OF THE
                  AS AMENDED
                     OF THE
                Washington, D.C. 20460

                      WASHINGTON, D.C.  20460
                           AUG U1975
                                                               OFFICE OF THE
TO:  All Water Quality Officials
     I have continued to stress over the past several years
the need to meld successfully the Federal and State water
pollution control efforts into a truly joint endeavor.

     Progress has been made.  We have instituted a joint
Federal-State program planning and reporting system.  Regional
Offices are increasingly interacting with their State counter-
parts.  States are assuming a greater share of the program
responsibility.  These achievements must be continued and
the effort pursued until we achieve a truly mutual partnership.

     Our resources are too limited to proceed otherwise.
The magnitude of the task ahead demands that work be cohesively
meshed and duplication eliminated.  The critical nature of
several programs requires that they proceed in a priority
fashion--and that this priority be supported through the
allocation of resources.  I expect that both Regional Offices
and States will be responsive to these two needs.

     The initial two years of effort after the enactment of
the Act were directed at accommodating a period of transition
during which States and EPA had to adjust existing programs
and procedures to address the requirements and initiatives
of the new Act.  Generally, this period of transition has
been completed.  We should see the results of this transformation
in the achievements of this year and future years.

     As an example, we are setting a target of an average
monthly obligation of $500 million in our construction
grants program over the next 22 months.  This rate is far
above our historical experience and will only be accomplished
by Regions and States pulling together to work in quickly
identifying and resolving problems, especially those that
impede ongoing program progress.

     There is much work to be done in the year ahead.  If
we are to accomplish our objectives, the dedicated effort
of the past several years must be continued.  I know that
it will be.

»  4% r.

                      WASHINGTON, D.C.  20460
                                1 8 1975
                                                            THE ADMINISTRATOR
TO:  Fellow Participants in the Effort to Clean Our
     Nation's Waters
     The Federal Water Pollution Control Act has  generally
been conceived as a program to be carried  out in  two phases.
The first phase concludes in July 1977 and the Nation  is now
half-way there.  The past nearly thirty months have seen
substantial progress--an achievement made  possible by  the
efforts of many of our citizens, both within and  outside of
government.  This progress was not easily  achieved.  The
hours have been long, the problems many, the issues unceasing;
and I commend you all for these efforts.

     This third edition of the Water Quality Strategy  Paper
charts the progress that has been made, but also  indicates
the extensive challenge that remains if this country is to
achieve the basic goals of both the Federal Water Pollution
Control Act and the Marine Protection, Research,  and Sanctuaries

     The Strategy is a dynamic document--it reflects changes
in direction, issues that are resolved, and problems that
arise.  It is not to be viewed as the final word, but  as a
presentation of our best thinking at this  time.  As the
program has proceeded, views have changed  and, hopefully,
matured.  As an example, we at EPA increasingly recognize
that funding resources at both the Federal and State level
may dictate the rate of progress.

     Perceptions are often the product of  dialogue, and I
wish that the many thousands of individuals who read and use
this Strategy Paper would come back to us  with their ideas
as to where we may be right or wrong in our approach to the
law.  Our wisdom is not perfect.  We have  benefited from the
counsel we have received from many diverse parties.  This
paper incorporates much of that advice and I expect future
Strategies to benefit similarly.

     This year is probably the most critical to date in our
implementation efforts:  permits must be secured by an
intensive compliance effort; an extensive areawide planning
effort will be commencing; and a construction grant award
program of great magnitude is being undertaken.  The tasks
are great but not insurmountable.  With your continued dedica-
tion and hard work, I am certain they will be accomplished.

                              Sincerely yours,
                                   R. Quarles, Jr.
                              Deputy Administrator

     The 1975 edition of the Water Strategy has been prepared for use
and review by Federal, State, and local government officials, and for
the information of the public.  It reflects the final decisions on the
Federal Government's FY 1976 budget.

     This year, the Overview is being issued as the basic strategy;
supplemented program modules which have been developed and are avail-
able from the separate program offices.  The Overview and program
modules are three-holed punched so that revised pages can be distributed
and incorporated during the course of the year to maintain currency.

     Major substantive changes to the 1974 edition of the Strategy have
been made.  Also, the discussion has been broadened to include
several new areas of program activity.

     The principal emphasis of the Strategy is on the implementation of
the Federal Water Pollution Control Act, for which EPA has the major
Federal responsibility; and the term "the Act" when used in the Strategy
means the FWPCA unless otherwise indicated.  EPA's role under the
Marine Protection, Research, and Sanctuaries Act in regulating ocean
dumping is also included.  Programs directed to the protection of
public water supplies are not addressed, although there is a discussion
of areas of the recently enacted Drinking Water Act which are related
to the FWPCAA.

     Persons using the Strategy are reminded that the Strategy, while
based on law, is not the law, nor is it a regulation mandated by the
law.  It is guidance for use by government agencies in implementing the

     The Strategy Paper is written under the aegis of the Water Planning
Division in EPA Headquarters.  While much of its development has been
within this Division, it also reflects the work of individuals within
all EPA Headquarters program areas, and the participation of EPA's
Regional Offices, the States, and interested public groups and citizens.

     Comments on the strategy are welcomed at any time.  They should be
addressed to the appropriate program offices and/or:

               Water Planning Division (WH-454)
               Environmental Protection Agency
               Waterside Mall, East Tower, Room 815
               401 M Street, S.W.
               Washington, D.C.  20460

                    LIST OF  PROGRAM MODULES

      The  following program  modules are  available.  Requests should be
 directed  to  the  EPA Assistant Administrator responsible for the
 subject program.


      1.  . Technology-based  Effluent Limitations.
      2.   Water  Quality Standards.
      3.   Toxic  Pollutant Discharge Standards.
      4.   Thermal  Limitations.
      5.   Modifications to  Effluent Limitations.
      6.   Preservation and  Maintenance  of Water Quality.


      1.   Compliance Monitoring and Enforcement.
      2.   Permits.


      1.   Treatment Plants  and Sanitary Sewers.
      2.   Combined Sewer Overflows and  Stormwater Discharges.


      1.   Planning and Program Management.
      2.   Water  Monitoring.


      1.   Nonpoint Sources  Pollution Control Program.
      2.   Oil and  Hazardous Substances.
      3.   Marine Sanitation.


      1.   Ocean  Dumping.
      2.   Ground Water.
      3.   Clean  Lakes.


      1.   Research and Development.


1.   Preparation of Environmental Impact Statements.
2.   International Agreements.
3.   Intermedia Impacts.
4.   Relationship between the Safe Drinking Water Act
     and the Federal Water Pollution Control Act.
5.   EPA and other Federal Agencies.
6.   Water Resources.

                          I.  OVERVIEW
     Summarized in this part of the Water Strategy are the near-term
and the long-range views of EPA on the control of water pollution.
Sections A and B chart EPA's goals for Fiscal Year 1976.  Sections C and
D put these goals in the broader perspective of the next decade.  The
1977-1983 sequence of the Act is discussed, and the direction of the
program is laid against recent and projected trends in water quality.

     The first two sections, in the form of themes and outputs, give
verbal and numerical images of EPA's immediate concerns.  It will be
evident that not all of the themes can be translated into or measured
by numbers.  Conversely, not all of the output categories represent
programs to be given top priority in the next year.

     Output values are, in reality, surrogate measures for the desired
end result, which is the improvement and maintenance of water quality.
Data on ambient conditions should appear increasingly in future versions
of the chapter on Water Quality in the Water Strategy, as these data
become available.

     This overview is supplemented by individual program modules.
Modules are being prepared for the following programs:

             The Basis for Control.
             Permits and Compliance.
             Municipal Construction.
             Program Management.
             Diffuse and Intermittant Sources.
             Oceans, Groundwater and Clean Lakes.
             Research and Development.
             Associated Program Areas.


            *  *  *    Major Themes for FY 1976    *  *  *

     The following major themes represent the focus for Fiscal Year 1976.
These are elements that should be common to every State and Regional
Office program effort.  They combine retained emphasis of past years,
new thrusts, and adjustments to program objectives.  The effect of these
themes is to establish priorities among program areas, which are sum-
marized at the end of the section.  While these are national themes, it
is recognized that States and Regions may need to establish additional
priorities that address individual areas of local and Regional concern.
These efforts are encouraged.

     1.   Follow-through on Current Accomplishments.

     During the past years, resources have been focussed on issuing
permits and awarding construction grants.  By the close of FY75 some
40,000 permits had been issued and $6.5 billion of grants had been awarded.
In FY76, issuance of first round permits should be completed, and further
major construction grant commitments will be made to overcome the backlog
of necessary treatment works construction.

     •    NPDES Permit Issuance and Compliance.--In the past, the permit
     program has emphasized issuance of permits specifying levels of
     control and phased dates for achievement of progress.  This now
     leads into a compliance monitoring and enforcement program based on
     those permits.  At the same time, reissuance of expiring permits
     and permits which presently lack self-monitoring or needed pretreat-
     ment requirements, and issuance of necessary new permits, will

          While compliance monitoring and enforcement will be this
     year's major focus, resources needs will be alleviated through the
     use of self-monitoring and reporting by permittees.  Self-monitoring
     requirements will be related to the source's potential environmental
     impact or lack of impact.

          The extent of non-compliance over the next several years is
     expected to be appreciable, other than with ocean dumping permits.
     Much of this non-compliance may be minor and temporary, but substantive
     violations will surely occur.  Appropriate judgment should be used
     by all parties so that resources will be directed toward achieving
     substantive industrial and municipal correction of this non-compliance.

     An effective compliance program can include many components.
Procedures as informal as a telephone call may often be the most

     Enforcement actions are an integral aspect of the NPDES program.
EPA and the States must conduct a joint effort to develop a realistic,
meaningful enforcement strategy.  The strategy must include assignment
of compliance monitoring and enforcement priorities.

•    Construction Grants.--For construction grants, EPA continues
to emphasize those municipal projects which form a central core to
achievement of both the effluent and water quality requirements of
1977/78.  Although obligations are not as high as last year's strategy
predicted, onligations in FY 75 wore over $3.6 billion, a large improvement
over FY 1974.  Increased State participation in the administration of the
program should continue to contribute to a more efficient grant award

     The Supreme Court recently ordered the release of the entire
$18 billion authorized in the Act for construction of treatment
works.  EPA now intends obligating nearly $11.5 billion more in
construction grants by the end of FY 1977.  This will demand a
major acceleration of the grants program.  It is important, however,
that EPA, the States, and local communities observe the established
construction priorities and perform thorough facility planning, to
insure these major expenditures will be cost-effective and will
contribute toward meeting the water quality goals of the Act.

•    Completion of Basin Plans.--Planning is the mechanism for
assessing water quality and making water quality management decisions
for an entire water body.  First round basin plans were to be
completed by July 1, 1975, except where the Regional Administrator
has allowed a one-year extension.  Completion of this round is a
key program output.

     Over time, existing plans will be expanded through the periodic
phase-in of additional elements.  In this way, basin plans will be
merged with the State's 208 planning requirements to form a single,
integrated program, termed "water quality management plans."
Revisions to the basin planning regulations (40 CFR 130-131),
proposed July 16, 1975, will provide guidance for this effort.

     Plan outputs must be available in time to feed into program
actions affecting both the 1977 and the 1983 goals of the Act.

     2.  New Thrusts.

     As last year's priority programs take hold, two important new
thrusts emerge:  Areawide waste treatment management planning and nonpoint
source programs.

     •    Areawide Waste Treatment Management.--Puring FY76, the initially
     designated areawide waste treatment management planning agencies
     (section 208) will produce work plans and begin their planning
     effort.  These plans must provide timely and usable guidance for
     water quality management decisions.  They must analyze existing
     pollution and the sources thereof to determine the water problem.
     Specific remedial needs should be identified.  Construction grants,
     permits and nonpoint source controls should key off the relevant

          Areawide planning focusses largely on the 1983 goals.  However,
     meaningful interim outputs are also expected.  Where appropriate,
     these should include support of near-term facility planning for
     municipal waste treatment planning.

     •    Nonpoint Source Programs.--The second new thrust calls for
     development of a balanced strategy that includes programs addressing
     nonpoint sources of pollution.  While approaches will vary in
     different areas, nearly all water areas will need to examine the
     runoff problem, including storm and combined sewers.  Use of non-
     capital intensive preventative methods will be emphasized.

          Control strategies will be developed by designated areawide
     planning agencies and by States.  For both, section 208 provides
     the principal authorities for addressing nonpoint sources.  The
     State NFS activities will commence in FY76 and will be programmed
     to support achievement of the 1983 goals.

          EPA recommends that NPS controls be based on a "best management
     practices" concept.  Importantly, once control needs and methods
     have been identified, implementation should be carried out.  Regulatory
     programs pursuant to section 208 should be established where necessary.

     3.  Preparing for the Years Ahead.

     During the first two years after the 1972 Amendments, many programs
could not be implemented as fully and as promptly as the Act contemplated.

This situation should not be repeated for the second phase, covering the
1977-1983 period.  Effluent guidelines, water quality analyses and waste
load allocations should be ready for use in the development of permits
addressing the 1983 requirements.  Similarly, planning should precede
the construction and permitting actions.

     The years of 1976 through 1978 are the period of preparation for
Phase II.  This year especially EPA and the States should carefully
examine their informational requirements for 1983 and develop the appro-
priate action for securing these data in 1977 and 1978.
     •    Program Decentralization.--EPA will continue to decentralize
     national water quality management responsibility to States.  Regional
     Offices should give higher priority to integrating their efforts
     with those of the States, and delegations of specific program areas
     should be stressed.

          By the end of FY77, EPA hopes that for each of the significant
     operational areas, other than marine protection (a Federal program),
     a majority of the States will have assumed the fundamental responsi-
     bility for the conduct of the program.  This view, of course, is
     dependent on the States receiving sufficient funding resources, and
     budget constraints at both the State and the Federal levels may dim
   ,  this goal.

          Many States have already assumed administration of the NPDES
     permit system.  Further State expansion should be emphasized in the
     areas of:  Construction grant administration, including 0§M review;
     enforcement (especially in those States which have assumed NPDES
     authority); monitoring; spill prevention and control; and small
     business loan applications.

          States and areawide agency capabilities and resources to
     operate effective programs are critical to this objective.  The
     annual development, by States and RA's, of State and Regional
     strategies and programs can focus the problem and identify EPA's
     role in supporting the State program.  In addressing resource
     needs, Federal manpower and education block grant programs should
     be considered.  If local institutional capabilities are not adequate
     for areawide management, the program grants under section 208
     should include assistance for development of the needed capabilities.

     •    Public Participation.--States and local agencies must develop
     effective mechanisms for workable community involvement.  For
     example, State or local advisory committees may be established for
     each planning area.  These committees should include appropriate
     local elected officials as well as other individuals and groups.
     In this way, their views and suggestions can be taken into account
     in the plan's formulation, before major decisions are cast.

          Constructive participation can benefit all parties:  It will
     help assure decisions which reflect the community's concerns, and
     it will also enhance the public's appreciation of the factors
     leading to those decisions.  An openly developed, responsive water
     quality management program should enjoy the public acceptance and
     support which is critical to its success.

     •    Examining Environmental Results.--It is anticipated that 1976
     will see the first major improvements in ambient water quality that
     will have resulted from actions taken under the 1972 law.  As these
     improvements occur, there will be an increasing need to correlate
     the efficacy of the abatement steps that were taken with the changes
     in water quality.

          Federal and State water quality monitoring programs are now in
     operation.  Monitoring information, and the analysis thereof, will
     form the basis for the States' first report to Congress, pursuant
     to section 305(b) of the Act, due to be submitted by EPA in October
     1975.  This report will be useful both to the Congress and to the
     National Commission on Water Quality, which is examining progress
     towards the Act's 1977 deadlines as a step in its broader examination
     of the goals and requirements for the next decade.  In addition,
     information on water quality and trends will help States, EPA and
     the Congress assess impact of current programs and indicate further
     needs and priorities.

     4.  A Continuing Attention to Program Problem Areas.

     EPA, in conjunction with the States, has intensified its attention to
major problem areas that developed during the first two years of implementing
the 1972 Amendments.  Many remedial measures have been accomplished.

     Some of the problems which are still present should respond to
administrative solutions.  Other problems are more substantive.  Remaining
programmatic problems include procedures to establish industrial pretreatment;
setting the nature of the control program for hazardous materials spills;
marine sanitation devices; and toxic substances.  Solutions in these
areas have yet to be implemented.

     Some program areas may require legislative remedy.  The agency has
submitted two major proposals for Congressional consideration in this
regard, and additional matters are being considered.  The current proposals

     •    An amendment to section 204(b)(l) to allow a
          municipality to use an ad valorem tax for its
          industrial user charge under certain circumstances.

     •    An amendment to section 307(a) to extend the time
          within which the Agency must hold public hearings
          on proposed toxic standards and to allow the
          statutory compliance period to be extended to
          up to three years from the date a standard is

     An amendment has also been submitted to provide that after 1976,
the required State water quality reports under section 305(b) would be
submitted biennially rather than each year.

     Other issues for which legislative changes may be appropriate
include a broader amendment to the toxic standards provision and modification
to the construction grant program.  The latter proposal would be designed
to maximize the grant program's funding impact by restricting sewer
eligibilities, limiting design periods, reducing the Federal grant share
in certain circumstances and altering the grant allocation formula.
EPA is reviewing the possible need for a toxics amendment.  The construction
grants-related issues were explored at public hearings held by EPA over
the summer.

     In addition, a bill introduced by Representative Cleveland would
authorize the Administrator to delegate a major portion of construction
grant program responsibility to States and to set aside up to 2% of the
State's construction grant allotments for the costs of program administration.
EPA has indicated its favor of the Cleveland bill.

     That issues are under consideration does not mean that EPA will
necessarily conclude that legislation is needed.  The Agency conducts an
environmental impact review in connection with its legislative proposals
and certain proposals introduced by others.  These comments help determine
the need for and effect of the possible amendments.  EPA's work with the
National Commission on Water Quality will also add to an appreciation of
possible legislative needs.

             *  *  *    Priorities for FY 1976    *  *  *

          NOTE:  National water quality program priorities
          are established by EPA's annual Regional Operating
          Guidance developed according to the Formal Planning
          and Reporting System.  These priorities are high-
          lighted here to provide overall program perspective.
          For actual priority directives, the Operating Guidance
          should be consulted.

     The following priorities, established among and within program areas
for FY 1976, form a general framework in assigning program resources.
(See Table I.)  Regional and State priorities may differ somewhat to
reflect the nature and dimensions of localized individual pollution

     The most important element in any water pollution control program
is that it be balanced.  Resources should not be exhausted on selected
program areas, leaving other priority areas without coverage; neither
should they be spread so thinly as to negate program effectiveness.

     For some EPA program areas and for some .States, it is recognized
that monies are not at desired levels to carry out effectively all the
program efforts and responsibilities under the Act.  In other instances,
it is taking time to bring additional personnel and resources to bear.
Near-term program requirements will not all be achieved by all implementing
parties all at the same time.  However, the Agency believes that through
a proper emphasis on priorities and an effective, decentralized manage-
ment system, critical program area goals can be achieved within a reason-
able period.

     EPA is acutely aware that the present recession may have a signi-
ficant impact on State revenues and the State's ability to fund its
programs at desirable levels.  Additionally; there has been a sizeable
inflationary bite.  Under these conditions, State assumption of greater
program responsibility may be dependent on additional Federal funds,
such as those that might become available under proposed legislation.

     1.   Priorities Among Program Areas.

     The major program priorities for FY 76, which are summarized in
Table I, are:

     •    Construction Grants.--Highest priority in FY 76 is for
          prompt, cost-effective and environmentally sound use of
          the massive construction grant sums available under the Act.
          Effective program management and adequate environmental re-
          views are important elements in carrying out this objective.

                                                                        TABLE I

                                                          WATER PROGRAM PRIORITIES, FY 76*
I.   First Priority National Water Program Areas.

     •  Municipal  Facilities Program Management.

        -  Construction Grant awards
        -  Facility planning
        -  EIS preparation

     •  Permits, Compliance monitoring and enforcement (Federal
        facilities carry the same priority as other facilities
        of the same type).

        -  Compliance of major dischargers with permit-schedules
        -  Compliance of major diselwirgers with effluent
        -  Increase program responsibility assumed by-States
        -  Resolve adjudicatory hearings and issue, reissue,  and
           modify  major, new source and power plant permits
        -  New source HIS preparation or negative declarations
           as  required.
        -  Achieve compliance with non-MPDES enforcement
        -  Ocean disposal permits

     •  Planning

        -  Areawide planning and management
         Source:   Water  Regional Guidance
         FY  76  (EPA,  2-14-75), pp.  3-4.
II.  Second Priority National Water Program Areas.

     •  Municipal facilities program management/manpower

     •  Oil and Hazardous Spills/response capabilities

     •  Permits, compliance monitoring and enforcement  (Federal
        facilities carry the same priority as other facilities
        of the same type).

        -  Compliance of minor dischargers  (except privately-
           owned sewage treatment plants).
        -  Ucissuancc of expiring permits for minor dischargers
        -  Pretreatment revisions to municipal permits
        -  Ocean sites EIS

     •  Planning

        -  Pliasc I point source and Phase II Statewide nonpoint
           source outputs through the  State continuing planning

III.   Third Priority  National Water Program Areas.

      •  Permits',  compliance monitoring and enforcement (Federal
         facilities carry the same priority as other facilities
         of the same  type).

         -   Issue  and revise minor permits
         -   Compliance of minor privately-owned sewage treatment

      •  Monitoring

         -   Ambient monitoring, including NNQSS          —
         -   Quality assurance
         -   State  implementation  of Appendix A program

      •  Oil and Hazardous Spills/SPCC plans

      •  SEA Loan  Application Review

      •  Technical Studies and  Support  (Coastal Zone Management,
         Marine Sanitation Devices, etc).

      •  Clean Lakes

      •  Water Quality Standards  Revisions

     •    Permits, Compliance Monitoring and Enforcement.--The permit
          and enforcement, with emphasis on major dischargers.
          Emphasis will also be given to encouraging State NPDES
          assumptions by States not yet participating and to con-
          tinued strengthening of existing State NPDES programs.

     •    Areawide and State Planning.--The third FY 76 priority I program
          is given to effective areawide planning by agencies
          designated under section 208.

     Oil and hazardous spill response capabilities should receive continuing
emphasis.  Other programs, although of lower priority, relate to water
quality monitoring, the small business loan program, technical studies
and support, the clean lakes program and water quality standards.

     The divisions of the incentive grant portion of the section 106
State program grants indicate the relative importance assigned to
various program areas.  Thus, municipal facilities management represents
the single most important program area, assigned some 22% of the incentive
resources.  Compliance monitoring and enforcement and permitting to-
gether almost equal the construction grant share, and water quality
management planning accounts for the remaining 8% of the incentive re-
sources .

     2.   Priority Within Areas.

     •    In construction grants, award and expenditure of cost-effective
     construction grants, supported by sound environmental review, is
     the highest program emphasis.  Provision and training of qualified
     operators must also receive a high priority.  Increasingly serious
     attention must be given to establishing effective and self-suffi-
     cient State agency manpower planning and training programs.  State;
     participation in program administration should be developed.

     •    Permits, Compliance Monitoring and Enforcement.--The highest
     priority in this area in FY 76 is to assure a high degree of com-
     pliance by major non-municipal dischargers with the NPDES permits.
     Non-NPDES compliance and enforcement also rates high priority.
     Assumption by States of NPDES authority in time for second round
     permits should be given major attention.  High priority is also
     given to the resolution of adjudicatory hearing requests and the
     issuance, reissuance and modification of major new source, power
     plant and ocean disposal permits.  This includes EIS's or negative
     declarations as required.  Lower priority is assigned to the
     issuance and reissuance of minor permits and to assuring their

     Enforcement actions against industrial violators of schedules of
compliance generally should receive a higher priority in the near-term
than actions against discharge conditions.  For municipal dischargers,
enforcement generally be against the discharge, since construction schedules
are largely controlled through construction grants.  Compliance monitoring
is a component of this activity and receives equal priority.

     •    Planning.--Development of areawide waste treatment management
     plans by designated agencies, including completion of initial
     interim outputs, is the highest priority in planning.  This is
     followed -in second priority by completion of the initial phase of
     basin planning and initiation of State nonpoint source planning
     in the Phase II water quality management planning process.  Prepara-
     tion for water quality standards review and, if necessary, revi-
     sions in keeping with the 1983 goals should commence.

          Timing for the State's activity is, of course, somewhat de-
     pendent on State capabilities and resources.  However, a recent
     court decision requires States to act as the section 208 planning
     agency for non-designated portions of the State in the same manner
     as designated agencies and to complete those plans by November,

     •    Monitoring.- -Analysis of major State laboratories is a third
     priority national objective and an important item in the FY 76
     monitoring program effort.  It will help assure that the labs can
     participate effectively in the compliance monitoring and enforce-
     ment program.  Development of a field laboratory quality assurance
     program is also emphasized.  Water quality analysis through the
     NWQSS network should be continued and expanded.

     •    Oil and Hazardous Substances Spill Prevention and Control.--
     Response effort to oil and hazardous spills should receive higher
     emphasis than development of contingency plans.  The hazardous
     materials prevention program will not be initiated until FY 77,
     due to delay in promulgation of key regulations.

     3.   Regional Priorities.

          uniform application of national priorities may be inappropriate
for the Regional Offices and States which have local and geographic problems
that require particular attention.  Specific areas that have been identified
by the Regional Offices as receiving focus in 1976 include:

     Region I.

     Special regional priorities in Region,! are:

     •    Lake restoration and preservation.

     •    Control of combined sewer overflows through facility
          construction grants and permit activities.


     •    Intensification of Federal/State programs providing technical
          0§M assistance and guidance to local communities.
     •    R§D programs on sludge and septage disposal.
     Region V.
     Region V will emphasize the Great Lakes Initiative Program, undertaken
pursuant to the Canada/United States Great Lakes Water Quality Agreement
(April 1972) .  The program includes:
     •    Upper Lakes Study.
     •    Pollution from Land Use Study.
     •    Great Lakes water quality surveillance.
     •    International Joint Commission support activities.
     •    Section 108(a) demonstration grants.
     •    Great Lakes research.
Various ongoing EPA activities further support the goals of the agreement.
    ~Region VIII.
     In Region VIII, the Regional Office and States are dedicating parti-
cular attention to the preservation of high quality water, recognizing
the environmental problems associated with the development of the major
energy resource reserves located in the Region.


     This sections describes the major anticipated program outputs.
Table II identifies numerical output projections for FY75 and FY76.

     Construction Grants.

     A total of $18 billion has been made available to the States from
FY 1973-75 monies under the Act.  Over $6.5 billion of this was obli-
gated by July, 1975.  Although this total is below the $7.7 billion
projected in last year's strategy, it nevertheless represents an
increase in grant activity in FY 75 over FY 74 and reflects an increased
number of grant applications meeting prerequisite requirements.

     In FY 1976 EPA plans to award about 6,000 construction grants
with a value of $5.6 billion, Achieving this goal will require a
strong acceleration in the grants program.

     A 35% increase in the number of 201 facility plans is forecast
from FY 1975 to FY 1976.  The number of plans is less than the number
of project awards as a plan may cover several separate facilities,
and much equivalent planning work has already been done.

     Permits, Compliance Monitoring and Enforcement.

     In compliance monitoring, all self-monitoring reports-- some
800,000-1,000,000--will be reviewed as to receipt; reports will be
reviewed selectively for contents.  In addition, one facilities
inspection will be conducted at each major discharger during the
year, with return visits as necessary.  Selected minor dischargers
will also be visited.  Enforcement actions will be undertaken as

     EPA and the States have received approximately 49,000 permit
applications.  Almost all majors and most minors had received their
permits by the beginning of FY76.  Emphasis will be on issuing, reissuing
and modifying the rest of major, new source, and power plant permits.
Remaining municipal, minor discharger, Federal facility, agricultural, ves-
sels, and privately owned treatment facilities permits must also be processed.

     Planning and Monitoring.

     The States' delineation of basin boundaries increased the number
of basins for planning purposes to about 630.  A basin plan is being
developed for each of the basins through the section 303(e) process.
Approximately 40-50% of the plans had reached an intermediate
level of management information by the beginning of FY 1976.  Nearly

                                                           TABLE  II
                                                     MAJOR PROGRAM OUTPUTS
                                         (Source:  Federal Planning and Reporting System)


Compliance inspections,
visits and/or samples
Municipal permits issued
Industrial permits issued
Agricultural permits issued
Federal Facilities permits issued Major
Number of New Construction Grant

(EPA $
(EPA §
(EPA §
(EPA §
(EPA §
(EPA $
(EPA §


Dollar Value of Construction Grant Awards (Millions)
Number of Facility Plan Grant Awards
Water Quality Management Plans :
208 Planning Areas designated
Phase I

plans completed

Number of State Laboratories Evaluated
Number of State/Regional Quality
Assurance Programs
As n<

                                 (12-month Fiscal Year)
                                 Projected (Preliminary)
                                                                                              Once each;  returned as needed.
 *135  approved; 138 grants  (3 from last year).

all plans will be complete with respect to water quality analyses
to support the issuance of permits in water quality segments.  As of
February 28, 1975, waste load allocations had been completed for
approximately 1700 water quality segments.

     Beginning in FY76, States are expected to initiate nonpoint
source planning as a part of the State's water quality management

     One hundred forty nine areawide waste treatment management agencies
were funded by the end of FY 75, including 11 FY 74 grants and 138 during
FY 75.  Interim outputs from these agencies are due within nine months
after their start-up.  The new areawide designations in FY 76 will be
dependent on the amount of funds made available and the use of any 208
funds by the State.

     In monitoring, most State quality assurance programs should be
acceptable by the end of  FY 76.  There will be no actual increase
in the number of monitoring stations from FY 1975, but some relocations
and changes in sampling frequency may occur.  This should result in
a contining enhancement of data recording.


     This section relates the various program activities discussed
in this paper to the time requirements of the Act.  This sequencing
is summarized by the flow chart on page 17.  The final objective
in this sequence is to achieve the Act's 1983 water quality goals.

     General phasing.

     The Act targets two dates, July 1977 and July 1983, to serve
as major mileposts.  There must be achieved by each date a national
base level of technological control.  In addition, by 1983 the Act
provides for the attainment of a general level of water quality in
the country that will protect aquatic life and allow swimming.  In 1977,
in contrast, there is no legislatively specified ambient goal, although
applicable local water quality standards are still to be met.  EPA
has determined that, generally, these local water quality standards
should provide for recreation on the water and protection of aquatic

     The period 1973-1977 is generally referred to as Phase I of the
Act's implementation, and 1978-1983 as Phase II.  The distinctions
between Phase I and II are sometimes blurred, especially in programs
which are not geared to the periodicity set essentially by the issuance
of permits.  These others include large areas of research, enforcement,
and the response to unique or accidental spills.

     •  Phase I emphasizes the issuance of permits and the award of a
        large portion of needed construction grants.  These two programs
        will be a major factor in efforts to achieve the 1983 goals:
        For some sources, achieving the 1977 requirements will be all
        that is necessary for 1983.  Most of the pollution problems
        being addressed in this phase are well identified and, compared
        to many of the problems which will remain, readily correctable.
        Much of the Phase I effort proceeds from the work of the State
        and the Federal Government in past years.

     •  Phase II will be a period when solutions become more subtle
        and the alternatives for abatement more conflicting.  It will
        demand a better understanding of the cause-effect and cost-
        benefit relationships between objectives and results.  This
        will be the period for implementing most of the plans for
        controlling nonpoint sources and the more difficult point
        sources of pollution.  A solid start toward addressing these
        problems will already begin, however, during Phase I.

     The Act also contains the goal of no discharge of pollutants for
1985.  This goal cannot be implemented under the authority of the
existing Act.  Furthermore, EPA foresees that universal achievement
of "no discharge" by 1985 may not be either feasible or environmentally
desirable.  Indeed, for the 1983 ambient water quality goal as well,
the present interpretation of the legislative caveat "where attainable"
recognizes that naturally induced background conditions could result in
a failure to meet the 1983 goal in some waters.  However it is not
intended that ongoing point source pollution, whether individual or
aggregate, be the prevailing reason for its non-achievement.

     Water Quality Analysis and Setting of Standards.

     During Phase I, State water quality analysis and planning has
concentrated on classifying segments as to water quality, analyzing
the problems and targeting solutions.  Attention has focussed on the
"water quality limited" segments--those in which compliance with the
Act's technology-based-effluent limitations guidelines and standards
is not sufficient to achieve water quality standards.

     For such segments, States determine the total maximum daily
load of pollutants which may be added to the segment without violating
standards.  Target effluent reductions for individual dischargers,
including Federal facilities, are derived from the total loads:  These
targets may form the basis for permits in both Phase I and Phase II.

     In preparation for the Phase II program, States will redefine
segments to include the land area relating to each stretch of water.
Classifications will also be reviewed in order to reflect the 1983
water quality goals and the impact of second phase technology-based
requirements.  The reclassifications will take into account nonpoint
source impacts.

     This information will lead into water quality standards revisions
during FY 1976-1977.  Revised standards should be directed to the 1983
water quality goal.  Waters which will be excepted from meeting this
goal will be identified in this effort.  EPA will promulgate revised water
quality criteria for use in the water quality standards revisions.

     Phase II waste loads in water quality limited segments will be
developed on the basis of the revised standards.  They will address
the specific parameters which are violated.

     The load analyses may lead to target limitations for permits
and/or identification of nonpoint source control needs.  Conversely,
they may show that use of 1983 technological limitations and basic
nonpoint source controls should be sufficient.  In the latter case,
the segment will be reclassified, and base level technological limits
will be employed in writing permits.

     Permits, Compliance Monitoring and Enforcement

     Permits have been issued as rapidly as possible during Phase I
to set compliance with the 1977 requirements.  By law, no permit
term exceeds five years.  Upon expiration, a second round of permit
issuances will occur to set compliance with the 1983 requirements.

     For industrial point sources, the first round of permits is based
on effluent guidelines and regulations describing best practicable
technology for many major industry categories, or on the basis of
water quality analyses in water quality limited segments.  Additional
water quality data and more complete and advanced guidelines and
regulations will be available for the second phase of permit issuance.

     Compliance monitoring and enforcement will become a major focus
of the permit program during Phase II, to assure that the permits'
potential for water quality improvement will be realized.

     Municipal Facilities.

     In the municipal field, a massive program of Federal financial
assistance is provided to communities to help meet the terms of permits.

     During Phase I, grant awards must be both expeditious and effective.
Awards will continue to be concentrated on historically eligible projects,
such as treatment plants, rather than newer eligibilities such as
collection sewers.  To achieve immediate water quality improvement,
permits for existing facilities will emphasize operations and maintenance
steps that can be achieved with minimal capital investment.

     During the 1975-1977 period, communities and States should
introduce within the State priority list facility plans relating to
combined sewer flows.  Abatement of pollution from combined and
storm sewers is likely to be necessary in some areas to meet the 1983
water quality requirements.
                                  1 Q

     As most municipal plants achieve the minimum technological
standards that are required, some facilities, because of growth or
water quality requirements, must employ higher levels of treatment.
They will undertake increasingly important studies to achieve a
cost-effective solution to their problems.  They will select between
major alternatives, including:  (1) the type of treatment:  recycling,
land disposal, or surface water disposal;  (2) the increase in capacity
versus correction of infiltration/inflow; and (3) the sources to be
treated--whether combined sewer overflows or higher plant efficiency.

     The Federal funding program will continue to be oriented towards
the correction of existing problems, and not towards a perpetuating
level of assistance.  It is expected that with the completion of that
construction necessary to meet the 1983 water quality requirements,
State and local governments will move to an era of financial self-

     Facility planning is an integral step to the construction of
municipal treatment facilities.  Their completion will be emphasized
during the next several years so that construction of treatment works
can proceed expeditiously.  Over time, these plans will be incorporated
into and in some respects, supplanted by, planning which will take
place at the areawide level.  However, areawide planning is not intended
as a substitute for all the elements of a facility plan, and facility
plans will remain a precondition to the award of a Step 2 or 3 grant.

     Water Quality Management Planning.

     In Phase I States have developed and begun to implement a coordinated
program of State water quality management.  Components of the program
are:  The State strategy, which covers a multi-year period; the
annual State program, which identifies specific program outputs each
year, and State water quality management planning, conducted in each
of the major hydrologic units of the State.

     In Phase II, program management will expand its attention to
nonpoint source pollution control needs.  Areawide planning authorities
under section 208 will be the principal vehicle for this program.
Current planning, which concentrates on point source control needs,
will be updated on a continuing basis in order to retain its rele-
vance for water quality management decisions.

     The areawide waste treatment management planning effort, conducted
by designated agencies pursuant to section 208, was initiated in
1974.  The bulk of initial designations was completed by July 1975, al-
though a number of initial designations remain as funds are presently
exhausted.  These agencies will develop comprehensive plans covering
both point and nonpoint sources.  They should be completed within two

     The primary importance of areawide agencies.will be realized
when plans are carried out during Phase II.  However, their work
should include interim outputs necessary to support facility planning
within Phase I.

     The State, as a part of its program management system, will
assure that areawide planning will be conducted throughout the
State.  In areas which are not designated pursuant to section 208,
the State's water quality management plans and individual facility
plans will provide programs in accordance with the needs of the area.

     Toxic Pollutants.

     During Phase II increased attention will have to be paid to
toxic pollutants in order to meet the 1983 water quality goal.
Phase I has concentrated on controlling traditional water pollutants,
such as biochemical oxygen demand and suspended solids.  The more
exotic pollutants, such as the refractory organics and the heavy
metals, remain a great challenge.  A coordinated effort of research
into toxic pollutant control technologies, health and ecosystem
effects, and fates in the environment must be coupled with existing
knowledge to produce an effective regulatory program for the control
of toxic pollutants if the 1983 goal is to be achieved.

     Nonpoint Sources.

     As the abatement of point sources is achieved, the scope and nature
of nonpoint source pollution will become increasingly obvious.  During
Phase II, NPS control will become a major program emphasis.  Preparation
for this will occur in Phase I, during FY75-76.  EPA will expand its
information and guidance on nonpoint source control methods and
techniques, and with the States undertake cooperative pilot projects.
Guidelines have been issued for the establishment of the appropriate
areawide planning processes and management capabilities, under
section 208, and State nonpoint source programs will be included in
the State water quality management planning regulations and guidelines.
States and areawide agencies are expected to develop NPS control
strategies in 1976-77.


     EPA's strategy for water pollution control is based upon certain
assumptions concerning the present quality of waters in the United
States, the causes of pollution where it exists, and the trends and
progress that can be made in pollution abatement.  This section presents
a selection of data on inland surface water and notes the relationship
of the national program to the problems that are identified.

     Water quality inventory.—On August 8, 1974, EPA sent to Congress
     the results of the Agency's first National Water Quality Inventory,
     as required by section 305(a).

          Briefly, the results of the 1974 inventory of river segments
     showed that:

          •  Pollution exists in 3100 water segments of varying
             lengths and areas, in the 53 States and Territories

          •  About half of the segments are so heavily polluted
             dischargers located on them will be required to go
             beyond 1977-level pollution controls to enable
             water quality standards to be met.

          •  Based on the State problem assessments now available,
             over one-third of the segments may be able to meet
             water quality standards by 1977.

          This projection represents a difference between the timetable
     of the Act (meeting applicable water quality standards by 1977, and
     meeting aquatic life and swimming water quality standards where
     attainable by 1983) and the States' own assessment of probable
     water quality improvement.

     State pollution identification.--The States have identified their
     most severe areas of water pollution.  These include both point and
     nonpoint types of pollution in both rural and urban areas.  Table III
     lists a few examples of these problem areas.

     The 1974 assessment, and the listing in Table III, indicate that
the variations in character and causes of severe pollution limit the
applicability of any single national strategy for water quality improvement.
State and Regional shifts in emphasis should be reflected in specific
State and Regional strategies and programs.

                                TABLE  III


District of




New Mexico

Puerto Rico
Lower Colorado River

Potomac River

Santa Fe River
Upper Snake River

Wabash River

Arkansas River

Major Lakes

Upper Blackfoot River

Tidal action on
  most rivers

Fecal coliform §

Malfunctioning sewage
  sewage treatment
  plants and septic

Industrial discharges
  § agricultural runoff

Oil field operations

Agricultural nonpoint

Cultural stress inducing

Acid Mining drainage

Inadequate sewage treat-
  ment facilities opera-
  tions and maintenance

Pollutant buildings
  at river mouth

      Study of major rivers.--In addition to the inventory of river
      segments,  EPA studied 22 major rivers in detail in 1973.  This
      study showed the following:

            •  The worst readings and trends are those for nutrients.

            •  Other pollutants with high levels are phenols
               (industrial compounds which can taint fish flesh)
               and suspended solids (which interfere with some
               aquatic life processes).

            •  The pollutants receiving the most widespread controls --
               bacteria and oxygen demand--show general improvement
               in the last 5 years.

            These data point to the emergence of eutrophication as a
      potential  problem in the country.  Both the amount and concentra-
      tion  of nutrients rise in wet weather.  This signals the future
      importance of nonpoint source controls on urban runoff and agriculture
      in correcting eutrophication.


      EPA's water quality data, along with the problems reflected in
 Table  III  and numerous variations thereof, underly EPA's two-phase
 strategy--Phase I emphasizing the institution of known controls, with
 Phase  II directed toward the more difficult and persistant problems.
4U.S. GOVERNMENT PRINTING OFFICE:1975 632-474/1082 1-3          23