rotecuon Agency

                    December 1970

            WALTER R. HAGER
          Program Grants Officer

     Office of State Program Review & Assistance
        Environmental Protection Agency
          Washington. D.C. 20242
             December 1970

For sale by the Superintendent of Documents, U.S. Government Printing Office
            Washington, D.C. 20402 - Price 35 cents (paper cover)


    Variations  in Legislation, Administration,
      and Organization of Programs  	  4
    Requirements for an Effective Water
      Quality Control Program	  8
    Need for Guidelines	  9
    Scope of This Study	 10

    Authority 	 11
    Program 	 17
    Organization	 22
    Staffing	 27

    Idealized Water Quality Management Program	 31
    Guidelines	 35



TABLE 1.  Positions Authorized for the  Staff of Texas
            Water Quality Board	 28
       2.  Comparison of Public Administration Service
            Recommendations and Fiscal Year 1969 Man-Years
            Assigned to State Water Pollution Control Agencies	 37
       3.  Texas Water Quality Board 1970 Workload	 45

       4.  Estimates of Personnel Requirements for the
            Texas Water  Quality Board Using Guidelines	 46


FIGURE  1.   Organization—Federal Water Pollution Control
             Administration, January, 1970	   6

        2.   Relationship of the Water Quality Board to Other
             State Agencies 		 14

       3.  Organization of Texas Water Quality Board	 23

        4.   Field Operations of the Texas Water Quality
             Board—Districts and District Offices	 26

        5.   Program Activities of Idealized State Water
             Quality Control Program	 34

        6.   Idealized Organization State Water Quality
             Control Agency   	        _ 	  ,_             36
                       o   j         ~                         ™^ ^"

        7.   Relationship of Inspection Frequency to Percent
             Urbanization			 40


   HIS work's  purpose is to dispel the air of mystery  surrounding
staffing of Government agencies  charged with regulating  the quality of
public waters. It was presented as a report to the faculty of the Graduate
School of the University of Texas at Austin in partial fulfillment of the
requirements for the Degree of Master of Arts in Public Administration
hi April 1970. While focusing on staffing needs for State water quality
management agencies, the  premise underlying the guidelines is that an
agency's staffing is  a  function of  the  authority granted it  and the work-
load  resulting from the exercise  of  that authority. Since the bulk  of
expenditures by a State water quality management agency is for salaries
and  associated benefits,  the  numbers of personnel  and  the skills and
experience needed to carry out the agency program also furnish a means
for establishing an operating budget.
   As State water quality management agencies are by and large staffed
and  directed by engineers  and scientists,  the guidelines, through use of
an engineering methodology, may be readily useful to those agencies with
only minor modifications for those functions not covered  by the general
   As  presented, the guidelines  provide only a method of  approach
founded upon the experience and  observations of those using them. Used
in this way, the methodology  is responsive to varying conditions. How-
ever,  the overall measure of their  utility is the  results  of the water
quality management program staffed using the guidelines, i.e., the quality
and usefulness of the State's water stemming from the implementation of
the authority assigned to the  agency and exercised through its staff. The
guidelines  can provide  direction  in  estimating total requirements  for
existing agencies, or for  undertaking added functions, as well as serving
as a tool for evaluating the effects on staffing and budget  of reorganiza-
tion  and/or reassignment of  functions.
  The author's hope is  that the  guidelines  provided in this report, by
formalizing  what program managers have  been  doing  informally  in
various ways, will lead to the development of more effective water quality
management programs.
                                              W. R. HAGER

                                              Washington, D.C.
                                              NOVEMBER 1970.


   HE CASE for water quality management was well put by the Select
Committee on National Water Resources of the U.S. Senate.  It reported
that by 1980 total requirements of water for all purposes, from surface
and underground sources, will almost equal total developable supplies
of 650 billion  gallons per  day and may by the year  2000  amount  to
almost double  the available water.  This magnitude of  use  is  not  nec-
essarily a cause for alarm, as water can be used again and again as it flows
to  the sea.1 Yet in  the process  of being  used, these waters become
polluted  and may become  unfit  for  some  useful purposes.  Hence, the
growing demands for water in  the face of limited supplies and increasing
pollution  necessitate  an  approach  to  water  resources management
founded on quality considerations as well as quantity.2
   While the select committee's findings were published nearly  10  years
ago, the general conclusion that future water needs will be met only by
using the available supply over and over again,  as  is already occurring
in some  of the more heavily populated and industrialized areas of the
country,  has been increasingly validated with the years.  To be used or
reused, water must be of suitable quality. Use almost  always results  in
degradation of the physical, chemical, biological, bacterial, and esthetic
qualities of water, i.e., it is  polluted.
   Preventing  and minimizing this  pollution  is the purpose of water
quality management. Stated simply, water  quality  management means
"providing the right quality of water in  right quantities for the purposes
to  be  served at  the  points where it  is needed." 3  With the placing  of
increasing demands upon limited supplies,  "more usable water can be
provided to meet these needs by controlling pollution than by any  other
means." 4
   Water quality management has been correctly described as "both a
concern and a responsibility  of every segment of our society, and calls
for the  exercise of  sound judgment  and discerning  statesmanship."5
Satisfactory meeting  of this responsibility, however,  requires that much
factual  information regarding water availability, quality, use, and con-
trol, including  the  multitude  of water pollutants and their effects, must
be collected, analyzed,  and disseminated, and also that  sound technical,
  1U.S., Congress, Select Committee on National Water Resources,  U.S. Senate,
 Water Resources Activities in the United States, Water Quality Management, Com-
 mittee Print No. 24 (Washington, B.C.: Government Printing Office, I960), p. 1.
  2 Ibid., p. 4.
  3 Ibid., p. 2.
  'Ibid., p. 3,

legal,  and administrative procedures  for the cooperative  planning for
multiple use of the available water resources be developed  and applied.6
These requirements,  the basis  of  sound water  quality management, are
dependent upon  the efforts of  governmental water pollution control

    Variations  in Leglislation, Administration

             and Organization of  Programs

   The national Government and various  States  have followed  similar
paths in developing and implementing water pollution control legislation,
resulting in continuing water quality management programs.  Water pol-
lution control legislation was first introduced by Senator Cockrell  in the
U.S.  Congress on December 18, 1897.7 Since that time,  numerous bills
have been  considered in both the  House and the Senate until at the
present  time,  the  Federal  Water Pollution  Control Act,  as amended,
(hereafter  referred to as the  act) guides  the  Federal Water Pollution
Control Administration's  activities.8
   Even a cursory comparison  of the legal, administrative, and organiza-
tional aspects of these programs reveals that no two are alike; but a broad
generalized description can be  given that all are  expected to  protect the
quality of the waters of the States from  degradation which makes them
unsuitable for legitimate  uses.  The national water  quality management
legislation interlocks with the States' legislation and programs  in purpose,
administration and organization.

National Water Quality  Control Program
   The general interrelationship of  the national  program to  the States'
programs is setout in the declaration of policy of the act:
   (a)  The purpose of this act is  to enhance  the quality and value of our water
resources and to  establish a national policy for the prevention, control, and abate-
ment of water pollution, (b) In connection with the exercise of jurisdiction over
the waterways of the Nation and  in consequence  of the benefits resulting to  the
public health and welfare by the  prevention and control of water pollution, it is
hereby declared to be  the policy of Congress to recognize, preserve, and  protect
the primary  responsibilities and rights of the States in  preventing  and controlling
water pollution, to support and aid technical research relating to the  prevention
and control  of water  pollution,  and to provide  Federal technical  services and
financial aid to State and interstate agencies  and  to municipalities in connection
with  the prevention and control of water pollution. *  * * (c)  Nothing in this
act  shall be  construed as impairing or in  any manner affecting any right  or
jurisdiction of the States with  respect to the waters  (including boundary waters)
of such States.8
   6 Ibid.
   7 U.S.,  Congress' House, Committee on Rivers and Harbors, Pollution of Navi-
 gable Waters, Hearings on  H.R. 519, H.R. 387, and H.R.  4070, 79th Cong., 1st
 sess., 1945, p. 180.
   8 Federal Water Pollution Control Act, U.S.C., vol.  XXXIII sec 466 et sea
   9 Ibid., sec. 466.

   The control of water pollution is essentially a local function, with the
State water pollution control  agency responsible for coordinating local
measures and works for preventing and controlling polluting conditions.
The act  does not alter this fundamental relationship. The national water
quality management program  places the primary responsibility for water
pollution control on the State and interstate agencies with the Federal
Government providing technical and fiscal support together with enforce-
ment of  national water quality standards on interstate and coastal waters.
   National government interest hi pollution began when regulation as
carried out by the State agencies did not adequately control pollution in
various  waters,  e.g., the  Ohio  River  Basin.  Through the  years,  the
emphasis on control of water pollution at the national level has expanded
from the protection of the public health (sanitary)  aspects of water use
to include protection of all legitimate uses through the addition of water
conservation considerations. The passage of the Federal Water Pollution
Control  Act  in  1956 10 and its  amendmentsu have provided  for a
program on a national scale  which will serve the various purposes of
water quality management.
   The act created  the Federal  Water Pollution Control Administration
(FWPCA)  and provides for  its staffing in general terms. In January,
1970, FWPCA was organized (as shown in fig. 1) under a commissioner
and five assistant commissioners for Environmental and Program Plan-
ning, Administration, Operations, Research and Development,  and En-
forcement, respectively. The commissioner is  in turn  responsible to an
Assistant Secretary of the Interior. The  Administration's field operations
are  administered through  nine regional offices.  FWPCA during  fiscal
year 1969 had an authorized  staff of approximately 2,200 positions and
an operating budget of $73  million.12  At the present time,  there  are
more  positions allotted to the national  agency  for  regulation of water
quality than by  the  combined 50 States  to their water pollution control
   The key authorization in the act has  the purpose of melding national
and State programs through the preparation and development of  com-
prehensive programs for water  pollution  control.  The FWPCA  is  to
develop  such plans with the cooperation of other Federal agencies, the
State water pollution control agencies and interstate agencies, and the
municipalities  and industries involved. The act  requires further that in
the  survey for or planning of  Federal agency reservoirs consideration

   10 U.S.,  Congress, Federal Water Pollution Control Act, Public Law 84-660,
84th Cong.,  2d sess.,  1956.
   11 U.S., Congress, Federal Water  Pollution  Control Act  Amendments of 1961,
Public Law 87-88, 87th Cong., 1st sess., 1961. U.S., Congress, Water Quality Act
of 1965,  Public Law 89-234, 89th Cong., 1st  sess., 1965. U.S., Cong., Clean  Water
Restoration Act of 1966, Public Law 89-753, 89th Cong., 2d sess., 1966.
   12 U.S.,  Congress,  Public Works Appropriations  for  1969 for Water Power
Resources Development and the Atomic Energy Commission,  Public Law 90-147,
90th Cong., 2d  sess., 1968.
   13 State and- Interstate Programs for  Water Pollution Control,  Digest of  Fiscal
Year 1969 State Program  Plans (Washington,  B.C.:  U.S.,  Department  of the
Interior,  Federal  Water  Pollution  Control  Administration, State  and Regional
Program  Grants Branch, 1969), sec. 2.

                                                         ASSOCIATE  COMMISSIONER
                         OFFICE OF
                     PUBLIC INFORMATION
                    ASSISTANT  COMMISSIONER
                       FOR OPERATIONS
                                                                         ASSISTANT  COMMISSIONER
                                                                         FOR ENVIRONMENTAL AND
                                                                           PROGRAM PLANNING
                                    ASSISTANT COMMISSIONER
                                  FOR RESEARCH & DEVELOPMENT
                                                      ASSISTANT  COMMISSIONER
                                                          FOR  ENFORCEMENT
                                                        REGIONAL  DIRECTORS
         BOSTON, MASS.

                    FIGURE  1.—Organization—Federal Water Pollution Control Administration, January, 1970.

be given to the inclusion of storage for regulation of stream flow for the
purpose  of water quality control. Also, with respect to water resources
planning, the act authorizes grants to  planning agencies for administra-
tive  expenses of  developing  effective  water quality  management  plans
for a basin.
   The act directs that the  Secretary of  the  Interior shall  encourage
"Interstate Cooperation and Uniform Laws" and gives the consent of the
Congress for  the  negotiation of compacts  between two or more States
for water pollution control purposes. The act authorizes the Secretary to
conduct  in the  Department of the Interior a  "Research,  Investigation,
Training, and Information" program and to make "Grants for Construc-
tion" of  necessary treatment works. A  Water Pollution Control Advisory
Board is established within the Department of  the Interior consisting of
the Secretary (or his  designee)  who shall serve as chairman and nine
members appointed by  the President, none  of whom  shall  be Federal
officers or employees. The act provides  for the establishment of water
quality standards for  interstate waters under a procedure in which  the
States play the primary role. Standards and a plan for their implementa-
tion and enforcement adopted by a State become the standards applicable
if, subsequent to their  adoption, the  Secretary determines them to be
consistent  with  the purposes of the act. Enforcement measures  against
pollution of interstate and navigable waters by the Federal Government
are also  authorized.  Cooperation to control pollution  from Federal in-
stallations is likewise provided.14
   At the outset, the act's "Declaration of Policy" recognizes the primary
responsibilities  and rights of  the States in enhancing the quality and
value of our  water resources by prevention, control, and  abatement of
water  pollution. Further, the  act provides for technical assistance and
financial aid to state and interstate agencies by the National Government.
This policy is supported by the establishment of grants for water pollution
control programs to  assist the  State and interstate agencies in meeting
the costs of establishing and maintaining adequate water quality  control

State Water Quality  Control  Activity
   Though differing in the details of organization and other administra-
tive  aspects, the fifty states can  be said to have similar  water  quality
control  legislation since all  authorize the adoption of  water  quality
criteria  for interstate waters and a plan  for  the implementation  and
enforcement of those criteria. Further, the standards and implementa-
tion plans adopted by the States have been approved by the Department
of  the  Interior.16  Stemming  from  the  similarities  in  legislation  and
approved plans,  all State water pollution  control programs  are  similar
in function. All are designed for the purpose of protecting water quality.
The Texas Water Quality Board is typical in  authorizing legislation,
administration,  and  organization  for  achieving that purpose.  Having
  u Federal Water Pollution Control Act,  United States Code op. cit, passim.
  KIbid. passim.
  18 Digest of Fiscal Year 1969 State Program Plans, sec. 1.

much in common with the other 49, it will provide an empirical model
for examining the workings of State water quality agencies.
   The day-to-day control of water  pollution is essentially a function of
the local governmental entities together with the industries which dispose
of wastes  to  the various  watersheds. The State agency's  relationship
with this function is in regulating water quality. This regulating authority
stems from a declared policy  that the quality of  the  waters within the
State is subject to control by  the State government and that pollution of
these waters constitutes a menace  and  shall be  prevented,  controlled,
and abated.17 Regulation of water quality through control of the actions
of municipalities and  industries which would result in quality degrada-
tion is the  implementation of that policy.
   The practical difficulties of dealing effectively with water  quality prob-
lems are accentuated  by the complexity  of the pollutants and the frag-
mentation  of control. While waste treatment and disposal is for practical
purposes a local  activity, it does not demand the duplication of  facilities
within  limited areas  as now exists.  Resources  in personnel,  advice,
training, finance, inspection,   and  enforcement  are dissipated  over an
unnecessarily  large  number of sewage authorities, districts, and indus-
tries. Development and implementation of comprehensive programs for
control of  water  pollution by  the State water quality management agency
is suggested by the national legislation as a remedy for this  problem.18
   Relations with industry present  a  problem when the industry is the
main source of  employment  and  prosperity  in  a locality. Some  local
authorities feel  that too enthusiastic  implementation  of  water quality
activities by the  State agency  will  drive  tl  industry out and keep  new
industry from  the area.19
   Thus, the State water pollution control agency is faced with a complex
balancing  of values in protecting water  quality through  local pollution
control entities  under legislative and economic  restraints  which  have
developed  over the years and  continue to evolve.

       Requirements  for  an Effective Water

                 Quality  Control  Program

   In a  recent  publication  entitled  An  Action  Program  for  Clean
Water,  a State water  quality  management program is described in five
basic elements   of  effort:  program administration, planning,  facilities
construction, technical services,  and enforcement.20 The  basic elements
  "U.S. Department of the  Interior,  Federal Water Pollution  Control Admin-
istration, Suggested State Water Pollution Control  Act, Revised,  (Washington,
D.C.: Federal Water Pollution Control Administration, 1966), p.  1.
  18 Federal Water  Pollution Control Act, as amended.
  "Thomas  R.  Jacobi,  Richard A. Pavia,  and  E.  F.  Ricketts, "Staffing and
Budgetary Guidelines for State Water Pollution Control Agencies," Journal Water
Pollution Control Federation, vol. 37,  No. 1  (January 1965), p.  10.
  20 Phillip L. Tate and James M. Hudgens, An Action Program For Clean Water,
Joint Study and Proposals by South Carolina Pollution  Control  Authority and
Federal Water Pollution  Control Administration, Middle Atlantic  Region (1969),
p. 59.


in turn must be supported by suitable legislative authority, funding, and
a plan of implementation to coordinate  the five  basic elements using the
resources and personnel available.
   Given  all three of the essential  supports—legal  authority,  funding,
and an implementation plan  to carry out the  five basic elements—there
remains a requirement for perhaps the  most  essential ingredient for an
effective water quality control program: personnel.  The essential supports
are devised by men  of various disciplines, and  suitably trained person-
nel in adequate numbers are needed to carry  out the plan of implemen-
tation.  As surely as it is man and his endeavors which have affected
water  quality degradation, it is  likewise man  who  must deal through
his societal programs with this degradation by preventing  and controlling

                   Need  for Guidelines
   Though much  information and data  have  been  provided  to  State
legislatures and water pollution control agencies for  guidance in setting
up water quality control  legislation,  implementation plans, and funding,
there has been little  study of personnel requirements for effective  State
water  quality management programs.21  In January 1965, Jacobi, Pavia,
and Ricketts presented "Staffing and Budgetary Guidelines for State Water
Pollution Control Agencies." 22 The work for that report was  done by
Public  Administration Service,  Chicago, 111. on a  contract from  the
Division of Water Supply and Pollution Control, Public Health Service,
U.S. Department of Health, Education,  and  Welfare.  As such, it was
oriented  mainly  toward public  health  program  implementation  and
centered, in general, on service  per unit of population. Since that time
water  quality management has  broadened  its emphasis  from  a public
health orientation to involve other considerations noted but  not used in
the Public Administration Services study as foundations for criteria. For
example, implementation of  standards  for interstate  waters  to  enhance
water  quality and protect all legitimate uses  was not a requirement of
state water quality management  agencies  at the  time  of that  sudy. Also,
much  weight was placed in the study upon  needs to  eliminate untreated
discharges of sewage and industrial wastes. While this is still a considera-
tion for some States, the bulk of the State  agencies  are now concerned
with upgrading treatment of municipal  and industrial waste  to  meet
water  quality standards in the streams.23  Also, the number  and complexity
of water quality management considerations do not necessarily increase
in concert with population and industrial  growth. Guidelines  for estimat-
ing personnel requirements could be made more useful through inclusion
of consideration  of diverse environmental conditions.
  21 The reader  is directed to: U.S. Department of the  Interior, Federal Water
Pollution  Control Administration,  Guidelines  for  Establishing  Water Quality
Standards  for Interstate  Waters, Federal  Water Pollution  Control Administration,
May 1966; State Water  Pollution Control Act, Revised, supra; and U.S. Depart-
ment of the  Interior, Federal  Water Pollution Control Administration, The  Cost
of Clean Water, Washington,  D.C.: Government Printing Office,  1968.
  23 Journal Water Pollution Control Federation, supra.
  23 Digest of Fiscal Year 1969 State Program Plans, sec. 6.

                   Scope of the Study
  This study proposes the development of general guidelines for esti-
mating personnel requirements  for state water quality control agencies
based upon an examination of a typical program, that of the Texas Water
Quality Board, and the projection  of an idealized water quality control

               CONTROL   PROGRAM
   HE AUTHORITY to regulate water quality in Texas is vested in
the Texas Water Quality Board.  The Board was created by the legisla-
ture to administer the policy of the State on water quality, which is:
    to maintain the quality of the water of the state consistent with the public
    health and  enjoyment, the  propagation and  protection of terrestrial  and
    aquatic life, the operation of existing industries,  and the economic develop-
    ment of the State; to encourage and promote the development and use of
    regional  and area-wide waste collection, treatment, and disposal systems to
    serve the waste disposal needs of the citizens of the state;  and to  require
    the use of all reasonable methods to implement this policy.1
The program for carrying out this policy is developed  by the Board  and
its  staff.
   The relationship  between the program's  requirements  and the staff
needed to carry out the requirements can be understood by examining
the program which implements the State's water quality  control policy  and
the organization which is evolving to operate the program effectively.
   The Texas Water Quality Board was  created by  the  Texas Water
Quality Act of 1967.- This act was the culmination of legislative efforts
to protect the quality of Texas  waters  which extend back at least to
I860.3 Additional authority was given the  Board by amendments passed
during the 1969  session of the legislature.4

   The first water pollution prohibition appeared in the Penal Code as
the result  of  the  acts of 1860 and prohibited the depositing  of  dead
animals in Texas streams.5  This prohibition underwent evolution  and
modification  over the years and was repealed when  the  Texas Water
Pollution  Control Act was enacted  in 1961.6 The first civil statutes on
  1 Texas Legislative Service,  S.G. 147 (61st Legislature, Reg. sess., 1969), sec.
1.02. Also Article 7621-d-l, Vernon's Texas Civil Statutes.
  2 Texas, S.B. 204 (60th Legislature, Reg. sess.  1967).
  3 Texas, acts 1860, p. 97.
  * S.B. 147, supra.
  5 Texas, acts 1860.
  6 Texas, H.B. 24 (57th Legislature, Reg. sess., 1961), sec. 14.


water pollution were codified in 1913,7 and underwent modification  and
change until repealed by the  1961 act.
  Early water pollution control program activities in Texas were carried
out primarily by the State Health  Department,  but protection of  fish
and wildlife was the responsibility of the  Game and Fish Commission.
The program was markedly informal, since  the State was for the most
part rural with its population  spread thinly  about the State  area. Most
early  efforts were  concentrated  on regulating disposal of  municipal
sewage. The informality  permitted  considerable  latitude and  judgment
by the law's administrators.8
  As water pollution grew  as a problem,  the Texas  Railroad Com-
mission joined  the health and  fish and wildlife authorities, with respon-
sibility for control of pollution from oilfield wastes.9
  In  1953,  the legislature created the  Texas Water Pollution Advisory
Council, composed of representatives of the Attorney General, the State
Health Department, the Game and Fish Commission, the  Board of Water
Engineers, and the Railroad Commission and  provided for a  systematic
exchange  of views and  information  among  the key State agencies  al-
though it  had  no real statutory authority, funds,  or personnel as  does
the present  Board.10 The Water Quality Board has cited the Council's
actions  as the  beginning of  an effective program, with  two  significant
steps. First,  a  program was  undertaken to control  pollution resulting
from  disposal of oil field wastes, principally  brines. Second, a statewide
water sampling network was established in order that the quality of the
waters of  the State would be monitored regularly to detect water quality
degradation  in advance of  serious damage.  This  "Statewide Water
Quality Monitoring Program"  was a cooperative operation of the State
Health  Department and the   Texas Parks  and  Wildlife Departments,
i.e., game wardens  collected water samples at  strategic locations on the
streams throughout the State,  while the State Health  Department labora-
tory  analyzed  the  samples.11  As  with the other legislation  which  had
evolved for  the regulation of water pollution in Texas, the statute creat-
ing the Council was repealed  by the State Water Pollution Control  Act
in 1961.12
  The 1961 act authorized  a six-man Water  Pollution  Control Board
which was increased to seven by the 59th Legislature in an amendment
adding as a member  the chairman of the Texas Railroad Commission.
The Board,  under the 1961 act as amended in 1965, was closely aligned
with the State  Health Department by having the Director of  the Water
Pollution  Control  Division of that  Department  serving as  Executive
Secretary  to the Board.  The Board's technical,  scientific,  legal, and other
services were performed by personnel of other State agencies. The execu-

  7 Vernon's Annotated Revised Civil Statutes of the State of Texas (Kansas City,
Mo.: Vernon Law Book Company, 1969), art. 4444.
  8Texag  Water Quality Board,   Texas Water Quality, A Summary of Water
Pollution Control in the State of Texas, undated statement, p.  1.
  9 Ibid., p. 2.
  10Texas,  H.B. 448 (51st Legislature, Reg. sess., 1953).
  11 Texas Water Quality, op. cit., p. 2.
  "H-B. 24 (57th Legislature, 1961), sec. 14.


tive secretary was designated the administrator of water pollution control
activities for the  Board.13
   A new board  with independent water quality management  authority
and its own staff  was created by the Texas Water Quality Act of 1967.14
The  new  Board  also  consisted  of seven members:  three appointed by
the  Governor and  four from  interested State agencies, Railroad  Com-
mission, Parks and  Wildlife, Water Development and Health  (see fig. 2).
.The  Board's Executive Director,  an employee of the  Board,  serves as
chief administrative officer.
   The Texas  Water Quality Act of 1967 was the first general  Texas
statute dealing entirely with water  quality control; other statutes con-
cerning water  pollution control either concern local jurisdiction or deal
with regulation  of  specific  segments  of the economy, e.g., petroleum
production or protection of fish and  wildlife. The  1967  Texas act  set
out the State  policy with regard  to water quality control,  created the
Texas Water Quality Board, outlined a  system of water quality control,
provided for coordination of water  quality control programs of various
State  agencies and local  governments,  and  provided  a  basis for co-
ordinating water quality control  programs of  the State with  those of
the  National Government.
      Specifically,  the 1967 legislation delegated to the Board authority to:
   (1)  Administer the Act and  to establish and control the quality  of  the  waters
of the State;
   (2)  Regulate, through a permit  system, waste discharges  into or adjacent to the
waters in the State;
   (3)  Regulate,  through area-wide orders,  septic  tank use to prevent pollution
that may directly or  indirectly injure the public health.
Further,  the 1967  act imposed duties to:
   (1) Encourage voluntary cooperation by various groups in preserving the greatest
possible utility of the  waters in the State;
   (2)  Encourage the  formation and organization of  cooperative groups of users
of  waters in the State for the purpose of providing a medium to discuss and
formulate plans for the attainment  of water quality control;
   (3)  Establish  policies  and  procedures for securing close cooperation  among
State agencies concerned  with water quality;
   (4)  Cooperate with governments of the United States and other States;
   (5)  Conduct studies and research on water quality criteria or control  problems,
disposal systems, and  treatment systems  for various wastes.
   The 1967 Act granted  the Board and its  employees quasi-judicial
powers to hold hearings and take testimony, quasi-legislative powers to
make rules, and  authority to institute legal proceedings to compel com-
pliance with provisions of the legislation. In  carrying out  its duties  and
authorized function, the Board and its employees were  granted  the right
of entry  for investigating  conditions relating  to water  quality in the
State and to examine  records pertaining to these matters. Authority was
also granted to conduct investigations  as the  Board may deem  advisable
in  discharging  its duties,  make contracts  and  agreements  as  necessary
to the exercise of the Board's powers, and to perform  such other func-
tions as are necessary to carry on the Act.
   Court review of  Board  decisions was  provided for by this legislation.
   13 Ibid.,  sec. 3(g).
   14 Vernon's Annotated Texas Civil Statutes, op. cit., sec. 7621 d-1.


                         APPOINTED BY
                        PARKS 8
                                             TEXAS STATE
                                              OF HEALTH
                                               APPOINTED BY
                                            APPOINTED BY
                                                                                            COMMISSION OF
                              LIAISON WITH ALL STATE AGENCIES
         FIGURE  2.—Relationship  of the Water Quality Board to  Other State Agencies.
                                       Source: Texas Water Quality Board.

A requirement that all persons proposing to construct  or  alter a sewer
system or treatment system  file preliminary plans and  specifications  30
days prior to the start of construction was incorporated  in the legislation
as well. The Board was specifically granted power under  the 1967 act
to enter into agreements with Federal agencies and to accept funds from
the Federal Government to  aid in carrying  out  its program and duties,
but imposed various restrictions,  i.e.,  no grant  shall be made for any
project  unless  the project is approved by  the  Board  and unless it  is
included in  the State water  quality program.
   The 1967 law provided  a general  prohibition against  pollution,  set
forth the enforcement procedures  and penalties, the authority of local
governments, exceptions, notice procedure,  protection  of  common law
remedies, protection  of confidential  information, validation of previous
permits,  orders,  etc., repealed previous legislation, provided  for  sever-
ance of unconstitutional clauses, and set  the effective date  as  September
1, 1967. These latter portions of  the  1967 act  supported and clarified
the duties and  authorities of the Board and its employees.

Texas Water Quality Act, as Amended
   The legislature amended  the  Texas Water Quality  Act of 1967 in
1969 by the enactment of  a piece of legislation known  simply as the
Texas Water Quality  Act (TWQ  Act). This law amends, revises, and
rearranges  the  1967  act to  improve its structure and provide for  more
effective control  of water quality. The  most recent legislation is broken
into six sections  covering  the various  authorities  provided by the
   The 1969 Act designates  the Board as the principal authority  on  all
matters relating to water quality in Texas and responsible  for establish-
ing a statewide water quality sampling monitoring program.  The  1969
legislation provides for prompt action  when necessary  to  effectuate the
policy and purposes of the law by  authorizing the issuance  of  temporary
orders relative  to existing or impending waste discharges. The Board is
specifically empowered to approve  the construction or material alteration
of all sewer systems, treatment  facilities,  etc. other than those reviewed
by the State Health Department and the Water Rights Commission.
   The 1969 Act includes a  procedure  for the Board to define the  areas
in which regional or area-wide  waste collection,  treatment and disposal
systems should be used in place  of a multiplicity of small plants and
the Board  can designate the system or systems  to  serve the  area. The
Board is granted authority  to set  rates  which may  be charged to the
users of such a system.
   With regard  to accidental  discharges  and spills, the Board is given the
power to adopt rules or issue orders establishing safety and  preventive
measures  for  activities  which  are  potentially  capable of causing  or
resulting in  the spillage or accidental discharge of pollutional materials.
The new law changed the enforcement provisions so that  the discharge
of certain defined types of waste  is a  violation  unless  the discharge is
made pursuant to a permit,  rule, or order of the Board, irrespective of
  15Texas, S.B. 147 (61st Legislature, Reg. ses., 1969).


whether or not pollution results. In  this way, a permit will serve  as a
device  to  regulate and control  the  quality of the  discharges  to Texas
   In addition  to these authorities,  the legislature  in  1969  placed the
responsibility  for regulating  industrial  solid  waste  disposal under the
Solid Waste Disposal Act with the Board 16 and  transferred the function
of issuing subsurface waste disposal  permits under  the Injection  Well
Act  from  the  Water Development Board to the  Water Quality Board.17

Other Texas Statutes Affecting Water Quality Management

   While the Board  is under the Texas Water Quality  Act vested  with
the largest portion of water pollution control authority, there does  exist
a substantial body of State and Federal law authorizing others to perform
similar functions. The 1969 legislation  is a synopsis of the cooperating
agencies'  functions.   These duties  and authorities  are  extensions  of
powers previously granted  to the Water Well Drillers Board,  the Water
Development  Board, Railroad Commission, Parks and Wildlife Depart-
ment, State  Department of Health,  and local governments.18

   The other  statutes are:
   (1)  The Water Well Drillers Act  establishes a licensing  agency for persons
engaged in the  drilling of water wells  and grants pollution control authority with
respect to proper drilling and plugging of  this type well.19 The 1969 amendments
transferred authority for regulation of injection wells for disposal of wastes to
subsurface  stratum from  the  Water Development Board  to  the  Water Quality
   (2)  The duties and  responsibilities of  the Texas  Water  Development Board
as specified by  the TWQ  Act are:  "The Texas Water Development Board  shall
investigate  all matters  concerning the quality of ground  water in the state and
shall  report its findings and  recommendations to the  board." The Texas Water
Development  Board  is the  state's  chief  water  resource  planning agency. The
agency historically has been the  state's groundwater investigation agency and has
an extensive program  for  the  protection of  the quality of groundwaters and the
investigation of possible pollution of these waters.21
   (3)  The Railroad Commission is vested with authority  to control:
       (a)  pollution from wastes produced in connection with the production of
   • oil and gas;22
       (b)  pollution which is likely  to result from the  plugging of abandoned oil,
    gas, injection or  exploration  wells; ** and
       (c)  the  business of transporting salt water from  oil and  gas wells for
    disposal elsewhere.24
   (4)  The Parks  and  Wildlife Department  is charged with enforcement of the
TWQ Act insofar as any violation occurs which affects  fish and other aquatic life,
birds, and animals.25
  10Texas,  S.B. 125 (61st Legislature, Reg. ses., 1969).
  "Texas, S.B. 138  (61st Legislature, Reg.  sess.,  1969).
  18 Texas Water Quality, op. cit., p.  6.
  19 Vernon's Annotated Texas Civil Statutes, op. cit., art. 762le.
  20 Texas,  S.B. 138 (61st Legislature, Reg. Ses., 1969).
  21 Texas,  S.B. 147 (61st, 1969), sec. 1.07.
  22 Vernon's Annotated Texas Civil  Statutes, op. cit.,  arts.  60029 and 6005  (Oil
and Gas Wastes).
  23 Ibid.
  24 Ibid., art. 6029b.
  25 Vernon's Annotated Penal Code of the State of  Texas (Kansas City  Mo •
Vernon Law Book Co., 1952), art. 978f.


  (5) The State Health Department's  pollution control function is concerned
essentially  with protection of public  drinking water systems and sewage disposal
  (6) City governments are empowered to prohibit pollution of any stream which
may constitute a source of water supply and to provide protection of  a watershed
using the concept of nuisance abatement and prohibition.27
  (7) The General Land  Office  is vested with authority  to control pollution
resulting from all development  (oil and gas production) of  state owned (public)
  In addition, there  are other statutes granting various degrees  of  au-
thority  to control  water pollution  to  local  governmental  institutions
such as river basin authorities, cities, and  water districts. These together
with certain interstate compacts providing  for control of  pollution  of
interstate waters complete the array of authorities augmenting the Water
Quality Board's authority.

  The duties and authorities vested in the Water Quality Board  by  the
legislature have resulted in  a  broad-based  program  for control  of  the
quality of the waters of Texas consisting of six major  program elements:
Water Quality Standards, Permits,  Enforcement, Planning, Construction
Grants, and the Galveston  Bay  Study.

Water Quality Standards
   Until very recently, the  water quality  in Texas streams and coastal
waters  was  undefined. The program objective of the  water pollution
control agency was usually to prevent obvious pollution and to maintain
the streams in such condition  that pollution complaints were kept at a
minimum. Also the quality was kept adequate to serve the various water
supply functions that might  be made of the State's waters.
   In 1965,  during the course of  consideration of the water pollution
problem  in  the Houston Ship Channel  of Harris County,  the  Water
Pollution Control Board began defining quality standards for  the  waters
in  that area.  Following the enactment of the 1965 amendments  to  the
Federal Water Pollution  Control Act, the Board developed water quality
standards for all  Texas waters, both inter and  intrastate. The standards
and plan for their  implementation were adopted by  the Board in June
1967, and shortly thereafter  were approved  by  the  Secretary  of  the
Interior.  The standards are  not uniform throughout the State  but reflect
natural differences  occurring from  stream to stream and varying quality
requirements related  to water  use.
   The  Board  administers a program for  changing the standards as  re-
quired  by improved  technical  and economic evaluation techniques and
changing quality needs in  the various portions  of Texas waters. This
program  also provides for  monitoring the quality of the State's  waters
to  ascertain whether the standards  are being met and, if they are not,
determining the cause of the departure from the set  standards.29
  26 Vernon's Annotated Texas Civil Statutes, op. cit., art. 4477-1.
  27 Ibid., art.  1175(19).
  28 Ibid., arts.  5351  and 5366.
  28 Texas Water Quality, op.  cit., p. 9.


  As provided  in  the  TWQ Act, waste  discharges  into the  waters of
the State shall be made only in accordance with the terms and conditions
of a permit  issued by  the Board. At a minimum, each permit states:
(1)  The duration  of the  permit;  (2) the maximum quantity  of waste
which may be discharged thereunder at any time and from time to time;
and  (3) the quality,  purity, and character of waste  which may be  dis-
charged in keeping with the permit requirements. Three types of permits
are issued to regulate the  quantity  and quality of wastes  discharged
to State waters:
  (a) A "statutory permit" (commonly called a grandfather  clause permit) allows,
under the 1961 law, waste discharges in existence at that time to continue;
  (b) A "regular permit" is  issued by the Board for new  waste discharges; and
  (c) An "amended  permit"  is a statutory or regular  permit  which has been
altered at the  direction of the Board following the carrying  out of required quasi-
judicial procedures.
  The procedures to be followed in issuing permits require full investi-
gation  by  the  Board  and  its staff,  full  public  disclosure of  pertinent
information,  and notification of  interested  persons.  The procedures
provide for  the protection  of  those  subject to its  regulation by notice,
opportunity to be heard, and decision without bias. Independent review
of Board action is available in the  appropriate  courts.
  The Board requires  the  holding of a public  hearing on each permit
application  following notice to the  general public through newspapers
and  interested  persons through direct mail advice. Persons wishing to
support or deny the issuance of the  permit are  given an  opportunity to
be heard at  the hearing, which is  held as close  to  the area of  the State
where the waste discharge is to be made  as possible. Hearings are held
by a Hearing Examiner  for the Board  (usually an  attorney)  with the
assistance of technical and scientific personnel.  The examiner's report
is reviewed and evaluated by the Board's staff and, after acceptance by
the executive director of the Board, is considered by the Board. Majority
approval of  the Board  is required for issuance of  the permit.  Similarly,
majority opposition results in denial of a permit.  The primary considera-
tions in the Board's deliberations  are:  (1)  the information  obtained
at the public hearing;  (2) the technical staff's findings that in com-
pliance  with the Board's  requirements the pollution control  measures
proposed are, as far as is reasonable and  economical, the highest degree
that can be  obtained; and  (3) the Water Quality  Standards established
for the  State waters involved.30
  The permit program  element is closely allied with the water quality
standards and enforcement program elements. The procedures  and  staff
utilized in setting  standards are  a salient part  of the permit program
element. The water quality standards provide the  bases  for setting the
effluent quantity and  quality  requirements  contained in the waste dis-
charge permits.  The  water quality monitoring portion of the standards.
program element furnishes the data required to evaluate the effectiveness
   'Ibid., pp.  10 and 21.


of the permit program, as well as information  needed to allow for  suit-
able  revision of existing  permits.

   The enforcement program element  is concerened with gathering the
data  and  information  needed  to achieve  compliance  with  the water
quality standards and permits  and initiation  of suits against polluters,
i.e.,  those  discharging without  a  valid permit or in violation of a valid
permit. The TWQ Act  provides  that  the  Attorney General, at the di-
rection of the Board, institute and  conduct a suit for the State. In advance
of the Attorney General's formal action,  various  informal  and formal
actions would be undertaken by the Board and its staff.31
   Enforcement is based upon  an  inspection system, involving all permit
holders,  operated  to  assure that all significant waste  discharges  for
which permits have been issued will be inspected at appropriate intervals.
During the inspections, field analyses are performed and samples collected
for laboratory analysis to confirm the quality  of  the waste  water dis-
   When an inspection reveals that  a waste  discharge  is not  in  com-
pliance with  the governing permit,  the  permittee receives a letter in-
forming  him  of the  violation  and  requesting  remedal action.  This
letter does not specify a course of action. Should  the violation continue,
specific instructions for remedying the  violation  are provided through
the following steps:
   (1) Approximately  two months following the  initial  notice  of non-
compliance, a followup inspection is carried out, and additional samples
are  collected.
   (2) Should  the followup indicate  no  substantial improvement,  the
permittee  is notified that a detailed study will be  made  and  specific
recommendations submitted to the  permittee.  These recommendations
are provided to  the permittee in  both informal and formal  forms,  i.e.,
verbally  and in writing. Variations of this procedure are employed as
circumstances dictate.  However, in all instances, every conceivable  step
is taken to  secure voluntary compliance to  avoid institution of a suit by
the Attorney General.
   The Board  refers to a  policy  of "enforced  compliance" as denoting
all those activities necessary to bring about  compliance with water quality
standards  in  cases where  the  agency  is faced  with  recalcitrant or un-
cooperative attitudes on the part  of polluters.  For violations  originating
within the  State, the  Board (or other  agency having  authority)  can,
acting through the State  attorney general, initiate suit. In  general, a
public hearing, in advance of the suit, is held  in the area of  concern to
gather pertinent evidence  as to  the  causes and  effects  of  the  alleged
violation. Should the  facts warrant, the matter is then  referred  to  the
Attorney General's office with  sufficient  evidence to  support  a  suit.
Following  referral, the Board continues to gather data  and  to attempt
settlement  of the matter  through voluntary compliance.
    Ibid., p. 10.


   When  pollution originates outside of the State  and adversely affects
 the  quality of  State  waters, contact  is initiated  with  the appropriate
 agency in the  State  involved  to  undertake the action  which  may  be
 necessary to correct the difficulty through joint efforts.32
   In a broad sense,  the actions  taken following  the setting  of water
 standards, the issuance of permits, and the followup inspection  to assure
 compliance are all a  part of the enforcement  of the  TWQ Act.

   The  planning program of the  Board is  setup  to  evaluate  how the
 social and economic trends  in the State will affect the Board's adminis-
 tration of a comprehensive water quality management  program and  how,
 in  turn,  the  Board's programs, policies,  and decisions  will  influence
 the social and economic growth of the  State.  The Board's program is co-
 ordinated with  those of other State  agencies.  The  Board's  planning
 staff  provides it with pertinent information on land  use planning and
 economic considerations  so  that  the  Board will  be able  to  properly
 evaluate  the  total effect  of  its  decisions.  The  Board  is  represented on
 the 15  member Planning Agency Council  for Texas (PACT).  PACT
 is coordinated  from  the Governor's  office  and insures  (1)  that the
 results of planning  efforts by one State agency are  available  to other
 State agencies;  (2) that  the impact of the  plans  of  one  State  agency
 on  the plans  of another  State agency  are considered;  and  (3)  that the
 total  resources available  to the  State (universities,  colleges, foundations,
 Federal  Government,  and  industry)   are  applied to  State  planning
 for the solution of a  problem and that the  use of basic data  by State
 agencies involved in planning is uniform.33 The Board's  planning activi-
 ties, therefore, are conducted under the concept voiced  by the legisla-
 ture that  the  Governor  is the Chief  Planning Officer  and  that he  is
 authorized to appoint Interagency Planning Councils in certain func-
 tional areas  including natural  resources  and  health. An example of
 this concerns  area-wide  sewage disposal planning.
  The Texas  legislature,  at its Regular Session  in 1967,  appropriated
$2 million to  the Board  to be used for "planning and  feasibility studies,
by  contract,  of area-wide sewage treatment facilities." M As  a result,
an ad hoc committee, consisting of representatives  of the Office of the
Governor—Division of Planning Coordination, the  Texas State  Depart-
ment  of Health, and  the  Board, has under  preparation  an "overview"
of the State with respect to the  need for  area-wide sewage planning
funds. The committee deduced  that the  extent  of pollution problems
is related  to a significant  degree  to the population density of  the area.35
  It is the Board's responsibility to implement  and  administer the plan-
ning  grant and  loan program and to  this  end has setout  policies  and
procedures for the use of these funds in the Rules of the Texas Water
  32 Texas Water Quality Board, State Program Grant Application, Water Pollution
Control Program, FY  1970  [FWPCA-112 (Rev. 4-68)], pp. 25-27.
  33 Vernon's Annotated Texas Civil Statutes, op. cit., art. 4413  (32a).
  34 Texas, S.B. 15 (60th Legislature, Regular Sess., 1967).
  35 Texas Water Quality, op. cit., pp. 10-11.


 Quality Board.36 While the area-wide sewage disposal planning activities
 using the planning grant appropriations are  the keystone of the Board's
 planning  program, the Board's planning effort is not limited  to  admin-
 istration of that appropriation.
   River  basin planning, for the  most  part, is  carried  out by  river
 authorities  in  Texas. Several of the larger  authorities have  plans and
 most of the remainder are  in the  process of  devising and/or initiating
 plans. The Board through  its planning grants has funded or partially
 funded a large amount of planning in 8 of 14 basins.37
   All of the  long-range water  quality  management  planning  by the
 Board is  keyed to State and Federal research efforts having to do with
 Texas waters.  Constant attention is given to water quality management
 as the water resources of the State continue to be developed and used
 as the result of the  growth of municipal and  industrial water needs. A
 major effort toward  developing  area-wide  waste  disposal  systems for
 the State's metropolitan areas and river  basins is a large part of the water
 quality management  plan. From these planning outputs come  the neces-
 sary  information  to guide  the Board  in the issuance of permits  and
 orders to promote logical orderly development of  water quality  control
   In its  general  concept of planning  the Board recognized  the  broad
 impact of its  adoption and implementation  of water  quality  standards
 for the surface waters of the state and  that the effect of its decisions
 concerning  permits  for individual waste discharges is  broader than the
 prevention  of  stream pollution.  The planning program is  the result of
 this realization, together with the need  for inter agency  coordination  and
 administration  of  planning grants.38

 Construction Grants
  Under  section  8  of the  Federal Water  Pollution  Control Act,  as
 amended, the  Board administers  at the  state level  Federal grants for
 the construction of municipal sewage treatment works. Any municipality
 or similar public  body created by or pursuant to State law and  having
 jurisdiction over disposal of sewage, industrial wastes, or  other  wastes
is eligible for a grant.   The Board sets the priority of  this eligibility as
the requests for grants usually exceeds  the funds available. Applications
 for funds are rated  on the basis of financial need,  condition of existing
 facilities,  pollution aspects,  nuisances,  and readiness-to-go  factors.  This
 program  is carried   out  in  cooperation with  the  State Department of
Health, which  sets  the design  criteria  for sewerage facilities  under its
 public health  authorities and  reviews plans  and specifications for pro-
 posed works to assure compliance  with these criteria.  (In  addition, the
Texas Water Rights  Commission reviews and  approves sewage disposal
systems constructed by  certain water districts.) During the construction
of pollution control  facilities under  the Federal grant  program, inspec-

  38 Texas Water Quality Board, Rules of the Texas Water Quality Board,  adopted
 Nov. 28, 1967, pp. 46-55.
  37 State Program Grant Application, op. cit., p. 42.
  38 Ibid., pp. 51-52.


tions are made at  the 25, 50, 75,  and 100  percent  stages of comple-
   The TWQ Act authorizes grants  to supplement those of the Federal
Government. However, no funds have been appropriated by the legisla-
ture to implement this program element.40

Galveston Bay Study
   The Galveston Bay  Study is a major program being conducted under
the direction of the Board utilizing a wide variety of sources of finances
and services. As planned, it is  a 3-year, $3 million, multidisciplinary
effort to  determine  the optimum management  program for the Galveston
Bay system  waters. Expectations are  that the  managerial mechanism
derived  from the correlated  findings of the  study  may result in  the
creation  of a State agency patterned  after the River Development Boards
that have been successful in controlling water quality in  the rivers  of
Germany. The study is being carried out by  various State universities,
agencies  of the Federal Government, and consulting engineering  firms
under the management of a small Board staff  to coordinate the contracts
and inputs of the various agencies.41
  The staff -of the Texas Water Quality Board  is organized into five
divisions (see fig. 3) to carry out the program authorized and funded by the
legislature. Each  of these divisions is  headed by  a Director responsible
to the Executive Director, and the Deputy Director, who assumes the
duties of the Director in his absence. The five operating divisions  are:
Administrative Services, Field Operations, Central Operations, Hearings
and Enforcement, and the Galveston Bay Study.
  The Executive Director  and  his immediate staff direct and coordinate
the activities of the five divisions and perform other required functions,
such  as coordinating  the Board's activities  with those of other  agencies
or institutions  and reporting Board  activities. These functions  include
public information, legislative liaison, interagency  coordination, program
and plans development and analysis.
  Public  information  keeps the  public  informed of  agency program
activities, the effect these programs have on individual  members of the
public, and what can be done  to gain maximum  benefits from the pro-
grams. The information is as candid, nontechnical,  and timely as possible.
Similarly, this information in  slightly  more technical and detailed form
is available to the legislature.  Contacts with legislative committees are
extremely important in making known to the legislature information on
program progress, goals, and problems.
  Interagency coordination provides the vehicle for the Board to  interact
with  those State  agencies  affected by or having  responsibilities  in the
  39 Ibid., p. 34.
  40 Ibid., p. 33.
  41 Texas Water Quality, op. cit., pp. 13-14.


                                                                   WATER QUALITY
                                                                  DEPUTY  DIRECTOR
                  GALVESTON BAY
                     DIST.  I
 DIST. 4
  DIST. 8
 DIST. 9
DIST.  10
                                         FIGURE 3.—Organization of  Texas Water  Quality  Board.
                                                        Source: Texas Water Quality Board.

 management of water quality, e.g., the Water Development Board, Parks
 and Wildlife Department, Railroad Commission, and the State  Depart-
 ment  of  Health. The coordination is accomplished through  informal
 contacts by agency  staff  and by membership  on committees  such as
 PACT and the  water quality data  committee  chaired  by  the  Board's
 representative, the Executive Director.
   The analysis of on-going  programs  and their development along with
new undertakings resulting from legislative actions is also handled by the
 executive staff. This is a  continuing function for maximizing the value
 of objectives reached by the agency, considering the resources of man-
 power and  money available  to achieve those objectives. Based  on these
 evaluations,  changes  in  program  management can  be  recommended
 to the Board,  such  as alteration  of priorities or changes  in goals.  Pro-
 grams and plans are developed to meet projected needs.42
   The Executive Director  has  an  Administrative  Coordinator  to  aid
 in planning and  coordinating agency activities and programs and a staff
 assistant with  journalistic experience to carry on a  public  information
 Administrative  Services Division
   The Administrative Services  Division  has  five sections:  Personnel,
 Fiscal, Files and Reproduction,  Purchasing,  and Staff Services.  This
 division provides functions without which the  program  activities of the
 Board  staff would  be  severely  hampered.  Its clientele is the  other
 divisions.  Each section supplies a specialized service interrelated to the
 other  sections of the Administrative Services Division  and auxiliary
 to the operations of the other divisions.44
   The Personnel Section is responsible to  the Director of Administrative
 Services for carrying out personnel policies concerning recruiting and
keeping qualified personnel and for the Board's continuing staff  training
 and  career development program.
   A primary operation of  the Fiscal section concerns  budgeting,  the
 allotting of  funds to carry out the Board's functions. A  second  activity
of this section  is budgetary accounting, which is an  integral part of the
operating budget procedure. All disbursements made by the Board  are
conditioned on the Board's formal approval on recommendation from the
Executive Director  and certification from the  Fiscal Section as  to  the
 availability of funds  prior to  the commitment  of any funds. The account-
ing system  is  operated so that the  Executive  Director  can know  the
fiscal position of the agency at any time.45
   The Files and Reproduction Section maintains  the Board's  records
and  reproduces for  distribution the documents which are a  part of  co-
operation and  coordination  within the State government  and intergov-
ernmental organizations.
  42 Emory G.  Long, Administrative  Coordinator, Texas Water  Quality Board,
private interview, Jan. 21, 1970.
  43 State Program  Grant Application, op. cit., p. 52.
  "Emory G.  Long, Administrative  Coordinator, Texas Water  Quality Board,
private interview, Jan. 21, 1970.
  ^ State Program  Grant Application, op. cit., pp. 13-14.


  The Purchasing Section handles the procurement of goods and services
for the Board and its staff.
  The Staff Services Section is responsible for dispersing office supplies,
opening  and distributing incoming  mail,  collection and posting of out-
going mail, clerical and secretarial  assistance,  office services and mis-
cellaneous support  to  the agency  staff.  Originally, all  secretarial  and
clerical staff was assigned to this  section on pool basis.46

Field Operations Division
  The Field Operations Division is organized to carry out routine tech-
nical operations and  investigations  in  the field.  For  this purpose  the
State is  divided into  11 districts with  an office in  each  (as shown in
fig. 4). The primary function of this division is determination of  whether
the municipal and industrial permit holders are operating in  compliance
with  effluent  requirements contained  in their  permits granted by  the
Board. This  is accomplished  through a routine permit surveillance pro-
cedure. In addition, the  district personnel collect 15 quarterly and  145
monthly samples in the 109  zones of the inland  river  basins  and  64
monthly profile samples in the 51  coastal water zones.  These  samples
are collected and forwarded to the laboratory of the State Department
of Health for analysis in order to monitor the  State's inland  and coastal
waters with respect to  the standards set for water quality. Field personnel
conduct  routine investigations  to  discover pollution  discharges for  which
no  permit has  been issued; make inspections to determine qualifications
and needs  of  communities  applying for  grants  to construct  sewage
treatment facilities; instigate joint studies and surveys with other agencies
of  Government into  causes,  effects,  and  possible  remedies of  water
pollution; and  report their findings to  the Board.  The  Field  Support
Section at the Board's headquarters in Austin provides technical backup
for the field staff and augments  them  as needed  for  special situations
which arise with regularity. In effect, this is a "trouble shooting"  group.47

Central  Operations  Division
   The Central Operations Division has three sections: Technical Services,
Construction Grants, and Planning and  Research.
   The Technical Services Section  furnishes complete technical review
of the treatment schemes proposed  for  various waste-producing opera-
tions which  are submitted to the  Board for permit  approval,  permit
amendment,  or for other actions. This  section also develops the tech-
nical information required for evaluation of proposed  or  existing  waste
treatment facilities,  the expected effluent quality, and the  expected effect
on  receiving  waters.48
  The Construction Grants Section administers the program providing
federal funds granted  for construction of  municipal treatment facilities.
This section's staff processes applications for grants, determines priorities,

  w Emory G.  Long,  Administrative  Coordinator,  Texas Water Quality  Board,
private interview, Jan. 21,  1970.
  47 Ibid.
  48 Ibid.


                                            4   \     5
                                                    LA PORT

                              SAN ANTONIO    ft       \ 7



FIGURE 4. — Field  Operations of  the Texas Water  Quality  Board-
                     Districts and District Offices.

Source: Texas Water Quality Board.
makes onsite inspections at 25, 50, 75, and  100 percent completion to
ascertain construction progress  and assure that  all permit requirements
are being  carried out. Also, post-construction  inspections  insure  that
performance and maintenance  are  satisfactory  and  alert  the  district
office  personnel  that followup  is  needed  should operating  problems
be revealed.49
  The Planning  and  Research Section administers funds  appropriated
by the legislature for the  development of comprehensive water quality
control and pollution abatement programs as well  as  handling the  staff
work involved  in contracting for various research studies on the myriad
   1 Ibid.

of problems associated with water quality control. In developing recom-
mendations for the Board's use in awarding planning grants or research
contracts,  priorities are established according  to  guidelines  set by the
section's staff. Applications are evaluated according to these guidelines.
After  the  grant  is  awarded, this section  follows  the  progress  of the
planning activity or research project.
   In addition to the grants and contract activities, the  section provides
information and evaluation to the Board concerning planning and goals
for its water quality management program.50

Hearings  and Enforcement Division

   The  Hearings and Enforcement Division consists of the Hearings
Section and the Permits Section.
   The Hearings Section provides specific legal services for the scheduling
and conduct of public hearings required by the TWQ Act for the modi-
fication of water quality standards and  the granting or  modifications of
permits to discharge to State waters.  Further,  the  section obtains  legal
information and  technical data necessary to  make recommendations to
the Board regarding formal enforcement of Board orders.
   The Permits Section issues waste discharge  permits  following favor-
able Board action and gathers and reviews all  applicable data to insure
adequacy of application  content.  This  section  also  records all  permit
issuances and compiles statistical data  pertinent to waste discharges.51

Galveston Bay Study

   The Galveston  Bay  Study is a major effort  to  devise a program for
optimum management  of  the waters of the Galveston Bay System. As
such, it is an integral part of the overall water quality program of the
State.  As originally authorized the survey  portion  of the study was to
be completed by 1971. However, due to the way the  project funds were
made  available, it may be  necessary to extend the  study  beyond the
original completion date to accomplish the  goals set in the study plan.52

   The program of the Board is carried out by a staff having a currently
authorized strength of 135 positions as shown in Table 1. Approximately
half of the positions are professional with the remainder being technical
aides,  secretarial, or clerical.
   According to interviews with members of the Board's executive staff
and the budget analyst for the Legislative Budget Board who is familiar
with the Board's budget requests, the Board's staff is at a level which is be-
low that required to administer the act effectively. However, while neither
  50 Ibid.
  31 Ibid.
  53 Ibid.

agency has devised  parameters for determining adequacy,  the staff is
being developed on a phased basis.53
TABLE  1.—Positions Authorized for the Staff of Texas  Water Quality

ACTIVITY                                                    POSITIONS

     Executive Director  	   1
     Deputy Director 	   1
     Administrative Coordinator  	   1
     Staff Assistant	   1
     Secretarial 	   4
        Sub Total ...	    8
Administrative Services Division:
     Director  	   1
     Operating  Staff	  18
        Sub Total	  19
Field Operations Division:
     Director  	   1
     District Offices  Staff	  41
     Central Office Staff	  15
        Sub Total	  57
Central Operations Division:
     Director  	   1
     Operating  Staff	  25
        Sub Total	.	  26
Hearings and Enforcement Division:
     Director  	   1
     Operating  Staff	  20
        Sub Total	  21
Galveston Bay  Project:
     Director  	   1
     Staff  	   3
        Sub Total  	   4
        Total  	.	 135

  Source: Interview with Texas Water Quality Board personnel, Jan. 21, 1970.

   Current evaluation of staffing is based on three principal considerations:
   (1)  Availability of the various disciplines and skills  at  the current
State pay scales. Practically speaking, could the positions be filled with
qualified personnel if the funds  were  appropriated? There  has existed
over the years a scarcity of qualified water pollution control engineers,
technicians,  and specialists,  such as  chemists and aquatic  biologists
  53 Joe  Teller, Deputy Director, and Emory Long,  Administrative Coordinator,
Texas Water Quality Board, private  interviews, Oct.  1,  1969. Bill Wells, Budget
Analyst, Texas Legislative Budget Board,  private interview, Jan. 22, 1970.

willing to work at the pay scale established for State  agencies. In this
situation, the Board, knowing that the legislature is unwilling to appro-
priate funds which cannot be suitably expended, requests only the amount
which it  expects can be expended in the current technical skills market.
  (2) The geographic and  program  distribution  of  staff  within the
organization, whether in the central office or in the field. This distribution
of the  existing staff  and the  disciplines  represented  on it is compared
with the projected program needs. Staff assignments are correlated with
the current and expected workload at each location and in each program.
Current  opinion is that the Board is understaffed, but it  is not clear as
to how much.  Program goals are as yet  not clearly defined enough to
estimate  total requirements for central and field operations.
   (3) Recognition  that administrative and auxiliary operations are  func-
tions of  the size of  the technical staff. For  example,  jc  number of  engi-
neers requires  y  secretaries or clerks for support.  No  firm  parameters,
such as  amount  of  correspondence  or filing operations,  are used. As
with the availability of technical skills, administrative personnel require-
ments  are based primarily upon the judgment and experience  of  those
planning, budgeting, and evaluating the personnel needs.
   Requests for increases in auxiliary staff are evaluated  upon  expecta-
tions of  increase  in  workload, including possible reallocation or reorga-
nization  of existing  staff  to  handle the  expected  increase  in  activity.
This type of evaluation  is used for agencies which have existed  long
enough  to- be  considered fully  staffed to  meet the administrative re-
quirements of the laws under which they function. The  Water Quality
Board has not yet  reached  that point, as  the  legislature expanded  its
duties and responsibilities during both the  1967 and 1969  sessions.
   The Legislative Budget Board's budget examiner keeps in close contact
with the Board executive staff so as  to be sensitive to the agency's con-
ception  of  its  effectiveness  and  budgetary  problems,  often  offering
advice as to potentially useful techniques  and devices which have  been
used by  other  agencies within  the State or in other States  or govern-
mental institutions.54
   In summary, staffing requirements of the Texas Water  Quality Board
are determined through the  judgment  of  the Board's executive staff in
concert with that of the Legislative Budget Board considering mainly
availability  of  competent recruits  and  expected workload. However,
no  workload criteria have been  developed to date.



   HIS REPORT proposes guidelines for  the development of estimates
of personnel needs  of  State water  quality control  agencies using the
pollution  control legislation suggested by  the Federal  Water Pollution
Control Administration1  as the authority for  an "idealized  (model)

Idealized Water Quality Management Program

   The "ideal" water quality management program functions authorized
in the suggested legislation prompts the  derivation  of an organization
of general design to carry out  these functions. This  organization serves
as a framework for the  presentation of  guidelines  for  the  workload
projections employed to estimate the number  of personnel required for
effectively implementing the authorized  program. Thus,  in this report
the  base  for estimating the staff needed  for program implementation
is the suggested legislation.
   Several current trends in State  pollution control  legislation should
be noted. First, there has  been recognition of the relationship between
water quality control and  solid waste disposal,  with regulation  of both
based in the  same agency,  as in Texas.2 Further, regulation of all forms
of environmental pollution has been placed in one agency, i.e., control
of air and water pollution as well as solid waste disposal, as in Arkansas.3
While cognizance is  taken  of these apparent bellwether conditions, this
report is  limited to  consideration of personnel requirements  for  State
agencies concerned  only with  water quality control.
Ideal Program Authority
  The model authority  for the  "ideal" program  is the suggested act de-
veloped to aid in carrying out the requirement in section 4(a) of the Fed-
eral  Water Pollution Control Act, as amended, "to encourage the enact-
ment of improved and so far as practicable, uniform state laws.  * * *" 4
The  revised suggested  act  was  issued in 1966  to  include establishment
of water quality standards  throughout the United States and a "shifting
emphasis  from the mere abatement  of existing  pollution  to the policy
of preventing pollution  in  its incipiency." 5 The suggested act provides

  1 U.S., Department of the Interior, Federal Water Pollution Control Administra-
tion,  Suggested State Water Pollution Control Act, Revised,  (Washington, D.C.:
Federal Water  Pollution Control Administration, 1966), p. 10.
  2 Texas, S.B.  125 (61st Legislature, Reg. Sess., 1969),  sec.  2.(7).
  3 Arkansas Water and Air Pollution Control Act, Act 472 of 1949 as amended
by Act 183 of  1965, Arkansas Statutes sec. 81-1909  et seq. and sec. 19-2743.
  4 Federal Water Pollution Control Act, as amended, 33 U.S.C. 466 et seq.
  5 Suggested State Water Pollution Control Act, Revised, op.  cit., p. vm.


the base  for  a model  water quality  control  program.  This program
should be capable of responding to changes  in:  (a) pollution  control
technology, (b) water use and  subsequent waste production,  (c) popu-
lation and industry size and location, and (d) water quality requirements
to meet use shifts without requiring changes  in the  authority granted
the regulatory agency by the legislature.  Further, the  program under
this  Act  should be  capable of  responding to  trends  affecting water
quality with resulting changes in the number and skills of the personnel
required to carry out the program.
   Cognizance is taken of the budgeting and appropriations procedures
which describe  the limits  to  which programs  for water quality  control
can be implemented; however, it is  assumed that the  program for water
quality control authorized in  the  suggested act is of  key importance to
the health and welfare of  the State and, as such, enjoys the support of
the people  of the State  and  is  granted adequate appropriations  by the
legislature. The  suggested  act sets no limit as to quality  of the program
authorized; so it is assumed that protection of the State's  water resources
is of considerable importance, thus requiring a program to meet the policy
objectives  of the suggested act.   "
   In   general,  the  legislation authorizing the  program  of  the  Texas
Water Quality Board is congruent with  the suggested act  and the  "ideal"
program functions parallel those of the Board.

Ideal  Program Functions and Organization
   The ideal (or model)  program  and organization to carry  it out is for
study purposes.  Perhaps the program and organization to be discussed
and which will serve as the base for developing the personnel guidelines
should have been  designated  "suggested"  as was the act providing the
model authority. However, it is not necessary  for the purposes  of this
report to  suggest a program  and  organization,  only to devise them  as
a  step to  developing the  guidelines. The specification  of the  program
and organization as ideal  should  not be  interpreted  as representing it
as best, for there is no  general best program  and organization  for  all
state  water pollution control agencies.  The program  and organization
are nevertheless  presented as ideal in the sense of  being archetypal
ideal  (or  prototype)  for developing the personnel  requirements  guide-
lines  under the  authority  described in the suggested Act. The various
program elements and organization segments  described below  can  be
expected to exist in similar forms  in those states using the water  quality
standards-permit type system  for management of water quality, as in the
typical program.
   Under the suggested act the  comprehensive  program  plan serves  as
the basis for management of the various program functions and activities
such as planning, water quality standards, facilities construction, permits,
and  enforcement.  All activities  are dependent upon information and
data  describing water  quality  and  the  waste  discharges  affecting  it.
This information must be kept current  to  serve the planning and evalu-
ation  function which provides  a means for assigning priorities to activities
in terms  of immediate,  urgent, near future, and long-range needs  to


assure compliance with existing standards or permit conditions and/or
prevention of damages to water quality by the amendment of permits.
Thus,  the basic  continuing program  function  is  surveillance of  the
quality of the waters  of  the State and  the waste  discharges to them.
   The information and data gathered by the surveillance activity in the
field provide the bases for the planning, water quality standards, facilities
construction, permits, and enforcement program  activities.  Each of the
program  activities requires different types of information and  depth of
detail in the  information  and data. The use of these data by each of the
major program  activities  will illustrate the significant program functions
and how each is coordinated with the others  (as shown in Fig. 5).
   Planning is carried on as a continuing program activity  in two inter-
related areas: water quality control program for  the State's waters  and
the State's administration of that program.
   Under the model program,  the  State's comprehensive water quality
control program  plan is  assembled to meet present, near future (five
years),  and long  range (25 and  50 years) needs of the State and as
such  will use the data furnished by surveillance activities to  establish
base data and trends in  water quality, as in the typical program. The
plan, as developed, serves as the foundation of the budgeting and  ap-
propriations  process,  since each year's  needs would result  from evalua-
tion of progress in meeting the criteria set in the plan and  development
of conditions relating to them. The complexities of controlling  water
quality through the governmental  process  do not  permit  a piecemeal
operation based upon solutions to problems  after damage and  degrada-
tion.  Current practice recognizes the validity for prevention of  pollution
and,  thus, the  necessity  of the continuing planning function.  The  de-
velopment of the overall state plan for preserving  water  quality at  a
high  level to serve a wide'range of uses makes possible  the  develop-
ment of a plan  for the agency itself so that the required staff and leader-
ship will be available  when needed.
   The data obtained  from the  stream (and coastal waters) surveillance
activities can be evaluated to determine whether  progress is being made
toward meeting the  standards,  when a  water quality  improvement is
required, or whether  a degradation trend is developing requiring action
to prevent pollution  from  violating  the standards.  The economic  de-
velopment of the state as projected in the state plan may from time to
time  require modification of  standards.  Information from  surveillance
activities is needed to determine whether such a modification is feasible
and what its effect will be on water quality in downstream and upstream
locations. Information developed by the water quality standards program
activity provides  inputs  to  the planning, permits, and enforcement  ac-
   The review and evaluation of data obtained from surveillance activity
coupled with the water  quality standards and state plan  provides  the
basis  for  the  permit  function,  i.e.,  issuance, denial,  modification,  or
revocation.  Permit  program activities provide the foundations for  the
facilities construction activities.


FIGURE 5.—Program Activities of Idealized State Water Quality Control

   The facilities construction program activity also  utilizes data obtained
from surveillance of treatment plant construction and operation to pro-
vide information to the other program activities and administers the state
and federal grants to  municipalities for construction of water pollution
control works.
   A  significant  adjunct  activity to the facilities  construction program
element is  operator training.  The engineering works  for treatment  of
wastes will prove to be of little  value without suitably  trained personnel
to  operate  them.  Certification  of operators  is  a permit activity  for
regulating those who operate water pollution control works. The absence


of adequate  water pollution control  facilities  or operation of existing
works can result in formal enforcement action under  the suggested act.
   The results of surveillance activity are the bases for formal enforce-
ment action, when combined with inputs from permits,  water quality
standards, and facilities  construction.   The enforcement  activity  pre-
pares  the technical  and legal  instruments required for action by  the
Board in turning >a violation over to the Attorney  General.  Supporting
all of the functions authorized by the  suggested act  are  the  auxiliary
activities which  must  be provided  to  keep the administration of  the
program elements working smoothly.
   Over  all these program  segments is  the executive function stemming
from  the authority granted to the Board's  executive director.  This
activity  provides  coordination  and  direction of the  program  activities
within the Board's staff.  Further, this  activity  furnishes  the focus  for
interagency  coordination with  other  state agencies  and the agencies  of
other  states, agencies  of the federal government and  interstate institu-
tions, as well as providing information  to the legislature and  the public.
   Government agencies are organized on the basis  of  either  or both  of
two models. One is known  as the staff and line  model; the other is the
functional model.   However,  most  organizations  are a  composite  of
each rather  than pure types. A major  problem  is the relationships be-
tween the functional headquarters and the individuals carrying out the
program in  the field.6  There is, as with the idealized  program, no one
best organization,  only those that perform effectively. As  illustrated  in
Fig. 5, all program functions are equally important and interrelated, re-
quiring full-time coordination by the  executive. For purposes  of descrip-
tion in this report in estimating staffing  requirements, the idealized  orga-
nization will be  divided into five segments:

     Headquarters Program
     Field Program
     Legal Counsel
   Figure 6  illustrates  the idealized organization.

   The purpose of the guidelines developed in this report is to provide
 a tool for estimating the workload  of  an effectively administered State
 water quality management program much  in the manner  of Taylor's
 "Scientific Management." 7 However, these guidelines are not considered

   6 John M. Pfiffner and Robert V. Presthus, Public Administration,  4th ed. (New
 York:  The Ronald Press,  1960), p. 249.                         ,»*!.„
   Frederick  W. Taylor, Scientific Management  (New York: Harper & Brothers
 Publishers,  1947), passim.


 to be useful for setting work rates. Conversely, the work rates  determine
 the program workload and the number of personnel.
   A study by the Public Administration Service,8 based upon data avail-
 able  for all of the  50 States, developed guidelines based on  two types
 of staffing needs: general and facility  service. Facility service staff are
 those personnel involved  primarily in  surveillance  of  existing  water
\ , 	
\ 1

                                           /      /
FIGURE 6.—Idealized Organization State Water Quality Control Agency.

pollution control facilities,  including the training  and licensing of treat-
ment plant operators.  Facility service staff requirements  criteria  were
based upon absolute ratios of staff to number of treatment plants  and
water-using industries. The general  staff needs included those personnel
not included in facility service and  were determined  on a relative scale.
State population,  area,  recreational use of water, and industrial work
force, coupled with jnterviews with the water pollution control program
administrators of  13 States were used  to derive  estimates of minimum
and desirable general staff  needs. That report indicated that staffing for
special  problems,  such as acid mine drainage  and oil-field  brine pollu-
tion, would require additional staff.9
   Table 2 compares the staffing for State water  pollution control agen-
cies recommended in 1964 by Public Administration Service with the
number of man-years assigned to water quality management by the same
State agencies during fiscal year 1969.
Criteria for Guidelines
  The guidelines  to  be used  in  estimating personnel needs  are based
upon the primary function  authorized  by the  suggested act, i.e., regula-

   8 Thomas R. Jacobi, Richard  A.  Pavia,  and  E. F. Ricketts,  "Staffing  and
Budgetary Guidelines for State Water  Pollution Control  Agencies," Journal Water
Pollution Control Federation, Vol. 37, No. 1 (January  1965).
  'Ibid., p. 13.

TABLE 2.—Comparison of Public Administration Service Recommenda-
           tions and Fiscal Year  1969 Man Years Assigned to  State
           Water Pollution Control Agencies.
Colo. _._
Del. „ 	
Ind. _.._

— 33
_. 15
_.. 180
-- 32
— 46
.— 20
..._ 58
._.. 43
..._ 12
.._ 21
..... 133
._.. 61
~~ 41
.__ 32
__ 26
__ 38
__ 110
__ 26

FY 1969
Nev. ...
N.H. ..
W Va
•• j '
- - £*{*


FY 1969
   1 Minimum.    2 Desirable.

   Sources: Minimum  and Desirable from Thomas R. Jacobi,  Richard A. Pavia,
 and E. F.  Ricketts,  "Staffing and Budgetary Guidelines for State Water Pollution
 Control Agencies,"  Journal Water Pollution Control  Federation, Vol. 37, No.  1
 (January 1965), p.  20. State and Interstate Programs for Water Pollution Control,
 Digest of Fiscal Year  1969 State Program Plans (Washington, D.C.: U.S. Depart-
 ment of the  Interior,  Federal Water Pollution Control Administration, State  and
 Regional Program Grants Branch, 1969),  Sec. 2.

 tion of water quality,  and should  reflect changes in workload resulting
 from variations of water quality requirements, improvement in the tech-
 nology of water quality control,  and shifts in population and  water uses
 affecting water quality. Alterations of these factors and/or the agency
 function will result in increases  or decreases  in  staffing needs. The
 guidelines should be sensitive to these changes. Likewise, as for the guide-
 lines developed by Public Administration Service, "they must be relatively


simple if only because  there  still are no foundations for a technically
refined 'scientific' approach in detail."10
   Since  all of the States  have adopted  water quality  standards  and all
but six require discharge permits,31 guidelines based upon a water quality
standards-permit type regulatory model  administration are presented in
this report. Further,  the guidelines  are applicable only to activities  con-
tained in the program as planned under the authority in the  suggested
act. Contingency planning for disasters,  either natural or manmade, are
not within the purview of this report although it is recognized that  staff
will be diverted to such highly necessary activities from time to time.
Only  state agencies of small proportions with respect to the  manpower
required to cope with the disaster are expected to be severely affected by
such situations. However,  even these, if adequately  staffed, would possess
the necessary degree of flexibility to handle  emergencies without serious
disruption of  routine operations.
   In  keeping  with the  policy  set out in the suggested act to prevent
pollution,  surveillance of stream  quality and  waste  discharges is  the
fundamental activity of an idealized water quality  control agency.  Sur-
veillance activity  workload  can be  estimated by determining  the num-
ber of discharges requiring  inspection, the frequency  of inspection, the
number  and type of water quality monitoring stations and the  frequency
of sample collection. As various program activities  affect or are affected
by the surveillance function (see Fig. 5),  the  other program activities can
be estimated as a function  of the surveillance workload.

Unit  of  Measure:  Man-Year
   The unit  of measure for estimating staff  requirements in this report
is the man-year,  which has  available no more  than  1,840  man-hours,
46 (40-hour)  man-weeks, or 230 8-hour man-days. This unit was deter-
mined on the basis  of  a 2,040 man-hour  (52  40-hour man-weeks or
260 8-hour man-days)  year and the average employee having: 10  days
of annual leave (80 hours); 10 days  of holidays  (80 hours), although
most States have more official holidays;  5 days of  annual sick  leave (40
hours);  and 5 days of  annual training (40 hours)  either on the job
or at suitable institutions.  Few employees will follow this outline exactly,
but it is  an indication of the considerations involved in estimating staffing
needs. Adjustments can be easily made in this estimate to provide a more
realistic  appraisal  of available working time per person.

Program Operations—Field
   Program  operations  in the field  consist essentially of:
   (1) Inspections of municipal and industrial waste  treatment plants to assure
compliance with discharge permit conditions;
   (2)  Inspections of construction  of  water pollution control works to assure
compliance with permit conditions  and  expected  completion schedule;

  10 Ibid.
  11 State and Interstate Programs for Water Pollution Control, Digest of Fiscal
Year  1969 State Program Plans (Washington, D.C.: U.S., Department of the
Interior,  Federal Water Pollution  Control  Administration,  State  and Regional
Program  Grants Branch,  1969), Sections  5  and 6.


  (3) Monitoring of quality of the waters of the State;
  (4) Participation in conferences and hearings on water quality standards and/or
issuance, modification, or enforcement of waste discharge permits; and
  (5) Preparation of reports concerning the above activities.

  The  inspections activities  workload  can be estimated  on the basis
of the number of locations to be inspected, the average  frequency of
inspection, and  the average time  required per inspection.  The number
of locations  to be used in the estimate are a function of the agency's
policy on regulating  discharges.  For  example,  many industries have
multiple outlets,  each with its own  treatment system  and  all operating
under a single permit from the agency. The same is true of many munici-
palities. In general, each treatment works  or system  rather than each
permit  holder should  be considered a location for  estimating purposes.
   Frequency of  inspection can  be discussed  in  terms  of complexity of
treatment (secondary  or tertiary), amount of waste handled (in million
gallons daily), complexity of waste treated,  downstream uses, etc.  All
have merit  as considerations while not  providing  a basic measure of
workload. To date, inspection programs of State  pollution  control agen-
cies have been handled on the basis of devoting resources to inspections
not needed  for report compilation,  special technical studies,  and other
"crash  projects."  The result has been that,  while the agency insisted on
construction of treatment works, no surveillance program is provided to
assure  that works are being operated effectively at all times.12
   Frequency of  inspection, on the whole, can serve the purposes of the
pollution control program by being setup proportional to  the  uses  pro-
tected  and the potential for water quality degradation. Quality degrada-
 tion, in turn, can be described as  a function of concentration of industry
 and  population as  measured  by urbanization, i.e.,  the more highly ur-
 banized, the more frequent the inspection should be to assure compliance.
 This inspection program  would be analogous  to  that carried  on by the
 Department of Agriculture  in the meatpacking industry or the Depart-
 ment of Defense among its  contractors, where   the packers or  con-
 tractors are  under surveillance in proportion to their size or significance.
   For  estimating  purposes, Figure  7 displays the  relationship between
 per cent urbanization as defined by  the Bureau of the  Census  and aver-
 age annual frequency of inspection. Not all discharges  need be inspected
this often while others need more frequent and detailed inspections. Also,
 the inspection program goals of  the various  state  agencies are plotted
 against 1960 percent urbanization in this  figure. Frequency of inspec-
 tion goals are, in general, arbitrary  under existing conditions, as staff is
 seldom available to meet them.
   The average number of  inspections needed per discharge are deter-
 mined  from figure 7.  The  manpower  needs  for  this activity  can be
 estimated by multiplying by  the average time  required  per inspection
 and  the number  of locations requiring surveillance by the average fre-
 quency of inspections, i.e., Mf = (I)(T)(L), where
    'Ibid., sec. 8.


      Mf= Manhours/year, field
        I = Inspections/year (Figure 7)
       T= Average manhours per operation
       L= Number of locations.
  In general;  the construction inspections workload can  be estimated
on  the basis of  expected activity in issuing permits  to municipalities
and industries  and grants  for construction  to  municipalities. As  with
plant operation surveillance, inspections planned multiplied by the aver-







                                                      2 2
                                            o  o   oo   o o     o
                          30    40     50    60
                             PERCENT URBANIZATION
        o Reported Inspections /Year  v. Percent Urbanization (for each state)
FIGURE 7.—Relationship  of Inspection Frequency to  Percent Urbaniza-

  Source:  Percent urbanization—U.S.  Department of Commerce, Bureau of the
Census, 1960;  inspections - State  and Interstate Programs  for  Water Pollution
Control, Digest of Fiscal Year 1969 State Program Plans (Washington, D.C.:  U.S.,
Department of the Interior, Federal Water Pollution Control  Administration,  State
and Regional Program Grants Branch, 1969), sec. 8.

age time required for each will determine the workload for this activity,
i.e., M'f  = (P) (T) (L), where P =  number of inspections of plant con-
  The protocol in carrying out each inspection is important. The indus-
trial plant manager (or responsible  municipal official)  is usually  con-
tacted prior to actually entering the plant for the construction or opera-
tions inspection.  This  brings  the  gravity  of  the  need  for  compliance
to the attention of a responsible official. The construction superintendent
or plant operator is then interviewed to  determine the current status of
construction  or  operation. A  tour  of  the plant  ensues  to  verify the
information shown in  construction or operations  reports. Samples are
collected and  analyzed for further  verification of operating results.  Usu-
ally  a summary report  of the inspection is prepared for the record. This
may be as simple as filling in of blanks on a form, or it may be more
   Inspection  time can be  diverted to unscheduled investigations  of
fish-kills, unauthorized discharges,  etc.,  as  these  activities properly
are a part of  the surveillance  function.
   Like inspection activities, stream  sampling is another field operation
which can be  planned and its manpower requirements estimated.  Most
states have established the water quality monitoring  station locations
required to implement their  standards  program. In  general, there are
two classes of monitoring:  (1) small  streams  and  (2)  large streams
and  coastal  waters.  Different sampling  techniques  are used  in  each
class. Samples of small streams are easily obtained, whereas large streams
and coastal waters usually must be "sectioned," using boats and special
sampling equipment.13 As with  inspections, estimates  can be  based
on number of locations,  frequency  and manpower per  sample run (in
man hours), i.e.,  M"« = (S)(T)(L) + (S')(T)(L), where
        S= Samples  collected/year from small streams
       S' = Samples collected/year from  larger streams and coastal waters
   In general, participation in conferences and hearings can be estimated
on the basis of anticipated activity.  The field personnel have a feel for
what is  developing as  the result of contacts during inspections and ob-
servations, much as a  salesman "knows the territory," and can provide
a base for estimation M'"*  = (C)(T), where
       C = number of  conferences/year.
   Preparation of reports  on  program  field  activities workload can be
estimated as a function of the workload required by those  activities, i.e.,
Mtr  =  k (Mf + M/ +  Mf" +  Mf'"). In this equation, k represents
the  ratio between the man-hours required for report preparation and the
man-hours expended in the various field activities.

Other Field Activities
   The field personnel  estimates should also include  manpower required
by special problems,   such as acid-mine drainage, oil-field brine, feed
   13 Emory Long,  Administrative Coordinator and Joe  Teller, Deputy Director,
 Texas Water Quality Board, interviews on Oct. 1,  1969 and Jan. 21, 1970.

lot run-off, or irrigation return flows, the control of which is a significant
part of the field  operations. However,  each requires  special estimates
which  would follow the pattern  set in the general  operations estimating
procedure outlined above, i.e., number of operations per year,  time per
operation, and number of locations.
  In general,  a  ratio of  clerical-stenographic  personnel  to  technical
personnel should be  established for  field operations.  This ratio  may
range from  1:3  to 1:7 depending  upon  the amount and detail of cor-
respondence to be handled  in the field.14

Program Operations—Headquarters
  Program  operations at agency headquarters  consist of:
  (1) Technical support including data evaluation,  specialized services, and lab-
oratory services;
  (2) Construction grants activities;
  (3) Enforcement (including hearings); and
  (4) Planning.
The headquarters technical support  activity  serves  not only  the  field
by handling contacts and correspendence with  industries and municipal-
ities concerning  compliance but provides technical  service to  other
headquarters  elements,  such  as construction  grants  and  enforcement
activities. This activity evaluates the  data gathered by the surveillance
operation in  the field and assesses  the  need for  actions  to  achieve
compliance  with water quality standards and  permits.
  Operator certification  and  training  is  a necessary  adjunct  to this
activity,  being directly related  to treatment plant operation. Many states
water quality management  agencies require that those operating munici-
pal  and industrial waste treatment works be certified as a  device  to
assure operating  proficiency.
  Operator training  should be  included as a program activity in the
State water quality management agency.  Often  this activity is carried
out  by other  groups, agencies or institutions, such  as the State water
pollution control association,  State  education agency,  or  colleges and
universities. The  operator  training program,  while taking  a variety  of
forms, should be coordinated  with the  certification activity  to assure
communities and industries that  an adequate number  of suitably quali-
fied operators are available and that  those working operating personnel
have an  opportunity to keep abreast of new development and techniques
in water quality management.
  The  number of technical support  personnel  required  should be  a
function of the activity in  the field,  together  with the activity  level in
enforcement operations, i.e., MQ  = k'  (M*t) + k" (Me), where
     Ma=manhours/year,  headquarters
     Mft = manhours total field activities
   k', k" = constants and
     Me = manhours/ year,  enforcement.
  The manpower needed to staff the agency laboratory is  a function of

  "Data  obtained  on staffing  of Texas Water Quality  program during interviews
with Emory Long and Joe Teller, Oct. 1,  1969 and  Jan.  21, 1970.


the number of samples to be  analyzed, the detail of analysis  required,
and the average time required per sample analysis, i.e., Mi =  (S) (T) +
(S')(T) + (S'")(T), where S'" =  number of samples collected/year
from  water pollution control plants during inspections.  Automation has
had a significant impact on laboratory operations so that a high volume of
work is required to operate efficiently. Agencies having less than the criti-
cal amount of work needed to operate a laboratory efficiently usually con-
tract for their laboratory work, as is done in Texas. State health agencies
usually have developed  an efficient laboratory program which can ac-
commodate the water quality  agency's load  until it has the workload
required to operate its own laboratory.
   The staff required to operate the construction grants activity is a func-
tion of the number  of  grants  applications processed and  the average
time spent per application, i.e., Mg =  (N)(T), where N =  number of
   The enforcement activities staff in  headquarters can  be estimated on
the basis  of the expected number of hearings, compliance and enforce-
ment  actions  relating to water quality  standards, and  permits and the
average input required for completion  of these actions,  i.e., Mo =  (A)
(T), where A =  actions/year.
   The amount of  field activity is a suitable  guide to workload for the
planning  activity on the basis that planning will be affected by the find-
ings of these activities, i.e., MP = K (M*t).
   Headquarters program operations are concerned mainly with prepar-
ing correspondence and reports. Therefore,  the ratio of clerical-steno-
graphic personnel to  technical-professional  personnel can be based  upon
workload but should not exceed 1:4.15

   The staff required to perform the  executive functions can  be  based
upon  the complexities of the activities involved, such as interagency co-
ordination, activities planning,  public  information, legal  counsel, legis-
lative liaison, and  special projects. Estimates of the workload  for inter-
agency coordination can be founded upon the number of agencies having
interrelated activities  with  the water  quality control  agency.  As with
the surveillance portion of the  agency  operations these contacts  are  more
often than not relegated to being done  "hit or miss"  or more often when
a crisis arises resulting in the lost motion of reestablishing rapport with
the coordinating agency. Therefore, time should be planned to  carry out
this function, i.e.  a set  program of interaction varied according to the
scope of  the interrelationship.  The workload  can be estimated  as MX =
 (n)(T)(B)  where
        n = number of contacts per year
       B = number of agencies to be contacted.
   Activities  planning, public information,  legal counsel,  and legislative
liaison are functions needed to carry  out an effective program of water
quality management  though  no  bases for  estimating  the  workload

   15 Ibid.


have been derived. Of the three, public information comes closest to being
estimated on the basis of activity  in the field  and rapidity of program
change, with needs  being proportional  to  enforcement and  compliance
activities tempered by the change factor. The frequency of Board meet-
ings also influences the public information  function.

Auxiliary Operations
   In  general, the function of auxiliary operations,  which include  the
personnel,  fiscal,  purchasing,  filing  and reproduction, automatic data
processing, and other service activities designated as staff  services in  the
typical agency, are related to all the activities of the  agency and should
be estimated on the basis of total  agency program. Much consideration
must  be given to the experiences and  staffing of  other  state  agencies
(such as Highway Department, Health Department,  etc.) regarding these
functions.16  Often, since these functions  are common to all agencies,
standard practices are  adopted which can be used to guide the personnel
needs estimate, particularly those concerned  with personnel,  fiscal, and
purchasing activities. Based upon these  practices, a proportionality can
be  determined between agency  activities  expressed  in man-years and
auxiliary services, i.e., M* = K'  (Mft  + MUt).
   One  auxiliary  service  runs  counter to  the proportionality expressed
above. Automatic data processing  (ADP)  can be  used to increase  the
agency's productivity by  handling  routine tabulation  and computations.
Increases in ADP personnel may be required hi the absence of an  in-
crease (and perhaps a decrease)  in the number  of personnel in the other
agency  activities.

Program Coordination
   The idealized  program and organization are schematic only and  do
not provide  specifically for program coordination through  other than
the program planning function in the Executive. Day-to-day coordination
is recognized as necessary for effective program operations. An  estimate
of staffing needs  therefore must include  the supervisory staff  required to
accomplish this function. Just as there is no one best organization there
is likewise no one best way  of  estimating staff needs  for program  co-
ordination;  however,  a  coordinator  (supervisor)  is  needed for  each
operating unit, such-as field offices, divisions and sections in headquar-
ters, et cetera.

Occupational  Distribution
   In  a manner similar to the Public Administration Service report, it is
desirable to touch upon the aspect of staffing needs concerned with  the
major occupational categories. That report weighed  heavily the judgment
of the administrators of the 13  States visited during the  course of that
survey. It was found that practice and judgments varied considerably. The
findings  of  that  study concerning occupational  distribution  were that,
in general, the States with the smallest  staffs have  the highest ratios of

   10 Bill Wells, Budget Analyst, Texas Legislative Budget Board, private  interview,
Jan. 22, 1970.


professional to nonprofessional personnel.17 As shown in  Table 2, few
of the States  have been able to meet  even the minimum  levels recom-
mended  in the Public Administration Service report. With the  expecta-
tion that staffing will not be provided at minimum levels any more than
water  quality will  be managed to meet minimum  standards, it "seems
highly probable that as such staffing objectives are approached increased
opportunities  will be  available for more extensive use of support person-
nel (nonprofessionals including clerical employees, inspectors, engineer-
ing aides and technicians,  and laboratory assistants)." 18  Based on the
staffing  of the typical water quality control  agency,  approximately  50
percent  of  the total  may  be  nonprofessional  in  the model program
founded  upon regulation of quality through surveillance.15*
Example of Use of Guidelines
   In order to test the suitability  of the  broad guidelines presented, the
idealized program  and organization are  combined with program opera-
tions  of the  typical  program of  the  Texas  Water  Quality Board
(TWQB). The TWQB program plan for fiscal year 1970 indicates the
information pertinent to estimating staffing needs as shown in Table  3.
Using these data and the guidelines, Table 4  illustrates the staffing needs
for the  idealized program.
   The  example does not  consider  staffing  requirements  for special
projects, such as the Galveston Bay Study, nor special problems requiring
continuing  operations  or project type research or  technical assistance.
These latter would concern control of acid-mine drainage,  oil-field brine,
feed lot run-off, wastes  from water craft, oil and  hazardous materials
 spills, etc.  Staff for  administration of  these  functions is  authorized  in
the suggested act,  but the  workload for program elements  of this  type
 should  be  estimated  separately and  added  to the staff  needs  for the
 basic  water  quality  standards-permit  type regulatory program.
   17 Journal Water Pollution Control Federation, op. cit., p. 20.
   18 Ibid., p. 21.
   19 Data obtained on staffing of Texas Water Quality Board program during inter-
views with Emory Long, Jan.  21, 1970.

      TABLE  3.—Texas Water Quality  Board  1970 Workload.
     Number  of field offices 	      H
     Discharges to be inspected	  2,200
     Construction  sites to be inspected	    300
Water Quality Monitoring
      Total-stations 	    224
         Stream  	    160
           Quarterly	      15
           Monthly 	    145
         Coastal waters	      64
           Quarterly	      64
Hearings and  Compliance
     Actions on permits and standards  	    400
     Conferences  	    300
Interagency Coordination
     State  agencies 	      5
     Interstate agencies  	      3
     Federal agencies 	      5

  Source: Texas Water Quality Board, State Program Grant Application,  Water
Pollution Control Program, Fiscal Year 1970  [FWPCA—112 (Rev. 4-68)], passim.

TABLE 4. — Estimates  of Personnel Requirements for the Texas  Water
           Quality Board Using Guidelines,

                                                   MAN-      MAN-
Program operations — field:                          HOURS      YEARS
     Mt    =  (I*)(T)(L) = (4)(8)(2200) = ___________  70,400      38.3
     Mf'   =  (P)(T)(L) =  (4)(8)(300) =  ____________   9,600       5.2
       (4)(16)(64)  = ______________________________________________   7,696       4.2
     M*'"  =  (C)(T) = (300)(8) __________________________   2,400       1.3
                                                  90,096      49.0
     M.r  =  k (Mf + M/ + /' M/")
        =  0.25 (90,096) = ____________________________________  22,500      12.3
     Supervision (11  offices)  ________________________________  20,200      11
       Field  subtotal (M«) __________________________________ 132,796      72
     Clerical-stenographic, 1:5 ___________________________________________________  14
     Field total ____________________________________________________________________________  86
 Program operations — headquarters:
     Ma = k' (M*t) + k" (M*)  = 0.75 (72)
        +  0.5 (12) __________________________________________________ 110,400      60.0
     Mg = (N)(T)  =  (300)(24) ____________________________   7,200       3.9
     Me = (A)(T)  =  (400)(56) __________________________  22,400      12.2
     MP = K (M«) = 0.1  (72) ____________________________  13,300       7.2
                                                 153,300      83.3
     Supervision _______________________________________________________  18,400      10
     Headquarters  Subtotal  (Mht) __________________________ 171,700      83
     Clerical-Stenographic 1:4 ----------------------------------------------------  20
     Headquarters  Total ____________________ ..... ------------------------------------- 103
     Director, Deputy Director, activities
        planning, public information, etc. ----------------------------------------   3
      Interagency Coordination MX = (h)(T)(B) =
        (12)(8)(18)  __________________________________________________  .  1,728       0.9
     Executive  ____________________________________________________________________________   ^
      Clerical-Stenographic 1 : 1 ----------------------------------------------------   4
        Executive total __________________________________________________________________    °
 Auxiliary Operations:
      Ma  =  Kr(M" + Mht)  - 0.2 (72 + 83) = ------------------------   31
     Agency total — 86+103 + 8 +  31 ...                      228
   * Based on 75 percent urbanization.

   The  guidelines presented in this report  can (and should) be  altered
 to  reflect changes in program  function and supporting technology.  For
 example, the trend line in Figure 7 should  be  shifted when data become
 available  on the impact of an effective surveillance  program  on plant
 operations. A study  correlating number and quality of plant inspections
 with operating efficiency  would  greatly aid in  better setting the slope
 and location of the  trend  line. Also, the user of the  guidelines  should
 be  aware that  the various constants (k and K) were estimated for the
 typical  agency in the example  and will vary from agency to agency.
 However, those used  in the example  provide a suitable "point  of de-
 parture" for use in  estimating program staffing needs. Likewise,  the
 time factor (T)  for  each  program activity must be  derived from pro-
 gram experience, as  travel  and other conditions affecting  this factor vary
 widely. In summary, the guidelines in this report provide a framework
 for estimating personnel  needs  for  state  water quality management
 agencies to be  tempered in use with judgment and experience.
   PPRECIATION  is expressed to  Dr.  Emmette S.  Redford, Ashbell
Smith Professor of Government, The  University of  Texas at Austin,
for the  opportunity to develop this  report under his guidance and to
Lynn F. Anderson, Director, Institute of Public  Affairs, for his advice,
comments,  and confidence regarding this report.
  For their very good help  in furnishing the information and data re-
garding  the operations of the Texas Water Quality Board, the  author
is  most grateful to  Hugh Yantis,  Executive Director of the Board,
Joe  Teller,  Deputy  Director, and  Emory  Long, Administrative Co-
ordinator of the Board's  staff. Likewise,  the comments and suggestions
of Bill Wells of the Texas Legislative Budget Board were most helpful.
The  encouragement and comments of Kenton Kirkpatrick of the Dallas
Regional Office of the Federal Water Pollution Control Administration
during the  development of this  report are gratefully  acknowledged by
the author. Also, the author is indebted to Mrs.  Kay Estes for her skill
in preparing the drawings for this report. Finally, the author wishes to
acknowledge the contribution of the Federal Water  Pollution Control
Administration in providing  the  opportunity to  study  for  1 year at the
University of Texas  at Austin.
                     Public Documents and Reports
 Arkansas. Arkansas Water and Air Pollution Control Act, Act. 472 of  1949 as
     amended by Act 183 of 1965.
1 TATE, PHILLIP L., and HUDGENS, JAMES M., An Action Program for Clean Water.
     Joint Study and Proposals  by South Carolina Pollution  Control Authority
     and Federal Water Pollution Control Administration, Middle Atlantic Region
     1969                                                           '


Texas. Acts 1860.
Texas  Water Quality Board. Rules  of  the  Texas Water  Quality Board, Adopted
     November 28, 1967.
Texas  Water  Quality  Board. State Program  Grant Application,  Water Quality
     Board, Fiscal Year  1970.
Texas  Water Quality Board. Texas Water Quality, A Summary of Water Pollution
     Control in the State of Texas, undated statement.
U.S. Federal Water Pollution Control Act, U.S. Code. Vol. XXXIII, 1969.
U.S. Congress. Clean Water Restoration Act of 1966. Pub. L.  89-753, 89th Cong.,
     2d Sess.,  1966.
U.S. Congress. Federal  Water Pollution Control Act Amendments of 1961. Public
     Law 87-88, 87th Cong., 1st Sess., 1961.
PFIFFNER,  JOHN M., and PRESTHUS, ROBERT V. Public Administration. 4th ed. New
     York: The Ronald Press, 1960.
TAYLOR,  FREDERICK W., Scientific Management. New  York:  Harper  & Brothers
     Publishers, 1947.

                               Other  Sources
Texas Legislative Budget Board. Private interview with Bill Wells. January 22, 1970.
Texas Water Quality Board. Private interviews with Emory Long,  Administrative
     Coordinator. October  1, 1969 and January 21, 1970.
Texas Water  Quality Board. Private interview with Joe  Teller, Deputy Director,
     October 1, 1969 and January 21, 1970.
U.S. Department of the Interior, Federal Water Pollution Control Administration.
     Suggested State  Water  Pollution  Control  Act, Revised. Washington,  D.C.:
     FWPCA,  1966.

                              Legal  Citations
Texas. H.B. 24. 57th Legislature, Regular Session, 1961.
Texas. H.B. 448. 51st Legislature, Regular  Session, 1953.
Texas. S.B. 15. 60th Legislature, Regular Session, 1967.
Texas. S.B. 125. 61st Legislature,  Regular Session,  1969.
Texas, S.B. 138. 61st Legislature, Regular Session, 1969.
Texas. S.B. 147. 61st Legislature, Regular Session, 1969.
Texas. S.B. 204. 60th Legislature, Regular  Session, 1967.
 Vernon's  Texas Civil Statutes.

 Vernon's  Texas Penal Code.
JACOBI, THOMAS  R., PAVIA, RICHARD  A.,  and  RICKETTS,  E.  F., "Staffing  and
     Budgetary Guidelines for  State Water Pollution  Control Agencies," Journal
     Water Pollution Control Federation, Vol. 37, No.  1  (January  1965), 5-24.
U.S. Congress.  Federal Water Pollution Control Act. Public Law 84-660, 84th
     Cong., 2d Sess., 1966
U.S. Congress. Public Works Appropriations for 1969  for Water Power Resources
     Development and the Atomic Energy Commission. Public Law 90-147, 90th
     Cong., 2d Sess., 1968.
 U.S. Congress. Public  Works for Water, Pollution Control,  and Power Develop-
     ment  and  Atomic  Energy  Commission Appropriation   Act,  1970. Pub. L.
     91-144, 91st Cong.,  1st Sess., 1969.
U.S. Congress.  Water Quality Act of 1965. Public Law  89-234, 89th Cong.,  1st
     Sess., 1965.
U.S. Congress, House,  Committee on Rivers and Harbors. Pollution of Navigable
     Waters, Hearings  on H.R.  519,  H.R. 387, and  H.R.  4070,  79th  Congress,
     1st  Sess.,  1945.
U.S. Congress. Select  Committee on  National  Water Resources, United  States
     Senate. Water Resources Activities in the United States,  Water Quality Man-
     agement. Committee Print  No. 24. Washington,  D.C.:  Government Printing
     Office, 1960.


U.S. Department of the Interior, Federal Water Pollution  Control Administration.
    The Cost of  Clean Water.  Washington, D.C.:  Government Printing Office,
U.S. Department of the Interior, Federal Water Pollution  Control Administration.
  Guidelines for  Establishing  Water Quality  Standards  for  Interstate  Waters.
    FWPCA, May,  1966.
U.S. Department of the Interior, Federal Water Pollution  Control Administration.
    State and Interstate Programs for Water Pollution  Control, Digest of Fiscal
    Year 1969  State Program Plans. Washington, D.C.: State and Regional  Pro-
    gram Grants  Branch,  1969.

                                     U.S. GOVERNMENT PRINTING OFFICE: 1971 0—411-020