United States
             Environmental Protection
             Office of Water
             Program Operations (WH-547)
             Washington DC 20460
February 1979
Municipal Wastewater

Public Involvement
Activities Guide


          Public Involvement Activities Guide
                       Edited by

                   Clem L. Rastatter
             The Conservation Foundation
                   Washington, B.C.
                    Project Officers

                      John Hammond
                     Larry McBennett
                       January 1979
U. S. Environmental Protection Agency
Office of Water Program Operations
Facility Requirements Division
Washington, D.C.   20460

The research for this book was financed with federal
funds from the U. S. Environmental Protection Agency
under Grant No. T-900-7050.  This report has been
reviewed by the Environmental Protection Agency and
approved for publication.  Approval does not signify
that the contents necessarily reflect the views and
policies of the Environmental Protection Agency, nor
does mention of trade names or commercial products
constitute endorsement or recommendation for use.
 The Conservation Foundation
 1717 Massachusetts Avenue, N.W.
 Washington, D. C.   20036
 William K. Reilly, President

Part I of this book is adapted from manuscript prepared
by:  John S. Banta, Barbara Reid Alexander, Robert T. Dennis,
Elizabeth Haskell, and Marissa T. Roche.  Portions of
Part II of this book were adapted from original manuscript
by Char White.

Many thanks to Stuart A. Rohrer for his editing assistance.

       This handbook was prepared by The Conservation
Foundation for use in a training program to acquaint
citizen leaders with the important decisions that are
made in planning for the management of municipal waste-
water.  The training program was designed to:

    •  identify the key decisions throughout the planning
       process that are critical to the outcome of that
       process and to the future of the community;

    •  identify and analyze the environmental, economic,
       and social considerations that affect these impor-
       tant decisions;

    •  facilitate citizen input to those decisions by
       stripping the process of technical jargon, and
       helping the reader understand the community
       judgments that must be made; and

    •  help citizens understand the legal tools and
       participatory techniques that will facilitate
       their involvement in the planning process.

       The Environmental Protection Agency and The Conser-
vation Foundation initiated this training program in the
belief that the impacts of constructing a community sewage
treatment facility may have profound long-term environmental,
economic, and social consequences.  We felt that community
involvement in planning for sewage treatment facilities
would result in cleaner water at lower ultimate cost.
Only careful public scrutiny can ensure:

    •  that sewage treatment planning meets the present
       and future needs of the community;

    •  that all the relevant environmental, economic, and
       political data necessary to ensure effective implemen-
       tation emerge;

    •  that appropriate measures are taken to mitigate
       negative impacts; and

    •  that a community develops a commitment to continued
       oversight of the operation and maintenance of the

       The book that follows is divided into two parts.
The first part—the Facilities Planning Process—is essen-
tially a summary of a larger and more detailed handbook

entitled Municipal Wastewater Management:  Citizens Guide
to Facilities Planning.  The summary of the""handbook has
been included in the Public Involvement Activities Guide
as a "short-course" to the facilities planning process.
As you get more deeply involved in planning for a municipal
wastewater treatment facility, you may wish to obtain a
copy of the more detailed handbook.   You may order a copy

       General Services Administration
       Centralized Mailing Lists Services
       Building 41, Denver Federal Center
       Denver, Colorado   80225

       The second part of this book is designed to provide
guidance to the public involvement opportunities of the
facilities planning process.   In addition to describing
the regulatory and legal framework for public participation,
the second part of the book describes some of the basic
tools of public participation.

       The two parts of this book—taken together—are
designed to assist your involvement in the facilities
planning process by highlighting key decision points
appropriate for citizen focus as well as appropriate
techniques for affecting those decisions.  We hope that
local governments and citizen leaders in communities
beginning the process of municipal sewage treatment
planning will be able to use this book to assist them
in designing an approrpiate public participation program
for their community.
Clem L. Rastatter
Project Director
The Conservation Foundation

January 1979





      AN OVERVIEW	    5

        Federal Goals and Strategies  	    5

        Goals of the Municipal Facilities Program .  .    8

        Other Planning Programs of the Clean
        Water Act	    9

        Other Federal Laws and Regulations	   11


        A Sample Planning Case	   12

        Direct and Secondary Impacts  	   15

        Long-Term Responsibilities  	   16

      MANAGEMENT	   16

        What are the federal responsibilities in
        the Construction Grants Program?  Who are
        the federal actors	   16

        What are the state responsibilities in
        the  Construction Grants Program?  Who
        are the state actors?	   17

        What is the local role in the facility
        planning process?  Who are the local
        actors?	   18

        How does Section 208 planning relate to the
        ongoing facility planning process?  	   19

        How is the sewage treatment program meeting
        congressional goals and objectives for it?   .   19


        What federal policies implement  the
        Construction Grants Program?  	   21

        What are the earliest opportunities to
        influence the direction of the Step 1 Plan?  .   25



        What are themajor steps of the facilities
        planning process? 	    28

        What are the important issues for public
        involvement in assessing the current
        situation?	    28

        What are the important issues for public
        involvement in assessing the future
        situation?	    31

        What geographic area will the facility serve? .    32

        Small-Scale Service Area Options  	    33

        What range of alternatives might be evaluated
        during the facilities planning process? ....    34

        Evaluating Monetary Costs of Alternatives ...    35

        Evaluating Nonmonetary Considerations 	    37

        Financing the Selected Alternatives 	    38


        How are the appropriate mitigation measures
        chosen?	    40

        What is the role of EPA?	    42


        What are the broad requirements for public
        involvement under the Clean Water Act?  ....    45

        What's in it for you?  Why get involved?  ...    45

        Which major federal regulations give you
        access to the facilities planning process?   . .    47

        How will public participation Regulations be
        enforced?  Who will enforce them? 	    56

        How will these regulations affect what
        happens in your community?	    57

        How should a public participation program be
        developed?  What will be its major components?    58

        What are the public participation tools?  ...    62


          Education/Information  Mechanisms 	   63

          Reactive/Interactive/Dialogue Mechanisms   .   68

          Training Mechanisms 	   75

        What problems might be encountered in the
        implementation of public participation
        requirements? 	   81

        What are the rewards of public involvement
        in the facilities planning process? 	   84



    APPENDIX A  - Federal Regulations 	   87

    APPENDIX B	   91

                  Table 2
                  FACILITY PLANNING

                  Tables 3-8

    APPENDIX C - Glossary	117

                          PART I

                    FACILITIES PLANNING


       Controlling water pollution in this country's 78,267
square miles of lakes, rivers and streams is an enormous under-
taking; meeting community wastewater treatment needs is a major
part of that job.  There are now 12,800 treatment plants operating
in the United States, and another 6,200 under construction or
planned.  Over half of them fail to meet water quality standards.
Solving this problem involves an immense planning job, huge outlays
of money, coordination between federal, state and local governments
and the active participation of concerned citizens.

       For individual communities, planning for proper municipal
waste treatment means making decisions that will affect the face
and shape of the area for years to come.  Public participation is
therefore essential to preserve a community's values and goals.
Yet the decisions made in planning are complex, complicated by
technical jargon, and often difficult for concerned citizens to
understand.  This manual provides a citizen's guide to the process
of planning for municipal wastewater management.

Federal Goals and Strategies

       The current federal effort to clean up the nation's waters
began in 1972 when Congress, by passing the Federal Water Pollution
Control Act Amendments, took the unprecedented step of deciding that
the nation's water could no longer be an integral part of waste
treatment.  The Senate noted:  "Pollution continues because of tech-
nological limits, not because of any inherent right to use the
nation's waterways for the purpose of disposing of waste."

       Five years later, after sometimes controversial experience,
the law was modified by the 1977 Clean Water Act.  The two laws
are collectively known as the Clean Water Act; the Act's ultimate
goal is to eliminate the discharge of pollutants into any surface
waters by 1985.  More immediately, by July, 1983, it seeks to
achieve where possible "fishable and swimmable waters," ". . .an
interim goal of water quality which provides for the protection and
propagation of fish, wildlife and shellfish and provides for recre-
ation in and on the water."

       The Congress also recognized the enormous expense of cleaning
up the nation's waters.  The Act attempts to balance water quality
goals against the cost of achieving them.

       Along with these new water quality goals came fundamental
changes in strategies for controlling or eliminating pollution.
The 1972 Act set as its primary goal the protection of aquatic

ecosystems.  As a central strategy, it  established a new set
of standards (called effluent limitations) to control pollution
at its source—either point sources (direct discharges from pipes)
or nonpoint sources (the more diffuse discharges such as runoff
from agriculture or construction).  This source control strategy
is designed not only to be enforceable but also to impose more
equitable  and uniform requirements on similar polluters located in
different  places.  A paper mill on a comparatively clean river
must control its pollution to the same degree as a mill on a
dirty river, for example.  Thus, the clean river will be pre-
served and the dirty one cleaned up.  This strategy also elim-
nates the  incentive for polluters to locate their plants in
areas with weak regulations.

       Each state's particular standards play a significant,
though secondary, role.  Standards based on use (swimming,
drinking,  industrial use) have been established for all surface
water; when the uniform national source controls fail to meet these
standards, more stringent controls based on water quality standards
are to be  imposed on a case-by-case basis.

       The 1972 legislation also brought about a major institu-
tional change—a significant boost in federal authority, exercised
by the U.  S. Environmental Protection Agency  (EPA).  In general:

    •  state water quality agencies establish all surface
       water quality standards,  subject to EPA approval;

    •  EPA establishes uniform national source controls for
       both industrial and municipal dischargers; and

    •  EPA regulations interpret  the federal  law and the
       federal/state relationship  in implementing the law.

       The 1977  Clean Water Act  builds on the basic strategy of
source control,  but  gives  a new  priority  to state water quality
standards.  It also grants a number of variances from previously
specified tight  deadlines.

       The Act  sets  effluent limitation requirements—and deadlines
for reaching them—for industrial  and municipal point source dis-
charges.   Communities with publicly-owned sewage treatment  works
 (POTW) were directed to  achieve  a  level of wastewater treatment
equivalent to  secondary  treatment (see Glossary) by July  1,  1977
 (unless  they were  subject  to certain delays beyond their  control,
such  as  lack of  availability of  federal  funds).  They must  achieve
a level  of treatment called Best Practicable  Waste Treatment
Technology (BPWTT)  by July 1,  1983.   (EPA defines BPWTT as  the
equivalent of  secondary  treatment  or whatever more stringent
treatment level  might be necessary to meet water quality standards.)


       The Clean Water Act requirements are backed up by
significant financial and legal penalties, and are enforced on
industrial and municipal dischargers through permits issued under
the National Pollutant Discharge Elimination System (NPDES).  The
NPDES permits set the effluent limit for point source discharge
by individual dischargers.  These permits are issued and enforced
by either an EPA Regional Office or by a state water quality
agency (if EPA delegates authority to that state).

             Federal Assistance to Communities

       When it imposed these requirements and potential penalties,
the Congress recognized the financial problems that municipal
dischargers would have in meeting them.  To provide incentives,
therefore, the Clean Water Act offers federal money to cover 75
percent of the cost of constructing publicly-owned sewage treatment

      (In fact, Congress clearly tied the regulatory requirements
to the availability of these funds.  Communities that have not met
the 1977 deadline for secondary treatment of municipal discharges
may receive a variance—until 1983—if one reason for noncompliance
is a  lack of federal money.)

       Taken together, the two major sections of the current water
quality laws that concern municipal wastewater are frequently called
the municipal facilities program.  The first of these is the NPDES
permit system; the second is the federal Construction Grants Program
for treatment works.  This program awards federal grants in three

       Step 1 - the facilities planning phase, when most major
                decisions leading toward construction of
                publicly-owned treatment works are made;

       Step 2 - the design and specifications for the facility; and

       Step 3 - actual construction.

       Plans completed under a Step 1 grant are also called Facilities
Plans or 201 Plans (taking their name from the section of the Clean
Water Act that establishes the conditions for planning municipal
waste treatment facilities).

       EPA recognizes that because of the huge federal outlays
involved, the municipal facilities program runs inherent public
policy risks similar to those encountered in the construction of

    •  that large amounts of available federal money would reduce
       incentives for cost-effectiveness;

    •  that the presence of federal money would discourage
       local initiative and local spending;

    •  that inflated cost figures and fraud would siphon off
       significant parts of the available funds; and

    •  that environmental impacts brought about by this
       public works project—especially those relating to the
       location of the facility—would in many cases create
       worse problems than those the project was designed to

       EPA therefore imposes strict conditions on grant awards,
ranging from requirements for cost-effectiveness and community
financing to requirements that alternative waste treatment methods
be fully evaluated and that environmental impacts receive substan-
tial public scrutiny.

                    Public Participation

       Planning requirements for the Construction Grants Program
include broad-based procedures for public participation.  These
are described in Section 101(e) of the 1972 Federal Water Pollution
Control Act Amendments:

       Public participation in the development, revision, and
       enforcement of any regulation, standard, effluent
       limitation, plan, or program established by the EPA
       Administrator or any State under this Act shall be
       provided for, encouraged, and assisted by the Adminis-
       trator and the States.  The Administrator, in cooperation
       with the States, shall develop and publish regulations
       specifying minimum guidelines for public participation
       in such processes.

       Community planners should be particularly aware that planning
decisions made in the course of constructing a waste treatment sys-
tem can have long-lasting social, economic and political repercussions
on each community. Public participation is crucial.

Goals of the Municipal Facilities Program

       The goals of the municipal facilities program are found in
Section 201 of Title II of the Clean Water Act.  To meet the condi-
tions for federal funding, waste treatment must:

   1.  provide for evaluation of alternatives in order to apply
       the "best practicable waste treatment technology" (BPWTT)
       before any discharge into receiving waters, including the
       options of reclaiming and recycling of water, confining
       disposal of pollutants so they will not migrate to cause
       water or other environmental pollution, and considering
       advanced waste treatment techniques.

   2.   be pursued on an areawide basis as far as possible, and
       must provide for the control of all point and nonpoint
       sources of pollution;

   3.   encourage revenue-producing facilities that rely on
       recycling wastewater, confinement and containment of
       pollutants not recycled, and disposal of sludge in an
       environmentally acceptable way;

   4.   encourage the combination of open space and recreational
       uses with waste treatment goals;

   5.   encourage techniques to reduce energy requirements;

   6.   After September 1978, planners for all projects are required
       to evaluate "innovative and alternative" waste treatment
       management techniques; and to analyze potential recreation
       and open space opportunities.

Other Planning Programs of the Clean Water Act

       Ideally, the planning requirements of the Clean Water Act
should provide a framework for decision making under the entire
Act.  These requirements, spelled out in Sections 106, 201, 208
and 303 of the Act, are intended to bring the following results:

   1.  achieving the 1983 water quality goal of fishable and
       swimmable waters;

   2.  determining the information from which NPDES permits can
       be issued to impose discharge standards stricter than
       the uniform national effluent standards where necessary
       to meet a state's water quality standards;

   3.  a management plan to control pollution from all point and
       nonpoint sources; and

   4.  a process to ensure that federal construction grants are
       spent to build the most cost-effective treatment works.

       Planning under Section 208 is conducted on an area-wide
basis within states in regions designated by the governor, or,
in nondesignated areas, on a statewide bases.  These plans must
address all 'point and nonpoint sources of pollution within the
areas in order to achieve fishable and swimmable water by 1983.
Planners are empowered to control pollution by limits on dis-
charge, by regulating the location of potential pollution-causing
activities, or by a combination of both methods.

       One unusual aspect of 208 planning is that it must iden-
tify the measures needed to carry out the final plan and must
recommend appropriate state, regional or local agencies to carry
them out.  This implementation strategy is a crucial element;
many past efforts have failed for lack of one.  The 208 plan

also is designed to be at least partially self-implementing:
no permits or construction grants are to be issued unless they
are consistent with it.

       303(e) planning, conducted solely by the state (unless
subcontracted to a local agency), concentrates on the water quality
of entire river basins.  It determines what discharges will be
allowed along particular rivers, streams and lakes.  Bodies of
water classified either as effluent-limited (where uniform national
discharge limits are enough to meet state water quality standards)
or water-quality limited (where stricter limits are needed to
meet state standards).  The resulting discharge limits are
written into the NPDES permits for dischargers along river
basins and must be incorporated in local planning.  These river
basin plans must also decide how to prevent water of high
quality from being degraded, how water quality standards can be
revised and which stream segments should receive priority

       The planning required under Sections 208 and 303(e) are
intended to work together to bring about a water quality manage-
ment plan in each state.  These plans should then form the
framework for the individual Facilities Plans.

            Strategies for Better Implementation

       Unfortunately, these various planning requirements have
been controversial, generating conflict between Congress and EPA
and causing confusion and lack of coordination in state water
quality agencies.  Proposed new water quality management regula-
tions published in the Federal Register on September 12, 1978,
attack this problem and herald a new era in water quality
management planning.

       Under these regulations, a formal State/EPA Agreement
designed to integrate the various planning elements of EPA1s
environmental laws would become the central management tool of
a newly unified Water Quality Management Program.  The water
quality management portion of the State/EPA Agreement would
cover many programs for which EPA provides state water quality
agencies with financial assistance—including areawide and
basin planning programs, permit programs and Construction
Grant Management Programs.

       The proposed regulations renew emphasis on yearly program
targets and on implementation of Water Quality Management Plans.
Proposed sanctions for lack of implementation include withdrawal
and possible recovery of federal grants.

       Details about facilities planning decisions made during
water quality management planning are discussed in other sections
of this handbook.  These decisions are:

    •  priority funding;

    •  effluent limitations;

    •  boundaries of facilities planning areas; and

    •  population projections.

       Generally, no grants for treatment plants are to be
given unless the plans are consistent with an approved Water
Quality Management Plan.

Other Federal Laws and Regulations

       Executive Orders and federal laws other than the Clean
Water Act also play an important role in facility location and
design decisions.  These include:

    •  the Wetland Executive Order

    •  the Floodplain Executive Order

    •  the Archeological and Historic Preservation Statutes

    •  the Endangered Species Act

    •  the Wild and Scenic Rivers Act

    •  the Coastal Zone Management Act

    •  the Safe Drinking Water Act

    •  the Resource Conservation and Recovery Act

    •  the Rivers and Harbors Act (dredge and fill)

       In most but not all cases, the requirements of these acts
and orders must be met during the facility planning process or
the process  is vulnerable to legal challenge in the courts.
The Environmental Impact Statement process is the general vehicle
for communicating findings or conclusions about these pro-
visions; in  some cases, there are supplementary procedures that
involve other agencies and may provide additional opportunities
for public participation.


       Most  existing wastewater treatment facilities or disposal
processes in U. S. communities have failed to meet the standards
of the 1972  Federal Water Pollution Control Act Amendments.
The states or EPA have instructed many public authorities to
improve the  quality of their existing treatment process or to
build new plants.

       The key issues to consider as a community plans for new
or replacement wastewater facilities are:

    •  Disposal of solid waste  (sludge) generated by improved
       secondary and advanced treatment;

    •  Appropriateness of facilities to rapidly changing short
       and long-term needs in a community;

    •  The long-term reliability factor—especially the opera-
       tion and maintenance needs and costs that the community
       must support.

    •  Location, cost and quantity of new housing available in
       a community;

    •  Conservation of prime agricultural land;

    •  Minimizing  flood hazard  risks and protecting wetlands
       and other environmentally sensitive lands;

    •  Protection  of community  water supplies, particularly from
       toxic  chemicals and heavy metal contamination; and

    •  Control and planning of  future industrial and commercial
       growth for  best use of land and to avoid damaging
       existing resources.

How a  community resolves these  issues will depend on the choices
it makes about such questions as facility location, type of
treatment process, plant capacity, service area and water reuse.
These  choices depend heavily both on topographic features (slopes,
watershed boundaries and soils) and on political decisions that
control future patterns of community growth, often referred to as
land-use parameters.  The following brief example illustrates the
most basic issues.

A Sample Planning  Case

       Two riverside towns (X and Y) each have existing developed
areas  serviced by  separate sewage treatment plants.  (See illus-
tration.)  Located about 15 miles apart, each town is in a sepa-
rate watershed.  Local streams  are valued for their high water
quality.  But Town X, which is  upriver from Town Y, has discovered
that the quality of the water in its smaller stream is declining
because of subdivisions in the  hills of its watershed.  Unfor-
tunately, these subdivisions are actually within the political
jurisdiction  of Town Y, which has roughly the same population as
X but  is much larger in area.

       The state orders construction of a new sewage treatment
facility for  these subdivisions, both to serve existing housing
and to permit new housing construciton to proceed.  Towns X and
Y must also improve the secondary treatment capacity of their

existing plants to obtain state discharge permits.
enforcement action.
EPA threatens
       These two communities face a number of choices:

Option 1) Town Y can build additions to its sewage treatment
          facility to serve the new subdivisions.  (They have  to
          improve the plant to achieve current secondary treatment
          standards anyway.)  This will require a force main
          (pressurized sewer) to move the sewage from one watershed
          to another.  It will also require a long and expensive
          interceptor (trunk) sewer to run to the remote sub-
          divisions, which are actually bedroom suburbs of Town
          X.  The interceptor will cross farms and environmentally
          sensitive lands served by good roads, and demands
          for subsequent subdivision and development of these
          areas are likely if the sewer line is put in.

Option 2) Town X can provide service to the new subdivisions.
          Because the service will remain within a watershed,
          gravity mains could provide more inexpensive ser-
          vice, and the shorter distance would also reduce the
          capital costs for providing the new service. The open
          land between Town Y and its remote subdivisions would
          not be serviced with sewers, making new development
          there unlikely.  Political agreement between Town
          X and Y would be required.

Option 3) The two communities together could build a new regional
          sewage plant that would be served by a gravity interceptor
          running along the river. Each of the smaller watersheds
          could be served by gravity trunk sewers.  If the open
          land between Towns X and Y were needed for development
          at some time in the future, another trunk could be
          added to serve this area. Substantial economies of
          scale might be realized. However, construction of
          the regional plant might generate subtle pressure
          for the development of the open agricultural and environ-
          mentally sensitive lands between towns as the two
          communities sought formulas to recoup the large initial
          capital costs. (One technique communities often use
          to recover treatment plant costs that EPA does not
          reimburse is to service large areas for new con-
          struction and to shift costs to the incoming residents
          as rapidly as possible.)

Option 4) Town Y could recommend that a small new on-site system be
          built just to serve the subdivisions.  This solution, plus
          modification of the two existing treatment facilities to
          meet secondary treatment standards and to provide  for some
          new growth in the already built up areas in Towns  X  and Y,
          may in fact solve the  immediate pollution problem  at the

                                                         force main
                                                             New Trunk
                                                               ption 1)
                                                      Prime Farmland
                                 ,  NEW
                                 I   SUBDIVISIONS
                                    New Trunk
                                    (Option 2)
                                   Boundary between
                                   Townsr X and Y     /
  (Option 3)
Other Options:
   Land treatment;
   agricultural reuse.
   Retain existing plants
   Small plant for new sub-
   divisions, perhaps with
   innovative technology.

   Other combinations of more
   limited expansion.
                                                        Treatment Plant
                                         New Regional
                                          Treatment P]
                                         (Option 3)

       least cost.   Two problems emerge with this strategy/
       however.   Unless the communities adopt more stringent
       land-use policies in the future than they have in the
       past, orderly growth near existing communities may not
       be possible. New subdivisions creating new pollution
       problems may continue to be built at some distance from
       the towns as a consequence. If the communities were to
       decide in the future that they wanted to expand,  they
       might have to assume the construction costs for the large
       sewage treatment plant necessary to accommodate greater
       new growth than planned for, since there is no assurance
       that federal funds will be available for such purposes
       in the future.

Direct and Secondary Impacts

       These kinds of decisions facing communities and the
conflicts that lie behind them are generally evaluated in terms
of the direct (or primary) and secondary impacts associated with
various alternatives.  Many direct impacts of facility location
and construction are straightforward and short-term—traffic
disruption, temporary erosion and construction noise, for
example—and can be minimized if the contractor follows  accepted
methods (for example, by staggering hours of operation).

       Direct impacts may also include:

    •  Land Use

       Wildlife relocation; habitat destruction
       Loss of environmentally sensitive areas (wetlands,
           floodplains, endangered species habitat, etc.)
       Conflicts with adjacent uses
       Loss of agricultural land
       Archeological losses
       Growth in population

    •  Aesthetic

       Visual, noise, dust, odor, loss of open land

    •  Mechanical

       Disruption of commercial/residential activity
       Energy consumption
       Employee commuting, housing

    •  Risks

       Adjacent property value changes
       Seismic activity
       Safety hazards associated with construction; water pollution

       Secondary impacts can be more subtle and long-lasting—
impacts arising from changes in community land use and population
growth due to facility construction and new sewer service.  Facility
construction may be the most important or simply one of many causes.
They may include environmental disruption and increased costs of
housing and services.

       Some secondary impacts are addressed by specific provisions
in state and federal laws.

Long-Term Responsibilities

       When the facility construction is completed, the community
must make sure that its facility,is operated and maintained well
enough to meet design standards and the effluent limitations of
its NPDES permit.  Enforcement actions for violations of permit
conditions may bring substantial civil fines and/or criminal

       Many past systems built primarily with federal funds have
not operated to design capacity.  Complex, high technology systems
sometimes were designed for communities with neither the money
nor the know-how to operate them.

       The Clean Water Act deals with this problem in two ways.
First, it requires communities to develop a detailed operation
and maintenance plan before construction is complete.  Second,
communities must design a system of user charges to pay long-term
operation and maintenance costs.

       The community is also responsible for any future expansion.
The completed treatment facility should have a reserve capacity
to handle 20 years of anticipated future expansion.  If the popu-
lation projections are accurate, the community will want to start
actively planning expansion after 10 of these 20 years have elapsed.
Federal funds may not be available for any future expansions.


What are the federal responsibilities in the Construction Grants
Program? Who are the federal actors?

       The U.S. Environmental Protection Agency, which administers
the Clean Water Act, plays the preeminent role in the Construction
Grants Program:  it writes regulations and guidelines that interpret
the law and awards the grants.  SPA headquarters in Washington, D.C.
takes primary responsibility for interpreting the law, while EPA's
10 Regional Offices throughout the country have primary authority
to award Step 1, 2 or 3 grants.

       EPA publishes three major kinds of documents that direct
and guide EPA personnel, state agencies and local applicants in

implementation of the Construction Grants Program.

    1) Regulations having the force of law are proposed for public
       comment and then issue in final form (generally after a
       60-day comment period) in the Federal Register, which is
       published daily by the Superintendent of Documents, Govern-
       ment Printing Office, Washington, B.C. ($50 for annual sub-
       scription) .  EPA regulations also appear under Title 40 of
       the Code of Federal Regulations (CFR), an annual compilation
       of all federal regulations in final form.

    2) Program Requirements Memoranda (PRM's) interpret significant
       issues raised by regulations.  They do not have the force of
       law, but are generally considered to be more specifically
       instructive than are guidelines.

    3) Guidelines, giving advice on the general procedures, methods,
       and material to implement regulations.  They do not have the
       force of law.

What  are  the state responsibilities in the Construction Grants
Program?  Who are the state actors?

       The state water pollution control agency has a powerful role
in the sewage treatment program.  The state agency develops a Prior-
ity List  each year that determines which community receives how
much  federal money to solve its waste treatment needs. The state
also  determines the facilities planning boundaries and establishes
the water quality standards applicable to specific waters. Each
state must approve applications for facilities planning grants
before they can be submitted to EPA, and also reviews and approves
the completed Facilities Plan prior to EPA's review. In addition,
the state will have an increasing role in developing population
projections for individual  facilities planning areas.

       The Clean Water Act Amendments of 1977 call for a further
increase  in state involvement in the Construction Grants Program
through the provision of Construction Management Assistance Grants
(CMAG).   These grants, which come out of the construction grants
funds allotted to each state, allow the state to assume responsi-
bility for certification that all federal requirements are met
prior to  the actual grant award.

       Most states currently have some sort of delegation agreement
with  EPA  that allows them to certify that ongoing construction
is proceeding properly and  that the Operations and Maintenance
Manual prepared for each facility has been properly done.  Many
states are anxious to assume responsibility for the entire program.

       Some functions remain with EPA arfd cannot be delegated
to the states:  determination of the necessity for and preparation
of an Environmental Impact  Statement and the actual award of funds
for any Step 1, 2, or 3 grant.

       Once the delegation agreement is completed, the Construc-
tion Management Assistance Grant (CMAG) may be awarded.  Both the
completed agreement and the CMAG may be amended and extended at
any time.

                       Public Involvement

       Newly issued EPA regulations require public involvement
during the negotiation of delegation agreements and any substan-
tial amendments to them.  Actual copies of draft delegation agree-
ments (and substantial amendments) and fact sheets are to be dis-
tributed 45 days before approval, and if there is significant
public controversy a hearing must be held.  The public is spe-
cifically asked to consider whether the state program is ade-
quate to handle the proposed delegations.

       Members of the public should be particularly alert to the
provisions made in any delegation agreement for assuring compli-
ance with the public participation requirements of the Clean Water
Act.  Once a delegation has been made, it will be politically
difficult for EPA to retract it.

What is the local role in the facility planning process?
Who are the local actors?

       The local recipient of a Step 1 grant is responsible for
preparing the Facilities Plan and for making the important deci-
sions concerning the community's future required by the Act.

       The official grant applicant may be the town officials
(selectman, mayor, town council) or the trustees or commissioners
of a special sewer or sanitary district established for this pro-
gram.  Because local officials tend to be inexperienced in sewage
treatment questions, they usually hire an engineering consultant
for actual preparation of the Facilities Plan.  In many instances,
important political decisions are delegated to the engineer.
Although often buried in technical jargon, the issues raised by
the facilities planning process affect the future and shape of
communities.  Unraveling the value-laden political judgments from
the mass of technical materials is an important role for citizen
participants in the facilities planning process.

       Concerned members of the public should become involved as
early as possible in facilities planning.  In the past, public
participation often has come late in the process, in response to
a controversial plan recommendation. Massive controversies then
ensue, often requiring years of negotiation, new plans and wasted
expenditures of public funds.  Development of a public participa-
tion program as part of the grant application for the planning
funds may save a good deal of time and, ultimately, money.

How does Section 208 planning relate to the on-going  facility
planning process?

       Congress intended Section 208 to be the keystone of clean
water planning.  It was to bring about integrated areawide and
statewide management plans that would provide the framework  for
the more local decisions of the Facilities Plan.  Yet historically
the reverse has been the case:  the Step 1 facilities planning
effort funded under Section 201 has provided much of  the framework
for the broader water quality management planning of  Section 208.
Factors associated with 201 planning—local constituencies more
powerful than regional ones, more detailed federal requirements,
more emphasis and funding for Step 1 planning—have combined to
move facilities planning ahead of 208 planning in most localities
and to set many planning decisions in concrete before other options
can be thoroughly evaluated.  Serious 208 planning, however,
is now underway in most states; a major problem lies ahead in
trying to coordinate the 201 and 208 planning efforts.

       You should be aware of the status of 208 planning in your
area especially if you live in a region that is under the juris-
diction of an areawide agency.  If final 208 decisions have been
made and final approval given, your facilities planning may be
constrained in important areas by the approved 208 plan.  Such
critical issues as population projections, service areas and re-
commended waste treatment alternatives and locations may have
been already decided.  If so, you should examine how these deci-
sions were reached.  If you are unhappy about them, you will have
to seek an amendment to the 208 plan, in addition to working through
the facilities planning process.

How is the sewage treatment program meeting congressional goals
and objectives for it?

       The Construction Grants Program is the largest public works
program since the federal aid-to-highways program.  Over $19 billion
has been obligated by the federal government for the planning and
construction of treatment works since the passage of the Clean
Water Act  in 1972.  More than 100 grants are awarded every month;
more than 6,000 Step 1 grants have been awarded so far, totalling
over $500 million; and more than 670 Step 3 projects have been
completed.  Most of the grant money has been awarded to communities
with populations over 10,000; over one-third of it to cities with
a population greater than 500,000. *

       However, two-thirds of the 12,800 treatment plans currently
in operation nationwide do not meet the secondary treatment require-
ments of the Act.  More than half of these facilities require treat-
ment stricter than secondary to meet their state water quality stan-
* These  figures are derived  from a FACTSHEET  issued by the EPA
  Construction Grants Program in August 1978.


                  Basic Political Conflicts

       Two continuing and related tensions accompany implemen-
tation of the Construction Grants Program at all levels of
government. The first is the continuing tension between
facilities planning—intended to find ecological solutions to
environmental problems—and the construction grants that are
the basis of a huge public works program.

       Recognizing possible employment opportunities, and faced
with meeting strict regulatory deadlines, the major institutional
actors—Congress, the states, the sewage treatment industry and
EPA—have put great priority on speeding up the rate of obliga-
tions to the Contruction Grants Program.  Observers of the pro-
gram have noted that the political necessity of moving money
quickly has higher priority than ensuring the value of the plan-
ning. Attempts to upgrade quality, if they could cause delays
in the rate of obligations, are discouraged.

       The second major tension of the program has involved its
management at the local level.

       Since 75 percent of the planning and construction funds
come from the federal government (and perhaps an additional 5-15
percent from state government) local communities have little in-
centive to worry much about facilities planning.  The community's
future cost of maintaining and operating the system may at first
seem obscure and remote.

       Furthermore, since the recipient of the construction
grant is frequently a group of lay people—county councilmen,
town selectmen—who have no experience with wastewater management,
the job is typically turned over completely to a consulting
engineering firm.

       The vast majority of consulting engineers who design
publicly-owned waste treatment works are people of competence
and integrity; however, they are only human. Like everyone else
their competence for a particular project may be affected by
their training, their past experiences and their future interests.
Relevant facilities planning requires the involvement of informed
layment from within the community (both inside and outside of
government) who are sensitive to the present and future needs
of their community.


       The basic purpose of the three-step construction grants
process is to assure that facilities built with federal funds
are both environmentally sound and cost-effective.  The Step 1
plan provides opportunity for local, state, and federal review of
the planning process at a key point along the road to final con-

struction.  It also allows mid-course correction, and offers
assurance to both the affected community and the federal
officials responsible for grant disbursement that the facility
being planned will be a sound one.

What federal policies implement the Construction Grants

            Special Environmental Considerations

       As noted earlier, wastewater treatment facilities
are subject to all federal laws relating to protection of
the environment, governing disposal of solid wastes, and
promoting wise land and resources use (the Clean Air Act,
National Environmental Policy Act, etc.).

       Floodplains Management and Wetlands Protection

       To implement the requirements of a recent Executive
Order on  floodplains and wetlands (11988 May 24, 1977), EPA
has established its policy and guidance for protection of
floodplains or wetlands.

       If there is no practicable alternative to locating in or
affecting the floodplains or wetlands, EPA must consider oppor-
tunities  to minimize adverse impacts on them and to restore and
preserve  their natural and beneficial values. Once the agency
has made  a decision on the most desirable alternative, it must
notify the public and also produce a statement of finding that
explains  its decision.

               Significant Agricultural Lands

       EPA policy concerning protection of significant agricul-
tural lands requires, among other things, that specific project
decisions involved in the planning, design, and construction of
sewer interceptors and treatment facilities must consider farm-
land protection.  If it is necessary to construct sewers on prime
agricultural land, appropriate measures to protect that land for
agricultural purposes are to be taken.

         Small-Scale, Innovative and Alternative Systems

       Concern over the large number of expensive conventional,
centralized secondary treatment and discharge facilities in the
U.S. led  Congress to put new emphasis on nonconventional systems
in  the 1977 Clean Water Act.  Several provisions of the Act can
be expected to have a significant impact on the type of treat-
ment systems that are funded.
 *  This  discussion  is  limited  to  the most  important  policies.
   Other policies  (and more detail) are discussed  in the
   companion  volume  to this book  entitled:  Municipal Wastewater
   Management;   Citizens Guide  to Facility Planning.

       First, after September 30, 1978, no construction grants
may be awarded unless "innovative and alternative" systems
that provide for the "reclaiming and reuse of water, otherwise
eliminate the discharge of pollutants and utilize recycling
techniques, land treatment, new or improved methods of waste
treatment management for municipal and industrial waste . . .
and the confined disposal of pullutants. . ." have been studied.
(See definition below.)

       Second, a special reserve fund is to be set aside for
bonus grants to be allotted for construction of innovative and
alternative treatment systems.  This bonus raises the federal
share of the approved treatment works from 75 to 85 percent.

       Another special provision allows that, when comparing
the life-cycle costs of different treatment systems, a so-called
innovative and alternative system may exceed the costs of a
conventional system by as much as 15 percent and still be eligible
for federal funding.

       As additional incentives for innovative and alternative
technologies, states may include them as a criterion for
priority funding. Communities that invest in approved innovative
systems that fail may find that 100 percent of their investment
is protected by federal guarantees if the failure occurs during
the first two years of operation.

       EPA guidelines published on September 27, 1978, attempt
to define innovative and alternative technology. Essentially,
alternative technology is a treatment method other than a centralized
conventional treatment and discharge system using biological and
physical/chemical unit processes.  Innovative systems are systems
that have not "been fully proven under the circumstances of their
contemplated use and represent a significant advancement over
the state of the art in terms of meeting the national goals. . ."
Criteria that the regional administrator must use in reaching a
determination of innovation include:

    •  cost of 15 percent less than the most cost-effective other

    •  reduction by 20 percent of net energy requirements for

    •  improvements in operational reliability;

    •  better toxic materials management;

    •  increased environmental benefits; and

    •  improved joint municipal industrial management and treatment.

       The guidelines for the funding of innovative and alternative
systems are flexible.  The decision concerning whether a system
is innovative or alternative must be made by the EPA regional
office (or by the state in the case of a delegated program)
on a case-by-case basis.

    Special Attention to the Concerns of Small Communities

       During the 1977 debates over the Clean Water Act,
Congress paid particular attention to the problems of small
communities in meeting goals for municipal facilities. Communities
with populations under 25,000 and a planned facility costing
less than $2 million  ($3 million in states with unusually high
construction costs) may submit a combined application for Step
2 and 3 in order to speed up construction, cut administrative
costs and reduce the  inflation of construction costs caused
by delays. In addition, EPA is authorized to provide direct
technical assistance  to small communities with qualified
innovative and alternative systems.

                    Individual Systems

       For the first  time, individual systems such as septic
fields are eligible  for federal grants under certain conditions.

       These small systems are considered alternative to conven-
tional treatment under the definition of "innovative and alter-
native."  EPA has ruled that these individual systems are eligible
for  a bonus grant from the innovative and alternative "set-aside"
as well as for the 75 percent federal funding available through a
special reserve set  aside for alternative systems for small com-
munities.  Since states with populations that are 25 percent or
more rural must set  aside 4 percent of their annual alternative
systems allotment for small communities, that alone should provide
some special incentives for funding individual systems.  Individual
systems are not eligible for the 15 percent cost preference in
the  cost-effectiveness analysis.

           What Costs are Eligible for Federal Funds?

       The entire facilities planning process and subsequent parts
of Step 2 are directed toward answering this complex question.  As
a general rule, the  75 percent federal share can pay for all
reasonable Step 1 costs—engineering data, analysis of alternatives,
environmental assessment, public participation activities and
recreational planning—of a facility that is appropriately eligible
on the state Priority List.  These costs are outlined and approved
in a proposal called  a Plan of Study submitted to the state water
pollution control agency and EPA before the grant award.

       The budget for Step 1 planning is negotiated on a case-by-
case basis before the grant is awarded.

       Each state is required to reserve 5 percent of its annual
allocation for possible increases to ongoing grants, which may
be awarded while Step 1 planning is underway.  The vehicle used
for this increase is a grant amendment that is first submitted
and approved by the state agency and then sent to the EPA
Regional Office.

       Funding eligibility for Step 2 (the design phase) and Step
3 (actual construction) is largely determined by the outcome of
Step 1.  Federal funds will pay for design and construction of
the least expensive treatment alternative that meets required
effluent limitations without overriding environmental and social
impacts.  A number of quite specific requirements (described in
Section V) establish the parameters of the so-called cost-
effectiveness analysis, which results in the selection of a
preferred alternative, its technology, its size and its service

       The federal government will not pay for:  (1) a facility
that is larger than necessary for anticipated present and future
wastewater flows, as determined by established procedures; (2) a
facility designed solely to meet community expansion needs rather
than existing water quality needs; and (3) ongoing administrative
activities of local government.  Grant funds may be used, however,
to pay the expenses of staff who are actually producing work for
Steps 1, 2, or 3 (i.e., the cost of a grantee construction crew
may be eligible for federal funding).

       Community leaders planning for sewage treatment now should
always keep the next step in mind:  The community should either
be determining limits to its growth or be thinking ahead toward
another round of facility planning and construction.

       Some special cost eligibility considerations are worth
paying attention to here.

       1)  The treatment facility must be constructed to treat
           primarily domestic waste.

       2)  Advanced treatment  (beyond secondary) will receive
           intense scrutiny from EPA, particularly when the
           incremental costs of the advanced treatment exceed
           secondary treatment costs by $1 million (or by 25
           percent in the case of innovative and alternative

       3)  Interceptor sewers are generally eligible if part
           of a cost-effective system.  Generally, collector
           sewers to serve new communities built after 1972 are
           not eligible.

       4)  The cost of land is only eligible if it is used for
           wastewater storage prior to land treatment, or the

           land is an integral part of the treatment system.
           (In the case of individual systems, land is not
            eligible at all.)

       5)  Multiple purpose projects are currently eligible for
           federal funding only to the extent of the most cost
           effective alternative designed for water quality only
           purposes.  (This policy is currently undergoing review.)

What are the earliest opportunities to influence the direction of
the Step 1 Plan?

                Decisions Made by Nonlocal Actors

       Before a community begins facilities planning, a number of
constraining decisions may have been made through the statewide
water quality management process:  amount of allowable discharge,
boundaries of the facilities planning area, population projections.
These decisions are to be made by state agencies or by designated
areawide waste treatment management agencies.  In fact, according
to new EPA regulations these critical decisions must appear in
approved Water Quality Management plans.  After October 1, 1979,
EPA will generally not approve grants for Step 1 planning unless
the related information is available in an approved WQM plan.

             Establishing Effluent Limitations

       The municipal effluent limitation is the specified amount
of pollution a community may discharge into surface waters.

       Effluent limitations are essentially derived from three
sources.  First, all municipal dischargers must meet a national
minimum  standard of discharge that is defined as the discharge
level that can be expected from a well operated secondary treat-
ment facility.

       Second, if meeting the national minimum is not enough to
meet state water quality standards, a stricter standard may be

       Third, if a  facility discharges into marine waters, the
EPA Administrator may, under certain conditions specified in
the 1977 Amendments, allow a variance from secondary discharge

                Establishing Planning Boundaries

       The state's water quality agency will usually determine the
planning area for Step 1 grants in consultation with local offi-
cials or in the contents of a completed WQM plan.  A completed
WQM plan must assign an agency to manage planning and construc-
tion of waste treatment facilities.  The assignment may go to an

areawide agency, or the authority may be delegated to the
individual jurisdictions in the area.

       In the absence of a completed WQM plan, the state water
quality agency has authority to establish the local 201 planning
boundaries.  The boundaries must include the sources of the pollu-
tion problem itself; how much other area is also included may
directly influence the contents of the Facilities Plan itself.

       EPA regulations and guidelines offer some guidance to those
who draw these planning boundaries.  First, the geographic area
must be large enough to assess all potential environmental impacts
of any treatment alternative chosen.  Planning area boundaries are
discussed in Section V.  Yet, the establishment of planning boun-
daries before the facilities planning process begins may in fact
establish the basic parameters of service area determinations.

     The Statewide Disaggregation of Population Projections

       As is explained in later discussions regarding population
projections, the states are responsible for breaking down state-
wide population projections into projections for individual faci-
lities planning areas.

                     The Priority System

       EPA will not award a Step 1, 2, or 3 grant unless a state
certifies that the proposed project is entitled to priority for
federal funds in accordance with an EPA-approved state priority
system and the state Priority List.  Within certain constraints,
therefore, the state controls the timing and amount of federal
funds awarded for the facility planning process.

       EPA reviews the criteria and method of application used
in developing the state Priority List.  The state must determine
its water pollution control needs according to categories that
are related to the water pollution goals of the Clean Water Act,
but can assign any weight it chooses to the various categories
when it ranks them.

       A public hearing must be held annually prior to the
finalization of the state Priority List.  EPA reviews the list
to make sure that the criteria adopted by the state have been
consistently applied and that neither political nor economic
factors have entered into selection of projects.  EPA may only
interfere in a Priority List if an individual project fails to
meet the enforceable goals of the Act.  An exception to this
EPA review is in the case of so-called "pipe projects."  Twenty-
five percent of a state's construction grant allotment may be
set aside for such pipe projects as new interceptors, sewer
rehabilitation, etc.  As long as these projects are otherwise
eligible for construction grant funds, EPA will not review
them to see they meet the enforceable goals of the Act.

       The Act requires a number of "reserves" or "set asides"
from each state's allotment, all designed to serve specific
national goals.  Of the two most significant reserves, one en-
courages "innovative and alternative" treatment systems, and the
other focuses more federal funds on smaller communities.

     .  A state with a rural population of 25 percent or more must
set aside 4 percent of its allotment for small rural communities
and other less-populated areas for alternative to conventional
sewage treatment works.  "Non-rural" states may request up to
4 percent of their allotment for the same purpose.

       Treatment works using "innovative or alternative" tech-
niques and processes are allowed an increase in the federal share
of total costs from 75 to 85 percent.  A state must set aside 2
percent of its allotted funds for these projects.  (By 1981 that
"set aside" will be 3 percent of the allotment.)  One-half percent
of the 2 percent allotment must be used only for innovative projects,

                  The Grant Application

       The public body applicant (the grantee) makes a number of
critically important decisions before and during a Step 1 grant
application.  The procedure:

       1)  A local government official is designated to act for
           the applicant;

       2)  Pre-application conferences with EPA and the states
           sometimes result in:

           a)  initial alternatives to be examined and initial
               direction of the Facilities Plan;

           b)  suggested names of consulting engineers who might
               be hired by the grantee;

       3)  Subagreements with the potential consulting engineer
           are frequently drawn up before the grant aplication.
           The engineer will then proceed to work on the required
           Plan of Study;

       4)  A Plan of Study, submitted as part of the grant
           application, describes problem areas, the scope of
           the planning effort and the work schedule.  Eventually,
           the Plan will be made part of the grant agreement; its
           work schedule and cost estimates will be used to deter-
           mine a formal grant payment schedule.  The proposed
           public participation program, its budget and schedule
           will also be outlined.


What are the major steps of the facilities planning process?

       The fundamental decisions of the facilities planning
process are usually made at formal "step," or decision points.
Wastewater management officials and consulting engineers generally
refer to the following major steps:

    •  the Plan of Study/grant application

    •  assessment of the current situation

    •  assessment of the future situation

    •  identification of alternatives

    •  cost/effectiveness analysis

    •  environmental assessment/Environmental Impact Statement

    •  selection of recommended alternative

       The facilities planning process is in fact, much more
complex than a series of seven linear steps.  (The 201 Public
Participation Guide in Appendix breaks the Step 1 process into
26 decision points.)  On their surface the steps appear logical
and linear; in fact they bear a somewhat circular relationship
to each other.  Information gathered and decisions made must
be constantly reevaluated as new information becomes available.

       Table 1 below is a much simplified description of the
major decisions in which citizens will want to get involved during
the Step I process.

What are the Important Issues for Public Involvement in Assessing
the Current Situation?

       This decision point is not just a straightforward data-
gathering exercise:  it is in fact a critical step for public in-
volvement.  Information not gathered, or misinterpreted, may sub-
stantially affect the outcome of the facilities planning process.

       The infiltration/inflow analysis (I/I), one of the first
steps of facilities planning, is a preliminary engineering eval-
uation of the sewer system to find out how much of the total
wastewater flow comes from excessive infiltration into the sewer
system from leaky pipes or excessive inflow from various kinds
of storm drains.  If excessive I/I is found, a more extensive
study of the sewer system will be made to determine how much
rehabilitation of pipes and drains can cost-effectively replace
the need for extra treatment plant capacity.

                                                TABLE 1
                                  MAJOR FACILITIES PLANNING DECISIONS
 Assess the Current Situation
 Assess the Future Situation
 Identify Alternatives
gather information on plan-
  ning area:
     water quality
     other environmental
gather data on:
  existing wastewater flows
  existing treatment systems
  infiltration/inflow analysis
  performance of existing systems

What are our water  quality
Are the existing facilities
What unique resources  does
  our community have that
  are worth protecting?
a) land use
b) demographic and economic
c) future flow and wasteloads
d) future environment without
     treatment project
a) biological or physical/
     chemical treatment and
     discharge to receiving
b) reuse/recycling systems
c) land application systems
d) revenue generating appli-
e) on-site and nonconventional
f) sludge and residual disposal
                                 How much growth is projected to
                                 Are projections consistent with
                                   community goals/land-use plans?
                                 Are wastewater flow projections
                                 Is a new treatment facility
                                   necessary to preserve environ-
                                   mental quality of community?

                                 Is a full range of alternatives
                                   being considered including
                                   smaller scale, low technology
                                   options as well as centralized
                                   high technology ones?
                                 Is land treatment being seriously
                                 Are there opportunities to recycle
                                   or reuse treated wastewater?
                                 How much treatment capacity is

 Cost Effectiveness Analysis
 Environmental  Impact
 Statement  (EIS)
 Select Alternative
       TABLE  1 cont'd.


a) establish present worth of
     alternatives (monetary
     value of capital costs
     plus O&M costs over life of
     of project.
     1) service area
     2) service life
     3) staging construction
b) develop water conservation
c) institutional arrangements
     for implementation
d) environmental impact assess-
     ment for each alternative
e) recreational use assessment
     for each alternative
f) energy consumption assessment

a) gather additional information
     on primary and secondary
     environmental impacts.
b) prepare draft impact statement
     and seek public and govern-
     mental review of draft EIS.

a) develop measures to mitigate
     primary and secondary
     environmental impacts
b) select site

What sewage treatment alternative
  has the least monetary cost
  without overriding environ-
  mental and social consider-
Are the environmental impacts
  identified in the environ-
  mental assessment significant
  enough to warrant a full scale

       Other important questions to ask during  the  "current
situation" assessment concerns the accuracy of  the  data-

       Have current water quality problems been sufficiently  and
accurately identified?  Are the sources of current  wastewater
flows known?  How well are the existing treatment facilities
operated?  Have existing population and land use data been properly
assessed?  Have all environmentally sensitive areas been  identified?

What are the important issues for public  involvement in assessing
the future situation?

               How big should a new facility be?

       Determining facility size is in part a technical job,  based
on average-to-peak flow ratios, land  slopes, and the like.  It  is
also subject to federal policies limiting grant payments  for
"reserve"  (growth) capacity.  The facility should be large enough
to last 20 years from its first day of operation.

       There are three variables governing facility size  that the
community can influence:  population  projections; per-capita  waste-
water  flow calculations; and amount and type of industrial discharge
into municipal facilities.

A summary of EPA policies on facility size:

    •  Population projections for facilities planning areas are
       generally to be developed by the state from  the projec-
       tions of the Bureau of Economic Analysis, U.S. Department
       of  Commerce.  A state's own projections  may  be used if they
       are not more than 5 percent greater than BEA's, or if  they
       are approved by the EPA Regional Administrator.

    •  Wastewater flows are to b estimated from existing  water
       use records, preferably; or by using a specified gallons-
       per-capita-per-day allowance.

    •  No  allowance is permitted for  increased  per-capita water
       use.  Quite the opposite.  Cost-effective water conser-
       vation measures must be included in the  wastewater manage-
       ment solution, and the size of the treatment facility  should
       be  based on the reduced per-capita flows expected.  Public
       education, pricing policies, and regulatory  measures also
       must be evaluated and included, as appropriate.

    •  Industrial flows are to be calculated by adding present
       industrial flows treated in the municipal plant, docu-
       mented future flows, and an allowance for unforeseen
       industrial growth.

                 Assessing Future Land Uses

       A community's assessment of its future land uses will
partly determine capacity, location and service area of the re-
commended treatment plant.  Local and regional land use and de-
velopment plans provide a framework for facility planning, as
does the 208 planning process.  Facilities Plans must conform
to the Water Quality Management Plans developed under Section

       Yet the water quality management process is not a static
process.  In fact, Water Quality Management Plans must be re-
evaluated yearly through a formal continuous planning process.
Citizens should have ample opportunity to obtain amendment of a
WQM plan if desirable.

                       The Sewer Issue

       New sewers may stimulate new development and generate
new wastewater loads.  At the very least, if they do not sti-
mulate growth, they direct the location of that growth.

       EPA policies on sewers briefly summarized:

           •  collectors will only be funded when they involve
              replacement or rehabilitiation of an existing
              system, or when they are for a community in
              existence before 1972;

           •  interceptors are to be designed for a 20-year
              period, unless a period of not more than 40
              years is demonstrated to be consistent with
              approved water quality and land use plans and
              will reduce overall environmental impacts.

           •  interceptor routes may not extend into undevel-
              oped lands, prime agricultural lands and environ-
              mentally sensitive areas unless they are demon-
              strably necessary to alleviate existing problems.
              If they are determined to be necessary, appro-
              priate measures to mitigate impacts are to be
              part of the grant conditions and included in
              the NPDES permit.

What geographic area will the facility serve?

       The service area question is essentially this:  Is it
more effective to link a  number of wastewater service areas
together into a single large service area with a set of sewers,
feeding a single central  treatment facility  (a system which
will likely support additional population and industrial growth);
or to establish a number  of smaller service  areas which are
interconnected to a lesser degree or not at  all?  The answer
will determine much about the future size and shape of the

Small-Scale Service Area Options

       Cost-effectiveness is a controlling federal criterion for
service area and treatment mode decision-making.  Thus, a com-
munity might well be forced to select centralized treatment even
though it would prefer individual systems.

       The smallest-scale wastewater facility service area is the
individual septic system, compost toilet or similar "innovative"
system.  The 1977 Amendments to the Federal Water Pollution Control
Act now recognize these individual facilities as a valid option
under the Construction Grants Program.

       If individual systems are not a viable option, then atten-
tion must shift to some sort of centralized treatment facility
served by sewers.  Should the community's identified water problems
be limited to a few scattered neighborhoods, the community might
seek to locate small "package plant" facilities in each neighbor-
hood not interconnected by development-stimulating trunk sewers.

       "Package plants"—essentially delivered by the manufacturer
in ready-to-plug-in-and-operate condition—can deliver high quality
effluent.  But either a trained operator should be present at all
times, or the plants should be monitored and supervised under a
system that assures quick response to any malfunction.  In past
years, many a package plant has become just one more community
headache.  Some rural communities have favored growth-restricting,
low-technology central treatment facilities, such as stabilization
ponds or land application systems, serving small areas.

       The Clean Water Act sets aside 4 percent of the construction
grant allotment to states with a rural population of 25 percent
or greater "only for alternatives to conventional sewage treatment
works for municipalities having a population of 3,500 or less,
or for the highly dispersed sections of larger municipalities."
In other words, as in the case of individual systems, Congress
recognizes that some communities will prefer to think small.

                 The Regional Service Area

       Large metropolitan wastewater treatment facilities have
long been in vogue for economic reasons—more treatment capability
can be provided per dollar, in terms of capital outlay, operation
and maintenance.  Since 1965, water quality policymakers have
favored regional systems for other reasons, too:  more professional
operation, higher standards of treatment, fewer effluent outfalls
which can be sited to incur minimal environmental damage.

       A community that selects a regional service area for its
new facilities probably will derive three major practical benefits.
First, the Clean Water Act gives high priority to regional water
quality planning, meaning that both the state water quality agency
and EPA are likely to look kindly upon a regional facilities plan.
Second, a project designed to solve water quality problems of

regional scope will probably draw a higher priority rating from
the state than the smaller project.  Third, depending on what
service alternatives are studied, a regional plan may be most
likely to meet federal cost-effective criteria.

      A central question is:  How big a region?  Enough
serious disadvantages to large regional facilities have
become apparent that regional solutions may have less appeal
in the years ahead.  By their nature, they tend to rely heavily
on technology.  Costs of building high technology-based plants
are escalating rapidly, and may reach exorbitant levels when
"advanced waste treatment" (extremely high levels of pollutant
removal) is required to meet effluent standards). And, for a
variety of reasons, the time lapse between planning and actual
operation of large regional facilities ("construction time")
may cause difficulties for the communities being served.

       Furthermore, regional treatment plants collect the
wastewater they treat through a network of interceptor or major
trunk sewers.  Development generally follows those sewers,
particularly where they cross open land, sometimes bringing
unwanted patterns of suburban sprawl.

       Finally, regional facilities usually serve more than one
political jurisdiction, and therefore require interjurisdictional
agreements and flow allocations that can be difficult to negotiate
and achieve.

What Range of Alternatives Might be Evaluated During the Facilities
Planning Process?

       Given all the criteria, standards, and policies that a
community must deal with—secondary treatment, effluent controls,
water quality standards, cost-effectiveness policy—the community
may find that its range of facility options is severely limited.
Indeed, those options may depend on the community's influence over
facility service area and facility sizing decisions.  As the number
of variables is reduced, the selection of treatment process may
become and more an engineering and economic decision.

       Technical possibilities for wastewater treatment are
numerous and may be combined in a variety of ways, depending
on the imagination of the designing engineer.  Advantages and
disadvantages of each must be determined in large part for each
community on the basis of population, population distribution,
land values, geology, climate, and similar factors.

     The option of no facility;  Are new facilities required?

       The first step in facility planning is to determine whether
new wastewater treatment facilities are in fact required—or exist-
ing facilities can somehow be made to make do.  In some communities,
identified problems might be corrected by repairs or improvements in
the existing system or by modifying the treatment process now in use,

   Traditional, centralized physical/biological/chemical
      treatment and treatment and discharge to waters

       An adequate central treatment and disposal facility
usually provides secondary treatment to remove about 85 percent
of the biological oxygen demand  (BOD) and suspended solids  (ss).
In some situations, advanced waste treatment is needed to remove
more BOD, significant amounts of nitrogen, phosphorus, chemicals
and heavy metals, and all pathogenic bacteria.  Facilities  for
collection, treatment, discharge, and sludge handling will  be
included in this option.

   Centralized collection, treatment, and land application  of
       effluent, rather than discharge to a waterway

    Land application is usually an alternative to constructing
an advanced wastewater system, but in some instances may substitute
for secondary treatment.  Treated effluent is considered a  resource
and applied to soil and vegetation for crop and soil nourishment
and groundwater replenishment.  Land application systems include
spray irrigation and infiltration-percolation systems, in which
nearly all effluent is absorbed  into the soil, and overland
flow methods, in which wastewater is sprayed over the upper
edges of sloping terrain and flows downhill, filtering through
grass and other vegetation.

       Waste treatment and reuse of purified waters.

    This alternative also considers treated effluents to be
valuable resources.  After the cleaning process, waters and
pollutants are reused in industry, utilities, and agriculture,
and for recreation, municipal supplies, and groundwater recharge.

           On-sitewastetreatment and disposal.

    Septic tanks, cesspools, and other subsurface disposal  systems
can be used for one or more residences, small commercial establish-
ments, or even small towns and highly dispersed sections of larger
cities.  Public or central management may be needed to ensure
proper maintenance and operation of such facilities.

       The most cost-effective wastewater treatment solution
for a given area or community is the option with the lowest
monetary costs over a 20-year planning period, without overriding
adverse nonmonetary costs, that meets all federal, state and
local requirements, or subsurface disposal requirements.

Evaluating Monetary Costs of Alternatives

       Monetary costs include all capital construction costs
(for treatment plants, interceptors, sewers, discharge or reuse
facilities and sludge-handling equipment, land, administrative,
legal, and interest charges during construction, etc.) and  all
operation and maintenance  (O&M)  costs  (labor, chemicals, energy,

routine replacement of equipment, etc.).  Offsetting revenues,
such as those from sale of sludge and reclaimed waters, are
calculated as financial benefits.

       The cost considerations for three major wastewater
management alternatives are discussed below.  Treatment and
reuse systems are not discussed directly since these systems
will often use some combination of the first two options.  The
major difference, of course, will be the revenue value of reused

       The cost considerations of improvements of existing
facilities are too complex to generalize.  The basic questions
of sizing and service area discussed below will obviously affect
costs.  In the case of excessive infiltration/inflow, a sewer
system evaluation will determine cost-effective sewer rehabil-
itation measures.  Another part of the cost-effectiveness analysis
will also recommend measures to reduce wastewater flows and
conserve water.

       Cost considerations vary for central treatment, land
application and on-site facilities.

       (1) Centralized physical/biological/chemical treatment costs.
Wherever collection of wastewater and central treatment is included
in an alternative--as in treatment and disposal, treatment and land
application, or treatment and reuse—five major factors will affect
the monetary costs of the system:  (a) type of treatment technology
selected,  (b) the volume and makeup of incoming raw wastes, (c) size
of the treatment facility,  (d) service area, and (e) staging of con-
struction.  Site conditions for the treatment works, prescribed
effluent limitations and reliability requirements (i.e. extra backup
facilities required if there is a fresh-water intake downstream)
may also contribute to monetary costs.

       A centralized treatment system includes the treatment plant;
interceptors and trunk sewers, if separate populated areas are
linked; pumping stations and force mains (which move wastewater
by pressure rather than gravity) used for connections between
natural drainage basins; and the local sewer facility, which
includes house connections, laterals, and submains.  Of the total
cost of a gravity flow sewerage system, lateral sewers ususally
account for between 30 and 60 percent, larger pipes between
20 and 40 percent, and treatment plants between 20 and 40 percent.

       The most cost-effective system will optimize the costs
and performance of treatment plants, sewers, package plants
and on-site disposal to produce the best overall system for
a region.  For example, potential economies of scale in plant
construction and operation must be weighed against the rising
costs of linking up separate populated areas by interceptors
and force mains to create regional system.

       (2)  Land Application Costs.  The monetary costs of
disposing of treated effluent on land include the costs of
conventional primary or secondary treatment, whichever is
required, as well as the cost of land, facilities to transport
and store wastewater, spray irrigation equipment or other land
application devices, and underdrains to recover renovated water.

            Land treatment offers many cost advantages.  A very
advanced degree of treatment is possible without generating any
chemical sludges or using chemicals or activated carbon.  Recycled
water, nutrients and crops grown in the treatment area have market
value.  Large open space areas are preserved with potential for
multiple recreation use during the nonirrigation season.  Land
appreciates in value and represents a future resource to the
community.  Operating costs can be less than for other teriary
processes.  If land application can be a substitute for secondary
treatment, there could be substantial cost-savings.

       There are disadvantages, however.   Large land areas
are required,  ranging from 100 to 600 acres per mgd of capacity.
In addition, large ponds and other storage facilities are needed
to store effluent when the grounds are frozen.

       (3)  On-Site Facility Costs.  The cost of on-site
waste disposal facilities—septic tanks,  various means of
upgrading septic tanks, mounds, and other facilities,  as well
as holding tanks—figures in the cost-effectiveness analysis
when a community must decide whether or not to include outlying
sites in a sewage service area. (The funding of individual  systems
is now eligible for federal funds under certain circumstances,
as described earlier.)  The question often is:   Is it cheaper
for a source to use on-site disposal, or be sewered?

       In addition to costs, the effectiveness of the on-site
system must be calculated.  Soil conditions are a key factor in
costs of on-site disposal.  If soils are  not conducive to good
subsurface disposal, on-site disposal costs go up.  Sewer service
may be appropriate even if more expensive than on-site,  because of
improved ground water quality and elimination of system failure.
Typically, septic tank costs include the  tank,  houseline,  distri-
bution box, absorption field, operation and maintenance (pumping
and inspection) and cost of financing.  Per capita costs could be
low, such as $60 per year, or as high as $150 a year,  depending on
system needs.

Evaluating Nonmonetary Considerations

       After monetary costs have been calculated for each
major waste management alternative, nonmonetary factors of
each are expressed quantitatively, if possible, or more likely,
described qualitatively, and weighed against monetary costs.
Monetary costs are the most important aspect of cost-effectiveness
calculations and will determine a waste treatment choice unless
the nonmonetary factors have major consequences.  Nonmonetary
factors include:

       Primary and secondary environmental effects.  Primary
effects are those directly related to location, construction,
and operation of the project.  Negative effects might include
impacts on ground and surface waters, air pollution from in-
cinerated sludges, odors, loss of open space, noise, and ero-
sion.  Primary beneficial environmental effects include re-
charged groundwaters from land application, restored soils,
and irrigation water from parks.  Secondary effects are in-
direct or induced changes in population, economic growth,
and land use, and the environmental effects resulting from
those changes. For example, unwanted development pressures
from locating interceptors in open areas or including less-
developed areas in a service district, may result in air
pollution from induced traffic to new suburbs or shopping
centers, excess energy consumption, and water pollution
from urban runoff in newly paved areas.

       Reliability and flexibility.  A reliable system is one
that meets its design efficiency with the anticipated O&M costs
and effort.  A flexible system has the capability to change to
meet future needs—to expand the size of the treatment system,
extend sewers to needed areas, upgrade the level of pollutant
removal, or switch to wastewater reclamation and reuse.

       Implementation factors.  A system likely to be approved
by local, state, and federal governments, adequately financed,
and meeting all legal requirements has the greatest chance of
being carried out.  Local politics, the amount local funding
required, prevailing state and local public health, water rights,
water supply, and land-use laws are key implementation factors.

Financing the Selected Alternatives

       EPA has a great deal to say about how each alternative
treatment will be financed and the local attractiveness of each.
It provides federal grants to finance:

       •  75 percent of construction costs of the most cost-
          effective wastewater treatment system, but no O&M

       •  85 percent of construction costs of an innovative or
          alternative wastewater treatment system, if it is not
          more than 15 percent more expensive than the most co£t-
          effective solution.  Land application, wastewater re-
          clamation and reuse and other resource recycling tech-
          niques, cost-saving, and efficiency-increasing tech-
          nology are included in this definition.

       •  privately owned individual systems for one or more
          homes and commercial establishments, if the grant is
          applied for by a public body that certifies public

          ownership is not feasible and promises that the treat-
          ment works will be properly operated and maintained.

       •  in states where the population is at least 25
          percent rural, 4 percent of a state's allocation
          of federal construction dollars is to be set aside
          for alternatives to conventional sewage treatment
          works for municipalities with less than 3,500 people.

       The remaining construction costs and O&M costs must .be
financed by state and local governments.  Federal law requires that
user charges be assessed against all users of a federally funded
system to ensure that all users pay their proportionate share of
O&M costs.  Additionally, industrial users must pay their share
of construction costs, although Congress has put this industrial
cost recovery provision into abeyance for 18 months while EPA
studies the efficiency and need for such industrial charges.


       Construction of sewage treatment facilities most often
brings two types of impacts--primary and secondary—which can
be both positive and negative.  Some negative impacts are in-
evitable, but most can be avoided or mitigated if recognized
early enough in the facilities planning process.  Federal law
requires grant applicants to identify negative impacts and
make efforts to mitigate them.

       Primary impacts are those that can be attributed directly
to the development of the proposed facility.  They include:
environmental impacts associated with construction (erosion,
sedimentation, noise); economic impacts associated with con-
structing and operating the facility (capitalization, O&M costs,
user charges, etc.); and social impacts, such as traffic disrup-
tion during construction or decline in the property value of
land adjacent to plant.

       Secondary impacts are those resulting from indirect or
induced changes in community land-use patterns, population
growth, and subsequent environmental quality.  They are often
long-term and far more difficult to identify.  Whereas primary
impacts are directly related to the construction process and
specific construction activities, secondary impacts result from
the placement, sizing, and staging of interceptor sewers and the
provision of reserve capacity in them.

       Consideration of primary and secondary impacts and miti-
gating measures during the planning and construction of sewage
treatment facilities is required by federal law, specifically
the 1972 Federal Water Pollution Control Act Amendments (Section

511(c)(l)), which provides that the National Environmental Policy
Act requirements for Environmental Impact Statements apply to
the Construction Grants Program.

       Other federal environmental laws administered by EPA
and other agencies (i.e., Clean Air Act, Endangered Species Act)
also apply to the Construction Grants Program.  These laws re-
quire EPA to make sure that proper steps are taken to mitigate
adverse impacts on specific natural and cultural resources such
as floodplains, aquifers and water recharge areas, and archae-
ologic or historic sites.

How are the appropriate mitigation measures chosen?

       There are usually several possible ways to mitigate a
particular primary or secondary impact.  It is important to
select the mitigation measures that best meet a community's
particular needs.  Several key questions should be asked in
the process:

1)  What mitigating techniques are available?

                        Primary Impacts

       Noise, odor, erosion, and sedimentation are generally
short-term impacts and relatively easy to identify and mitigate.
The first step  in mitigating these primary impacts involves
careful site selection and design based on a detailed inventory
of site topography and geology, compact site planning, odor and
aerosol sources, noise sources, and maintenance and access
requirements, among others.

       Careful  control over construction activities is the
second step—careful timing of construction activities,
immediate restoration of disturbed areas, and the periodic
wetting of unpaved surface to minimize dust, for example.

       A third  mitigating step includes operating procedures
such as noise control measures within the plant and adequate
treatment and disposal of sludge to minimize odor.

                       Secondary Impacts

       Secondary impacts related specifically to the construc-
tion of sewage  treatment and collection facilities tend to be
long-term consequences that are usually difficult to predict.
In fact, distinguishing future community changes specifically
induced by the  construction of a particular facility from those
changes that would have occurred naturally over time often in-
volves more soothsaying ability than technical skills.  Also,
because efforts to control secondary impacts have been initiated
only in recent  years, little documented experience is yet avail-

able to indicate how effective any proposed mitigation measure
can be in the long run.

       EPA has identified a range of possibilities  for miti-
gating secondary impacts.  The list includes:

       •  Phasing and orderly expansion of sewer  service.

       •  Project changes (reduction in plant capacity).

       •  Improved land-use planning.

       •  Better coordination of planning among communities
          affected by the project.

       •  Sewer use restrictions.

       •  Modification  or adoption of environmental programs
          or plans (i.e., state air quality maintenance plans).

       •  Improved land-management controls to protect water
          quality (i.e., erosion control or floodplain manage-
          ment ordinances).

 2)  Howfeasibly can these measures be implemented?

       In many cases, primary impacts can be handled routinely
 by  the facility design  or construction contractor through
 careful site design or  environmentally sound construction prac-
 tices.  Secondary impacts, on the other hand, often can be miti-
 gated only by enforcement of land-use regulations or management
 practices.  It is therefore important for a community to assess
 the political feasibility of adopting or modifying  land-use con-

       In situations where state or local land-use  controls,
 such as floodplain ordinances, Air Quality Maintenance Plans, 208
 Water Quality Management Plans, or comprehensive  growth-management
 plans are in effect, it may be relatively easy to initiate control
 of  secondary impacts simply by enforcing existing ordinances.  But
 in  situations where adequate 'land-use controls do not exist (which
 is  more often the case), a community may have to  adopt new measures
 to  successfully mitigate secondary impacts; if the  community resists
 the concept of land-use controls, this can be difficult.

       Timing is a key  element in successful implementation of
 mitigation measures.   Impacts should be identified  very early in
 the planning process and a range of mitigation techniques should
 be  considered.  For obvious reasons, once considerable time and
 money have been invested in the development of a  Facilities Plan,
 it  becomes increasingly difficult to make design  changes.

       Another consideration affecting the feasibility of
given mitigation measures is the implementation costs to
the community.  Some mitigating measures, such as reduction
in facility size or service area, may actually result in
decreased project costs.  Others may increase the total cost
of the project by a relatively small margin or have no cost
effect at all; siting the facility to use prevailing winds
as a natural odor control, for example, or using existing
trees on site as a natural screen.  Of, if the additional
costs for a particular mitigating measure are significant
(i.e., costs for extending outfall an extra 100 yards),
they may be considered eligible for a federal grant; hence,
the community share of these costs would be minimized.

       However, some mitigating measures (for example, acquiring
environmentally sensitive areas to adequately-regulate future
development) may require community expenditures that are not
covered under the construction grant.  Communities are often
unwilling or unable to finance significant additional costs and
most often will seek a less costly alternative.

3)  Who has responsibility for implementation?

       An equally important consideration is who will have
ultimate responsibility for implementing various mitigation
measures.  In most situations, a number of government agencies,
organizations, and individuals may be involved; it is there-
fore important that their respective roles be identified and
that the wastewater management agency have the capacity to
coordinate these independent efforts to ensure that the
variety of potential impacts is successfully mitigated.

4)  What authority and capabilities are available to ensure

       Among other requirements, the Step 1 plan must show that
those designated to implement the plan have the necessary legal,
financial, institutional, and managerial authority and resources
to ensure construction, operation, and maintenance.  This means
that the plan must demonstrate that the authorities identified
to implement specific mitigation measures have the necessary
qualifications to do.

What is the Role of EPA?

       EPA has the ultimate responsibility and authority for
ensuring that appropriate mitigation measures are implemented.
No grant is to be issued unless EPA is satisfied that the
proposed facilities plan has addressed any and all contro-
versial environmental issues.  EPA has developed a series of
regulations and guidelines that amplifies the agency's policy
on mitigating secondary impacts of sewage treatment facilities.

       The EPA Regional Office has responsibility  for ensuring
that potential primary and secondary  impacts are considered
by the grantee from the outset of the  facilities planning
process.  If the potential impacts appear significant and
adverse, EPA may require that a  full  EIS  (rather than an
environmental assessment) be prepared  to accompany the Step 1
plan.  The Step 1 plan must then include adequate  measures
to mitigate the projected impacts.

       In some cases, the EPA Regional Office may  choose to
condition a Step 2 or Step 3 grant on  the stipulation that
specific mitigating measures be  adopted by  the communities
involved. Grant conditioning, however, may  not always be the
best solution. Although some communities may use EPA inter-
vention as a convenient scapegoat to  justify passage of
necessary land-use controls, other may resent federal inter-
vention into what they consider  "home  rule" decisions and be

        In fact, the conditioning of grants  on the  adoption
of  land-use measures raises a series  of legal and  political
questions about how far EPA can  go  in controlling  what are
basically local land-use decisions.   Also,  if not  properly
instituted, grant conditions can create a considerable admin-
istrative burden within EPA Regional  Offices responsible for
overseeing  local adherence  to the conditions.  Consequently,
most grant  conditions that have  been  imposed have  been written
in  ways  that  reinforce existing  state or  local legislation,
leaving  the adminstrative responsibilities  with the local
government  involved.

                          PART  II

What Are the Broad Requirements  for Public  Involvement Under
the Clean Water Act?

       Recognizing the  federal environmental programs would
need strong grass-roots support  to be effective, the 1972
version of the Clean Water Act contained  a  broad directive
for public involvement  at all levels of water quality decision
making.  These requirements  are  found  in  Section 101(e):

       Public participation  in the development,
       revision, and enforcement of any regula-
       tion, standard,  effluent  limitation, plan,
       or program established by the Administrator
       (of the Environmental Protection Agency) or
       any State under  this  Act  shall be  provided
       for, encouraged, and  assisted by the
       Administrator and  the States.   The Admin-
       istrator, in cooperation  with the  States,
       shall develop and  publish regulations
       specifying minimum guidelines for  public
       participation in such processes.

What's In It For You?   Why Get Involved?

       Let's face  it:   A  sewage  plant  lacks the public appeal
of  a new park, town hall, or highway.  The  average citizen
has little,  if any,  interest in  sewage treatment processes
and problems, unless they pose some personal threat to him,
his family,  or his community.  A foul-smelling treatment
plant  in the neighborhood, sewage seeping up in the street,
or  escalating treatment costs will grab his attention. But
not planning.  But when you  get  right down  to it, waste-
water  facilities are essential to a community.  They can
significantly enhance or  degrade its environment, depending
on  how well  they are planned.

       Good  planning means more  than just professional
competence.  It means considering a community's character,
its environmental  and social values, and  the attitudes and
desires of  its citizens.  These  qualities can only be
incorporated through concerted efforts to involve the
public in all phases of the  planning process.

       Public participation  makes good sense for several
reasons.  Open discussion and citizen  input can help planners
develop plans that reflect  community values and concerns.
Controversies can be  identified  early  and resolved through
compromise  and open  airing  of  the issues.  Citizens get  a
chance to have a "say"  in how  federal  and local monies are

being spent in their communities.  And public involvement  in
community issues gives participants a stake in the project's
long-term benefits.

               Incorporating public values

       Local residents often have a more intemate under-
standing of particular community problems than the staff
or consultants working on a project.  Their information
is pertinent and up-to-date; they know the community's
values, concerns, and goals; and since they will be living
in the area long after a project is completed, they are in
the best position to decide the future of their community.

                    Better plans

       Public discussion and advice can help the consulting
engineer to fine-tune a facility plan to fit the community's
special circumstances.  Alternative technologies and facility
locations must be explored and their ramifications discussed
and understood.  Citizens can work with the professionals to
identify the range of issues that must be considered and can
alert the engineers to impacts of special concern.

               Assuring reasonable costs

       Virtually all wastewater treatment facilities are
planned and constructed with public money, and therefore
the public has the right and even the responsibility to
participate in determining how that money is spent.
Increasingly, people want to have a say in how federal
dollars will be used in their communities.  Across the
country, communities have sometimes been wary of accepting
federal or state funds for fear of hidden secondary costs.
Because it emphasizes public participation, the water pollu-
tion control program can foster a working partnership
between the public and government so long as attitudes of
open planning and mutual problem solving prevail.

              Added community benefits

       The real payoff of that partnership may come in the form
of long-term community benefits.  Citizens who participate in
planning a project will develop a sense of continuing respon-
sibility for it.   They will be the ones who will walk the
extra mile to secure added benefits—shorelilne protection,
swimming, boating, biking, and so on—that make the difference
between an ordinary project and an outstanding one.

                      Voter support

       Most communities will need voter  authorization for
municipal or pollution control bonds  to  pay the local share
of project costs.  Voters who have taken part  in planning
and who feel they've had a chance to  influence the decision-
making process will most likely  support  local  financing plans
and encourage their friends, neighbors,  and community organ-
izations to do the same.  People attending public hearings
to learn about the project for the first time as a bond elec-
tion approaches will probably not be  so  easily convinced.

               Resolution of controversies

       Controversial issues are  bound to crop  up in facili-
ties planning, particularly in large-scale projects.  It is
far better to debate these issues publicly early in the plan-
ning stages so that reasonable compromises can be worked out;
when the public is kept in the dark,  disagreement often erupts
too late to make changes in the  project  without additional ex-
penditures or delays.  The engineering consultant who is in
touch with community opinion will be  able to foresee contro-
versy and can spend more time working with residents to find
acceptable alternatives.

Which Major Federal Regulations  Give  You Access to the
Facilities Planning Process?

       The requirements governing public participation in
facilities planning are principally derived from two sets of
federal regulations—40 CFR Part 25,  "Public participation in
programs under the Resource Conservation and Recovery Act, The
Safe Drinking Water Act, and the Clean Water Act," and 40 CFR
Subpart E, Part 35.917-l(g) and  35.917-5.*  These regulations
differ both in breadth and specificity.  They can be valuable
tools for you during the facilities planning process, particu-
larly if you meet resistance from "official" participants.  (See
"What Problems Might Be Encountered in Implementation of Public
Participation Requirements?" at  the end  of this chapter.)

       These EPA regulations attempt  to  provide an optimum
blend of general goals and objectives for public participation
(which can be met by any number  of mechanisms  selected by the
grantee) and more specific requirements.  They adopt an active
(as opposed to passive) tone, exhorting  public officials to
seek out and encourage involvement of various  segments of the
public in decision-making.  This activist approach is summa-
rized in the definition of public participation in Part 25:
   The regulations  upon which  this discussion  is based have
   not yet been promulgated and are  in  final stages of appoval
   at EPA. They should appear  in final  form in the Federal
   Register in February.

            Public participation is that part of the
            decision-making process through which
            responsible officials become aware of public
            attitudes by providing ample opportunity for
            interested and affected parties to communicate
            their views.  Public participation includes
            providing access to the decision-making process,
            seeking input from and conducting dialogue with
            the public, assimilating public viewpoints and
            preferences, and demonstrating that those
            viewpoints and preferences have been considered
            by the decision-making official.

       The general public participation requirements of Part
25 apply to:

            •  EPA activities such as rulemaking,
               issuing permits and informational
               materials, significant strategy and
               policy guidance, and decisions to dele-
               gate program activities to state control;

            •  Developing and implementing activi-
               ties supported by EPA grants to state,
               interstate and substate agencies;  and

            •  State administration of certain programs
               for which responsibility has been dele-
               gated by EPA: the Construction Grants
               Program, State Hazardous Waste Program,
               NPDES Permit Program, Dredge and Fill
               Permit Program.

       Part 25's general public participation requirements
therefore govern all Construction Grants Program activities.

       Specific additional requirements for public participa-
tion in facilities plans are found in 40 CFR Subpart E, Part
35.917-5,--Grants for Construction of Treatment Works.

       Other requirements are found in specific program regula-

            •  40 CFR Subpart E 35.915{d):  state priority
               system and project priority List;

            •  40 CFR Subpart E, Part 35.928-1:  approval of
               Industrial Cost Recovery System;

           •  40 CFR Subpart E, Part 35.929-2(e):  General
              Requirements for all User Charge System;

           •  40 CFR Subpart E, Part 35.940-1(t):  Allowable
              Project Costs;

           •  40 CFR Subpart E, Appendix A, Part 8(3):
              cost-effectiveness analysis guidelines;

           •  40 CFR Subpart F, Part 35.1033:  state
              management assistance grants; and

           •  40 CFR Subpart G, Part 35.1507-8, 1533:
              grants for Water Quality Planning Management
              and Implementation.

       The requirements recognize essential differences in the
levels of participation to be expected for different kinds of
projects.  They therefore set up two-tiered approach to public
involvement in facilities planning, specifying minimum require-
ments that virtually all construction grant recipients must meet
and some additional requirements to be met only by projects that
appear to justify a more intensive effort.

              The Basic Public Participation Program

       All Step 1 projects awarded after the date of promulga-
tion of these regulations must meet basic minimum requirements
for public involvement.  Step 1 projects begun before that date
will proceed according to previously approved work plans.   If
these old Step 1's come in for significant grant amendments,
however, or decide that an upgraded public participation program
would be useful, appropriate public participation requirements
may be negotiated.

       The regulations describe a Basic Public Participation
Program (BPPP), which is the minimum standard for projects ex-
cept those that the EPA Regional Administrator determines  in-
volve only minor upgradings of treatment works or minor sewer
rehabilitation.  But even those minor projects are not exempted
from a required public hearing and public disclosure of costs.
Any exemptions from the BPPP must be decided in a public forum.
The Regional Administrator must issue a notice of intent to
waive public participation requirements and must allow 30  days
for public response that might indicate serious local issues
that should override the proposed waiver.

       To meet the requirements of the basic program a grantee

            1.  develop a public information program designed
to bring about public involvement from the earliest stages of
the decision-making process.  This program must:

                •  be a continuing program that provides
                   policy, technical information and assis-
                   tance, and that highlights significant

                •  include the creation of one or more
                   central collections of important reports,
                   studies, plans and other documents re-
                   lating to significant decisions or con-
                   troversial issues. These collections
                   should be housed in convenient locations
                   such as public libraries;

                •  include the development and maintenance
                   of a mailing list focused on the publics
                   that are or should be interested in the
                   facilities planning process.

            2.  A program for consulting the public that begins
with the selection of the professional consulting engineer and
the Plan of Study and continues throughout the facilities plan-
ning process.  Grantees must provide for early consultation
preceded by timely distribution of information.

            3.  The Plan of Study submitted with the Step 1
grant application must contain an outline of the public
participation program that the grantee plans to follow
throughout Step 1 process--including:

                •  a description of the consultation and
                   information techniques to be used;

                •  the staff and resources to be devoted
                   to it;

                •  a schedule for proposed public partici-
                   partion activities;  and

                •  a description of the publics that will
                   be targeted for involvement.

       Because the Plan of Study must be submitted before the
Step 1 grant award and is not funded by EPA,  a more extensive
(although still brief) public participation workplan must be
submitted to EPA no later than 45 days after the Step 1 grant
award.  In this workplan, the staff and budget for public par-
ticipation are to be allocated to categories of activity;
specific consultation points where responsiveness summaries
(see below) will be prepared are to be noted; and the method
of coordinating the Section 208 public participation program
with the facilities planning program is to be described.

            4.  To ensure public  awareness  of  both  the
project and the public participation  opportunities,  the
workplan and  a fact sheet  about  the  project are  to  be widely
distributed to  interested  groups and  individuals.   The  fact
sheet should  contain information  describing  the project, the
staff for  the project  (including  the engineer and  the grantee
staff contact)  and any preliminary estimates  that  are avail-
able concerning additional  per household  costs  for  upgrading
sewer service  in the community.

            5.  The grantee is  specifically required  to
"consult" with the public in  the  early  stages when  the grantee
and consultant begin  assessing the  current and future situa-
tions and screening alternatives  (but before selecting the
actual alternatives  to be  evaluated  during cost-effectiveness
analysis). A reponsiveness summary must be prepared and distrib-
uted after  this public consultation.*

            6.  A public  meeting must be held when  the cost-
effectiveness  analysis of  the  alternatives has been largely
completed,  but before  the  alternative  plan has  actually  been
selected.   This  consultation process  must also be accompanied
by a responsiveness summary that  is distributed to the public.

            7.  A public hearing is to be held in the community
to discuss the recommended alternatves prior to the adoption of
the facilities plan.

            8.  A final responsiveness summary and an evaluation
of the effectiveness of the  public participation program are to
be included  in the  facilities plan  that  is submitted to EPA
(or the state) for final approval.

        The Full-Scale Public Participation program  (FSPP)

       For complex projects of important community significance
that justify  a more intensive public involvement effort,  the
regulations outline a  Full-Scale   Public  Participation  (FSPP)
program  comprised  of  all  elements of  the  basic program plus
a few additional ones.   The Regional Administrator must order
a full-scale public participation program under  the following

           •  when EPA prepares or requires the
              preparation of and  Environmental
              Impact Statement;
   A variety of consultative mechanism may be utilized to meet
   this requirement—workshops,  public  meetings,  task forces,
   etc.  Some of  these  mechanisms are described in the companion
   volume to this book entitled Municipal Wastewater Management;
   Citizens Guide to Facility Planning.

            •  where advanced wastewater treatment
               (AWT) is required to meet stringent,
               effluent standards; (AWT will be defined
               by EPA guidance.  The currently accepted
               definition is treatment requirements of
               less than 10 milligrams of BOD per liter
               plus nitrogen removal.);

            •  where the Regional Administrator determines
               "that more active public participation in
               decision-making is needed because of the
               possibility of particularly significant
               effects on matters of citizen concern, as
               indicated by one or more of the following:"

               - changes in land use and/or impacts
                 on environmentally sensitive areas;

               - significant increases in treatment
                 capacity, amount of sewered area, or
                 construction of new treatment and con-
                 veyance systems;

               - substantial increased total cost to the
                 community or to users;

               - significant public controversy;

               - significant impact on local population
                 or economic growth; and

               - substantial opportunity for implementation
                 of innovative or alternative wastewater
                 treatment technologies or systems.

       In addition to meeting the public participation require-
ments of the basic program, a grantee with a full-scale public
participation program in its community is required to:

            1.  Hire or designate a public participation
coordinator who will be responsible for carrying out the public
participation workplan throughout the facilities planning  process.
The coordinator can be a member of the grantee staff, a staff
person hired by the grantee's consultant, or a representative of
a public interest group within the community.   (For example, a
local civic leader with grass-roots ties throughout the commu-
nity may make an ideal public participation coordinator.)

            2.  Establish an advisory committee shortly after
acceptance of the Step 1 grant award.  Regulatory requirements
establish the membership, responsibilities and resources of this
committee.  These requirements were designed to ensure that the
advisory committee encourages the continued attention of a core
group of informed citizens—in a manner that complements other

public participator! mechanisms—without  becoming  the  sole mech-
anism for public  involvement.   Membership requirements  also are
designed to ensure that people  who  do  not normally have regular
access to the decision-making process  be can  singled  out for
service on advisory committees.

       Some of  the most important requirements  that apply to
advisory committees are:

            •   Affirmative  action is required on  the
                part of the  grantee  to  ensure  a  balanced
                membership,  consisting  of substantially
                equal proportions of private citizens,
                representatives  of public interest groups,
                governmental officials, and citizens with
                substantial  economic interests.  Private
                citizen representatives should not have
                any direct  financial gain or loss  at stake
                greater than that of the  average homeowner,
                taxpayer, or consumer.  The public interest
                groups should be organizations acting  out
                of general  concern for  the area  and should
                not reflect  the  direct  economic  interests
                of their membership.

            •   The grantee  is required to designate (or have
                his contractor designate)  a staff  contact
                responsible  for  day-to-day liaison and
                coordination between the  advisory  committee,
                the grantee  and  the  grantee's  consultant.
                This  staff  contact may  or may  not  be the
                public participation coordinator.  In  either
                case,  the staff  contact must be  located  in
                the project  area, not based in another city.
                The staff contact must  be identified as  a
                budget item  in the grant  agreement.

            •   The grantee  must establish an  operating
                budget and  identify  the professional and
                clerical staff time  that  will  be made
                available to the advisory committee.

            •   Reasonable  out-of-pocket  expenses  of advisory
                committee participation will be  reimbursed by
                the grantee. The total dollar amount  and the
                actual items eligible for reimbursement  will
                be established by the grantee  after negotiation
                with  the advisory committee.

            •   The advisory committee  may on  the  request of
                the grantee  assume responsibility  for  the
                overall public participation program.  The
                committee also will  make  written recommenda-

               tions to the grantee, as appropriate, on major
               decisions or upon the request of the grantee.

            •  The advisory committee is reasonably indepen-
               dent:  it may select its own chairperson,
               adopt its own rules, and schedule and conduct
               its own meetings.  These meetings are to be
               open to the public.

            •  Advisory groups are urged to conduct public
               participation activities in conjunction with
               grantee, and to solicit outside advice.  They
               are encouraged to form subcommittees and ad hoc
               groups or task forces in order to continually
               expand committee membership and to draw on
               other resources outside the membership.

       Many other specific requirements that establish the
roles and responsibilities of advisory committees are spelled
out in the EPA general regulations on public participation
(Part 25).  You should read them over if you want to understand
this critically important component of the full-scale program.

            3.  The full-scale public participation program
requires that a public meeting be held early in the facilities
planning process at the time when current and future situations
are being identified and initial alternatives are being screened.
(The basic public participation program simply requires an un-
specified "consultation" at this point.)  After this meeting the
grantee is to prepare and distribute a responsiveness summary
(see below).

            4.  EPA has developed a technical training package
for advisory group members and local officials, which the grantee
should arrange to have provided to the advisory group early in
the facilities planning process.

      Other public participation requirements applicable
             to the basic and full-scale programs

       Many other requirements apply to how public participation
programs are carried out; some address the important issues of
compliance and enforcement.  To completely understand the public's
right to involvement, you must read carefully the relevant regu-
lations.*  Some of the most important ones are listed here:
   The regulations are listed in Appendix A.   They may be
   obtained from the Regional EPA office, or  may be located
   in the appropriate Federal Register volume in public
   libraries, or by writing to the Government Printing Office
   in Washington, D.C.

            1.  Agencies are encouraged  to provide free copies
of important documents to the public.  When  not available for
free, however, the charges for such documents  should not exceed
prevailing commercial copying costs in that  area.  In other words
if you could go to a commercial copier and have a document copied
for $.25 a page, a local government grantee  or his consultant
should not charge you $2 a page to copy  that document.  If you
come up against apparently excessive charges for copies of
information, you should request an explanation from the grantee
or consultant.  If such explanation is not satisfactory, you
may wish to complain to the EPA Regional Administrator (or
the State Agency) regarding the adequacy of  the grantee's public
involvement effort.

            2.  In an attempt to define what constitutes
adequate public notification of major decisions for which
an agency is seeking public input, Part  25 specifies that
responsible agencies must provide written notice to those
people who appear on the required mailing list or applicable
portions of that list, as well as to the media.  To ensure
that notice of impending decisions is provided far enough
in advance to allow meaningful public response, such notice
is to be generally not less than 30 days  (except in the case
of public hearings or meetings).

            3.  All public hearings on facilities plans (or
any other decision covered by Part 25) must  meet certain
minimum requirements:

                •  notice mailed in time to  be received
                   by potential participants 30 days prior
                   to the date of the hearing  (except in
                   emergency situations possibly posing
                   imminent danger to public health);

                •  the notice is to contain  information
                   on the issues to be discussed at the
                   hearing, and any tentative  derminations
                   that have been made,  as well as information
                   on the location of relevant documents;

                •  relevant documents must be  available to
                   the public 30 days before the hearing;

                •  hearings must be held at  times and
                   locations that will encourage public
                   attendance and involvement;

                •  time must be reserved for unscheduled
                   testimony during the  hearing.  Decision-
                   making agencies are encouraged to hold
                   a question-and-answer period before public
                   presentations begin at the  hearing;

                •  a complete hearing record is to be
                   prepared and made available at no more
                   than cost to anyone who requests them.

            4.  Public meetings requirements are somewhat less
formal than those of public hearings.  They are subject to the
same notification requirements however.  Meetings must also be
held in locations and at times that will encourage public in-
volvement.  The notice requirement for public meetings is also
30 days.

            5.  Responsiveness summaries are a major tool
developed by EPA to assure not only that the public is asked
for its input, but that the asking agency in fact responds to
the input it receives.  The responsiveness summaries, required
at specific points in the facilities planning process by regu-
lation  (and when specified by the public participation work-
plan), will be used by the state agency and the EPA Regional
Office  to determine the adequacy of the public involvement
effort.  They must contain the following information:

                •  the public participation activity con-
                   ducted ;

                •  the issues on which the public was con-

                •  a summary of the public views;  and

                •  the Agency's specific responses to the
                   public views (modifications to the pro-
                   posed, action or explanation of why the
                   public views were rejected).

       An evaluation of the public participation program must
be submitted by the grantee as part of the final responsiveness
summary at the conclusion of the facilities planning process
when the facilities plan is submitted to the state or to EPA
for approval.  For full-scale programs that have an advisory
committee, a separate evaluation from the committee should
accompany the responsiveness summary.

How Will Public Participation Regulations Be Enforced?  Who
Will Enforce Them?

       Responsibility for ensuring compliance with public par-
ticipation regulations will fall to either the EPA Regional
Office or to the state water quality agency (in states where
tha-t agency has been delegated the management of the construc-
tion grants program).  The reviewing agency must analyze the
public participation outline (a component of the Plan of
Study)  before it ever awards the Step 1 grant to be certain

that there  is a reasonable  expectation of  meeting  the public
participation requirements during  the  facilities  planning
process.  No grant  is  to  be awarded  unless  EPA  is  satisfied
that these  requirements have  been  met.   Even in  the case of
a delegated program,  EPA still  has the responsibility for
final award  of  the  Step 1  grant. If  you  are concerned  that
public participation will be inadequate in your community,
you will  first  make  that  case  to the state agency, if it is
not responsive, you  will wish  to contact the  EPA  Regional
Administrator and make  your  point  at that level.

       EPA  (or the  state agency) is required  to evaluate
grantee  compliance  with public participation requirements at
various  stages when the  Facilities Plan  is in  progress and
after it  is completed.   Using  the  workplan, responsiveness
summaries and other  available  information,  the overseeing
agency must judge  the adequacy  of  the  public  participation
effort.   At  a minimum, this evaluation must take place  both
during  a mid-project review that EPA  conducts in conjunction
with  its  regular oversight  activities, and  at the end  of the
facilities planning  process.  If  EPA  or the state determines
that  public  participation activities   have not been  adequate,
the reviewing  agency is required to  take whatever actions it
deems appropriate  to mitigate   the  failures  and  prevent them
from  being  repeated  in  the future.  The enforcement action
that  EPA  is required to take is fairly minimal—it must
simply impose more  stringent requirements on  the  grantee
for the  next funding cycle.   But there are much  more power-
ful enforcement  actions available to  EPA:   it  may  terminate
or suspend  the grant, withhold  payments,  and  ask  for  its
money back.   It will be up to you, the concerned  citizen,
to see  that  appropriate enforcement actions beyond  the mini-
mum are  in  fact taken.

How Will  These Regulations Affect  What Happens in Your

       The  federal   regulations  described above simply provide
a framework for the  development of a public participation pro-
gram.   In  fact,  given   the  number of  institutional actors in-
volved,  the only  thing  you can  be  certain the regulations will
accomplish  is providing some minimum level  of funding eligibil-
ity for public participation activities during the facilities
planning  process.

       The  regulations  will  also  establish a skeletal outline
of a  public participation  program  for your community. How  that
outline  is  fleshed  out  will be  partly  up to  you  and  partly up
to the local government  recipient  of the Step 1 grant. You will
want  to work  with  the grantee  in your  community to ensure that:

            • the   public participation program  imaginatively
               meets the needs  of  your community;

            •  the significant publics in your community in
               fact participate in the facilities planning

            •  the publics that are asked to be involved are
               sufficiently informed of the issues to partici-
               pate effectively; and

            •  the views of the public are listened to and
               responded to by the grantee and his consul-

How Should a Public Participation Program Be Developed?
What Will Be Its Major Components?

       Designing a public participation program is (and should
be) the responsibility of the local government grantee, but the
informed citizen leader can be an invaluable resource.  In fact,
EPA regulations require consultation with the public in program

       As noted earlier in this chapter,  a grantee entering
the Step 1 planning process must provide  a brief outline of
a public participation program in its Plan of Study.  EPA
has emphasized the brevity of this outline because the devel-
opment of the Plan of Study is not eligible for construction
grant funds.  Nonetheless, this early outline will be extremely
important since it provides the basis for funding of public
participation activities during the Step  1 process.  It must
contain enough information to allow EPA or the state agency
to decide whether the proposed public participation program
is adequate.  As the grantee is required  to consult with the
public during the development of the Plan of Study, you may
have an opportunity to influence the course of the facilities
planning process at this point.

       No later than 45 days after the Step 1 grant award,
a more detailed-though still brief—public participation
workplan must be submitted to the reviewing agency.  The
local grantee is specifically directed to distribute the
workplan to interested groups.  Although  the brief outline
in the Plan of Study is subject to public consultation, the
workplan need only receive such scrutiny  as is given by the
advisory committee.

       If you believe that the public participation program
outlined and approved in the Plan of Study is inadequate, the
workplan developed after the Step 1 grant represents a second
chance.   A revised program submitted as part of the workplan
may even provide the basis for a grant amendment to increase
the dollar resources spent on public participation in Step 1

       Tables 2 through  8  in Appendix  B are designed to
help you to develop a Plan of  Study  outline and  a workplan.
Table 2, a 201 Public Participation  Planning Guide, divides
the important community  issues of  the  construction grants
program into 26 separate decision  points, beginning before
the Step 1 grant award and ending  after the Step 3 grant
award.  Issues to be resolved  at each  decision point are
briefly identified and discussed,  public participation
requirements are listed, and optional, additional activities
are recommended.

       Tables 3 through  8  provide  model public participation
outlines  (required during  the  Plan of  Study) and workplans
(required 45 days after  grant  award) for both the basic and
the full-scale programs. You may wish  to encourage the grantee
in your community to use some  version  of these model workplans
in its submissions to EPA. (Please note that these workplans
were designed for communities  of roughly 5,000-10,000 people.
Your public participation  workplan may vary considerably
depending upon the size  of your community and the scope of
your project.)

       When you become  involved in developing the public
participation workplan,  you will find  that you must address
three decisions at the  outset:

            1.   identifying major  community issues to be
addressed during  facilities planning,  including  among others:

                •  growth, land-use  issues;

                •  sensitive environmental areas;

                •  costs to  the community and per household;

                •   industrial  discharge problems (pretreatment
                   needs,  extra capacity needs,  etc.).

            2.   identifying  the publics  in your  community that
should be particularly  targeted for  public involvement; and

            3.   identifying  appropriate mechanisms for your
community in  developing  a  public participation program.

       When these  initial  decisions  are made, the key issues
remaining will  involve  setting up  opportunities  for public
participation in  your  community.   The  factors that affect
these opportunities will be:

            1.   identfying appropriate staff and budget
resources to  ensure  that public participation activities
take place;

            2.  identifying and scheduling of decision points
where it will be most appropriate to seek public involvement
in the decision-making process;

            3.  identifying and developing information,
materials and training opportunities to facilitate public

       The important facilities planning issues you are likely
to encounter in your community are discussed throughout this
manual (Please refer to Table 2 for a further discussion of
the issues and their relationship to the public participation
program. )

       Two other major decisions determine the scope of the
Step 1 public participation program—identifying the public
and identifying the mechanisms to reach these publics.

                     Who is the public?

       Government officials who grapple with the requirements
of 101(e)—or other mandates for public participation—often
begin with the question, "How do I identify the public?"

       It can be argued that there are four publics:  (a) the
general  public, popularly known as "the man in the street";
(b) the  organized public, whose citizen activities are chan-
neled through organizations; (c) the representative public,
made up  of elected and appointed officials; and (d) the
economically concerned public—those individuals and insti-
tutions  whose interests may be affected, adversely or favor-
ably, by water quality policies and decisions.

       Each of these publics obviously has a right to express
itself on all issues, and their input should be sought at
appropriate times.  The organized public, however, has already
demonstrated its interest in the issues and its determination
to be heard.  All public participation programs should seek
ways to  involve organized publics that have particular power
and interests in the community and that are likely to be
affected by the results of the facilities planning process.

       As you develop a Step 1 public participation program,
you should also be particularly attuned to ways that facili-
ties planning issues touch the interests of publics in your
community not normally involved in water quality issues.

       Major new treatment facilities or extensive expansion
of interceptor sewers will affect all segments of a community
in some  manner.  Certainly the local share of financing and
operating and maintaining the facilities will be borne by the
community as a whole.  Some segments of the public, however,

may be more affected  than  others  depending  on the proposed

       Extending  interceptor sewers into an agricultural  area
will certainly concern  farmers  and  ranchers.   Pressure  for  new
residential and commercial growth may push  up land values,
forcing farmlands  out of production because of higher taxes.
When facility planning  contemplates service to rural areas
and/or expansion  of  interceptors  through agricultural or  ranch
lands, farmers, ranchers,  and rural organizations like  the  Farm
Bureau should be  informed  of the  planning and encouraged  to
participate in evaluating  alternatives and  potential mitigation

       Expanding  interceptor lines  to rural areas may also
contribute to deterioration of  the  inner city as  residents,
businesses, and service organizations relocate in the new
suburbs.  Low income  and ethnic populations that  are unable
or  unwilling to move  may be forced  to cope  with dwindling
services and inferior living conditions as  city resources are
redirected to developing suburban areas. Inner-city jobs may
also be affected  as  businesses  shift to the suburbs; inner-
city residents may have to commute  long distances to their
jobs.  Neighborhood  organizations,  labor unions,  and ethnic
groups who will likely  be  affected  by such  a  population shift
should be involved in any  facility  planning that  may induce
significant new suburban growth.

       Potential,  deterioration  of environmental quality
will concern many community organizations and may have signifi-
cant impact on specific segments  of the public.   Potential
air quality deterioration, for  example, will  have special con-
sequences  for the elderly  and the chronically  ill.  Environ-
mental and public health organizations should be  involved in
resolving these issues, as well as  any solid  waste problems
generated by sludge  disposal or degradation of underground
water supplies or wetlands.

       Environmentalists will also  be worried about potential
destruction of natural  areas, animal habitats or  biological
systems.  Bird watchers and nature  photographers  may want to
participate in decisions that affect natural  areas, while sport
fishermen will have  a stake in  preserving aquatic life.   Pro-
fessional fishermen  will have concerns about  potential water
quality deterioration caused by increased urban and construc-
tion runoff.

       Aesthetic  deterioration  that could occur in the  vicinity
of  the treatment  facilities themselves will be of special con-
cern to nearby property owners, neighborhoods, and to civic
and business associations  in the  area.  Early involvement of
these groups as well  as beautification, parks and recreation
organizations may eliminate controversies over location of
the facility and  provide for mitigation of  site and odor

         What Are the Public Participation Tools?

     Public participation can cover a wide range of activities
designed to inform and involve the public.  Most of the mechanisms
of public participation fit into one of three categories, as indi-
cated by the chart below:

Education/Information     Review/Reaction     Interaction/Dialogue*

Newspaper Articles        Public Hearings     Workshops
Radio and TV Programs     Survey              Special Task Forces
Speechs and                 Questionnaries    Interviews
  Presentations           Public Inquiries    Advisory Boards
Field Trips               Public Meetings     Informal Contacts
Exhibits                                      Study Group
School Programs                                 Discussions
Films                                         Seminars

       Some of these mechanisms (workshops, newsletters, coalitions)
can be initiated by either citizens or by public officials.  Others,
however, (public meetings and hearings) remain exclusively with the
powers of public officials.

       Obviously, different mechanisms are used for different
publics. For example, an information program aimed at the
general public should be designed to:

            a.  Generate interest;

            b.  Provide enough information on the legal and regulatory
                framework to enhance public understanding;

            c.  Provide access to planning documents and other
                relevant information;

            d.  Provide information on opportunities for public
                participation; and

            e.  Elicit reaction to potential decisions.
    Katharine P. Warner, "Public Participation in Water Resources
    Planning," University of Michigan, Ann Arbor, 1971.

       In a program  for  the general public,  these points
are listed correctly in  descending  order of  priority.  An
information program  aimed  at the organized public,  however,
would give its greatest  emphasis to the last three  purposes
and, ideally would  include an additional purpose:

            f.   Provide  technical assistance for  citizens
                 groups seeking to effect community  goals and
                 to explore different ways to meet those goals.

       Many citizens organizations  are knowledgeable  about
interpretating statistics, computerized data,  and highly
sophisticated reports. Such groups  should be given  opportunities
to respond to the most up-to-date information about a  given
program.  A program  that makes information public should be
more than merely a device  to communicate decisions  already made.

       As you design a public participation  program that fits
withint  the framework of EPA regulations, be creative  in your
interpretation of  these  regulations.  Certain parts of the regula-
tions may be more  flexible than is  initially apparent.  For example,
both the basic and  full-scale public participation  programs require
public meetings  to  consider the issues raised at  specific decision
points.  A public meeting, however, is simply a gathering of indi-
viduals  to interact  face-to-face.  There are many different kinds
of public meetings.   As  well as different kinds of  institutional
settings under which the meetings are sponsored.

       Even the  apparently rigid structure and roles  of advisory
committees specified by  regulation  sometimes lend themselves to
flexible interpretation.

                  Education/Information Mechanisms

       The educational  tools designed to promote  the  quality of
public understanding of  issues have a special role  to play in
the  Facilities Planning  process. These tools must deal with the
 informational  needs of  both the most and the least  sophisticated
publics  in your  community. These tools will  be used to:

       •  familiarize the  public with the nature  of the water
          quality  problem  being addressed during  the  Facilities
           Planning Process;

       •  apprise  the public of key issues that may be of community

       •  apprise  the public of opportunities for input  into key
           issues;  and

       •  provide  detailed information in lay language on the
           technical  and  political aspects of wastewater management.

       The use of informational tools will be essential to the
conduct of any public participation program—whether conducted
by a local government entity or by a citizen organization.  These
informational mechanisms cannot be the end of the public participa-
tion program, however.  Meaningful public involvement will require
the use of reactive and interactive mechanisms as well.

Public Participation Outline or Workplan

       New public participation regulations require the development
of a public participation outline to be submitted with the Plan of
Study at the time of grant application.  This outline will set
forth budget and staff responsibility as well as a schedule of
proposed activities.  The outline will be revised in the form of
a more detailed workplan after the grant award has been made. In
this workplan resources will be directly related to activities,
specific responsiveness summaries will be identified, and coor-
dinating mechanisms between 208 and 201 planning will be noted.

       The public participation outline and workplan must not
only be thought of as a planning tool, but should also be viewed
as a public involvement tool. One of the most difficult tasks of
the public participation professional is to make certain that the
level of participation is relevant to the interests and needs of
the community and the proposed project.  If the development of
the public participation outline or workplan is viewed as an
opportunity to obtain public input into the scope of the overall
effort, it can be a useful technique for assuring relevance.

       In addition, the public participation outline or workplan
can be a useful public information device.  If presented in a clear
and concise format it can apprise potential public participants of:

       •  issues that have been singled out for particular attention;

       •  participation opportunities;

       •  important project staff contacts.

Mailing lists

       The development of a comprehensive mailing list of all
organizations and individuals likely to be interested in or affected
by facilities planning should be one of the first steps in a 201
Public Participation Program.  It will be required by the new public
participation regulations.  The list should include pubic officials,
business and civic groups, public interest and environmental organ-
izations, and representatives from outside the planning area such as
downstream residents who may have an interest in the project.  The
list should be supplemented throughout the planning process as more
people become aware of the project, attend meetings, and ask for
information. The mailing list will be useful for distributing news-
letters, fact sheets and other information materials and meeting

and hearing announcements,  and for conducting surveys or
widespread public  consultation activities.   Citizen groups
should be involved in  developing such a mailing list, both
for themselves and for the  use of governmental agencies
with public participation responsibility.

News Media

       Newspapers, local magazines, and radio and television
stations reach the general  public and help  to stimulate  in-
terest in the project.  They should be kept informed of  all
items of general  interest.   Key issues should be clarified
and made interesting to news editors and environmental re-
porters through news briefings and special  media events,  such
as a visit  to a discharge point causing pollution problems.

       Except when used to support in-depth feature stories,
the background material prepared for news items should be
brief and nontechnical.  When technical or  complicated in-
formation  is  to be included in an interview or media event,
it should always  be concisely stated in a fact sheet and
included with a brochure and/or background  materials in
a press kit.  Press kits should be prepared for all events
that you hope will be covered by the media.

        In order to use the media effectively you should
consider undertaking the following activities, early in
the Facilities  Planning Process:

        1)   Visit  media offices at the beginning of the process.

            (a)   identify key personnel responsible for covering
            stories that might be related to the project.

            (b)   learn media requirements for stories—dead-
            lines, filming requirements, requirements for
            public announcements.

        2)   Hold background briefing for media personnel  iden-
            tified.  Learn from media personnel what kinds of
            issues are likely to receive media attention.

        3)   Develop a media plan which will  anticipate media
            coverage for various aspects and stages of the
            planning process.  The plan should include:

            o  news releases about specific aspects of the
               planning process, such as hearings, appointment
               of  advisory groups, and workshops.  In order  to
               ensure arrival at the appropriate desk, these
               should always be hand delivered.

              public service announceents (PSA's)  for radio and
              television stations to publicize meetings and hear-
              ings or to call attention to some aspect of the plan,
              such as selection of alternatives.   Radio stations
              will usually prepare PSA's from written copy sent
              to them.   Television stations may request someone
              to appear in the PSA, or they may want to film on
              location.  It is always best to handle these
              arrangements in person.

              participation in radio and television talk shows.
              Make sure the individuals who appear are able to
              respond to a wide range of questions in an infor-
              mative and congenial manner.
       Publications may consist of such things as published
versions of draft components of the Facilities Plan,  draft and
final Environmental Impact Statements,  or of a variety of short
brochures, flyers, fact sheets or bulletins designed  to facil-
itate public input to the Facility Plan.   These publications
may be stored in depositories, handed out at meetings, enclosed
with mailings, and supplied to the media.

       •  Flyers:  A flyer should be very brief—one  or two pages,
          perhaps include a picture or  two.  It might explain the
          purpose of the facilities planning process  and give the
          name, address, and phone number of the consulting -engi-
          neer and/or the public official in charge of the plan-

       •  Brochures;  A brochure is a brief booklet which may, for
          example, describe the need for  the project, refer to
          federal and state laws and regulations, detail various
          stepsin the planning process, and provide background
          information for new advisory  committee members, govern-
          ment officials, newsmen, and  other interested persons.
          A summary of the draft Facility Plan might  be distri-
          buted as a brochure, prior to the final public meeting.

       •  Fact Sheets;  Probably one of the most useful publications
          will be the fact sheets, each on a single issue of concern
          in the project, such as population projections, user
          charges, treatment methods, secondary impacts of growth,
          etc.  Fact sheets might also  be used to outline the con-
          sequences of alternative approaches and draw upon the
          experience of other communities where appropriate.

       •  Technical Bulletins;  It might  prove advisable to prepare
          one or more detailed publications about the technical
          aspects of the plan, such as  waste-load allocation, for
          distribution to advisory committee members  and other
          specialized interests.

       Both the community  leader and the grantee  developing
publications will want  to  be  aware of the many publications
already developed by  EPA,  by  your state agency, and  by  others
(such as those developed for  The Conservation  Foundation's
training program).  Preparation of publications can  be  costly.
Use should be made of existing  general materials  whenever
possible, with new publications focusing on the specific
community situation.  The  EPA Office of Public Awareness
may be able to help you locate  appropriate materials.


       A newsletter should be published at regular intervals
and mailed to persons and  organizations on the project's mailing
list  (or on a list compiled by  community leaders).   For maximum
utilization, the newsletter might be designed  as  a slip sheet
that  can be distributed with  organizational mailings.

       A newsletter is  usually  started early in the  planning
stages and continued  throughout the planning process.   It is
an excellent way of reporting a variety of news to those either
are  interested  in or  whom  may become interested in the  Facility

       Some of  the  types of articles and information appropriate
to newsletters  include: general water resource and  water quality
news; feature articles  explaining alternative  plans  and technol-
ogies; summaries of relevant  workshops and meetings, hearings,
meetings and workshop notices;  responsiveness  summaries; reports
or recommendations of an citizens advisory committee; and letters
to the editor.

Information Depositories

       The local governmental agency is required  by  regulation to
maintain a central  information  file or depository which includes
significant project documents.   Ideally these  depositories should:

           (a)   be  in  buildings  (such as libraries) whose hours
                open  facilitate  community use;

           (b)   have copying machines on the premises;

           (c)   in  larger communities be in a number  of  locations;

           (d)   for more complex projects have  staff  support
                (perhaps volunteer) to assist any  search for


       A number of  forums  can be selected for  speeches
and  audiovisual presentations on the facility  planning
project.  Appropriate forums  include service clubs,  regular
meetings of civic groups,  churches, environmental organizations,

chambers of commerce, and educational institutions.  A speakers'
bureau including authorities on several aspects of the planning
process should be organized.  The consulting engineer, members
of his technical staff, advisory committee members, and
other community leaders knowledgeable about the planning
should be invited to participate.

       Speakers should possess effective speaking ability and
be able to tailor their remarks to the interests of the groups
to be addressed.  Presentations should be prepared on a variety
of topics, and then be used as a basis for individual talks.
Handouts, slide shows, and exhibits will assist in making a
speaker's presentation more interesting and understandable.


       Exhibits are visual displays which may be as simple
as maps, charts, and diagrams or as sophisticated as a walk-
through maze which allows the participant to make alternative
selections regarding the future growth and character of his
community. Simple exhibits may be used in conjunction with
public meetings, hearings, speeches, or seminars. More sophis-
ticated displays may be stationed in public buildings or
shopping malls where they can reach large numbers of people
Large exhibits should be designed to both provide information
and receive public input.  They are best managed if con-
structed so they do not require an attendant.

             Reactive/Interactive/Dialogue Mechanisms

       Most of the mechanisms described below can be considered
reactive or interactive depending on how the information obtained
will be used:  Will the mechanism be used simply to obtain public
response to an agency decision (Reactive) or also to allow an agency
to respond to considerations posed by the public (Interactive)?

       Functional two-way communication can help keep officials
in constant touch with the needs and expectations of the public.
Basic organizational and administrative techniques, such as those
discussed below, can provide the framework for public involvement.

Public Participation Coordinator

       For effective implementation a comprehensive public partici-
pation program will require a public participation specialist.  Few
engineering consultant firms or municipalities currently have the
necessary expertise within their existing staffs to undertake
this function.

       A public participation specialist should have expertise
working with community action groups, either in a paid or volun-
tary capacity.  He or she should also possess communications skills
—know how to work with the media, prepare publications, run work-
shops, organize meetings, and work with the public effectively.

       The 3ob of the public  participation  coordinator
is to facilitate public  involvement  in  the  facilities plan.
In facilitating this  involvement,  the public  participation
coordinator will need to  understand  how best  to  contact
the publics in the community  in which he or she  is working,
as well as what issues will be  important those publics? Who
should be called in order to  obtain  a certain level of
citizen input at a particular decision  point? What kind
of information will be needed by the publics  in  the community
in order to participate  effectively  in  key  decisions?

       A public participation coordinator is  required in the
Full Scale Public Participation Program (PSPPP)  described
earlier in this book.  Although not  required  in  the Basic
Public Participation  Program  (BPPP), these  communities may
also wish to hire such a public participation specialist.

       Several options should be considered in providing for
a specialist:

           •  He/she  might be hired  directly  by  the engin-
              eering  consultant.  This  will assure a close
              tie with the technical and planning

       The word consultations means the act of seeking
advice and exchanging views. A variety of formal and informal
mechanisms can be utilized to fulfill the consultation require-
ments of public participation regulations.  Some of these
mechanisms are:

Informal consultations

       Face-to-face interviews or conferences, are useful both for
transmitting information and for receiving pubic input.  Consul-
tations will be needed throughout the planning process, but par-
ticularly in its early stages.  Interested citizens and organ-
izations should initiate discussions with governmental decision
makers when they have information to offer, or issues to be re-

       Consultations initiated by citizen organizations often will
be most useful if arranged on an ad hoc basis covering specific
issues of concern to that organization.  Such activities will often
be particularly well-received by a governmental agency when they
involve a number of different organizations representing a variety
of interests.  On the other hand, effective advocacy of a par-
ticular position may require that the organizations requesting
the consultation come from similar interests.

Task Forces

       A task  force is usually a small group of people, including
some with special expertise, which is assigned to research or
resolve a specific problem in a limited time frame.  Task forces
may look at problems which are generally outside the purview of
civil or sanitary engineering studies, such as secondary impacts
of growth and  related air pollution problems.

       Frequently the work of a task force will require some
understanding  of technical issues relating to the facilities
planning process.  With appropriate assistance from staff in-
volved in the  planning for municipal wastewater management,
citizens' organizations are often able to study problems and
arrive at creative solutions that might not otherwise be con-
sidered to be  politically acceptable.

       The problem to be considered by a task force should be
clearly defined before its members commence work.  A work schedule
should be prepared, and a fair cross-section of knowledgeable per-
sons representative of a range of viewpoints should be selected to
serve.  Task force members should be furnished with sufficient back-
ground information to enable them to thoroughly understand the
problem at hand and to deal with it in a short period of time.  One
person (either on the Task Force or serving as staff to the task

force) should be appointed  to formally summarize  the  results,
including any missing data  or unresolved  issues.


       A workshop  is a  small group meeting at which all  partici-
pants have some familiarity with the topic to be  discussed and
are afforded the opportunity to comment in considerable  detail.
Such meetings are  particularly useful in  the  middle stages of the
planning process when  the basic facts are known,  but  the alterna-
tive proposals have yet to  be thoroughly  examined.  Workshops re-
quire substantial  preparation time to be  successful,  but offer
one of the most useful  ways to explore in depth what  people
think about the ramifications of the facility plan.

       In order to ensure a successful workshop,  the  organizer
should undertake the  following preparations:

           •  succinct  definition of the  objectives of the
              workshop.  What are participants expected  to

           •  preparation or identification of materials to
              be distributed to participants  before the  work-
              shop that will facilitate discussion during the

           •  a briefing of speakers and  resource people on
              what their roles are to be  and  what information
              they will present;

           •  attention to  the administrative details of the
              workship  to minimize confusion  and  maximize the
              comfort  of participants (i.e.,  Will the workshop
              take place over a meal time? Will  meals be pro-
              vided?   If not, where can participants  go  to
              quickly grab  a bite to eat? etc.)


       Several kinds of surveys can be used in planning  sewerage
treatment systems. A  technical survey might  be designed to elicit
information from those  with technical knowledge,  such as agencies
and corporations which  are  discharging pollution  into the waterways,
A general survey designed to gauge public opinion and pinpoint
community values and goals  might be circulated before selection
of alternatives in order to determine public  response to such
alternatives as voluntary or mandatory flow-reduction programs.
Or residents might be  asked to respond to questions regarding
the condition, problems, etc. of their on-site disposal  systems.

       Data collection  through surveys can be very useful.

In the Buffalo, New York 208 plan for example, a survey revealed
a depth of public support for improved water quality that led to
stronger implementation recomendations than the decision makers
would have otherwise supported.

       Surveys can also be expensive and time consuming.  Those
planning to conduct a survey should consider using academic
resources as a source of volunteer assistance.  For example,
university students may be available to help in the preparation
of a survey including pre-testing that survey.  High school
classes, or scouting groups might be willing to help distribute
a survey and compile resulting data.

Citizen Advisory Committee

       A formally constituted Citizens' Advisory Committee (CAC)
has the potential for serving as an institutionalized consultation
mechanism with the ability to provide continuous input to each
stage of the planning process.  If properly balanced and adequately
staffed (representing a broad base of community interests), a CAC
may ensure that important knowledgeable interests in the community
will have continuing input into the planning process.

       Citizens' advisory committees have been utilized in
various environmental programs throughout the years, and
they have been the subject of considerable well-founded
criticisms.  The criticisms leveled at CAC's have basically
fallen into the following three categories.

           •  Their membership is often dominated by interests
              with an economic stake in the issues under con-
              sideration.  While CAC's may be designed as a means
              for regularizing and institutionalizing the input
              of those with limited access to the decision-making
              process, they frequently do not achieve those goals.

           •  A CAC may become a barrier to public participation
              if it is viewed by the sponsoring agency as the
              whole public participation program. If the local
              government only consults with the CAC, then the
              decision maker simply receives the thoughts of
              another group of people who may or may not represent
              the general public.

           •  A CAC may be ineffective if their role is poorly
              defined, or staff support is inadequate regardless
              of whether or not it is appropriately constituted.

       Citizen Advisory Committees are required as part of the
Full Scale Public Participation Program.  They are not required
for the Basic Program, but may be suggested.  Citizen organizations
should be carefull not to blindly promote a CAC as a key activity of

a public participation  program,   if CAC's are selected as
a public participation  method be sure to give equal  attention
to the makeup of  the  committee,  functions of the committee,
and its staff support.

       EPA  's public  participation regulations (mentioned earlier)
contain the following guidelines for the formation of  a  CAC:

           •  The CAC membership should be comprised of  sub-
              stantially equal representation from four  in-
              terests:  private citizens; public interest
              groups; governmental officials; and economic

           •  Notice  of intent to form an advisory committee
              should  be circulated widely in the community so
              that those wishing to serve on such a  committee
              may have  an opportunity to do so.

           •  The tasks of the CAC should be clearly defined,
              including its role relative to other public
              participation mechanisms.  In this way,  the CAC
              can maintain its contacts and credibility  outside
              the CAC;

           •  The CAC work should be supported by adequate staff
              and budget.

           •  Certain expenses of the CAC will be reimbursable.

       Although  EPA regulations  may at first appear  to set a
pretty rigid  structure  for advisory committees,  these  committees
may be expected  to vary considerably.  A number of questions will
have  to be  carefully  resolved within the community as  the advisory
committee is  being formulated.

           •  membership (what economic interests are  represented?
              What types of local government officials,  public in-
              terest  representatives?)

           •  size (will the advisory committee have 10  members or
              30  members?)

           •  role and  responsibilities (will the advisory committee
              have some responsibility for the execution of the
              public  involvement program?  To what degree will the
              advisory  committee periodically expand its membership
              through ad hoc task forces?)

       The CAC should be appointed in the early stages of the plan-
ning  process.  It will  establish a necessary communication link be-
tween the consulting  engineer and the public; provide  a  valuable

forum for reconciling varying viewpoints; analyze, review and make
recommendations; and reflect community values and goals during the
planning stages.  The CAC may also assist in the development of a
public participation workplan, advise on politics, and participate
in public meetings, workshops, and seminars.

       It is important that the committee's role be established
early in the planning-process.  To be fully effective, the committee
must have direct input into all major decisions affecting the plan.
Their value will be greatly reduced if they become only a reactive
panel.  All CAC activities should be funded in the Step 1 grant,
and adequate staffing should be provided.

Public Meetings

       Public meetings afford an opportunity to introduce and
stimulate interest in the wastewater treatment planning.  They
also afford the chance to clarify issues and give concerned citi-
zens a forum in which to present their questions and air varying
points of view.

       Meetings should be scheduled throughout the planning
process to provide information as well as receive citizen's
opinions.  They provide a valuable opportunity to explore the
environmental, social, economic, legal, and political ramifica-
tions of various alternatives considered during the planning

       The new public participation regulations require public
meetings at specific stages in the facilities planning proces.
These meetings can take a variety of forms, for example:

           •  meetings designed to accomplish a task;

           •  meetings designed to identify and negotiate

           •  open forums simply intended to air a variety
              of viewpoints; and

           •  large mass meetings to present basic information.

       Public meetings also may be sponsored in different insti-
tutional frameworks.  For example:

           •  the advisory committee in a full-scale public
              participation program may hold a working public
              meeting designed to broaden input from other
              publics on specific issues;

           •  the grantee may hire the local chapter of the
              League of Women Voters to sponsor an open forum
              on specific issues;

an already scheduled  town meeting may focus its
attention on facilities  planning issues needing
resolution.                                   ^

   .u .C?u'S should n?rmally  play a role  in  formal  public meetings
so that they can receive  input  from the public  and  affectively
advocate legitimate public  interest.


       One of the more  sophisticated and  creative consultative
mechanisms, charette  is an  intensive brainstorming  session in
which a number of people  representing different interests get
together to define problems and come up with solutions. It may
last anywhere from a  couple of  hours to a few days,  and parti-
cipants are given no  food or  sleep.  In its  description, citizen
Participation Techniques, the Institute for  Participatory Plan-
ning (Laramie, Wyoming) list  the following characteristics of
a successful charette:

           •  Problems  can  serve as a catalyst  problem to focus
              peoples'  attention and facilitate discussion;

           •  There should  be large and small meeting rooms
              if more than  a  few people are  involved. Most
              of the  work will  be done in small groups;

           •  all kinds of  materials should  to  be available,
              particularly  roles of paper and magic  markers;

           •  all food  should be brought  in.  Some breaks
              for "cat  naps"  should be made  available;

           •  consulting  engineers, environmental specialists
              and other technicians should be sprinkled among the
              lay people  to facilitate meaningful discussion.

Training Mechanisms

       Three of  the most  common training  mechanisms  are:


       Seminars  as described  here are essentially training
exercises designed to assist  a  small group in the legal re-
quirements for and the  steps  in the process  of  wastewater
facility planning.  They  may  be repeated  several times with
different audiences and may be  planned by concerned  citizens,
by local government or  by the consulting  engineering firm.  The
purpose of the seminar  is to  convey necessary information early
in the planning  stages, so  that citizens  who will continue to be
involved will be knowledgeable  about the  issues and  able to par-
ticipate more effectively.  Seminars or training sessions should

be held by the local government grantee or the consultant for
advisory committee members, the public participation specialist
or coordinator, task forces, local government staff, and others
active in the planning process.


       Conferences involve the presentation of information
to a medium to large audience in a manner that facilitates the
group's understanding of issues that need resolution.  Con-
ferences may combine techniques common to public meetings,
workshops and seminars.  The key ingredient, however, is a
formal learning experience that will assist audience partici-
pants in understanding the issues that must be resolved before
decisions can be made.

                   Simulation and Games

       One of the most sophisticated public involvement mech-
anisms is the simulation of actual planning situations as a
technique for mediating conflict and for training citizen
participants and planners with differing points of view.

       A central goal of public participation programs under
201 is to create forums for the development of a consensus on
the single best solution to the community's wastewater problem.
Creating a consensus for whatever solution emerges from the plan-
ning process requires a highly complex interplay of political
forces.  Sometimes it is possible to stimulate these inter-
actions in a less-charged atmosphere by developing a "let's
pretend" situation which has been highly simplified to permit
acting out the interplay of forces.

       The simulation will often require the hiring of a
specialist to develop the game and conduct the activities.

Building a Coalition

       One of the most effective ways citizen organizations
can utilize the mechanisms described above is to build a broad-
based coalition within their community to affect the facilities
planning decision-making process. An organization's various
efforts to affect the decision-making process will be viewed
more favorably by the general public and by the local government
grantee if it is evident that a broad-base of community support
is involved.

       Whether you decide to hold a workshop or seminar or
to establish a task force, you will wish to consider expanding
the number of organizations and individuals involved in such an
activity.  Building such a coalition will involve informal meetings
with a number of different interests in order to establish common
points of concern.

            i     C0alltl0n mav not n«n that all  organizations
H    -M V**    ? ^^ m°St °f  the P°ssible  Positions  vis-a-vis
the facilities planning  process,   it may simply mean that  the
organizations forming the  coalition agree to disagree  on certain
issues, have identified  certain issues they  have in  common,  and
share the objective  to regularly communicate with  the  decision-
making body.

Public Hearings

       Although a public hearing is a consultative mechanism,
its formality and legal  requirements have caused us  to list  it
as a separate type of mechanism.

       A whole list  of  legal requirements must be  met  in conduc-
ting almost any public hearing  under the Clean Water Act.  These
requirements are described earlier in this chapter.  Anyone  in-
volved in either designing or participating  in a public involve-
ment program will wish  to be cognizant of those requirements.

       Public hearings  are normally a reactive mechanism and are
meant  to give individuals and organizations  a formal opportunity to
express their opinions on an issue immediately prior to decision
making.  Although  in theory most public hearings are scheduled just
before decision making,  in reality they usually take place after
the staff has completed  its work and has arrived at  a  tentative
conclusion.  All too often the  burden is on  the public to prove
that a different conclusion is  warranted.

       Public hearings  have been criticized  not only because
of the heavy burden  of  proof on the public to change an agency
course, but' also because the manner in which they  are  handled
often  discourages  rather than encourages citizen input.  Many of
the legal requirements  (such as notice periods, requirements for
Fact Sheets, etc.)  described earlier were designed to  respond
to these criticisms.

       Officials responsible for public hearings may wish
to consider  holding  one  earlier in the decision making process
than is required by  regulation. (This would  mean a second public
hearing, as  you would not be relieved of the existing  public
hearing required before adoption of a Facility Plan.). This
approach would give  officials the opportunity to better consider
and respond  to public  input before finalizing recommendations.

     Creative Use  of Existing Institutions In Implementing
                     Public Involvement Tools

       In addition  to  the tools for public involvement in  the
facilities planning  process discussed in preceding sections, there
will be a number of  opportunities for affecting Facility Plans
outside the  formal  planning process.  We cannot hope to describe

the range of opportunities available because they will vary
enormously depending upon the institutional structure of your
community and you community's relationship to other state and
regional governments.

       In constructing a public participation program, you should
examine the various governmental and nongovernmental tools for
decision making that exist in your community and tailor your pro-
gram to make maximum use of these tools.

Town Meetings

       New England towns and villages annually hold town
meetings in the spring to approve the yearly budget and specific
actions or programs to be undertaken by the Town Council or Board
of Selectmen.  The local financing share for facilities planning,
engineering design, and construction must be approved by community
members at the town meetings. User charges and local bond issues
might also be considered at such a time.

       For example, in a town meeting citizens might attach
a rider to the budget allocation for the local financing share
requiring a public participation work plan as part of the Step
1 grant application.  During a town meeting a sewer commission
might be directed to consider land treatment or other low-technology
systems in developing their Plan of Study, or limitations might
be placed on the selection of the location for a treatment facility.

       Citizens who wish to be involved in facilities planning
will wish to participate in all town meetings in which facilities
planning is on the agenda. In addition, if facilities planning
is not on the agenda, local decision makers might be responsive
to requests that it be added. A New England town meeting may offer
a unique opportunity to reach a broader constituency in the community
than is possible at other times.

Conservation Commissions

       Conservation Commissions, like town meetings, are
unique to the northeast and may significantly influence 201
planning. Commissioners have the authority to review Facility
Plan proposals and environmental impact statements (if an EIS
is prepared) and to assess the natural resource implications of
the proposed project.  They will probably also have a wealth of
data available to assist citizens in making their own determinations
regarding the environmental impact of a proposed treatment facility

Planning Boards and Commissions

       Many communities will have some type of planning and/or

zoning board or commission to develop -and/or approve  economic
development plans,  land-use plans,  or individual  requests  for
zoning.  These agencies will be involved in reviewing Facility
Plans to determine  whether the treatment plant  and  interceptor
sewer capacity and  location are consistent with local plans.

       Planning boards  and commissions  frequently have regular
meetings which are  open to citizens.   In such meetings,  citizens
may raise questions about  the implications of certain aspects  of
the facilities planning process.

       Such boards  and  commissions  may not have much  power or
authority in a community.  Concerned citizens however,  can  exert
considerable influence  to  insure better coordination  between the
Planning Commission and those planning  for sewage treatment, thus
making Facilities Planning more responsive to broader planning

Regional Planning Agencies

       Most areas of the country now have regional  planning
agencies of some  kind.  These agencies usually have  the respon-
sibility for conducting an initial  review (known  as A-95 Review)
of  Facility Plans to assure consistency with other  local and
regional plans  and  to assess environmental impacts.   The A-95
Review Process provides regional planning agencies  with  the
opportunity to  review and  comment on upcoming projects,  but
the recommendations generally are not legally binding.   The
201 Plan of Study and grant application, as well  as the  Facility
Plan and Step 2  and Step 3 grant applications,  must be reviewed
and commented on by the regional planning agency  prior to  sub-
mission to EPA.  The agency, when submitting its A-95  review,
may simply approve  or disapprove a  particular project or may
qualify its approval based on specific  project  changes.  If an
inconsistency with  local plans exists or if special environ-
mental problems  are known, this should  be brought to  the atten-
tion of the agency  when the grant application is  being reviewed.

       Certain  planning agencies may exercise additional authority.
The California  Tahoe Regional Planning Agency,  for  instance, has
permitting authority under the California Environmental  Quality Act.
Facility Plans  are  reviewed for compliance with land-use plans, con-
sistency with population projections, and analysis  of secondary en-
vironmental  impacts before a permit may be issued.  Projects which
plan for an excess  capacity or which may degrade  air  or  water  quality
may not be approved.

       Freauently an existing regional  planning agency is
in  fart the aaency  responsible for  conducting 208 planning.
Since Facility  Plans must  be consistent with 208  plans,  these
agencies may have real  influence over what happens  during  the

facilities planning process.  Early in your involvement
in the facilities planning process, you will wish to examine
how decision making may be constrained by an approved 208 plan.
If you feel that significant decisions have been made without
public involvement, or that certain decisions may have environ-
mental and/or social consequences not adequately considered,
you may wish to find out what provisions have been made for
amending the 208 plan through the formal continuous planning

       In many instances, there will be a number of public
participation mechanisms already in use by a regional planning
agency. Using these existing mechanisms may be an efficient way
to approach development of a public participation program for
the facilities planning process. For example, a regional planning
agency responsible for 208 planning may already have a citizens'
advisory committee. Perhaps the CAC for the facilities planning
process should be a subcommittee of that citizens advisory
committee, including membership from the larger 208 CAC.

       The regional planning agency with responsibility for 208
planning may have staff members experienced in public participation.
Since 208 planning and facilities planning are so closely linked,
arrangements may effectively be made to allow the facilities planning
process to make use of these already experienced public participation

       A number of other regional public participation mechanisms, such
as regular newsletters or other bulletins, and regularly scheduled pub-
lic meetings, may also provide useful opportunities for public involve-
ment in the facilities planning process.

Cable Television

       In a number of communities around the country, local cable
TV stations have sponsored regular public-service programs produced
in the community and dealing with issues of special local interest and
concern.  Local groups could develop programs focusing on the facili-
ties planning process and, for instance, discuss the water-quality
problems being addressed by the facilities planning process and
present controversial issues.

       Several communities are experimenting with the use of a
two-way capability that will allow cable TV viewers to transmit
back to local stations, offering a feed-back opportunity not
normally associated with television. In facilities planning
areas with a scattered rural population, this two-way capability
may significantly add to the usefulness of a public meeting if
it is transmitted on TV.

       The two-way capability of cable TV is still in the
experimental stage, and may not be widely available to you.

^C«nY,™?-natfdiPUbli° service Programming, however,  is not
at all experimental  and may be a useful mechanism to foster
broader public involvement in facilities planning.

 What  Problems Might  Be  Encountered in the Implementation of
 Public  Participation Requirements?	

                      A historical perspective

         The  development  of the  public participation regulations
 described in this chapter was  begun by EPA in October 1977 at
 the  request of  five  national environmental organizations—The
 Conservation Foundation, National Wildlife Federation,  Natural
 Resources Defense Council,  Sierra Club and Institute for Public
 Interest Representation (Georgetown University Law Center).  In
 a June  21,  1977 memorandum  to  EPA Administrator Douglas Costle,
  these organizations  stated:

              Despite  both the emphatic language of
              101(e) and  the  apparent recognition by
              EPA of the  significance of public par-
              ticipation, EPA has yet to issue regu-
              lations  that fulfill the promising and
              exacting public participation require-
              ments of the  [Clean Water] Act.

         Agreeing that the public participation efforts of EPA
  and of  implementing  agencies at the state and local level had
 been deficient, Thomas  Jorling, Assistant Administrator for  the
  Office  of Water and  Hazardous  Materials, began the effort to
  rewrite the rules for public involvement.

         Between 1972  and the end of  1978,  the public partici-
  pation requirements were  initiated  primarily by  a  few forward-
  looking administrators with appropriate  implementation authority
  The rules of the game were vague  indeed.  Regulations issued on
  August 23, 1973,  (40 CFR,  Part 105) were  in  fact performance
  standards that set limited goals  and  objectives  to be met by a
  public involvement program but virtually  no  requirements.
   (For example,  implementing agencies were  to  develop an
  information program, a program of early  consultation with
  various publics, etc.).  Program  regulations—which were to
  provide specific requirements—usually referred  back to Part
  105 and failed to specify any  other public participation re-
  quirements other than an occasional public hearing.

         Even the  few requirements  that did exist  (i.e., a


In fact, even the eligibility of public participation programs
for construction grants funding has been the subject of some
confusion.  With no clear-cut regulatory directive declaring
public involvement to be grant-eligible, some EPA regions and
states determined that some public participation activities
were not grant eligible.

       The new Part 25 regulations (replacing Part 105) are
surprisingly similar in approach to the old regulations.  They
consist mostly of performance standards and leave to the imple-
menting agency or to the specific program regulations the mech-
anisms and timing of the public involvement program.  There are,
however, significant differences:

            1.  New Part 25 pays a great deal of attention to
criteria for judging the adequacy of public involvement.  The
goals and objectives of public participation are clearly stated.

            2.  Although specific public involvement techniques
are not required by Part 25, when they are required in program
regulations they must be carried out in a specific manner.  For
example, public meetings must take place on 30-day notice, ad-
visory committee membership must be equally balanced among pri-
vate citizens, public interest groups, government officials and
economic interests, etc.

            3.  The reasonable costs of public participation
activities are clearly stated to be grant-eligible items.

            4.  All grant programs must outline an adequate
public participation work element (in the case of the Construc-
tion Grants Program, the Plan of Study outline fills this re-
quirement) before receiving the grant award.

            5.  Responsiveness summaries required periodically
throughout the facilities planning process will assist EPA
oversight responsibilities regarding the adequacy of the public
participation effort.

            6.  The EPA has obligated itself to provide
technical assistance and training to advisory committees
formed to participate in the facilities planning process.

            7.  Simply by revising the regulations, EPA
has signaled a change.  The agency has effectively said
—to the public and to implementing institutions—that
public participation efforts under old regulations were
not successful, and that public participation programs
will be taken far more seriously in the future.

                   Institutional resistance

       It is perhaps for this last reason that proposed

public participation  regulations—which took such modest
steps toward  changing the rules—evoked such controversy
at all levels of government.   Some EPA Regional  Offices,
and many state  agencies and local governments submitted
comments on the proposed regulations that decried any
specific requirements for the development of a public
participation program.

       Some of  their  objections were:

            •  the limited financial and staff resources
                available to oversee and/or implement  the

            •  the large number of federal regulations that
                local  and state governments already have to
                deal with in the Construction Grants Program;

            •  a  feeling that the specific requirements of
                the regulations would be insensitive to local
                institutions,  problems and opportunities.

       Other  reasons  for institutional resistance to  public
 involvement  in  facilities planning may be:

            •  a  lack of understanding on the part of the
                engineers who have run the program that there
                are political  and social value judgments in-
                volved in the  technical decisions that lead to
                the selection  of a waste treatment management

            •  a  lack of understanding of how to interpret
                public participation regulations  on the part
                of  those charged with interpreting them.
                Encouraging effective public  involvement
                is  a specialized skill  in the  same way that
                engineering a  treatment facility  is a  specialized
                skill.   At this point the people  who are charged
                with implementing public involvement programs are
                largely  the same people who are engineering the
                facilities. The development  of creative and mean-
                ingful public  involvement programs will probably
                require  hiring public participation specialists.

        The development of a  meaningful public involvement program
 in your community may  well require perseverance on the part of
 informed citizens.   You will want to  work closely with the local
 government grantee and with  the consulting  engineer  to ensure
 that public  involvement programs:

              •  closely track the decision-making process to
                ensure  maximum input without  causing  substan-
                tial  delays;

            •  identify important community issues at early
               stages in the decision-making process; and

            •  target the important affected and interested
               publics in your community.

                      Local apathy

       A final problem you might incur in developing a public
involvement program is lack of interest among the various publics
in your community.  This apathy may be caused by one of three

            •  lack of understanding of how the facilities
               planning process touches the lives of the
               people in the community;

            •  the proposed project may be only one of
               a number of important issues currently
               drawing on the volunteer time of people
               in the communty; and

            •  the proposed project may have truly
               minimum impact on the community.

       It  is important to remember that different projects and
activities generate different levels of interest in the community,
In some cases, no matter what your efforts, there is no way you
will be able to turn out 300 people for a public meeting on a
minor sewer rehabilitation project, for example.

       In many cases, however,  you will  be able to  actively
encourage public involvement by pointing out to various groups
how their interests coincide with or are affected by the
facilities planning process  (see "Who  is  the Public?" in this

What Are  the Rewards of  Public Involvement in the Facilities
Planning  Process?

       It is important to remember that the ultimate purpose of
public involvement in facilities planning is cleaner water at
a lower environmental,  economic and social cost.  Only careful
public scrutiny can ensure:

            •  that the  Facilities Plan meets the present
               and future needs of the community;

            •  that all  the relevant environmental,
               economic  and political data necesary to
               ensure effective implementation emerges;

that appropriate measures are taken
to mitigate negative impacts; and

that a community develops a committment
to continued oversight of the operation
and maintenance of the facility.

       A number of sources contain further descriptions
of public participation tools.  Three sources have been
particularly useful in the preparation of this book:

1.  A Manual for Communities on Public Participation in
    Planning for Wastewater Treatment, Draft Publication,
    EPA Region I, 1977.

2.  Institute for Participatory Planning/ Citizen
    Participation Handbook for Public Officials and
    Other Professionals Serving the Public, Chapter V,
    "Citizen Participation Techniques," Third Edition,
    1978, Box 4068, Laramie, Wyoming.

3.  Warner, Katherine, Public Participation in Water
    Resources Planning, University of Michigan,
    Ann Arbor, Michigan, July 1977.


                        APPENDIX A

      Principal  Federal Regulations and Guidelines

               Construction Grants Program
 Municipal Wastewater
 Treatment Works, 40 CFR
 Part 35,  Supart E [Grants
 for construction of
 Treatment Works, 43 Fed.
 Reg. 44022-44099,
 Sept. 27, 1978.]
 Public participation in
 the Construction Grants
 Program  [Cleared by the
 Agency, but not yet pub-
 lished as we go to print.
 When published, these regu-
 lations will amend Part 35.
 These requirements should be
 promulgated in  late January
 or early February, 1979.]

 State and Local
 Assistance 35 CFR
 Subpart  F.  State
 Management Assistance
 Grants  [43 Fed. Reg_.
 42251, Sept. 20, 1978.]

 Secondary Treatment
 Information, 40 CFR
 Part 133,  [38  Fed. _
 22298, Aug. 17, 1973,
 Amended  on Oct. 7,  1977.]

 Water Quality  Management,
 40  CFR,  Subpart G  [proposed
 on  Sept.  12,  1978,  43 Fed..
 Reg.,  40742-40757.   Not yet
 promulgated  in final as this
 book goes to print.]

 Preparation  of Environ-
 mental  impact  Statements,
' 50  CFR Part  6, [40 Fed_.
 Reg. 16811-6827,
 Apr. 14, 1975.]
Comprehensive regulations for con-
struction grants program.  Describes
conditions that must be met prior
to award of federal funds;  minimum
content of facilities plan, require-
ments for cost-effectiveness and
analysis, funding innovative and
alternative system and individual
systems, state priority lists and
set-aside funds, requirements for
architectural and engineering
subagreements, and the specific
public participation requirements
applicable to the Construction
Grants Program.
 Implements Section 205(g), providing
 funds to states for management
 of Construction Grants Program.
 Defines  effluent limitations for
 the minimum national requirement
 of secondary  treatment.
 Defines  contents of State/EPA
 Agreement  regarding water quality
 management requirements of Sections
 106,  208,  303  and  201(g).
 When and how to prepare  an
 Environmental impact  Statement
 for waste treatment facilities.

Public Participation          Describes general requirements for
in Water Pollution Control,   pubic participation for all EPA
40 CFR Part 25. [These        water programs. Reg.
regulations have not yet
been promulgated in the
Federal Register.]

       EPA also publishes guidelines, which are not compiled
in any official way and do not have the force of law.  They give
advice on desirable procedures and efficient methods and criteria.
Four of these documents have important impacts on the Construction
Grants Program:

Guidelines	Purpose	

Guidance for Preparing        Suggested topics, outline and data
a Facility Plan Revised,      necessary for a facility plan.
May 1975, Municipal           Now being revised.
Construction Division,
Office of Water Programs,
EPA, Washington, D.C.

Model Facility Plan
for a Small Community,
Sept. 1975.

Guidelines for State and      Details on the contents of a
Areawide Water Quality        208 plan.
Management Program            Now being revised.
Development, Nov. 1976.

Alternative Waste             Defines the acceptable options
Management                    for achieving BPWTT.
Techniques for Best
Practicable Waste
treatment, MCD-13,
Oct. 1975.
       Many other guidelines cover technical aspects of the
waste treatment program and contain valuable information on
alternative waste treatment management systems.  They are all
available from your EPA Regional Office.


    Decision Poinrs

1.  State delineation
    of facility plan-
    ning areas.
Criteria for state
priority list.
                                                              Table 2

                                                        FACILITY PLANNING
                                               PUBLIC PARTICIPATION PLANNING GUIDE
                      Public Participation
                      	Requirements *

                      Only as incorporated    a)
                      statewide water quality
                      management planning
                      public participation
                      requirements.  No
                      action specifically     b)
                      required here.
a) Factsheet

b) Public hearing (with
   30 days'  notice)
                       Responsiveness summary
                       submitted to EPA.
                                Issues to be

                              Are boundaries suf-
                              ificent to assess
                              potential environ-
                              mental impacts?

                              Do they allow for
                              maximum treatment

                              What are the politi-
                              cal and institution-
                              al implications?
    Do criteria re-
    late to national
    and state water
    pollution goals?

    Are major pollution
    problems given pri-

    Are rural pollution
    problems being ad-
                                                   d)  How are priorities
                                                       established within
                                                       "set asides."
                           Recommended Public

                          a)  Fact sheets stating
                             criteria for bound-
                             ary determination.

                          b)  Public notification
                             through media, press
                             and direct mail to
                             citizens and agen-
                             cies known to be
c)  Public meeting if
    controversy is known
    to exist.

a)  Active solicitation
    of public review
    and comment through
    direct mail.

b)  Several public
    meetings held
    before hearing.

c)  Circulation of
    Summary to hearing

d)  Summary of agency
    response to citizen
                                                   e)  Are innovative and
                                                       alternative  systems given
                                                       given high priority?

                          Planning boundaries will be
                          determined by completed
                          208 plan or state water
                          pollution control agency.
                          They must include source
                          of pollution and an area
                          large enough to analyze
                          environmental impacts of
                          treatment options.
The 1977 Clean Water Amend-
ments require states to
develop new criteria.  Citi-
zens should ask their states
to put them on the required
mailing list that will  ensure
their receipt of factsheets
describing changes in prior
ity ranking and rating  sys-
tems -
     The public participation regulations on which this table is based  are in the  process  of  final approval at  EPA
     before promulgation.  These regulations are  likely to be published in the Federal Register sometime in February.
     (See  text for  additional citation.)

Decision Points

State priority
   Public Participation

a) Circulate statewide    a)
   information about
   priority list (or any
   major revision thereto).
b) 30-day advance notice
   before public hearing
  Issues to be

Does list relate to
established cri-

Are innovative solu-
tions fully funded?
                                                                                  Recommended Public
4.  Preapplication
5.  Selection of




Responsibilities of
state and local

Time schedule.

Explanation of pro-
cess and require-
ments .
Does engineer have     a)
experience with inno-
vative treatment

Has he included public
participation in pre-
viously completed
201 projects?          b)

Does he have staff
capability to under-
take all phases of
201 planning?
Fact sheets which
cate the nature of pol-
lution problem and the
scope of the proposed

Direct mailings to
groups and individuals
known to be interested.

Public notification of
hearing thru press ,
media and mailings.

Summary of agency re-
sponsiveness .

Establish a Citizens'
Advisory Committee.
If CAC is established,
Advisory Committee
interview with engineer
candidates; or, if no
CAC yet, establish an
Engineer Selection

Distribute information
about candidates and
their previous exper-

States are only required
to give 30 days notice
of hearing.  Standard
practice is to provide
notification with pro-
ject name, number and
amount only.  Citizens
should pressure states
to provide sufficent
information to make hear-
ings and comments mean-
This conference takes
place between EPA, state
and grantee  (local offi-
cial) , and consulting
engineer, if hired.  Fund-
ing application will
commence after this confer-
                                                                                                    The selection of a consult-
                                                                                                    ing engineer is a critical
                                                                                                    decision.  It may deter-
                                                                                                    mine the alternatives
                                                                                                    selected for study, the
                                                                                                    extent of the environmental
                                                                                                    assessment, and whether
                                                                                                    any public participation
                                                                                                    takes place.  Some engi-
                                                                                                    neers may have experience
                                                                                                    with only one or two sys-
                                                                                                    tems and be reluctant to
                                                                                                    consider others.  Others
                                                                                                    will consider public input a
                                                                                                    nuisance rather than a help.
                                                                                                    EPA regulations encourage
                                                                                                    the grantee to consult with
                                                                                                    the public at this point.

    Decision Points

6.  Plan of Study.
                  Public Participation

                  Notify and consult
                  with public.

                  Develop  brief  outline
                  of public participa-
                  tion program.
A-95 Review of
 State  review of
Review adequacy of
public participation
outline in P.O.S.
                                Issues  to  be

                        a)  Nature  and  scope  of
                           201  plan.

                        b)  Schedule  for comple-
                           tion of tasks.

                        c)  Itemized  costs.

                        d)  Plan for  public par-
                           ticipation  including
                           staff,  preliminary
                           budget  and  schedule.
a)   Consistency with ex-
    isting regional and
    local plans.

b)   Is public partici-
    pation adequately
    provided for?
a)  Adequacy of plan-
    ning area.

b)  Proper scope of

c)  Reasonable cost
                               Recommended Public

                           a)   CAC,  if established
                               should review POS and
                               make  recommendations
                               for public participa-

                           b)   Notify groups and
                               individuals known to
                               be interested.

                           c)   Responsiveness  summary
a)  Citizen should be
    invited to appear before
    A-95 committee to make
    recommendations if POS
    inadequate and/or write
    letter to clearinghouse
    for consideration prior
    to meeting date.

b)  Comments and recommenda-
    tions of public for^-
    warded to the EPA
    regional office.
c)  Citizens should contact
    the press regarding any
    request coverage  of the

a)  Citizens should notify
    state agency of inade-
    quacies in plan by
    letter or appointment
    if possible.

b)  Request a response indi-
    cating how your recom-
    mendations have been

 The  POS  is not currently
 funded,  so officials may
 be reluctant to establish
 any  formal mechanism, but
 an effort  should be made
 to see that at the very
 least some informal
 public input occurs, and
 that public participation
 activities are scheduled
 with sufficient funding.
 A responsiveness summary
 although not required may
 be useful  at this point.

 The  A-95 review is usual
 conducted  by COG or Re-
 gional Planning Council.
 The  POS may be  considered
 by a sub-committee with
 geographic  representation
 or only by  a  policy com-
 mittee.  The  meetings  are
 open to the  public and
 usually time  is  provided
 for  citizen comment  if
It is always best to meet
personally with state and
local officials if possi-
ble.  Take along someone
with technical expertise
if your discussion will
include topics of a tech-
nical nature.

      Decision Points
  8.  State review
      of POS
  9.  EPA review
      Of POS
      (May principally
       be State Review
       in the case of
       of a delegated
Public Participation
a)  Review ade-         a)
    quacy of public
    work element in

b)  Determine whether   b)
    public participa-
    tion program should
    be Basic or Full
       Issues to be
    Is the public par-
    ticipation work ele-
    ment in the plan ade-
    quate to ensure that
    public involvement
    policies and objec-
    are met?

    Compliance with
    application require-
    ments, 208 and basin
    plans and priority

    Is public participa-
    tion adequately pro-
    vided for?
                           Recommended Public
                       c)   Ask that known in-
                           terest groups,  in-
                           dividuals and the
                           press be notified
                           of their decision
                           and its basis.
                       a)   Make known any objec-
                           tions to POS  to EPA
                           project officer.

                       b)   Include information re-
                           garding any special
                           pollution,  land use,
                           growth or social  or
                           economic problems
                           which have not been
                           included in POS.
                              Use the media to publi-
                              cize the controversy
                              only after you have
                              determined differences
                              cannot be resolved thru
                              discussions and nego-

                              If the POS has not been
                              available for review,
                              recommendations to each
                              agency should always in-
                              clude information regard-
                              ing issues, desirable
                              public participation
                              activities, alternative
                              system, etc.
      Award of Step
      I grant.
c)  How will the Faci-
    lities Planning
    Process be coor-
    dinated with 208

a)  Hire public parti-
    cipation coor-
                         b)  Grantee informs     b)
                             public of oppor-
                             tunities to serve
                             on Citizens Ad-
                             visory Committee

                         c)  Establish CAC*
Did agency respond
to issues received?
                            Will a comprehen-
                            sive public parti-
                            cipation be imple-
                            mented?  Will a
                            grant amendment be
                            necessary to en-
                            sure an adequate
                            public participa-
                            tion program?
a)  Contact consulting
    engineer to discuss
    scheduled planning.

b)  Request that CAC be
    established if not
    done to date.

c)  Discuss public par-
    ticipation program,
    how it will operate,
    staffing and budget,
    public participation
Under current EPA require
ments, any public parti-
cipation work plan and
funding allocation if
it is to be considered
must be a part of the
POS.  Proposed regula-
lations would allow the
grantee up to 45 days
after the grant award
to develop the plan.
Even without the pro-
posed regulations, if
funding for a public
participation program
is inadequate or absent
a grant amendment may
be sought.
* Required only in the Full-Scale Public Participation Program

Decision Points

Award of Step
I grant.
  inflow Analysis
Public Participation
^	Requirements

d)  Develop mailing
    list of inter-
    ested and
    affected indi-

e)  Establish staff
    contact for CAC
     (May be public

f)  Within  45 days
    after award of
    Step I  grant  sub-
    mit Public Parici-
     cipation Work Plan
     (PPWP)  to EPA

g)   Distribute to
     mailing list:
       1) copy of  PPWP
       2) fact sheet  on

 h)   Develop and  Insti-
     tute a  public in-
     formation program

 i)   Establish  informa-
     ation  depository

 j)   Train  CAC members*

       Issues to be

c)  Have the appropriate
    issues for public
    involvement been

d)  What kinds of infor-
    mation will facili-
    tate public involve-
                                                                             Recommended Public
a)  What parts of the
    system need rehabi-
    litation because of
    groundwater leakage?

b)  Might rehabilita-
    tion take the place
    of new sewage treat-
    ment capacity?
a)  CAC review and com-

b)  Keep public aware of
    progress and results
    with regulat mailings
    of newsletters and
    informational materials-
This step only applies
to projects with exist-
int sewers.
  *  Required only  in  the Full—Scale Public Participation Program

      Decision Points

12.    Assess current
                   Public Participation

                   a)  Consult with
                       public after 30
                       days notice
                         b)  Hold a public meet-

                         c)  Prepare and distri-
                             bute Responsiveness
                             (these requirements b)
                              must take place no
                              later than Decision
(See #12)
     Issues to be

    To what degree will    a)
    measures such as sewer
    system rehabilitation
    —water conservation
    and flow reduction
    programs—and better
    O&M of existing faci-  b)
    lities obviate the
    need for new treat-
    ment plant capacity?

    Have current water     c)
    quality problems,
    environmental con-
    ditions, population
    and land use data
    been properly assessed?

    Are there existing
    measurements on
    current wastewater
    flows?  Are the
    soprces of these
    flows known?
                           Recommended Public

                           A public participation
                           specialist should be
                           hired to carry out
                           public participation
                           work plans.

                           CAC should review
                           and comment on assess-
                           ment or individual
                           consultations sought.

                           Extensive mailing list
                           of interested indivi-
                           duals and groups
                           should be prepared by
                           an engineer.

                           Citizens task forces
                           might be formed at a
                           public meeting to
                           assist in assessing
                             1) current and future
                             2) sensitive environ-
                                mental and social
Have all environmen-
tally sensitive area
within planning
boundaries been
adequately consi-
See recommended participa-
tion in steps 12, 13, 14,
15 and 16.

                              When a CAC is not
                              established for develop-
                              ment of the Facility
                              Plan,  other consultation
                              methods should be pursued
                              at each decision point,
                              indicating CAC review or
The Environmental assess-
ment is an analysis of tie
current environmental sit
uation and any changes
likely to take place'as
a result of each of the
major alternatives under
consideration.  It starts
during the assessment of
current situation, gen-
erally is conducted by
*  Required only in the Full-Scale public participation program

Decision Points

                         Public Participation
 Decision to
 "Piggy-back"  an
 Impact Statement
                          (See #12)
       Assess future
                     (See #12)
                    a)  Mid-Project*
                        Evaluation by EPA
                        (or State) of com-
                        pliance with public
                        participation re-
 Issues to be

Have the primary
and secondary en-
vironmental impacts
of all the major
alternatives been
adequately considered?

Will a full scale
environmental impact
statement be necessary?
To what degree is there
sufficient knowledge of
environmental quality
problems to decide to
do the EIS concurrently
with the environmental
Are land-use projec-   a)
tions consistent with
local planning and/or
other community goals? b)
Do existing land-use
plans call for intru-
sion into environ-
mentally sensitive     c)
areas such as flood-
plains or wetlands?
                               Recommended Public
CAC reviews and makes

Workshop or public
meetings to discuss

Fact sheets should be
prepared and dissem-

 the consultant, and con-
 tinues right up until the
 time of consultant recom-
 mendation.   If the deci-
 sion is made to expand
 the analysis to a full
 environmental impact
 statement,  the informa-
 tion gathered in the
 assessment  will be the
 basis for the EIS.

 If  the environmental im-
 pacts are known to be
 significant early in the
 planning process,  the EIS
 may be prepared in con-
 junction with the prepar-
 ation of the plan.   This
 is  called "piggy-backing."
 If  this  occurs,  a  more
 extensive public parti-
 cipation program should
 be  undertaken which
 focuses  on  the environ-
 mental impacts.

 If  a  public  participation
 specialist  is  not hired
 or  the public  participa-
 tion  elements  contracted
 to a qualified  firm or
 organization,  it will be
 necessary for  interested
 community groups to con-
 tinually pressure for the
 opportunity  for public
 input, particularly when
major issues or contro-
 versies are  involved.
  *  Not required at this time necessarily, but at a "mid project"  point.

Decision Points

Assess future
                         Public Participation
      Cost Effective-
      ness analysis
                   a)  After 30  days
                       notice, public

                   b)  Responsiveness
       Issues to be

b)  Are population         d)
    projections con-
    sistent with BEA*
    projections or with
    significant new
    growth being planned

c)  Are planned future
    industrial flows
    adequately documented?
    Are they consistent
    with community plans?

a)  Is the planning        a)
    period reasonable?
 Recommended Public

Interest newspaper
in doing feature
                                                 b)  Are the maximum
                                                     number of alterna-
                                                     tives being con-
                                                 c)  To what degree are
                                                     flow and waste level
                                                     forecasts accurate?    c)
                                                     Does the facilities
                                                     plan contemplate an
                                                     aggressive Flow
                                                     Reduction program?     d)

                                                 d)  Has appropriate atten-
                                                     tion been paid to the
                                                     phasing or staging of
                                                     treatment works in
                                                     order to provide for
                                                     cost-effective treat-
                                                     ment in a manner that
                                                     helps control and
                                                     manage growth.
 CAC review of impor-
 tant decision points
 and recommendations

 Public meetings and
 workshops, including
 CAC grantee and con-
 sultant participation.

 Fact sheet and other
 information dissemin-

 On large projects
 public may need to
 be reached through
 neighborhood meet-
 ings, telephone
Public scrutiny of alter-
natives prior to the en-
gineers' preliminary
selection of an alterna-
tive is very important.
The cos't effectiveness
analysis weighs both
monetary and nonmonetary
factors in the various
alternatives.  Concerned
citizens will wish to be
involved in the value
judgment implicit in that
weighing process before
decisions are made.  If
the alternatives can be
agreed upon before the
public hearing, the plan
is more likely to be
completed on time at the
least expense.
* BEA - Bureau of Economic Affairs

Decision Points

Cost Effective-
ness analysis
                         Public Participation
    Issues to be
       Sewer System       None.
       Evaluation Survey
 Historical and
e)   Which alternative      e)
    has tlje least mone-
    tary cbst and en-
    vironmental cost
    and is most' com-
    patible with com-
    munity goals?  Will
    overriding environ-    f)
    mental and social
    costs point to the
    selection of a par-
    ticular alternative,
    even if that alter-
    native has the higher
    monetary costs?

f)   Are all the social and
    environmental costs
    considered in the cost
    effectiveness analysis?

a)   What are the needed    a)
    corrective actions
    for sewer system
    rehabilitation, and    b)
    what will be the
    specified cost?

b)   What parts of the
    system need rehabi-
    litation because of
    groundwater and storm-
    water leakage?

c)  Might rehabilitation
    take the place of new
    sewage treatment capacity?

a)  Are historic or archeo-a)
    logical sites affected
    by the alternatives
Recommended Public

 Encourage the use of
 speakers bureau, mul-
 timedia presentations,
 community options dis-
 play at organizational

 Request that special task
 forces be set up if major
 issues need more concen-
 trated scrutiny.
                                                                          Brief CAC on progress
                                                                          of evaluation.

                                                                          Keep public aware of
                                                                          progress through mail-
                                                                          ings of newsletters
                                                                          and informational
 Submit recommendations
 if sites  are known  in
 the area.

 CAC review and  comment,
 if any sites determined
 to be in  planning area.
                           This Evaluation is large-
                           ly on the engineering
                           study that will be con-
                           ducted by the consultant.
                           It may, nonetheless, in-
                           volve substantial cost
                           to the community, and
                           the public should be
                           kept apprised of results.

                           This step only applies
                           to projects with exist-
                           ing sewers.
These comments would best
be presented before or at
public hearing, if

Decision Points

Selection of
      A-95 review of
      Facility Plan
State review of
Facility Plan.
Public Participation

a)  30 days notice
    before public

b)  Final  respon-
    siveness summary
    with evaluation
    by grantee of
    effectiveness of
    public  partici-
    pation  program.
(See #22 below)
    Issues to be

    Is the selected
    alternative the
    most cost-effec-
    tive alternative
    to meet community

    To what degree
    have the environ-
    mental sociaO. and
    economic impacts
    of the recommended
    alternatives been
   Recommended Public

a)  Request question/answer
    period before public
    hearing opens.

b)  Considering scheduling
    public hearing in
    evening or on weekend
    to ensure adequate
    public attendance.

c)  Request distribution
    of Responsiveness
    summary to all who
    attend hearing.

d)  Evaluation by
    Advisory Committee
    of Effectiveness of
    public participation
Is plan in accord      a)
with all areawide

Will the alternative
selected eliminate
the problem?
                                                     Does plan comply with  a)
                                                     basin and 208 planning?
                               Request  to be heard
                               during review if plan
                               is  felt  to be inade-
                               quate or public input
                               has not  been adequate
                               ly  considered.
                                                      Present comments to
                                                      state agency if in
                                                      disagreement with
                                                      selection of alter-
                                                                           b)  Ask state to notify public
                                                                               of certification or refusal
                                                                               of plan and the basis for
                                                                               its action.

                                                     If  there has been mean-
                                                     ingful public involvement
                                                     throughout the Facilities
                                                     Planning process  (inclu-
                                                     ding  agency responsive-
                                                     ness  to public concerns,
                                                     much  of the hearing tes-
                                                     timony may focus on miti-
                                                     gating unavoidable im-
                                                     pacts.  In fact, if a
                                                     comprehensive and well
                                                     thought out public in-
                                                     volvement program has
                                                     taken place, the public
                                                     hearing may surface no
                                                     new issues, and may not
                                                     be  well attended.
                              The clearinghouse cannot
                              approve or  disapprove a
                              plan,  but rather gives
                              favorable or unfavorable
                              comments which are then
                              considered  by EPA.   The
                              comments can have a sig-
                              nificant impact on
                              whether a plan is
                              approved, however.

Discussion Points

EPA review of
Facility Plan
 (May be princi-
 pally state re-
 view in case of
 delegated pro-
 Impact Statement
       EPA Award of
       Step 2 grant.
Public Participation

a)  Evaluation of
    adequacy of
    public parti-
    cipation pro-

b)  If public par-
    ticipation found
    inadequate recom-
    mended remedial
 Public hearing.
    Issues to be

a)  Is the alternative
    cost effective?

b)  Have all require-
    ments been met?

c)  Has adequate public

d)  Should an environ-
    mental impact state-
    ment be prepared?

a)  Have all possible
    alternatives inclu-
    ding "no action" re-
    ceived adequate con-

b)  Have environmental
    impacts of all options
    been adequately

c)  Can negative impacts
    of recommended alter-
    natives be mitigated?
                                            (Award contingent  on  Step
                                             1 approval.)
 a)   Consultation with
     public regarding
     necessity of addi
     tional public par-   a)   User charge system
                          b)  Public participa-
                              tion workplan if
                              additional PP
                              deemed necessary
                                            b)   Industrial  cost
                                                recovery (ICR) system.
                          c)  Inform public of
                              financial impact of
                              user charge system.
    Recommended Public

    Make known any comments
    or views not expressed
    in foreworded Facility

    Request agency notifi-
    cation of determina-
    tion of plan.
CAC involvement in
weighing environmental
factors and determining

Widespread dissemina-
tion of information.

Workshop and meetings to
discuss impacts, alter-

Solicit widespread par-
ticipation in hearings.

CAC should continue to
function as needed
throughout Step 2.

They should especially
be involved in deter-
mining a user charge

Information should be
disseminated and a
public hearing should
be held if the costs
are high or contro-
versy arises.

                           If  you  are dissatisfied
                           with  any part of the
                           Facilities Planning Pro-
                           cess, this may be your
                           last  realistic oppor-
                           tunity  for appeal.  If
                           substantial parts of
                           the Facilities Planning
                           Process  have been dele-
                           gated to a state agency,
                           that agency will be your
                           first avenue of appeal.
No Facility Plan may
proceed until environ-
mental issues have been
satisfactorily resolved
when an EIS is prepared
by EPA.
                              An equitable user charge
                              system must be included
                              in the planning.   In
                              addition,  industrial
                              users must pay their
                              share of  construction
                              costs directly attribu-
                              table to  control  of  their
                              pollutant discharge.   A
                              proposal  for these charge
                              systems must accompany
                              the Step  2 application.
                              Detailed  engineering
                              plans and specifications
                              will be developed during
                              this stage.

      Decision Points

24.   EPA Award of
      Step 2 grant
25.   Step 3 grant
Public Participation

d)  Consult with public
    prior to adoption
    of user charge and
    Industrial cost
    Recovery system.
Issues to be
                        a)   Any primary impacts    a)
                            of construction such
                            as noise,  soil erosion,
                            air pollution, runoff,  b)
Recommended Public
                           CAC  should  continue
                           to function as needed.

                           Periodic  information
                           on progress, user
                           charge/ICR  ordinances,
                           or implementation
                           should be disseminated.
                          The construction phase
                          may create controversy
                          because of primary im-
                          pacts on adjacent pro-
                          perty or because some
                          members of the public
                          may not be aware of the
                          project until construc-
                          tion starts.   Implemen-
                          tation of user charge
                          and ICR must be com-
                          pleted by the time 80%
                          of construction is com-


                                                        PLAN OF STUDY OUTLINE

Grant Award
                                                   BASIC PROGRAM  (town of 10,000)

                                                                                      STAFF SUPPORT
                                                                              TARGET AUDIENCE
 Select Engineer
 Information Program
  Public  Participation
 Development of Plan
  Assessment of present
  and future situation
  Consideration of
  Submission of Final
  Plan to town
 Public notice
 Identify public liaison on grantee/
 consultant staff2

 Public notice to media and mailing
 list of depository and materials
 Identify key interests and develop
 project mailing list2
 Deposit key documents  in  town library
 Develop detailed public participation
 workplan w/informal public input3

 Develop and distribute public partici-
 partion workplan and first factsheet
 which  identifies engineer and describes
                                                                        wk.  1
                                                                        wk.  2
  Interview  208  PAC  members3
  Interview  key  local  officials  and  citizens3
  Newspaper  article  in local  paper
                          - Develop and distribute citizen survey3
                          - Attend various local group meetings3
                          - Compile results of survey3
                          - Agency responsiveness summary2
wks. 6-7

wks. 3-4

wk. 5

mos. 2-6
- Develop and distribute  factsheets3
- Notice of public meeting2
- Public meeting1
  Prepare article for local  newspaper
  Agency responsiveness  summary  2

  Distribute factsheet 3
  Notice of public hearing
  Public hearing *
  Agency responsiveness  summary  2
                                                                        mos.  7-9
                                                                        mo.  10

              Grantee and/or
Consultant,      Key citizen  leaders  who
                   express interest in
Public liaison     participating
 on grantee or   Mailing List
 consultant staff
                                                           Public liaison
                                                           Public liaison
                                                           Public liaison
              Public liaison
              Public liaison
              Public liaison,

              Public liaison
              Public liaison

              Public liaison
              Public liaison
                  208 PAC members
                  Public health officer,
                    town engineer,  town
                    planner, regional plan
                    ners, conservation com-
                    mission members, repre
                    sentative of local in-
                    dustry, chamber of com-
                    merce, etc.
                  Hailing list
                  PTA, JC's, Grange, LWV

                  Available to general
                    public, prepared for

                  Mailing list
                  Mailing list
                  General public
                  General public
                  General public

                  Mailing list
                  Mailing list
                  General public
  Town Approval State/
  EPA Review and EIS
  Dec ision
- Final responsiveness summary  1
mo. 11
 Note:  1Required by proposed Part 35
        2Required by proposed Part 25
        3Meets a performance standard of Parts 25 and/or 35

 Table  4
                                                    PUBLIC  PARTICIPATION WORKPLAN
                                                    BASIC  PROGRAM   (town of  10,000)

1. Step 1 grant award
2. Assessment of
   present and
   future situation
                                                                           wks.  1-6
wks. 9-10
                                                                           wks. 11-12
                                                                           wk.  13
Hire public liaison       f
Develop nailing list
Develop Public Participation Horkplan
Distribute PPWP and Pact sheet

Interview 208 PftC and/or CAC members 3
- their views on areawide and local water
  quality problems and key issuss which
  should be addressed, population projections
- their experience w/public participation
  key citizens who should be contacted

Interview key local officials and citizens 3
- identify major water quality problems/
- identify community goals and objectives
                         Publish article  in local newspaper which:
                         - describes current situation and status of
                           Facility Planning Process

                         - summarizes attitude of town officials and
                           key citizens on local water quality problems
                         - highlights the importance -of public input and
                           describes scheduled public participation
                         - identifies staff contacts
                         Develop and distribute  citizen survey             wks.  13-14
                           Based on data collected during previous
                           interviews, survey will seek to refine
                           community goals, identify  level of
                           knowledge and preferences  concerning
                           water quality

                         Compile results of survey 3                       wks.  15-16

                         Attend various local group meetings3              wks.  17-20
                           Get on the agenda of  various civic
                           aroups' weekly/monthly meetinas.  Present
                           overview of community water quality problems,
                           answer questions, explain  results of citizen
                           survey, seek to further refine community goals
                           and objectives

                         Prepare agency responsiveness summary             wk.  22
                         - summarizes results of citizen survey and
                           other public consultation  efforts.
                         - outlines grantee's response to citizen input
                         - placed on file at local libraries. Town Hall
                                                                                        Public  liaison
                                                                                        Public liaison
                                                                                                             TARGET AUDIENCE
                                 General public
Members of 208 PAC and
                                 Public health officer
                                   Town engineers.
                                   Conservation Commis-
                                     sion members
                                   Industrial discharges
                                   Chamber of Commerce

                                 General public
                                                               Public liaison on
                                                                consultant or
                                                                grantee's staff
                                                               Public liaison

                                 All registered voters
                                                               Public liaison
                                 PTA, JC's, Grange,
                                   League of Women
                                   Voters. Sierra Club
Note: ^Required by proposed Part 35
       Required by proposed Part 25
      3Meets a performance standard of Parts 25 and/or 35

   Table 4 cont'd.


3. Consideration of
 4.  Submission of
    Final Plan to town
 5. Town approval and
    submission to
    state and EPA
            TECHNIQUE                         SCHEDULE

Develop factsheets which describe various      wk. 26
  alternatives being considered and outline
  the costs and environmental impacts of each 3

Distribute factsheets which also include       wk. 28
  notice of upcoming public meeting *

Informal public meeting to discuss various     wk. 32
  alternatives, answer questions, identify
  options which may require further study ^

Prepare local newspaper article which de-      wk. 33
  scribes public meeting and decisions made 3

Prepare agency responsiveness summary 2        wk. 34

Distribute factsheet which highlights the      wk. 40
  major elements of the proposed plan and
  rationale for the selection 3

Notice of public hearing in local newspaper    wk. 41
  and sent to all on mailing list 2

Conduct public hearing to present final plan   wk. 46
  along with the draft EIS  (if required) for
  their approval to community.
  Allow for additional citizen comments.
  If previous public participation efforts
  have been successful, however, no signifi-
  cant new issues should be raised at this
• time, *

Public notice                                  wk. 47

Prepare final Responsiveness Summary1          wk. 48
  Place on file at local libraries. Town

Public  liaison
                                                                                      Public liaison
                                                                                      Consultant, pub-
                                                                                       lic liaison,

                                                                                      Public liaison
Public liaison

Public liaison

Public liaison
                                                                                     Public  liaison,
Public liaison

Public liaison

 Mailing list

 Mailing list

 General public

 General public


 Mailing list
General public, mailing

General public
General public

 Note:  * Required by proposed Part 35
        2 Required by proposed Part 25
        3 Meets a performance standard of Parts 25 and/or 35




  Public Liaison

  Consultant Staff



  $.15/mile - approx. 1,000 miles






1.  No actual dollar amounts are listed here as those amounts
    will vary depending upon a number of variables, such as:

      a.  size of community and resulting mailing list,
          travel costs, etc.

      b.  whether printed material is mimeographed, photo-
          copied or printed; and

      c.  whether community volunteer assistance is utilized
          (for example, the survey outlined in the Plan of
          Study could be distributed by local high school

2.  The budget need deal only with those expenses directly
    attributable to public participation.  The public
    participation and information responsibilities normally
    required of the consultant and the grantee need not
    be separately budgeted.

3.  The Plan of Study Outline submitted prior to grant award
    contains a"fair amount of detail on activities that
    take place during the first 45 days of the grant.  After
    the first 45 days, a revised workplan will provide
    additional detail on the remainder of grant activities.

Table  6

                                                            PLAN OF STUDY

Award of Step 1 Grant

1. Engineer selection
                                                   PULL SCALE PUBLIC PARTICIPATION
a) public notice
b) informal meeting w/key interests
                                                                            wk. 1
                                                                                                             TARGET  AUDIENCE
                                                               Range  of community interest
                                                                 that will ultimately be
                                                                 on advisory committee
    Initiate prelim-
    inary  stages  of
    public participa-
    tion plan  of  study
    (work  element of)
a) grantee hire
public participation
b) consulting firm designates public liaison2
c) begin to develop mailing list2
                          d)  deposit key documents in town library
                          e)  public notice regarding availability of
                          f)  establish citizen advisory committee^-
                             1)  notice to mailing list and media
                                of opportunity to become member
                             2)  notice to mailing list and media
                                of finally selected members.
                          g)  public notice w/factsheet of first  CAC
                             meeting to review public participation
                             wOrkplan.   Factsheet will describe  project.
                             Notice will include list of advisory  com-
                             mittee and engineer.3
                          h)  train advisory committee members  and
                             grantee in one-day workshop.  Purpose
                             will be to briefly review town's  water
                             quality problems, need for action,  role
                             of CACf types of conflicts and tradeoffs
                             likely.  Establish goals of CAC.  Workshop
                             run by grantee and consulting engineer.

 3. R«vi«w public parti-  a)  Public CAC meeting to review public partici-
    cipation work element.   pation workplan3
    Develop public par-
                                                                            wk.  2
                                                                            wk.  2
                                                                            wks.  1-3
                                                  wks. 1-3

                                                  wk. 3

                                               public part.
                                                                            wk.  3
                                                  wk. 6
    ticipation workplan
    Revised public participation workplan
    sent  to EPA1
                                                  wk. 5
                                                                            wks.  6-7
                                                               public part.
                                                public  part.
                                                coor .

                                               public part.
Volunteer  community leader
  w/organizational  skills
  and knowledge  of  water

Ali those  private and public
  interests with a.  potential
  interest in  the Facility
  Plan.  Some  of the  list
  will be  obtained  from the
  208 agency.

Hailing list media

Members of local organiza-
  tions such as:
  League of Women Voters
  Chamber of Commerce
  Sierra Club
  Tax Payers Association
  Local Union
  Minority Group
  Mailing list
                                                              CAC members, engineer,
                                                                town officials, state
                                                                              Bread range of community
                                                                                interests, CAC, consul-
                                                                                ting engineer, grantee
 Note:   ^Required by proposed Part 35
         2Required by proposed Part 25
         3Meets a performance standard of Parts 25 and/or 35

    Table 6  cont'd.


 Development of Facility

 1.  Assess  current
2. Assess  future
 3. Consideration of
   ness analysis
4. Engineer's .Recom-
   mendation on Pre-
   ferred Alternative
5. Town Approval
6. Application for
   Step 2 Grant
 a) begin monthly newsletter3

 b) informal consultation/interviews3

 c) joint 201-208 staff and CAC meeting3
a) field trip3
b) speakers bureau3
                          c)  series  of workshops  on special  issues3
                             1)  Sensitive  Environmental Areas
                             2)  Residential  and Industrial Growth
                          d)  public  meeting1
e) agency responsiveness summary1

a) factsheet on alternatives2
b) speakers bureau continues3

c) CAC mid-study briefing3

d) public meeting^
e) agency responsiveness summary1
a) public hearing notice2
b) prepare and mail factsheet 30 days2
   days in advance

c) hearing on recommended alternative and
   EIS 1

a) agency responsiveness summary distri-
   buted to hearing participants 2
b) final responsiveness study submitted
   to EPA with Facility Plan l
c) public notice of final decision 3
a) CAC meeting to develop public par-
   ticipation plan for Step 2 and 3
                                              mos. 2-4
                                              mos. 3-6
                                               mos. 7-8
mo. 9
                                                                                   public participation
                                                                                   public participation
                                                                                    coordinator, consult-
                                                                                    ant's public liaison
                                                                                   public participation
                                                                                    coordinator, grantee
                                                                                    rep., consultant
                                                                                    staff and public
           public part. coor.
           CAC, consulting
            engineer, grantee
           public part, coor.,
            consultant, public
           CAC, public part.
            coor., consultant
            liaison, grantee rep.
           public part. coor.
           public part. coor.
           as previously
           consulting engineer

           public part. coor.
                                                                                   public part. coor.
                                                                                   public part. coor.
grantee, puDiic
 part. coor.

public part. coor.
           public part. coor.
                                    TARGET AUDIENCE
                                  General public

                                  Key officials, selected
                                    citizen leaders and
                                    special interests
                                  201-208 staff and key
                                    advisory committees
                       General public
                       General public
                       Public and civic interest

                       General public and
                         special interests

                       EPA, state participants
                         in meeting

                       General public
                       CAC, grantee, public
                       General public
                       EPA, participants in
                                  General public
                                  Mailing list, civic
                                    organizations, local
                                  ueneraj. puDJLic
                                                                                                          EPA, state, hearing
                                                                                                          CAC members, grantee
Note:   Required by proposed Part 35
        Required by proposed Part 25
        Meets a performance standard of Parts 25 and/or 35

Table  7
Development of Facility

1. Assess current
                          PUBLIC PARTICIPATION WORKPLAN
                         FULL SCALE PUBLIC PARTICIPATION

             TECHNIQUE                          SCHEDULE
                                               mos. 2-4

a)  "Clean Water News",  Vol. 1 3 monthly news-   wk. 8
   letter to be mailed throughout the Step 1
   process.  The first newsletter will:
   - describe what is known concerning the
     current situation
   - describe additional information being
     sought by consultant
   - outline the project schedule including
     public participation activities
   - identify staff contacts and CAC members
   - solicit comments and feedback from public
     with brief tear out questionnaire

b) consultations with key publics
   i. informal interviews w/selected           wks. 8-12
      individuals w/knowledge of com-
      munity situation 3
                            ii. CAC meeting.   This will be an open      wk.  10
                                meeting announced in Vol.  I of the
                                newsletter and will center around the
                                key questions that should be asked
                                during the assessment of the current
                           Lii. Joint meeting with some 208-201 staff    wk.  11
                                and 208-201 CAC to discuss implica-
                                tions of 208 plan for 201 study.
                                Appoint permanent staff and CAC

                             "Clean Water News", Vol. 2 3               Wk.  12
                             - summarize preliminary findings of
                             - identify key areas of social/economic/
                               environmental conflict to be affected
                               by Facilities Plan
                             - notice of  field trip to problem areas
                                                                                     public part.  coor.
                         TARGET AUDIENCE
                       All interested persons
                         from the region
                       CACr consulting engineer
                         grantee representative
                       Use 208 mailing list
                                                                                     public part.  coor.
                                                                                      consultant,  public
                                                           public part. coor.
                                                           public part.  coor.
                                                            grantee rep.  con-
                                                            sultant staff and
                                                            public liaison
public part. coor.
                       Public health officer
                       Town engineers
                       Industrial dischargers
                       Conservation Commission
                       Other knowledgeable
                         citizen leaders
                       Citizens Advisory Commit-
                         tee and interested
                         members of general
                       Engineers,  grantee rep-
                         presentative,  key CAC
General public
     Notf>:   1 Required by proposed part 35
            2 Required by proposed part 25
            3 Meets a performance standard  of Parts  25  and/or  35

Table 7  cont'd.

2. Assess future
3. Consideration of
                         a) field trip focusing on areas of future

                         b) Speaker's Bureau:  public coordinator's
                            office and CAC speak at numerous scheduled
                            civic meetings regarding the issues involved
                            in the facilities planning process 3

                                                 mos. 3-6

                                                 wk. 16

                                                 wks. 12-24
                         c) send out notice of public meeting with
                            factsheet 2
                                   Water News", Vol. 3 3
                                  issues in future assessment study
  d) "Clean
     - key
     — what existing land-use plans and popu-
       lations projections mean for Facility
     - what does the 208 plan say about the
     - preliminary ideitification of treatment
     - notice of public meeting

  e) series of special interest workshops to
     discuss key issues and alternatives3

  f) public meeting with CAC*
     — establish working Task Forces as sub-
       committees of CAC to work w/consulting
       engineer in resolving critical issues
       and in monitoring the engineer's
       analysis of treatment alternatives
     agency responsiveness summary •*-

     Clean Water News,  Vol.  4  3
     - summarize results of public meeting
     - describe agency  responsiveness  summary
a) Clean Water News, Vol. 5, 3  This news-
   letter would include a factsheet presen-
   tation on the major alternatives being
   considered.  The factsheet will describe:
   - major environmental social and econ-
     omic impacts and implications for
     community development
b) public meeting notice
c) speakers bureau continues.  focus on
d) CAC and Task Force meet with consulting
   engineer for mid-study briefing on alter—
   natives 3
e) public meeting to solicit comments an
   questions on alternatives, and to present
   preliminary EIS study *
f) agency responsiveness summary
                                                 wk.  14
wk. 16
                                                                        wks. 14 -16

                                                                        wk.  19
wk. 20

wk. 20

mos. 6-9

wk. 24
                                                                        wk. 26

                                                                        wk.  28

                                                                        wk.  31
             public part.  coor.
                                                              public part.  coor.,
                                                               grantee rep.,
                                                               consultant liaison,
                                                                                     TARGET AUDIENCE
                                  CAC, grantee, consultant
                                    general public
                                  General public, civic
                                    groups, i.e., PTA,
                                    Rotary, garden clubs,
                                    environmental groups,
                                    round table, etc.
public part. coor.   Mailing list, general
                       public, CAC

public part. coor.
             public part. coor.,
              grantee rep., con-
              sultant liaison
             public part. coor.,
              grantee rep., con-
              sultant liaison
public part. coor.

public part. coor.
             public part.  coor.
             public part.  coor.
                     Civic  groups
                                                                                                          General public,
                                                                                                            special interests
EPA,  state
                     General public
                     General public
            public part,  coor.,
              grantee  rep.,  con-
              sultant  liaison,  CAC
            consulting  engineer,
              public part. coor.

            public part.  coor.,
              grantee, consult-
                                                                                                          General public,  CAC,


Table 7 cont'd.

4.  Engineer submits
   recommendation of
   preferred alterna-
   tive to town
   officials (mo. 11)
            TECHNIQUE                          SCHEDULE

a) notice of public hearing received 30        wk. **•
   days in advance"
b) factsheet summarizing final recommenda-     wk. 41
   tions and notifying of upcoming hearing 2
c) public hearing  (possibly town meeting) on   wk. 46
   recommendations and draft EIS 1

            public  part.  coor.

            public  part.  coor.


Newspapers,  mailing list
   general public

General  public,  mailing
5. Town approval of
   Facility Plan and
   submission to State
   and EPA
 6.  Application for
    Step 2 Grant
a) notify public-*
 - prepare agency final Responsiveness
   Summary •*•

 - place on file at easily accessible loca--
   tions around town  (public library, town
   hall), mail copies of agency responsive-
   ness summary to hearing participants

a) consultation with CAC to determine future
   role and develop public participation
   program for Steps 2 and 3  3
b) public notice and factsheet
                                                                        mo. 12
wk. 46
                                                                        wk. 47-48
                                                                                    public part. coor.
                                                                                    public part. coor.
General public
  State agency

General public

Table  8




  Public Participation  Coordinator

  Assistanc Public Participation Coordinator


  Consultant Liaison

Advisory Committee Budget


  Clerical Support

  Technical assistance

Staff Travel






1.  No actual dollar amounts are listed here as those amounts
    will vary depending upon a number of variable, such as:

      a.  size of community and resulting mailing list,
          travel costs, etc.

      b.  whether printed material is mimeographed, photo-
          copied or printed; and

      c.  whether community volu teer assistance is utilized
          (for example, the survey outlined in the Plan of
          Study could be distributed by local high school

2.  The budget need deal only with those expenses directly
    arrtibutable to public participation.  The public
    participation and information responsibilities normally
    required fo the consultant and the grantee need not be
    separately budgeted.

Table 8  cont'd.
3.  The Plan of  Study  Outline submitted prior to  grant award
    contains a fair  amount of detail on activities  that
    take place during  the first 45 days of the grant.  After
    the first 45 days, a revised workplan will provide
    additional detail  on the remainder of the grant activities,

4.  The cost of  the  public participation coordinator will
    vary depending upon the institutional attachments and
    background of that coordinator.  For example, the
    coordinator  could  be:

    a.  on the consulting engineer's staff;

    b.  on the grantee's staff;

    c.  a  representative of a public interest group; or

    d.  a  private citizen with background and experience
        in public participation programs.


                        APPENDIX C


Activated Sludge - Sludge  that  has  been  aerated and
   subjected to bacterial  action, used to  remove organic
   matter in raw sewage during  secondary waste treatment.

Activated Sludge Process - The  process of  using biologically
   active sewage sludge to hasten breakdown of organic matter
   in raw sewage during secondary waste  treatment.

Advanced Waste Treatment/Tertiary Treatment - Treatment
   beyond secondary or  biological stage  required to meet
   strict quality standards.  Depending  on the process
   selected, advanced or tertiary treatment can provide
   additional removal of standard organic  pollutants,
   suspended solids, inorganic  ions or nutrients such
   as phosphrous and nitrogen.  Advanced treatment is
   the "polishing stage" of wastewater treatment and
   generally produces a high quality effluent.

Ad Valorem tax - A value added  tax  such  as a property tax.

Advanced waste treatment/tertiary treatment - Provides
   additional treatment above secondary  treatment in order
   to provide additional removal of standard organic
   pollutants or to remove one  or more specific organic
   compounds or inorganic  ions  from the  stream.  A number
   of processes may be  involved depending  on the pollutants
   to be removed.

Ambient Water Quality - Quality of the receiving waters into
   which effluent is discharged.

Average Flow - The average quantity of effluent which
   enters the treatment system  over a given time period.
   Usually expressed as average daily flow.

Best Available Technology  (BAT) - The degree of pollutant
   removal possible by  application of the highest level
   of technology economically achievable.  BAT standards  are
   required for all toxic  and nonconventional pollutants  by
   July 1, 1984, unless  a  variance is obtained.

Best Practicable Technology (BPT)  - The  degree of pollutant
	removal achievable by application of  the best average
   technology economically and  technically practicable for
   a given industry.  BPT  standards are  required of all
   industries by July 1, 1977,  except where variances have
   been granted by EPA.

Best Practicable Waste Treatment Technology (BPWTT) - The
   degree of pollutant removal required of all publicly
   owned treatment works in 1983.  Defined by EPA as the
   equivalent of secondary treatment or whatever other
   treatment is required to meet water quality standards,
   BPWTT should involve reclaiming and recycling of water
   and confined disposal of pollutants so they will not
   migrate to cause water or other environmental pollution
   as well as consideration of advanced waste treatment

Biochemical Oxygen Demand (BOD) - The quantity of oxygen
   used in the aerobic decomposition of organic matter,
   usually expressed in parts per million.  The degree of
   BOD removal is used as a measure in determining the
   efficiency of a sewage treatment plant as well as in
   measuring stream water quality.

Cesspool - Large porous cistern into which residential
   wastewater flows.  Solids remain in the cistern while
   the effluent, a liquid portion, seeps out through the
   walls into surrounding ground.  Because little biological
   action takes place in the cesspool, the solids must be
   removed by frequent pumping.

Chemical Oxygen  emand (COD) - A measure of the amount of
   oxygen required to oxidize organic and oxidizable
   inorganic compounds in water.  The COD test, like the
   BOD test, is used to determine the degree of pollution
   in an effluent.

Chlorination - The application of chlorine to drinking
   water, sewage, or industrial waste for disinfection
   or oxidation of undesirable compounds.

Coliform Bacteria - A class of bacteria that live in the
   human intestines.  They are always present in raw sewage.
   Their presence provides positive evidence of pollution
   and the possible presence of the pathogenic bacteria.

Combined Sewers - A sewerage system that carries both
   sanitary sewage and storm water runoff.  During dry weather
   combined sewers carry all wastewater to the treatment plant.
   During a storm only part of the flow is intercepted because
   of plant overloading; the remainder goes untreated to the
   receiving stream.

Cost-Effectiveness Guidelines - Developed by EPA to aid
   grantees in the selection of the waste treatment management
   system component which will result in the minimum total
   resources cost over a fixed period of time to meet federal,
   state and local requirements.

Design Flow - The average  quantity of wastewater which a
   treatment facility  is designed to handle,  usually
   expressed in millions of  gallons per day (MGD).

Design Period - Time span  over which wastewater treatment
   facilities are expected to  be  operating; period  over
   which facility costs are  amortized.

Effluent -  (1) A liquid which  flows out of  a  containing
   space.   (2) Sewage, water or other liquid,  partially
   or completely treated,  or in its natural state,  flowing
   out of a reservoir, basin or treatment plant;  or part thereof,

Effluent Limitations - The maximum amount of  a pollutant
   that a point source may discharge into a water body.
   They may allow some or  no discharge at all,  depending
   on the specific  pollutant to be controlled and the
   water quality standards established for  the receiving

Effluent Limited -  Stream  segments which meet  and will
   continue to meet water  quality standards once  the
   national uniform point  source  controls are  applied.

Environmental Impact Assessment (EIA)  - A preliminary
   evaluation of the potential environmental  impacts
    (positive and negative) of  a proposed federally
   funded sewage treatment project.   It should be
   submitted ss part of the  Facilities  Plan.

Environmental Impact Statement (BIS)  -  A detailed analysis
   ofthe potential environmental impacts of  a  proposed
   project required when the EPA  Regional Administrator
   determines that  a project is highly  controversial or
   may have significant adverse environmental 'effects.

Facility Plan - Preliminary  plan  developed during the
   first step  (Step 1) of  the  Three Step Construction Program.
   The plan, based  on  an evaluation of  various  treatment
   alternatives, must  be both  cost-effective  and politically

Fecal Coliform Bacteria -  A  group of organisms  common to the
	intestinal tracts of man  and of animals.  The presence of
   fecal coliform bacteria in  water is  an indicator of pollu-
   tion and of potentially dangerous bacterial  contamination.

Force Mains - Pipes used to  remove wastewater  under pressure
	against the force of gravity,  allowing for  the transfer of
   sewage between natural  drainage basins or  for  conveyance of
   wastewater at minimal slopes over relatively long distances.

Grant-Eligible - Refers to costs of planning and constructing
   a treatment facility which may receive federal funds under
   the EPA Construction Grants program.

House connection (or house laterals) - This is the point of
   contact between the user and the treatment system.

Industrial Cost Recovery - A provision in the 1972 FWPCA
   which requires industries to pay back to the federal
   government the extra capital costs that their discharges
   impose on municipal treatment plants.  (The 1977 Clean
   Water Act established an 18-month moratorium on Industrial
   Cost Recovery.)

Infiltration/Inflow - Total quantity of water entering a
   sewer system.  Infiltration means entry through such
   sources as defective pipes, pipe joints, connections, or
   manhole walls.  Inflow signifies discharge into the sewer
   system through service connections from such sources as
   area or foundation drainage, springs and swamps, storm
   waters, street wash waters, or sewers.

Interceptor - Any pipe regardless of size that carries
   wastewater directly to the treatment plant.  Generally,
   they are the largest pipes in the collection system.

Lateral - The pipe to which individual houses and business
   establishments attach.  If one considers the analogy of
   tree, the laterals represent the twigs.

Main/Submain - The word main is frequently used loosely to
   indicate a large pipe which is not a lateral and not an
   interceptor.  It frequently forms one of the larger
   branches of a complex collection system.

National Pollution Discharge Elimination System (NPDES)
   The effluent discharge permit system establishes under
   the 1972 FWPCA which places conditions on the type and
   concentration of pollutants permitted in the effluent;
   and schedules for achieving compliance.

Non-Point Source Pollutants - Pollutions which do not enter
   the water, from any discernable, confined and discrete
   conveyance but rather wash off, run off or seep from
   broad areas of land.

Packaged Treatment Plant - A small treatment plant which is
   partially or completely preassembled by a manufacturer
   and shipped to a designated location.  They are available
   in a range of sizes from units designed to serve a single
   dwelling to modular units capable of handling one million
   gallons per day (MGD)

Peak flow - The maximum volume  of  effluent  expected  to
   enter a treatment  system  over a given  time  period.
   Treatment systems  are  designed  based on  an  estimate
   of the rate of peak flow  to  average flow for  different
   segments of the  system.

Plan of Study - An  initial brief description of  the  scope,
   schedule and costs of  a proposed facility plan.   It must
   be prepared by the grantee and  approved  by  the State and
   EPA before a Step  I grant can be approved.

Point source pollutants - Those that enter  the water from
   any discernable, confined and discrete conveyance such
   as a sewer pipe, culvert, tunnel or other channel or

Pretreatment - In wastewater treatment, any process  used
   to reduce pollution load  before the wastewater is
   introduced into  a  main sewer system or delivered  to
   a treatment plant  for  substantial reduction of the
   pollution load.

Pressure main - Some  systems rely  entirely  on  forced
   pumpingfas opposed to gravity  flow) of  sewage, to
   enable use of smaller  pipes  and simplify design and
   construction in  difficult terrain.

Primary impacts - Those which can  be attributed  directly
   to a proposed action.

Primary Treatment - The first stage in wastewater treatment
   in which substantially•all floating or settleable solids
   are mechanically removed  by  screening  and sedimentation.
   The process generally  removes 30-35 percent of total
   organic pollutants.

Prioritylist - A list developed by the state  Water
   Quality Agency of  proposed waste water treatment  projects
   in the state.  Projects are  ranked according  to their
   priority relative  to the  state's overall water quality
   management strategy and Federal Construction  Grant
   funding is distributed accordingly.

Reserve capacity -  Treatment system capacity which exceeds
   that required to meet  projected community needs for a
   given time period.  The law  requires that treatment
   facilities be designed to include "sufficient" reserve
   capacity to service future growth.  However,  EPA  will
   not fund excessive reserve capacity.   The actual  amount
   of reserve capacity funded by the Federal grant, must be
   approved by the  Regional  Administrator.

Sanitary Sewers - Sewers that carry only domestic or
   commercial sewage.  Storm water runoff is carried in a
   in a separate system.  See sewer.

Secondary impacts - Those resulting from indirect or induced
   changes in community land 'use patterns, population and
   economic growth, and environmental quality resulting
   from induced growth.

Secondary Treatment - Wastewater treatment beyond the
   primary stage, utilizing bacteria to consume the
   organic pollutants.  A number of processes may
   be used to achieve what EPA defines as acceptable
   secondary treatment standards—85-90 percent removal
   of total organic pollutants and suspended solids.

Septic Tank - The most popular on-site treatment technique
   relies on a collection tank which receives waste from the
   home and provides a period of settling, during which a
   significant portion of suspended solids settle out and
   are gradually decomposed by bacterial action at the
   bottom of the tank.  The remaining sewage is discharged
   into a drain field composed of lengths of porous or
   perforated pipe placed at shallow depths.  A well designed
   and maintained system will provide ecologically sound

Service Area - The area which will be serviced by a wastewater
   treatment system.

Sewage - Sewage refers to the wastewater flow from residential,
   commercial, and industrial establishments which flows
   through the pipes to a treatment plant.

Sewerage - Sewerage refers to the system of severs, physical
   facilities employed to transport, treat, and discharge

Sewer - Sewer refers to the pipe, conduit, or other physical
   facility used to carry off wastewater.

Sewer or Sanitary District - A sewer district is either a
   semiautonomous governmental unit whose purpose is the
   provision of sewerage or a special assessment district
   within which sewerage facilities are provided to residents.

Sludge - The accumulated settled solids deposited from sewage
   or industrial wastes, raw or treated, in tanks or basins,
   and containing more or less water forming a semi-liquid mass,

Storm Sewer - A conduit that collects and transports rain
   and snow runoff back to the ground water.  In a separate
   sewerage system, storm sewers are entirely separate from
   those carrying domestic and commercial wastewater.

Suspended Solids  (SS)  -  Small particles of solid pollutants
   xn sewage that  contribute to turbidity and that resist
   separation by conventional means.   The examination of
   suspended solids  and  the BOD test  constitute the two
   main determinations for water quality performed as wastewater

Tertiary Treatment - (see Advanced Treatment)

Trickling Filter - A device for the biological or secondary
   treatment of wastewater consisting of a bed or rocks or
   stones that support bacterial growth.  Sewage is trickled
   over the bed enabling the bacteria to breakdown organic

User charges - Fees  levied upon users of a wastewater
   treatment system  based upon the volume and characteristics
   of the waste.

Waste load allocations - Distribution of the total "pollutant
   load" permitted on a  particular water body among the
   various discharges to that water body.  (required by section
   303 of the Clean  Water Act.  The "pollutant load" for a
   particular water  body is determined by the water quality
   standards established for that water body.   Waste load
   allocations are applied in situations where stream segments
   are classified  as water quality limited.  They will generally
   result in imposition  of stricter effluent limitations on
   discharges to  a particular stream  segment than secondary

Water quality criteria - The levels of pollutants that affect the
   suitability of  water  for a given use.  Generally, water use
   classification  includes:  public water supply; recreation;
   propagation of fish and other aquatic life; agricultural
   use and industrial use.

Water quality limited -  Stream segments which will not
   meet water quality standards with  the application
   of uniform point  source controls.   Additional pollution
   control measures  for  industrial and municipal discharges
   will be required  if water quality  standards are to be

Water quality standard - A plan for water quality management
   containing four major elements: the use (recreation,
   drinking water, fish  and wildlife  propagation, industrial
   or agricultural)  to be made of the water; criteria to
   protect those  uses; implementation plans (for needed
   industrial-municipal  waste treatmsnt improvements) and
   enforcement plans, and an anti-degradation statement
   to protect existing high quality waters.
                           125         u.s. GOVERNMENT PRIHTIHC OFFICE: 1979 - 681-610/96 MCIOS HO. 8