the
lead agency should conduct enough background research on the Region of Concern to identify groups
and/or individuals already active in the Region of Concern. Depending on the situation in the Region
of Concern, the lead agency should coordinate with existing stakeholder groups or active individuals, or
invite other involved parties (e.g., local governments) to join an initial selection committee (formal or
informal) to assemble the Regional Action Team. The lead agency, in conjunction with its partners in
the Region of Concern (e.g., selection committee) should determine the size and structure of the Regional
Action Team and identify affected parties (i.e., persons/groups associated with or affected by chemical
contamination in the Region of Concern), key decision-makers, and subject matter experts to include as
participants on the Regional Action Team. When identifying groups and/or individuals to assist in the
Regional Action Team selection process, and again when identifying potential team members, it is
important to have the participation of individuals who adequately represent the wide variety of interests
of those affecting and being affected by chemical contamination problems in the Region of Concern. It
is especially important to involve individuals and/or groups that will play lead roles in implementing the
Regional Action Plan. Section 3.1.2 of this guidance provides more specific direction on a process that
can be used to identify and select Regional Action Team members.
Although it is critical to include representative stakeholders on the Regional Action Team, it is
also important to keep the group size manageable—no more than IS to 20 members are suggested
(optimal size is 7 to 15). This smaller number gives the group flexibility and allows it to operate in an
efficient manner. It also enhances the consensus-building process, which is essential to the ultimate
success of the Regional Action Plan. Although larger groups are possible, it becomes harder to ensure
equitable involvement from all team members, and the decision-making process may be more unwieldy.
If a group larger than 15 or 20 individuals is required, it may be necessary to form subcommittees (e.g.,
by source of pollution/land use category). To make drafting the Regional Action Plan workable, a
. .—
-------
Regional Action Plan Guidance Conducting the Process
drafting subcommittee, including approximately five members, may be formed. Alternatively, if
resources are available, it may be possible for the lead agency to provide staff and/or contractor support
to assemble background materials needed to develop the Regional Action Plan. If such "outside" sources,
or even a drafting subcommittee of the Regional Action Team, are used to prepare sections of the
Regional Action Plan, all stakeholders comprising the Regional Action Team should agree on the input
using a consensus-based approach. Section 3.5 hi this chapter ("Approaches to Building Consensus")
provides an overview of several approaches to building consensus.
Regional Action Team members should be enthusiastic and energetic about the planning process,
have leadership abilities, and be committed to the consensus approach to decision-making. Ideally, the
members should have technical familiarity with the issues facing the Region of Concern, but be involved
in management to the extent that they can influence the decision-making processes of the organizations
they represent. The members should also be able to speak with confidence about the feasibility of putting
the proposed implementation approach to work. It is important to involve both those who can contribute
to the planning process and those who can contribute to the implementation of the Regional Action Plan.
While it may be tempting to include only supporters of the regional action planning process on
the Regional Action Team, it is crucial to select team members representing all affected parties, especially
those that might be responsible for implementing a particular plan recommendation. By including
representatives from potentially resistant groups (e.g., a major contributor of chemical contamination)
in the early stages of the planning process, it may be possible to allay fears, build trust, and develop an
implementable plan that avoids potential pitfalls from the lack of cooperation and resistance that could
occur if affected parties feel excluded from the planning dialogue. When seeking to include members
from potentially resistant groups, it is helpful to identify individuals from those groups who will give the
process a chance, agree to use a consensus-based approach, and are willing to participate.
Exhibit 3-2 summarizes selected issues key to assembling an effective Regional Action Team.
If these concerns are considered and a strong commitment to a consensus-based process-using stakeholders
is pursued, then it should be possible to develop a sound, implementable plan. However, there is no
guarantee that any one team will succeed. Participants should look for warning signs and avoid pitfalls,
such as those listed in Exhibit 3-3.
3-7
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-2. Key Elements to Establishing a Regional Action Team
Determine appropriate participants. Represent affected parties (i.e., persons whose use of the Region
of Concern is impaired by chemical contamination and groups associated with chemical contamination),
subject matter experts, and key decision-makers. Ideally, participants should be able to represent groups
of affected parties (e.g., trade associations, coalition of several environmental organizations) rather than
individual entities (e.g., a single facility). Involve representatives from groups potentially responsible
for implementing aspects of the plan.
Select a team that is balanced and representative of all affected parties. One group should not dominate.
In most cases, it is inappropriate for more than one individual from a single entity to participate.
Identify affected parties and other potential Regional Action Team members by initially examining
available information on the nature of problems in the Region of Concern. After gaining a preliminary
understanding of problems in the Region of Concern, identify the types of affected parties associated
with each problem. Seek out existing organizations and/or individuals active in the Region of Concern
for advice on potential Regional Action Team members.
Identify enthusiastic, open-minded, and energetic participants who are committed to the consensus-
building process and have time to devote to developing a Regional Action Plan.
Avoid inviting people not affected by the objective^) of the Regional Action Plan. Also avoid
disinterested, unreliable individuals, and/or known meeting "disrupters."
Aim to have an adequate and balanced stakeholder group that is large enough to contain the knowledge
and opinions relevant to the planning task, but strive for a manageable group size. For decision-making
activities, the optimal group size is 7 to 15 participants. If more participants are needed, consider
establishing smaller subgroups.
Seek continuity of process and a balanced and representative group at all times by having team members
designate an alternate in case they are unable to attend a meeting.
Exhibit 3-3. Reasons Why Consensus Groups Fail
Failure to produce a plan that represents the interests of all significant stakeholders. This is often
caused when certain stakeholders, such.as environmental groups, do not join the team. Groups who
do not join the team usually attack what they do not like in the draft plan when it is presented for lead
agency review or review by the governing body. Therefore, it is important to make every effort to
involve each significant stakeholder group in the process directly or indirectly (e.g., by becoming a
corresponding member who receives meeting notes and is contacted regularly for ideas and opinions).
Members walk away from the process or do not commit to the process. This is usually because team
members believe their interests can be represented better in another way (e.g., in court, directly with
elected officials).
The team fails to deliver a Regional Action Plan that is adequate to guide implementation. Without
clear goals and objectives and strong leadership, teams tend to produce vague plans that do not resolve
major issues (e.g., specific implementation tools, such as farm pollution prevention plans to control
urban and agricultural runoff).
The ***"" loses momentum, thereby causing key members to abandon the process. Loss of momentum
is usually caused by inefficient and poor process management and getting bogged down on difficult
issues.
3-8
-------
Regional Action Plan Guidance Conducting the Process
3.1.2 Identifying Regional Action Team Members
Stakeholder groups, such as the Regional Action Team, should be balanced and represent key
decision-makers and affected parties (i.e., persons/groups associated with or affected by chemical
contamination) in the Region of Concern. To determine which stakeholders should participate hi the
Regional Action Team, it is necessary to examine the nature of the chemical contamination problems in
the Region of Concern. The lead agency, in conjunction with a formal or informal selection committee,2
should assemble and analyze readily available information (e.g., written documentation, personal contact
with knowledgeable individuals) to develop a preliminary overview of problems in the Region of
Concern. This understanding of problems is the necessary first step for identifying parties affected by
or contributing to beneficial use impairment and/or other adverse effects of chemical contamination.
After understanding the problems, it is possible to link candidate stakeholder groups and individual
representatives of those groups to the problems. Each step of the process to identify Regional Action
Team members is summarized below:
Assess Nature of Problems—Lead agency, working with existing stakeholder groups and/or
individuals active in the Region of Concern, conducts preliminary investigations to determine
the nature of chemical contamination problems in the Region of Concern. Readily available
written material (e.g., technical reports, newspaper articles), supplemented by discussions
with informed groups or individuals, should be assembled and summarized.
Identify Stakeholder Categories to be Represented on the Regional Action Team-
Information on problems and sources of problems provide the basis for identifying the types
of stakeholders that should be represented on the Regional Action Team. The lead agency,
in consultation with other key groups and/or individuals, develops a generic list of
stakeholder categories (e.g., fishing industry, property owners, chemical industry,
environmental groups) that should be included.
Identity Actual Representatives from Generic Stakeholder Categories—The lead agency,
hi consultation with other key groups and/or individuals, analyzes background information
to match specific names with stakeholder categories. A review of the literature, but more
likely personal knowledge/recommendations from groups and/or individuals already involved
in the Region of Concern, will help to identify specific persons associated with each generic
stakeholder category. Efforts should be made to identify individuals that represent groups
of stakeholders (e.g., an industry association or business group that captures multiple
business/industry groups in the Region of Concern). It is important to avoid
duplication—there is no need for two or more representatives from any particular stakeholder
category; certainly not from the same location/facility/group.
*The lead agency may want to coordinate with existing groups and/or individuals (e.g., an existing stakeholder
group such as the Elizabeth River Project or the Anacostia Watershed Restoration Committee) active in the Region
of Concern, as well as other involved parties (e.g., local governments) to form a Regional Action Team Selection
Committee.
' —
-------
Regional Action Plan Guidance Conducting the Process
Exhibits 3-4 and 3-5 provide an example of the process of identifying Regional Action Team members.
Exhibit 3-4 illustrates each step of the process, while Exhibit 3-5 displays a hypothetical list of
stakeholder categories developed from the example in Exhibit 3-4.
In addition to the lead agency, the likely stakeholders-to be involved in the process include other
relevant local, state, and federal agencies; industry and other business organizations; citizen/environmental
groups; and educational institutions. Other organizations and individuals that may be stakeholders include
commercial and recreational fishing groups, landowners, homeowner associations, and community
organizations, such as civic groups and churches. Ethnic and minority group participation should be a
priority.
The ideal candidate for a Regional Action Team is enthusiastic, energetic, and committed to a
consensus-building planning process; has leadership abilities; is technically familiar with issues in the
Region of Concern and is a key decision-maker and/or connected to management so that he or she can
speak with some reliability and commitment about the organization's resources and ability to participate;
is willing to contribute to the planning process and/or plan implementation. It is important to match up
a region's problems with appropriate team members. For example, if contaminated dredging materials
are a problem in one area, the Regional Action Team should probably include representatives from local
ports and the U.S. Army Corps of Engineers. If urban nonpoint source runoff is a concern, the team
should probably include city planners, developers, and property owners. For regions affected by
agricultural runoff, agricultural stakeholders should be invited to join the team. Exhibit 3-6 lists potential
stakeholders representing various interests and matches them with associated problems.
If the lead agency is uncertain about whether to include certain stakeholders, it is possible to rank
potential stakeholders by their expected level of impact on the planning process, as well as by process
impacts on them. For instance, certain stakeholders may have more influence on the process man others.
Similarly, the outcome of the process (e.g., specific cleanup and funding commitments) may affect
stakeholders differently. Other ranking or selection factors include anticipated commitment to the process
and the expertise and skills the team requires. Because the regional action planning process occurs over
an extended period of time, may require participation in meetings and materials preparation, including
possibly drafting portions of the plan, it is important to select members—public and private—who have
the time and resources to make this commitment. Because the Regional Action Plan will be a technical,
as well as a policy, document, the team should include scientists and engineers.
3-10
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-4. Example of Procedure to Identify Participants
for the Regional Action Team
Assess Nature of Problems—Attaboy Creek was designated by the Executive Council as a Region of
Concern. The state Department of Environment was designated as the lead agency but is sharing
responsibility with an existing group, "Friends of Attaboy Creek." The Department of Environment,
working closely with Friends of Attaboy Creek leaders, assembled and reviewed all readily available
background materials. Reports developed by several State agencies and a local university documented
many ways that chemical contamination has affected the aquatic living resources in the Attaboy Creek
Region of Concern—straining the fish and shellfish populations, causing physical deformities, and
destroying the fishing industries. The background information, supplemented by several conversations
with university professors and State officials, suggests that most of the chemical contaminants are heavy
metals and organics. Given the land use and industrial base of the area, experts suggest that the
identified problems are most directly a result of industrial and manufacturing discharges, shipyard
discharges, and nonpoint source runoff from commercial and industrial areas. Preliminary research
summarized in the background material also suggests such linkages between problems and sources.
Identify Stakeholder Groups to be Represented on the Regional Action Team—After assessing the
background materials, the state Department of Environment and its partner, Friends of Attaboy Creek,
objectively identified the groups being harmed by chemical contamination (e.g., fisheries) and the
groups contributing to or responsible for sources contributing to chemical contamination (e.g.,
shipyards, municipal planners responsible for storm water control). The Department of Environment
and Friends of Attaboy Creek leaders compiled these stakeholder categories into a table (see Exhibit
3-5) to use as the basis for identifying actual representatives, (i.e., individual names) from the
stakeholder groups.
Identify Actual Representatives from Generic Stakeholder Group Categories—The lead agency in
consultation with other key groups and/or individuals, analyzes background information to match
specific names with stakeholder categories. A review of die literature, but more likely personal
knowledge/recommendations from groups and/or individuals already involved in the Region of Concern,
will help to identify specific persons associated with each generic stakeholder category. Efforts should
be made to identify individuals that represent groups of stakeholders (e.g., an industry association or
business group that captures multiple business/industry groups in the Region of Concern). It is
important to avoid duplication—there is no need for two or more representatives from any particular
stakeholder category; certainly not from the same location/facility/group. For example, John Doe may
represent an association of shipyards in the Region of Concern. Because he represents multiple
shipyards, he would be a good candidate for the Regional Action Team.
Available sources on potential stakeholders are extensive, including surveys of existing
stakeholder groups active in the Region of Concern; the Chesapeake Bay Program Directory, published
annually by the Chesapeake Bay Program Office; local Chamber of Commerce directories; industry
directories; lists of government agencies in the area; lists of individuals who have participated hi relevant
meetings/hearings organized by agencies (e.g., National Pollutant Discharge Elimination System [NPDES]
public hearings on draft permits, Chesapeake Bay Program Tributary Strategy hearings); and lists of
members of the environmental and conservation community (e.g., annually published National Wildlife
Federation Conservation Directory). Local planning documents, environmental impact studies, and
directories of local planning and economic development commissions may also be useful sources of
_
-------
Regional Action Plan Guidance
Conducting the Process
Exhibit 3-5. Example of a Stakeholder Category Table Used to Identify
Participants for the Regional Action Team
Stakeholder
Reason for Inclusion
Business/industry
Industry and manufacturing are the primary causes of the toxics problems
within the Attaboy Creek Region of Concern. Businesses are affected directly
by the success of industry. Involving these interests in the planning process
may help to develop a more easily accepted plan and may reduce opposition.
The main businesses and industry active in the Attaboy Creek Region of
Concern are marinas and shipyards, chemical manufacturing plants, and
petroleum refineries.
Citizen/environmental
groups
Citizens are affected daily by the conditions in which they live.
Environmental organizations exist to protect the interests of the citizens and
wildlife affected by the health of the environment. The primary citizens
groups are the Rotary Club, Jaycees, local garden clubs, and local Parent
Teachers Associations. The most active environmental organizations are the
Sierra Club and Friends of Attaboy Creek.
Federal government
Federal Government involvement is beneficial in the implementation of the
Regional Action Plan. The government has the ability to create and enforce
regulations, if necessary, as well as provide financial support for the effort.
The U.S. military plays the largest Federal role in the Attaboy Creek Region
of Concern, including the presence of the largest U.S. Naval shipyard. The
U.S. Army Corps of Engineers, U.S. Coast Guard, and U.S. Fish and
Wildlife Service also have large roles in the Attaboy Creek Region.
State government
State government is important in both the planning and implementation phases
of the Regional Action Plan. It has the primary responsibility for developing
the Regional Action Plan and also has the authority and financial resources to
facilitate implementation.
Fisheries
The fisheries and fishery industries have been the group most severely
affected by the chemical contamination problem in the Attaboy Creek Region
of Concern. The stress put on the fish populations has been excessive, and it
is the most obvious indicator of the problems existing.
Land owners/
home owners
Land owners and home owners are financially, physically, and aesthetically
affected by the health of Attaboy Creek. They also may be affected by
proposed actions to protect the river.
Local government
The local government represents individuals living in proximity to Attaboy
Creek. The government has control over zoning regulations and other
potential actions. There are four cities and two counties in the Attaboy Creek
Region of Concern.
Recreational/tourism
Attaboy Creek is attempting to develop a tourism industry that would greatly
benefit from the restoration of Attaboy Creek. Recreational users (i.e.,
pleasure boaters, sport fisherman, and swimmers) would also benefit from
cleaner and healthier waters.
Scientists/educators
Faculty from area colleges and universities may have knowledge and
information that would be useful in the development of the Regional Action
Plan. They can also assure that decisions are being based on accurate data.
3-12
-------
Exhibit 3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed
Potential Problem
Rnfish/shellnsh tissue contamination
Restrictions on shellfish harvesting
Degradation of bentnlc community
Water column toxtelty
Sediment toxldty
Restrictions on fish and wlldllle consumption
Degradation of flsh and wildlife populations
Degradation of phytoplankton/zooplankton populations
Bird and/or animal deformities or reproductive problems
Tainting of fish and wildlife flavor
Loss of fish and wildlife habitat
Restrictions on drinking water consumption
Restrictions on dredging activities
Sediment contamination
Water column contamination
I
Groundwater contamination
Added costs to agricultural/Industrial water use consumption
Beach closings
Aesthetics degradation
Sediment transport/erosion
Stormwater runoff/Combined Sewer Overflows
Urban runoff
Agricultural runoff
Atmospheric deposition of contaminants
Industrial discharges exhibiting acute/chronic toxlclly
Municipal discharges exhibiting acute/chronic loxlclty
Superlund sites •
Hazardous waste transfer/storage facility
-------
Exhibit 3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed
Potential Problem
a
I
Rshkills
Finfish/shellfiah tissue contamination
Flnflsh tumors
Restrictions on shellfish harvesting
Degradation ol benthlc community
Water column toxlclty
Sediment toxlclty
Restrictions on fish and wildlife consumption
Degradation of fish and wildlife populations
Degradation of phytoplankton/zooplankton populations
Bird and/or animal deformities or reproductive problems
Tainting of fish and wildlife flavor
Loss of fish and wildlife habitat
Restrictions on drinking water consumption
Restrictions on dredging activities
Sediment contamination
Water column contamination
Groundwater contamination
Added costs to agricultural/Industrial water use consumption
Beach closings
Aesthetics degradation
Sediment transport/erosion
Stormwater runoff/Combined Sewer Overflows
Jrban runoff
Agricultural runolf
Atmospheric deposition of contaminants
Industrial discharges exhibiting acute/chronic toxldty
Municipal discharges exhibiting acute/chronic toxlclty
Superfund sites
t > tr n*t' r/ >tor .*- o f altlto*
f
r
'•>
-------
Exhibit 3-6. Overview of Potential Stakeholders Within the Chesapeake Bay Watershed
V*
i-t
en
Potential Problem
Rshkills
Finfish/shellfish tissue contamination
Flnfish tumors
Restrictions on shellfish harvesting
Degradation of benthtc community
Water column toxlclty
Sediment toxldty
Restrictions on fish and wildlife consumption
Degradation of flsh and wildlife populations
Degradation of phytoplankton/zooplanklon populations
Bird and/or animal deformities or reproductive problems
Tainting of fish and wildlife flavor
Loss of fish and wildlife habitat
Restrictions on drinking water consumption
Restrictions on dredging activities
Sediment contamination
Water column contamination
Groundwater contamination
Added costs to agricultural/Industrial water use consumption
Beach closings
Aesthetics degradation
Sediment transport/erosion
Stormwater runoff/Combined Sewer Overflows
Urban runoff
Agricultural runoff
Atmospheric deposition of contaminants
Industrial discharges exhibiting acute/chronic toxlcily
Municipal discharges exhibiting acute/chronic toxlclty
Superfund sites
Hazardous waste transfer/storage facility
"Sf#
- *•
' •. >-
£>
a
Ci
-------
Regional Action Plan Guidance Conducting the Process
potential stakeholders. Interviewing key stakeholders or community leaders for recommendations is
another way to identify stakeholders.
3.1.3 Identifying Regional Action Team Leaders
It is critical to identify and cultivate leaders for a Regional Action Team. The most important
role for the team leaders is to work with the lead agency and its partner or designee to determine an
overall approach for the regional action planning process, including defining roles and responsibilities for
the Regional Action Team and establishing a schedule for completing each step of the process. It is
essential that the team leaders understand the goals and objectives of the regional action planning process
and are able to convey them to the Regional Action Team. The team leaders are also responsible for
running Regional Action Team meetings (e.g., ensuring the meeting agenda is followed and topics are
covered in a timely fashion), although they may be supported by other parties (e.g., professional
facilitator, lead agency.)
In a consensus-based process, like that envisioned for regional action planning, team leaders
should orchestrate, but not dictate, the process. Leaders contribute to the process by providing ideas and
information, offering approaches for continued progress, ensuring that the process stays on track and
encouraging enthusiastic participation and commitment. They should enjoy respect from the other team
members and not show bias when leading meetings, regardless of the interests they represent. In some
cases, if the team leader is qualified, he or she may also facilitate the decision-making and/or consensus-
building, portions of Regional Action Team meeting. However, if a leader wants to negotiate or
otherwise represent his or her interests, then facilitation responsibilities should be given to another team
member or outside facilitator.
Leaders for the Regional Action Team can be provided by the lead agency, selected from the
Team's membership, or obtained from an outside source. They all should be required to commit
substantial time to the process and be enthusiastic about their commitment. Exhibit 3-7 summarizes
additional qualities of the team leaders.
To remove any perceptions of bias and to provide objectivity to the planning process, it may be
advantageous to use a professional facilitator for the decision-making and/or consensus-building portions
of Regional Action Team Meetings (e.g., developing evaluation criteria to select implementation actions).
Although some stakeholders may object to a facilitator because of concerns that a facilitator may inhibit
team members (e.g., hi terms of influencing the process or applying their own leadership skills),
_ -
-------
Regional Action Plan Guidance ^ Conducting the Process
Exhibits-?. Team Leader Qualities
• Is a significant stakeholder, but able to remain objective
• Is committed to a consensus-based process, not an autocratic one; is not overly directive in the effort
to reach agreement
• Makes time commitment to plan process and goals
• Is organized and energetic to help nmintajin momentum
• Contributes expertise and skills
• Offers leadership
• Has experience managing and facilitating meetings
• Is willing to contribute resources of organization (may not be possible for each member)
experienced facilitators, involve team members in leading and managing the process. For example, a
professional facilitator can periodically assign facilitation responsibilities to a team member. This may
give the facilitator a chance to evaluate the approach taken to date and plan the next step in the process.
The facilitator should have experience hi applying a consensus-based approach to solving environmental
problems. Although specific knowledge of the technical issues regarding watershed restoration is not
necessary, the facilitator or facilitation team can also contribute to the process by providing briefings on
background information, such as concept papers or fact sheets, and organizing meeting notes. If a team
does not have access to a professional facilitator, a facilitator could be chosen from the team or provided
by the lead agency. The ideal candidate has leadership abilities, experience successfully facilitating
similar meetings, and an understanding of the regional action planning process. If a non-professional
facilitator is used (e.g., someone is appointed from the team), it is recommended that the facilitator and
as many team members as possible attend a training workshop on consensus-based decision-making. This
training should be sponsored by the lead agency.
V
3.1.4 Obtaining Management Support
The goal of any regional action planning effort is to develop an implementable plan that will
effectively reduce and prevent problems associated with chemical contamination in a designated Region
of Concern. To be successful in meeting this overall goal, a plan must have a committed management
and staff. Individuals believing in the concepts of regional action planning and the proposed
implementation approach must exist at all levels, from top management to the staff person(s) who are
ultimately responsible for implementing the plan recommendations. The lead agency must provide this
level of commitment because it is responsible for initiating the regional action planning process, ensuring
3-17
-------
Regional Action Plan Guidance
Conducting the Process
development of the plan, and providing long-term oversight of the implementation actions. Committed
management can ensure continued involvement throughout the regional action planning process by
directing staff and financial resources; obviously, interest and commitment from the highest levels of
management can have the greatest impact. Ideally, the senior agency official responsible for the Regional
Action Plan should attend the initial meeting to explain the purpose and importance of the regional action
planning activity, the role of the Regional Action Team, and the commitment of the lead agency. Better
yet, demonstrated support from elected officials will lend credibility to the process. Team members will
be more likely to commit to the planning process if they know that it has the support and commitment
from the lead agency's management and/or elected officials. This type of high-level support will lend
credibility to the planning process; give team members a heightened sense of purpose that then- efforts
are important, needed, and will be considered; and may foster greater involvement and cooperation from
team members.
Because proposed implementation
actions are likely to involve multiple groups
(government agencies, affected parties such as
industry), management and staff support and
commitment from these groups are also
critical. Another key role of the lead agency,
supplemented by the Regional Action Team,
is to provide education and outreach to these
groups to ensure that they have a clear
understanding of the overall goals of the
Regional Action Plan and then* roles and
responsibilities in implementing proposed
actions. The groups should be trained in the
importance of the regional action planning
process and the implementation actions to
which they are charged.
'' ~
vernment C
_ intheGreat Lakes'Asblabula
; Ohio, benefited greatly from demonstrated,
top level agency:
' officials; After years of perceived
severe
lack of actual deanW ;ictfons»
^process with cyni
to stress the importance of public i
tate Senator Robert Jto
members to^ meetmg::j
-problems offfije) Ashtabuia Area
Concern, tne
remedial action planning guidelines; and its plan
establish local input at file early stages. "
involvement of the weUrrcspested^fckat'goVc
official, plus tie demonstrated jbOTomftment of Ohio
*"" influenced the eventual active, participation of
' 4" ->-
/1*
In a geographically based approach to chemical contamination prevention and reduction such as
that envisioned for Regions of Concern, many different actions, focused on a variety of pollutant types
and sources, often occur simultaneously. To ensure smooth, consistent implementation of the plan, it is
helpful to have an enthusiastic plan coordinator. The Regional Action Plan coordinator should be
3-18
-------
Regional Action Plan Guidance Conducting the Process
affiliated with the group responsible for writing the final plan and delivering it to the Executive Council
(generally this group is the lead agency). An ideal coordinator will be an enthusiastic, organized, and
knowledgeable community member, who has the authority to make the recommended changes and who
is provided the financial and technical resources to complete his or her job.
32 OVERVIEW OF THE REGIONAL ACTION TEAM'S INVOLVEMENT
As described in Section 3.1, the type and level of the Regional Action Team's involvement in the
regional action planning process will vary depending on the planning approach selected by the lead
agency. If the lead agency chooses to maintain full responsibility for plan development, then the Regional
Action Team's role is somewhat limited to reviewing and commenting on material prepared by the lead
agency. On the other hand, the lead agency may delegate all authority for plan development to the
Regional Action Team. In this scenario, the Regional Action Team is responsible for assembling and
evaluating background materials and developing draft chapters of and recommendations for the plan.
The Chesapeake Bay Program recommends an approach of shared responsibility between the lead
agency and the Regional Action Team. This type of approach, involving participation of both parties,
is successful because it draws upon the technical and financial resources of the lead agency, while still
involving stakeholders in decision-making and consensus-building so that buy-in and commitment to the
plan is achieved. One way to implement this approach of shared responsibility is to have the lead agency
develop relevant background materials and options papers to be used as the foundation for a facilitated
consensus-building process involving the Regional Action Team. Background papers provide an overview
of the issue, while options papers suggest choices of language for the plan and/or plan recommendations
(e.g., implementation actions). Section 3.5 of mis chapter describes this process in more detail.
It is essential for the Lead Agency and the Regional Action Team to decide early in the planning
process how they want to approach development of the Regional Action Plan, including defining
appropriate roles and responsibilities for each step of the process. The approach should be mutually
decided and understood by all parties in order for the planning process to proceed effectively.
Recognizing that the exact approach to conducting the regional action planning process will be unique
to each Region of Concern, the Regional Action Team should be involved in the development of the
Regional Action Plan at least to the following extent:
• Evaluating background materials
• Providing expertise and input for the plan (e.g., technical materials, recommendations for
additional sources of material and contacts)
3-19
-------
Regional Action Plan Guidance
Conducting the Process
• Supporting the decision-making process required for effective plan development.
The Regional Action Team's most important role is that of participating in the decision-making process.
As discussed throughout this guidance document, the regional action planning process, and final plan,
must be streamlined and focused on priority issues so that limited resources are effectively used.
Therefore, many of the steps needed to complete the plan involve decision-making about priorities (e.g.,
What are the most important adverse ambient effects? What chemical contaminant types and sources are
the greatest concern? What implementation actions should be pursued first?). The Regional Action Team
should be involved in all decision-making aspects of the plan. In fact, many of tasks toward developing
the Regional Action Plan should be accomplished in a consensus-building framework, where the affected
parties (stakeholders) are represented by the Regional Action Team.
The remainder of this section further describes the anticipated involvement of the Regional Action
Team in the planning process. The information is presented in the following subsections:
• Identifying stakeholder interests
• Evaluating environmental problems and establishing goals and objectives
• Evaluating existing management programs
• Determining implementation actions.
3.2.1 Identifying Stakeholder Interests
The interests of stakeholders participating on the Regional Action Team should be identified as
soon as possible, perhaps as early as the initial team meeting. The information gained in this process will
help team members understand each other's motivations, as well as the interests that lie behind any
positions that might be taken in the planning process. This information can foster an open and honest
dialogue.
It is important that team members not
judge or evaluate interests—every interest
represented by a stakeholder should be welcomed
and recorded. The interests generally pertain to
human health and the environment, as well as to
economic and social issues. The team should
make every effort to represent non-human
environmental interests.
group's or individnaTs stand
or decision aBoaEan issue, whereas Interests are the
underlying concerns that helped form me position.
For example, a group's position could be mat they
want to ban ne^j^ustnss from being allowed to;
while
3-20
-------
Regional Action Plan Guidance Conducting the Process
Planning processes can deteriorate at this early stage because people may try to alter or question
other stakeholder interests or because they do not have the patience to spend a few hours or a day
identifying and understanding interests. If the team moves through this step efficiently, however,
participants will have valuable information for later in the process. When negotiating recommendations,
for example, it is necessary to consider the relationship between a stakeholder's position and his or her
interests. If the position a stakeholder chooses threatens team consensus, team members should consider
whether the position is consistent or inconsistent with the stakeholder's interests. If it is inconsistent,
team members should ask the stakeholder to consider whether his or her interests can be satisfied in a
different way. For example, if a stakeholder's position is that it is necessary to ban new industries from
directly discharging to the Region of Concern but then- interest is in restoring a recreational fishery,
perhaps the interest could be achieved through a means other than a ban (e.g., modification of existing
NPDES permit limits to be more stringent). This kind of situation underscores the importance of
understanding stakeholder interests early in the process.
During each Regional Action Team meeting, information such as stakeholder interests, common
interests, and conflicting interests, as well as the agenda for the next meeting, should be recorded on flip
charts and distributed as notes between meetings.
Evaluating Environmental Problems and Establishing a Vision Statement, Goals and
Objectives
The early stages of the regional action
. . ,. , .... , ' BuringJftns initial problem identification stage, the
planning process should focus additional
investigations on priority problems. An effective
Regional Action Plan will be streamlined and
targeted on the primary sources of chemical
contamination identified as contributing to priority * i*«—^"""P*"**^^
team and lead agency could sponsor aefivities to
< educate and seel: input from the public & large on
the nature and scope of the Identified?
These activities should include
.; toundtable discussions, and citizm:
or
_ ^
problems. In order to prioritize problems for
action, the Regional Action Team must have a sense of the vision, goals, and objectives it hopes to
achieve in the Region of Concern. The process of identifying and prioritizing problems, including
sources, and determining a vision statement, goals, and objectives is iterative—as the Regional Action
Team develops its information base on problems, goals and objectives might become apparent. Likewise,
achievement of goals and objectives might clearly require focus on specific problems and chemical
sources.
3-21
-------
Regional Action Plan Guidance Conducting the Process
The Regional Action Team should be involved hi all phases of the decision-making processes to
identify and prioritize problems, including chemical contaminant types and contributing sources. The
team is also integral in establishing the plan's vision statement, goals, and objectives. The results of mis
process will not only guide plan development, but will provide much of the written portion of the final
plan. Early consensus by the team on these topics can be developed from a general understanding of the
problem (i.e., why the area was designated as a Region of Concern), supported by readily available
information, including written materials (e.g., newspaper articles, research documents, and other technical
reports), consultation with individuals familiar with the Region of Concern, and materials acquired and
generated by the Chesapeake Bay Program when identifying the particular Region of Concern. This base
level of information will provide the necessary background needed to stimulate the team to further
characterize the problem and begin establishing goals. In addition to participating hi the decision-making,
the team is expected to evaluate materials and provide technical support, as necessary. Chapters 4 and 5
of this guidance document provide more detailed information on establishing the plan's vision statement,
goals, and objectives (Chapter 4) and evaluating environmental problems (Chapter 5).
3.2.3 Evaluating Existing Management Programs
The most successful actions to reduce the impacts of chemical contamination in Regions of
Concern are often developed by evaluating and modifying existing approaches. Therefore, the thorough
evaluation of existing management programs, including regulatory and nonregulatory approaches (e.g.,
NPDES permit compliance, pollution prevention) is an important and essential prerequisite for developing
an implementation approach. The Regional Action Team should play an integral role hi identifying and
evaluating existing management programs.
Chapter 6 of this guidance defines an approach for evaluating existing management programs.
The lead agency would likely spearhead these evaluations, supported by Regional Action Team members.
The investigations must include an assessment of regulatory and nonregulatory approaches and activities
taken by government agencies and non-governmental organizations. A well-selected Regional Action
Team could provide the majority of information needed for these investigations. It is expected that
Regional Action Team members representing different stakeholder groups (e.g., government, industry,
environmental organizations) could report on key programs and/or provide a list of additional contacts
for consultation. The Regional Action Team would also determine the criteria to guide the evaluation
(i.e., the basis for measuring effectiveness). Once the evaluation is complete, the Regional Action Team
would review the results, determine if additional investigations were needed, and consider which existing
management measures should be considered as potential implementation actions.
_
-------
Regional Action Plan Guidance Conducting the Process
t
3.2.4 Determining Implementation Actions
The ultimate effectiveness of a Regional Action Plan hinges on developing effective
implementation actions. Chapter 7 of this guidance outlines a procedure to identify and select
implementation actions. The Regional Action Team plays a critical role in determining these actions.
Because of their importance in determining overall plan effectiveness, it is essential that sufficient time
be allocated to identify, research, and rank potential implementation actions; generally, the Regional
Action Team needs at least 2 full meeting days to evaluate and select implementation actions.
Although the lead agency may assemble the background materials needed to evaluate potential
. actions, the Regional Action Team will be involved in most steps of the process—brainstorming about
potential actions, providing background information, volunteering to conduct additional research if
needed, and developing criteria to evaluate me suitability of actions.
One of the first steps involves developing an organized inventory of potential implementation
actions. The facilitator/team leader should first poll the team on suggested approaches for organizing
actions. To do this, it may be appropriate for the team to review the purpose of the Regional Action Plan
and to structure the actions accordingly (e.g., by pollution source category).
Once the team identifies a loose structure for the implementation actions, team members should
"brainstorm" to identify actions within each category (e.g., point source actions, nonpoint source actions,
actions directed at urban areas, actions directed at marinas). The team should develop as many actions
as possible without judging them. When developing actions, it is important for the team to be innovative
and creative in attempting to address stakeholder interests. In addition, it is important to carefully
evaluate existing management approaches in the Region of Concern, as well as proposing new ones. It
is especially important to consider existing laws and policies; a priority of the planning process should
be to evaluate compliance and enforcement effectiveness. The team should also identify gaps in existing
laws, programs, and policies so that effective new solutions can be developed.
After developing a list of potential implementation actions (this may take a few meetings), the
Regional Action Team must further refine and organize these options. The team may want to establish
specific criteria, such as technical feasibility, cost, financing, and public acceptability, to determine
whether an action is appropriate and, therefore, a candidate for further evaluation (see Chapter 7). The
Regional Action Team should work closely with the lead agency to identify evaluation criteria. These
criteria must be well understood by all team members. Although each Regional Action Team may
— 3-23
-------
Regional Action Han Guidance Conducting the Process
develop its own evaluation criteria, it is important that the selected criteria enable the team to narrow its
comprehensive list of potential actions to a manageable size for further consideration.
Regional Action Team members or subgroups/workgroups of the Regional Action Team, working
with the lead agency, can be charged with further evaluating and defining promising actions between team
meetings. Meetings will be more productive and tune efficient if the team members have this background
information prior to the meetings.
During this phase, the Regional Action Team should also evaluate implementation actions with
respect to identified stakeholder interests. The team should try to move toward the action that best meets
its diverse interests, reminding stakeholders mat the option is probably better than the alternatives that
would result if an agreement could not be reached.
Strong leadership is essential to timely and complete closure on an issue. Closure entails a full
and accurate transcription of recommendations and commitments, as well as assurance that each
commitment can be fulfilled. Recommendations should be as thorough as possible and should be related
to specific evaluation criteria. The Regional Action Team should work with the lead agency and other
responsible groups to ensure that final implementation actions are fully described and address the
following questions:
• Who is responsible for implementation?
• What actions are necessary to implement the plan?
• Where should the implementation activities be targeted?
• When should actions be taken?
• How should actions be implemented?
The team should organize its final recommendations into the format of the Regional Action Plan.
The lead agency (and responsible agencies, if possible) should be prepared to assist the team in compiling
the plan. The draft plan, including implementation actions, should be made available to the team for
review and comment before submittal to the general public and any governing agency (e.g., Chesapeake
Executive Council) for review, comment, and adoption.
3-24
-------
Regional Action Flan Guidance Conducting the Process
33 DEVELOPING A WORK PLAN
It is important that the approach to regional action planning and consensus-building be established
near the beginning of the planning process, ideally before the first meeting of the Regional Action Team,
so that it can be thoroughly described to all participants in the planning process. In addition, the roles
and responsibilities of the lead agency, team leaders, team members, and other participants (e.g., a
facilitator) should be clarified.
Frequently, planning activities, including stakeholder meetings to build consensus, suffer from
a lack of focus and an unspecified game plan. A perception of disorganization and a lack of clearly
defined goals and objectives can severely hurt the regional action planning process and the development
of an implementable plan. In the early stages of the regional action planning process, it is important to
clarify the overall purpose of the planning activities, identify an approach to the planning process,
determine a schedule and planning milestones, and define the roles and responsibilities of participants.
The lead agency, in conjunction with an existing stakeholder group (if applicable, should the lead agency
choose to delegate some or all of its authority to such a group), and Regional Action Team leaders, may
want to draft a work plan to guide the planning process. At a minimum, the work plan should:
• Provide an overview of the approach that will be used to conduct the planning process (e.g.,
use of a professional facilitator, methods used to make decisions and build consensus)
• Identify roles and responsibilities for the planning process
• Outline potential meeting agendas, including anticipated decision points, for the Regional
Action Team
• Present a schedule for planning activities (e.g., proposed meetings, draft materials, and plan
completion).
A work plan provides the basis, or road map, for the regional action planning process. It ensures that
all participants understand the anticipated process from the beginning, and contains a schedule to keep
the process moving in a timely manner. The work plan is intended to serve as a guide only—it is not
cast in stone, and should be reviewed throughout the process and revised as necessary. Exhibit 3-8
highlights selected activities that should occur during the development of the Regional Action Plan and
should be addressed in the work plan. These activities are tied to hypothetical Regional Action Team
meetings. The exhibit presents information on proposed agendas for each meeting, as well as suggestions
for background materials needed to prepare the Regional Action Team for the meeting and suggestions
for products/outcomes to be generated from the meetings. This information is presented as guidance and
~~ 345
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process
Materials Distributed in Advance
• Agenda
• List of team members
• Background materials (summary materials describing planning process, Region of Concern; draft work plan; feet
sheet mimmariring existing information on problems; draft language on vision statement, preliminary goals and
objectives)
Suggested Agenda Topics [Responsible Party]
• Welcome [Lead Agency]
• Introductions, including statement of participant's interests, and personal goals and objectives for the process [Team
Leaders]
• Background Presentations
- Overview of the Planning Process [Lead Agency]
- Roles and Responsibilities [Lead Agency, Team Leaders]
- Preliminary assessment of problems [Lead Agency, Invited Speakers]
- Overview of existing activities, including assessment of current actions by representative
stakeholders (e.g., success stories) [Lead Agency, Invited Speakers]
- Meeting ground rules [Lead Agency, Facilitator]
• Present work plan and describe approach for Regional Action Team. [Lead Agency, Team Leaders]
- Procedures (e.g., use of a facilitator; development of background papers)
- Roles and responsibilities
- Desired final product
- Anticipated schedule
• Seek agreement on work plan and team approach. [Lead Agency, Team Leaders]
• Discuss need for public participation. Seek volunteers to develop public participation strategy. [Lead Agency, Team
Leaden]
• Review presentations and other existing background information on problems with goal of beginning prioritization. If
materials are distributed in advance of meeting (at least one week), it may be appropriate for group to reach
facilitated consensus on problem statement and prioritization of problems for consideration. If advance distribution is
not possible, use meeting to introduce materials and prepare Regional Action Team for next meeting. [Team
Leaders, Facilitator]
• Present draft language on vision statement, preliminary goals, and objectives. If distributed in advance of meeting (at
least 1 week), it may be appropriate for group to reach facilitated consensus on preliminary goals and objectives. If
advance distribution is not possible, use meeting to introduce materials and prepare Regional Action Team for next
meeting. [Team Leaders, Facilitator]
Products To Be Generated From Meeting
• Problem definition and prioritization (if materials distributed in advance and adequate time allowed to discuss)
• Vision statement, preliminary goals and objectives Of materials distributed in advance and adequate, time allowed to
discuss)
• Summary of participants interests and desired outcomes
• Finalized work plan
• Meeting evaluation
3-26
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process
(continued)
Materials Distributed in Advance
• Agenda
• Meeting highlights
• Background materials (background reports on sources of problems, existing management approaches)
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. [Team Leaders]
• Seek .consensus on problem definition and prioritization. [Facilitator]
• Seek consensus on preliminary goals and objectives. [Facilitator]
• Present more detailed problem definition, including chemicals of concern and sources of concern. Present evidence,
to date, linking sources to problems. If evidence is sufficient, and/or if team has had time to review materials,
begin to prioritize sources for action. Develop criteria for identifying priority sources.1 [Team Leaders, Lead
Agency, Facilitator, Invited Speakers]
• Present results of evaluation of existing management measures. [Team Leaders, Lead Agency, Facilitator, Invited
Speakers]
Products To Be Generated from Meeting:
• Products that must be completed from first meeting:
Final problem definition and prioritization
Vision statement, preliminary goals and objectives
• PreHnrinary ranking of priority source categories.
• List of action items for next meeting.
• Meeting evaluation.
Meeting #3
Materials Distributed in Advance
• Agenda
• Meeting Highlights
• Background materials (final report summarizing sources of chemical contamination; preliminary list of
implementation actions based on preliminary ranking of source categories).
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. [Team Leaders]
• Present additional information miking sources of chemical contamination to priority problems. Discuss sources of
chemical contamination. Develop final ranking of sources based on evaluation criteria. [Team Leaders, Lead
Agency, Invited Speakers, Facilitator]
• Evaluate preliminary goals and objectives. Modify as needed to reflect new information. [Facilitator, Team
Leaden)
'ft is impnitont to nmoBber tint flie Regional Action Ptaa'i uftmtie gotl is to present an impkmcatiiioa approach for addressing problems
csmed hy ehamtai MUmJMtMi ~ . A»fri.t«d ».g«i nf Caneem. The mar/lei conducted for the planning process should ihrays bear mis goal in
mind so fat limited resources en be utffizod effectively, ft is useful to streamline the planning approach by focusing oo priority problems and sources
of problems. Once priority problems and source* sre identified, farther imestigaiioia should be focused on those aicas.
_
-------
Regional Action Plan Guidance Conducting the Process
Exhibit 3-8. Overview of Activities Comprising the Regional Action Planning Process
(continued)
Meetiig re (continued)
• Review work plan. Detennine if work plan needs to be modified. [Facilitator, Team Leaders]
• Report of approach and results for identifying implementation actions.2 [Lead Agency, Team Leaders, Invited
Speakers]
Products to Be Generated from Meeting
• Final ranking of priority source categories
• List of action items for next meeting
• Meeting evaluation.
Materials Distributed in Advance
• Agenda
• Meeting highlights
• Background materials (reports presenting comprehensive list of implementation actions by source category, including
qualitative information needed to evaluate and prioritize actions)
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. {Team Leaden]
• Present research on implementation actions. [Lead Agency, Team Leaden, Invited Speakers]
• Select implementation actions to be pursued further. [Lead Agency, Team Leaden, Invited Speakers]
Products To Be Generated from Meeting
• Short list of implementation actions to be evaluated in more detail.
• Meeting evaluation
Meeting
Materials Distributed in Advance ^
• Agenda
• Meeting Highlights
• Background materials (final report on implementation actions, outline and materials prepared to date for final plan)
Suggested Agenda Topics
• Conclude unfinished business from previous meetings. {Team Leaden]
• Review status of implementation actions. Seek implementation commitments. [Team Leaden, Invited Speakers,
Facilitators]
• Discuss presentation of final plan (ft i* appropriate throughout the planning process for the lead agency and/or a
drafting subcommittee from the Regional Action Team to prepare draft chapters of the plan for distribution, review,
and comment). [Team Leaden, Lead Agency]
• Determine schedule for additional meetings, if necessary. [Team Leaden]
Products to Be Generated from Meeting
• Approach, including assigned responsibilities, for preparing final plan and securing comiuitmeuts for implementation
actions.
• List of remaining action items and next steps.
• Meeting evaluation.
it k important to focm on priority problem* md gomcet. Abo, the level of detail needed in die
ihoukl be limited to tnrtrequind for aotrnddecnio^
lirt ~f,w*~rt^iinyleniaiMk»«ctioi»totfao«ettoihouM Exctm tjqfytit ibanld be avoided.
-------
Regional Action Plan Guidance Conducting the Process
should be modified to suit the unique needs of the Region of Concern. As discussed in more detail in
Section 3.4, it is important to set aside sufficient tune during the meetings to adequately cover each
agenda topic.
3.4 CONDUCTING EFFECTIVE REGIONAL ACTION TEAM MEETINGS
Successful regional action planning depends largely on effective stakeholder involvement so that
parties affected by and contributing to chemical contamination problems in the Region of Concern feel
an important part of the process, gain a sense of ownership to the plan, and commit to the proposed
implementation actions. Since the Regional Action Team is the main forum for involving stakeholders,
it is important to conduct effective Regional Action Team meetings. The efficiency and effectiveness of
Regional Action Team meetings depends on an organized approach with clearly defined roles and
responsibilities for all participants, a well-planned meeting schedule that accounts for all phases of plan
development, and clearly articulated meeting agendas and approaches to developing the plan. Without
these elements, the chances of conducting a successful regional action planning process are greatly
reduced, as:
Confusion over roles and responsibilities may result in a duplication of efforts and/or gaps
in responsibilities.
Meetings may lose focus, become rambling discussions, or are side-tracked, so that concrete
action items are not developed.
Participants may become disinterested and discouraged because they feel that they are not
accomplishing anything (not a part of the process) or they lose sight of the overall purpose
and end goal of the planning process.
The resulting plan may lack focus and/or may not adequately represent stakeholder groups.
It is important to ensure mat the overall meeting schedule, and individual meeting agendas, allow enough
time for the consensus-based process to occur. The Regional Action Team must reach consensus on
many issues throughout the planning process—vision statement, goals, and objectives; problem definition
and prioritization; and implementation action selection. In order for the team to feel a legitimate part of
the planning process, it is necessary for them to have time to review background materials, formulate
their ideas, and discuss their opinions in a facilitated process. The amount of time needed for these
activities varies, depending on the complexity of issues being addressed and the size of the Regional
Action Team. In general, a facilitator needs at least 2 to 3 hours per issue (e.g., identifying goals and
objectives) to effectively work with the Regional Action Team. The length of each team meeting should
3-29
-------
Regional Action Plan Guidance Conducting the Process
be adjusted to reflect the number of issues being addressed. In many situations, it works well to have
the Regional Action Team meeting run from mid-morning to early afternoon (e.g., 10:00 a.m. to 3:00
p.m.), with a break for lunch. This structure enables the morning session to cover background material,
gives the team members time to discuss information and formulate opinions during the lunch break, and
saves sufficient time for facilitated decision-making hi the afternoon. The lead agency and team leaders
should work closely with the facilitator to block off appropriate amounts of tune for each topic.
The importance of clearly defining meeting roles and responsibilities, in terms of who is
responsible for which parts of the meeting and how the meeting will be conducted, cannot be
overemphasized. An effective Regional Action Team meeting must have a designated team leader or co-
leaders and a balanced and representative group of participants (i.e., team members) representing key
stakeholders. In addition, it is recommended that a facilitator conduct portions of the meeting and a
meeting recorder provide notetaking and other support for the meeting. The appropriate roles and
responsibilities for participants in Regional Action Team meetings (i.e., team leaders, team members, lead
agency, facilitator, and recorder) are defined in Exhibit 3-9. The lead agency can remain active in the
planning process by providing technical support and/or facilitation expertise, if possible. Frequently, it
helps to have an outside facilitator to build trust among all meeting participants, so they do not perceive
a hidden agenda. For this reason, it is also advisable that the Regional Action Team leader(s) be someone
other than the lead agency. However, the lead agency is a valid stakeholder in the planning process and
should appoint a member to the Regional Action Team.
Just as it is important to have clearly defined roles and responsibilities among planning
participants, it is also necessary to have clearly articulated meeting agendas and approaches. The lead
agency, its partner or designee (e.g., existing groups), team leaders, and the facilitator should work
together to develop effective meeting agendas and approaches. Sometimes this process can be guided
through the joint development of a work plan to guide the planning process (see Section 3.3). Regional
Action Plans are developed from the evaluation of different types of information, as well as substantial
input from the Regional Action Team and the general public. To effectively synthesize the information
in a timely and efficient fashion and to ensure that all parties are adequately represented requires an
organized meeting approach. Without an organized approach, meetings and/or the planning process can
get side-tracked, result in time-consuming, unfocused discussions, and potentially not achieve the goals
of the planning process.
3-30
-------
Regional Action Plan Guidance ^^ Conducting the Process
Exhibit 3-9. Roles and Responsibilities—Regional Action Team Meetings
Team Leader or Cfr-Leaders ?,./.- ' -,
Establish meeting objectives and plans and are responsible for the overall direction of die meeting
Clarify participants' roles and responsibilities
Start meeting on time
Provide introductions, summarize meeting objectives and agenda items, and define roles and responsibilities
Work with facilitator to ensure meeting agenda is followed in a timely manner
Participate as group members
Summarize key decisions and actions
Teamfifenbm .' ' « *V 'Me
Generate ideas, analyze information, provide technical input, make decisions, and implement action plans
Review agenda and other meeting materials before attending meetings
Conduct enough pre-meeting background research to participate effectively in the meeting
Know purpose of meeting ahead of time and do "homework" if necessary to prepare
Confirm attendance and delegate an alternate if cannot attend
Attend meeting on time
Keep an open mind, avoid premature judgment, and try to understand other perspectives
Help facilitator eliminate distractions and encourage active involvement
Speak up; share useful ideas
Support ground rules and other meeting guidelines
Participate in a timely fashion
Volunteer for tasks only if capable of following through
Agree to participate in consensus-building exercises
Lead Agency:
Provides technical and financial support
Schedules meetings
Prepares draft agenda
Provides background materials for the meeting
Participates as a team member
Facilitator
Manages how people work and communicate in the meeting
Is responsible for flow of the meeting
Coordinates with Regional Action Team leaders and lead agency to acquire any needed background or other
preparatory information
Reviews planned agenda and action items
Ensures meeting runs smoothly
Reviews team's ground rules
Focuses me group
Monitors and regulates participation
Evaluates effectiveness of process and suggests alternative methods and processes as necessary
Protects people from "attack" and deals with problem people
Remains neutral at all times, particularly during disagreements
Recorder
Keeps track of important information throughout the meeting, prepares flip charts and other necessary visual
aids during the «i«»*i»«g, and prepares post-meeting summaries and action hems.
Prepares necessary meeting summaries, highlights, and other materials.
Captures ideas visually without editing or paraphrasing.
Checks to ensure that appropriate information has been recorded; obtains clarification from the participant if
needed.
Helps leader and facilitator keep track of information.
Produces meeting summaries, highlights, and other materials.
Source: Adapted from Chang and Kehoe (1994)
3-31
-------
Regional Action Plan Guidance Conducting the Process
Many references exist that summarize the elements of productive meetings, including preparing
the meeting, conducting the meeting, and evaluating the meeting (Chang and Kehoe 1994; Doyle and
Straus 1976; Fisher and Ury 1991). Exhibit 3-10 summarizes some basic considerations for conducting
effective meetings in the context of regional action planning.
Exhibit 3-10. Basic Considerations for Conducting Effective Regional Action Team Meetings
• Determine appropriate participants (e.g., subject matter experts, key decision-makers, and affected
parties, not unaffected parties and known meeting "disrupters").
• Ensure continual and balanced representation. Primary team member should select alternate if he/she
cannot attend.
• Clearly define and reach agreement on roles and responsibilities for all meeting participants, including
meeting leaders, meeting facilitator, recorder, Regional Action Team members, and lead agency.
Define and maintain roles and responsibilities from the beginning to end of the process.
• Fully consider each stage of meeting development: (1) Preparing for the meeting, (2) Conducting the
meeting, and (3) evaluating the meeting. No stage should be ignored or minimised
• Develop a well-thought out agenda providing the following information: meeting objectives, logistics,
anticipated attendee list (defining leader, facilitator, recorder), roles and responsibilities, action items
(i.e., list of items that must be covered to achieve meeting objectives),'and allocated time.
• Reach agreement on approach to planning process, including meeting schedules, ground rules, and
guidelines.
• Distribute necessary background materials to meeting participants sufficiently hi advance of the meeting
• Keep meetings focused on priority issues. When making decisions, develop a variety of options from
which to prioritize using a consensus-based set of objective evaluation criteria.
• Allow sufficient time to cover the subject adequately and build consensus, if necessary.
• Avoid getting bogged down hi details. Investigations are designed to support the development of sound
implementation actions. Detail beyond that needed for the purpose of developing implementation actions
may be superfluous.
• Ensure open and balanced participation from all participants.
• Strive toward consensus-based decision-maiding.
• Produce meeting summaries and progress reports to ensure that the overall planning process remains
focused toward its end goal.
• Evaluate the meeting to ensure that participants are satisfied with the approach.
Sources: Chang and Kehoe (1994); Fisher and Ury (1991); Chechile and Carlisle (1991); Doyle and Straus (1976)
3-32
-------
Regional Action Plan Guidance Conducting the Process
3.5 APPROACHES TO BUILDING CONSENSUS
An effective Regional Action Plan will be developed using a consensus-based process involving
major stakeholders represented through the Regional Action Team. This type of process, which ensures
that all parties are heard and the actions are not dictated, but mutually agreed upon, typically leads to a
greater sense of ownership to the plan, commitment to its recommendations, and a better chance mat it
will last over the long run. There are many techniques that can be used to develop plans based on a
consensus-approach, depending on the size of the group involved and the particular situation in the
Region of Concern. As mentioned previously, the optimal group size for this type of process is no more
than 7 to 15 participants; if more people are needed, it may be necessary to break into smaller subgroups.
In an ideal planning situation, a trained facilitator (especially one having some technical
familiarity with the issues facing the Region of Concern) will provide the skills needed to guide the
Regional Action Team. If it is not possible for the Regional Action Team to. have a professional
facilitator, die team leader, or someone from the lead agency, could perform these duties if the team
agrees to that approach and the chosen facilitator is able to remain objective. Alternatively, the lead
agency may want to offer facilitation training as part of its overall technical assistance to the regional
action planning process. Many organizations offer facilitation services and/or training. Regardless of
the approach used to obtain a facilitator, care should be taken in the selection process because the
facilitator has a great deal of influence on the overall success of the planning process. Selection criteria
include experience with similar planning situations, familiarity with a variety of approaches used to build
consensus, familiarity with the ground rules and procedures to conduct efficient meetings, enough
technical background to have some familiarity with Region of Concern issues, experience working with
groups of a similar size and composition, and ability to remain neutral (not representing any interests).
While it is beyond the scope of this document to provide a thorough discussion of the consensus-
building approach to decision-making, two key elements are essential (Fisher and Ury 1991; Doyle and
Straus 1976):
• Generating a wide variety of possibilities and alternatives before making a decision
• Measuring the possibilities against previously agreed upon, objective evaluation criteria to
determine final outcome.
When evaluating candidates for the facilitator's role, it would be useful to ensure they have familiarity
with this kind of approach.
__
-------
Regional Action Plan Guidance Conducting the Process
Facility-based pollution prevention planning provides one example of using this approach.
Typically, the facilities determine at the outset of the planning process the environmental problems or
issues of greatest concern. Using those priorities as the basis for further investigations, the facilities
identify a broad range of pollution prevention opportunities that will address targeted environmental
problems. This broad list of opportunities is then compared against predetermined evaluation criteria
(e.g., liability, regulatory compliance, implementation considerations, costs, environmental impacts) to
determine final choices (Chechile and Carlisle 1991; Gaunt et al. 1994; SAIC 1993). Chapter 7 and
Appendix D of this guidance document provide more information on decision-making using evaluation
criteria.
In order to provide effective input to the planning process, participants need to have enough
background information to form the basis for sound decision-making. Ideally, Regional Action Team
members will have some technical familiarity and understanding of the issues concerning a Region of
Concern. .The preparation of background materials in advance of planned meetings can also help. An
approach that was effective in conducting the Chesapeake Bay Program's Nonpoint Source Evaluation
Panel (Chesapeake Bay Program 1990) is briefly summarized below and may be applicable to the regional
action planning process:
Identify topics for investigation— Overall purpose of the planning process is defined by Lead
Agency and Regional Action Team, and discrete topics needing additional information are
identified. For example, the Regional Action Team may want to learn more about the
effectiveness of existing management approaches.
Prepare background and options papers— Lead agency (or volunteers from the Regional
Action Team) prepares background materials (e.g., short overview papers) on identified
topics. In addition, options papers, outlining specific choices the group may want to use as
the basis for its decision-making process, may be prepared. For example, the background
paper would summarize the effectiveness of existing management programs, while the options
paper would make suggestions on ways to modify/improve the existing programs.
Suggestions made in the options paper could be included by the Regional Action Team as
potential recommendations in the final plan. Background and options papers should be
distributed to team members in advance of the planned meeting so they can have time to
review the information (e.g., at least 1 week). The background and options papers may also
be supplemented by a presentation at the meeting.
Facilitate decision-making— Using the background and options papers as the basis for
dialogue at the meeting, a facilitator guides the group through a consensus-building process
to reach agreement on choices (e.g., which options paper recommendations to include in the
final plan).
•
Prepare plan— Using the decision-points generated from the options papers, supplemented
by additional input, the lead agency, or a subcommittee of the Regional Action Team,
-------
Regional Action Han Guidance Conducting the Process
prepares sections of the final plan. Each section, and the completed draft plan, are
distributed to the group for review, comment, and approval.
The length of time for this process obviously varies depending on the situation. It is necessary to give
team members adequate time to review materials before the scheduled meetings, so drafts should be
distributed at least a week in advance. As well, it is important to allocate sufficient tune at the meetings
to fully discuss issues and reach consensus. It may be necessary to discuss some issues over the course
of several meetings. As outlined hi Exhibit 3-8, the regional action planning process should plan on at
least the following schedule (Note: Schedule assumes meetings will be conducted for most of a day [e.g.,
10:00 a.m. to 3:00 p.m.]):
Defining vision, goals, and preliminary objectives—One early meeting, but to be modified
and refined throughout the process
Developing a problem statement—One meeting
Reviewing the efficacy of existing measures—Half of a meeting to one meeting. Could be
coupled with a preliminary overview of proposed implementation actions.
Developing implementation actions—At least two meetings.
3.6 PUBLIC PARTICIPATION AND EDUCATION
A public participation and education program should be implemented throughout the regional
action planning process. The Regional Action Team, in conjunction with the lead agency, should take
responsibility for defining a public participation approach. Because the Regional Action Team may be
consumed with developing the Regional Action Plan, a subset of the team, or a new group designated by
the Regional Action Team and/or lead agency, should take responsibility for involving the public. In
addition, the Regional Action Team should include ongoing public participation and education as an
implementation action for the Regional Action Plan.
The public participation and education program recommended for regional action planning is
different from, and moves beyond, stakeholder involvement on the Regional Action Team. Although
specific segments of the public are represented on the Regional Action Team, the extent and level of
public participation envisioned for the regional action planning process is much broader than the
representation provided by the Regional Action Team. In addition, me roles and responsibilities of the
Regional Action Team are very different than what is needed for public participation and education. The
Regional Action Team is a small group tasked with developing a Regional Action Plan, whereas the
_
-------
Regional Action Plan Guidance Conducting the Process
public participation and education approach is intended to build support for the Plan's implementation by
informing and enthusing the general public about the Region of Concern.
The public includes all citizens who live in the area—those represented by specific stakeholder
groups (e.g., Regional Action Team, civic groups, business associations, environmental organizations)
and citizens who may not be so represented (e.g., homemakers, subsistence fishers). Some examples of
specific sectors of the public that should be included in a public participation and education approach are
private businesses, homeowners associations, garden clubs, civic groups, schools and colleges, churches,
educational nonprofit organizations, and groups that represent racial and ethnic minorities. The broad
involvement of these groups is necessary to ensure successful plan implementation. Only when the public
understands and embraces the plan, will they be able to support implementation.
The importance of including the general public cannot be overemphasized. Public involvement
is a critical link between plan development and implementation. During this era of severe constraints on
both government and private sector funding, recognizing the value of the public as a resource is essential
to achieving the goals and objectives of Regional Action Plans. Likewise, public involvement in planning
will generate more commitment and volunteerism during implementation. An educated and motivated
public can provide much of the expertise, time, effort, and leadership needed to protect and monitor the
Region of Concern. Two factors are crucial for encouraging public involvement: (1) education about
the Region of Concern, including how the individual is a part of the problem and solution, and (2)
inclusion in the planning process, even if it is just to be kept informed. People work for that which they
understand and are committed, and people are committed to that which they help create. The public's
talents, energy, and technical and financial resources can be a cost-effective way of solving many of the
Region of Concern's problems.
One of the cornerstones of successful action planning efforts is the building of coalitions among
government agencies, parties affected by or contributing to problems in the Region of Concern, and an
informed, committed general public. Citizens are important hi keeping the regional action planning
process focused and moving towards its goals. As well, citizens groups may be active participants in the
process—serving as watchdogs, conducting volunteer cleanup and monitoring activities (e.g., schools and
churches can sponsor an "adopt a watershed" program, contribute to "Bay or river watch" computer
bulletin boards, or help with a speaker's bureau and with periodic conferences and workshops). The
resident of a Region of Concern will work harder to secure his or her own future than other, more
transient entities (e.g., distant government employees) (Hartig and Zarull 1992; Law and Hartig 1993).
3-36
-------
Regional Action Plan Guidance Conducting the Process
Because the development and implementation of Regional Action Plans is a long-term, ongoing process,
continued public involvement and a long-term commitment to regional action planning is essential.
Continued effective involvement can only be maintained, however, if all participants are
convinced that the time spent on regional action planning is productive. If the public does not see short-
term progress in remediation, they may become disillusioned and abandon the process. Short-term,
focused projects must be organized that are of interest to and achievable by the public. Building a record
of such successes is one mechanism of sustaining public involvement.
Two important components to any public participation program are to define the elements of
effective public participation and to design a public participation program mat will produce the support
needed for Regional Action Plans. Critical elements to every public participation program are trust,
communication, opportunity, and flexibility (Law and Hartig 1993). Trust must be established between
those directly involved in the regional action planning process and the public. Although it is the most
difficult of the four elements to attain, trust is also the most essential element in a successfully
implemented Regional Action Plan. To establish trust the following must occur: communication must
be open between participants, opportunities must exist for public input, and flexibility must be maintained
in the planning process to accommodate both new information and necessary changes in the program.
To build broad-based community support, effective public participation in the regional action
planning process should be encouraged throughout the entire planning process. Public involvement
should be initiated at the outset of the planning process with the distribution of information (e.g., press
releases, public meetings) about the planning process, including goals and objectives, approach, and
timeframes and milestones. Opportunities for continued public involvement should also be outlined at
that time. Actions to inform and involve the public should occur throughout the life of the planning
process, especially at critical stages, such as defining the problems, developing goals and objectives, and
brainstorming about implementation actions. The public should also be involved in monitoring the Plan's
implementation until restoration is complete. It is not intended that the public become part of the
Regional Action Team. Rather, the public participation and education approach provides opportunities
for the general public to provide input to the Regional Action Team. Such citizen involvement will
provide the Regional Action Plan with invaluable local knowledge, the continuous and vigorous public
oversight needed to overcome bureaucratic inertia, and the political will accomplish goals and objectives
(Hartig and Zarull 1992; Law and Hartig 1993).
3-37
-------
Regional Action Plan Guidance Conducting the Process
To maximize its effectiveness, the public outreach should compliment existing user groups and
avoid costly duplication of other groups' efforts. The Regional Action Plan's public participation
programs most useful role may be coordinating between and filling gaps in existing programs. There are
may ways to achieve these objectives; however, the following scenario is presented for example. First,
the Regional Action Team or its public participation subgroup should identify the Regional Action Plan's
educational priorities. Second, existing public education and outreach programs in the Region of Concern
should be surveyed. This investigation may demonstrate that many public and private groups in the
Region of Concern are addressing issues that the Regional Action Plan deems important. Once the list
of major education organizations is complied, the list can be analyzed for specific geographic areas or
focus on a specific issue. The Regional Action Plan represents many interests throughout the Region of
Concern and may serve a unique role as coordinator of a network of complementary, overlapping
interests. Gaps of information can be filled by sharing and disseminating information and resources.
Not all user groups are the same and the Regional Action Plan should determine the audience's
level of knowledge and involvement with the Region of Concern. The Regional Action Plan's public
participation program should provide a foundation for a true understanding of issues related to the Region
of Concern. Accordingly, the public participation program should devise a public education strategy that
provides for different levels of involvement. First, the Regional Action Plan may promote existing
programs. Second, the Regional Action Plan may seek to change existing programs or broaden their
focus to incorporate Regional Action Plan messages. Third, the Regional Action Plan should encourage
the creation of new programs when appropriate. For example, if another group is addressing an issue
adequately, the Regional Action Plan may help to promote and publicize its efforts. Whereas, if a second
group needs financial or logistical assistance, the Regional Action Plan may try to provide the resources
necessary for the group to organize its work. As a last resort, if the Regional Action Plan identifies an
educational need that no one else is addressing, then the Regional Action Plan should initiate a new
program.
Once it defines areas needing additional involvement, the team should implement a range of
public participation and education tools. In addition, the team should coordinate with any existing
communications activities that support the Chesapeake Bay Program. Throughout the planning process,
the public should be given regular updates through newsletters, fact sheets, and press releases. It is
important to communicate possible planning options to the public before they are narrowed or selected.
It may also be appropriate to publish a newsletter for each Region of Concern. Team members should
periodically speak to organizations that represent sectors of the general public. Among other activities,
-------
Regional Action Plan Guidance ,
Conducting the Process
the team should establish contacts with the media
and encourage regular stories and news clips.
The media should be encouraged to take
responsibility for educating the public at large by
contributing staff and other resources to
educational video spots and public service
announcements, along with other actions.
Depending on the public's involvement in the
Region of Concern, it may be useful to consider
establishing a nonprofit organization that could
promote public education and participation during
plan development and implementation or to build
Public Participation and Education Tools
Public meetings and hearings "
Public workshops and forums
, Public roundtaHes
Speakers' bateau •• *
Outreach to schools, such as teachers' guides
and curricula ,
' Citizen surveys •• ,
Citizen monitoring and/or watchdog groups
" Newsletters, videos, and television programs
Annual progress reports
Computer bulletin boards
Nonprofit educational groups
Cleanup days and other special events .
upon the efforts of an existing organization.
3-39
-------
Regional Action Plan Guidance Conducting the Process
CITED
Chechile, R. and S. Carlisle. 1991. Environmental Decision Making: A MidtidistipUnary Perspective.
New York: Van Nostrand Reinhold.
Chang, R. and K. Kehoe. 1994. Meetings that Work! Irvine: Richard Chang Associates, Inc.
Chesapeake Bay Program. 1990. Report and Recommendations of the Nonpoint Source Evaluation
Panel. CBP/TRS 56/91.
Davidson, C. Personal communication with Carla Davidson, Southeast Michigan Council of
Governments, in June 1994.
Doyle, M and D. Straus. 1976. How to Make Meetings Work! New York: Berkley Books.
Fisher, R. and W. Ury. 1991. Getting to YES: Negotiating Agreement Without Giving In. New York:
Penguin Books.
Gaunt C., K. Palmer, K. Allman, and G. Childs. 1994. Opportunities for Community-Based Pollution
Prevention Planning in the Chesapeake Bay Basin—The TIPPP Example. Prepared for the
Chesapeake Research Conference, June 1994.
Harris, V. Personal communication with Vicky Harris, Wisconsin Department of Natural Resources, in
June 1994.
Hartig, J., N. Law, and G. Wever. 1994. Applying TQM to Remedial Action Planning in the Great
Lakes. E2M. Spring 1994.
Hartig, J. and M. Zarull. 1992. Under RAPs—Toward Grassroots Ecological Democracy in the Great
Lakes Basin. Ann Arbor: University of Michigan Press.
Law, N. and J. Hartig. 1993. Public Participation in Great Lakes Remedial Action Plans. Plan
Canada. March 1993.
Letterhos, J. 1992. Dredging Up the Past: Tne Challenge of the Ashtabula River Remedial Action Plan.
In: Hartig, J. and M. Zarull. 1992. Under RAPs—Toward Grassroots Ecological Democracy
in the Great Lakes Basin. Ann Arbor: University of Michigan Press.
Schramik, R. Personal communication with Roy Schramik, Michigan Department of Natural Resources,
in June 1994.
Science Applications International Corporation (SAIQ. 1993. Fort Eustis/Fort Story Pollution
Prevention Program Plan. Prepared for Directorate of Engineering and Housing, Environmental
and National Resources Division, U.S. Army Transportation Center-Fort Eustis. AEPI Contract
Number DAC 88-92-D-002.
Shuyler, L. Personal communication with Lynn Schuyler, Chesapeake Bay Program, hi June 1995.
Swiniuch, R. Personal communication with Rich Swiniuch, New York State Department of
Environmental Conservation, in June 1994.
-------
CHAPTER 4
DEFINING THE PLAN'S VISION, GOALS,
OBJECTIVES, AND MILESTONES
-------
CHAPTER 4
TABLE OF CONTENTS
Page
4. DEFINING THE PLAN'S VISION, GOALS, OBJECTIVES, AND MILESTONES 4-1
4.1 THE NEED FOR VISION STATEMENTS, GOALS, OBJECTIVES, AND
MILESTONES 4-2
4.2 DEVELOPING EFFECTIVE VISION STATEMENTS, GOALS, OBJECTIVES,
AND MILESTONES 4-4
4.2.1 Conducting Preliminary Background Research 4-5
4.2.2 Developing a Vision Statement 4-6
4.2.3 Establishing Goals, Objectives, and Milestones 4-11
References Cited 4-15
EXHIBITS
4-1. Overview of Steps Needed to Develop a Vision Statement, Goals, Objectives, and
Milestones 4-4
4-2. Example of a Relatively Specific Vision Statement for the Citizens' Desired State of the
Lower Green Bay and Fox River Ecosystem , 4-7
4-3. Example of a General Vision Statement and Associated Goals Developed for the
Comprehensive Conservation and Management Plan for the San Francisco Bay 4-8
4-4. Common Vision Sketch of the Desired Future State for the Chesapeake Bay Basin 4-10
4-5. Example Questions for a Citizen Survey 4-11
4-6. Regional Action Plan Example—Vision Statement, Goals, Objectives, and Milestones 4-13
-------
Regional Action Plan Guidance Defining Goals
CHAPTER 4. DEFINING THE PLAN'S VISION, GOALS,
OBJECTIVES, AND MILESTONES
The successful development and implementation of Regional Action Plans depends, in part, on
having an overall vision and clearly defined and measurable goals and objectives. Many comprehensive
planning efforts, such as Great Lakes remedial action planning, have found that establishing an articulated
long-term vision statement at the beginning of the planning process is an important prerequisite for the
subsequent definition of goals and objectives (Hartig et al. 1994; Hartig and Zarull 1992). Once an
overall vision for a Region of Concern is determined and agreed upon by all significant stakeholders
(represented by the Regional Action Team), the process of establishing goals, objectives, and milestones
becomes more clear. Establishing milestones throughout the planning process is an effective way to
maintain momentum in plan development and implementation, especially with regards to measuring
progress.
Regional action planning is a hierarchical process that proceeds from a general, all-encompassing
vision statement to more specific goals, objectives, and milestones for achieving the vision. Each step
is an important link in the process and a necessary prerequisite for the next aspect of the planning effort.
As a general rule, the steps should be completed sequentially to ensure that actions completed later in the
process are consistent with the vision statement and goals. However, many parts of the regional action
planning process are iterative, and the plan should be flexible to accommodate change as more knowledge
is gained about the Region of Concern. Goals, and especially objectives, are likely to be refined or
otherwise modified as the information base grows.
This chapter addresses the importance of using stakeholders and the general public to develop a
vision statement, goals, objectives, and milestones. This chapter also provides suggested techniques for
establishing vision statements, goals, and objectives and presents a variety of examples. Drawing in part
on the experiences of planning efforts in other areas of the United States, this chapter summarizes some
key considerations in developing effective goals. Specifically, the chapter addresses:
• The Need for Vision Statements, Goals, Objectives, and Milestones
• Developing Effective Vision Statements, Goals, Objectives, and Milestones.
Developing a vision statement and corresponding goals is a crucial early phase of the planning
process that focuses the additional investigations needed to develop an effective implementation approach.
4-1
-------
Regional Action Plan Guidance
Defining Goal*
This chapter defines objectives as more specific,
often measurable, subparts of goals. Preliminary
objectives and milestones may be prepared early
in the planning process but are likely to be
revised and expanded as more information is
generated throughout plan development.
Milestones, in particular, are likely to evolve
from general to specific as the planning process
progresses. Initial milestones will be developed
as general targets associated with a goal, while
later milestones will be more specific to address
each step of an implementation action.
4.1 THE NEED FOR VISION STATE-
MENTS, GOALS, OBJECTIVES, AND
MILESTONES
The most important task in developing a
Regional Action Plan is arguably the formulation
of a vision statement and corresponding goals and
objectives. The vision statement identifies the
stakeholders' common purpose for the Region of
Concern and provide* the glue for holding the
other components of the Regional Action Plan
together. Empowering stakeholders to develop
and reach consensus on the Regional Action
Plan's vision statement, goals, and objectives is
absolutely necessary to design an effective
implementation approach. Working toward a
unified vision and goals also focuses the planning process, thereby increasing the opportunity for efficient
resource use.
The planning process is likely to be much more productive if early Regional Action Team
consensus is achieved on the vision statement and goals. Such consensus establishes a common purpose
and focus for the Regional Action Team. Operating without a clear vision statement and goals is like
Definitions and Examples of Vision Statement,
Goals, Objectives, god Mflestooes*
• Vision Statement— A very general statement
identifying me dented future state of * Region
of Concern that provide* overall direction for
the regional action planning process,
Example: A healthy river and Boy environment
providing the quality of water and habitat
needed for indigenous species and recreational
fishing.
• Goal*— Statements more specific than the vision
statement, bat anil generxl, mat describe »
desired condition ramer man a carefully defined
end-point. Goals, when taken together, win
move toward achieving me vision for me
Region of Concern. Goals can be both short"
and long-term and most be realistic. It is
important to develop a mix of goals mat are
easy to impletnent/achieve earfy in me process
(this will hdp build comtmtment/buy-m) and
goals that may be mow difficult {but ace «tfll
realistic) to implement/achieve. ^ ,.;•-•*&•••
' v%.' ''''-•'
Example: Return a sustainable recreational
fishery in the river.
• Objective*—- More specific subsets of goals,
Objectives can be used to guide me selection of
concrete implementation actions and to judge
proposed actions for funding priorities. They
must be realistic, time-oriented, and sufficientty
quantifiable to allow measurement of me plan's
•access. " ', ,.- ^W--
Example: Reduce ambient toxidty in the water
and sediment* in the Region of Concern to at to
eliminate fith consumption advisories,
• MBestone*-Rri*te objective* to specific
schedules. Again, it ia useful to nave bom
short-term and long-term objective*.
Example: Reduce ambient Mdctiyinthe water
eliminate fish consumption advisories by the
year 2000. §
Examples are
4-2
-------
Regional Action Plan Guidance Defining Goals
traveling without a destination. Loosely defined objectives and milestones will fail to give the Regional
Action Team the roadmap needed to measure progress during implementation. Stakeholder groups (e.g.,
Regional Action Team), including the lead agencies, often do not spend the time necessary to define
property a vision, goals, objectives, and milestones. Frequently, water resources planning efforts default
to the Clean Water Act goal of "restoring beneficial uses" to the Region of Concern. While this is an
admirable goal, it does not provide the level of specificity needed to guide the regional action planning
process or to develop a measurable implementation approach. Stakeholder groups should be encouraged
to think beyond a default regulatory goal to more broadly consider whether f^^«t'ona', more specific (and
possibly less regulatory) goals should be developed.
Vague and undefined goals, objectives, and milestones cause problems hi both developing and
implementing Regional Action Plans. For instance, proposed implementation actions may be debated to
a greater extent during plan development if the Regional Action Team did not build a consensus on goals
and objectives earlier in the process. The process of developing a vision statement and goals can unify
stakeholders. Developing an early consensus, however, does not guarantee that the group will agree on
an implementation approach. Traditionally, these decisions, which incorporate economic, political, and
social issues, are much harder to reach because they more directly affect stakeholders.
Undefined goals, objectives, and milestones can also erode plan implementation because they
create a situation that weakens the accountability of parties responsible for implementing the plan. For
instance, it is very difficult to measure success or to hold responsible parties, including public agencies,
accountable if the plan's goals and objectives are not specific or measurable. Unclear goals and
objectives can also reduce the value of a monitoring program became it is difficult to measure the results.
Securing commitments from elected officials to the goals and objectives will often increase the
political accountability and impetus for the Regional Action Plan. In fact, commitment from top level
management is often critical to a plan's success. Frequently, this level of buy-in may provide the needed
authority (including regulatory) and financial resources required to improve plan development and
implementation. Elected officials on the local and state level can also embrace the goals as political
objectives.
Goals and objectives will evolve and change as the planning process moves forward. As more
is learned about the Region of Concern, the goals and objectives may need to be modified to reflect better
4-3
-------
Regional Action Plan Guidance Defining Goals
the current state of knowledge. A successful regional action planning effort must be iterative, with the
incorporation of re-evaluation steps and opportunities for plan adjustment.
43 DEVELOPING EFFECTIVE VISION STATEMENTS, GOALS, OBJECTIVES, AND
MILESTONES
This section describes the steps that the Regional Action Team should take hi developing a
Regional Action Plan that links a vision statement, goals, objectives, and milestones to problems and
implementation actions. Although the process is iterative, the steps described in Exhibit 4-1 should
generally be followed. The remainder of this section describes some of these steps hi.the following
subsections:
• Conducting preliminary background research (Step 1)
• Developing a vision statement (Step 2)
• Establishing goals, objectives, and milestones (Steps 3, 5, and 6).
The subsections provide an overview of the process, including recommended methodologies, that could
be applied when developing a vision statement, goals, objectives, and milestones. Information related
to further problem definition (Step 4) is presented in Chapter 5 of this document.
Exhibit 4-1. Overview of Steps Needed to Develop a Vision Statement,
Goals, Objectives, and Milestones
1. Conduct preliminary background research—Gather and synthesize readily available information to
prepare a general overview of chemical contaminant-related problems that are affecting the Region of
Concern. Coordinate and, if applicable, integrate Regional Action Team efforts with existing plans and
efforts (e.g., the Anacostia Watershed Restoration Committee and its six-point plan).
2. Develop vision statement—Use the background research to stimulate Regional Action Team development
of a vision statement.
3. Identify preliminary goals and objectives—Use the background research, problem overview, and vision
statement to facilitate Regional Action Team decision-making on preliminary goals and objectives.
4. Further define problems—Use the process presented in Chapter 5 of this document to further define
problems in the context of the vision statement, goals, and objectives.
5. Refine goals and objectives—Modify preliminary goals and objectives and/or develop new ones, as
necessary, as more is learned about the Region of Concern throughout the planning process, especially
as problems become better understood.
6. Develop milestones—As the information base on the Region of Concern grows, it is possible to begin
developing milestones for identified goals and objectives. Milestones will range from the general
(e.g., achieving a goal by a certain year) to the specific (e.g., schedule for implementing each step of a
proposed action).
4-4
-------
Regional Action Plan Guidance Defining Goals
Throughout the regional action planning process, technical experts and the scientific community
should review the team's recommendations and supporting information to ensure that stakeholders have
access to the most recent technical approaches and information and to provide an opportunity for
balancing stakeholder interests with scientific information, as appropriate. Periodically, the team's
progress should also be presented to the general public for their review and contributions. Section 3.6
of Chapter 3 provides more information on the importance of public participation.
4.2.1 Conducting Preliminary Background Research
It is important to have a general understanding of the problems facing the Region of Concern
before a vision statement and preliminary goals and objectives can be established effectively. The reason
for this is obvious—it is not expedient to have the Regional Action Team spend time and resources
developing goals and objectives for problems that are not of concern. In later stages of the planning
process, a much more detailed definition of the problems is needed to develop an effective, targeted
implementation approach. Chapter 5 describes how to refine the understanding of problems by acquiring
and interpreting information on the nature, extent, and sources of chemical contamination contributing
to the problem. It is not practical nor desirable to complete these more detailed investigations before
preliminary goals and objectives are established. Rather, goals and objectives should be used to focus
the specific investigations needed to define problems so that a well-designed implementation approach can
be developed.
The lead agency can use existing materials (e.g., reports, journal and newspaper articles, and fact
sheets) and can contact groups or individuals familiar with the Region of Concern to build a basic
understanding of issues and problems in the Region of Concern. The lead agency should present these
background investigations for the Regional Action Team as a short paper or fact sheet summarizing the
problems and other relevant information on the Region on Concern. Background materials prepared by
the lead agency and distributed to the Regional Action Team in advance of its planned meeting for
establishing a vision statement and preliminary goals and objectives, supplemented by presentations at
the meeting and by Regional Action Team input, should provide the foundation needed to establish
consensus on a preliminary problem definition and corresponding vision statement, goals, and, possibly,
objectives. Because objectives are more quantifiable, they may be best developed later in the planning
process. While it is necessary to focus the planning process by identifying key problems and
corresponding goals, it is important not to focus too narrowly in these early planning stages, or other
important problems could be excluded. The regional action planning process is a challenging one—
4-5
-------
Regional Action Plan Guidance Defining Goals
although it is necessary to focus the study to effectively use limited resources, it is also important to
maintain an open mind and flexibility so that modifications can be made as more information is garnered.
Establishing specific goals and objectives based on an adequate general understanding of the
environmental problems early in the planning process can minimize conflict and arguments about specific
actions later on. For example, it may be clearer to an industry representative why stormwater plans and
monitoring are necessary in a particular location within the Region of Concern if the stakeholder group
establishes goals and objectives relating to the control of chemical contaminants from stormwater early
in the process.
4.2.2 Developing a Vision Statement
Stakeholders should develop a vision statement as a way of creating a framework for more
specific goals, objectives, and milestones. A vision statement should be a broad representation of
stakeholder values, both human and non-human. The statement should convey a desired state for the
Region of Concern. Stakeholders should consider the vision statement their overall mission. The vision
should be a practical statement based on the physical, social, and political conditions in the Region of
Concern. The vision statement, and the related goals and objectives, should recognize the current and
expected land uses in the watershed surrounding the Region of Concern. In Baltimore Harbor or the
Elizabeth River, for example, restoring water bodies to pristine conditions for aquatic life is not practical
because of the current levels of chemical contamination and the expectation that most of the land will
remain in urban and industrial use. A realistic vision statement could include restoring recreational
fishing for species currently found in these Regions of Concern. Vision statements developed by
stakeholders involved in regional action planning in several areas, including the Lower Green Bay area
in Wisconsin and the San Francisco Bay in California, vary in their level of detail (San Francisco Estuary
Project Management Committee 1993; Wisconsin Department of Natural Resources 1987; Wisconsin
Department of Natural Resources and Green Bay Remedial Action Plan Public Advisory Committee
1993). Most statements, however, are broad-based and general, such as ensuring a healthy river and bay
ecosystem.
As an example of a relatively specific vision statement, Exhibit 4-2 summarizes the citizens'
desired state of the Lower Green Bay and Fox River Ecosystem that was developed by the Lower Green
Bay Remedial Action Plan Citizens Advisory Committee (Wisconsin Department of Natural Resources
and Green Bay Remedial Action Plan Public Advisory Committee 1993). This vision statement relates
closely to the goals and objectives. For instance, the stakeholders who developed mis statement obviously
--
-------
Regional Action Plan Guidance Defining Gods
Exhibit 4-2. Example of a Relatively Specific Vision Statement for the Citizens' Desired State of
the Lower Green Bay and Fox River Ecosystem
1. A healthy river and Bay environment providing water quality and habitat for balanced and
productive wildlife and plant communities including a well-balanced, sustainable, and edible sport
and commercial fishery.
2. Water-based recreation opportunities including:
a. Accessible local swimming beaches on the Bay; and
b. Adequate boating areas and facilities,
3. Fox River and Lower Green Bay water quality that protects human health and wildlife from effects
of contaminants and meets water quality standards which could provide for drinkable water after
standard treatment.
4. Balanced public and private shoreline usage including park, agricultural, commercial, residential,
and industrial lands.
5. An economical transportation network including both water and land-based systems which
adverse environmental effects.
6. Point and nonpoint discharges and runoff consistent with the maintenance of the desired water
quality future state.
Source: Wisconsin Department of Natural Resources and Green Bay Remedial Action Plan Public Advisory
Committee (1993).
believed that a specific vision statement was necessary to guide plan development and to communicate
a vision effectively to the public. The statement includes elements mat other planning efforts, including
the San Francisco Estuary Project, would include as goals and even objectives. For example, the element
that involves point and nonpoint discharge and runoff control could be an appropriate objective.
Developing a more specific vision statement may be possible if there is broad understanding of the
problem and a general consensus on appropriate solutions early in the planning process. Also, as stated
previously, the incorporation of vision statements and goals from planning documents that already exist
for the Region of Concern or similar areas, such as watershed management plans, may allow for the
development of a more specific vision statement.
Exhibit 4-3 provides an example of a general vision statement used as a preface for more specific
goals. More man 100 stakeholders contributed to the vision statement, which was developed for the
Comprehensive Conservation and Management Plan for the San Francisco Bay Estuary Project (San
Francisco Estuary Project Management Committee 1993). The Estuary Project example, like the one for
the Lower Green Bay, offers a vision that incorporates an ecosystem approach, not only concern about
protecting human health and the environment from chemical contaminants.
4-7
-------
Regional Action Plan Guidance Defining Goals
Exhibit 4-3. Example of a General Vision Statement and Associated Goals Developed for the
Comprehensive Conservation and Management Plan for the San Francisco Bay
Vision Statement: "We, the people of California and the Sao Francisco Bay-Delta Region, believe the
San Francisco Bay-Delta Estuary is an international treasure and that our ongoing stewardship is critical
to its preservation, restoration and enhancement. Acknowledging the importance of the estuary to our
environmental and economic well-being, we pledge to achieve and maintain an ecologically diverse and
productive natural estuarine system."
Goals:
• Restore and protect a diverse, balanced, and healthy population of fish, invertebrates, wildlife,
plants, and their habitats, focusing on indigenous species.
• Assure that the beneficial uses of the Bay and Delta are protected.
Improve water quality, where feasible, by alimiriating and preventing pollution at its source, while
minimi Ting the discharge of pollutants from point »*^ oonpoint sources *TK^ remediating existing
pollution.
Manage dredging and waterway modifications to minimta* adverse environmental impacts.
Effectively manage and coordinate land and water use to achieve the goals of the Estuary Project.
• Increase our scientific understanding of the Estuary and use that knowledge to better mmn*g* the
Estuary.
• Develop and expand nonregulatory programs, such as public-private partnerships and market
incentives, in conjunction with regulatory programs, to achieve the goals of the Project.
• Preserve and restore wetlands to provide habitat for wildlife, improve water quality, and protect
against flooding.
• Assure an •A»f«qtf freshwater flow as one of the essential components to restore and maintain a
clean, healthy, and diverse Estuary.
Source: San Francisco Estuary Project Management Committee (1993).
Although this guidance document focuses on chemical contaminant*., the Regional Action Team
may want to establish a vision statement and goals within the framework of a more holistic approach
concerned about restoring a broader desired state (e.g., ecosystem restoration) for the Region of Concern.
This can be accomplished by gathering information from stakeholder groups addressing other concerns,
such as wetlands and wildlife, and planning goals, including public access and recreation.
Several methods, some more elaborate than others, can be used to develop vision statements.
The methods include using visual preference or community image surveys, verbally characterizing a
vision, and employing citizen surveys. A useful and creative way to develop a vision statement is to
perform a visual preference survey of the stakeholders' images or visions of the desired future state of
the watershed. Stakeholders (e.g., the Regional Action Team) are shown a series of photographic slides
mat illustrate possible visions for the watershed. The slides, taken from existing areas, should provide
4-8
-------
Regional Action Plan Guidance ' Defining Goats
a range of visions, representing ideal and current conditions, of the various qualities of a desired future
state (e.g., fishing, other recreation, public access, wildlife, riparian habitat). As few as 40 slides can
be used. The group should rank the slides on a scale of 1 to 5, with 1 being the preferred vision. The
purpose of this exercise is to create a common vision of the Region of Concern. If appropriate, after the
group establishes the vision, a local artist (perhaps a community college art teacher or another person
interested in watershed protection that could volunteer his or her tune) could visit the group and draw
a sketch based on the shared understanding. Exhibit 4-4 provides an example of a common vision sketch
based on the environmental indicators program of the Chesapeake Bay Program. The use of pictorial
images to convey a vision is gaining popularity in the design of community land use and development
plans and is appropriate for identifying a vision for the uses and qualities of a watershed (Nelessen 1994).
The general public can also provide input for establishing the vision statement. When the vision,
goals, and objectives are being established, large meetings and workshops should be held to invite public
participation. A visual preference survey can be given at a public meeting, or the common vision, as
well as possible alternative visions, established by the Regional Action Team can be displayed and
discussed.
Other ways of getting public input for the vision-setting process include:
• Asking students to develop images for class projects
• Videotaping images of the watershed (perhaps based on another area that is already at a
"desired future state") and showing these images on local news programs and to community
and business groups.
Citizen surveys, either by mail or telephone, to determine public perceptions of the problems and
images for a desired future state provide another technique for developing a vision statement. Preferences
or tradeoffs between different values, such as aquatic habitat and public access to riven, can be gauged
and numerically weighted during these surveys or focus groups. Preference surveys are often used in
environmental management to determine the relative importance of environmental and other attributes.
For example, this technique has been used extensively in siting studies for industrial facilities. Using the
resulting information, stakeholders and public agency decision-makers can craft solutions that consider
public preferences. Exhibit 4-5 provides a list of example questions mat could be included hi a citizen
survey.
4-9
-------
Exhibit 4-4. Common Vision Sketch of the Desired Future State for the Chesapeake Bay Basin
Forests
Falling Aquatic
Grasses
WHERE WE
STARTED
WHERE WE
ARE HEADED
Source: Chesapeake Bay Program (\994a).
-------
Regional Action Plan Guidance Defining Goals
Exhibit 4-5. Example Questions for a Citizen Survey
1. What role or interests do you have in the Region of Concern?
2. What do you see as the major problems (associated with chemical contamination) in the Region of
Concern?
3. Has chemical contamination in the Region of Concern caused you to stop doing or do less of the
things you used to do for recreation (e.g., fishing, boating, sightseeing)?
4. Has chemical contamination in the Region of Concern affected you in any other ways?
5. Do you think that the current water quality in the Region of Concern makes it very safe for
swimming, somewhat safe, somewhat unsafe, or very unsafe?
6. Do you think that the current water quality in the Region of Concern makes it very safe to eat fish
and other seafood from the Region of Concern, somewhat safe, somewhat unsafe, or very unsafe?
7. Do you think that the current water quality in the Region of Concern makes it very safe for fish
and other aquatic life that live in the Region of Concern, somewhat safe, somewhat unsafe, or
very unsafe?
8. What do you think the highest priority should be for the Region of Concern (e.g., to make it safe
for swimming, safe to eat seafood from, safe for fish and other aquatic life)?
9. Can you think of any other improvements, with regards to problems associated with chemical
contamination, that you would like to see in the Region of Concern?
10. What is your primary goal for addressing chemical contamination issues in the Region of
Concern?
11. What method or techniques should be used to involve citizens in the development of the Regional
Action Plan (e.g., newsletters, workshops)?
Sources: Chesapeake Bay Program (1994b); Lane Council of Governments (1995).
4.2.3 Establishing Goals, Objectives, and Milestones
Specific goals, objectives, and milestones must be developed to realize the vision established for
the Regional Action Plan. They should be clearly stated and supported by a realistic assessment of the
problem and the feasibility of resolution. The goals should encourage physical change hi the watershed,
such as restoring fish and wildlife populations. Goals should also be established for improving scientific
understanding and public education, as well as for developing management approaches, such as regulatory
and nonregulatory programs (e.g., public-private partnerships).
Objectives are even more specific than goals. They can establish quantitative measures, such as
a percentage reduction in a particular chemical contaminant or the attainment of a particular water quality
standard. Building a capital improvement project, such as a retention basin for combined sewer
4-11
-------
1
Regional Action Plan Guidance Defining Goals
overflows, or creating a public education center are other examples of objectives. Achieving high profile
and easy to implement objectives, such as public education centers and improved public access to the
Region of Concern, early in the plan's implementation can create momentum and public support for more
complex and expensive objectives, such as the establishment of a stonnwater retention basin. Preliminary
objectives can be developed early in the planning process, at the same time goals are being established.
Because they contain more specific information than goals, however, objectives will probably be
developed and refined throughout the process as the information base expands.
Milestones should relate objectives to a specific end-point (e.g., product) and schedule. For
example, an appropriate milestone could be to reduce polychlorinated biphenyl concentrations in sediment
in a particular stream section by 40 percent by the year 2000.
Exhibit 4-6 shows the relationship among the vision statement, goals, objectives, and milestones.
As shown in this exhibit, goals and objectives should be measurable. Consequently, milestones provide
timetables for monitoring and tracking progress towards achieving goals and objectives. The Regional
Action Team also may choose to add comments reflecting possible opportunities and challenges associated
with the goals and objectives. For example, objective I.A.3 simply notes that the milestones would
necessitate nearly a "... 30 percent reduction from current levels." The exhibit formats are useful models
for Regional Action Plans in the Chesapeake Bay area.
If the process to establish goals and objectives adequately accounts for the interests of
stakeholders, it should be possible to get volunteers (e.g., members of the Regional Action Team) to
marshal! specific implementation actions. As a backup strategy, the lead agency may want to give the
goals and objectives more clout by incorporating them into the Clean Water Act regulatory framework.
The process would formally establish a goal as a regulatory standard so that it becomes a designated use
for the Region of Concern or a segment of this area. This procedure must be performed in accordance
with applicable water quality regulations (40 CFR 131).
In certain Regions of Concern, plans and programs related to watershed restoration have been
developed and are being implemented. For example, a six-point action plan has been developed for the
Anacostia River watershed (Anacostia Restoration Team and MWCOG 1991). As mentioned previously
hi this chapter, the Regional Action Team should review existing plans and programs already developed
for the Region of Concern and similar locations when establishing goals, objectives, milestones, and
specific implementation actions. The team should, for example, review other Regional Action Plans,
_
-------
Exhibit 4-6. Regional Action Plan Example—Vision Statement, Goals, Objectives, and Milestones*
Vision Statement
Goals
Milestones
Comments
I. Water quality that
protects human health and
wildlife from the effects of
chemical contaminants and
meets water quality
standards that could provide
drinkable water after
standard treatment
LA Achieve and maintain water
quality that protects the ecosystem
from the adverse effects of
chemical contaminants on shoreline
and aquatic vegetation, fish, aquatic
life, and wildlife utilizing the
aquatic resources and that protects
human health
LA. 1 Reduce chemical contaminants in the water
column to levels that meet the most stringent state
and/or federal fish consumption advisory levels
and protect human health, wildlife, and fish and
aquatic life, as well as their reproductive success1
Achieve by
the year 2000
a
I
I.A.2 Reduce chemical contaminants in fish tissue
to levels that protect the humans, birds, and
animals that consume them and that protect
reproductive success1
Achieve by
the year 2000
I.A.3 Reduce chemical contaminants in wildlife
tissue to levels that protect human and wildlife
health and do not impair reproductive, success
(i.e., Food and Drug Administration Action Level
of 2.0 X l
Achieve by
the year 2000
30-percent
reduction from
current levels
I.A.4 Reduce chemical contaminants in sediment
or the release from sediment to levels that are not
acutely or chronically toxic to fish and aquatic life
or humans and wildlife that consume them1
Achieve by
the year 2005
Items are listed for illustrative purposes only and are not intended to be an exhaustive list. They are partly based on the Lower Green Bay Remedial Action Plan,
1993 Update (Wisconsin Department of Natural Resources and Green Bay Remedial Action Plan Public Advisory Committee 1993).
Specific contaminants include polychlorinated biphenyls, dioxin, DDT, ammonia, mercury, and lead.
-------
Regional Action flan Guidance Defining Goals
area-wide water quality management plans (e.g., 208 plans, 319 plans, tributary strategies), sewer service
area plans, wastewater facility plans, and other specific watershed plans. Proceeding from mis review,
the group can incorporate ongoing initiatives into the Regional Action Han. For instance, if an existing
plan establishes goals for stonnwater management (e.g., development of municipal stormwater
management plans), these goals should be incorporated, as appropriate, into the Regional Action Plan
rather than developing new goals. It is also important to ensure that goals, objectives, and milestones
developed for the Regional Action Plan are not in conflict with ongoing planning efforts.
4-14
-------
Regional Action Plan Guidance Defining Goals
Anacostia Restoration Team and Metropolitan Washington Council of Governments (MWCOG). 1991.
A Commitment to Restore Our Home River— A Six Point Action Plan to Restore the Anacostia
River. Washington, DC: Metropolitan Washington Council of Governments. Publication
Number 91708.
Chesapeake Bay Program. 1994a. Environmental Indicators Presentation— Photographic Slides and
Speaker's Notes.
Chesapeake Bay Program. 1994b. Chesapeake Bay Attitudes Survey.
Hartig, J. and M. Zarull. 1992. Under RAPs— Toward Grassroots Ecological Democracy in the Great
Takes Basin. Ann Arbor: University of Michigan Press.
Hartig, J., N. Law, and G. Wever. 1994. Applying TQM to Remedial Action Planning in the Great
Lakes. &m (Spring 1994).
Netessen, A. 1994. Visions far an American Dream, Chicago: American Planning Association.
San Francisco Estuary Project Management Committee. 1993. San Francisco Bay Comprehensive
Conservation and Management Plan. San Francisco: San Francisco Estuary Project.
Wisconsin Department of Natural Resources. 1987. Lower Green Bay Remedial Action Plan: First
Annual Progress Report. Madison: Wisconsin Department of Natural Resources.
Wisconsin Department of Natural Resources and Green Bay Remedial Action Plan Public Advisory
Committee. 1993. Lower Green Bay Remedial Action Plan, 1993 Update, Madison: Wisconsin
Department of Natural Resources.
Lane Council of Governments. 1995. How the McKame Watershed Coundl Got Started. Eugene:
Lane Council of Goven
4-15
-------
CHAPTERS
DEFINING THE PROBLEM
-------
CHAPTERS
TABLE OF CONTENTS
Page
5. DEFINING THE PROBLEM 5-1
5.1 IDENTIFYING AND RANKING ADVERSE AMBIENT EFFECTS 5-5
5.1.1 Identifying Adverse Ambient Effects 5-5
Using Regions of Concern Information 5-6
Reviewing Additional Sources of Information 5-7
5.1.2 Ranking Adverse Ambient Effects 5-12
5.2 IDENTIFYING AND RANKING CHEMICAL CONTAMINANTS AND THEIR
SOURCES 5-14
5.2.1 Identifying Chemical Contaminants 5-15
5.2.2 Identifying Contaminant Sources 5-23
5.2.3 Ranking Chemical Contaminants and Sources ' 5-26
Ranking Chemical Contaminants 5-27
Ranking Sources of Chemical Contaminants . 5-30
References Cited 5-35
EXHIBITS
5-1. Description of the Steps Required for Defining the Problems in a Regional Action Plan 5-3
5-2. Potential Sources of Information 5-9
5-3. Example Goals/Beneficial Uses and Associated Impairments 5-13
5-4. Summary Checklist of Factors To Be Considered During Initial Data Reviews 5-18
5-5. Example Calculation for Estimating Receiving Water Concentrations 5-22
5-6. Sample Evaluation to Determine Chemical Contaminants of Concern 5-28
5-7. Example Prioritization for Chemicals To Be Addressed in a Region of Concern 5-31
-------
Regional Action Plan Guidance
Defining the Problem
CHAPTERS. DEFINING THE PROBLEM
The overarching objective when
defining problems in the context of regional
action planning is to assemble and evaluate
sufficient information to develop a sound,
defensible, and targeted implementation
approach for the Regional Action Plan (see
Chapter 7 of this document for information on
developing an implementation approach).
This requires identifying adverse ambient
effects, linking them to elevated concentra-
tions of chemical contaminants, and
identifying sources of contamination
contributing to the elevated concentrations.
The approach further requires focusing on
priorities established by the Regional Action
Team so that limited resources can be used
most efficiently and investigations can be
completed in a timely fashion. As described
later in this chapter, the investigations needed
to define problems in the Region of Concern will
following three tasks are critical to the process:
Defining Problems for the Regional Action Plan
Regions of Concern are designated when available data
show evidence for a causal relationship between adverse
ambient effects (i.e., effects) and elevated concen-
trations of chemical contaminants above thresholds
associated with adverse effects (i.e., stressots)
(Chesapeake Bay Program 1994). Therefore, the
problem definition portion of the Regional Action Plan
must identify adverse ambient effects (e.g., water
column and sediment toxicity, impaired ecological
community structures, fish and shellfish tissue
contamination) and link them to elevated levels of
chemical contamination. Further, to develop an
implementation approach for the Regional Action Plan,
the problem definition must also include an assessment
of the sources contributing to the elevated levels of
chemical contamination. The investigations should be
geared toward defining the linkages between adverse
ambient effects, elevated levels of chemical contamina-
tion, and sources of the elevated levels of chemical
contamination.
To streamline the planning process, all investigations
must be prioritized. The problem definition should
prioritize adverse ambient effects in order of preference
for future actions. The types of chemical contaminants
causing the adverse effects, and their sources, should be
similarly prioritized.
move from the general to more specific, although the
1. Identifying and prioritizing adverse ambient effects associated with chemical contamination
2. Identifying and prioritizing chemical contaminants causing or contributing to the adverse
ambient effects
3. Identifying and prioritizing sources of chemical contaminants.
Although described separately, many of the activities to complete these investigations are similar,
especially when evaluating chemical contaminants and their sources, and may be conducted
simultaneously. These investigations are also dynamically related to the development of the Regional
Action Plan's vision statement, goals, and objectives. As described in Chapter 4 of this guidance, a
preliminary overview of problems is used by the Regional Action Team to develop a vision statement,
5-1
-------
Regional Action Plan Guidance Defining the Problem
and initial goals and objectives. The vision statement, and initial goals and objectives, are used, in turn,
to focus further, more specific, investigations needed to define problems (e.g., providing more detail on
chemical stressors and their sources).
It is crucial to keep the problem definition investigations focused. Not only should the
investigations target priorities established by the Regional Action Team, but existing information (e.g.,
technical reports) should be used whenever possible. Additional analyses (e.g., evaluating and/or
integrating environmental data bases, calculating waste load allocations) should only be conducted if the
existing materials do not provide sufficient background information for sound decision-making. Original
investigations, such as developing and implementing a monitoring program, are beyond the scope of the
Regional Action Plan, but could be proposed as an implementation action in the plan.
Exhibit 5-1 summarizes an approach that will help focus problem definition investigations for the
Regional Action Plan. This chapter describes available sources of information relevant to conducting the
investigations and provides an overview of techniques that can be used for ranking and decision-making.
Chapter 4 describes how to develop a vision statement and define preliminary goals and objectives using
available information on problems. The chapter presents information in the following two sections:
• Identifying and Ranking Adverse Ambient Effects
• Identifying and Ranking Chemical Contaminants and Sources.
As shown in Exhibit 5-1, the lead agency, supported by existing groups, and/or subject matter
experts, will usually initiate this process by providing an overview of the problems (including a summary
of adverse ambient effects and associated chemical contaminants and their sources), based on readily
available information, to the Regional Action Team at one of its first meetings. This general background
information is used by the Regional Action Team to facilitate development of a. vision statement, and
preliminary goals and objectives (see Chapter 4). The vision statement and preliminary goals and
objectives are necessary to guide the planning process and focus further investigations. The Regional
Action Team will also use this background information, in conjunction with the vision statement and
preliminary goals and objectives, to begin prioritizing the adverse ambient effects according to level of
importance for future action. The Regional Action Team may feel that the available materials provide
sufficient information to prioritize ambient effects, or it may request additional investigations. It is
important that the Regional Action Team complete its prioritization of adverse ambient effects as early
in the planning process as possible, because this information will guide most subsequent investigations.
5-2
-------
Regional Action Plan Guidance Defining the Problem
Exhibit 5-1. Description of the Steps Required for Defining the Problems in a Regional Action Flan
• Prepare Overview of Problems
Hie lead agency (and/or its partner or designee) will assemble readily available background information
to prepare an overview of problems for consideration by the Regional Action Team. Information should
be evaluated to summarize what is readily known about adverse ambient effects, elevated levels of
chemical contaminants, and sources of the chemical contaminants. Three main sources of information
should be evaluated at this stage:
- Results of Regions of Concern identification process
- Other available, documented information (e.g., technical reports)
- Consultation with subject matter experts.
• Develop Vision Statement, and Preliminary Goals and Objectives (see Chapter 4)
The lead agency (and/or its partner or designee) will present the overview of problems (e.g., visual
presentation, fact sheets) to Regional Action Team and obtain input from the team on the completeness
of the definition and to further identify problems and additional sources of information. The information
on problems will be used as the foundation for developing a vision statement and preliminary goals and
objectives.
• Prioritize Adverse Ambient Effects
After developing the vision statement, and preliminary goals and objectives, the Regional Action Team
will rank adverse ambient effects according to priority for action. If the Regional Action Team feels they
do not have adequate information to prioritize, additional investigations may be conducted. Sources of
information for additional investigations include:
- Clean Water Act authorities
- Environmental data bases
- More extensive literature reviews and consultation with subject matter experts.
« Conduct Additional Investigations to Identify and Prioritize Chemical Contaminants and Their
Sources
The lead agency (and/or its partner or designee) and the Regional Action Team will conduct investigations
needed to identify chemical contaminants causing or contributing to the adverse ambient effects and link
chemical contaminants to their sources. The following investigations might be appropriate depending on
the required level of detail:
- Review existing materials
— Analyze environmental data bases (including geographic information systems)
- Perform modeling.
After developing a vision statement, goals and objectives, the Regional Action Team will conduct
more detailed investigations to further define the problem (i.e., identifying and prioritizing chemical
contaminants and their sources) so that sufficient information is available to develop the implementation
approach for the plan. Generally, these more detailed investigations ask who, what, when, where, and
how questions, such as:
5-3 -
-------
Regional Action Plan Guidance Defining the Problem
• What is causing the problem? (e.g., investigations into contaminant types, such as oily
wastes)
• Who is contributing to the problem's cause? (e.g., investigations into contaminant sources,
such as petroleum storage facilities)
• When does the problem occur? (e.g., investigations into time and frequency, such as low
volume leaking on a continuous basis)
• Where does the problem occur? (e.g., investigations into which portion of the Region of
Concern is affected, such as the lower half-mile of the river)
• How does the problem occur? (e.g., investigations into the exact cause of the problem, such
as leaking tanks and insufficiently treated storm water runoff).
Although these questions do not have to be answered in any particular order, the Regional Action Team
should seek this type of information, to the extent possible, to have an adequate basis of understanding
for developing the implementation approach.
The more detailed investigations needed to develop the implementation approach should always
be conducted in the context of the vision statement, and preliminary goals and objectives defined by the
Regional Action Team. This type of focused, or targeted, investigation is necessary to keep the planning
process on track and to efficiently and effectively utilize limited resources. Too often, planning efforts
suffer because they take on too much, become diffuse and unfocused. For example, after several years
of remedial action planning in the Great Lakes, planners found that the process had become "very
complex, time consuming, and cumbersome" because the focus of the remedial action planning process
had become "development of detailed, voluminous documents rather than identification and
implementation of actions to address priority environmental issues in the Areas of Concern (Klemans
1993)." As a result, the remedial action planning process was revised through a series of conferences
and workshops in 1993 to streamline the plans in two key ways (Klemans 1993):
• Agree on a long-term "vision" and short-term goals/objectives
• Prioritize environmental issues and focus activities on the highest priorities first.
This guidance acknowledges the lessons learned in the Great Lakes and promotes an approach
that requires prioritizing information for action. The approach described in this chapter presents the full
range of potential activities that could be accomplished when defining problems hi the Region of Concern.
Remembering that the overarching consideration when defining problems is to limit investigations to the
5-4
-------
Regional Action Plan Guidance
Defining the Problem
level of detail needed to develop a sound
implementation approach, the more
complicated and time-consuming procedures
described in this chapter should only be
pursued if they are needed to clarify areas of
uncertainty. If readily available background
information (e.g., technical reports)
summarizes adverse environmental effects,
stressors, and sources of the elevated levels of
chemical contaminants, the Regional Action
Team may not need to pursue more detailed
investigations. Expending limited resources
on marginally useful data collection and
analysis is not cost-effective.
Overarching Considerations When Evaluating
Information on Problems
• Start with readily available information and conduct
additional investigations as needed. Use existing,
and readily available, sources of information as
much as possible.
• Focns investigations on those areas needed to
achieve the plan's vision statement, goals, and
objectives.
• Do not overanalyze information. Limit die level of
detail to that needed by the Regional Action Team to
make informed decisions regarding an implementa-
tion approach (see Chapter 7 of this document for
more information).
• Ensure mat adequate resources are saved to
complete later stages in the planning process (e.g.,
developing implementation actions). Avoid over-
dbaracterizmg and overanalyzing information (e.g,,
when defining problems) m the early planking
5.1 IDENTIFYING AND RANKING ADVERSE AMBIENT EFFECTS
Adverse ambient effects must be identified and ranked in order to focus the regional action
planning process. A basic understanding of adverse ambient effects provides the foundation for
developing the Regional Action Plan's vision statement, goals, and objectives. This, hi turn, provides
the focus for prioritizing adverse effects and further defining the problem to identify and prioritize
chemical contaminants and their sources. This section of the guidance describes the process of
assembling and evaluating information to identify and rank adverse ambient effects. It describes available
sources of information and provides an overview of approaches that could be used to rank the adverse
environmental effects in order of priority for action.
5.1.1 Identifying Adverse Ambient Effects
There are many sources of information that can be tapped by the lead agency to identify adverse
ambient effects. The lead agency should begin its investigations by gathering readily available
information and then, if necessary, assemble additional sources. The lead agency should first contact the
Toxics Subcommittee's Region of Concern Workgroup and/or the Chesapeake Bay Program Office's
Toxics Coordinator to determine the availability of information as a result of the Regions of Concern
identification process. The extent of data accumulated and synthesized for this process will determine
whether additional investigations are needed. Published reports and other written materials (e.g., journal
5-5
-------
Regional Action Plan Guidance Defining the Problem
articles, white papers) are other good sources of information. Input from the Regional Action Team and
subject matter experts should also be solicited.
Researchers and managers outside of the immediate Chesapeake Bay Program agencies and
institutions may also be working in some of the Regions of Concern. They may be able to contribute
additional information and expertise and identify local experts who are more familiar with some of the
areas. It may also be possible to obtain relevant technical reports, published papers, and hard copy or
electronic data from these sources.
The remainder of this section describes the types of information that might be available from the
Regions of Concern identification process and identifies potential, additional sources of information.
Using Regions of Concern Information
When an area is designated as a Region of Concern, it has usually undergone a fairly intensive
data analysis procedure using written materials assembled by the Toxics Subcommittee's Regions of
Concern Workgroup and information contained hi the Chesapeake Bay Program's Toxics Data Base. The
Toxics Subcommittee's Regions of Concern Workgroup evaluates information to determine if an area
qualifies as a Region of Concern. The process comprises the following steps (see Appendix A):
1. Initial identification of areas where there is reason to believe a chemical contaminant-related
problem is present
2. Compilation of evidence for the presence of chemical contaminant-related problems
3. Classification into one of four categories using a matrix of exposure and effects indicators
with quantitative thresholds and professional judgment.
The third step of the Regions of Concern identification process is the most data intensive and
involves examining the data against some measure of severity (e.g., thresholds or standards). The data
requirements for the Regions of Concern identification protocol are very specific and include an
evaluation of contaminants in water and/or sediment and effects data (e.g., toxicity, fish tissue
contamination). Factors examined hi Step 3 include (see Appendix A for more detail):
• Water Column contamination
• Bottom sediment contamination
• Water column toxicity
_ -—
-------
Regional Action Plan Guidance Defining the Problem
• Bottom sediment toxicity
• Benthic community structure
• Finfish tumors
• Finfish and shellfish tissue contamination.
From the investigations conducted for the Regions of Concern identification process, especially
Step 3, information on problems, chemicals, and sources will begin to be synthesized. To designate a
Region of Concern using the identification protocol, adequate data must exist; otherwise, the area is
characterized as having insufficient data and designation is postponed pending further investigation. In
some cases, areas may be named as Regions of Concern without going through the formal identification
protocol (e.g., Anacostia River, Baltimore Harbor, and Elizabeth River). However, this is more the
exception than the rule. Areas being considered as potential Regions of Concern are usually subject to
the protocol outlined hi Appendix A. Therefore, an excellent foundation for the problem characterization
phase of the Regional Action Plan development may exist in many cases.
Reviewing Additional Sources of Information
If additional data are needed to identify adverse ambient effects, other sources can be accessed.
The Clean Water Act prescribes that the states adopt water quality standards recognizing the value of our
Nation's waters for "...their use and value as public water supplies, propagation of fish and wildlife,
recreational purposes, and agricultural, industrial, and other purposes, and also taking into account their
use and value for navigation" (CWA 303(c)(2)(a)). As a result, the states in the Chesapeake Bay Basin
have adopted water quality standards for all waters, establishing a list of beneficial uses often on a
segment-specific basis. By consulting state water quality standards (which include a list of designated
uses for all segments in their jurisdiction), the Regional Action Team can develop a list of desired
beneficial uses for the Region of Concern. By assessing the attainment of these beneficial uses, additional
information regarding problems in the Region of Concern can be gathered. It may be necessary to
consult numerous sources to determine the status of use attainment, including direct consultation with the
state agency responsible for preparing the following reports mandated by the Clean Water Act:
• Section 3Q5(b)—Provides data on whether uses are being supported and what sources/
pollutants are barring attainment of uses
• Section 304(0—Identifies all surface waters not achieving water quality standards due to the
discharge of toxic conventional and nonconventional pollutants
5-7
-------
Regional Action Plan Guidance Defining the Problem
• Section 319—Identifies waters adversely affected by nonpoint sources
• Section 303(d)—Identifies waters not meeting/not expected to meet water quality standards
in the absence of water quality-based control measures.
In addition, a well-selected and representative Regional Action Team should be able to supplement
the list of information sources, if necessary. Numerous readily accessible data bases may also provide
information pertinent to identifying problems and impaired uses. These data bases may provide
information on chemical contaminants and sources as well. Exhibit 5-2 lists problems or unpaired uses
potentially present in a Region of Concern and identifies relevant information sources. Appendix C
provides more detail on these sources and additional tools that can be used to obtain information (e.g.,
other federally compiled date bases). The sources hi Appendix C are listed alphabetically. The Regional
Action Team will need to consider, as appropriate for the specific Region of Concern, some of the
following use impairments or other indicators and evidence of environmental and biological health:
• Advisories on fish and wildlife consumption
• Tainting of fish and wildlife flavor
• Degradation of fish and wildlife populations
• Presence of fish tumors or other deformities
• Bird and/or animal deformities or reproductive problems
• Degradation of benthos
• Restrictions on dredging activities
• Restrictions on drinking water consumption, including taste/odor problems
• Beach closings
• Aesthetics degradation
• Added costs to agricultural/industry water use consumption
• Degradation of phytoplankton/zooplankton populations
• Loss of fish and wildlife habitat.
When developing final problems and goals statements, the Regional Action Team may choose to
further specify preliminary assessments of problems (use impairments) and goals (beneficial uses) to
establish a solid framework for subsequent regional action planning analyses. For example, rather than
having a goal of "maintaining a recreational fishery," the Regional Action Team may want to refine the
goal to "improving die fishery for striped bass at the X pier." Further definition of the desired goals for
f
the Region of Concern, both in definitional and geographic/spatial terms, will focus on analyses directed
5-8
-------
Regional Action Plan Guidance
Defining the Problem
Exhibit 5-2. Potential Sources of Information1
JYoblem/Inifiai
t Source
Atmospheric Deposition of
Contaminants
Aerometric Information Retrieval System (AIRS) Database -
Data on airborne pollution
Superfund Sites
Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCIIS) Database - Data on
all aspects of cleanup and inventoiy of sites
Record of Decision System (RODS) Database - Tracks history
of cleanup sites, response actions, and remedies
Facility Index System (FENDS) Database - Basic and specific
information on regulated facilities
Hazardous Waste Generator or
Transfer/Storage Facility
Biennial Reporting System (BRS) Database - RCRA data on
waste generation, management, and minimi ration
Resource Conservation and Recovery Information System
(RCRIS) Database - Tracks permit application status and
compliance monitoring
Agricultural Runoff of Pesticides
Pesticide Monitoring Inventory (PIN) - Inventory on pesticide
monitoring
Agricultural Waste (AgWaste) Database - Data on
management, disposal, and productive use of agriculture waste
Pesticide Action Network Updates Service (PANUPS) -
Variety of information on integrated pest management and
pesticide use
Water Column Contamination
Ocean Data Evaluation System (ODES) Database - Data on
sewage discharges, NPDES, ocean dumping, and industrial
discharges
Storage and Retrieval (STORET) Database - Files on CWA,
TSCA, RCRA, drinking water, and solid waste
STORET-Water Quality System (WQS) File - Contains
information from monitoring sites
Water Pollution Control Act Section 305(b) Reports - Data on
each state's surface water and groundwater quality
Water Body System (WES) Database - Data on water body
specific assessments per 30S(b)
Aquatic Toxicity Information Retrieval (AQUIRE) Database -
Data on the effects of toxics on aquatic organisms
Contaminated Sediments
National Sediment Inventory (NSI) - Data on nature, extent,
and causes of sediment contamination
Ocean Disposal Database (ODD) - Data on ocean disposal of
sediments from U.S. Corps of Engineer Projects
Accumulation Factor Database (AFD) - Data on concentrations
of organic chemicals in gftdimenta and organisms
Contaminants Database - Data on sediment and tissue residue
levels of dioxins, furans, PAHs, and PCBs
AQUIRE Database - Data on the effects of toxins on aquatic
Urban/Stormwater Runoff
Stormwater Bulletin Board - Information shared between users,
including special studies and compliance monitoring
5-9
-------
Regional Action Han Guidance
Defining the Problem
Exhibit 5-2. Potential Sources of Information1 (continued)
Probteii/Impaired Used
Fish Consumption Advisories
Water Column Toxicity
Industrial Discharges/
Municipal Discharges
Restrictions on Drinking Water
GrOUndwater Contamination
Fish Kills
Degradation to Benthos, Fish, and
Zoo/Phytoplankton Populations
Degradation to Habitat
Water Quality
Habitat Loss/Land Use
Restriction on Shellfish Harvesting
r,V fcotenial Information Source " j» ;
Fish Advisory Bulletin Board
National Fish Tissue Data Repository - National repository on
potential risks of chemical contaminants
AQUIRE Database - Data on the effects of toxics on aquatic
organisms
Toxic Release Inventory (TRI) Database - Data on chemical
releases, offsite waste transfers, and waste treatment
Permit Compliance System (PCS) Database - Information on
NPDES facilities
STORET Database - Files on CWA, TSCA, RCRA, drinking
water, and solid waste
FINDS Database - Basic and specific information on regulated
facilities
Industrial Facilities Discharge (IFD) Database - Information on
1,200 NPDES discharges
Complex Effluent Toxicity Information System (CETIS) -
Provides whole effluent toxicity data
Federal Reporting Data System (FRDS) Database - Information
on public drinking water supplies
STORET - Files on CWA, TSCA, RCRA, drinking water, and
solid waste
FRDS Database - Information on public drinking water
supplies
STORET Fish Kill - Files on fish kills
Water Pollution Control Act Section 305(b) Reports - Data on
each state's surface water and groundwater quality
STORET-Biological Data System (BIOS) - Data on community
structure and habitat of organic organisms
STORET-BIOS - Data on community structure and habitat of
organic organisms
STORET-Daily Flow System (DPS) - Data on stream flow and
water quality standards
Chesapeake Bay Water Quality Standards (CBWQS) Database -
Data on water quality standards and aquatic life criteria
Integrated Risk Information System (IRIS) - Data on chemical
health risks and regulatory summaries
Land Use and Data Analysis (LUDA) Database - Data on land
use types and locations for entire United States
National Wetlands Inventory (NWI) - Computerized mapping
of wetlands
State Public Health Departments - Contact directly for reports
and bulletins
U.S. Food and Drug Administration (USFDA) - Contact
directly for reports and warnings
5-10
-------
Regional Action Plan Guidance
Defining the Problem
Exhibit 5-2. Potential Sources of Information1 (continued)
Problem/Impaired Used
Bird/Animal Deformities
Restrictions on Dredging
Beach Closings
Other Information ,.••.:.'
Mapping the Region of Concern
General
Information
Pollution Prevention
Hazardous/Solid Waste
Pesticides
Nonpoint Sources
Potential Information Source
State Resource Protection Agency
National Wildlife Federation
State Port Authority
Army Corps of Engineers
State Health Departments
Geographic Resources Information Data System (GRIDS)
Database - Commonly needed geographic data products
National Wetlands Inventory (NWI) - Computerized mapping
of wetlands
Information Systems Inventory (ISI) Database - Information on
more than 500 EPA systems
Online Library System (OLS) Database - Bibliographic
citations from EPA and other agencies
U.S. Geological Survey, Mapping Earth Science Information
Center
U.S. Geological Survey, National Water Information
Clearinghouse
Enviro$ense (formerly Pollution Prevention Information
Exchange System) - Provides pollution prevention, regulatory,
case study, research data, and funding information
Small Business Ombudsman Clearinghouse - Regulatory
activities information for small communities/business
Clean-Up Information BBS (CLU-IN) - Bulletin board on
hazardous waste remediation and corrective action
National Pesticides Information Retrieval System (NPIRS) -
Information on registered pesticides
National Pesticide Telecommunications Network (NDTN) -
Impartial information on pesticides
Nonpoint Source (NPS) Information Exchange - Information
on nonpoint source water pollution
1 Appendix C contains more detailed information on the information sources, including contacts.
at identifying chemical contaminants of concern and on the identification and evaluation of implementation
actions. Refinement of the goals may proceed throughout the regional action planning process in an
iterative fashion. Chapter 4 of this guidance document provides more information on developing goals.
To enhance the implementation of the Regional Action Plan, it is important to clearly define measurable
goals.
5-11
-------
Regional Action Plan Guidance Defining the Problem
Adverse effects can be compiled on a segment or sub-segment basis within the Region of
Concern. Exhibit 5-3 presents one way of organizing this information. The Regional Action Team will
use its initial assessment of adverse ambient effects as a starting point for analysis. As the analyses
unfold, an iterative process will develop, where potential, and actual adverse effects are added,
subtracted, and modified from the original list. Regional Action Plan developers should continually
review the original list of possible adverse effects by asking some of the following questions:
• Is it a complete list of possible adverse effects?
• Have all stakeholders been consulted, or do additional members of the stakeholder community
(e.g., subsistence fisherman) need to be contacted to verify and/or expand the list?
• Are adverse effects not associated with elevated levels of chemical contaminants included?
• Can adverse effects be identified as acute, chronic, or sporadic/episodic?
The Regional Action Team should develop as complete an inventory of potential adverse ambient
effects as possible, even if the adverse effects have not been fully documented. For example, if
recreational fisherman are not using public access point A, which is upstream from restricted site B, men
this "impairment" should be noted for further study even though fishing is not restricted at point A. If
past studies have documented that submerged aquatic vegetation degradation is correlated with elevated
turbidity levels due to nonpoint source runoff, the Regional Action Team may want to explore the
possibility that pesticide runoff might also contribute to the problem in this localized area. Potential
adverse effects should not be removed from the list too early; further investigation of existing chemical
contaminant data may reveal that past studies missed elevated contamination levels of chemical
constituents as a contributing cause to the adverse effect.
5.1.2 Hanking Adverse Ambient Effects
Information gathered for the Regions of Concern identification protocol provides an excellent
starting point for evaluating and ranking adverse ambient effects. The protocol provides a decision-
making framework for ranking the relative "severity" of problems by providing thresholds for comparison
with contaminant and/or effects data. This information, coupled with input from stakeholders on their
priorities (e.g., stakeholders can be used to develop evaluation criteria against which adverse effects can
be weighed—see Appendix D on ranking and decision-making procedures), provides the base to prioritize
and rank adverse effects for action.
5-12
-------
Exhibit 5-3. Example Goals/Beneficial Uses and Associated Adverse Effects
V
N"*
u>
;•;;:.;.•?:•• • ,-: :- • . Goal/Beneficial Use ^ \ ;|ci>-
Anacostia River1
Restore fishery to historic species abundance
and diversity.
Restore recreational subsistence fishery for
catfish, carp, and eels.
Improve aquatic life habitat in Anacostia River.
Elizabeth River2
Improve aquatic species abundance and
diversity.
Alleviate the potential for adverse impacts on
biota, such as skin lesions, cataracts, and fin
rot. Restore public confidence in recreational
fishery.
Restore shellfish fishery.
Baltimore Harbor3
Provide recreational fishery for catfish, carp,
and eels.
Improve species diversity and abundance.
_-„.., Adverse Ambient Effects
Elevated concentrations of chemical contami-
nants in water column and sediments are
prohibiting species diversity and reproduction.
Elevated concentrations of PCBs and chlordane
in sediments are reflected in bottom feeder
tissue, resulting in fishing advisories.
Sediment loads altering natural habitats.
Sediments and water are contaminated with
organic compounds and metals, which is
reducing species diversity and abundance.
Occasional fish kills also occur.
Sediments contaminated with polyaromatic
hydrocarbons (PAHs) are causing finfish
abnormalities.
PAH-contaminated sediments are impairing
shellfish fishery.
Elevated concentrations of chlordane resulted in
a consumption advisory for catfish, carp, and
eels.
Point and nonpoint source loadings of lead and
chromium are contributing to reductions in
species diversity and abundance.
;•/'; . v .*j ^watfo^^ - % t
Particularly in Sligo Creek and Lower
Beaverdam Creek.
Lower Anacostia: Kingman Lake, North East
Boundary combined sewer overflow, 1 1th
Street and South Capitol Street bridges,
Buzzards Point Marina, and Washington Ship
Canal.
High in lower Northwest Branch, Point
Branch, and Lower Indian Creek.
Highest levels in southern and western
branches of the Elizabeth River.
Southern and western branches of the Elizabeth
River.
Hampton Roads area.
Baltimore Harbor and Back River.
Baltimore Harbor, Patapsco River, and Back
River.
!
1 Sources: CBP 1992; MWCOG 1990
2 Sources: CBO 1991; CBP 1993; ACB
3 Sources: ACB; BRCOG 1992
-------
Regional Action Plan Guidance Defining the Problem
If information was not assembled as part of the Regions of Concern identification procedure, the
Regional Action Team will have to gather and analyze data in order to determine priorities for action.
However, the evaluation criteria presented in the Chesapeake Bay Program's Chesapeake Bay Regions
of Concern identification protocol (see Appendix A) provides a good starting point from which to analyze
new data for the ranking characterization. Although the Regional Action Team can select any
prioritization procedure, it may be prudent to follow the existing Regions of Concern identification
protocol as closely as possible to ensure consistency and resource efficiency. Again, this process should
be supplemented with input from the stakeholders (e.g., have they noticed any problems not covered by
the Regions of Concern identification process).
If the Regional Action Team decides it does not want to follow the Chesapeake Bay Program's
Regions of Concern identification protocol, then it can establish its own ranking procedure. The art and
science of ranking and decision-making analysis is a growing field, described in many textbooks, journal
articles, and academic courses. Broadly stated, ranking and decision-making analysis is a process to
identify the best solution to a problem or to select preferred options (priorities) from multiple choices
using predetermined evaluation criteria. The discipline of ranking and decision-making analysis is too
broad to discuss in detail in this guidance document; however, Appendix D provides an overview of some
of the main techniques used in environmental decision-making. Two additional sources provide more
information on these techniques: Environmental Decision Making: A Multidisciplinary Perspective
(Chechile and Carlisle 1991) and Geographic Targeting: Selected State Examples (EPA 1993a).
References on facilitating meetings, described hi Chapter 3 of this guidance, provide additional
background.
5.2 IDENTIFYING AND RANKING CHEMICAL CONTAMINANTS AND THEIR SOURCES
After gaining a sense of which adverse ambient effects are priorities for the Regional Action Plan,
it is necessary to identify chemical contaminants, and their sources, that cause or contribute to the adverse
effects. For the purposes of developing the plan's implementation approach, it is most important to
determine the linkages between sources of chemical contaminants and adverse ambient effects. Most
actions proposed in the implementation approach will be targeted at contaminant sources (e.g., urban
stormwater runoff, direct discharges from certain industries)—investigations into the types of chemical
contaminants should be conducted only to the level of detail needed to credibly identify contributing
sources. In some situations, sources of chemical contamination may be obvious from the available
background information. In other instances, it may be necessary to carefully identify contaminant types
5-14
-------
Regional Action Plan Guidance Defining the Problem
so that linkages to sources can be made. The level of detail required for this part of the problem
definition process will vary on a case-by-case basis.
As described in Section S.I, the process of identifying an area as a Region of Concern and
refining adverse ambient effects has probably involved compiling and assimilating a large volume of
information. Some of this information may provide a good starting point for identifying and prioritizing
chemical contaminants and sources contributing to the adverse effects. This section describes selected
approaches for identifying and prioritizing chemical contaminants and sources so that sufficient
information will exist to develop an effective implementation approach. Specifically, this section
discusses ways to:
• To verify the nature, extent, relevance, and quality of chemical data available for the Region
of Concern
• To associate, but not necessarily statistically correlate, the presence of chemical
concentrations with the (possible) adverse ambient effects
• To evaluate the spatial distribution of concentrations of each chemical contaminant
• To identify and target sources of chemical contamination.
To accomplish each of these steps, the Regional Action Team will need to review available ambient
(physical, chemical, biological) data on chemical constituents and compare chemical concentrations to
standard references, including criteria, standards, and laboratory-generated toxicity data, to provide a
measure of contamination severity. The Regional Action Team will also have to compare the relative
extent and magnitude of sources using a variety of information and techniques. Prior to initiating any
analysis, however, the quality and relevance of available ambient chemical data must be assessed.
5.2.1 Identifying Chemical Contaminants
Information and data to support the identification of chemical contaminants and sources in the
Region of Concern may be in a variety of forms. As in the case of assessing adverse ambient effects,
a logical starting point for this investigation is to determine what information was assimilated and
analyzed as part of the Regions of Concern identification process. Information may also be contained
in other data bases (see Appendix C) or in written reports and other technical documents. In some cases,
data may not be available, or sufficiently available, to characterize ambient concentrations of all chemical
contaminants. In these cases, the Regional Action Team may model theoretic concentrations of these
5-15
-------
Regional Action Plan Guidance Defining the Problem
chemical contaminants using, for example, National Pollutant Discharge Elimination System (NPDES)
effluent, modeled nonpoint source, or Toxicity Release Inventory data. This section describes how to
(1) assess chemical contaminant data availability/quality and (2) generate "secondary" sources of data,
as necessary.
The first activity in developing an information base for chemical contaminants is to determine
whether the existing data are sufficient to support the development of Regional Action Plans. The
Regional Action Team must assess whether enough data exist to provide the base needed to develop well-
conceived strategies to reduce chemical contamination within the Region of Concern. This initial
compilation of available chemical data should be undertaken with the objective of quickly identifying key
characteristics of the data to enable analysts to assess the extent and coverage of chemical information.
The data do not need to be extensive to provide a first-cut overview of data quality, relevance, and
sufficiency. Additional data will be gathered throughout the regional action planning process.
This initial data evaluation should be exploratory hi nature, offering a broad characterization of
the data. The Regional Action Team should be prepared to answer the following key questions:
• Are ambient chemical data available for all toxics of concern?
• Are the data available for one or more exposure routes, water column, sediment, and fish
tissue?
• What were the detection limits used hi measuring the data? Will data comparability emerge
as an issue as a result of differing detection limits?
• How recent are the data? What is the period of record?
• What is the geographic scope of the available data? Does it represent a portion of the Region
of Concern or the entire Region of Concern?
• What is the time period associated with the data?
• How many observations were noted for each chemical constituent?
• Were accepted analytical methods used?
The Regional Action Team will face two distinct situations in this early stage. The first situation
is when a Region of Concern has been established with little prior data collection to support its
designation. The second is when a Region of Concern has been established with prior data collection and
analysis as part of the Region of Concern identification process. In each situation, the types of
-------
Regional Action Plan Guidance Defining the Problem
information necessary to assess data sufficiency are similar. The level of detail needed to develop the
final Regional Action Plan, including implementation approaches, however, is more demanding. If the
Regional Action Team has data from the Region of Concern identification process, men the level of effort
needed to assemble initial data should be reduced greatly.
All data sets should be screened for relevance, extent of coverage, and quality. Exhibit 5-4
provides an example format for organizing the initial data review. Although not necessary to complete
the plan, this format summarizes the crucial data elements needed to characterize the extent of chemical
contamination within a Region of Concern. By summarizing data in this manner, data quality issues will
also be easier to evaluate. While these minimum requirements provide sufficient information to evaluate
whether the data exist for a specific chemical contaminant, judging data quality requires further review.
After assembling this basic information and conducting some simple analyses to summarize the
data (e.g., distribution, means, medians, ranges, number of nondetects, outliers), the Regional Action
Team should have adequate information to identify data gaps and determine geographic areas for which
additional data are needed. The preliminary review and analysis also provides the basis for designing
additional information collection programs in the field or from other sources. Some judgment and
management discretion are required. It is important to remember that the purpose of any additional data
collection hi the context of the regional action planning effort is to develop a plan for reducing chemical
contamination in a specific location. Therefore, extensive surveys and monitoring efforts should not be
necessary at this stage. Severe data quality issues should be addressed as part of the Regional Action
Plan, however.
The Regional Action Team must evaluate two essential data considerations:
Geographic Coverage—The Regional Action Team should review and evaluate available data
to determine whether information is sufficient to characterize and describe the entire Region
of Concern. The key objective at this stage is to determine if data gaps exist that will
preclude linking problems with contaminants in parts of the Region of Concern.
Temporal Coverage—The Regional Action Team needs to determine whether data are
sufficient to describe patterns of chemical contamination over time. Long-term and evolving
problems need to be distinguished. This is a crucial component of the ranking process that
will assist hi determining which chemicals to address in the Regional Action Plan. A good
guideline is that the data should cover a sufficient time period to assess seasonal and long-
term patterns of chemical contamination.
5-17
-------
Exhibit 5-4. Summary Checklist of Factors To Be Considered During Initial Data Reviews
Chemical
X,
^SV •-
yes/no
&
Nokuff
Observations
e.g., 10
Concentration
(units) V
mean
- " v "*?
Media
water column,
sediment, air,
tissue
Location
lat/long or other
geographic
identifier
Collection
Bate
m/d/yr
Detection
Limits
mg/1, ppb
Analytical
Method
e.g.,
Standard
Methods
Xv
< v'*
Reference
e.g.,
Jane Doe
(1994)
V
>—'
oo
-------
Regional Action Plan Guidance Defining the Problem
The number of observations or data points necessary to meet these data quality objectives cannot
be fixed. It is important to note, however, that the confidence the Regional Action Team can assign to
the problem definition and characterization of chemical contamination relates directly to the available
data. The type and variability of summary statistics that will be used to describe the data are calculated,
in part, using the number of observations. In addition, the analytical method used to detect and to
quantify levels of chemical contamination is a key factor in assessing the accuracy and precision of the
reported levels. Because evaluating data quality and analyzing data and information for Regional Action
Plans involve so many considerations, it is important that the Regional Action Team contain, or have
access to, individuals familiar with using and interpreting data. An ideal candidate, for example, would
include a statistician or chemist.
If additional data are needed beyond that which were assimilated for the Regions of Concern
identification process (e.g., if the Regions of Concern identification process was incomplete or not done
at all), it is recommended that this analysis begin with a review of the Chesapeake Bay Program's Toxics
Data Base. As described in Appendix C, this data base contains a significant amount of information on
ambient concentrations, including water column and surface microlayer, sediments, finfish, and shellfish.
The Regional Action Team may choose to initiate this exploratory data analysis on a location-specific
basis, dividing the Region of Concern, for example, by segment codes and/or other location-specific
parameters available hi the Toxics Data Base.
As a result of data quality conventions established by the Chesapeake Bay Program, many of the
common problems encountered in using water quality data have already been addressed in the Toxics
Data Base. For example, the detection limits used in all analyses have been recorded. The minin^im
data elements described previously are standard items hi this data base.
In some cases, the Toxics Data Base may not provide sufficient data to support the regional action
planning process. For example, data for a specified chemical contaminant may never have been collected
or it may not have been collected at location A with sufficient frequency to support a valid analysis. In
these cases, the Regional Action Team should develop alternative strategies for building a more inclusive
data base. Pooling the data from more man one location, while reducing the site-specific analyses
available to the Regional Action Team, may provide a more useful data base for the entire Region of
Concern. The Regional Action Team should always consider combining data from a variety of sources
to fill data gaps. In other words, the Regional Action Team must use data from a variety of studies,
sources, and programs conducted over time and throughout the Region of Concern to build an adequate
5-19
-------
Regional Action Plan Guidance Defining the Problem
information base to develop a strategy to reduce chemical contamination. A well-selected Regional
Action Team could be instrumental in providing information. In addition, a number of readily accessible
data bases, listed in Appendix C, may provide additional information.
The Regional Action Team may also want to consider accessing and integrating environmental
data bases (e.g., Toxics Release Inventory, Permit Compliance System) that are available through the
U.S. Environmental Protection Agency (EPA). One available EPA tool is the Environmental Data
Display Manager (EDDM), which accesses selected federal data bases to provide information for a
number of potential investigations (e.g., identifying river reach segments that are not meeting water
quality standards and evaluating the causes for use impairment), performs a number of different analyses,
and displays results in several formats (e.g., summary tables or on maps) (see Appendix E).
If ambient data for specific chemical contaminants are not sufficient for conducting further
investigations (e.g., comparing ambient data to reference data), the Regional Action Team may choose
to supplement the data set with modeled ambient concentrations. Modeling chemical contaminant
concentration data should be performed to fill data gaps only where absolutely necessary to support the
decision-making process for determining implementation actions. Depending on the level of
sophistication, modeling efforts can be very resource intensive. It is important to use this tool only as
necessary and to avoid falling into the data analysis trap. Rather than modeling in the chemical
contaminant identification and characterization phase of the Regional Action Plan, it may be more
appropriate to initiate it later in the planning process or to recommend it as a potential implementation
action (see Chapter 7).
If modeling is needed to assess chemical contaminants, many types of input information may be
needed, including loadings data (e.g., data from NPDES permit files and the Toxic Release Inventory),
and less "direct" information (e.g., procedures for estimating urban runoff, atmospheric deposition,
sediment release rates). Again, the Toxics Data Base is a repository for some of this information and
includes such data as EPA's Permit Compliance System loadings data for NPDES point source
dischargers, extrapolations (by county) of urban runoff loadings of specified chemical contaminants,
extrapolations (by basin) of atmospheric deposition loadings, and pesticide usage by county/basin.
Additional information may be available from other federal, state, and local sources. For
example, state NPDES files (e.g., NPDES application forms) may provide more complete information
on the chemical contaminants contained in a particular discharger's effluent than presented in the NPDES
5-20
-------
Regional Action Plan Guidance Defining the Problem
permit. Knowledge of a particular publicly owned treatment work (POTW) within an industrial user
community may enhance the Regional Action Team's understanding of possible contaminants detected
«
in the effluent. Similarly, an understanding of the community's industrial/commercial base should
enhance efforts to model runoff quality.
Exhibit 5-5 provides an example for modeling information to determine chemical concentrations.
The following materials, among others, provide more information on these procedures:
Water Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in
Surface and Ground Water—Parti (Revised 1985) (EPA 1985)
Technical Support Document for Water Quality-Based Toxics Control (EPA 199 la)
Technical Guidance Manual for Performing Wasteload Allocations. Book 2, Streams and
Rivers (EPA 1984)
Technical Guidance Manual for Performing Wasteload Allocations. Book 4, Lakes,
Reservoirs, and Impoundments (EPA 1986a)
Draft Technical Guidance Manual for Performance Wasteload Allocations. Book 3, Estuaries
(EPA 1989)
Technical Guidance Manual for Performing Wasteload Allocations. Book 6, Design
Conditions (EPA 1986b)
Guidance for Water Quality-Based Decisions: The TMDL Process (EPA 199 Ib)
Superftmd Exposure Assessment Manual (EPA 1988).
Modeling approaches for both point and nonpoint sources mat are more sophisticated than the
example presented in Exhibit 5-5 are available. In the early stages of the regional action planning
process, it is presumed that the Regional Action Team would use the "simple method," which is
documented in Controlling Urban Runoff: A Practical Manual For Planning and Designing Urban BMPs
(MWCOG 1987). During later stages, as implementation actions are prioritized, more advanced models
may be appropriate to ensure mat the most cost-effective controls are adopted. The type of model to be
used will depend, in part, on the hydrologic characteristics of the water body, the types and sources of
pollutants, and the desired degree of sophistication of the modeling effort (e.g., simple dilution models,
steady state models, or dynamic models). The EPA Center for Exposure Assessment Modeling
distributes and supports the use of 21 simulation models and data bases, many of which could be applied
to the Regional Action Plan area analyses. Access EPA (EPA 1993b) contains information on the center
and the 21 models it supports.
_
-------
Exhibit 5-5. Example Calculation for Estimating Receiving Water Concentrations
The following example provides a simple method for approximating pollutant concentrations in a water body based on information available for the pollutant sources
to the water body. For purposes of the example, we are estimating the pollutant concentration in a river, downstream of the pollutant sources. The example is
based on the following simplifying assumptions:
• No provisions are made for the environmental fate of the pollutant; it is assumed to be conservative in the environment and reduced only by the dilution
of the receiving water.
• Atmospheric deposition and agricultural runoff do not contribute to the pollutant loading.
'^lt>% ' Stepl» SoutceSwrt*Klo*wdLoadCiilculatio^|^^j, ^ ^ ^ '; •_ :
Source A - Urban Development
Using the Simple Method (MWCOG 1987):
L =[(P)(Pj)(Rv)/12](C)(A)(2.72)
Where:
L = Annual storm pollutant load (Ibs/year)
P = Rainfall depth (inches)
Pj— Correction factor for storms that produce
no runoff
Rv- Runoff coefficient
C = Flow-weighted mean concentration of
pollutant (mg/L)
A = Area of site development (acres)
Example Calculation
L - [(40 in)(0.9X0.30)/12](0.25 mg/L)(500
acres)(2.72)
L = 306 IBs/year
Source B - Industrial Point Source
L =(C)(Q)<8J4)(D)
Where:
L' = Annual pollutant load (in Ibs/year)
C = Long-term average discharge
concentration (mg/L)
Q = Long-term average flow (MGD)
D = Number of operating days per year
Example Calculation
L = (O.OS mg/L)(20 MGD)(8.34)(350
days/year)
L = 2,919 Ibs/year
Source C - Municipal Point Source
L =(C)(Q)(8J4)(D)
Where:
L = Annual pollutant load (in Ibs/year)
C = Long-term average discharge
concentration (mg/L)
Q = Long-term average flow (MGD)
D = Number of operating days per year
Example Calculation
L = (0.03 mg/L)(5 MGD)(8.34)(365
days/year)
L = 457 Ibs/year
'•f!: ' \:f " ,. " steP 2* Estfnmttog Ambient Concentration in Receiving Water; •• •' ;; ~ " >,
Total Load = (Source A Load + Source B Load + Source C Load)
= 306 Ibs/year + 2,919 Ibs/year + 457 Ibs/year
= 3,682 Ibs/year
= 10 ton/day
Cs = (Total Lo*d)(l/Qs)(l/8.345)
Where:
Cs = Receiving water effluent concentration (mg/L)
Qs = Receiving water flow (MGD)
Cs - (10 lbs/day)(l/40 MGD)(l/8.345)
Cs = 0.03 mg/L
-------
Regional Action Plan Guidance Defining the Problem
53,2 Identifying Contaminant Sources
A Region of Concern can be affected by various potential sources of chemical contamination,
including point sources (e.g., industrial dischargers, POTWs, combined sewer overflows), nonpoint
sources (e.g., agricultural and urban runoff, contaminated sediments, atmospheric deposition), and
hazardous and solid waste disposal facilities (active and inactive). At a minimum, the Regional Action
Plan should address the possible sources of each chemical contaminant and the method used to identify
the source. If the sources can be quantified, the basis of the quantification and the associated rationale
should be identified.
Through its efforts to summarize adverse ambient effects and chemical contaminants, the Regional
Action Team will probably identify a preliminary list of potential sources of contaminants). For
example, where ambient chemical information is not widely available and where such data are modeled
using point and/or nonpoint source data, the team will come into contact with information on chemical
contaminant sources. Using this list as a starting point, the Regional Action Team may review, if
necessary, additional information to identify other potential contaminant sources. As a result of
regulatory control and planning efforts over the last several decades, a significant amount of information
on chemical sources is available to the Regional Action Team. Moreover, many of these data are readily
accessed through computerized data bases (see Appendix C).
This section describes information that may be available on potential sources of chemical
contaminants according to the following topics:
• NPDES point source discharges
• POTW and combined sewer overflow (CSO) discharges
• Availability of total maximum daily load (TMDL) calculations and waste load allocations
(WLAs)
• Use of the EDDM to evaluate point source information
• Active and inactive hazardous and solid waste sites
• Information contained in EPA's Integrated Data for Enforcement Analysis (IDEA) system
• Nonpoint sources of pesticides
5-23
-------
Regional Action Plan Guidance Defining the Problem
* Contaminated sediments
• Urban runoff.
NPDES point source discharges: Past regulatory efforts have focused on point source discharges
and, consequently, a significant amount of data is available on the chemical contaminants released by
these dischargers. NPDES permit files provide the loadings and concentrations of effluent regulated
pollutants. In addition, more comprehensive information, addressing pollutants not limited by the NPDES
permit, are also available hi the NPDES permit file. Many NPDES dischargers (both industrial and
municipal) have whole effluent toxicity testing or effluent toxicity limits hi their permits. Some
permittees have conducted intensive toxicity identification evaluations. Background information on
industrial processes, such as that contained in effluent guidelines development documents, may also
indicate different chemical contaminants that may be associated with industrial waste streams.
POTW and CSO discharges: In addition, contaminants discharged from POTWs may include
chemical contaminants detected hi industrial, commercial, and residential discharges. While pretreatment
POTWs generally have an excellent understanding of significant industrial users discharging to then*
systems, less is generally known about other users. Nonetheless, many POTWs have developed estimates
of Industrial, commercial, and "other" flows, which are generally associated with the regulatory
requirements to develop local limits. Commercial and residential users may be significant sources of
chemical contaminants, especially as POTWs exercise increasing control of industrial users through the
application of local limits designed to protect worker health, water quality, and sludge quality. Indeed,
many POTWs indicate that the residential sector is providing a greater proportion of remaining loads of
certain chemical contaminants. As a result, household hazardous waste programs are often considered
a potentially cost-effective alternative to additional chemical contaminant control. Commercial users,
including service stations and photo finishing shops, are also viewed with increasing scrutiny.
Information on contaminants detected hi CSOs, while more variable than that detected hi more
"traditional" point source discharges, should also be obtained. With EPA's increased emphasis on CSO
discharges, POTWs are continually generating increasing amounts of information on contaminants
detected hi these discharges as a result of revised NPDES permit requirements.
TMDLs and WLAs: State agencies may have already made significant gams hi assessing the
relative contributions of various point and nonpoint sources to the Region of Concern. As a result of
longstanding Clean Water Act requirements, TMDL calculations and wasteload allocations (WLAs) may
have been initiated or completed. If the Region of Concern encompasses Section 304(l)-listed water
—
-------
Regional Action Plan Guidance Defining the Problem
bodies, such water quality studies probably exist. These data should be used to the maximum extent
possible.
Environmental Data Display Manager: Point source data on industrial and municipal
dischargers can be accessed either directly from the Permit Compliance System or through EDDM.
Using EDDM, specific water quality segments can be targeted and the system can be searched for point
source discharges up or downstream of the discharge within specified distances. In addition, EDDM
enables the user to locate hazardous waste sites and public drinking water intakes within specified
distances of the water quality segment of concern. Appendix E provides more information on EDDM.
Active and inactive hazardous and solid waste sites: Active and inactive hazardous and solid
waste sites are another potential source of chemical contaminants. As a result of Comprehensive
Environmental Response, Compensation, and Liability Act remedial action studies and Resource
Conservation and Recovery Act (RCRA) corrective action studies, a significant body of information exists
on chemical contaminants released from these sources. Of particular note are the RCRA facility
assessment reports completed at active RCRA treatment, storage, and disposal facilities. These reports
summarize potential releases to surface and ground waters from active and inactive units. Information
on hazardous waste sites can be gathered from state and EPA files. EPA's Resource Conservation and
Recovery Information System and Biennial Reporting System files provide information on the types of
hazardous wastes handled at waste sites. This information can be accessed on a state, locality,
latitude/longitude, or ZIP code basis.
Integrated Data for Enforcement Analysis: The Regional Action Team can review non-
enforcement sensitive data from EPA's IDEA system to support the source identification procedure.
Through IDEA, multiple EPA compliance data bases can be accessed to identify regulated parties (e.g.,
Clean Air Act; Clean Water Act; Federal Insecticide, Fungicide, and Rodenticide Act; and Toxic
Substances Control Act) within the Region of Concern. Using sorting techniques, for example, all
regulated parties within designated ZIP codes that release more than some specified mass of chemical
contaminants of concern can be identified. IDEA can be accessed through EPA's Office of Enforcement
and Compliance Assurance.
Nonpoint source pesticides: Nonpoint sources of contaminants have long been recognized as
a source of chemical contaminants. Pesticides are detected hi both agricultural and suburban runoff.
Golf courses and other recreational activities involving intensive turf management are a potentially
545
-------
Regional Action Plan Guidance Defining the Problem
significant source of pesticides. As noted previously, the Chesapeake Bay Program's Toxics Data Base
includes estimates of pesticide application by county/basin. Similarly, atmospheric deposition estimates
are available from the Toxics Data Base.
Contaminated sediments: Another nonpoint source of chemical contaminants is contaminated
sediments. By developing models on a site-specific basis, contaminant releases from these sediments can
be estimated. As noted earlier, the U.S. Army Corps of Engineers and port authority studies can serve
as important data sources for this information. In addition, the Chesapeake Bay Program's Toxics Data
Base includes significant data on contaminated sediments.
Urban runoff: Urban runoff is another potential source of chemical contaminants. Recent Clean
Water Act regulations offer a significant control alternative for this source. The NPDES stormwater
regulations, issued hi November 1990, require municipalities with populations greater than 100,000 to
obtain NPDES permits for their stormwater discharges (55 FR 48062). More than 20 municipalities are
regulated in the Chesapeake Bay watershed, including large cities (e.g., Baltimore, Maryland,
Washington, D.C., and Richmond, Virginia) and suburban counties (e.g., Montgomery County,
Maryland, and Fairfax County, Virginia). State permitting authorities are issuing permits to these
municipalities with requirements to implement a comprehensive stormwater management plan that may
include both structural and nonstructural best management practices. Industrial activities, including
activities on military installations, are also required to obtain NPDES permits for then* stormwater
discharges. Permits require that these facilities prepare and implement stormwater pollution prevention
plans and, in some cases, submit monitoring data. These monitoring data, as well as other information
submitted as part of the NPDES application and permitting process, may contain information useful in
preparing the Regional Action Plan. State permitting authorities can be contacted to obtain access to this
information.
5.23 Hanking Chemical Contaminants and Sources
After assembling and analyzing chemical contamination data, it is essential to measure the relative
severity or contribution of each chemical and source to adverse ambient effects. This analysis will
provide a base level of information needed to prioritize chemicals and sources for the Regional Action
Plan's implementation approach.
5-26
-------
Regional Action Plan Guidance Defining the Problem
Ranking Chemical Contaminants
In some cases, available information may clearly identify chemical contaminants, provide
information on severity, and link the contaminant to a particular adverse effect and/or contaminant source.
If such background information is available, it may be relatively easy to evaluate the chemical
contaminant. For example, the weight of evidence presented in available technical reports may clearly
link chemical contamination from a particular chemical/source to the identified problem. If a link can
be made, then comparisons of ambient concentrations of water quality or sediment quality data to
prescribed threshold or reference levels may not be necessary. If "indisputable" data are not available,
however, but the inventory of available and modeled ambient data indicates the presence of chemical
contaminants, then inventory data should be compared to threshold/reference data to assess potential
toxicity. Exhibit 5-6 demonstrates this procedure by comparing concentration data to available reference
points using protocols similar to those defined for the Regions of Concern identification protocol.
Reference criteria are directly available, or can be derived, from a number of sources. The most
obvious sources are the applicable state water quality standards, although other reference levels are being
developed (in some locations) for sediments and fish/shellfish tissue. The Chesapeake Bay Program has
developed three data bases as part of its overall Toxics Data Base development that summarize the
following threshold or reference levels:
Chesapeake Bay Water Quality Standards Data Base—Summarizes water quality standards
from each state in the Chesapeake Bay Basin and EPA Region DDL The data base also
summarizes Chesapeake Bay Program habitat requirements (CBP 1991).
Sediment Quality Threshold Compendium—Contains a comprehensive compilation of
federal and state sediment threshold values used to evaluate the toxicity of contaminated
sediments.
Compendium of Fish/Shellfish Tissue Human Health Protection Values—Compiles U.S.
Food and Drug Administration and other available fish/shellfish action levels.
The Chesapeake Bay Program has also developed habitat requirements for key living resources (CBP
1991). The habitat requirements present numeric guidelines, or thresholds, for selected contaminants and
species: The numeric habitat requirement guidelines were developed through an extensive literature
review and represent the geometric means of literature values for acute toxicity and chronic or sublethal
toxicity to target species. In addition to being published in report format (CBP 1991), the habitat
requirements are also included in the Chesapeake Bay Water Quality Standards Data Base.
5-27
-------
Regional Action Plan Guidance Defining the Problem
Exhibit 5-6. Sample Evaluation to Determine Chemical Contaminants of Concern
Water Body: Welch Sound, a remote inlet classified as freshwater and designated for primary and secondary
recreation and sport fishing.
I. Available Data
Water Column Concentrations of Chamical Contaminants (May»"""" Concentrations)
mercury: 10 ug/1 (48 samples)
cadmium: 45 ug/1 (48 samples)
phenol: 15 ug/1 (48 samples)
Acute Toxicity: No significant difference from control (1 sample)
Sediment Toxicitv Data
Acute Toxicity: Mortality is significantly different from control (based on numerous samples in a
long-term study).
Chronic Toxicity: Growth is significantly different from control (based on numerous samples in a
long term study).
Fish Tissue
Fishing advisory is in effect, due to mercury.
H. Applicable Criteria/Tbresholds
State Standards
mercury: 2.4 ug/1 (acute), 0.012 ug/1 (chronic)
cadmium: 3.9 ug/1 (acute), 1.1 ug/1 (chronic)
phenol: 100 ug/1 (acute), 20 ug/1 (chronic)
Ambient Acute Toxicity: Narrative prohibition on toxics in toxic amounts
EPA (Water Column) Criteria
mercury: 2.4 ug/1 (acute), 0.012 ug/1 (chronic)
r^HfnfiiTn- 3.9 ug/1 (acute), 1.1 ug/1 (chronic)
phenol: 10,200 ug/1 (acute), 2,560 ug/1 (chronic)
Ambient Acute Toxicity: 0.3 acute Toxic Units
Comparison to Criteria
Water Column Chemical Analyses Results of Comparison
mercury Actual Concern— Exceeds 50% of state standards and EPA
criteria for aquatic life.
phenol Potential Concern— Is within 25% of state standard for aquatic
life.
cadmium Actual Concern— Exceeds 50% of state standards and EPA
criteria for aquatic life.
Water Colntnn Toxicity
acute toxicify Insufficient Data— One data point does not characterize die
whole Region of Concern, especially considering that chemical-
specific data indicate there probably is ambient toxicity.
Sediment Toxicitv
acute toxicity Actual Concern— Percent mortality is significantly different
from the control.
chronic toxicity Actual Concern— Growth is significantly different from die
control.
Fish Tissue Co"*"1"'""^"" Actual Concern — Fishing advisory is in effect.
5-28
-------
Regional Action Plan Guidance Defining the Problem
In the absence of applicable state water quality standards, the Regional Action Team could derive
protection criteria. One such approach is described in the NPDES regulations. Permitting authorities
are required to derive water quality-based effluent limitations using criteria established from relevant
information contained in Water Quality Standards Handbook (EPA 1993c), risk assessment data, exposure
data, information available through the U.S. Food and Drug Administration, and current EPA criteria
documents (40 CFR 122.44(d)). Other potential sources for criteria development include field and
laboratory studies, including the IRIS and AQUIRE data bases that are accessible through the Chesapeake
Bay Program's Toxics Data Base. The Regional Action Team may also consider using the methodology
recently proposed under the Great Lakes Water Quality Guidance (58 FR 20802; April 16, 1993) for the
derivation of Tier n criteria. Essentially, the methodology was derived to enable development of criteria
with limited data. Although the procedure yields more conservative (i.e., stringent) criteria, it provides
a mechanism that ensures that protection criteria can be developed for all chemicals of concern.
Depending on data availability, the Regional Action Team can apply a number of manipulations
to assess the potential severity of ambient conditions. While analysts prefer to use the most "powerful"
statistical tests available, data may limit the analyst to less powerful tests (e.g., reliance on non-parametric
tests as opposed to parametric tests). If data are especially sparse, the Regional Action Team may be
reduced to reporting".. .only two data points are available at this station. Both data points were generated
in the same study during a high flow period hi spring 1987. Neither data point exceeded the existing
acute water quality standard. However, dischargers within the water quality segment are known to
discharge the chemical contaminant and have exceeded permit limits within the last Discharge Monitoring
Report (DMR) period."
Comparing chemical contaminant concentrations to various reference points/threshold levels
provides one means of assessing the relative risk of the chemical and provides information needed to
prioritize chemical contaminants. The Regional Action Team may also want to use other tests of severity
to prioritize chemicals. These tests include evaluating the physical/chemical properties of the chemicals
N
of concern. Physical/chemical properties, such as water solubility, vapor pressure, Henry's law
constants, organic carbon partition coefficient (K^, and persistence, can be used to determine the
potential for these pollutants to be exposed to aquatic life, wildlife, humans, and other pathways.' In
addition, the propensity for the chemical to bioconcentrate or bioaccumulate and whether the chemical
is a carcinogen should also be considered.
5-29
-------
Regional Action Plan Guidance
Defining the Problem
Information from assessing all of these measures, supplemented by stakeholder input, can help
generate a list of evaluation criteria useful in prioritizing chemical contaminants for action. For example,
evaluation criteria might include the following:
• Number of problems/impaired uses linked with the chemical
• Magnitude and duration of exceedance of water quality criteria
• Relative toxicity of the chemical
• Physical/chemical properties of the chemical
• Level of populations to be affected by (exposed to) the chemical.
Appendix D presents various techniques for ranking and prioritizing chemical contaminants. When
developing these evaluation criteria, many other factors (e.g., cost, available resources, and technical
feasibility) may need to be considered. These will be more of an issue when developing/weighing
implementation actions (see Chapter 7). If remediation of certain chemical contaminants is exorbitantly
expensive, resource intensive, or technically infeasible, the Regional Action Team may want to consider
these factors as part of the evaluation criteria. Exhibit 5-7 demonstrates some of the factors that might
be considered when prioritizing chemical contaminants for action.
The Chesapeake Bay Program is also
developing procedures for ranking and prioritizing
chemical contaminants as part of its commitment to
"evaluate and revise as necessary the Chesapeake
Bay Toxics of Concern List and the Chesapeake Bay
Chemicals of Potential Concern List (1994
Chesapeake Bay Basinwide Toxics Reduction and
Prevention Strategy). The chemical ranking system
incorporates sources, fate, exposure, and effects of
chemical contaminants on Chesapeake Bay living resources and human health. The detailed procedures
for the ranking system are described in a draft workplan, reproduced as Appendix F of this guidance
document.
Cbemical RantdmjiSysteni Criteria
,, j - Bnvugnmertal "^ ^
, persistence • " '*
Sources of Chemical Contaminants
The Regional Action Team can review existing source data to associate sources with adverse
ambient effects to determine the relative extent to which each source contributes to the adverse effect.
5-30
-------
Regional Action Plan Guidance Defining the Problem
Exhibit 5-7. Example Prioritization for Chemicals To Be Addressed in a Region of Concern
Description of the Region of Concern
• Periodic, but significant, exceedances of acute and chronic aquatic life water quality criteria for
copper.
• Frequent exceedances of acute aquatic life water quality criteria for phenol; periodic exceedances of
human health criteria.
• Periodic minor exceedances of chronic aquatic life criteria for mercury.
Considerations for Prioritization
• Designated use(s) of the receiving water: Secondary contact and warm water aquatic life uses would
focus attention on copper and phenol due to the relatively significant exceedances of criteria as
compared to mercury.
• Chemical properties/relative toxicity of pollutants: Mercury has a greater potential to bioaccumulate
and biomagnify compared to phenol and copper. Mercury is also relatively more toxic to aquatic life
than either phenol or copper.
• Source(s): Phenol and copper are discharged by known point sources; mercury is discharged by
nonpoint sources (atmospheric deposition and urban storm water runoff).
Possible Conclusion
Phenol and copper become short-term priorities because controls can most likely be quickly identified and
implemented. Mercury would be considered the long-term priority due to aquatic life concerns (high
relative toxicity) and the uncertainty of sources and controls.
A precise, quantitative assessment of source-specific effects is not necessary to complete this assessment.
Assessments can be completed, as needed, throughout the Regional Action Plan implementation process.
While an assessment on a loadings basis is not a scientifically valid approach for determining which
source may have the greatest effect, using loadings data as a surrogate for effects is appropriate at this
stage. Loadings estimates by themselves do not provide much information. However, a comparison of
loadings with other environmental aspects, such as critical habitats and species abundance, may indicate
cause-effect relationships between chemical contaminant concentrations and impacts.
To evaluate the contributions from sources, several techniques can be used. A relatively simple
qualitative approach, such as listing all possible sources of a certain contaminant, may be all that is
needed. This type of approach is comparable to the problem assessments performed prior to TMDL
development. Alternatively, data could be arrayed geographically in a geographical information system
(GIS) or other mapping system. Sometimes, this pictorial evidence may provide enough information to
—
-------
Regional Action Plan Guidance Defining the Problem
match adverse effects, chemical contaminants, and sources. GIS is a tool that is especially effective when
dealing with large data sets. In addition to mapping, it may be helpful to evaluate loadings with respect
to compliance information to determine whether permit limit excursions are contributing significantly to
overall loadings.
Frequently, however, more analytical techniques are needed where (1) identification of all
potential sources within X miles of the affected site is required and (2) cursory or more refined analyses
are conducted to estimate the likely impact of various sources on the subject site. More refined analyses
would involve modeling upstream (and upwind) sources on the affected site. The Regional Action Team
should use data from any past studies on source-specific impacts, such as WLAs on local point sources,
or allocations defining loads from upstream tributaries. The Regional Action Team can also calculate
TMDLs, which have been expressed as the sum of the WLAs (i.e., point source loads) and the load
allocations (i.e., the nonpoint source loads) plus a margin of safety to account for uncertainty about the
relationship between pollutant loads and water quality. Nonpoint sources to be addressed hi the TMDL
include urban and agricultural runoff, atmospheric deposition, contaminated sediments, and natural
background (EPA 1992).
The derivation of TMDLs can range from simple to complex, depending upon the pollutants being
controlled and the number and types of sources contributing the pollutants. For simple cases, TMDLs
and WLAs can be calculated using simple mass balance equations. As situations become more complex,
one of several mathematical models can be used to establish TMDLs, as well as to evaluate alternative
WLA scenarios. The Regional Action Team should refer to the Compendium of Watershed-Scale Models
far TMDL Development (EPA 1992) for further guidance related to mathematical TMDL models.
Generally, these TMDLs and associated WLAs have been more definitive in capturing the
magnitude and effects of point sources than nonpoint sources. Nonetheless, these studies, which are often
associated with intensive surveys of relevant river segments, can provide useful information for
establishing priorities among point sources. TMDL and WLA information is likely to be available in
previously water quality-limited segments. As a result of the Section 3040) listing process and other
CWA-inspired water quality assessment activities, significant data may be readily available. Example
sources of analytical and flow data necessary to estimate point source loadings include the following:
• Permit Compliance System for monthly monitoring results
• NPDES permit files for monthly Discharge Monitoring Reports
542
-------
Regional Action Pirn Guidance Defining the Problem
• U.S. Geological Survey water data (for receiving water flows)
• Chesapeake Bay Basinwide Toxics Loading and Release Inventory.
Data related to nonpoint source loadings of toxic pollutants may not be as readily available. In
the absence of data, however, the Regional Action Team can estimate nonpoint source loadings by using
models. Data inputs needed for calculating nonpoint source loadings vary according to the models being
used. The most common models are listed below:
• "Simple Method"
• Hydrologic Simulation Program-'Fortran (HSPF) model
• Storm Water Management Model (SWMM).
Of these three methods, die Simple Method is a non-computer model and is the least complex. The
Simple Method recommends a series of standard default values for chemical contaminant concentrations
hi runoff. These concentrations are multiplied by the runoff volumes. Controlling Urban Runoff: A
Practical Manual For Planning and Designing Urban BMPs (MWCOG 1987) describes the Simple
Method. Hydrology textbooks are also appropriate references for calculating runoff volumes (e.g.,
Veissman et al. 1989). The HSPF model (EPA 1993d) is often used to develop TMDLS. The HSPF
model predicts pollutant loadings by modeling numerous point and nonpoint sources. For example, the
HSPF model was used to develop the Watershed Model of the Chesapeake Bay, which was developed
for nutrient modeling. SWMM (Huber and Dickinson 1988; Veissman et al. 1989) is designed for
analyzing urban point source discharges of storm water, but may also be used to analyze nonpoint source
runoff quality in an urban area. Input parameters for SWMM include precipitation, temperature, snow
melt, surface and subsurface runoff, catchment geometry, and drainage network. The output is in the
form of hydrographs to describe the quantity of runoff and pollutographs to show the quantity of
individual chemical contaminants. Further guidance related to estimating nonpoint source loadings is
presented in the Modeling of Nonpoint Source Water Quality in Urban and Non-Urban Areas (EPA
1991c).
When data are limited, it becomes difficult to make good decisions. Estimates of chemical
contaminant concentrations are not equal substitutes for actual data. Therefore, rather than ineffectively
using resources to develop potentially inaccurate estimates of loadings, resulting,in potentially
misinformed decisions, it may be more cost-effective to collect data. Analogous to die requirements for
a phased-TMDL, die Regional Action Team can establish interim implementation actions concurrent with
—
-------
Regional Action Plan Guidance Defining the Problem
data collection activities. Further guidance related to the development of TMDLs and phased TMDLs
/
is provided in Guidance for Water Quality-Based Decisions: The TMDL Process (EPA 1991b). The
Regional Action Team can also use the following approaches to evaluate limited data sets if new data
cannot be collected:
• Estimate distribution using probability/statistics
• Look at weight of evidence (e.g., if loadings estimates are inaccurate, consider population
studies, observations from fishermen, fish tissue concentrations, and number of sources to
determine whether a chemical contaminant exists in concentrations that may cause impacts).
5-34
-------
Regional Action Plan Guidance Defining the Problem
REFERENCES CITED
Alliance for Chesapeake Bay. No Date. Baltimore Harbor Fact Sheet.
Alliance for Chesapeake Bay. No Date. Elizabeth River Fact Sheet.
Baltimore Regional Council of Governments (BRCOG). 1992. The Lower Patapsco River/BH
Contaminant Database Assessment Project - 1991. Prepared by Chesapeake Research
Consortium, Inc.
Chechile, R.A. and S. Carlisle, eds. 1991. Environmental Decision Making: A Multidisciplinary
Perspective. New York: Van Nostrand Reinhold.
Chesapeake Bay Office. 1991. Elizabeth River Toxics Initiative, First Biennial Progress Report 1990
(Basic Data Bulletin No. 84, VWCB).
Chesapeake Bay Program (CBP). 1994. Draft Chesapeake Bay Toxics of Concern Workplan, Revision
No. 5.
Chesapeake Bay Program (CBP). 1993. Chesapeake Bay Finfish/Shellfish Tissue Contamination Critical
Issue Forum Proceedings. (CBP/TRS 97/93).
Chesapeake Bay Program (CBP). 1992. Report to Congress: The Restoration of the Anacostia River.
Chesapeake Bay Program (CBP). 1991. Habitat Requirements for Chesapeake Bay Living Resources.
Huber, W.C. and R.E. Dickinson. 1988. Storm Water Management Model Version 4, User's Manual.
U.S. Environmental Protection Agency, Athens, GA. EPA/600/3-88/001a (NTIS PB88-
23664VAS).
Klemans, D. 1993. Strategies to Improve Michigan's RAP Process. Unpublished White Paper.
Metropolitan Washington Council of Governments (MWCOG). 1990. The State of the Anacostia: 1989
Status Report.
Metropolitan Washington Council of Governments (MWCOG). 1987. Controlling Urban Runoff: A
Practical Manual for Planning and Designing Urban BMPs.
U.S. Environmental Protection Agency (EPA). 1993a. Geographic Targeting: Selected State Examples.
EPA 841/B-93/001.
U.S. Environmental Protection Agency (EPA). 1993b. Access EPA. Washington, DC. EPA
220-Br93-008.
U.S. Environmental Protection Agency (EPA). 1993c. Water Quality Standards Handbook.
U.S. Environmental Protection Agency (EPA), ORD. 1993d. Hydrological Simulation Program-
Fortran (HSPF): Users Manual for Release 10.0. EPA 600/3-84-066.
5-35
-------
Regional Action Plan Guidance Defining the Problem
U.S. Environmental Protection Agency (EPA). 1992. Compendium of Watershed-Scale Models for
TMDL Development.
U.S. Environmental Protection Agency (EPA), Office of Water. 1991a. Technical Support Document
for Water Quality-Based Toxics Control. EPA 505/2-90/001.
U.S. Environmental Protection Agency (EPA), Office of Water. 1991b. Guidance for Water Quality-
Based Decisions: The TMDL Process. Washington, DC. EPA 440/4-91/001.
U.S. Environmental Protection Agency (EPA). 1991c. Modeling ofNonpoint Source Water Quality in
Urban and Non-Urban Areas. EPA 600/3-91/039.
U.S. Environmental Protection Agency (EPA), Office of Water Regulations and Standards. 1989. Draft
Technical Guidance Manual for Performance Wasteload Allocations. Book 3, Estuaries.
Washington, DC.
U.S. Environmental Protection Agency (EPA), Office of Remedial Responses. 1988. Superfimd
Exposure Assessment Manual. Washington, DC. EPA 540/1-88/001.
U.S. Environmental Protection Agency (EPA), Office of Water Regulations and Standards. 1986a.
Technical Guidance Manual for Performing Wasteload Allocations. Book 4, Lakes, Reservoirs,
and Impoundments. Washington, DC: EPA 440/4-87/002.
U.S. Environmental Protection Agency (EPA), Office of Water Regulations and Standards. 1986b.
Technical Guidance Manual for Performing Wasteload Allocations. Book 6, Design Conditions.
Washington, DC.
U.S. Environmental Protection Agency (EPA), Environmental Research Laboratory. 1985. Water
Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and
Ground Water—Part I (Revised-1985). Athens. EPA 600/6-85/002a.
U.S. Environmental Protection Agency (EPA), Office of Water Regulations and Standards. 1984.
Technical Guidance Manual for Performing Wasteload Allocations. Book 2, Streams and Rivers.
EPA 440/4-84/022.
Veissman, W. Jr., G.L. Lewis, and J.W. Kraft. 1989. Introduction to Hydrology, 3rd edition. New
York: Harper Collins Publishers.
5-36
-------
CHAPTER 6
EVALUATING EXISTING MANAGEMENT PROGRAMS
-------
CHAPTER 6
TABLE OF CONTENTS
Page
6. EVALUATING EXISTING MANAGEMENT PROGRAMS 6-1
6.1 IDENTIFYING EXISTING REGULATORY AND NONREGULATORY PROGRAMS 6-1
6.2 FOCUSING ON PROGRAMS THAT ADDRESS KEY PROBLEMS 6-2
6.3 EVALUATING THE EFFECTIVENESS OF PROGRAMS 6-7
6.3.1 Program Authority or Mission 6-8
6.3.2 Program Tools 6-9
6.3.3 Program Resources 6-10
6.4 SYNTHESIZING FINDINGS 6-11
6.5 PRESENTING THE EVALUATION IN THE REGIONAL ACTION PLAN
DOCUMENT 6-11
EXHIBITS
6-1. Examples of Existing Programs that Address Problems Encountered in Regions of
Concern 6-3
6-2. Questions Regarding Program Scope and Mission 6-8
6-3. Questions Regarding Program Tools 6-10
6-4. Questions Regarding Program Resources 6-10
-------
Regional Action Man Guidance Evaluating Existing Programs
CHAPTER 6. EVALUATING EXISTING MANAGEMENT PROGRAMS
Once the problems being targeted in the Region of Concern have been defined, the Regional
Action Team should focus on developing a comprehensive approach to address the problems. This
requires an understanding of the capabilities and limitations of existing programs (both regulatory and
nonregulatory) to address problems in the Region of Concern. After characterizing the current programs,
the Regional Action Team can identify specific actions that may be implemented under existing programs
or that require new implementation mechanisms. Chapter 6 focuses on the evaluation of current programs
being implemented in the Region of Concern. Chapter 7 builds on this evaluation to identify the specific
actions necessary to achieve the objectives for the Region of Concern.
This chapter will assist the Regional Action Team in identifying and evaluating existing programs.
Through this evaluation, a Regional Action Team can identify linkages, as well as gaps, between existing
programs and Regional Action Plan goals. The chapter is organized according to the following steps for
*
identifying and evaluating the programs that could be used to address the problems in the Region of
Concern:
• Identify existing regulatory (e.g., zoning restrictions, discharge permits) and nonregulatory
(e.g., recycling centers, voluntary pollution prevention) programs
• Target programs that address the priority problems and goals identified by the Regional
Action Team
• Evaluate the effectiveness of the targeted programs
• Synthesize findings
• Present the evaluation in a Regional Action Plan.
6.1 IDENTIFYING EXISTING REGULATORY AND NONREGULATORY PROGRAMS
Numerous organizations administer programs that directly or indirectly affect chemical
contaminant loadings to Regions of Concern. Identifying these organizations and their programs is
critical to solving problems in any Region of Concern. In addition to federal, state, and local
environmental protection agencies responsible for environmental quality, other organizations may be
active in addressing chemical contaminant problems:
6-1
-------
Regional Action Plan Guidance Evaluating Easting Programs
• Local planning offices have programs on building and development, zoning, growth
management, parks, and conservation
• Local public works offices administer trash collection, recycling, wastewater treatment,
sewage sludge disposal, road maintenance, vehicle maintenance, and public transportation
• State universities often administer agricultural extension services in cooperation with state
departments of agriculture
• Local and regional public and/or business interest groups (e.g., citizen organizations,
grassroots environmental groups, chambers of commerce) frequently have education and
assistance programs.
Based on their existing knowledge, the Regional Action Team members can probably develop a
preliminary list of both regulatory and nonregulatory programs that currently address, or could address,
the problems identified. It is critical that the initial list of programs be as comprehensive as possible.
Therefore, the Regional Action Team should also solicit input from other stakeholders whose interests
may not be represented by Regional Action Team members (see Chapter 3). Stakeholder input at this
stage helps ensure a comprehensive starting point and initiates the process of developing support for
Regional Action Plan recommendations. Mechanisms used to obtain stakeholder input range from
distributing the initial list of programs for review and comment to convening stakeholder roundtable
meetings.
Exhibit 6-1 lists examples of existing programs. The programs are organized according to the
general problems that they address. The list does not provide the level of specificity that the Regional
Action Team and stakeholders would include in the Regional Action Plan for a specific Region of
Concern, however.
6.2 FOCUSING ON PROGRAMS THAT ADDRESS KEY PROBLEMS
Once the preliminary list of programs is developed, the Regional Action Team should narrow the
list of the programs to be evaluated in order to most effectively utilize resources. The Regional Action
Team should focus on the programs offering the greatest potential to support the goals and objectives
developed for the Regional Action Plan. The Regional Action Team should use the problem
characterization data developed for the Regional Action Plan to further focus this section of the Regional
Action Plan on an assessment of the existing regulatory and nonregulatory programs most relevant to the
problems in the Region of Concern. For example, if the Region of Concern is being threatened by the
deposition of airborne chemical contaminants, the discussion should address programs capable of reducing
6-2
-------
Exhibit 6-1. Examples of Existing Programs That Address Problems Encountered in Regions of Concern
Problem
Federal Program
State ftngrams
Local Programs
Direct discharge to water
body (point toutce)
Under the Clean Water Act, all point sources that discharge to U.S. waters
mutt be authorized by a National Pollutant Discharge Elimination System
(NPDES) permit (40 CFR Part 122) to discharge conventional, toxic, and
nonconventional pollutants. The permit includes the following controls:
• Technology-Based Controls—Include use of national effluent guidelines
limitations and standards for industrial dischargers. Guidelines for
conventional pollutants are baaed on the best conventional pollutant
technology; guidelines for toxic and nonconventional pollutants are baaed
on the best available pollutant technology economically achievable.
Controls for municipal dischargers are based on secondary treatment
standards for biological oxygen demand, total suspended solids, and pH
(40 CFR Part 133).
• Water Quality-Based Controls—Water quality-based effluent limits
required as necessary to protect water quality beyond technology-based
controls.
• Beat Management Practices—Allowed in lieu of effluent limits to control
point source discharges to surface waters.
All point source stormwater discharges associated with designated industrial
activity and from large and medium separate storm sewers. Coverage
includes conventional, toxic, and nonconventional pollutants.
Maryland, Virginia, and
Pennsylvania are authorized
to implement the NPDES
permit program, which
they do under state law.
These programs regulate
point source discharges,
including point source
stormwater discharges from
industrial, municipal, and
federal facilities.
Pollution prevention
assistance is provided
through public/private
partnerships.
Medium and large
municipalities with
separate storm sewers
regulate point source
stormwater from
industrial facilities.
Some municipalities
provide local technical
assistance.
Emergency response
programs can affect point
source discharges.
General permits and/or
individual permits that
include:
• Discharge limits
• Monitoring
requirements
• Reporting requirements
• Best management .
practices
• Spill control and
response plans
• Pollution prevention
plans.
Indirect discharge to
publicly owned treatment
works (POTW)
Under the Clean Water Act, all indirect industrial discharges of conventional,
toxic, and nonconventional pollutants to POTWs are subject to the following
controls:
• Technology-Based Controls—In die form of national categorical
pretreatment standards for industrial indirect dischargers.
* Prohibited Discharges—General and specific prohibitions based on
General Pretreatment Regulation practices.
• Local Limits—Pollutant limits developed by POTWs to protect the
collection system, treatment works, worker health and safety, receiving
stream water quality, and sludge quality.
Maryland and Virginia am
authorized to implement the
federal pretreatment
program. Their authorities
are outlined in state law.
Pennsylvania implements
the pretreatment program
jointly with EPA.
Local governments
implement most
pretreatment programs.
Their authority is outlined
by local sewer use
ordinances, state law, and
NPDES discharge
permits.
Sewer use ordinance.
Discharge permits.
Spill control and
response plans.
Pollution prevention
plans.
Local discharge limits.
Monitoring and
reporting.
Community outreach.
Technical assistance to
industry.
-------
Exhibit 6-1. Rumples of Existing Programs That Address Problems Encountered in Regions of Concern (continued)
!
Under fee Clew Water Act. i
t dnchnge to
of«*e
*• (firectea py
NPDES peak.
NPDES permit or
iackx&qg toug-terfli
Water QMttj Itmi
to protect
W*erAetnqnm&tio$me*at**Kq*fyctilm&iaK
•red ID develop Mocedam far tf
NPDES
--j gj- r.., -^ --*— .* -* • ^f
•BD pCOWD VMT ••> RVKMr MO CWMMSB Off
EPA • ngjHrad to develop MioMi w«er qiwity cttem to
to eMnrePOTW
EPA
ActMdlfae
•bibyActwe
to
level of de«np.
Water ifwEty
•re abo Med u act
le»ei» fcr if mf rial
w Ktioa leweb for i
Sectio* 319 of Oen Water Act pnmta teA« to
Md local efibttt
PobBc
COMUl
ROM! Md vehicle
f
1
-------
ntered in Regions of Concern (oMtmoed)
(NAAQS),
fcrcrik
NAAQS
AkActi
i to adopt
NAAQS.
rib fee
Ak Potent* (NESHAPl) fee
ndcoke
10 yen.
i(40CRFM61). The 1990
> NE5HAP progEMi 10 mUam 199
EPAMONESHAPlfcr
types of opcntioML Tkeee
The
1990 CleM Air Act
New Some
(NSPS«)Mtoa(
of ik pafctiM (40 CHt PM «)
NFDESor
ifcrhvi.
to NAAQS. NESHAFfe. md NSFS.
Tide IV of *e OHM Air Art
Local
ofcMMG
40 CHt Puts 7Z, 73,75,77. n<
-------
Exhibit 6-1. Examples of Existing Programs That Address Problems Encountered in Regions of Concern (continued)
Implementation:
• Mechanisms
Mobile sources of air
pollution
Clean Air Act prescribes emissions standards for moving sources of air
emissions (40 CFR Parts 85, 87). Limit tail pipe emissions of non-methane
hydrocarbons, carbon monoxide, and oxides of nitrogen from new cars and
other vehicles. Clean Air Act amendments of 1990 tighten the controls on
motor vehicles and require the production and use of clean fuels.
States implement federal
standards.
Local jurisdictions address
mobile sources through
transportation planning
and land use/zoning
requirements.
Implemented through
federal regulations, state
implementation programs,
and local requirements.
Contaminated sediments
Under the Clean Water Act, EPA is developing water quality criteria to
protect sediment quality. EPA, in cooperation with other regional agencies,
has published contaminated sediment management guidance.
EPA also has jurisdiction over the safe disposal of contaminated sediments.
The U.S. Army Corps of Engineers is responsible for management of
contaminated sediments that are dredged from navigable waterways.
Some states may have
developed contaminated
sediment management
strategies.
Local land use planning
may affect the potential
for sediment contamina-
tion.
NPDES discharge permits.
Remedial action plans.
E
Hazardous waste disposal
Resource Conservation and Recovery Act (RCRA) establishes standards
applicable to the generation, transportation, and treatment, storage, and
disposal of hazardous waste (40 CFR Parts 148, 240-299).
Hazardous wastes include specific wastes that are listed as such under 40 CFR
Section 261 Subpart D, as well as other wastes that exhibit one or more EPA-
defined hazardous "characteristics," which include ignitability, reactivity,
corroiivity, and toxicity (40 CFR Section 261, Subpart C).
States may be authorized to
implement the program if as
stringent as federal
requirements. Forty-eight
states and territories are
authorized to implement
base RCRA program. Joint
EPA-atate implementation
where states are not
authorized for complete
program. Waste exchange
and technical financial ~
assistance to businesses.
Household hazardous
waste disposal.
Pretreatment program.
Waste exchange.
Technical and financial
assistance to businesses.
Technical standards,
notification, and
recordkeeping
requirements applicable to
generators and
transporters.
Treatment, storage, and
disposal facilities must
obtain permits or operate
pursuant to interim status.
Ground water quality
RCRA establishes regulatory standards for municipal solid waste landfills
establishes criteria defining open dumping, which is prohibited under RCRA
Section 4005, and regulates municipal solid waste.
Underground storage tanks of petroleum and hazardous substances (excluding
hazardous waste) must meet operation, monitoring, and repair/removal
standards for underground storage tanks.
Under the Clean Water Act, the aewage sludge regulations are designed to
prevent ground water contamination from sewage sludge that is land applied
or placed in surface disposal facility
States implement municipal
solid waste landfills criteria
through EPA-approved
permit or prior approval
program.
Wellhead protection
program.
Local jurisdictions protect
ground water through
zoning and land use
restrictions (e.g., design
codes for septic systems).
State or prior approval
.program.
Land use and zoning
restrictions
Building codes.
Land use
Coastal Zone Management Program establishes state coastal zone management
programs to achieve wise use of land and water resources of coastal zone.
Land use activities that affect the coastal environment are managed.
Programs designed to address ambient air quality and nonpoint source
pollution also address land use planning.
State agencies develop and
implement coastal zone
management plans.
State Implementation Plans
for air quality.
Nonpoint source programs.
Primary authority to
control land use.
Local zoning and land use
requirements.
Coastal zone management
program and special area
management plans.
I
-------
Regional Action Plan Guidance Evaluating Existing Programs
or preventing the emissions of concern (e.g., state air pollution control board, regional transit authority,
industries). An exhaustive evaluation of all existing programs should not be an exercise strictly for
purposes of drafting the Regional Action Plan, document; a targeted evaluation should be an opportunity
to identify linkages between the problems and potential solutions. It is critical that the evaluation of
individual programs include not only their current actions but also possible other actions consistent with
their missions.
Targeting the relevant regulatory and/or nonregulatory programs for addressing problems in the
Region of Concern is accomplished by linking the priority problems with programs that appear to have
the greatest potential to address them. The Regional Action Team and other stakeholders should work
with the information previously generated to define and rank the problems in the Region of Concern when
identifying which programs to evaluate. The Regional Action Team and stakeholders should array
(perhaps using a matrix) all of the programs identified for each problem (e.g., chemical contaminants,
sources, pathways, impacts) and then perform a preliminary screening to select programs and/or
organizations offering the greatest potential to address the problems in an effective and timely manner.
Once the programs are selected, they should be prioritized for detailed evaluation. The following
considerations should be helpful:
• Ability of the program to have a local impact (e.g., a local program controlling industrial
discharges to the sewer system may be able to respond more quickly to reduce loadings of
chemical contaminants than a state or federal program)
• Ability of the program to respond rapidly (e.g., a program requiring legislative or regulatory
changes may be slower to respond)
• Whether the program directly or indirectly addresses the problems
• Whether an obvious gap or deficiency in the program needs to be filled or corrected (e.g.,
a municipality has not developed or implemented a stormwater pollution prevention plan hi
a region where urban runoff is a major source of chemical contaminants of concern).
6.3 EVALUATING THE EFFECTIVENESS OF PROGRAMS
The next step is to characterize linkages between existing programs and the Regional Action Plan
goals. The purpose of characterizing linkages is to identify partners for implementation, as well as
programs or organizations with conflicting missions. The evaluation must provide specific information
on how the program is currently addressing the problems in the Region of Concern, the accomplishments
of the program, whether the program has encountered any impediments to implementation, and ways to
6-7
-------
Regional Action Plan Guidance Evaluating Existing Programs
overcome any impediments. It may be useful to organize each program evaluation by focusing on the
(1) authority or mission of the program, (2) tools used by the program, and (3) resources of the program.
The process of evaluating existing programs should create awareness among program managers
and staff of both the Regional Action Plan's goals and objectives and of the integral role of key programs
in the success of the Regional Action Plan. It is important for the Regional Action Team to recognize
that the Regional Action Plan may not be a priority to many programs, even though they exert a great
deal of influence over the conditions in the Region of Concern. The Regional Action Team should be
careful not to adopt a command and control approach when working to identify linkages with other
programs. Through cooperative evaluation, the Regional Action Team can build support for
implementing the Regional Action Plan actions. The program evaluation phase of the process may also
uncover additional sources of information relevant to Regional Action Plan preparation (e.g., about the
problems in the Region of Concern).
63.1 Program Authority or Mission
In reviewing the authority or mission of programs, the Regional Action Team needs to understand
the legislative mandate, regulatory approach and interpretation, and current implementation. Similar
analysis is needed for nonregulatory programs, though the scope is more likely to be described in a
charter or mission statement than legislation or regulation. The review should provide information on
the extent to which chemical contaminants and associated problems are or are not addressed and the
flexibility for initiating actions to support the Regional Action Plan. It is particularly important to
identify potential opportunities to expand or refocus the program to incorporate the Regional Action Plan
objectives. Exhibit 6-2 lists some basic questions to explore when documenting the program's authority
or mission.
Exhibit 6-2. Questions Regarding Program Scope and Mission
• What are the program's statutory goals and mandate, charter, or mission statement and are they being
achieved?
• Are program goals consistent with or counter to the goals of the Regional Action Plan? What is the net
result?
• Which sources, activities, or chemical constituents are covered and which are specifically exempted?
• What are the regulatory requirements and what is the rate of compliance and/or what are the non-
regulatory commitments and the rate of success?
• What entity has the authority to alter the scope or mission of the program?
• Can the scope or w**** be modified to better target the issues in the Region of Concern?
6-8
-------
Regional Action Plan Guidance Evaluating Existing Programs
633, Program Tools
All programs, whether regulatory or nonregulatory, employ various tools to achieve their goals
or mission. Understanding how these tools are used and their effectiveness will help the Regional Action
Team understand the possibilities and limitations of an existing program to support the Regional Action
Plan recommendations.
All levels of government utilize numerous regulatory tools, including applications, permits,
licenses, plans, inspections, monitoring, reporting, and enforcement actions. For example, municipal
agencies use a variety of tools to control discharges to the sewage system under their local pretreatment
program authorities. At a minimum, municipalities adopt local ordinances that specify conditions for use
of the sewer system (e.g., pollutant limits, prohibition of explosive materials, permits required for some
discharges). Municipalities develop and issue industry-specific discharge permits for significant industrial
users. Frequently, other industrial and commercial users are issued simpler or more generic permits.
In addition to establishing limits of chemical contaminants in facility discharges, these permits are
opportunities for the municipalities to require industrial or commercial facilities to develop and implement
pollution prevention plans; spill prevention, control, and response plans; and employee training programs.
Municipalities evaluate and reinforce compliance by conducting inspections and monitoring and by taking
enforcement action when appropriate. Inspections provide pretreatment program staff another opportunity
to assess facility operations and identify pollution prevention opportunities. In addition to enforcement
actions (or to supplement some), many creative tools have been developed to facilitate improved
compliance, including the following examples:
• Community-wide source reduction projects, including technical assistance, workshops, and
newsletters, targeted to different sectors of the community
• Compliance awards
• Use of penalties to fund source reduction activities.
Nonregulatory tools used by government, public, and private programs frequently involve
education and/or technical assistance actions. Nonregulatory programs also serve as a conduit for
organizing private sector and citizen action to address regional and local problems. The Regional Action
Team should identify the communication or outreach strategy of key nonregulatory programs, including
target audience, media, tone, and response. Another type of tool commonly used by nonregulatory
programs and increasingly used by regulatory programs is incentives (e.g., grants, tax breaks, subsidies,
6-9
-------
Regional Action Plan Guidance Evaluating Existing Programs
and positive public relations). Again, the evaluation should identify the target audience, the techniques
for creating the incentive, and the response of the target audience.
Exhibit 6-3 outlines some questions the Regional Action Team may explore in documenting the
effectiveness of regulatory and nonregulatory tools used by existing programs that address problems in
the Region of Concern.
Exhibit 6-3. Questions Regarding Program Tools
What tools are employed by the program?
Who or what activities do these tools target?
Are procedures for implementing tools efficient?
Do these tools effectively reach all members of the targeted community?
Is there a means to measure their effectiveness?
Could these tools be an effective mechanism for addressing problems in the Region of Concern?
Could existing programs adopt new or modified tools to implement the Regional Action Plan?
6.3.3 Program Resources
Examination of program resources extends beyond the level of funding and staffing to
organizational efficiency. Evaluating standard operating procedures for implementing program tools is
useful for identifying opportunities and obstacles to linking existing programs with implementation of
Regional Action Plan recommendations. For example, the Regional Action Team could evaluate the
program approach for identifying its target or regulated community, the way tools are applied, and tools
for measuring and ensuring program effectiveness or compliance. Exhibit 6-4 suggests specific questions
for exploring program resources.
Exhibit 6-4. Questions Regarding Program Resources
• Does the program have adequate resources to achieve the goals of the program (i.e., to implement the
program as it is designed)?
• Does the program have resources to evaluate whether the program is achieving its goals?
• How is the program funded?
• What is the mix of skills and expertise of program staff?
• Could the existing program be modified to better achieve the goals of the Regional Action Plan within the
existing resources or if new or modified funding mechanisms were available?
• Is the program willing to commit, in writing and action, to implementing the goals of the Regional Action
Plan?
6-10
-------
Regional Action Han Guidance Evaluating Existing Programs
6.4 SYNTHESIZING FINDINGS
After evaluating the effectiveness of key regulatory and nonregulatory programs, die Regional
Action Team and stakeholders should discuss the findings. This discussion should focus on four issues:
• Documenting linkages among regulatory and nonregulatory programs and problems in the
Region of Concern
• Resolving gaps where problems in the Region of Concern are not addressed by existing
programs
• Improving the effectiveness of existing programs so that individual programs better target
problems in the Region of Concern
• Coordinating programs to improve the efficiency with which combined resources are applied
to solving problems in the Region of Concern.
The outcome of the discussion should be specific recommendations and commitments to adopt mem.
6.5 PRESENTING THE EVALUATION IN THE REGIONAL ACTION PLAN DOCUMENT
The Regional Action Plan should document the process of identifying and evaluating existing
programs. The full range of programs identified for each problem should be listed. If the list is very
long, it can be placed in an appendix. Documenting this initial list in the Regional Action Plan keeps it
available for future reference.
The Regional Action Team should identify the programs selected for detailed evaluation, as well
as the reasons for their selection, and document the findings of the evaluation. The contributions that
a program can make to the goals of the Regional Action Plan should be assessed in either a table or a
couple pages of text. Each program assessment should include a description of the authority or mission
of the program, tools used to implement the program, and resources dedicated to program implementation
and evaluation. The program assessments most valuable function is to describe the problems and sources
of problems that are, or could be, addressed by the program. If program gaps were identified, the
Regional Action Team should include recommendations for addressing these gaps.
6-11
-------
CHAPTER?
APPROACH TO DEVELOPING IMPLEMENTATION ACTIONS
TO ACHIEVE THE GOALS OF THE REGIONAL ACTION PLAN
-------
CHAPTER?
TABLE OF CONTENTS
Page
7. APPROACH TO DEVELOPING IMPLEMENTATION ACTIONS TO ACHIEVE THE
GOALS OF THE REGIONAL ACTION PLAN 7-1
7.1 IDENTIFYING ALL APPLICABLE ACTIONS 7-2
7.2 EVALUATING AND SELECTING THE IMPLEMENTATION ACTION(S) 7-6
7.2.1 Relationship of the Action to the Problem 7-7
7.2.2 Technical Feasibility 7-7
7.2.3 Cost 7-11
7.2.4 Financing 7-15
7.2.S Regulatory and Nonregulatory Incentives 7-18
7.2.6 Public Support 7-20
7.2.7 Indicators for Measuring Progress 7-21
7.3 ASSIGNING AND TRACKING COMMITMENTS 7-22
7.4 PRESENTING IMPLEMENTATION ACTIONS IN THE REGIONAL ACTION PLAN 7-23
References Cited 7-27
Other Sources of Information 7-27
EXHIBITS
7-1. Relationship of Goals/Objectives to Applicable Actions 7-3
7-2. Potential Implementation Actions for Improving Shad Fishery at Attaboy Creek:
Elevated Concentration of Lead in Fish Tissue 7-5
7-3. Summary of Evaluation of Implementation Actions 7-8
7-4. Questions for Evaluating the Relationship Between the Action and the Problem 7-9
7-5. Questions for Evaluating Technical Feasibility 7-9
7-6. Example of Evaluating Technical Feasibility: Contaminated Sediment Remediation 7-10
7-7. Questions for Evaluating Costs of Actions 7-11
7-8. Cost Categories 7-12
7-9. Overview of Economic Techniques 7-12
7-10. Primary Variables of Concern and References/Contacts for Key Source Categories 7-14
7-11. Example Cost Comparison for Potential Implementation Actions for Controlling
Stormwater Runoff 7-16
7-12. Questions Concerning Financing 7-17
7-13. Questions Concerning Implementation Incentives/Disincentives 7-18
7-14. Questions Concerning Public Support 7-21
7-15. Recommended Format of Periodic Progress Report, With Project Example 7-24
7-16. Regional Action Plan Summary of Recommended Actions 7-26
-------
Regional Action Plan Guidance Developing Implementation Actions
CHAPTER 7. APPROACH TO DEVELOPING IMPLEMENTATION ACTIONS TO
ACHIEVE THE GOALS OF THE REGIONAL ACTION PLAN
Previous chapters of this document provide guidelines to the Regional Action Team and the
stakeholders on establishing goals and objectives, reviewing evidence of problems, ranking problems and
sources, and evaluating existing programs. The purpose of this chapter is to assist the Regional Action
Team in taking the next step—developing implementation actions to achieve the goals and objectives of
the Regional Action Plan. In doing so, the Regional Action Team will need to:
• Identify the universe of applicable implementation actions, both regulatory and nonregulatory,
that can address specific problems and help achieve stated goals.
• Evaluate and select the most appropriate implementation actions based on factors such as
technical feasibility, cost, financing, incentives, and public support.
• Assign responsibility and track progress.
This chapter provides guidelines for addressing each of these points. This chapter assimilates
information from the two previous chapters to develop feasible implementation actions using existing
programs to address priority problems in the Region of Concern. This chapter outlines one approach,
although any approach developed by the Regional Action Team is welcomed as long as it fully considers
all possible implementation actions, provides a rational process for selecting the most appropriate
implementation action, and presents a scheme for ensuring that implementation actions move to successful
completion, facilitating full achievement of goals and objectives established for the Region of Concern.
Before presenting the suggested approach to developing implementation actions, it is important
to note that implementation of the Regional Action Plan will involve coordinating individuals,
organizations, and programs. It is highly unlikely that one, or even a few, implementation actions and
implementing entities will represent the total Regional Action Plan implementation effort. As noted
throughout the Chesapeake Bay basin, improving Bay water quality depends on the efforts of government,
industry, and the public at large. This reinforces the need to leverage the creative energy and resources
of multiple organizations and individuals.
Within this framework, "community-wide action" (i.e., where stakeholders throughout the
community get involved in Bay restoration) is a useful paradigm for Regional Action Plan
implementation. Community-wide action, in the context of a Regional Action Plan, would distribute
7-1
-------
Regional Action Plan Guidance Developing Implementation Actions
responsibilities for implementation among all relevant stakeholders: industrial/commercial facilities,
government facilities, public interest groups, households, and regulators. In this way, all members of
the stakeholder community are engaged in the return of the resource, and all are provided with an
opportunity to take part in achieving the goals and objectives established for the Region of Concern.
7.1 IDENTIFYING ALL APPLICABLE ACTIONS
The purpose of this section of the Regional Action Plan is to define all possible implementation
actions necessary to achieve established goals and objectives in the Region of Concern (see Exhibit 7-1,
which defines the relationship among goals, objectives, and implementation actions). As noted in
Chapter 4, each goal will probably have multiple objectives. Each objective, hi turn, will probably
involve numerous implementation actions. Individual implementation actions may address multiple
sources of chemical contaminants, and individual sources may require multiple actions. When identifying
all applicable implementation actions, the Regional Action Team should include:
• Regulatory and nonregulatory actions
• Activities throughout every stage of the implementation process, from conducting further
studies to evaluating the success of an action
• Projects already underway, as well as those not yet initiated
• Actions required under existing federal, state, and local law, as well as projects traditionally
beyond the reach of statutory/regulatory control.
If the Regional Action Team has been established appropriately (see Chapter 3), it will be able
to build a fairly comprehensive inventory of implementation actions based on members' knowledge of
the problems and sources, the community's socioeconomic base, and the available regulatory and
nonregulatory programs, as well as technical control alternatives. Nonetheless, when building an
inventory of all applicable actions, the Regional Action Team should consult with state and local
regulatory officials, planning and zoning agencies, resource management agencies, public utility officials,
community and business leaders, and other individuals, as appropriate, to identify currently active and
planned projects. Appendix G contains a matrix illustrating example implementation actions and various
entities that could contribute to their implementation.
In some cases, the list of implementation actions applicable to a specific problem may be fairly
narrow. For example, if aromatic hydrocarbons are impairing the commercial and sport fishery and
7-2
-------
Regional Action Plan Guidance
Developing Implementation Actions
Exhibit 7-1. Relationship of Goals/Objectives to Applicable Actions*
•
* Items list*
Goal
Objective
Actions
•ki l &&^*Grti& •*&•*%><•:*'
Restore recreational fishery in the Attaboy
Creek.
•;* -us*
Reduce elevated concentrations of metals
and organics affecting shad health and
propagation.
Actions A.l^^'
1. Conduct analyses to develop total
maximum daily load (TMDL) for
stream segment.
2. Conduct data collection effort to assess
current loading from point and
nonpoint sources (e.g., industrial and
municipal dischargers, agricultural
runoff, urban runoff, atmospheric
deposition, and sediment source
loading contributions).
3. Determine necessary reductions from
point and nonpoint sources to meet
TMDL.
4. Implement necessary reductions
through:
- Review National Pollutant
Discharge Elimination System
(NPDES) permits as they come up
for renewal
- Revise NPDES monitoring
requirements and limits, as
necessary
- Recalculate local limits for
pretreatment publicly owned
treatment works as necessary
- Conduct pollution prevention
outreach seminars
- Investigate opportunities for
integrated pest management with
agricultural extension agents
- Assess opportunities for household
hazardous waste programs.
id are for illustrative purposes only; the list is not intended to be comprehensive.
,
*
7-3
-------
Regional Action Plan Guidance Developing Implementation Actions
contaminated sediments represent the overwhelming contribution of aromatic hydrocarbons to the system,
then the list of applicable actions may be narrowed to this source. Even in this situation, however, the
use of various control authorities may be possible: Resource Conservation and Recovery Act corrective
actions, Comprehensive, Environmental Response, Compensation, and Liability Act remedial actions, and
U.S. Army Corps of Engineers maintenance dredging. Within each of these authorities, different
remediation techniques can be considered, including upland disposal and innovative bioremediation
techniques.
In other cases, the list of applicable implementation actions may be broad. For example, if the
chemical contaminant is relatively ubiquitous, such as lead, then the potential sources, control authorities,
and control techniques may be numerous. The Regional Action Plan might recommend several phases
of implementation actions, including (1) immediate action to control major sources, (2) initiation of an
analysis of the relative contribution of other sources, and (3) evaluation of the efficiency of actions
targeted as lesser sources.
At the conclusion of the initial review of available alternatives, it is recommended that the
Regional Action Team prepare a preliminary inventory of implementation actions and circulate the list
to key stakeholders and recognized experts for comment and revision. Because the list will be subjected
to the evaluation process described hi Section 7.2, developing a broad and creative list of applicable
implementation actions is recommended at this stage of the process.
To illustrate the myriad of implementation actions being considered, the Regional Action Team
may choose to use tabular displays as an organizing framework. Consistent with the framework of tying
actions to goals and objectives, as described in Exhibit 7-1, Exhibit 7-2 illustrates one means of
displaying all applicable actions under consideration. The exhibit lists alternative actions for achieving
a specified goal (return the recreational fishery) and a specified objective (reducing effects of lead on shad
health and propagation). Preparing lists of potential implementation actions for each specified objective
by geographic location and chemical contaminant may result in redundant entries. However, this
approach enables the Regional Action Team to address each objective so that each problem, each
geographic area, and each source of contamination is given careful consideration. Summary table formats
can be arranged hi many ways, including by chemical contaminant type and source category.
Once the preliminary inventory of implementation actions meets the expectations of the Regional
Action Team and, as applicable, peer reviewers are identified, it is recommended that the Regional Action
7-4
-------
Regional Action flan Guidance
Developing Implementation Actions
Exhibit 7-2. Potential Implementation Actions for Improving Shad Fishery at Attaboy Creek:
Elevated Concentration of Lead hi Fish Tissue*
Goal: Restore recreational fishery in the Attaboy Creek
Objective: Reduce elevated concentrations of lead so that the health and propagation of shad can be
restored
Potential Implementation Actions
Responsible Parties
Publicly owned treatment works
(POTW)
Develop water quality-based
permit limits
National Pollutant Discharge
Elimination System (NPDES)
Authority (state/EPA)
Develop technically based local
limits for application to industrial
users
POTW Pretreatment Program
Calculate loading and associated
influent concentrations from
commercial and residential sources
POTW Pretreatment Program
Implement lead reduction program
across sewer users
POTW Pretreatment Program,
municipal public works, business
associations
Municipal solid waste disposal
operations
Separate lead acid batteries by
source prior to disposal/
incineration
Municipal solid waste authority,
commercial waste management,
industry associations
Recreational fishermen
Establish outreach/replacement
program to reduce lead-based
fishing tackle
Park authority/public interest
groups, tackle stores
Coal piles associated with power
generation
Cover coal piles, reduce runoff
potential
Utilities, industrial/commercial
sector, state/local water
management program
Urban/suburban runoff
Improve best management
practices, including frequency of
street sweeping and maintenance
of catchment basins
Municipal public works, state/local
planning and zoning authorities
Drinking water lead service lines
Accelerate replacement of lead
service lines in older residential
neighborhoods, reducing
residential contributions to POTW;
coordinate with street repair
Public utility/municipal public
works
"Items listed are for illustrative purposes only; this list is not intended to be comprehensive.
7-5
-------
Regional Action Plan Guidance Developing Implementation Actions
Team invite wider public participation in the review and modification of the list of potential
implementation actions. As noted throughout this document, the need to leverage the resources of
government agencies, the private sector, public interest groups, and the general public is paramount to
successful implementation of the Regional Action Plan.
7.2 EVALUATING AND SELECTING THE IMPLEMENTATION ACTION(S)
The Regional Action Team should develop a procedure for identifying the most appropriate or
priority implementation actions from among all those identified. This procedure should include a full
definition of the evaluation criteria and the decision-making process that the Regional Action Team
expects to use in selecting the most appropriate actions, so that stakeholders understand, from the
beginning, the basis of subsequent decision-making. When appropriate, the Regional Action Team should
develop preliminary screening criteria in addition to the evaluation and selection criteria. A preliminary
screening may be necessary if the inventory of actions is too large to allow complete evaluation given
available resources.
In addition to identifying a range of activities that may be implemented, the Regional Action Plan
should offer an approach for assessing which actions may be more appropriate than others based on the
action's feasibility and its ability to address problems. Feasibility is influenced by technical limitations,
cost, financing incentives, and public support. This section describes seven criteria that the Regional
Action Team can use to evaluate implementation actions:
• Relationship of the action to the problem
• Technical feasibility
• Cost
• Financing options
• Incentives (regulatory and nonregulatory)
• Public support
• Indicators for measuring progress.
The Regional Action Team is responsible for developing the decision-making framework,
including selecting the factors to be included in the framework and the interaction of those factors in the
decision-making process. The Regional Action Team can choose any combination of factors in assessing
implementability. This list is not meant to circumscribe the Regional Action Team's consideration of
additional factors. Some implementation actions may require the Regional Action Team to consider
. --
-------
Regional Action Plan Guidance Developing Implementation Actions
factors not described herein, such as actions requiring changes in the state's statutory authority. In these
cases, the likelihood of legislative support will need to be gauged.
In addition, the Regional Action Team may "score" the actions in order to establish a hierarchy
for implementation or for more detailed evaluation. This scoring can be done using an explicit scoring
approach, where the implementation action is given a high, medium or low score for each criterion.
Exhibit 7-3 illustrates this scoring technique. The Regional Action Team can also differentially weight
the various criteria, so that, by way of example, the relationship of the action to mitigating the use
impairment is given greater value than cost considerations. Appendix D provides additional information
on techniques for ranking and prioritizing.
7.2.1 Relationship of the Action to the Problem
Chapter 5 covers the topic of identifying the relative severity of chemical contaminants or
contribution of different sources associated with Region of Concern problems. The chapter also presents
techniques to rank the sources of pollutants for action. When developing an implementation approach,
it is important, as one evaluation criterion, to address the priority sources of contamination. Using the
information evaluated as part of Chapter 5, the Regional Action Team should assess the relative extent
to which each source contributes to the problem(s). A precise, quantitative assessment of source-specific
effects is not necessary. More complete assessments can be conducted, as needed, while the Regional
Action Plan implementation process proceeds. Exhibit 7-4, suggests questions to consider when
evaluating the relationship of the action to the problem.
733 Technical Feasibility
The purpose of this aspect of the analysis is to identify whether or not the identified actions are
technically feasible. In some cases, the Regional Action Team may label the feasibility of the approach
as "unknown" or "to be investigated." Technical infeasibility should not be confused with whether or
not the technology is reasonable from a cost perspective. Cost factors are addressed in Section 7.2.3.
Exhibit 7-5 contains several questions that can be considered when evaluating the technical feasibility of
a proposed implementation action.
While these questions and the remainder of this section target reviews of the technical feasibility
of engineering approaches, similar questions should be considered when evaluating the technical feasibility
of other types of implementation actions. For example, the sampling designs or approaches for
7-7
-------
Exhibit 7-3. Summary of Evaluation of Implementation Actions
00
Goal I: Returning Recreational Fishery
Objective A: , Reducing Elevated Metals Concentrations
Actions: Point Source Reduction Actions
\ ' ' <
.., Implementation Action
1 . Reduce metal loadings from
industrial point sources
2. Reduce metal loadings from
publicly owned treatment works
3. Reduce metal loadings from urban
runoff
4. Reduce metals loading from
atmospheric sources
Evaluation Criteria
1
•
•
2
•
•
3
•
O
4
•
•
5
O
O
6
•
O
7
O
0
O
Comments . <: :
Industrial sources already reducing to best available technology; further reductions
may prove more beneficial elsewhere. Feasibility/cost impact not expected to be an
issue, dependent on stringency of "new" limits. Public support not likely to emerge
as an issue unless limits result in plant closures, unemployment.
Technical feasibility not expected to be a concern. Limits on commercial users are
expected to result in reductions and that they can be achieved by adapting good
housekeeping measures.
No urban runoff control program currently in place. Program adoption requires
establishing administrative framework and financing new program. Technical
feasibility of controls needs to be established.
Oncoming Clean Air Act regulatory requirements may provide sufficient controls.
Key:
• High
• Medium
O Low
Evaluation Criteria:
1 Relationship of Action to problem
2 Technical feasibility
3 Cost
4 Financing
5 Regulatory and nonregulatory incentives
6 Public support
7 Indicators for measuring progress
I
-------
Regional Action Plan Guidance Developing Implementation Actions
Exhibit 7-4. Questions for Evaluating the
Relationship Between the Action and the Problem
Does the action target a priority problem?
Does the action target a priority source?
Will the action have a direct impact on the problem?
What is the magnitude of impact of the action on the problem?
What is. the timeframe for implementation of the action?
What is the timeframe for measuring the results of the action?
Exhibit 7-5. Questions for Evaluating Technical Feasibility
• Does the technology or practice exist to implement the action?
• Is the technology or practice commonly used?
• Is the technology or practice readily available?
• Are any negative side effects associated with the technology or action (e.g., transfer of pollutants across
media, or generation of different pollutants)?
developing total maximum daily loads can also be evaluated from a technical feasibility perspective.
Questions might include what data will be necessary to develop a complete survey, what assumptions will
need to be made, and how reliable the resulting analysis will be.
As a result of the continued demand for pollution control and remediation technologies, innovative
environmental technologies are constantly being developed. Some of these technologies may be
applicable to problems in the Region of Concern. Technology performance depends on factors including
space limitations, energy requirements, product specifications, and pollutant concentrations.
Consequently, the Regional Action Team will need to use both site-specific information about the source
category and technical literature to determine whether the action can be applied hi the local situation.
To illustrate mis kind of evaluation, Exhibit 7-6 provides an example of contaminated sediments and
potential sediment remediation. The example is not meant to provide sufficient rigor to allow for
evaluating the use of sediment remediation technologies hi a site-specific situation. Readers are directed
to texts and experts in the field for site-specific evaluations. This exhibit is provided as an overview of
the types of factors that need to be considered when assessing technical feasibility, specifically in
evaluating sediment remediation technologies.
Pollution prevention technologies are important actions meriting review with regard to this
criterion. Commonplace pollution prevention techniques, such as good housekeeping approaches,
— ,
-------
Regional Action Plan Guidance
Developing Implementation Actions
Exhibit 7-6. Example of Evaluating Technical Feasibility:
Contaminated Sediment Remediation
Technology
Availability
Removal and placement in
confined disposal facility (CDF)
Well-developed and widely used.
Requires participation of local and
state authorities for site location.
Also entails long-term maintenance
responsibilities. Placement of CDFs
near populated areas may attract "Not
in My Backyard" opposition.
Requires significant public outreach.
Open-water disposal
Only applicable to uncontaminated
and very slightly contaminated
sediments. May be used for
slightly more contaminated
sediments if combined with
capping.
Protocols for determining suitability of
sediments for open-water disposal are
well-developed at the national (e.g.,
the EPA/Corps Green Book) and
regional (e.g., Region V guidelines)
levels.
In-place capping
Degree of usage not known.
Applicable to sediments in fairly
quiescent waters. May require long-
term maintenance and monitoring.
Removal and upland placement
Well-developed and widely used.
Requirements similar to those for
CDFs.
Application Of contaminant
removal and treatment
technologies, such as:
Thermal destruction
Chemical conversion
Biodegradation
Chemical extraction
Soil washing
Solidification/Stabilization
Under various levels of
development.
Most require removal and dewatering
or other pretreatment. Costs run from
moderate to prohibitive.
chemical substitution, and raw material recovery, are well-known throughout industry and, in many cases,
can be transferred to other industries. However, many pollution prevention technologies involve
redesigning production processes and even final products. Many industries may be reluctant to invest
in pollution prevention technologies, because, for example, product substitution techniques may detract
from overall product quality or financial incentives favor waste treatment technologies. In addition,
individual companies may be reluctant to share trade secrets/production patents with competitors, even
if pollution prevention opportunities accrue. Consequently, in considering the potential reductions that
one might gain from pollution prevention approaches, the Regional Action Team will need to work
closely with the industrial, commercial, and government sectors.
7-10
-------
Regional Action Plan Guidance Developing Implementation Actions
7.23 Cost
A key variable that the Regional Action Team should consider when choosing among alternatives
is the cost of each implementation action. The Regional Action Team should identify the economic
issues, as well as the level of precision about the costs of implementation actions that will be addressed
during Regional Action Plan development. Several factors need to be considered when evaluating costs,
as indicated by the questions presented in Exhibit 7-7. Before committing to answering these questions
during the Regional Action Plan development process, the Regional Action Team should understand the
activities involved. Evaluation of costs ranges from a simple order of magnitude estimate to a detailed
cost-benefit analysis. Both levels of cost estimates provide valuable information for evaluating and
selecting implementation actions to the Regional Action Team. The Regional Action Team should
consider which level of analysis is appropriate and may decide that both should be applied at different
stages in the process of evaluating and selecting implementation actions.
Exhibit 7-7. Questions for Evaluating Costs of Actions
• What is the life-cycle cost of the action, including capital costs, operation and maintenance costs, and
avoided costs?
• Can an alternative action deliver similar, or greater, benefits at a lower cost?
• Who will pay for implementation?
• Are these mechanisms to provide financial assistance to those who are expected to participate in
implementing the action?
• Will the action under consideration impose "unacceptable costs" on the firm or community?
• What is the expected return, or benefit, on the investment?
One example of an approach for evaluating the costs of potential implementation actions is mat
being used for the Elizabeth River Regional Action Plan. The Virginia Department of Environmental
Quality is proposing to apply two levels of cost categories when evaluating implementation
actions. Level 1 is designed to be used as part of a preliminary screening of the initial inventory of
implementation actions. After the priority implementation actions are selected, the Level 2 cost categories
are applied using a more quantitative evaluation of the costs associated with the implementation action.
Exhibit 7-8 summarizes the suggested cost categories.
The following paragraphs provide a general overview of three more rigorous analytical techniques
for evaluating economic issues: economic achievability analysis, cost-effectiveness analysis, and benefit-
cost analysis. The Regional Action Team will need to determine whether and how it plans to use each
of these three types of economic analyses in assessing which implementation actions may be most
7-11
-------
Regional Action Plan Guidance
Developing Implementation Actions
Exhibit 7-8. Cost Categories
• *.* , -Lev* "':":w & -
i
Very low
Low
Medium
High
Veiy high
2
1
2
3
4
5
6
7
8
9
10
11
12
; - - ^ Adhnf
< 10,000
10,000 - 50,000
50,000 - 100,000
100,000 - 250,000
250,000 - 500,000
500,000 - 750,000
750,000 - 1 million
1-5 million
5-10 million
10 - 25 million
25 - 100 million
> 100 million
"appropriate." The most expensive action may be the most likely to achieve the objectives and goals,
but taking such an action will depend on whether it is justifiable and understandable to the stakeholders.
\
Exhibit 7-9 defines each of these economic techniques and how each is commonly used in evaluating
projects.
One of the most commonly used techniques in evaluating environmental expenditures is the
economic achievability test. (See the Work Book for Determining Economic Achievability for National
Pollutant Discharge Elimination System Permits [EPA 1982].) Using this technique, regulatory officials
can assess the impact of a given pollution control expenditure on the firm's balance sheet and/or the
community's tax burden. This technique does not address the value of the benefits derived from the
Exhibit 7-9. Overview of Economic Techniques
' ' ' __
-------
Regional Action Plan Guidance Developing Implementation Actions
expenditure; however, it does answer a very real question of interest to stakeholder: How will this cost
affect my pocketbook?
Cost-effectiveness analysis can be used to assess alternative implementation actions for achieving
the same objective at a single site (e.g., identifying the least expensive alternative for reducing metal
loadings to a publicly owned treatment works [POTW]) or across sites (e.g., evaluating whether urban
nonpoint source control or more stringent POTW National Pollutant Discharge Elimination System
[NPDES] limits can achieve metals loading reductions at lesser cost). The need to place dollar values
on intangible environmental benefits is reduced in cost-benefit analysis, because benefits are assumed to
be constant across the alternatives being evaluated. Cost-effectiveness analysis employs life-cycle analysis
to quantify the direct (e.g., capital cost, operation and maintenance) and indirect (e.g., avoided waste
disposal costs) costs anticipated over the life of the alternative projects.
Benefit-cost analysis is usually used to evaluate large-scale investments or infrastructure projects.
This technique presents many practical problems for environmental projects, the most obvious being that
it is difficult to calculate monetary benefits accurately, such as the value of a recreational fishery.
Consequently, benefits are often underestimated because factors that influence their value cannot be
quantified objectively and are ignored. While it is not recommended that the Regional Action Team
expend the resources to perform benefit-cost analysis for each implementation action (e.g., controlling
urban runoff from a particular site), it may want to consider the use of benefit-cost analysis in evaluating
the benefits of the entire "package" of actions.
Each method of analysis requires different data inputs, but all share the need for basic costing
information:
• What are the capital costs associated with the project?
• What operation and maintenance costs can be expected?
Exhibit 7-10 provides examples of variables that generally must be considered in a costing
exercise. It also lists reference manuals that can be used hi generating cost estimates. For example, costs
for remediating contaminated sediment can be obtained from vendors of the technology and, for more
standard techniques, engineering texts can be consulted. Typical variables used in estimating the cost of
sediment projects include the volume of sediment to be pumped (including water content), the number
7-13
-------
Exhibit 7-10. Primary Variables of Concern and References/Contacts
for Key Source Categories
Primary Costing Variables
References/Contacts
Industrial sources
Wastewater volume and variability, pollutants of
concern, influent concentrations and variability, desired
effluent concentration, residual generation and
management, existing treatment processes (including
upgrade capabilities), energy costs, pumping
requirements, land availability
1. Specific wastewater treatment system vendors (lists available from sources
such as Pollution Equipment News Buyers' Guides, American Chemical
Society Environmental Buyers' Guides).
2. EPA Office of Science and Technology Effluent Guidelines industry-specific
Development Documents and contacts.
3. EPA Office of Research and Development Risk Reduction Engineering
Laboratory Treatability Database (Version 4.0).
4. Engineering News-Record Construction Cost Index.
5. Metcalf and Eddy, Inc., McGraw-Hill Series in Water Resources and
Environmental Engineering (particularly, Wastewater Engineering).
6. Robert Snow Means Company, indices for unit price estimating (i.e., The
Means Index). *
7. EPA's Pollution Prevention Information Exchange Systems.
Municipal wastewater
treatment plants
Wastewater volume and variability, organic and solids
loadings, pollutant influent loadings, energy costs,
effluent limitations, sludge generation and management,
existing treatment processes, geographic location, land
availability
1. EPA Sewer Construction and Sewage Treatment Plant Construction Cost
indices.
2. Sources 1, 5 and 6 from above.
Urban nonpoint sources
Percent impervious surfaces, volume average and peak of
stormwater, pollutant concentrations, development
density (availability of land for retrofit structural
practices), staff to inspect maintenance of structural
practices
EPA. 1993a. Guidance for Specifying Management Measures for Sources of
Nonpoint Pollution on Coastal Waters. EPA 840-B-92-02.
Metropolitan Washington Council of Governments. 1992. A Current
Assessment of Urban Best Management Practices: Techniques for Reducing
Non-Point Source Pollution in the Coastal Zone.
Agricultural sources
Volume of agricultural chemicals handled onsite, access
to mixing pad
1. Soil Conservation Service Local and District Offices.
2. EPA. 1993a. Guidance for Specifying Management Measures for Sources of
Nonpoint Source Pollution. EPA 840-B-92-02.
Contaminated sediments
Location, volume, pollutant concentration
1. National Academy of Sciences. 1989. Contaminated Marine Sediments-
Assessment and Remediation. Washington, DC: National Academy Press.
2. EPA. 1993b. Selecting Remediation Techniques for Contaminated Sediment.
EPA 823/1393/001.
3. EPA. 1993c. Assessment and Remediation of Contaminated Sediments
(ARCS) Program Assessment Guidance Document. EPA 905-R-94-002.
4. EPA. 1993d. Assessment and Remediation of Contaminated Sediments
(ARCS) Program Remediation Guidance Document. EPA 905-R-94-003.
-------
Regional Action Plan Guidance Developing Implementation Actions
of dredge pumps and barges required, the amount of water, if any, that will require treatment, and any
ancillary construction that will be necessary. The estimated costs for remediation are project-specific.
Procedures for estimating the cost of industrial and municipal water pollution control technologies are
well established. The U.S. Environmental Protection Agency's (EPA) effluent guidelines development
documents, available from the EPA's Industrial Technology Division, provide a rich source of information on
the cost of industrial wastewater treatment. A greater challenge will be quantifying costs associated with high-
technology pollution prevention alternatives, such as redesigning a manufacturing process.
Cost information for urban and agricultural nonpoint source control is less straightforward due to the
number of site-specific factors that need to be addressed. Comparative costs for urban nonpoint source
controls, such as stormwater runoff controls, can be obtained from A Current Assessment of Urban Best
Management Practices: Techniques for Reducing Non-Point Source Pollution in the Coastal Zone (MWCOG
1992). An excellent source for both urban and agricultural nonpoint source controls is Guidance for Specifying
Management Measures for Sources of Nonpoint Pollution in Coastal Waters (EPA 1993a). Costs for urban
and agricultural nonpoint source controls may include the size of me areas contributing to the contamination,
local labor rates and construction rates, and expected size of control features.
Cost data will likely be generated in an iterative fashion throughout the development and
implementation of the Regional Action Plan. For example, the Regional Action Plan may simply provide
previously generated cost information for some alternatives and present no more man a "guesstimate" (e.g.,
less man $100,000, approximately $1 million) for other identified alternatives. If cost data are not available,
however, the Regional Action Plan should identify sources, methods, and responsible parties for generating
mat cost data. Available cost data may be presented in tabular form, as shown in Exhibit 7-11, to facilitate
the decision-making process for various alternatives.
12 A Financing
A factor closely related to cost is financing. Environmental planners need to consider budgetary and
fiscal constraints early in the Regional Action Plan process. The Regional Action Team should review the
costing information and current funding directed by state, regional, and local programs and public utilities to
assess the possibility of any financial constraints. The Regional Action Team should also consider the area's
economic health and identify whether particular implementation actions will create unacceptable economic
hardships. Exhibit 7-12 lists questions to consider.
7-15
-------
Exhibit 7-11. Example Cost Comparison for Potential Implementation Actions
for Controlling Stormwater Runoff*
!^* "' *3& ,M-
A*i$L^ -1P< "•
.. s *M»W!|^ v ^^ **
w •> VA v •' X
^ -> , .
Construct infiltration basin
Construct infiltration trench
, Construct porous pavement
Construct sand filter/
filtration basin
Construct oil/grit separator
Construct extended
detention dry pond
,. „> ,. . Estimated Costs " .ifc^ftii^^ . ., .
^. ^-iOjpltal A'; Annual O&M "^ "%S^Mhual
Average: SO.S/ft3 storage
Average: $4.0/ft3
Average: $1.5/ft2
Average: SS/ft3
\
Average: $18,0007
drainage acre
Average: SO.S/ft3 storage
Average: 1% of capital
cost
Average: 9% of capital
cost
Average: SO.Ol/fl2
Average: Not Available
Probable Cost: 7% of
construction cost
Average: $20/drainage
acre
Average: 4% of capital
cost
$0.03 - $0.05/fr1
$0.3 - $0.9/ft3
$0.15/ft2
$0.1-$0.8/ft3
$1,000/ drainage acre
$0.007 - $0.3/fl?
¥'"V >ff '£ "?*
*?•* ^T $£ V-^-
Sodrce^ate of Estimate
^ $ ^
* '
Wiegand et al. (1986);
SWRPC (1991)
Wiegand et al. (1986);
SWRPC (1991); Macal et
al. (1987); Kuo et al.
(1988)
SWRPC (1991)
Schueler (1987)
Tutt (1990)
Schueler (1987)
APWA Res. Foundation
* This example is for illustrative purposes only and is not intended to be comprehensive.
Source: EPA (1993a).
I
-------
Regional Action Plan Guidance Developing Implementation Actions
Exhibit 7-12. Questions Concerning Financing
How much money will be required for the implementation action?
Do the anticipated environmental benefits warrant the cost?
Who will pay for the implementation action?
Is funding available?
Can innovative finance mechanisms be used?
Is the implementation action required under an existing regulatory program?
Is the implementation action already being initiated under an existing voluntary plan?
Funding shortfalls, both public and private, can be a serious roadblock to environmental projects.
The success of the Regional Action Plan will depend on the ability of stakeholders to identify funding
mechanisms. Appendix H briefly describes potential financing mechanisms. The appendix includes both
traditional (e.g., general tax revenues, surcharges, revolving funds) and nontraditional (e.g., permit fees)
mechanisms that may be used to raise funds for environmental projects. Many of these funding
mechanisms are incentive-based, such as lower-than-market loans, NPDES permit fees based on mass
pollutant or discharge toxicity, and user fees that more closely reflect the costs of providing services.
Another good general reference for financing implementation actions is the 1995 report from the
Governor's Blue Ribbon Panel entitled, Financing Alternatives for Maryland's Tributary Strategies. The
report describes a wide array of financing ideas, including bonds, fees, loans, private initiatives/
incentives, public/private partnerships, redirection of existing programs, and surcharges.
At this stage of the process, the Regional
Prince Georges County, Maryland, funds a
stonnwater utility through an ad valorem tax and
by requiring developers to set aside land (or
equivalent value) for stonnwater control projects.
Other jurisdictions fond stonnwater utilities by
taxing properties based on "percent permeability,"
an indicator of runoff potential.
Action Team should identify which of the
available projects, such as a stonnwater utility,
require finding an alternative funding source.
The Regional Action Team may also want to
initiate discussions with financial experts (both in
and out of government) to determine which alternative funding sources may be appropriate to raise the
necessary funds. To the extent these discussions can be accomplished prior to production of the final
Regional Action Plan, the contact points and funding sources discussed should be identified in the
Regional Action Plan. In lieu of these discussions prior to production of the Regional Action Plan, the
Regional Action Plan should identify the contacts to be made and the party(ies) responsible for making
those contacts.
7-17
-------
Regional Action Plan Guidance Developing Implementation Actions
The Regional Action Team should also consider what other programs can be "leveraged" to fund
Regional Action Plan implementation actions. For example, has a Superfund preliminary assessment/site
investigation been conducted at abandoned waste sites? Is it possible to speed Resource Conservation and
Recovery Act corrective actions at local industrial sites? Can the U.S. Corps of Engineers maintenance
dredging be coordinated with remediation priorities? The Regional Action Plan should identify the
ongoing environmental programs that can be viewed as "leveraging candidates" and the basis for
attempting to leverage mat program.
73.5 Regulatory and Nonregulatory Incentives
The Regional Action Team will need to consider whether implementation actions can reasonably
succeed, given the incentives and disincentives associated with the implementation action. As the cost
of the action increases, the incentives must increase. Whether the program has a regulatory and/or
nonregulatory component, incentives must exist. In the context of regulatory programs, the expectation
of enforcement creates an incentive for compliance. Without the benefit of regulatory enforcement,
nonregulatory programs depend on market incentives or public commitment to generate voluntary
compliance. If a nonregulatory action is important to meeting the objectives of the Regional Action Plan,
the Regional Action Team will want to evaluate whether sufficient incentives are in place to foster
voluntary implementation. Exhibit 7-13 lists questions to consider when evaluating how responsive the
target audience will be toward implementation of individual options.
In general, incentives are market-driven (assuming complete access to information). For example,
farmers will reduce the use of expensive pesticides, if the reduction is shown to not affect overall
profitability. Because of barriers in information flow and the existence of non-market goods, government
action is often necessary to build or correct incentives. Consequently, outreach efforts are often
Exhibit 7-13. Questions Concerning Implementation Incentives/Disincentives
Is the action covered under an existing regulatory program?
Do any regulatory requirements act as barriers to implementation?
Is the action covered under an existing voluntary program?
Are there adequate mechanisms for disseminating information about the action?
Are there mechanisms to provide technical assistance to implement the action?
Do any financial incentives stimulate implementation of action?
Do any financial impediments discourage implementation (including subsidies that encourage activities that
conflict with this commitment)?
What organizations) will be responsible for monitoring progress in implementation?
_
-------
Regional Action Plan Guidance Developing Implementation Actions
employed to disseminate information on the use of proven pollution prevention technologies that reduce
costs without sacrificing product quality. If success depends directly on voluntary action, the Regional
Action Team needs to consider whether sufficient incentives exist to motivate action.
Protecting Chesapeake Bay resources enjoys widespread public support. Consequently, public
recognition, through "green" certifications or award ceremonies, may act as another incentive to motivate
actions. EPA is initiating a new program that creates incentives and rewards facilities for compliance.
The Environmental Leadership Program, which is in its pilot phase, publicly recognizes private sector
facilities that are identified as environmental leaders. The cornerstone of this program is industrial self-
audits and self-disclosure. The program provides facilities a limited period in which to correct violations
discovered hi self-audits and disclosed to the regulatory agency. In addition, it guarantees that no routine
inspections will be conducted at the facilities during their tenure in the program. EPA is developing a
similar program for federal facilities.
Regulatory programs include an enforcement component, either through judicial or administrative
actions, that provides a powerful motivating tool. Additional regulatory incentives include industrial self-
monitoring, reporting, and public notice of violations. Increasingly, regulatory agencies are employing
fees, penalties, and trading systems to create compliance incentives. Fees and taxes can be used to
encourage facilities to reduce pollution in order to save money. Some jurisdictions are experimenting
with point/nonpoint trading. For example, a POTW may meet nutrient control objectives by obtaining
nutrient management agreements with farms. Farmers are obliged to undertake actions or sacrifice
payments and possibly suffer breach of contract charges.
Innovative compliance agreements provide a control option worthy of consideration. EPA and
several states have been developing Supplemental Enforcement Projects in which the agreed-upon penalty
would be reduced to reflect the commitment made by the alleged violator to conduct a prescribed project,
often a pollution prevention or remediation project, which might otherwise be viewed as beyond the reach
of regulatory requirements (see Policy on the Use of Supplemental Environmental Projects in EPA
Settlements [EPA 1991]). EPA Region 5, for example, was able to compel a facility to remediate
contaminated sediment as a condition of a Clean Water Act enforcement settlement. Another viable
Supplemental Enforcement Project alternative is requiring the violator to sponsor a series of training
sessions for other members of the regulated community (e.g., have the facility sponsor a training session
on pollution prevention options in a particular industry).
7-19
-------
Regional Action Plan Guidance Developing Implementation Actions
In addition to administrative or judicial enforcement, officials may take other actions to encourage
compliance. Municipalities administering industrial pretreatment programs have successfully encouraged
compliance by publishing the names of violators in local newspapers. Industry will consider the impact
of public notice of noncompliance when formulating corporate compliance policies and in training
personnel responsible for ensuring compliance with environmental regulatory requirements. Public notice
of noncompliance can have a profound effect on a community's perspective of its corporate citizens. As
citizens become more concerned about Bay quality issues, many companies have initiated marketing
campaigns highlighting voluntary pollution prevention efforts, contributions to restoration of damaged
local natural resources, and overall corporate concern with environmental issues.
7.2.6 Public Support
Public support is an important component to the success of any environmental project. In
general, the public has been supportive of environmental projects, recognizing the intrinsic value of a
cleaner environment to their quality of life. Many environmental projects are prodded into being by
enthusiastic public involvement. Other projects, such as household hazardous waste collection programs,
hinge then* success on widespread pubic involvement. Indeed, with the increased emphasis on voluntary
programs, such as nonpoint source control, the need to generate and maintain public support is
paramount.
Nonetheless, enthusiastic public support cannot be expected for all projects. The Not in My
Backyard syndrome has been well documented. Similarly, the public values a good return on its invested
tax dollars and is unlikely to support a project for which cost has not been given adequate scrutiny.
Consequently, the Regional Action Team needs to ensure public support for the project. Moreover, it
is best to generate public support throughout the process, rather than seeking "rubber stamp" public
approval after the alternative project list has been narrowed. Chapter 3 provides more information on
the need for public participation. Exhibit 7-14 lists several questions to consider when evaluating public
support for individual implementation actions.
An issue related to public support, but encompassing all stakeholders, is impetus. Undertaking
environmental projects can be a long-term process, where planning, design, implementation, and
completion involve years of time and effort. Stakeholder interest, important to the overall success of the
Regional Action Plan, can wane over time. Consequently, maintaining impetus is essential to Regional
Action Plan success, and alternative projects should be assessed with regard to this important variable.
While certain projects may "score" low with regard to certain variables (e.g., may not reduce contaminant
_
-------
Regional Action Plan Guidance Developing Implementation Actions
Exhibit 7-14. Questions Concerning Public Support
Will the action impact employment rates?
Will the action impact recreational opportunities?
Will the action impact other quality of life indicators?
Is there precedent for public support or disapproval of similar actions?
Are there studies documenting public opinion (e.g., Chesapeake Bay Attitudes Survey [Chesapeake Bay
Program, 1994])?
loadings to any significant degree), these projects may have value in that they can be accomplished
quickly, demonstrating rapid results and anchoring continued stakeholder interest.
7.2.7 Indicators for Measuring Progress
The ability to demonstrate progress is an important factor in maintaining impetus for program
implementation. Past experience has demonstrated that collecting sound evidence on the success of
actions is also an important factor in fostering trust among government, industry, environmental groups,
and citizens. Identifying indicators or measures of progress and effectiveness is another factor to consider
when evaluating and selecting implementation actions.
Progress should be measured from both a programmatic standpoint (e.g., whether milestones are
being achieved) and an environmental response perspective (e.g., whether chemical concentrations in fish
tissue are declining). Monitoring programs can be expensive, so it is important that they are designed
to collect only relevant information and that data gathering activities are accurate and reliable. If data
collection efforts need to be increased beyond current ones, the costs of these efforts should be included
in the estimate of the cost of the action. The following points should be considered when identifying
measures of progress:
• Whenever possible, supplement programmatic indicators with environmental indicators
• Use existing data collection efforts, if appropriate
• Design data collection efforts so that they are consistent with other data collection programs
in the Bay, whenever feasible
• Develop a sampling plan identifying minimum data collection requirement, sampling locations
and frequency, sampling and analytical protocols, and quality assurance/quality control
procedures
• Develop feedback programs to communicate information to both stakeholders and decision-
makers.
7-21
-------
Regional Action Plan Guidance Developing Implementation Actions
7.3 ASSIGNING AND TRACKING COMMITMENTS
Because the Regional Action Plan represents the beginning of the implementation process, it is
important that it initiates the concept of responsibility. The Regional Action Plan can accomplish this by:
• Identifying actions that need to be taken
• Assigning parties responsible for taking the needed action
• Providing aggressive, realistic schedules for achieving the action
• Developing a "report back" scheme.
The first item, identifying actions that need to be taken, was discussed hi the first two sections
of this chapter. Therefore, the remainder of this section addresses the last three! points.
Chapter 3 of this manual describes an approach for selecting appropriate Regional Action Team
members. These individuals will probably represent core stakeholder groups, which are key to
successfully implementing the Regional Action Plan. The Regional Action Plan should assign
responsibilities, and associated accountability, to groups and individuals for implementing the various
actions provided for in the Regional Action Plan. The Regional Action Plan can make tentative initial
assignments with subsequent review and confirmation by the tentatively assigned party(ies).
Equally important is the provision of an aggressive, yet realistic, schedule. Two general types
of deadlines are envisioned. One set of deadlines will be programmatic in nature, describing when, for
example, permitting actions can be expected. The second set will be more global and goal-oriented,
providing timelines for achieving the goals identified for the Region of Concern. Chapter 4 defines the
goal-setting process.
Deadlines must be established to ensure progress. At the same time, deadlines must be realistic
and sensitive to technical, institutional, and socio-political constraints. For example, deadlines should
not be so aggressive that the opportunity for public input is minimized In addition, unrealistic,
unattainable deadlines may discourage participants and derail momentum.
Programmatic deadlines need to be considered seriously and, if the Regional Action Team is not
sufficiently confident that concrete deadlines can be set without further information, "process-oriented"
deadlines, such as a progress report and associated briefing of the Regional Action Team, can be included
until more concrete deadlines can be established. In other cases, the timelines may be contingent on other
_
-------
Regional Action Plan Guidance Developing Implementation Actions
actions (e.g., "Six months from the receipt of the report on the feasibility of...."). The Regional Action
Plan is expected to include an abbreviated list of actions, or steps, required by responsible parties, and
more comprehensive timelines are expected to be developed as the Regional Action Plan unfolds.
The Regional Action Team needs to stay abreast of implementation action progress made by
assigned agencies/individuals. It is recommended that the Regional Action Team receive periodic reports
(e.g., monthly) summarizing progress to date. The lead agency should coordinate development and
collection of these reports. As illustrated in Exhibit 7-15, the report should include activities during the
current period; problems/issues that have arisen, including how they are being/will be addressed; planned
activities for the following period; a schedule documenting major milestones (with planned and actual
accomplishments); and a description of assistance, if any, that the project leader requires.
It is also recommended that the Regional Action Team organize periodic (e.g., semiannual)
meetings of all project leaders to discuss current progress toward achieving objectives and goals. This
meeting can also be used to raise the need for making mid-course corrections, as necessary, that more
realistically address the project's current progress.
7.4 PRESENTING IMPLEMENTATION ACTIONS IN THE REGIONAL ACTION PLAN
The Regional Action Team should document the process used for identifying, evaluating, and
selecting implementation actions in the Regional Plan. The Regional Action Plan should describe die
approach for preparing the initial list of implementation actions by including responsible
individuals/groups, materials reviewed, individuals/organizations contacted, and formal and informal peer
review procedures and modifications to the list, if any, resulting from the review procedures.
The Regional Action Plan should summarize the methodology used to assess which actions are
most appropriate and how such decisions were made. As noted in Section 7.2, the Regional Action Team
should identify factors used in evaluating and then selecting the most appropriate actions. If factors were
given different priority, the Regional Action Team needs to explain the rationale for weighting. If some
/
factors were considered hi evaluating one set of options, but not another, an explanation should be
provided. The Regional Action Team will also need to describe any additional fact finding necessary as
the Regional Action Plan process moves forward.
7-23
-------
Regional Action Plan Guidance Developing Implementation Actions
Exhibit 7-15. Recommended Format of Periodic Progress Report, With Project Example
Tide of Project: Develop Total Maximum Daily Loads for Metals on Attaboy Creek (Goal I, Objective
A, Action 6) Project Leader: Joan Sloan
Current Activities
• During week of August 8, prepared sampling plan, distributed for peer review, and finalized.
• Met with John Jones of Soil Conservation Service to discuss natural background of metals found in
soils of the Upper Attaboy.
• Reviewed National Pollutant Discharge Elimination System permit files of major dischargers on the
Attaboy Creek.
• Briefed Citizens Advisory Committee representative, Betty Davis, on opportunity for citizen
monitoring.
Problems/Issues Arising in Current Period
• Scheduled sampling events on Longarm Run were delayed due to equipment malfunctions. Sampling
has been re-scheduled to the first week of September.
• Funding limitations prohibited biomonitoring at Brown Bend on the Attaboy Creek.
Planned Activities for Next Period
• Conduct sampling on Longarm Run first week of September
• Conduct sampling on Brown Bend during third week of September.
• Meet with S. Stump and D. Fanner of F&AU to discuss current estimated sediment runoff rates
associated with farming on Upper Attaboy and projected pesticide application rates using approaches
recommended by agricultural extension agents.
• Meet with D.W. Waters to discuss current metal loadings to publicly owned treatment systems and
influent sources based on industrial waste survey.
• Meet with Chesapeake Bay Modeling Subcommittee regarding procedures for estimating load
allocation from nonpoint sources.
Major Milestones
Deliverable Name Planned TVaHHno. Actual Date
• Collect background data from 304(1) reports 6/21/9- 6/20/9-
• Select appropriate total pnaTimum daily load model 7/15/9- 7/15/9-
• Collect all necessary ambient data to calibrate model 10/9/9-
• Complete model calibration 11/7/9-
Assistance Sought
• Identify sources of backup monitoring equipment tt> use in case of malfunctions.
-------
Regional Action Plan Guidance Developing Implementation Actions
The Regional Action Team will need to develop a format for presenting the implementation
actions in the Regional Action Plan. The Regional Action Plan should document the initial inventory of
actions, the evaluation of actions, and identify which actions were selected. Exhibits 7-1, 7-2, and 7-3
illustrate several approaches for presenting the implementation actions hi the Regional Action Plan.
Another approach is to prepare a fact sheet or summary table for selected actions. As illustrated in
Exhibit 7-16, this approach facilitates a description of how the action may address several problems and
target several sources in the Region of Concern. This presentation format allows decision-makers to
compare the benefits, costs, and implementation framework of each action.
7-25
-------
Regional Action Plan Guidance
Developing Implementation Actions
Exhibit 7-16. Regional Action Plan Summary of Recommended Actions
Evaluation
Factor
Action 1
Action 2
Summary of
action
Reduce lead discharged to publicly
owned treatment works (POTW) by
providing pollution prevention
information to industrial and
commercial users
Reduce metal loadings from urban runoff by
ensuring effectiveness of existing stormwater
management programs (under federal
stormwater program) and instituting additional
urban runoff programs where needed
Problem(s)
addressed
Ambient concentrations exceed water
quality standards (WQS)
Shellfish contamination
Sediment contamination
Ambient concentrations exceed water quality
standards (WQS)
Shellfish contamination
Sediment contamination
Magnitude of
contribution to
problem
Unknown due to lack of POTW
discharge monitoring requirement
for lead and uncertainty about
sediment-water column interactions
Uncertain due to lack of monitoring data on
stormwater
Sources targeted
Commercial and industrial
dischargers
Commercial and industrial properties
Municipal properties
Developing areas
Entity
responsible for
implementation
• Municipal pretreatment program
Municipal governments), flood control
districts, departments of transportation
Entities
contributing to
implementation
• State pollution prevention office
• Industrial and commercial facilities
• State/federal stormwater coordinators
• Industrial and commercial facilities
• Households
Cost
$30,000 to identify sources, conduct
workshop, and perform 20 pollution
prevention opportunity assessments.
$75,000 - $500,000, depending on size of
municipality
Financing/
resources
available
State to train POTW staff on
pollution prevention opportunity
assessments and conduct workshop
with POTW for dischargers; POTW
to perform 20 assessments
104(b)(3) grants from states
Potential for stormwater utility fees
Incentives
POTW initiating monitoring program
to collect data for re-evaluating local
limits, as required by NPDES
permit.
Represents a proactive approach toward Plan
n of the federal stormwater program
Prevention approach, particularly hi
developing areas, is less costly than
retrofitting •
Timeframe for
implementation
6 months for pollution prevention
training
12 - 18 months for local limit
• 2-5 years
Measures of
success
Reduction of lead in discharge by
both industrial users and POTW
Reduction of shellfish concentration
Meet WQS
Loadings reduction
Reduction of shellfish concentration
Meet WQS
Ranking of
priority for
implementation
High
High
7-26
-------
Regional Action Plan Guidance Developing Implementation Actions
REFERENCES CITED
Metropolitan Washington Council of Governments (MWCOG). 1992. A Current Assessment of
Urban Best Management Practices: Techniques for Reducing Non-Point Source Pollution in
the Coastal Zone.
U.S. Environmental Protection Agency (EPA). 1993a. Guidance Specifying Management Measures
for Sources ofNonpoint Pollution in Coastal Waters. EPA 840-B-92-02.
U.S. Environmental Protection Agency (EPA). 1993b. Selecting Remedial Techniques for
Contaminated Sediments. EPA 823-B-93-001.
U.S. Environmental Protection Agency (EPA). 1993c. Assessment and Remediation of Contaminated
Sediments (ARCS) Program Assessment Guidance Document. EPA 905-R-94-002.
U.S. Environmental Protection Agency (EPA). 1993d. Assessment and Remediation of Contaminated
Sediments (ARCS) Program Remediation Guidance Document. EPA 905-R-94-003.
U.S. Environmental Protection Agency (EPA). 1991. Policy on the Use of Supplemental
Environmental Projects in EPA Settlements.
U.S. Environmental Protection Agency (EPA). 1982. Work Book for Determining Economic
AchievabiUty for National Pollutant Discharge Elimination System Permits.
Governor's Blue Ribbon Panel. 1995. Financing Alternatives for Maryland's Tributary Strategies.
OTHER SOURCES OF INFORMATION
Chesapeake Bay Local Government Advisory Committee. 1992. Local Solutions A Local
Government Guide to Managing Household Hazardous Waste in the Chesapeake Bay Region,
Lindsey G., L. Roberts, and W. Page. 1991. Stormwater Management Infiltration Practices in
Maryland: A Second Survey. Maryland Department of the Environment, Sediment and
Stormwater Administration, Baltimore.
Livingston, E.H. and E. McCarron. 1992. Stormwater Management: A Guide for Floridians.
Florida Department of Environmental Regulation, Tallahassee.
Macal, C.M. and B.J. Broomfield. 1980. Costs and Water Quality Effects of Controlling Point and
Nonpoint Pollution Sources. National Science Foundation, Argonne National Laboratory.
Metropolitan Washington Council of Governments. 1987. Controlling Urban Runoff: A Practical
Manual for Planning and Designing Urban BMPs.
Northern Virginia Soil and Water Conservation District. July 1994. Developing Successful Runoff
Control Programs for Urbanized Areas.
7-27
-------
Regional Action Plan Guidance Developing Implementation Actions
Santa Clara Valley Water Control District. 1992. Best Management Practices for Automotive-
Related Industries. Santa Clara Valley Nonpoint Source Pollution Control Program and the
San Jose Office of Environmental Management, Santa Clara, CA.
Seattle-King County Department of Public Health. 1990. Local Hazardous Waste Management Plan
for Seattle-King County.
Southeastern Wisconsin Regional Planning Commission. 1991. Costs of Urban Nonpoint Source
Water Pollution Control Measures. SWRPC, Waukesha, WI. Technical Report Number 31.
Tahoe Regional Planning Agency. 1988. Water Quality Management for the Lake Tahoe Region,
Handbook of Best Management Practices, Vol. n. Tahoe Regional Planning Agency, Tahoe,
NV.
U.S. Department of the Interior (USDOI). 1991. Pollution Prevention Handbook: Housing
Maintenance. No. 16 in a series of fact sheets. U.S. Department of the Interior, Office of
Environmental Affairs, Washington, DC.
U.S. Environmental Protection Agency (EPA). 1995. Combined Sewer Overflows—Guidance for
Permit Writers.
U.S. Environmental Protection Agency (EPA). 1995. Combined Sewer Overflows—Guidance for
Long-Term Control Plans.
U.S. Environmental Protection Agency (EPA). 1994. Assessment and Remediation of Contaminated
Sediments (ARCS) Program Remediation Guidance Document.
U.S. Environmental Protection Agency (EPA). 1994. Industrial User Inspection and Sampling
Manual for POTWs. EPA 831-B-94-001.
U.S. Environmental Protection Agency (EPA). 1994. Storm Water Pollution Abatement
Technologies. EPA 600-R-94-129.
U.S. Environmental Protection Agency (EPA). 1994. Guidance Manual for Developing Best
Management Practices (BMP). EPA 833-B-93-004.
U.S. Environmental Protection Agency (EPA). 1993. Urban Runoff Pollution Prevention and
Control Planning. EPA 625/R-93/004.
U.S. Environmental Protection Agency (EPA). 1993. Guidance Specifying Management Measure for
Sources of Nonpoint Pollution in Coastal Waters. EPA 840-B-92-002.
U.S. Environmental Protection Agency (EPA). 1993. Selecting Remediation Techniques for
Contaminated Sediment. EPA 823-B93-001.
U.S. Environmental Protection Agency (EPA). 1992. Storm Water Management for Industrial
Activities: Developing Pollution Prevention Plans and Best Management Practices.
EPA 832-R-92-006.
7-28
-------
Regional Action Plan Guidance Developing Implementation Actions
U.S. Environmental Protection Agency (EPA). 1992. Storm Water Management for Construction
Activities: Developing Pollution Prevention Plans and Best Management Practices.
EPA 832-R-92-005.
U.S. Environmental Protection Agency (EPA). 1992. Sediment Classification Methods Compendium.
EPA 823-R-92-006.
U.S. Environmental Protection Agency (EPA), Office of Water. 1992. Storm Water Management
for Industrial Activities—Developing Pollution Prevention Plans and Best Management
Practices. EPA 832-R-92-006.
U.S. Environmental Protection Agency (EPA). 1992. Facility Pollution Prevention Guide.
EPA 600/R-92/0088.
U.S. Environmental Protection Agency (EPA). 1994. Guidance Manual for Implementing Municipal
Storm Water Management Programs.
U.S. Environmental Protection Agency (EPA). 1991. Guidance for Water Quality-based Decisions:
The TMDL Process. EPA 440/4-91-001.
U.S. Environmental Protection Agency (EPA). 1991. Technical Support Document for Water
Quality-based Toxics Control. EPA SOS/2-90-001.
U.S. Environmental Protection Agency (EPA). 1991. Supplemental Manual on the Development and
Implementation of Local Discharge Limitations Under the Pretreatment Program.
EPA 21W-4002.
U.S. Environmental Protection Agency (EPA). 1989. Industrial User Permitting Guidance Manual.
EPA 833/B-89-001.
U.S. Environmental Protection Agency (EPA). 1989. Guidance for Developing Control Authority
Enforcement Response Plans.
U.S. Environmental Protection Agency (EPA). 1988. Waste Minimization Opportunity Assessment
Manual. EPA 625/7-88/003.
\
U.S. Environmental Protection Agency (EPA). 1988. Waste Minimization Opportunity Assessment
Manual. EPA 625/7-88/003.
U.S. Environmental Protection Agency (EPA). 1992. Facility Pollution Prevention Guide.
EPA 600/R-92/088.
UiS. Environmental Protection Agency (EPA). 1987. Permit Writer's Guide to Water Quality-based
Permitting for Toxic Pollutants. EPA 440/4-87-005.
U.S. Environmental Protection Agency (EPA). 1987. Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the Pretreatment Program.
EPA 833/B-87/202.
7-29
-------
Regional Action Plan Guidance Developing Implementation Actions
U.S. Environmental Protection Agency (EPA). 1987. Guidance for Preventing Interference at
POTWs. EPA 833/B-87/201.
U.S. Environmental Protection Agency (EPA). 1987. Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the Pretreatment Program,
EPA 833/B-87/202.
U.S. Environmental Protection Agency (EPA). 1986. Environmental Regulations and Technology—
The National Pretreatment Program. EPA 625/10-86/005.
U.S. Environmental Protection Agency (EPA). 1974. Excerpts from Control of Infiltration and
Inflow into Sewer Systems and Prevention of Correction of Excessive Infiltration and Inflow
into Sewer Systems: A Manual of Practice. EPA 670/9-74-004 and PB-273440/8.
U.S. Environmental Protection Agency (EPA). 1974. Manual for Deiting Chemicals: Storage and
Handling. EPA 670/2-74-033 and PB-236152.
U.S. Environmental Protection Agency (EPA). Guides to Pollution Prevention:
Metal Casting and Heat Treating Industry. EPA 625/R-92/009.
Paint Manufacturing Industry. EPA 625/7-90/005.
The Pesticide Formulating Industry. EPA 625/7-90/004.
The Commercial Printing Industry. EPA 625/7-90/008.
The Fabricated Metal Industry. EPA 625/7-90/006.
For Selected Hospital Waste Streams. EPA 625/7-90/009.
Research and Educational Institutions. EPA 625/7-90/010.
The Printed Circuit Board Manufacturing Industry. EPA 625/7-90/007.
The Pharmaceutical Industry. EPA 625/7-91/017.
The Photoprocessing Industry. EPA 625/7-91/012.
The Fiberglass Reinforced and Composite Plastic Industry. EPA 625/7-91/104.
The Automotive Repair Industry. EPA 625/7-91/016.
The Automotive Refinishing Industry. EPA 625/7-91/016.
The Marine Maintenance and Repair Industry. EPA 625/7-91/015.
Mechanical Equipment Repair Shops. EPA 625/R-92/008.
The Metal Finishing Industry. EPA 625/R-92/011.
Non-agricultural Pesticide Use.
U.S. Environmental Protection Agency (EPA). 1989. Pollution Prevention Information Clearing
House (PPIC). Electronic Information Exchange System (EIES)—User Guide, Version 1.1.
EPA 600/9-89/086.
Washington State Department of Ecology. 1993. Sediment Source Control Standards Users Manual.
Washington State Department of Ecology. 1991. Sediment Cleanup Standards Users Manual.
Wiegand C, T. Schueler, W. Chitteren, and Jellick. 1986. Cost of Urban Runoff Quality Controls.
Urban Runoff Quality—Impact and Quality and Enhancement Technology. In Proceedings of
an Engineering Foundation Conference, Henniker, NH, June 23-27, 1986. American Society
of Civil Engineers.
7-30
-------
Regional Action Plan Guidance Developing Implementation Actions
Woodward-Clyde. 1990. Urban Targeting and BMP Selection, An Information and Guidance
Manual for State Nonpoint Source Staff Engineers and Managers. Prepared for the U.S.
Environmental Protection Agency, Region 5, Water Division, Chicago, DL, and the Office of
Water Regulations and Standards, Washington, DC.
7-31
------- |