&EPA
United States
Environmental Protection
Agency
Office of Water
Program Operations (WH-547)
Washington DC 20460
EPA-430/9-79-006
February 1979
Municipal Wastewater
Management
Citizen's Guide to Facility
Planning
FRD-6
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MUNICIPAL WASTEWATER MANAGEMENT
Citizens Guide to Facility Planning
Edited by
Clem L. Rastatter
The Conservation Foundation
Washington, D.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
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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
NOTES
To order this publication, "Municipal Wastewater
Management, Citizen's Guide to Facility Planning,"
(FRD-6) from EPA, write to:
General Services Administration (8FFS)
Centralized Mailing Lists Services
Building 41, Denver Federal Center
Denver, Colorado 80225
Please indicate the FRD number and title of publication.
Multiple copies may be purchased from:
National Technical Information Service
Springfield, Virginia 22151
ii
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ACKNOWLEDGMENTS
Much of the material in this handbook has been adapted
and updated from papers written for The Conservation
Foundation in 1978 by: John S. Banta, Barbara Reid
Alexander, Robert T. Dennis, Elizabeth Haskell and
Marissa T. Roche.
Special thanks go to Stuart A. Rohrer for his careful
editing of the final manuscript. Thanks also to EPA
personnel who reviewed the manuscript for technical
accuracy: John Hammond, Larry McBennett, John Kingscott,
and Elaine Stanley.
ill
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FOREWORD
JThis 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 handbook 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 important
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 madeV and
-—«d
• 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 insure;
® 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
9 that a community develops a commitment to continued
oversight of the operation and maintenance of the
facility.
This handbook is organized around a logical progres-
sion of questions that the involved citizen or local
governmental official is likely to encounter in trying to
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influence the municipal sewage facilities planning process.
The handbook reflects the latest federal regulations and
policies, as of January 1979, and assumes a level of
interest that is more than casual on the part of the reader,
The book does not contain a large number of citations, how-
ever, and the reader may wish to obtain copies of certain
regulations from the Regional EPA Office. A detailed Table
of Contents proceeding each chapter allows the reader to
focus on selected issues without having to read the entire
book.
This handbook has been designed for the "lay"
reader, either governmental or nongovernmental. Never-
theless, certain technical terms were unavoidable. A
glossary can be found in Appendix B. A second book is
being published by EPA concurrently with this handbook.
It contains a summary of the material in this book, plus
descriptions of useful public involvement tools. That
book, entitled Municipal Wastewater Management: Public
Involvement Activities Guide (FRD-7) may be obtained by
contacting the following address:
General Services Administration (8FFS)
Centralized Mailing Lists Services
Building 41, Denver Federal Center
Denver, Colorado 80225
Please indicate the FRD number and title of publication.
Clem L. Rastatter
Project Director
The Conservation Foundation
January 1979
vi
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FORWARD
CONTENTS
Chapter I:
Chapter II
Chapter III
THE FEDERAL WATER QUALITY PROGRAMS:
AN OVERVIEW
The Clean Water Act and the Municipal
Facilities Program. Planning provisions
of the Clean Water Act. Controversy and
confusion in implementing planning
provisions. New regulatory thrusts.
Other federal laws that affect the Clean
Water Act.
SEWAGE TREATMENT PLANNING IN A COMMUNITY
CONTEXT
Ecological problems of wastewater
treatment. Relationship of wastewater
treatment to housing and community
environment. Controversial issues
in wastewater planning. Primary and
secondary environmental, economic and
social impacts. The continuing
community responsibility after
construction.
INSTITUTIONAL ISSUES OF SEWAGE MANAGEMENT .
Federal, state and local responsibilities
for the Construction Grants Program.
New state role for management of program
through Delegation Agreements. The local
role and actors. Political issues in the
implementation of the Construction Grants
Program. The impact of federal financial
assistance on the program.
23
43
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Chapter IV:
Chapter V:
Chapter VI:
Chapter VII:
INTRODUCTION TO STEP 1 PLANNING 65
Controlling objectives and standards of
the Construction Grants Program. What
will the federal government pay for?
Early opportunities to influence sewage
treatment planning. Establishing initial
eligibility for a federal grant. The
grant application and Plan of Study.
The role of the public participation
outline in the Plan of Study.
FACILITIES PLANNING 91
Major decision points in the facilities
planning process. Assessing the current
situation. Assessing the future situation
Size of the facility. Establishing
population and wastewater flow projections.
Land use and sewer issues. Service area
of facility.
The sewage treatment alternatives that
might be evaluated. No facility.
Conventional options. Land application.
Reuse of wastewater. On-site treatment.
Cost factors associated with major
treatment systems. Nonmonetary factors
in selecting the sewage treatment
alternative. Procedure for evaluating
environmental impacts. Political,
institutional and legal considerations.
Financing the wastewater management
system.
PUBLIC INVOLVEMENT IN FACILITIES PLANNING . .159
Public participation requirements in the
Clean Water Act. The major federal
regulations that establish public right
to involvement. The effect of public
participation regulations in your
community. Developing a public partici-
pation program. Problems and opportunities
in the implementation of public partici-
pation programs.
MITIGATING PRIMARY AND SECONDARY IMPACTS
OF WASTEWATER TREATMENT FACILITIES 209
Primary and secondary impacts. Legal basis
for consideration. Selecting appropriate
mitigation measure. Techniques available,
feasibility, implementation responsibility;
authorities and capabilities for implemen-
tation.
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Page
Role of EPA.
Case Studies: Block Island, Rhode Island;
North Fremont County, Idaho; East Bay,
California.
Appendices
APPENDIX A 253
Calculations of Present Worth
User Charge Systems
APPENDIX B 257
Glossary
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LIST OF TABLES
Page
1. Impact Categories of Sewage Treatment Plant 30
Construction
2. Interceptor Construction and Maintenance
Primary Impacts 33
3. Major Facilities Planning Decisions 99
4. Secondary Treatment 118
5. Advanced Treatment 119
6. Summary of Available Alternatives Relative to
Requirements for Pollutant Removal 120
7. Sludge Treatment Techniques 124
8. Comparative Characteristics of Irrigation,
Infiltration-Percolation, and Overland Flow
Systems for Municipal Wastewater 138
9. Facility Planning
Public Participation Planning Guide 185
10. Model Plan of Study Outline
Basic Program (town of 10,000) 197
11. Model Public Participation Workplan
Basic Program (town of 10,000) . . . 198
12. Budget - Basic Public Participation Program 200
13. Model Plan of Study
Full-Scale Public Participation 201
14. Model Public Participation Workplan
Full-Scale Public Participation 203
15. Budget - Full-Scale Public Participation Program . . 206
16. Typical Stages of Development in a Municipal
Wastewater Treatment Facilities Project 219
17. Summary - Impact Mitigation Measures 221
18. VWT Reduction Strategy #1 247
Transportation Mitigation A 247
19. VMT ReductionStrategy #1
Transportation Mitigation B 248
20. VMT Reduction Strategy #2
Land Use Mitigation C 249
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LIST OF FIGURES
1. Sewage Treatment Options: Towns X and Y . . . . 38
2. Total Costs of Sewage Treatment ........ 132
3. Map of Block Island, Rhode Island ....... 227
4. Map of North Freemont County, Idaho ...... 235
5. Map of East Bay, California
Recommended Phase I Project .......... 242
6. Map of East Bay, California
Study Area ................... 243
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CONTENTS
.CHAPTER I
THE FEDERAL WATER QUALITY PROGRAMS: AN OVERVIEW
Page
Goals and Strategies of the Federal Programs 9
The 1977 Act 11
Enforcement 12
Federal Assistance to Communities 12
Public Participation 13
The Shalls and Shall-Nots 14
Specific Planning Programs of the Clean Water Act:
Section 303 (e) and Section 208 15
Controversy and Confusion 17
Draft Regulations for Water Quality Management Program ... 17
How Will Water Quality Management Planning Relate to
Facilities Planning in the Future? 18
Other Federal Laws That Affect Treatment Facilities .... 13
The Clean Air Act • 19
Wetlands Executive Order, No. 11990 ...... 19
The Floodplains Management Executive Order, No. 11988 . . -j_g
The Archeological and Historical Preservation Statutes . 19
The Endangered Species Act of 1973 19
The Coastal Zone Management Act 20
The Wild and Scenic Rivers Act 20
The Safe Drinking Water Act 20
The National Environmental Policy Act of 1969 20
What is the Role of the Courts in Enforcing EPA Compliance
with Other Federal Laws? 21
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CHAPTER I
THE FEDERAL WATER QUALITY PROGRAMS; AN OVERVIEW
Controlling water pollution in this country's 78,267
square miles of lakes, rivers and streams is an enormous
undertaking; 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.
Goals and Strategies of the Federal Program
The current federal effort to clean up the nation's
waters began in 1972 when Congress passed the Federal Water
Pollution Control Act amendments.]./ 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. Understanding the general intent of
this legislation and other applicable federal laws is a first
step in planning for the waste treatment needs of your community,
In 1972, Congress took the unprecedented step of
deciding that the nation's waters could no longer be an
integral part of waste treatment. The 1972 Amendments to
the Federal Water Pollution Control Act begin: "The objective
of this Act is to restore and maintain the chemical, physical
and biological integrity of the Nation's waters." In its
report on the legislation, the Senate noted: "...this
legislation would clearly establish that no one has the right
to pollute . . . and that pollution continues because of
technological limits, not because of any inherent right to
use the nation's waterways for the purpose of disposing of
Portions of this chapter are adapted from manuscript by
Barbara Reid Alexander.
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waste." The Act's ultimate goal is to eliminate the
discharge of pollutants into any surface water by 1985.
More immediately, by July 1, 1983, it seeks to achieve where
possible, "an interim goal of water quality which provides for
the protection and propagation of fish, wildlife and shellfish
and provides for recreation in and on the water."
The Congress also recognized the enormous expense of
cleaning up the nations's lakes, streams and rivers. Another
theme, therefore, runs through the 1972 legislation: balancing
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. Until 1972, the approach had been
to designate a particular stretch of water for a particular
use, such as recreation or drinking, and to establish an ambient
stream standard (water quality standard) to permit- that use.
The total amount of pollutants allowed by that standard (the
effluent load) was then divided up between current and future
dischargers (industry and municipalities) along that stretch.
This approach was plagued with technical difficulties.
First, by emphasizing direct water uses such as drinking,
swimming or industrial consumption, it tended to minimize
the importance of human health and the integrity of aquatic
ecosystems. Second, water-use designations erroneously assumed
that it was always possible to determine the threshold of damage
for a body of water—that is, the amount of pollutants the water
could absorb before itself becoming polluted. As a result,
equitable and consistent enforcement often was impossible,
and effluent discharges bore little relationship to instream
water quality.
The 1972 Act sets as its primary goal the protection
of aquatic ecosystems. As a central strategy, it substitutes
for "use designations" a new set of standards (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). The strategy was designed not only to be
enforceable but also to impose more equitable and uniform
requirements on similar polluters located in different places.
For example, a paper mill located on a comparatively clean
river would as a minimum be required to control its pollution
to the same degree as a mill on a dirty river. Thus the clean
river would be preserved, the dirty ones made cleaner, and
polluters would no longer be motivated to locate their plants
in areas with weak regulations.
Despite this basic strategy shift, water quality
standards still play a significant, though secondary, role
under the 1972 Act. Standards based on have been established
for all surface waters; when the uniform source controls fail
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to meet these standards, more stringent controls based on
water quality standards are to be imposed on a case-by-case
basis. For example, if the imposition of uniform effluent
limitations would not result in a given stream meeting its
water quality standard, the dischargers on that stream might
be given a stricter effluent limitation than the national
uniform standard.
The 1972 legislation also brought about a major
institutional change—a significant boost in federal authority,
exercised by the U.S. Environmental Protection Agency(EPA) .
Yet, the state role, which had been preeminent before 1972,
remains significant. Although the responsibilities of state
and federal authority frequently overlap or fall into grey
areas, it can be frequently said that:
• state water quality agencies establish all
surface water quality standards, subject to
EPA approval;
• EPA establishes effluent limits for both
industrial and municipal dischargers;
• EPA regulations interpret the federal law
and the federal/state relationship in
implementing the law.
The 1977 Act
Under the 1977 Clean Water Act, source control remains
the basic strategy for pollution control, but water quality
standards have a new priority. A number of variances from
previously specified tight deadlines also appeared in the
1977 Act.
The source control requirements of the 1972 and 1977
Clean Water Acts establish certain effluent limitation
requirements—and deadlines for reaching them—for industrial
and municipal point-source discharges. Publicly-owned sewage
treatment works (POTW) must have achieved a level of treatment
equivalent to secondary treatment 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. The EPA has
defined BPWTT as the equivalent of secondary treatment or
whatever more stringent treatment level might be necessary
to meet water quality standards.^/
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Enforcement
The Clean Water Act requirements are backed up
by significant financial and legal penalties and are
enforced on industrial and municipal dischargers through
permits, which describe the effluent limitation require-
ment of the point source discharge and other conditions
to be imposed on individual dischargers, such as moni-
toring and schedules for compliance. These permits are
part of the National Pollutant Discharge Elimination
System (NPDES) and 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 works. 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 sections of the current
water quality laws that concern municipal wastewater are
frequently called the municipal facilities program-—-the
NPDES permits described above, which set limits for
discharge, and grants for construction of publicly-owned
treatment works are the program's two major elements.
To receive construction grants, communities must
meet a series of conditions (based on Title II of the Act).
Grants are awarded in three steps:
the facilities planning phase, when most
major decisions leading toward construction
of publicly-owned treatment works are made;
S_tep__2i the design and specifications for the
facility? and
S_tep___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).
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The conditions set for these steps by EPA recognize
that the municipal facilities program runs inherent
public policy risks similar to those encountered in the
construction of highways:
• 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
drain significant parts of the available
funds; and
• that secondary 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 solve.
The EPA conditions, therefore, range from requirements
for cost-effectiveness, user charges and industrial cost-
recovery to requirements that alternative waste treatment
methods be fully evaluated and that secondary environmental
impacts receive substantial public scrutiny.
Public Participation
Communities should note that planning procedures for
the Construction Grants Program include the broadbased require-
ments for public participation specified for all the Clean
Water Act programs. 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
Administrator and the States. The Administrator,
in cooperation with the States, shall develop
and publish regulations specifying minimum
guidelines for public participation in such
processes.
Again, community planners should be particularly
aware that planning decisions made in the course of
constructing a waste treatment facility can have long-lasting
social, economic and political repercussions on each
community. Public participation is crucial.
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The Shalls and Shall-Nots
The effects on your community of all these national
goals and policies can be conveniently summarized as the
"snails11 and "shall-nots" of municipal waste treatment .J3/
The EPA Administrator SHALL by law consider or give
priority to five policies in administering the municipal
facilities program:
1) Waste treatment management must provide
for application of "the best practicable
waste treatment technology before any
discharge into receiving waters, including
reclaiming and recycling of water, and
confined disposal of pollutants so they
will not migrate to cause water or other
environmental pollution and shall provide
for the consideration of advanced waste
treatment techniques."
2) Waste treatment must be pursued on an
areawide basis as far as possible and
must provide for the control of all point
and nonpoint sources of pollution. (See
the description of section 208 later in
this chapter.)
3) The Administrator must encourage revenue-
producing waste treatment facilities that
rely on recycling wastewater, confinement
and containment of pollutants not recycled
(i.e., no discharge), and disposal of any
sludge in an environmentally acceptable way.
4) The Administrator must encourage waste
treatment management that combines open
space and recreational uses with waste
treatment goals.
5) The Administrator must encourage techniques
that will reduce total energy requirements.
The most important of the SHALL-NOT policies:
1) After June 30, 1974, EPA cannot approve
grants that do not provide for evaluation
of alternative techniques of waste treatment
to determine the "best practicable waste
treatment technology,"
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2) After September 1978, EPA cannot approve
grants unless the applicant demonstrates
the "innovative and alternative" waste
treatment management techniques have been
studied and evaluated.
3) After September 1978, grants cannot be
approved unless potential recreation and
open space opportunities are analyzed in
planning for the proposed treatment facility.
These "shalls" and "shall-nots" demonstrate the clear
intent of Congress to encourage ecological solutions to our
waste treatment problems—solutions that rely on natural
systems (lands, lagoons and marshes) for ecological disposal
of wastewater. The municipal facilities program thus attempts
much more than simply building a secondary treatment plant in
every community.
Specific Planning Programs of the Clean Water Act;
Section 303(e) and Section 208
The planning requirements of the Clean Water Act are
spelled out in four sections of the legislation—Sections 106,
201, 208 and 303(e)—and 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 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 costeffeetive treatment works.
Two of these sections of the Act—-Sections 303(e) and
208—are intended to work together to bring about a Water Quality
Management Plan in each state. These statewide plans should
then form the framework for individual facility plans. Since
most of 208 planning is conducted by local governments on a
regional basis, and the planning requirements of Section 303
are conducted by the State, these two planning programs are
often considered separately, and their respective requirements
are usually addressed in separate documents. New regulatory
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strategies being considered by EPA would better integrate
these two planning functions.
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 waters. Bodies of water are
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 and must be
incorporated in local planning. These river basin plans
also must decide how to prevent waters of high quality from
being degraded, how water quality standards can be revised,
and which stream segments should receive priority attention.
Planning under Section 208 is conducted on an areawide
basis within states in regions designated by the governor,
or, in nondesignated areas, on a statewide basis. These plans
must address all point and nonpoint sources of pollution within
the area in order to achieve fishable and swimmable waters
by 1983. The 208 plans control pollution by placing limits
on discharge, by regulating the location of potential pollution-
causing activities, by regulating certain management practices
(such as the manner in which construction activity is carried
out),(Or by some combination of all three.
Areawide planning under Section 208 is based on the
congressional acknowledgement that land use practices can
often directly or indirectly affect water quality. Therefore,
areawide plans must create a program to regulate the location,
modification and construction of any facilities (municipal
or industrial) in the area that might cause pollution. More
to the point for municipal dischargers, the 208 plan must
include a comprehensive areawide waste treatement management
program based on the goals in Title II of the Clean Water Act
("best practicable waste treatment technology," no discharge,
and use of recycling).
The 208 plan must also contain a program to control
diffuse sources of pollutants (nonpoint sources). This means
identifying and implementing practices that lead to nonpoint
source pollution by controlling the management of activities
such as farming, timber harvesting, mining, construction,
sludge disposal or dredge and fill activities, activities
that affect groundwaters, and intrusion of salt water.
One unusual aspect of 208 planning is that it must
identify the measures needed to carry out the final plan
and must recommend appropriate state, regional or local
16
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agencies to carry them out. This implementation strategy is
a crucial element; many past planning efforts have failed for
lack of one. Finally, the 208 plan is designed to be at least
partially self-implementing: No permits or construction grants
are to be issued unless they are consistent with the plan.
Controversy and Confusion
Under the original timetable of the Clean Water Act,
the above described plans for pollution control were to be
developed at the same time that the first NPDES permits were
issued and the first construction grants given. Eventually
the water quality plans, the regulatory decisions and the
construction grants would fit together. Unfortunately, this
integration of planning and action is far behind schedule.
Confusion and conflicts have resulted.
>
In the early stages of implementing the Act, the EPA
decided to deemphasize the areawide planning of Section 208
in favor of the statewide planning under Section 303(e), since
the statewide plans would be needed to establish effluent
limits for municipal and industrial facilities. Thus, the first
areawide plans are just now being completed, and few have been
fully approved or implemented.
Detailed regulations were prepared for individual
sewage treatment facilities constructed with_federal funds,
and over $18 billion has already been spent or obligated for
the planning, design and construction of sewage plants. There-
fore, decisions have been made and concrete poured for projects
that may not fit into the objectives of the areawide 208 plans.
Draft Regulations for Water Quality Management Program
Draft water quality management regulations published
in the Federal Register on September 12, 1978,4/ herald a new
era in water quality management planning.
A formal state/EPA agreement designed to integrate the
planning elements of EPA's environmental laws would become
the central management tool for 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 the state water quality agency with financial assistance
—including areawide and basin planning, permit programs and
construction grant management.
17
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Proposed regulations renew emphasis on yearly program
outputs, and on an implementation of water quality management
plans. Proposed sanctions for lack of implementation include
withdrawal and possible recovery of federal grants.
How Will Water Quality Management Planning Relate to
Facilities Planning in the Future?
Both the proposed planning regulations and newly pro-
mulgated construction grant regulations make clear that the
ties between Water Quality Management Planning (WQM planning)
and facilities planning will be much tighter in the future.
Critical and often controversial decisions in the planning
for municipal wastewater management will be made at the state
or areawide level through the Water Quality Management process.
A citizen wishing to become involved in local facilities planning
will find that he may have to seek amendment of critical decisions
through a formally established Continuing Planning Process that
is part of the state water quality management program.
The details of the facilities planning decisions made
during water quality management planning are discussed at
appropriate points in other chapters. These decisions are:
$ priority funding
• effluent limitations
9 delineation of facilities planning areas? and
• population projections
Generally, no grants for treatment works are to be
given unless they are consistent with an approved Water Quality
Management Plan. After October 1, 1979, if construction grant
related information is not available in an approved WQM Plan,
the grant may not be given (unless the EPA Regional Administrator
determines in writing . . . that the facility related information
was not within the scope of the WQM work program, or that award
of the 201 facilities planning grant is necessary to achieve
water quality,5/
Other Federal Laws That Affect Treatment Facilities
More than 25 other federal environmental statutes and
Executive Orders affect construction grants for sewage treatment
plants. The most important will be introduced briefly here and
some will be discussed in more detail in succeeding chapters.
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The Clean Air Act imposes controls on sources of air
pollution, including municipal incinerators that burn sludge.
Section 316 of the 1977 amendments authorizes the EPA Adminis-
trator to condition wastewater treatment construction grants
on control of air pollution associated with secondary impacts
of plant construction. State air quality implementation plans
may limit plant size and location to control subsequent housing
development that might contribute to air pollution.
Under the Wetlands Executive Order, Number 11990, federal
agencies shall not finance new construction in wetlands unless
the head of the agency makes two findings:
• there is no practicable alternative;
• the proposed action includes all practicable
measures to minimize the harm that may result
from such use.
While this order does not completely prohibit treatment plants
from wetlands, its strong language reinforces EPA's policy of
preserving wetlands. It may affect siting decisions that would
put a plant near a coast or river, which may be within the
wetlands zone.
The Floodplains Management Executive Order, Number 11988,
is intended to avoid the long and short-term impacts of flood-
plain development wherever there is a practicable alternative.
Guidelines written by the federal Water Resources Council explain
how to identify floodplains and provide standard definitions
and methodology for identifying alternatives.6/ EPA must write
implementing guidance for its actions before February 1979.
The Archeological and Historical Preservation Statutes,
through the Advisory Council on Historic Preservation, require
identification of historical or archeological resources of
special value. If such places qualify for the National Register
of Historic Places, the Advisory Council and a state's historic
preservation officer must agree on measures to protect such
sites before construction or further action in the area.
The Endangered Species Act of 1973 prohibits federal
actions that jeopardize threatened or endangered species of
plants and animals as listed by the U.S. Department of the
Interior. The Environmental Impact Statement (EIS—see below)
for a facility usually will discuss possible impacts on
endangered species, and the Department of the Interior will
then comment on expected impacts and suggest mitigation measures.
19
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Other federal laws may be important in particular
situations. The Coastal Zone Management Act helps coastal
states to develop and implement coastal zone management ,
programs. In some states it may require special review of
a proposed treatment facility that would affect new development
in the coastal zone, access to the coast, or coastal water
quality. The law requires that approved state coastal zone
management programs be given opportunity to comment on federal
grants and licenses; grants and licenses must then be consistent
with the state coastal program.
Wild and Scenic Rivers Act may require special
protection^ £ lor7 ~d^sTgna"ted~r"i ver segments . Procedures for
resolving conflicts over discharges into these rivers currently
are being outlined by the Departments of Agriculture and Interior,
The Safe Drinking Water Act includes a procedure for
designating "sole source aquifers" — water sources that provide
a community's entire water supply. Designated aquifer-recharge
areas are protected from any federal action that would contribute
to contamination, including discharge from treatment plants or
underground storage of pollutants. The EPA Administrator
implements the procedure.
Tjie_JJajy^nal_Environinental Policy Act of 1969 (NEPA) .?/
This law requires an Environmental Impact Statement (EIS)
before federal agencies proceed with actions that significantly
affect the environment, including wastewater treatment plant
construction grants.
Under NEPA, a lead agency is designated to prepare the
impact statement. For construction grants, EPA is responsible
for EIS preparation. The details about alternatives and
impacts in the EIS are shared with the public and other federal
agencies. The EIS is a vital document that permits evaluation
of a construction grant in the light of other federal laws and
requirements including many of those described above.
NEPA also provides strong policy guidance to federal
agencies. In the past, it has been the means of delaying
projects while alternatives were explored or other federal
laws were applied. Current legal interpretations are requiring
potential litigants to have participated in various adminis-
trative procedures (such as the EIS process and other public
planning procedures) before resorting to court action.
20
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Thus, participation in the facility planning process
would possibly be a prerequisite to a NEPA lawsuit.
What is the Role of the Courts in Enforcing EPA Compliance
With Other Federal Laws?
The courts may enforce statutory procedures like
NEPA's Environmental Impact Statements or Advisory Council
on Historic Preservation consultation if the EPA fails
to follow the statutes and implementing guidelines. The
Endangered Species Act provides a specific rule, enforceable
in court (and which can only be modified by Congress),
that endangered species shall not be further destroyed.
Courtroom challenges may be based on constitutional
principles as well as laws. In New Jersey, for example,
a challenge alleges discriminatory housing impacts as a
result of EPA regulations and guidelines that use local
zoning in facility planning. It is based on both
constitutional equal protection principles and fair
housing statutes.
Where the law requires a judgment by EPA, such as
the designation of a "sole source aquifer," courts
generally presume that the judgment is appropriate unless
it is arbitrary or without any basis in fact. This makes it
difficult to challenge EPA judgments. More typically,
environmental lawsuits argue that the agency has failed to
act in a way required by law, a fact which is demonstrable
and usually reviewable in court.
Executive Orders, like the Floodplains Management
Order and the Wetlands Order, are enforced through
executive action by the President. This means that EPA
is primarily responsible for policing its compliance; a
court suit for enforcement is unlikely.
21
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FOOTNOTES - CHAPTER I
1. Federal Water Pollution Control Act Amendments of 1972,
33 USC, Sec. 1251-1376, (Amended by the Clean Water
Act of 1977).
2. Secondary treatment as defined by EPA regulations is
that level of treatment which will achieve 85 percent
removal of BOD and suspended solids and ensure main-
tenance of pH values between 6 and 1. (Some exceptions
for suspended solids are allowed in the case of waste
stabilization ponds.) 40 CFR, Part 133.102.
3. These policies are found in the various parts of
Section 201 of Title II of the Clean Water Act of
1977, 33 USC 125 et seq.
4. EPA "Proposed Water Quality Management Regulations,"
Fed. Reg, pp. 40742-40757, Sept. 12, 1978. (40 CFR,
Subpart Q, Part 35).
5. 40 CFR, Part 35.917(e).
6. Water Resources Council "Guidelines on Floodplain
Management, 43 Fed. Reg., pp. 6030-6055., Feb. 10, 1978
7. National Environmental Policy Act of 1969.
CEQ guidelines for implementing NEPA Aug. 1, 1973.
These guidelines will be substantially revised by new
NEPA regulations (43 Fed. Reg., pp. 55990-56006,
Nov. 29, 1978) scheduled to become effective July 1, 1979,
22
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CONTENTS
CHAPTER II
SEWAGE TREATMENT PLANNING IN A COMMUNITY CONTEXT
Page
The Need for Treatment 25
Types of Treatment 26
The By-products of Wastewater Treatment 27
Performance of Treatment Plants ..... 28
Potential Points of Conflict . 28
"Direct" or "Primary" Impacts of Construction 31
32
"Secondary" Impacts of Facility Construction
Economic and Social Impacts 34
The Cost of Delays 36
After Construction 36
Planning Alternatives: An Example 37
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CHAPTER II
SEWAGE TREATMENT PLANNING IN A COMMUNITY CONTEXT
The Need for Treatment
Until recently, wastewater treatment and disposal
in most communities has failed to meet Clean Water Act
standards. When the 1972 law was enacted, many localities
provided no treatment at all or only the most basic screening
(primary treatment) of their wastewater. What happens when
such untreated or undertreated wastewater enters the envi-
ronment?
When natural waters are used as a sewer, basic ecological
relationships are disturbed, resulting in long-term adverse
consequences for both the natural environment and water users.
Many contaminants found in wastewater directly affect the
aquatic environment, including bacteria, concentrated
amounts of nutrients (such as phosphorus and nitrogen), toxic
chemicals, heavy metals (such as cadmium or mercury) and
excesses of organic solids that accumulate on the bottoms
of lakes, rivers and streams. Most of these contaminants
occur naturally in small amounts, depending on development
in the area and patterns of rainwater runoff. Large
forests or pasture areas, for example, may produce
significant contamination from the bacteria in animal
wastes. But large and concentrated discharge of under-
treated wastes from a treatment plant into surface waters
greatly degrades those waters' value as a fish and wild-
life habitat and often makes them unsuitable for
drinking or recreation.
In many places, the groundwater system is also
threatened by poorly treated wastewater and by saltwater
intrusion caused by excessive withdrawal for use. Treated
water may be used to restore the groundwater system,
especially when treatment produces water of higher
quality than existing groundwater. Groundwater supplies are
recharged by precipitation, by seepage from rivers and
streams, by absorption and storage of rainfall in soils, and
in some cases by underflow from adjacent areas. The rate of
recharge depends on many conditions: the type of soil,
density of vegetation, intensity of rainfall, terrain,
buildings, coverage with impermeable surfaces (such as
paving of roads and parking lots) and compaction of soil.
This chapter has been adapted from manuscrip by John S. Banta.
25
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Types of Treatment
Levels of wastewater treatment include the following:
Primary Treatment - The first stage in wastewater treat-
ment 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.
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.
Advanced Treatment - Treatment beyond the secondary or
biological stage is required to meet strict quality standards.
Depending on the process selected, advanced or tertiary
treatment can provide additional removal of standard
organic polutants suspended solids, inorganic ions or
nutrients such as phosphorus and nitrogen. Advanced
treatment is the "polishing stage" of wastewater treatment
and generally produces a high quality effluent.
The 1972 Clean Water Act requires municipal dischargers
to achieve the minimum level of pollutant removal possible
through a well run secondary treatment system. (In some
cases as discussed in Chapter I, even stricter standards
must be reached by some dischargers to meet goals for river
basins. These stricter standards may require advanced or
tertiary treatment, which may produce "drinkable" water.)
A community that plans to upgrade the treatment
level of an existing plant, expand capacity of its
existing facility or provide new treatment capacity may
choose from among six basic categories of treatment and
management options:
1) conventional, "centralized" physical/chemical/
biological treatment and discharge of treated
wastewater into streams, lakes or rivers;
2) centralized treatment but with effluent disposed
of on the land;
3) waste treatment and reuse of purified water;
4) increase capacity of existing facility by
flow reduction measures;
5) small, onsite options such as individual and
community septic fields and composting toilets; and
6) systems combining appropriate treatment components
of any of the above.
26
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These treatment options and the conditions that
affect selection of each are described in more detail in
Chapter V.
The By-Products of Wastewater Treatment
To meet Clean Water Act goals, of course, a
wastewater treatment system must produce relatively clean
water that will not degrade natural streams and lakes.
The treatment process may also leave behind by-products that
may bring benefits or problems: large amounts of solid
waste, either as sludge or in other forms, organic
chemicals; and treated water that may be clean enough to
recycle for agriculture and other uses.
Sludge. To achieve fishable, swimmable waters
using conventional technology, a treatment facility must
remove the bulk of human wastes from wastewater,
leaving behind solid waste that must be disposed of.
Sludge is in fact a major by-product of most conventional
treatment facilities. The makeup of sludge or concentrated
solid waste depends largely on the kind of pollutants en-
tering the system. Systems with industrial as well as
residential users may find toxic chemicals or heavy metals
in their sludge (such as mercury or cadmium) posing special
problems for disposal. Much sludge may be either disposed
of on land or burned, possibly creating solid waste disposal
problems or air pollution problems. In other cases, the
sludge may be basically organic, making it suitable for
composting or for being made into usable soil components.
It may be utilized as supplemental fertilizer on farm land
or to restore lands stripped of natural vegetation through
mining operations.
Whatever the makeup of solid waste, a large treat-
ment system plant will produce a lot of it. A conventional
primary treatment plant that processes 1 million gallons of
wastewater per day (1 MGD) will produce an average of from
1 to 1.5 tons of sludge each day. The amount varies directly
with the size of the plant. Different treatments of the
sludge may reduce it to essentially dry waste or leave
it in partial solution for application to land.
Chemicals. Some tertiary processes may produce
significant amounts of various organic chemicals: including
nitrogen compounds (which may be spread on the land during
or through a spray irrigation treatment process or discharged
into the water) and carbon, phosphorus and amonia—all of
of which have high resale potential.
Recyclable water. Reliable secondary and tertiary
treatment can turn wastewater into a potentially recyc-
lable resource for use in agriculture, industry or for
27
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II
return to the natural environment. Treated water
returned to natural streams may actually improve water
quality—for example, when seasonal low flows in streams
(aggravated by withdrawal for industrial or agricultural
use) leave inadequate supplies or poor quality water for
fish, wildlife and recreation. Properly treated waste-
water may be cleaner than the low flow stream water and
may thus enhance the aquatic environment and perhaps
allow water recreation where it had been unsafe. This
recreation component can be especialy significant in
areas where low flows occur during the summer. In some
cases the recycling of wastewater can be most effectively
exploited through innovative treatment techniques.
Performance of Treatment Plants
The amount of water treated and the quality of
treatment depend most fundamentally on the nature of the
treatment plant—its capacity, techniques, level of treat-
ment and storage-—which will affect the outflows during
normal operation and at periods of peak flow. ("Peak flow
usually occurs when stormwater enters a system through
combined storm/sanitary sewers or through infiltration
into old and leaking sewers.)
But how well the plant is operated and maintained also
can affect treatment levels and reliability. Many of the
smaller treatment plants built in the early 1960's
have been criticized for breakdowns due to lack of supervision
or poor maintenance. The quality and skill of the operator
are important too. Any plant failure, whether due to
breakdown, power loss or other operational problems,
may lead to discharge of untreated sewage or grossly
inadequate treatment until the problem is remedied.
Financial support for operation and maintenance is currently
derived solely from the local community.
Finally, the quality of incoming water can have
significant effects on the performance of treatment plants.
Some incoming wastewater may contain toxic chemicals
or heavy metals that are difficult or impossible to
remove completely. These same materials may disrupt the
biological treatment process of the sewage treatment plant
and may prevent the plant from operating at design levels.
It may be more efficent to remove these pollutants at
their source rather than in a community facility. (Hence,
some industries may be required to pretreat their wastes
before discharging them to a municipal system.)
Potential Points of Conflict
Once a community decides to address its sewage treat-
ment problems, it may anticipate a number of controversies
28
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as possible alternatives are considered. Some of the key
conflicts may arise over:
I. "Direct" or "primary" environmental impacts
A. Disposal of solid waste generated by improved
secondary and advanced wastewater treatment
B. Protection of community water supplies,
especially from toxic chemical and heavy metal-
contamination
C. The siting and construction of treatment plant
and sewer system has the potential to jeopardize
wildlife habitate, historic/archaeological
resources and create odors or aesthetic eye-
sores for neighboring property owners, etc.
II. "Secondary" environmental impacts
A. Location of new residential development
B. The relationship of growth to conservation of
prime agricultural land
C. Control and planning of future industrial
and commercial growth to best utilize the
land and to avoid damaging existing resources
D. Minimizing flood hazard risks and protecting
wetlands and other environmentally sensitive
lands
III. Economic and social conflicts
A. The cost, quantity and type of new housing
available in a community
. B. Changing property values for existing homes
C. The type of new industrial development
incentives
D. Distribution and amount of charges to pay
for the community's share of the capital
costs, operation and maintenance of the
facility
E. The appropriateness of facilities to rapidly
changing short and long-term social and
economic needs in a community
These types of conflicts will arise whenever choices
have to be made—facility location and design, type of
treatment process, plant capacity, service area, solid
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TABLE 1. IMPACT CATEGORIES OF SEWAGE TREATMENT
PLANT CONSTRUCTION
Land Use
Aesthetic
Mechanical
Risks
Wildlife
- habitat destruction
- relocation
destruction
Vegetation
- revegetation
- destruction
Loss of environmentally
sensitive areas
Incompatible adjacent
land uses
Erosion
Loss of agricultural land
Archaeological losses
Growth in population
Disposal/reuse land
utilization
Visual disruption
Noise
Dust
Odor
Loss of open land/
greenery
Traffic *
Disturb commercial/
residential activity
Commuting by employees
Housing for employees
Air pollution by
machinery
Water quality degradation
- surface water
groundwater
Energy consumption
Property value
changes
Floods
Seismic activity
Safety (public
health
construction
water/air
pollution
OJ
o
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waste disposal, water reuse and others. The impacts of
building or expanding a municipal wastewater treatment
facility can be grouped into the four sets of potential
impacts outlined in Table 1: Land Use; Aesthetic,
Mechanical, and Risks.
"Direct" or "Primary" Impacts of Construction
Perhaps the most important variable in assessing the
primary environmental impacts of sewage treatment plant
construction is the site selection for the treatment plant.
What sites are available and the location of potential
sludge disposal areas may determine what level of treatment
is possible, the extent to which capacity can be expanded to meet
future needs, and what techniques are required to meet
water quality standards.
Ironically, cities with the greatest need for new
facilities are often high-density urban areas with few
suitable sites for new facilities. If such cities require
both tertiary treatment—which creates a need for storage
capacity and usually produces a large volume of sludge—
as well as a significant reserve capacity for the future,
their problems become particularly acute.
Direct impacts are interrelated. For example, if a
planner hopes to minimize environmental disruption or loss
of prime land, the project should likely be built
within a developed area. But such siting increases
aesthetic impacts on residents: unsightly construction and
traffic disruption as the plant is built, noise and
possible odors. Planners in Monterey, California, faced this
kind of dilemma when the only available sites were on prime
farmland—a principal source of artichokes for a national
market. In the end, agriculture was forced to less
desirable land.
Impacts that are less obvious may include erosion, loss
of wildlife habitats and destruction of open space. Plant
siting will determine where recycled wastewater will be
available for users. It will also affect the layout of
sewer pipes leading from the plant to residential, commercial
and industrial users—with the impacts described below—and
thus directly influence the potential for new housing
construction in different areas of a community.
Interceptor sewers are the large sewer pipes that
link the treatment plant to the smaller residential
collector sewers (trunks, mains, laterals, etc., see glossary)
which provide individual service. Many interceptors may
branch off from a large plant; only a single interceptor
may be needed for a small plant.
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A basic policy choice controls the primary impacts
of construction and operation of interceptor sewers: Should
the pipelines follow existing rights-of-way or break
through undeveloped land? Breaking new ground destroys
flora and fauna but may avoid traffic disruption or noise
pollution in a residential area during construction. It
also may trigger pressures to develop such undeveloped
land, unless access to the sewer is restricted. On the
other hand, following existing rights-of-way may bring
desirable new development or new roads, or create new
public rights-of-way across open country. Table 2 notes
the primary impacts of interceptor construction and
operaton.
Collector sewers are the smaller pipelines that
connect homes and businesses with the interceptors, thus
actually providing sewer services to individual users.
Like interceptors, their primary impacts tend to be aesthetic:
construction, noise, odor, visual intrusion, dust and incon-
venience .
There are, however, important differences between
impacts of collector and interceptor sewers. First,
collectors are simply closer to users and therefore
more obvious, especially if repair teams must dig up a
homeowner's front lawn to repair a pipe. This impact is
magnified by the fact that while interceptors have a
useful life of 20 to 50 years, collectors require more
frequent maintenance, thus, creating recurring evidence
of their existence.
Finally, collectors are more liable to infiltration
by stormwater, which may cause problems in other parts of
the sewage system—possibly affecting plant capacity, for
example. Repairs or replacement of the system may be needed
to remedy such problems.
"Secondary" Impacts of Facility Construction
"Secondary" impacts refer to subtle but persistent
changes in timing, density, type and location of new
residential, commercial and industrial development brought
about by construction of a new or expanded treatment facility.
Because wastewater treatment and access to sewers are pre-
requisites for most new housing construciton, the decision
to provide service will largely determine a community's
development opportunities.
In the broadest sense, secondary impacts include all
factors arising from poorly conceived or executed development.
Many people see sewers as a source of pressure to build and
sell new housing, perhaps because some communities seek to
recover their share of facilities costs through new tax
assessments on new homeowners. Or a large facility may be
sought because communities want to take full advantage of
currently available funding.
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TABLE 2. INTERCEPTOR CONSTRUCTION AND MAINTENANCE
PRIMARY IMPACTS
Impacts of Construction
Impacts of Operation/Maintenance
Wildlife disturbance
Wildlife loss
Habitat loss
Water quality degradation
Erosion
Loss of agricultural land
Noise
Air pollution from machinery
Dust
Traffic disruption
Visual disruption
Energy consumed by constructgion
Loss of vegetation/rare plants
Noise
Energy consumption by repair teams
Revegetation problems
Erosion
Water quality degradation
Traffic disruption by repair teams
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In the continuing national debate, many planners
argue convincingly that sewers and sewage treatment plants
are rarely the cause of growth in a region. There is, however,
little argument that the siting of sewers and treatment plants
has a direct influence on the location of that growth within
a region.
Some secondary impacts are singled out for special
attention by federal law. These include destruction of
endangered species habitats, construction in wetlands,
unsafe construction on floodplains, and degraded air
quality in special "air quality maintenance" areas. Other
impacts may be of special concern to states or communities.
Sewer service to steep slope areas, for example, may lead
to unsafe building sites, erosion and public safety problems.
Economic and Social Impacts
Local governments may find the cost of providing the
necessary or desirable level and capacity of wastewater
treatment overwhelming. The extent of this economic impact may
not always be realized until the facility is built. Local
governments must pay for all capital costs not covered by
federal and state grants. The local share includes that
portion of the 25 percent nonfederal share not paid by the
states, plus items ineligible for federal financial assistance
such as lateral sewers, most collector sewers, and reserve
capacity beyond that allowed by EPA regulations. In many cases
their share of the cost may exceed 25 percent of the total system
costs. In addition, local users of the sytem must absorb
the costs of operation and maintenance. Faced with this
expense, the community must grapple with difficult questions:
How will the local share be financed? Who in the community
should pay?
One alternative is to decide that the entire community
should pay for the treatment system; therefore, the local
share of capital costs can be financed through general revenue
bonds. This action, however, might severely strain the bond
credit rating of some communities (if they are able to issue
bonds at all), thus precluding their ability to raise
funds for other necessary capital investments.
Another option is for the community to cover only a
portion of the capital costs, to require developers to
cover the costs for installing lateral sewers and house
connections, and homeowners to pay a one-time hookup fee.
Part of the overall costs would then be passed on to new
homebuyers in the form of higher prices. This approach,
however, may raise questions of equity--Are newcomers paying
a disproportionate share?—and of community responsibility to
provide moderate-income housing.
34
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As for the costs of operation and maintenance (O & M),
communities generally will attempt to recover these costs
directly from the system's users by charging a monthly^ service
fee based on how much sewage is generated. In some cases,
however, particularly when a system is designed to accommodate
substantial future growth, the initial number of users may not
be enough to cover costs without imposing great burdens on
customers. Until the number of users approaches the design
capacity, the community may have to subsidize 0 & M costs
with general tax revenues.
It is of paramount importance that communities under-
stand the total costs of all its sewage treatment system
alternatives before any final decision is made. For example,
a decision to economize by building a plant with only
limited reserve capacity may mean that 10 years later the
community will be forced to finance expansion of the plant
(possibly without any federal assistance) if future develop-
ment exceeds expectations. Failure to accurately assess
total O & M costs for each alternative system could lead to
some form of taxpayers' revolt (as is now occurring in
Manassas Park, Va. ) once citizens discover the price they are
being asked to pay.
Another potential impact to be considered is the fact
that access to treatment facilities not only affects the
location of housing, but also the type and quantity of
housing available and, ultimately, housing costs. Sewering
an area usually permits high-density development such as
townhouses, garden apartments or high-rises. Since high-
density development tends to be less expensive than building
single family homes, communities may consider sewering as
an opportunity to provide more moderately-priced housing.
On the other hand, some communities may decide that
providing lower-cost housing will simply encourage rapid and
unwanted growth. Thus, they may choose to limit the capacity
of the treatment plant and its service area or restrict
access to the system. Communities should be aware, however,
that such ostensible growth control measures may be challenged
as discriminatory. In New Jersey, for example, the office of
Public Advocate is challenging EPA construction grants condi-
tions on the the grounds that EPA must consider fair housing
concerns along with traditional environmental and economic
concerns. *
Finally, the impacts of facility construction may
cause a decrease in the property values of adjacent lands.
Presumably such a loss would be more than offset by property
value increases in other parts of the community as a direct
* Title VIII of the Civil Rights Act of 1968 gives EPA some
responsibilities for encouraging fair housing, programs in its
constructioan grants activities (42 USC 3601 et. seg.).
constructioan grants
35
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or indirect result of improved water quality. Changes in
property values may pose thorny questions of equity, however,
since citizens faced with decreased property values are not
likely to be comforted by increases for others.
The Cost of Delays
The direct, secondary, economic and social impacts of
construction must be consciously raised and carefully con-
sidered very early in the facility planning process. Other-
wise they later could become the focus of intense public
controversy, causing lengthy delays in design and construction
of a treatment system. Delays mean added economic, social and
environmental costs that the community ultimately must bear.
Not only will delays inevitably push up the final price
tag of the selected alternative, but they will postpone
resolution of the community's water quality problems.
After Construction
When construction is completed, the community must
make sure that its facility is well operated and maintained
and meets design standards. The community will be responsible
for meeting the effluent limitations of its NPDES permit;
enforcement actions for violation of permit conditions may
bring substantial civil fines and/or criminal penalties.
In the past, many systems built primarily with
federal funds have not operated to design capacity. Complex,
high technology systems sometimes were designed for communities
with neither the financial nor technical resources to ensure
adequate operation.
The Clean Water Act deals with this problem in two ways.
First, communities are required to have a detailed operation
and maintenance plan in place before construction is complete.
Second, they are required to have a system of user charges
to pay operation and maintenance costs. A treatment
facility frequently becomes controversial and receives
community attention at the time the user charge system
is adopted. That is when many small communities have
found that high technology systems built with seemingly
"free" federal and state grants are costly to operate.
Delays in construction (and resulting inflationary costs)
can result from community debates that take place too late
in the process to be very effective. Concerned citizens
will want to see that the user charge debate is raised
publicly early in the facilities planning process.
The community is also responsible for any future
expansion. The completed treatment facility will have a
reserve capacity for future expansion equal to the 20-year
population projection approved by the state and EPA and
found in the appropriate water quality management plans.
36
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(See Chapter V). The community will want to start actively
actively planning expansions after 10 of those 20 years
have elapsed. Population projections may not be accurate,
and concerned citizens and local government will want to
keep close tabs on area demographics in order to begin
planning for expansion in time to prevent sewer hookup
moratoriums and/or overloaded treatment plants.
It is likely that any future expansions will have to
be paid for by the community. The Clean Water Act allows
communities to retain a portion of the capital costs
recovered from industry through the Industrial Cost
Recovery System (see Chapter V) to help pay for future
expansions. This money may not be enough, however, so
financial planning for future expansions will be an
important community responsibility.
Planning Alternatives; An Example
The following example illustrates how treatment
planning choices depend heavily on two factors: natural
features (slopes, watershed boundaries and soils) and
political decisions about patterns of future community
growth (often called "land-use parameters"):
Two riverside towns (X and Y) each have existing
developed areas serviced by separate sewage treatment plants
(see illustration, p. 30). Located about 15 miles apart,
each town is in a separate watershed. Local streams are
prized 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.
Unfortunately 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 treatment facility
for these subdivisions both to serve existing housing
and to permit new housing construction to proceed. Towns
X and Y must also improve the treatment level of their
existing plants to a required secondary treatment standard
to obtain state discharge permits. The state agency
and the EPA threaten enforcement action.
These two communities face a number of choices:
Option 1
Town Y can build additions to its treatment facility
to serve the new subdivisions (they have to improve the
plant to achieve secondary treatment standards anyway).
37
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FIGURE 1: SEWAGE TREATMENT OPTIONS: TOWNS X AND Y
force main
New Trunk
Sewer
p'tion 1)
Prime Farmland
SUBDIVISIONS
Existing «**•
Treatmen
Plant
WetlandsTloodplain
New
Regional
Intercepto
(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.
Existing
Treatment Plant
New Regional
Treatment P"
(Option 3)
38
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This will require a force main—a sewer moving wastewater
under pressure—to move the sewage from one watershed to
another. It will also require a long and expensive trunk
sewer line to run to the remote subdivisions, which
are actually bedroom suburbs of Town X. The trunk line
will cross open space such as farms and environmentally
sensitive lands that are served by good roads, and demands
for 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, a
combination of gravity mains and the shorter distance the
sewage would travel to the treatment facility would reduce
the capital and operating 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 and financial agreements
between X and Y would be required.
Option3
The two communities could together 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 X and Y was 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, the construction of the regional plant might
generate subtle pressure for the development of the open
agricultural and environmentally sensitive lands between
towns as the two communities seek formulas to recoup
the large initial capital costs. One technique to
recover the costs that EPA does not reimburse is to
service large areas for new construction and to shift costs
to the incoming residents as rapidly as possible.
Option 4
Town Y might provide a new small-scale on-site
treatment system to service only the problematic sub-
divisions. Both Town X and Town Y would then improve the
level of treatment at their existing facilities providing
some additional capacity for orderly development around
the towns. Unless these decisions were accompanied by
restrictions on further subdivision development in the
hills, however, the communities might find themselves in a
situation similar to the one they are in now in a few
years. In addition, planning for limited expansion of
sewage treatment capacity now might well mean the
39
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community would have to foot a significant bill for new
construction later because once the current construction
is completed, additional federal funds might not be
forthcoming.
Each of these four options would resolve the water
quality problems facing the two communities. Yet, each
wold pose another set of problems that the communities
would be forced to resolve. The preferred option would
obviously depend on specific circumstances.I/
40
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FOOTNOTES - CHAPTER II
1. Adapted from Land Use and the Pipe, Richard D. Tabors,
Michael H. Shapiro and Peter P. Rogers, (D.C. Heath
& Co., Lexington, Mass., 1976), p. 19.
41
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CONTENTS
'CHAPTER III
INSTITUTIONAL ISSUES OF SEWAGE TREATMENT MANAGEMENT
Page
Key Government Influences on the Facility Planning Process
What are the federal responsibilities in the
Construction Grants Program? Who are the federal
actors? 45
What are the state responsibilities in the Construction
Grants Program? Who are the state actors? 48
How has recent legislation increased the authority of
state water quality agencies in managing the Construction
Grants Program? 49
How do I know if the delegation of the Construction Grants
Program is an issue in my state? 50
How will delegation of Construction Grants Program
take place? 50
What affect will the Delegation Agreement and the CMAG
have on my involvement in facilities planning? 52
Key Questions to Ask 52
What is the local role in the facility planning process?
Who are the local actors? 54
Political Issues Raised by the Construction Grants Program
and the Facilities Planning Process 56
How will Section 208 planning relate to the on-going
facility planning process? 56
What has happened to the congressional goals and
objectives of the sewage treatment program? 58
What basic political conflicts are raised by the
Clean Water Act? 59
What Impact Does the Availability and Method of Federal
Funding Have on the Construction Grants Program? 61
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CHAPTER III
INSTITUTIONAL ISSUES OF SEWAGE TREATMENT MANAGEMENT
Key Government Influences on the Facility Planning Process
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 award the grants. EPA 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.
In general the Water Division of each Regional Office has
one branch mainly concerned with municipal facilities or engi-
neering and another, separate branch for water quality planning
standards. Facility planning under the construction grants program
is usually not the responsibility of the water quality planning
branch but of the municipal facilities branch, which is primarily
staffed by engineers. Coordination and communication between^these
two branches varies from region to region. Typically, there is a
constant struggle for information within them , a struggle that
often flares up into a pitched battle between engineers on one
side and planners and lawyers on the other. Engineers typically
view concern for environmental issues as a delaying tactic; plan-
ners and lawyers accuse the engineers of running roughshod over
ecological objectives. Power usually resides with the branch that
control the flow of information.
Public Participation Offices. As a concerned citizen
you should find out whether there is a Public Participation Office
in your Region. Most Regions do not have such a separate office;
public participation is buried in EPA's Office of Public Awareness,
whose primary duty is to educate the public about the Agency s
mission. A few regions do have personnel who are directly respon-
sible for stimulating and supporting public participation in the
208 (areawide) planning programs, as well as the 201 facilities
planning programs.
EPA documents. EPA publishes three kinds of documents
that dir^t and guid¥ EPA personnel, state agencies and local
arant aDDlicants! First, regulations^ are proposed for public
commen?Paid?hen issued in-fIHaTTHr¥ in the Federal Register
(Fed. Reg.), which is published daily by the Superintendent of
Documents, Government Printing Office, Washington, D. C. ($50
for annual subscription). EPA regulations also appear under
Title 40 of the Code of Federal Regulations (CFR), an annual
Portions of this chapter have been adapted from manuscript by
Barbara Reid Alexander.
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compilation of all regulations in final form (also available
from the Superintendent of Documents). Each Title includes
a number of Parts, each of which addresses a specific subject,
These regulations have the force of law. The
key regulations that apply to the municipal facilities
planning program include the following:
Regulation
Purpose
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, 1978.1
Secondary Treatment
Information, 40 CFR
Part 133, [38 Fe d. Reg.
22298, Aug. 17, 1973,
Amended on Oct. 7, 1977.]
Water Quality Management,
40 CFR, Subpart G [proposed
on Sept. 12, 1978, 43 Fe d .
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.
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Public Participation
in Water Pollution Control,
40 CFR Part 25. [Although
cleared for publication
as we go to print, these
regulations have not yet
been promulgated in the
Federal Register.-]
Describes general requirements for
pubic participation for all EPA
water programs. Reg.
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
a Facility Plan Revised,
May 1975, Municipal
Construction Division,
Office of Water Programs,
EPA, Washington, D.C.
20460
Model Facility Plan
for a Small Community,
Sept. 1975.
Guidelines for State and
Areawide Water Quality
Management Program
Development, Nov. 1976.
Alternative Waste
Management
Techniques for Best
Practicable Waste
treatment, MCD-13,
Oct. 1975.
Suggested topics, outline and data
necessary for a facility plan.
Now being revised.
Details on the contents of a
208 plan.
Now being revised.
Defines the acceptable options
for achieving BPWTT.
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.
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The third category of program development documents come
in the form of Program Requirements Memoranda (PRM). These are
policy and operation memoranda in the form of directives to EPA
Regions, but also are made available to others involved in the
Construction Grants Program (available from your EPA Regional
Office). They are usually not advertised widely. PRM's are
important because they often interpret significant issues raised
by the regulations. PRM's are identified by a two-digit prefix
that signifies the fiscal year in which they were issued and
are then numbered sequentially (e.g. PRM 77-1 is the first
memorandum issued in the fiscal year 1977).
It is not necessary that you be intimately familiar with
all of these EPA documents before you participate in facilities
planning. However, the overview of their contents provided in
this manual may prove useful. Youthen can refer to regulations
and guidelines when you need: (1) to learn more detail about an
aspect of facilities planning that is of particular interest to you,
or (2) to quote a source to give greater weight to your sugges-
tions at the local level.
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. Local officials probably
will deal primarily with representatives of this agency in prepar-
ing and conducting sewage treatment plans. Its organization, of
course, varies widely, but may reflect the EPA Regional Office
with which it deals. It is usually dominated by engineers. The
relationship between those with responsibility for facility
planning and those responsible for 303(e) and 208 planning is
crucial. As with EPA offices, state agencies commonly treat the
201 facility plan as a part of the Construction Grants Program,
not as part of water quality planning.
The state's responsibilities in the facility planning
process are vital. Besides formally managing the Construction
Grants Program (see the description of the state's new authority
below), the state water pollution control agency establishes
the Priority List, which determines when and how much money
the local communities receive. The state also establishes water
quality standards for specific bodies of water and has a role
in determining the geographic boundaries of the 201 planning
ning area and establishes water quality standards for specific
bodies of water. As is discussed in Chapter IV, the states
also have been given new responsibilities for establishing
population projections in specific facilities planning areas.
Furthermore, each state must approve a community's
application for a facility planning grant before it can be
submitted to EPA, and must approve the completed plan itself
48
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prior to EPA review. In fact, the state actually transmits the
grant application and completed facility plan to EPA. During
its own review, the state must certify that the plan conforms
with any applicable 303(e) basin plan or 208 waste treatment
management plan. Thus, the power of the state water pollution
control agency to determine the timing and direction of facility
planning is enormous.
How has recent legislation increased the authority of state water
qualityagencies in managing the construction grants program?
The Clean Water Act Amendments of 1977 call for greatly
increased state involvement in the Construction Grants Program.
Historically, EPA has retained responsibility for certifying
that all requirements of the Act and the regulations have been
met before funds are awarded for Step 1, Step 2, and Step 3
grants. But the new amendments—recognizing EPA's limited
resources and the desire of several states for more control
over the program—contain both authority and money for a
potentially major change in the Construction Grants Program:
Each state now can negotiate an agreement (termed the "Delega-
tion Agreement") with its Regional Administrator to take over
management of major parts of the Construction Grants Program
and to receive a federal Construction Management Assistance
Grant (CMAG) to assist its own management effort. (A maximum
of 2 percent or $400,000, whichever is greater, is now avail-
able from each state's construction grant allotment for this
function.) The Clean Water Act of 1977 contains not only
explicit authority for this delegation but also a new policy
directive on the subject:
It is the policy of Congress that the States
manage the Construction Grants Program under this
Act and implement the permit programs under
Sections 402 and 404 of this Act. [Section 101(b)]
You should be aware of how your state seeks to increase
its authority over the program.
State management of the Construction Grants Program will
be accomplished through a separately negotiated Delegation
Agreement between the state and EPA. (This agreement will form
part of the State/EPA agreement described in Chapter I.)
Responsibilities transferred by these agreements will range from
relatively straightforward engineering management, such as
inspection of on-site construction and review of required
operation and maintenance manuals, to the more complex require-
ments of facilities planning. The state agency may, in fact,
llcllllaon to.certify the adequacy of such critical components
of Step 1 planning as innovative and alternative technology
evaluation?, cost-effectiveness analyses, public participation
programs and environmental assessments.
49
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Once EPA has officially delegated such authority to a
state, the Regional EPA office is required to accept that
state's certification that a particular requirement has been
met (unless the Regional Administrator has positive reason to
believe a certification is faulty).
Several functions cannot be delegated, however. These
include determining the need for and preparation of
Environmental Impact Statements (under the National Environ-
mental Policy Act of 1969) and the actual awarding of funds for
Step 1, Step 2, or Step 3 grants. In fact, EPA may also decide
that a particular project requires special attention from its
staff.
Because EPA retains authority over undelegated functions
as well as bottom-line responsibility to sign grant awards, it
is likely that EPA has residual legal liability under Clean Water
Act provisions for citizen suits if there is a failure to carry
out nondiscretionary duties. The extent of this liability
probably will remain unclear until tested in the courts.
How do I know if the delegaton of the Construction Grants
Program is an issue in my state?
Delegation of authority to manage the Construction
Grants Program is an issue in nearly every state. Even in
states where the lead water quality agency has no obvious
capability to manage it, it is likely that the EPA Regional
Office and the state agency are engaging in quiet discussions
concerning what changes must be made so the state can take
over.
Given political pressure from the states and Congress,
and chronic staff shortages at EPA, it seems likely that many
delegations will take place quickly. (EPA's own projections
call for more than half the states to receive Construction
Management Assistance Grants by October 1, 1979.)
How will delegation of Construction Grants Program
take place?
(As you consider the formal steps of state delegation
described below, keep in mind that informal steps may be much
more important than the formal process. Informal discussions
now going on between the EPA Regional Office and the state
agency may result in "tentative" decisions from which changes
require a heavy burden of proof.)
The delegation procedure begins with a formal agreement
between the EPA Regional Office and those states with the
capability and desire to manage the Construction Grants
Program. The Delegation Agreement specifies which functions
will be transferred to the state agency over a 5-year period.
All terms and conditions are to be covered including designation
50
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of a management agency, staff and budget requirements,
scheduling for the assumption of delegated fuctions,
and the procedure for EPA reviews.
Once the Delegation Agreement is completed, the
Construction 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
recjuire public involvement during the negotiation of Dele-
gation Agreements and any substantial amendments to them.
Actual copies of draft delegation agreements (and substantial
amendments) and fact sheets are to be distributed to the
45 days before approval, and, if there is significant public
controversy, a hearing must be held. The public is specifically
asked to consider whether the state program is adequate to
the proposed delegations.
The State of California was the first state to receive
comprehensive authority from EPA to review and approve the full
spectrum of functions under the federal wastewater grant program.
The first stage was a memorandum of agreement signed in 1972;
formal delegation was begun in 1975. From 1976 to 1978 more
than 18 separate subagreements were prepared to outline how
the state would implement each certification and review function.
Under the California agreement, only the state
agency reviews the Step 1 application—the facility plan
itself, project reports, plans and specifications and
operation and maintenance manuals. During that review
the state fills out checklists to document to EPA that
required procedures, regulations and laws have been
followed. The state then certifies to EPA that proposed
projects are acceptable for Step 1, 2 or 3 grant awards.
Only the checklists are reviewed and signed by EPA, which
formally awards the grant. The state does all the paper-
work to prepare for the grant awards; the state agency
essentially is acting in place of EPA staff.
Will this management transfer do anything more than
just eliminate duplication and transfer the paperwork from
the EPA Regional Office to the state capitol? Obviously,
the answer to this question will depend on: 1) the
competence and training of state personnel; 2) the degree to
which EPA will scrutinize and respond to signs of problems raised
by grantees or by concerned citizens; 3) the amount of
political pressure exerted by the state on EPA to delegate
quickly or comprehensively; 4) the contents of the Delegation
Agreement itself and how it handles protests and disagreements
between the state and the grantee or the state and a citizens
group.
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CMAG regulations call for mid-year and end-of-year
evaluations of the state's program before the CMAG grant can
be renewed. The Regional Administrator must hold a public
meeting to assist the end-of-year evaluation. Presumably,
this evaluation will condition and affect new grants for the
coming fiscal year.
The delegation agreement for the Construction Grants
Program is intended to be one subpart of the broader State/
EPA Agreement described in Chapter I. Because State/EPA
Agreements have not yet been negotiated and adopted, CMAG
regulations require that the State/EPA Agreement be well enough
developed in fiscal year 1979 to allow a Delegation Agreement
to be consistent with it. By fiscal year 1980, state programs
funded under CMAG will be 'part of the State/EPA Agreement and
that agreement must be completed before execution of new
Delegation Agreements.
CMAG's generally will track the beginning of a new
fiscal year which starts October 1. Citizens who wish to be
involved in end-of-year evaluations should expect such
proceedings to occur in late spring and early summer. Most
actual grant activity will probably take place in the fall.
What affect will the Delegation Agreement and the CMAG
have on my involvement in facilities planning?
Once a program function has been delegated to a
state, EPA generally will accept the state's certification
that a local facilties plan meet a particular federal
requirement. The state agency will be the court of first
(and sometimes last) resort for your appeal if you consider
the local public involvement program, the environmental
assessment, or the local assessment of alternative technologies
to be inadequate. Although you may appeal disputes to the EPA
Regional Office, EPA will find it increasingly difficult, for
political reasons, to step into a local/state issue.
Key Questions to Ask
Here are some key questions you may ask of both your
state agency and EPA Regional Office:
1) Are the engineers in the municipal facilities branch
of your EPA Regional Office sensitive to environmental
early warning signals?
2) How does the planning and standards branch insert
its comments into the internal review of proposed
Step 1 grants?
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3) Are the comments of the planners given serious
consideraton?
4) One of the key indications of conflict or
cooperation relating to a specific Facilities
Plan might be found in the special conditions
inserted in the Step 1 grant prior to EPA
approval. Are the comments and issues raised
by the water quality planners included?
5) The relationship between the regional construc-
tion grants office and the environmental impact
office (which is usually separate and reports
directly to the Regional Administrator) also
becomes crucial. Who determines the adequacy
of the environmental assessment in the facility
plan and the need for an Environmental Impact
Statement?
6) Do planners, ecologists and biologists have
any responsibility in the facilities planning
process? Is jtheir responsibility a direct one
or only for review and comment?
7) What is the relationship between the construction
grants personnel and those responsible for
reviewing local 208 plans?
8) Does your water pollution control agency act
as a whole, or do specific personnel have
stated biases with regard to alternative
waste treatment systems?
9) Is there a state policy to fund innovative
systems or a history of preferring small
community septic systems when appropriate?
10) What is the present status of the delegation
of the Construction Grants Program to your
state agency? Does the state intend to work
toward a complete delegation of the program
as in California?,
11) When will a memorandum of agreement be
signed between the state and EPA to begin
the process of delegation? What areas of
authority will the state begin to take over
first?
12) Will a public hearing be held prior to
official delegation?
1.3) What role will EPA play when potential
disputes occur and problems are raised by
members of the public?
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14) What provision has the state made for compliance
with the public participation requirements of the
Clean Water Act? Does the Delegation Agreement
mention this important issue? Will EPA require
a full-time public participation specialist
at the state agency?
What is the local role in the facility planning process?
Who are the local actors?
The local applicant for federal construction grant
funds for a Step 1 planning grant has the responsibility
for producing the actual document, "Facilities Plan for
(your area)". It is the local responsibility to hire an
engineering consultant if necessary and to make the
important decisions required by the Clean Water Act and
EPA regulations, such as: Should septic systems now
serving an area be replaced with sewers? Which kind of
treatment alternative best serves the community needs and
the national effluent limitation prescribed as BPWTT?
Where should the treatment works, if any, be located? What
open space and recreational concerns can be built into the
plan? What secondary environmental impacts will result from
the proposed treatment works? Subsuming all these questions,
how much will the preferred alternative cost the town as a
whole and the individuals served by the system?
When it comes time to apply for a Step 1 planning
grant, concerned citizens should know who the official grant
applicant is. Unless it is a large urban area, chances
are the applicant will not be able to afford to hire
specialists to review plans and deal with state and federal
agencies with a high degree of technical expertise. These
jobs, then, will most likely fall to non-expert "generalists"-
local officials.
The official applicant may be local elected officials
such as selectmen, mayors or town councils. Whether these
officials in your community are full-time professionals or
basically volunteers will indicate much concerning the
amount and quality of time they will devote to facilities
planning. Find out who has supervisory responsibility.
Overworked officials may have little time to devote to
overseein.g the planning effort? an interested member of
the planning board or conservation commission might play
the important role of coordinating the flow of information
to key local personnel.
If a special district has been formed for sewage
treatment planning and construction, the official grant
applicant is the Sanitary District Board, Sewer Commis-
sion or Water District, whose directors or trustees
may or may not be elected. If the geographic scope of
the Facilities Plan crosses political boundaries, two or
54
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more jurisdictions may apply jointly or one of several
communities may act as the lead agency.
,In these cases, there is a danger that local
officials might consider that the problem "has been
taken care of" and thus feel little need to get
involved. Even a cursory look at the issues involved
in sewage treatment planning should convince you that
this is not so. Local officials have a large stake
in growth and environmental impact issues. Before
assuming "it has been taken care of," investigate
backgrounds and interests. How do the functions of the
special district relate to those of your local
government, especially planning, zoning and other
environmental functions?
In almost every case the local grant applicant
hires an engineering consulting firm to actually conduct
the facilities planning process. Although consultants
are nearly always engineers, individual firms may vary
greatly in their ability to bring to bear other points
of view. The local grant applicant acts alone in hiring
the consultant, though state and federal EPA offices
may offer a list of available firms upon request.
If the relationship between applicant and consultant
proves to be amicable, the same engineering firm is often
chosen to design and construct the recommended waste
treatment alternative. This is not a requirement, however,
and some have argued that hiring the same firm for planning
and construction may be detrimental to the process. EPA
no longer allows the consultant's profit to be a percentage
of construction costs, but the fixed fee of the consultant
is, of course, based on the scale of the overall system.
A conflict of interest may arise when a consultant is asked
to evaluate and compare systems of low capital cost and
small scale against large centralized regional systems
if that consultant is likely to receive a major construc-
tion contract.
The consultant's role depends on the contract nego-
iated with the local grant applicant (town government,
special district, etc.), but usually the consultant will
be responsible for producing a 201 Facilities Plan document
that conforms to EPA and state requirements. How involved
the applicant wants to be will determine the degree of
responsibility it retains for public participation in the
planning process, provision of personnel or certain testing
of soils and water, review of the plan in its initial
stages", and consultation with other local government
boards and agencies. Some of the issues that should
be raised with any potential consultant prior to hiring
are outlined later in this chapter and in Chapter IV.
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Which members of the public will be concerned about
facilities planning in the community? All sorts of people
and interests: local real estate developers; members of
civic action or environmental organizations; low-income
families worried about the cost of operating and main-
taining a fancy treatment plant; commercial fishermen who
want to clean up local shellfish areas; land owners
fearful about the location and impact of a sewage
treatment facility; local industry; and many others.
~ In many communities, members of the public have
not participated in facilities planning until the plan was
complete and the recommendations for construction made to
the state and EPA. Massive controversies then ensued
that required years of negotiation and investigation to
solve problems that could have been handled more easily
early in the planning process. The message is clear:
Getinvolved as early as possible.
Your role will depend on the energy and time you
devote to the issue. Perhaps you can act as an informal
adviser to your town officials; you might want to work
closely with the engineer/consultant to conduct public
participation programs concerning the planning process.
You may want to act as an advocate from a position
you hold in local government: conservation commission,
planning board, etc.,
Whatever your role, remember that you have a right to
all the information contained in state, EPA and consultant
files and that you have the right to expect compliance
with the public participation regulations.
Political Issues Pvaised by the Construction Grants Program
and the Facilities Planning Process
How will Section 208 planning relate to the on-going
facility planning process?
Congress intended Section 208 to be the keys^tone
of clean water planning. It was intended to bring about
areawide and statewide management plans to clean up
existing pollution and prevent future pollution from all
point and nonpoint sources in each planning area. Areawide
and statewide waste treatment needs would be identified
and planned for a 20-year period. These management
plans would provide the framework for the more local
decisions of the Facility Plan in communities that choose
to participate in the federal Construction Grants Program.
Congress emphasized 208 planning by providing for
100 percent federal funding during the first three years of
plan preparation: $150 million was authorized to be
spent for the first two years. No other planning program
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of the Clean Water Act received this level and amount
of federal funding. However, EPA was worried about the
land use implications of 208 planning and afraid to inter-
fere in historically local decisions. In addition, federal
budget officials resisted the increased spending:
Section 208 was not funded at all by EPA in fiscal year
1973 and only $25 million was provided in fiscal year 1974.
It took a court suit to force EPA to even begin requiring
and funding statewide 208 planning for the areas outside
the jurisdiction of designated areawide agencies. Serious
208 planning efforts were significantly delayed, but are
now underway in all states.
A major headache has been brewing since the beginning
of serious 208 planning efforts: how to coordinate the
final 208 plans with the 201 facilities planning program.
If 208 plans are to provide the framework for local
Facilities Plans, as the Act intended, then the provisions
of 208 plans clearly are crucial to the successful operation
of the program. However, these provisions may be quite
out of step with individual 201 plans, if only because
of the different actors involved. Most 208 planning is done
by regional planning agencies or councils of government
that have hired professional planners with federal funds.
The typical 201 grant recipient, by contrast, is a town
government or sanitary district that has hired a consulting
engineer to prepare its Facilities Plan. The different
perspectives of the planners may bring quite divergent
recommendations.
Furthermore, the scope of the two planning efforts
is significantly different. Local facility planning is
primarily structural in nature; the consulting engineer
arrives at a concrete solution (in more ways than one)
because federal funds are only provided for treatment
"works". Section 208 planning, however, must focus on
nonstructural land-use restraints required to achieve
good water quality. The 208 planners get no reward for
structural solutions.
If the 208 plan fails to be specific enough in its
identification of waste treatment needs over the next 20 years,
or recommends approaches that are unacceptable locally,
trouble may be brewing. There is a mechanism for amending
208 plans-—a system of annual review and update called
a contining planning process—but it may be complicated,
since it requires approval by both the state governor and
EPA.
Proposed new policies for coordinating facilities
planning and Section 208 planning are described in Chapter
IV. They make clear that in the future EPA intends that
local facilities planning decisions fit into the framework
established by areawide 208 planning: in case of disagree-
ment, areawide planning decisions will prevail.
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You should be aware of the status of 208 planning
in your area, especially if you live in a region that is
under the jurisdiction 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. Critical issues like
population projections, service areas and recommended
waste treatment alternatives and locations may have been
decided. If so, you should examine how these decisions
were reached. If you are unhappy about them, and the
208 plan already has been approved, you will have to seek
an amendment to the 208 plan, in addition to working
through the Facilities Planning Process.
What has happened to the Congressional goals and
and objectives of the sewage treatment program?
A look at some numbers associated with the
Construction Grant Program tells the story of a massive
federal program.I/ As of August 30, 1978, $19,37 billion
was obligated by the federal government for this program.
Over 100 grants are being awarded every month. Recent
1977 amendments have authorized an additional $4.5 billion
per year for the next five years. Although $4.2 billion
was actually appropriated for fiscal year 1979 (and there
is speculation that the appropriation for 1980 will be
less), almost 7,000 Step 1 grants have been awarded for
a total of over $600 million. Over 1,000 Step 3 construction
projects have been completed. Communities with a population
under 2,000 have received the most grant awards (41.4 percent);
communities with a population in excess of 500,000 have
received almost one-third of the federal funds.
There are 12,800 treatment plants currently in
operation in the U.S.; 6,200 are planned or under construc-
tion. Two-thirds of the plants now in operation do not
meet the secondary treatment requirements of the Clean Water
Act. Over 50 percent of the facilities now in operation
require treatment more stringent than secondary to meet
local and state water quality standards. Over 50 percent
of these treatment plants have less than one million
gallons per day flow. Over 91 million people are served by
treatment plants which will not meet the 1977 secondary
treatment deadline.
Had enough? The Program is a behemoth. However,
remains to be done. A 1976 survey of needs turned up
the figure of $95.902 billion necessary to meet the
requirements of the Clean Water Act (excluding needs for
the control of stormwater).
Clearly, the availability of federal funds is
the key to the entire program. There are not the
funds available at the local and state level to continue
this program without federal help. The degree of federal
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help necessary is often a debated question, but the
present 75 percent federal share seems to be here
to stay. The 1977 amendments seek to commit the
necessary federal funds for the next five years.
What has been accomplishd with the massive federal
program? Is this a public works program or a water
pollution control and public health program? Is the answer
to our pollution problems technical or ecological? Is
this an engineer's or a biologist's program? How do the
answers to these questions determine the end result: the
type of treatment works funded by all this federal money?v
Though a large number of projects have been built
and are under construction, the program is far behind
its initial deadlines.
What do these numbers mean about the ecologically
based water quality goals of the Clean Water Act?
Hard data on the kinds of treatment facilities built
is sketchy at best, but the vast majority of treatment
facilities built in the past six years have been
centralized conventional systems using physical/chemical or
biological treatment technologies. Relatively few land
treatment systems have been built. Until recently the
funding of individual systems to correct faulty septic tanks
was not allowed. Much of the thrust of the Construction
Grants Program in rural areas involved sewering those areas
and hooking them up to a centralized system.
Centralized conventional treatment systems are
often expensive to operate as well as to build. Sometimes
requiring large quantities of expensive chemicals and energy,
they also require sophisticated and well-trained operators.
Since operation and maintenance is a responsibility of the
local community and often falls between the cracks as
communities face substantial costs and inadequately
trained operators, observers have estimated that upwards
of 50 percent of currently operational treatment facilities
are not meeting to design standards.
The Construction Grants Program is in transition now.
One can be hopeful that renewed congressional and EPA
attention to land treatment, to other innovative and alterna-
tive systems, to cost-effectiveness analysis, to funding of
individual systems, and to the special needs of small
communities will lead to smaller, more effective ecological
treatment facilities more in tune with a given community's
needs and capabilities.
What basic political conflicts are raised by the
Clean Water Act?
Two continuing and related tensions accompany imple-
mentation of the Constructon Grants Program at all levels
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of government. The first is the continuing tension between
facilities planning as a way to find ecological solutions
to environmental problems and the Construction Grants
Program as a public works program.
An EPA fact sheet published in September 1978
notes that construction grants projects employ about
14,000 people on construction sites and an additional
22,000 off the sites for every $1 billion of total
expenditures by federal, state and local governments.
Since communities and states contribute at least 25 percent
of total costs, each $1 billion committed by EPA results in
employment of about 17,930 persons on site and about
27,500 off site.
Recognizing these 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 obligations of the program (see
the next section). Observers of the Construction Grants
Program have noted that the political necessity of moving
money quickly has higher priority than ensuring the quality
of the program. Attempts to upgrade quality, if they
may bring delays in the rate of obligatios, are discouraged.
The second major tension of the Construction Grants
Program involves management at the local level.
Since 75 percent of planning and construction funds
come from the federal government (and perhaps an extra 5-15
percent from state government), local communities have little
incentive to worry much about facilities planning. The
community's future cost of maintaining and operating the
system may be initially obscure and remote.
Furthermore, since the recipient of the construction
grant is frequently a group of lay people who have no
experience in wastewater management, the job is typically
turned over completely to a consulting engineering firm.
Three problems often result from this approach.
Many basic wastewater management decisions involve
political value judgments of which the community should
be a part. These decisions--population projections, land
use, housing and recreation opportunities, distribution of
the financial burden, effects on environmentally sensitive
areas, to name a few--are buried in the engineer's
technical jargon and frequently never emerge for public
review. By the time the consulting engineer presents the
community with a draft Facilities Plan, both the general
public and the grantee will find it difficult to uncover
these value judgments, strip them of their mystery, and
comment on them.
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Second, the consulting engineer is likely to be
biased by his experience in considering treatment
alternatives during the planning process, and perhaps
also by his expectation of receiving a piece of the action
in the construction project. (And, of course, as a
practical matter, if the engineer has designs and specs
already on his shelf that he can use in your community,
he can cut that part of his costs.)
The vast majority of consulting engineers who
design publicly-owned waste treatment works, are people
of competence and integrity; however, you must remember
that they are only human, and like everyone else their
competence for a particular project may be affected by
their training, their past experience and their future
interests.
Thirdly, a single engineering firm may not have the
expertise to meet all the planning requirements imposed by
law and regulation. Planning for municipal wastewater
management requires training and experience in sanitary
engineering, ecology, and planning and expertise in
obtaining public involvement. If one consulting engineering
firm is made responsible for all construction grant
planning in your community, some of the required expertise
may be missing.
What Impact Does the Availabilityand Method of Federal
Funding Have on the Construction Grant Program?
It is the rare community that will begin any part
of the planning, design and construction of a sewage
treatment facility without the assurance of the 75 percent
federal share of the cost. (Federal money may not be used
to reimburse costs incurred before the grant award except
under very narrowly defined circumstances.) Federal limita-
tions on what costs are eligible for 75 percent federal
funding thus determine what kind of planning and design
will take place and what actually gets built. (See "What
will the federal grants program pay for?" in Chapter V.)
It should be noted that the 1977 Clean Water Act
clearly linked the enforceable requirements of the Act
(in the case of municipalities achievement of secondary
treatment or whatever is necessary to meet water quality
standards or whatever other requirements are placed in
permits), as they applied to municipal treatment facilities,
to the availability of federal funds. Municipalities
will be given exemptions for failure to meet 1977 and
1983 requirements if one of the reasons for that failure
is lack of federal funding.
Federal money is allotted annually to each state
on the basis of a prescribed formula. The 1977 Amendments
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to the Clean Water Act tied grant awards to the congres-
sional appropriations process. In other words, EPA will
allot the $4.5-5 billion authorized by Congress in the 1977
Amendments (based on a statutory formula), but that money
will not become available until it is actually appropriated
by Congress. If funds are appropriated in a lesser amount
than the appropriation, EPA may have to reallot the actual
money allotment to the states.
Delays in congressional appropriations may well
mean delays in the award of construction grants. During
the 1976-1977 congressional debates over the amount of a
new construction grants authorization, many states actually
ran out of construction grant funds. This problem was
not solved with the passage of the 1977 Clean Water Act
Amendments, but rather with the passage of an appropria-
tion bill some months later.
Once allocated to a particular state, a state's
construction grant money is available for obligation
within that state for one year beyond the fiscal year in
which it was appropriated. After that time unobligated
funds are put back into the national pot and reallocated
among all the other states. Once reallocated, the funds
do not again become available to the state that could not
initially obligate them. This procedure creates additional
pressure on states and on EPA regions to obligate available
funds as quickly as possible. Although a construction grant
Priority List (described in detail in Chapter IV) may specify
that Community "A" has first priority over construction
funds, if Community "A" is not ready to apply for the funds
(due to delays in Step 1 planning, delays in guaranteeing
25 percent local share, etc. ) the funds are likely to be
obligated to the next project that is "ready to go."
This "readiness to go" factor is an unstated criterion
in determining the state's priorities.
The final grant award for actual construction of a
waste treatment facility (Step 3) often takes place
years after the approval of a Step 1 grant and plan.
Some projects considered approvable several years ago may
still be awaiting federal funds for Step 2 or 3 even
though local conditions or federal requirements may have
radically changed. Many Step 1 plans were completed
prior to the 1972 Clean Water Act and in theory must be
redone because of the new legislative and regulatory
mandates. Often these old sewage treatment proposals are
carried along into "new" Step 1 plans with little serious
thought about reevaluating alternatives.
Controversies may add years and lots of inflated
dollars to a project's life. A call for an environmen-
tally and politically sensitive alternative in a Step 1
plan may trigger the development of an Environmental
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Impact Statement. The EIS may recommend a totally
different alternative, which could in turn require a
new Step 1 plan. Those faced with this history may
ask: Is a final decision ever made?
The answer is that there is a constant opportunity
for revision during the Step 1 process and afterwards.
This is as it should be; otherwise Step 1 planning would
be a mere exercise to justify a previously decided result.
One example of the possibilities for revision has
been mentioned—the EIS; but other, less formal means
are available. Planning boundaries might be narrowed or
enlarged. Preliminary cost analysis may reveal that the
options chosen for study are too expensive and locally
unacceptable, so new alternatives are then studied more
closely.
You should hope, however, that the means of revision
now going on in Greenville, Maine, is not relied upon in
your community. In that community a complex and expensive
tertiary treatment plant was built for discharge into a
large recreational lake. The plant replaced a system of
village septic systems that were malfunctioning. The plant
is so expensive the town cannot afford to operate it, and
the complex physical-chemical system does not work
properly anyway. There was a local outcry about the
effects of direct discharge into the lake. Because the
plant doesn't work, the town has voted to investigate a
new waste treatment system based on land disposal of the
effluent. EPA is being petitioned to pay to remove the
old system and build the new one. How the town will retire
its substantial debt on the old facility is not yet known.
Court suits against the engineer and the manufacturer are
pending.
To prevent such mishaps in your community, get
involved early. A vigorous public participation program
can avoid some of these problems.
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FOOTNOTES - CHAPTER III
1. "Clean Water: Factsheet," EPA Office of Water Programs
Operations, Aug. 30, 1978.
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CONTENTS
.CHAPTER IV
INTRODUCTION TO STEP 1 PLANNING
Page
What Does Wastewater Facility Planning Involve? . 67
What are the Basic Steps to Obtain Federal Construction
Grant Funds? 67
What are the Controlling Criteria and Standards? ...... gg
Federal Requirements 68
State Requirements 69
Local Requirements 70
What Special Environmental Considerations Must the
Construction Grants Program Address? . 70
Floodplains management and wetlands protection 70
Significant agricultural lands 70
What Are Some of the Special Objectives of Sewage Treatment
Management „ 71
Multiple purpose facilities . 71
Integrated recycling/reuse facilities 72
Energy reduction .... ...... 72
Water conservation 72
Innovative and alternative technologies . . . . 72
Special attention to the concerns of small communities . 74
What Will the Federal Government Pay For? 75
What Are the Earliest Opportunities to Influence the
Direction of the Step 1 Plan? 78
Decisions made by nonlocal actors 78
Establishing effluent limitations 79
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Page
Establishing Planning Boundaries 7^
Statewide disaggregation of population projections ... 81
How Does a Community Establish Initial Eligibility for a
Federal Grant? 81
The priority system 81
The Priority List 84
The Grant Application 84
What Are the Key Elements of the Grant Application? .... 85
What is the Role of the Consulting Engineer? 87
What is the Role of the Public Participation Outline in the
Plan of Study? 88
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CHAPTER IV
INTRODUCTION TO STEP I PLANNING
What Does Wastewater Facility Planning Involve?
A wastewater Faciliies Plan (also known as a 201
plan or Step 1 plan) is, in essence, a preliminary
engineering plan for a treatment system that is cost-
effective, environmentally sound, and politically accep-
table.
Its purposes are:
1) To determine and evaluate the alternatives
available to a particular community for
controlling pollution in order to meet water
quality standards;
2) To select the plan that best meets water
quality standards and the community's needs;
3) To provide preliminary engineering for the
selected plan.
The Facilities Plan also includes an officially-
adopted strategy for financing the facility—and it is the
first step toward secruing a federal grant for construction.
The goal of the entire Facilities Planning Process is
to select the alternative means of managing sewage that meets
effluent and water quality goals at the least financial
cost to the community while recognizing environmental and
social concerns.
What are the Basic Steps to Obtain Federal Construction Grant
Funds?
Every engineering project demands advance planning.
However, preparation of a facility plan is the necessary
first step in a three-step process required for construction of
sewage treatment facilities with federal financial assistance.
As such, the wastewater facility plan must contain elements not
necessarily included in all preliminary engineering plans.
Once a community's wastewater facility plan has been
approved by, first, the state water quality agency, and then
EPA, Step 2 may be taken: preparation of detailed engineering
design plans, specifications, and cost estimates. Step 3 is
Portions of this chapter were adapted from manuscript by
Barbara Reid Alexander and Robert T. Dennis.
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actual construction. As a general rule, EPA will provide
75 percent of the "eligible costs" (see "What will the Federal
Government Pay For?" in this chapter) of each of these three
steps. When a project is classified as innovative or alterna-
tive (see "Special Objectives/' this chapter), the federal
share may go as high as 85 percent. Many states also offer
grant assistance, so that the community share of the total
engineering cost may be as low as 5 percent.
The three-step construction grants process basically
assures that facilities built with federal funds will be
both environmentally sound and cost-effective. The Step 1
plan provides for local, state, and federal review of the
planning process at a key point along the road to final
construction. 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.
As discussed on the following pages, the facilities
planning process must include opportunity for public review and
input. Therefore, as an interested citizen you should partici-
pate in assessing the Step 1 plan, the facility it proposes, and
the possible need for plan adjustment before the remaining
steps leading to construction are taken.
What are the Controlling Criteria and Standards?
Whatever its service area and size, the facility
must be designed to meet a host of treatment and engineering
criteria and standards. The following list is not exhaustive--
controls vary from state to state, and will be known by your
state water quality agency and your community's consulting
engineer. This list is intended only as a summary of major
criteria and standards. Many of these controls are discussed
in more detail elsewhere in this manual.
Federal Requirements
• All publicly-owned wastewater treatment facilities
must apply "best practicable waste treatment
technology" (BPWTT) by July 1, 1983. BPWTT is
determined in a cost-effective comparison of a
range of alternative systems (including land treat-
ment systems, treatment and discharge systems,
treatment and reuse systems) that produce the
desired degree of effluent quality. BPWTT has
been interpreted by EPA to require the equivalent
of secondary treatment or whatever more stringent
treatment level is necessary to meet water quality
standards.
9 Secondary treatment by July 1, 1977, for all publicly-
owned facilities discharging into navigable waters,
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except for municipalities that have attempted to
comply but were faced with extended construction
periods, or were unable to secure needed federal
construction grants. Deadlines in these cases may
be extended on a case-by-case basis up to July 1,
1983. EPA has set national minimum standards for
secondary treatment, but may waive them in some
cases for discharges into marine waters.
• Each entity owning and operating a public wastewater
treatment plant must adopt and enforce an ordinance
requiring pretreatment of industrial wastes entering
that plant, as a prerequisite to eligibility for
federal grant assistance.
• Ordinances must also be adopted to establish a user
charge system and to recover that portion of the
capital investment required for treatment of
industrial wastes (Industrial Cost Recovery).
• Each treatment facility must secure and renew
every five years a National Pollution Discharge
Elimination System permit, specifying schedules
for achieving effluent criteria for various '
pollutants with enforcement by regular monitoring
of the effluent. (These permit programs are
operated by the states under a delegation process
in about 30 states.)
• Requirements for adherence to federal laws governing
contracts, equal employment opportunity, wage deter-
mination, freedon of information and other adminis-
trative matters.
State Requirements
The state water quality agency, perhaps in cooperation
with the state health department, will also have requirements
which must be met by the Facilities Plan. These include:
• Effluent criteria in addition to those capacities
by EPA.
• Water quality standards and assimilative capacities
for water receiving the facility effluent.
• Engineering and construction standards, including
design criteria for aeration basins and other
facility components, buffer areas around facilities,
and fail-safe requirements for mechanical equipment.
• Eminent domain and easement acquisition practices.
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Local Requirements
The facility must be built in accordance with all local
zoning, building permit, site management, environmental protec-
tion, plumbing and electrical codes.
What Special Environmental Considerations Must the Construction
Grants Program Address?
Wastewater treatment facilities are subject to all fed-
eral laws relating to protection of the environment, governing
disposal of solid wastes, and promoting wise land and resource
use. The Clean Air Act applies; so does the National Environ-
mental Policy Act. Accordingly, the facility must be designed
so as not to impact adversely upon wetlands, critical environ-
mental areas, or shellfish waters (See Chapter I).
Floodplains Management and Wetlands Protection
To implement the requirements of the recent Executive
Order (No. 11988, May 24, 1977), EPA has proposed agency policy
and guidance for protection of floodplains and wetlands. In
terms of the Construction Grants Program, the new policy
would require that EPA, before undertaking any action, first
determine whether or not the proposed facility will be
located in or affect a floodplain or wetland. If potential
impacts can be identified, EPA would then conduct a "flood-
plains/wetland assessment" in conjunction with either an
Environmental Assessment or Environmental Impact Statement
review process. This assessment is to include a description
of the proposed action, a discussion of its impacts and a
description of alternatives considered. EPA also would be
required to notify the public of any action that has potential
floodplain/wetland impacts and provide adequate opportunity
for public review.
If there is no practicable alternative to locating in
or affecting the floodplains or wetlands, the policy would
require that EPA consider ways to minimize adverse impacts on
these sensitive areas and to restore and preserve their natural
and beneficial values. Once EPA made a decision on the most
desirable alternative, it would have to notify the public and
produce a statement of findings to explain its decision.
Significant agricultural lands
EPA policy for protection of significant agricultural
lands requires, among other things, that specific project
decisions involved in the planning, design and construction
of sewers and treatment facilities must consider farmland
protection. Consistent with EPA cost-effectiveness guide-
lines, interceptors and collection systems should be located
on agricultural land only if necessary to eliminate existing
discharges and serve existing habitation. In addition, EPA
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must see that primary and secondary impacts on this land
are identified and that mitigation measures are recommended in
Environmental Assessments, in EPA Environmental Impact State-
ments, and in reviews by EPA through the EIS process of
actions proposed by other federal agencies. In all its
programs EPA must support and encourage state and local
government agricultural land protection programs.
What Are Some of the Special Objectives of Sewage Treatment
Management?
Multiple purpose facility
Recreation and open space. As of 1977„ the Clean Water
Act requires documented consideration of recreational and open
space use of properties acquired for wastewater facilities. EPA
regulations require that the recreational opportunities of
each sewage treatment alternative be evaluated as part of the
facilities planning process. Until now, only a few pioneering
communities have reaped the potential recreation benefits
associated with the millions of dollars' worth of land and
water involved in wastewater treatment.
In most cases, recreation agencies have been suspicious
of sewage treatment facilities,--and wastewater agencies have
not wanted any part of the potential liability for recreational
use of their properties. It would seem logical, however, to
arrange for joint management of certain wastewater properties:
sewer easements can be put to use for stream access, hiking,
and bicycle paths? the ponds and reservoirs used for some
treatment processes can support fishing and swimming; and
land treatment systems can be thoughtfully planned to double
as urban open space.
You should recognize that recreational uses of waste-
water facilities can help improve the facility's image as an
important community asset among the residents of your
community. Planning a facility for recreation and open
space can sometimes defuse neighborhood opposition to the
site selected.
As you get involved in assessing the recreational
opportunities of each management or treatment alternative, you
should be aware of the constituencies in your community for
open space and recreational activities. Recreation groups,
civic groups, and urban/poverty groups may have their own
reasons to be interested in analyzing recreational opportunities
during facilities planning.
EPA allows Step 1 funds to be used during the required
analysis of recreational use for each treatment alternative, but
Step 2 and 3 funds may not-be used to design or implement such
use. Citizens interested in this part of the program will have
to seek other resources to realize recreation plans. Local
recreation and parks departments may provide technical assistance
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to the required Step 1 analysis. Their early involvement may
ensure implementation, since they may know of community, state,
and federal resources available to help pay for recreational
use of sewage facilities.
Integrated Recycling/Reuse Facilities
In 1972, the Clean Water Act exhorted the EPA Adminis-
trator to encourage waste treatment management facilities that
are integrated into other industrial and municipal waste manage-
ment facilities "including . . . solid waste and waste heat
and thermal discharges." EPA is currently considering a new
funding policy for these multiple purpose projects that utilize
treatment systems that qualify as alternative or innovative.
Energy reduction
Increasing attention is being given to the energy budgets
of wastewater treatment facilities. Some plants constructed in
the recent past have proven to be high energy consumers—using
electricity or oil to run pumps, drive treatment processes, and
incinerate sludge. Public policy and economics are now focusing
new attention on low-energy processes, sewage digestion methods
that produce gas to be burned for heat, techniques to combine
sludge and solid wastes for burning to produce electricity,
and working solar energy into wastewater treatment technology.
The Clean Water Act of 1977 requires the EPA Administrator to
encourage energy-efficient waste management alternatives.
Water conservation
The Clean Water Act encourages the reclamation and
recycling of wastewater. Its 1977 Amendments give new life
to water conservation measures. The reserve capacity (to serve
future needs) of treatment plants may only be calculated after
efforts to reduce the flow of sewage and unnecessary water
consumption have been taken into account. (See Chapter V for
EPA implementation through cost-effectiveness guidelines.)
Innovative and alternative technologies
Concern over the large number of expensive conventional,
centralized secondary treatment and discharge facilities led
Congress to place new emphasis on nonconventional systems in
the Clean Water Act of 1977.
EPA guidelines published on September 27, 1978 attempt
to define innovative and alternative technology. Essentially,
alternative technology is defined as anything 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
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meeting the natioal goals . . ."2/ 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 alternatives;
• reduction by 20 percent of net energy requiremnts for
alternatives;
* improvements in operational reliability;
* better toxic materials management;
• increased environmental benefits; and
• improved joint municipal/industrial management and
treatment.
Several provisions of the Clean Water Act can be
expected to have a significant impact on the type of treat-
ment systems that are funded.
First, after September 30, 1978, no construction grants
may be awarded unless innovative and alternative systems have
been studied. The 1977 Clean Water Act defines such systems
as those "which 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 (discharged into municipal systems) and the confined
disposal of pollutants ..."
Second, a special reserve fund—2 percent of a state's
total yearly construction grant in 1979 and 1980, 3 percent
in FY 1981—must be set aside for bonus grants to be made
available for construction of innovative and alternative
treatment systems. This bonus raises the federal share of
the approved treatment works from 75 percent to 85 percent.
(The "bonus" grants are authorized for only three years—
through FY 1981.)
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 (See "The Priority System" in this chapter),
and 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.
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The guidelines for funding of innovative and alternative
systems are flexible. The EPA Regional Office, or the state
if authority has been delegated, decides on a case-by-case basis
whether a system is innovative or alternative.
EPA has ruled that the bonus grants for innovative and
alternative systems may only come out of the innovative and
alternative set-aside. ("if the system is for a small community,
the first 75 percent of the federal share may come out of
the small community set-aside.) If a large number of new
projects meet the criteria for innovative and alternative,
it is possible there will be insufficient funds to pay the
intended 85 percent federal share for all eligible projects.
The special reserve for innovative and alternative systems
is only authorized for three years. EPA has ruled that innovative
and alternative systems must be eligible for federal funding in a
given fiscal year and will be funded in chronological order of
grant application. If only a part of a project is innovative
and alternative, only that portion of the project attributable
to an innovative and/or alternative system will be eligible for
the 10 percent bonus grant.
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 Step 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 assis-
tance to small communities with qualified innovative and alter-
native 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 conventional
treatment under the definition of "innovative and alternative"
and as such, they are not eligible for a bonus grant from
the innovative and alternative "set-aside." Individual systems
may not receive the 15 percent cost preference in the cost-
effectiveness analysis to which other innovative and alter-
native systems are entitled. They are also eligible for the
75 percent federal funding available through a special reserve
fund set aside for alternative systems for small communities.
Since states with populations that are 25 percent or more
rural must set aside 4 percent of their annual allotment for
alternative treatment systems for small communities, that alone
should provide some special incentives for funding individual
systems.
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What Will the Federal Government Pay For?
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—including, but not
limited to, engineering data, analysis of alternatives,
environmental assessment, public participation activities and
recreational planning for a facility that is appropriately
eligible on the state Priority List (see "The Priority
System" in this chapter). 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 generating over-
environmental and social impacts. A number of quite specific
requirements (described in Chapter 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 area.
The federal government will not pay for:
1) a facility that is larger than necessary for
anticipated present and future wastewater
volume, as determined by established procedures;
2) a facility designed solely to meet community
expansion needs rather than existing water
quality needs;
3) ongoing administrative activities of local
government. Grant funds may be used, 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), but may
not be used to pay the mayor's salary; and
4) sewage treatment plant site acquisition.
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Some special cost eligibility considerations are worth
paying attention to here.
1) A new or improved and expanded treatment facility
built primarily to treat domestic waste is eligible
for federal funding. Industrial waste may be treated
at the facility, but the proportionate capital outlay
(less interest charges) is paid back through an
industrial cost-recovery system.
2) Federal funds may only be used to pay for the most
cost-effective system that meets the enforceable
requirements of the Clean Water Act. As has been
noted previously the 1983 BPWTT standard has been
defined as secondary treatment (or its equivalent)
or whatever more stringent treatment is necessary
to meet state water quality standards. This means
that federal grant funds may not be used for treat-
ment more stringent than secondary unless state
standards require such treatment, or unless the
treatment system resulting in a higher degree of
treatment is, in fact, the most cost-effective
system to meet the secondary treatment minimum.
Recent concern over the high incremental costs of
treatment beyond secondary have led the Congress and EPA to
adopt new policies that may make it more difficult to con-
struct sewage treatment facilities that go beyond secondary
treatment standards. In approving the fiscal year 1978 Con-
struction Grants Appropriation, the Congressional Appropriation
Conference Committee directed that the EPA Administrator
personally approve advanced treatment for all projects in
which the incremental costs of such treatment exceeds $1 million.
The Administrator must make a definitive finding that such
treatment will result in "significant water quality and public
health improvements."
Basically, EPA policy will be to take a hard look at all
such projects. Before they may be funded, they must undergo
rigorous financial analysis and their benefits must be determined
to be significant. If an advanced treatment project involves
innovative and alternative technology, its projected costs must
exceed secondary treatment costs by 25 percent before it is sub-
jected to the rigorous cost-benefit analysis of other advanced
treatment projects. The analyses required by EPA Regional Offices
are to be forwarded to EPA headquarters for the Administrator's
approval.
Because determinations concerning "significant water
quality and public health improvements" will have to be made on
a case-by-case basis, considerable confusion about what kinds
of projects are eligible for federal funding is to be expected.
3) Necessary interceptor sewers that are part of the
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recommended cost-effective alternative are eligible
for federal funds. Generally speaking, new collector
systems serving communities built after 1972 are not
eligible. (The test for what constitutes an existing
community is based on population density.) Rehabili-
tation of sewer systems may be eligible if that is
cheaper than adding treatment capacity. If the sewers
to be"rehabilitated are house connectors located on
private property, they will not be eligible for a
federal grant.
4) The cost of land is eligible only if it is land used
for wastewater storage prior to land treatment, or
if used as part of the treatment system.
5) As mentioned previously, individually-owned and
operated systems may be eligible for federal funding
if that alternative proves to be the most cost-
effective.
To be sure that funding of individual systems does not
give a windfall to certain private homeowners, funds used for
individual systems are subject to a number of additional
limitations. Some of these limitations are:
« acquisition of land is generally not eligible for
federal funds, as it is presumed that the home-
owner already owns the land;
• the only portion of the wastewater generating
fixture that is grant-eligible is the residue
disposal mechanism;
® site improvement beyond preconstruction conditions
is not grant-eligible.
Individual systems may be considered innovative and
alternative systems and therefore eligible for the 10 percent
bonus grant allowed those systems. They may not, however, be
given the 15 percent advantage in the cost-effectiveness deter-
mination. In order for individual systems to be eligible for
federal funds, a public body must make application for those
funds, and must certify that the individual systems will be
properly operated and maintained.
6) Multiple-purpose projects are currently eligible
for federal funding only to the extent that they
are the most cost-effective alternative designed
to meet water quality standards. While planning
for recreational use of facilities is required
(and in fact, is eligible for Step 1 planning
funds) neither the design, nor implementation
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(purchase of surface easements, etc.) are
eligible for construction grants funds.
EPA is currently considering a new policy for multiple
purpose projects that use innovative and alternative treatment
systems. If a multiple purpose project meet certain specified
conditions, the portion of the total multiple purpose package
(pollution control plus utility cooling system, for example)
that would be eligible for construction grant funds would be
calculated according to the following formula:
« divide the total cost (capital costs plus
operation and maintenance over the entire
project period, expressed as present worth—
see Chapter V) of the most cost-effective
single purpose pollution control option, by
the present worth of the most cost-effective
multiple purpose option;
e multiply the resulting quotient by 115 percent.
The fraction obtained by this formula is the
portion of the multiple purpose project which
is grant eligible.
Because in some multiple-purpose projects the amount of federal
funds the project would be eligible for will be less (if by
combining a water quality function with another function, the
total cost of the water treatment function declines), a minimum
level for grant eligibility will be 115 percnt of the capital
cost of the most cost-effective pollution control option. (Such
multiple-purpose projects as those that combine recreational
use and water pollution control will continue to fall under the
old policy.)
In other words, for multiple purpose projects using
innovative and alternative systems, some of the cost of the
parts of the project that are not related to water quality
needs may be covered by federal assistance from the Construction
Grants Program.
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,and population projec-
tions. These decisions are to be made by state agencies or by
designated areawide waste treatment management agencies (see
Chapters I and III). 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 I planning unless the related information
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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. These limits are expressed in terms of the amount of
or concentration of pollutants that may be discharged into
receiving waters (i.-e. amount of biological oxygen-demand
material (BOD) that may be discharged per million gallons
per day (mgd) of wastewater, or miligrams per liter (mg/1)
of suspended solids (ss)).
Effluent limitations are essentially derived from these
sources. First, all municipal discharges (with one exception
to be described later) must meet a minimum national standard
of discharge, which is defined as the level of discharge that
can be expected from a well-operated secondary treatment
facility.
Second, if the equivalent of secondary treatment is not
sufficient to meet state water quality standards for a particular
body of water, a stricter standard requiring higher degrees of
pollutant removal may be established. This level of treatment
may be expressed in terms of percent of pollutants removed, up
to 100 percent.
Third, if a facility discharges into marine waters, the EPA
Administrator may (under conditions specified in the 1977 Amend-
ments) allow a variance from secondary discharge requirements.
It is relatively easy to find out which effluent standards
apply to a community with an existing sewer system and untreated
(or undertreated) discharge. The permit issued under the National
Pollutant Discharge Elimination System will require effluent limi-
tations based either on a minimum of secondary treatment or on
state water quality standards, whichever is stricter.
It is more difficult to find out which effluent limitations
aPPly when a community has no existing publicly-owned discharge
(i.e., no sewers or treatment plant), and therefore no NPDES
permit to dictate minimum treatment levels and cleanup schedule.
A state-issued permit or abatement order or an approved WQM plan
may then be the place to look for effluent limitation requirements.
Establishing Planning Boundaries
Your state's water quality agency will usually
determine the planning area for Step 1 grants in consultation
with local officials or in the contents of a completed WQM
plan. A completed WQM plan must assign an agency to manage
planning and construction 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.
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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
source of the pollution problem itself? how much other
area is also included may directly influence the contents of
the Facilities Plan itself.
Consider the following scenario:
A small village has malfunctioning septic systems.
Two nearby villages have the same problems. The entire
area is subject to growth pressures. A large urban
area has a modern secondary treatment facility nearby.
Now, if the 201 planning area is limited to the
first small village and its political boundaries, certain
small-scale treatment options become viable. If planners
define the 201 planning area to include all three small
villages, a more centralized treatment option probably will
be considered. And if the three villages are annexed to the
urban area planning district, or join the urban sewer district,
a vast treatment system becomes an obvious treatment alternative.
The selection of treatment boundaries in cases like
this obviously can tell you a great deal about the preliminary
thinking of the state waste treatment planners.
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. It must, for example,
include the entire area that might be affected by secondary im-
pacts brought brought on by sewer induced growth. Second, it must
be large enough so that cost-effective alternatives can be con-
sidered—a requirement often seen as a way to enlarge planning
areas to allow study of regional solutions. In fact, EPA regula-
tions specifically require that "appropriate attention should
be given to including the entire area where cost savings, other
management advantages, or environmental gains may result from
interconnection of individual waste treatment systems or collec-
tive management of such systems." (40 CFR 35.917-2(a)(1))
Although it is the state's job to draw planning
boundaries, local officials must be consulted. In addition,
EPA has the right to change boundaries (after consulting with
local and state officials) on the grounds that the geographic
scope of facility planning should be limited to the extent
necessary to assure that subsequent grant awards will be
cost-effective and environmentally sound.
Boundary selection has political and legal implications
that you and your local officials should be aware of: Planning
boundaries larger than your town's own borders may involve you
in a tug-of-war with more powerful nearby communities. A small
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town can easily lose control over selection of treatment
alternatives if it becomes part of a larger sewer district.
Planning area boundaries are distinctly different
from and broader than service boundaries discussed later in
this chapter and in Chapter V. Yet, the drawing of planning
boundaries before the facilities planning process begins may
in fact establish the basic outlines of service areas.
Statewide disaggregation of population projections
The states are responsible for disaggregating (breaking
down) statewide population projections in facilities planning
areas (See Chapter V). The statewide disaggregations are to be
submitted to the EPA Regional Administrator before October 1,
1979, and each subsequent year thereafter, and are to be
presented before a public meeting for discussion before
they are submitted to EPA for approval.
How Does a Community Establish Initial Eligibility For a Federal
Grant?
The priority system
No Step 1, 2 or 3 grant can be awarded unless the state
certifies to EPA that the project in question is entitled to
priority for federal funds in accordance with an approved
state priority system and the state Priority List. This means
that within the constraints of the congressional appropria-
tion process and other constraints described below, the
state controls the timing and amount of federal grants
under the Clean Water Act's Construction Grants Program.
The state decides how to rank potential Step,1, 2 or 3
projects (the priority system) and then publishes a list
(the Priority List) of projects in the order in which
federal grants will be made. Typically, the public gets
involved in the Construction Grant Program after this
priority ranking is decided and the award of a Step 1
grant is imminent or already made. However, if you are
interested in the statewide program for water quality or are
a local official or citizen concerned about the timing and
amount of federal funding, here's how the priority system works:
There are a number of constraints on a state's use
of its federal construction grant allotment. The priority
system used by the state to determine its Priority List
is reviewed and approved by EPA to ensure "procedural
completeness" and to see that it is "designed to obtain
compliance with the enforceable requirements of the Act ..."
[40 CFR 35.915(a)]
The priority system, or revisions of it, must also
be subject to a public hearing. A summary of public comment
must be included when a state submits its priority system
to EPA. The priority system must include a system for
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public involvement in revisions to the system and in
adoption of the Priority List.
Typically, a state sets up several categories as a
way to classify its waste treatment needs. The Clean
Water Act requires that categories be related to such
things as the severity of the water pollution problem,
the extent of the population affected by the pollution,
the need to preserve high quality waters and the necessity
to assure compliance with state water quality standards.
Classifications based on economic criteria (such as the
level of unemployment in an area) or criteria generally
based on anything other than water quality are not acceptable.
This requirement emphasizes that the Construction Grants
Program is based on water pollution rather than its public
works or job-producing aspects.
Once these general categories and subcategories are
decided, each state can select its own system for weighting
the various categories. If the state wants to give higher
priority to achieving water quality standards than to other
classifications (for example, preserving existing high quality
waters), it is free to do so. Each state is required, however,
to define its fundable projects in one list that groups them
according to the following breakdown: Category I, secondary
treatment; Category II, more stringent treatment necessary for
compliance with state law? Category IIIA, infiltration/inflow
corrections; Category IIIB, major rehabilitation or replacement
of existing systems; Category IVA, new new collector sewers and
appurtences; Category IVB, new interceptor sewers and appurtences;
and Category V, correction of combined sewer overflows.
Whatever the system for ranking the eligible projects,
it must be applied consistently. The only limit on the state's
freedom to put a project on the Priority List is that the pro-
ject must meet the enforceable goals of the Clean Water Act.
(Special provisions regarding sewers are described below.)
There are a number of "reserves" or "set-asides" required
by the 1977 Clean Water Act. These involve amounts or percentages
of the state's total construction grants allotment that must be
used for certain kinds of projects or for certain kinds of goals.
Although EPA regulations are not explicit on this subject, these
new requirements would seem to mandate a major revision to the
state priority systems that have been in existence since 1973.
Participating in the required hearing on any revision of your
state's system is one way you will be able to influence which
projects come first in the race for federal funds.
The final state Priority List must reflect a mix of
high priority projects that are ready to proceed and which
reflect the following reserves:
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1) A state may give higher priority to those projects
in the Step 2 and 3 phases that utilize innovative
or alternative techniques and processes.
2) 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
to be used for alternatives to conventional sewage
treatment works. A governor of a "nonrural" state
may request up to 4 percent of its allotment for
the same purpose.
3) Treatment works that use innovative or alternative
processes and techniques are allowed an increase
in the federal share from 75 percent to 85 percent.
A state must set aside 2 percent of its alloted
funds for the extra incurment of these projects
(3 percent in 1981). One-fourth of the allotment
must be used only for the innovative projects.
4) A state may spend up to 25 percent of its allotment
on so-called "pipe projects": rehabilitation of
existing sewer systems; new collector services; new
interceptors; correction of combined sewer
overflows. Expenditures for pipe projects must
meet constraints imposed by a number of regulations
(such as cost-effectiveness requirements) and be
otherwise eligible for a federal grant. EPA
regulations state that when pipe projects exceed
25 percent of a state's construction grant allotment,
allocation for these projects will be carefully
examined to see that the proportion of pipe
projects exceeding 25 percent meet the enforceable
goals Of the Act. Specific projects will be dropped
from the Priority List if they fail to help meet
enforceable goals, until the so-called pipe projects
total no more than 25 percent of the allocation.
5) Up to 2 percent of the state allotment, or $400,000,
whichever is greater, may be allocated to the state
agency to reimburse it for construction grant manage-
ment functions (CMAG, see Chapter III) it has under-
taken pursuant to a Delegation Agreement.
6) Each Priority List must reserve 5 percent of its
allotment for contingencies involved in increased
grant needs.
7) A statfe may set aside up to 10 percent of its
allotment for Step 1 or Step 2 projects that are
of a lower priority than current funds would allow
or for which no need had surfaced yet at the time
of Priority List development.
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The Priority List
Each state submits a five-year Priority List each year
for EPA approval. A public hearing must be held before it is
submitted. EPA's review consists only of assuring that the
criteria adopted by the state have been applied consistently and
that individual projects will result in compliance with
enforceable requirements of the Act. If EPA challenges a
project's place on the Priority List, a public hearing must
be held. Revisions to the Priority List will also generally
require a public hearing.
Theoretically, it should not be difficult to find ways
and means to spend the available federal money on the basis
of totally objective criteria. However, "federal grantsmanship"
—the constant struggle among local officials for their share
of federal dollars for whatever project—certainly enters into
the system, if not overtly then in covert ways. The most common
conflict is the "city problem." The largest city in the state
often suffers the worst pollution problem simply because its
discharge of untreated wastes affects a larger percentage of
the state population. In a sparsely populated state, solving
the big city's problem may use up the bulk of the state's
allotment. How to concentrate on solving the worst pollution
problems first, but still distribute federal funds equitably
around the state, is often a headache for the state water
quality agency director, who well knows that rural areas
tend to dominate state legislatures from whom his budget
and his legislative authority come.
In the past EPA discouraged the use of population
alone as a deciding factor in the allocation of construction
grant funds, but the 1977 Amendments to the Clean Water
Act make clear that a state may give whatever weight it
desires to population so long as it is related to water quality
goals. Realistically, the use of an entire state allotment
for Step 3 construction in a large city is unlikely; more
likely the large city system would be built in segments so
that construction—and cost—is spread over many years.
The most controversial part of the Priority List for
people concerned about the growth-inducing aspects of the
Construction Grants Program will be the percentage of the
state's allotment devoted to pipe projects: collector
sewers, interceptors, combined sewer overflows, etc. Find
out how your state ranks the importance of these projects;
the time to ask questions and demand explanations is at the
mandatory annual public hearing on the submission of the
Priority List to EPA.
The Grant Application
After a project is placed on the fundable portion of
the approved Priority List (the portion for which funds will
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be alloted in the coming fiscal year) the public body
responsible for sewer management must take the initial steps
of applying for federal financial assistance.
As one such step, the community must formally designate
a government official (not a consultant) to act for it in all
matters relative to application for federal assistance. This
designee may well continue in a key role through the three-
step construction grants process; his/her attitude about public
involvement and other matters of community interest will be
important in shaping facilities planning policies and procedures
once a grant has been procured. If possible, the public should
advise on selection of this person.
The application and related documents will be reviewed
first by the state water quality agency, then by EPA. No
grant payment will be made for any Step 1 facility planning
work that was begun prior to EPA's award of the grant, or
without written approval of the Plan of Study accompanied by
reservation from the state allotment of the needed funds.
What Are the Key Elements of the Grant Application?
• A Plan of Study should briefly describe problem
areas, scope of the planning effort, and work
schedule. Eventually, the Plan of Study will be
made part of the grant agreement; the work schedule
and cost estimates related to the proposed Step 1
work will be used to determine a formal grant payment
schedule. Remember that the Plan of Study, and
the Step 1 planning budget, can be important for
what they leave out as well as what they include.
If, for example, there is community interest in
thoroughly pursuing on-site, innovative, or alter-
native wastewater treatment processes, it would
be desirable to spell this out in the Plan of Study.
The Plan of Study should also provide for public
participation procedures to be implemented during
facilities planning. Funds for special investigations
and public participation should be specified in the
planning budget.
• Comments from the appropriate "208 agency" (see
Chapter II). Community leaders should discuss
their application with this agency in advance
to assure full consideration of any special
aspects of the Plan of Study. The 208 plan
is critically important to facilities planning
(see later sections in Chapter V about on service
area, facility sizing, and community options).
® A description of how a consulting engineer will be
selected, and copies of proposed engineering
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contracts. The consulting engineer plays a
critical role in facilities planning; in fact,
selection of the engineer may be the most
important decision made by the community in the
whole planning process. Selection procedures are
therefore of more than passing interest, and
the consulting contract will help to define the
scope and nature of the ultimate Facilities Plan.
The contract should also describe the engineer's
role in assisting public participation in the
planning effort.
It should be noted that the Plan of Study and the costs
of producing it are not eligible for reimbursement as part of
the Step 1 planning effort. The time devoted to it and the
level of detail it contains usually reflects this fact.
Plans of Study are often preceded or accompanied by a con-
ference between applicant, the consultant and representatives of
state and EPA agencies. These preapplicaton conferences review
in detail what is required for an acceptable Facilities Plan so
that all concerned understand the task ahead. Treatment alter-
natives to be explored in the Plan of Study are often discussed
in some detail; controversial issues such as geographic scope
may be reviewed and decided. Potential environmental issues may
be raised, thus underlining the importance of the environmental
assessment that is part of every Facilities Plan.
The Plan of Study is the focus for a series of major
decisions, many of which surface for public review for the
first time: the drawing of planning boundaries; minimum
treatment requirements for the facility in question; selection
and cost of the engineering consultant; preliminary selection of
waste treatment alternatives to be examined during the planning
phase; and the public participation plan for the planning phase.
It is not unusual for a Plan of Study to be prepared by an
engineering consultant who is likely to become the consultant
for the entire Step 1 Plan.
The amount of the initial Step 1 grant award will be
determined on the basis of the budget outlined in the Plan
of Study. If the scope of work changes after the Plan of Study
is completed, a formal "change order" (approved first by the
state agency and then by EPA) must be filed before the
applicant can receive more federal money. Approval of a
change order will depend on how sympathetic the agency reviewer
is to the goals of the change order and how closely budgeted the
state's annual construction grant allocation is. (This is not to
discourage you from submitting change orders when necessary;
but it may be more effective to be sure an item is budgeted
correctly to begin with than to submit a change order.) As
mentioned earlier, 5 percent of the state's allocation must
be set aside for increases to on-going projects.
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What is the Role of the Consulting Engineer?
Many citizen leaders involved in facilities planning
are shocked to discover that signifiant decisions are made
long before the grant award. And many of these critical
decisions are reflected in the selection of the principal
local actors—the key local government representative and
the consulting engineer.
A Step 1 grant may only be awarded to an applicant
with the capability of constructing or managing the facility.
When a waste treatment management agency has been designated
in the Water Quality Management process, a grant may only be
awarded to that designated agency.
It is theoretically possible for the public body that
will "own" the new treatment facility to itself carry out the
task of facilities planning through its sewage agencies. The
record suggests, however, that the facility owners and operators
are reluctant to accept direct responsibility for planning and
construction—even if such agency has the capability to enlarge
its staff to provide the required engineering talent.
In any event, the major day-to-day job of detailed
facilities planning will in all likelihood be performed by a
consulting engineering firm. Federal regulations require,
among other things, that the engineer for any federally-assisted
wastewater facility be selected on the basis of proposals sub-
mitted by at least three firms.
Choosing the engineering firm may well be the most
significant single planning step the community will take,
though it's not often recognized as such. The firm will
likely stay with the project through all three steps of the
process, ending up xvith final responsibility to oversee
construction and initial operation of the facility. The
community should therefore take care to advertise widely its
need for an engineering consultant, review thoroughly and
compare the engineers' proposals it receives, and evaluate
as well as possible the facilities plans prepared by each
firm for other communities.
Does the firm's proposal and track record indicate
inclination and capability to consider a full range of
solutions to the community's wastewater problems, or does the
firm instead seem to specialize in some particular engineering
approach? Does the firm support any specific philosophy
about community development that might cause difficulties on down
the ro^d? Does the firm's demeanor fit the character of the
community? Does the firm appear interested in and sympathetic
to the public participation role the community expects of
the engineer? Are its proposed financial and other contractual
arrangements clear and fully understandable? The answers to
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questions such as these may have a bearing on the ultimate
acceptability and success of the Facilities Plan.
The consulting engineering firm will report to someone
in the community--probably the officially designated
representative of the "applicant" (see Chapter III) or the
staff head of the applicant agency. Except as provided in the
consulting arrangements, the engineer's dealings with the
community will tend to be channeled through this person or
the applicant agency. Few, if any, engineers will "go around"
their official contact point to deal directly with the
community on sensitive planning policy issues. Thus, the
person to whom the engineer reports is obligated to bring
such issues into the open, and has special importance in the
planning process; the community should select that person
carefully.
What is the Role of the Public Participation Outline in the
Plan of Study?
New EPA regulations to implement Section 101(e) of the
Clean Water Act require communities to submit a public
participation outline as part of every grant application.
The workplan is to describe staff and budget resources for
public participation? the proposed schedule of public
partcipation according to decision points in the program;
types of information and consultation mechanisms; and the
segments of the public to be targeted for consultation. At
a minimum, this workplan will establish the initial budget
for public participation in facilities planning, and may,
in fact, outline formal public involvement opportunities that
will be utilized. If you're involved in the facilities
planning process in your area, you will want to pay particular
attention to the public participation element of the Plan
of Study. (Chapter VI details the public participation
regulations governing the Construction Grants Program, and
suggests how to implement them.)
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FOOTNOTES - CHAPTER IV
1. EPA Draft Policy Requirements Memorandum, "Grant
Eligibility of Single Purpose and Multi-purpose
Projects Using Innovative and Alternative Technology,"
January, 1979.
2. 40 CFR, Part 35, Subpart E, Appendix E, "Innovative
and Alternative Technology Guidelines," (43 Fed. Reg.
p. 44098, Sept. 27, 1978).
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CONTENTS
CHAPTER V
FACILITIES PLANNING
Page
What Topics Covered Are in the Facilities Plan? 95
Selection of the recommended alternative 97
What Are the Major Decision Points in the Facilities
Planning Process? 98
What Are the Important Issues for Public Involvement in
Assessing the Current Situation? 98
What Are the Important Issues for Public Involvement in
Assessing the Future Situation? 101
How big should a new facility be?
How is future pollution estimated? 102
How much wastewater will the population generate? .... 103
Where does industry fit into the facility sizing
picture? .- 104
What federal (and state) requirements apply to
industrial users? 104
What about commercial and industrial wastewater flow? . . 105
How is the total wastewater flow estimate calculated? . . 105
Is it better to seek reduced flows or to build "reserve"
(growth) capacity? 106
What about future land use? 107
The sewer issue
What controls will EPA exercise regarding the location
of interceptor sewers?
109
If EPA refuses to fund certain kinds of sewers, can they
still be built?
What geographic areas will the facility serve? 110
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Page.
Small scale service area options .......... ...
112
The regional service area ................
What Range of Alternatives Might be Evaluated During the
Facilities Planning Process? .................
1. The Option of No Facility: Are New Facilities Required? . 114
What water quality and/or related problems have been
identified? ...... . ...... . ......... 114
Can performance of existing facilities be improved? . . . 114
Can industrial users of the system reduce their load? . . 115
Can water conservation programs reduce or eliminate
the need for new capacity? ................
2. "Traditional" Wastewater Treatment Options ........ 116
3. Centralized Physical/Biological/Chemical Treatment and
Land Application of the Effluent ... .......... 117
4. Waste Treatment and Reuse of Purfied Water ........ 122
5. On-site Waste Treatment and Disposal ........... 122
6. Sludge Management . . .................. 123
How is the Final Sewage Management Alternative Selected? . . . 123
What is cost-effectiveness? .............. .125
What are the monetary costs of wastewater management
alternatives? ............... ....... 125
Offsetting revenues ................... 126
How is "present worth" or "equivalent annual value "
calculated? ....................... 126
What interest or discount rate does the federal
government allow? ................. ... 127
Is an inflation factor included in cost-effectiveness
analysis, as allowed by federal guidelines? ....... 128
What service life is allowed by federal guidelines
, for treatment works? ..... .............. 128
What are typical cost factors for each maj'or wastewater
management alternative? ...... ..... . ..... 129
What is a regional treatment facility cheaper
(in monetary costs) than several smaller ones? ...... 131
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Where can package treatment plants be uses?
What requirements do EPA guidelines place on staging
a treatment plant or interceptor? 135
Staging Periods of Treatment Plants 135
How is the community likely to react to the combination
of federal funding and federal regulation? 136
What Are the Nonmonetary Factors in Choosing the Sewage
Treatment Alternative? How Are They Weighed? -139
What primary and secondary environment effects must
be weighed? 140
How are environmental factors analyzed? . • 141
What are the contents of the Environmental Impact
Assessment? 142
How and when does EPA decide to prepare an
Environmental Impact Statement? 142
How will I know if an Environmental Impact Statement
is to be developed for my community's Step 1 grant? . . .144
What are the contents of an Environmental
Impact Statement? 144
What factors influence a system's reliability and
flexibility? 145
What Political/Institutional Factors Influence the Choices
of a Wastewater Treatment Alternative? 146
What Legal Considerations Affect the Choice of a Sewage
Treatment Alternative? 146
How is the Wastewater Management System Financed? 148
How will a community finance its share of construction
costs and 0 & M costs? 148
What are the user charge provisions of federal law? . . .149
What are industrial cost recovery (ICR) provisions? . . . 150
A Case Example - Choosing the Alternative 151
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CHAPTER V
FACILITIES PLANNING
Size of the treatment plant, its sewered area,
the type of treatment technology, and mitigating measures
to soften environmental impacts: These are some of the
facilities planning decisions to be made by a community
once it has received a Step 1 construction grant.
What Topics Covered are in the Facilities Plan?
The content, scope, and degree of detail of a
facilities plan will depend on the facilities being
considered, the initial Plan of Study and the working
budget. The preapplication conference and follow-up
discussions between the applicant, state and EPA offi-
cials, and consulting engineer will determine the exact
content of each plan.
In general, to pave the way for approval of a Step 2
grant application the Facilities Plan should include:
* An introduction, describing why a plan is needed
and outlining its major objectives. Of particular importance
is a review of effluent limitations (see Chapter IV); these
controls, spelled out in NPDES permits, determine the level
of treatment required since they establish the types and
quantities of pollutants that can be discharged from the
wastewater treatment facility.
® _A_ description of the community's current situation,
including water quality problems, environmental conditions,
all wastewater sources, existing wastewater facilities, and
pertinent institutional, demographic, and land-use data.
* An engineer's evaluation of the existing sewer
system (if any) to determine (1) how much of the existing
sewage treatment capacity is consumed by groundwater and
stormwater leakage into sewers ("infiltration and inflow"
or "I/I" analysis), and (2) what might be done to correct
serious problems that have been identified ("Sewer System
Evaluation Survey" or "SSES").
« Planning Criteria, including flow and wasteload
assumptions, effluent limitations, and future needs—to
be used as the basis for facility design. (See following
sections on service areas, facility sizing, and controlling
criteria and standards.)
This chapter was adapted from manuscript by Robert T. Dennis
and Elizabeth Haskell.
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• Engineering alternatives for implementing the plan-
ning criteria and objectives (see "What are the Plan-
ing Options?" below). In most cases, each engineering
alternative will include:
1) A wastewater treatment facility—a "conven-
tional" plant using physical, chemical, and
biological treatment processes, for example,
or a partial treatment facility to prepare
wastewater for application to the land
(see "The Basic Treatment Choices" below).
2) Sewers. Included here might be new or
rehabilitated interceptor (major trunk)
or^collector (neighborhood) sewers. To
be eligible for grant assistance, however,
collector sewers must meet strict criteria
(see "The Sewer Issue" below). Sewer
facility planning might also address the
i problem1of controlling pollution from
storm sewers: Treatment facilities for
combined wastewater and storm sewers may
be grant-eligible, but separate storm
sewer facilities are not.
3) Pump stations needed to move wastewater
through sewers.
4) Sludge and/or effluent management systems.
* Comparison of alternatives in terms of economics,
environmental impacts, and implementation. This comparison
will focus on determining the "best practicable waste treat-
ment technology" (BPWTT) from among such alternatives as
treatment and discharge, treatment and reuse, land applica-
tion, revenue generating facilities, and on—site and non-
conventional systems. (Best practicable waste treatement
technology means the most cost-effective system that pro-
duces effluent of the required quality.)
The comparison must also document what opportunities
the public has to participate in assessing alternatives; it
should describe major points raised and opinions expressed
by the public about the alternatives, and should indicate
the planning response to those points and opinions.
As an interested citizen, you should keep in mind
that the Clean Water Act includes a general requirement
for public participation, and that EPA encourages public
participation in facilities planning throughout the planning
process and urges grantees to use a variety of techniques
to assure that such participation takes place. EPA requires
a public hearing on the Facilities Plan unless EPA has waived
the requirement in advance. In any event, if you believe
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facilities planning is off course and not likely to be
corrected locally, voice your concerns to EPA.
Comments of relevant state, interstate, regional
and local agencies . These will range from the state health
department to regional planning bodies.
Selection of the recommended alternative.
An environmental assessment of the recommended
alternative. This critical element of the Facilities Plan
is discussed more fully later in this chapter.
Statement on land treatment alternatives and
innovative technology. Clean Water Act amendments approved
by Congress in 1977 require that EPA withhold grants for
construction unless the applicant has demonstrated that
"innovative and alternative wastewater treatment processes
and techniques which 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 ... have
been fully studied and evaluated . . .." EPA regulations
require that all facilities planning begun after September
30, 1978 (whether or not prepared under a Step 1 grant),
evaluate these opportunities.
A municipal p retire a tment program, where appropriate,
to pretreat industrial discharges before they enter a
municipal facility.
Statement on total energy requirements and energy
conservation or recovery possibilities.
Statement on outdoor recreation and open space
potential of the facility. Another 1977 amendment requires
analysis of recreation and open space opportunities before
a construction grant is approved.
i
Preliminary engineering design and cost estimates
for the recommended alternative, including an estimate of
costs that must be borne by the community and an indication
of what these costs will mean to the individual user of the
community wastewater system.
Implementation arrangements. The Facilities Plan
must describe how the selected alternative will actually
be constructed. Performance and cost schedules are to be
outlined and local government and applicant responsibilities
defined. The key item here is an approved plan for providing
the nonfederal funds required for facility construction.
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What Are the Major Decision Points in the Facilities
Planning Process?
The fundamental decisions of facilities planning
are made in the context of formal "steps" or decision
points. Federal and state officials, local government
grantees and consulting engineers generally refer to the
following seven decision points when describing the facil-
ities planning process:
• the Plan of Study/grant application
• assessment of the current situation
m • 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 just seven linear steps: The 201 public participa-
tion planning guide found in Chapter VI breaks these steps
down into 26 decision points, each one involving the resolu-
tion of a series of issues. And, of course, the public
participation process and the environmental impact assess-
ment process (described later in,this chapter) are woven
into all of the elements of Step 1 planning. On their
surface, the facilities planning steps appear logical and
linear; in fact, they bear a circular relationship to one
another. Information gathered and decisions made must be
constantly reevaluated as new information becomes available.
Table 3—a much simplified and shortened description
of the major decisions you'll want to be involved in during the
Step I process--is the framework for the discussions that follow.
What Are the Important Issues for Public involvement in
Assessing the Current Situation?
This first decision point is not just a straightforward
data-gathering exercise: It is in fact a critical step
for public involvement. Information not gathered, or
misinterpreted may substantially 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 en-
gineering evaluation of the sewer system to find out how
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TABLE 3
MAJOR FACILITIES PLANNING DECISIONS
DECISION POINT
Assess the Current Situation
Assess the Future Situation
Identify Alternatives
a)
b)
ISSUES
gather information on plan-
ning area:
institutions
population
environment
water quality
other environmental.
conditions
gather data on:
existing wastewater flows
existing treatment systems
infiltration/inflow analysis
performance of existing systems
QUESTIONS
What are our water quality
problems?
Are the existing facilities
adequate?
What unique resources does
our community have that
are worth protecting?
a) land use
b) demographic and economic
projections
c) future flow and wasteloads
d) future environment without
treatment project
a) biological or physical/
chemical treatment and
discharge to receiving
water
b) reuse/recycling systems
c) land application systems
d) revenue generating appli-
cations
e) on-site and nonconventional
systems
f) sludge and residual disposal
alternatives
How much growth is projected to
occur?
Are projections consistent with
community goals/land-use plans? cr>
Are wastewater flow projections
accurate?
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
considered?
Are there opportunities to recycle
or reuse treated wastewater?
How much treatment capacity is
required?
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DECISION POINT
Cost Effectiveness Analysis
Environmental Impact
Statement (EIS)
Select Alternative
TABLE 3 cont'd.
ISSUES
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
program
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
QUESTIONS
What sewage treatment alternative
has the least monetary cost
without overriding environ-
mental and social considerations?
Are the environmental impacts
identified in the environ-
mental assessment significant
enough to warrant a full scale
EIS?
o
o
H
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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 rehabili-
tation of pipes and drains can cost-effectively replace
the need for extra treatment plant capacity.
_ infiltration/inflow analysis results have both
economic anc[ environmental consequences. The economic
issue: Is it cheaper (more cost-effective) to provide
more treatment capacity to compensate for excessive in-
filtration/inflow, or to repair the sewer system?
The environmental consequences are more complex.
Excessive infiltration/inflow usually happens during
rainy periods. Excess plant capacity intended to accom-
modate peak foul weather periods can become instead an
excuse for more sewer hook-ups, thus, an incentive to
further community growth. More hook-ups mean less
excess capacity, and can lead to plant overflows during
rainy weather. The environmental issue: How do you
control sewer hook-ups to keep this from happening?
During the "current situation" assessment you will
also want to know the accuracy of data gathering. Have
current water quality problems been sufficiently and
accurately identified? For example, are the sources of
current wastewater flows known? What portion of the
community's water quality problem comes from nonpoint
sources or industry? What is the current per capita
daily wastewater flow? How well are the existing
treatment facilities operated? Has existing population
and land use data been properly assessed? Have all
environmentally sensitive areas been identified?.
The answers to these and other questions will
affect eventual decisions on how much treatment capacity
is needed and whether industrial pretreatment programs
are required. Environmental data-gathering also will
define the outside parameters of the environmental
impact assessment/statement process.
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.
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The facility should be large enough to last 20 years
from its day of operation (Construction in stages at less
than 20-year increments will be considered during the
cost-effective analysis.)
There are three variables governing facility size
that the community can influence: population projections,
per capita wastewater flow calculations, and amount and
type of industrial discharge into municipal facilities.
How isfuture^population estimated?
Over the years, communities throughout the United
States have turned bullish population forecasts into self-
fulfilling prophesies by providing the sewage treatment and
other infrastructure necessary to sustain growth; many
Americans now question the quality of what has resulted.
Other communities are paying for facilities designed to
serve "phantom populations" that haven't yet materialized.
Thus there is new interest in rational population forecasting.
To avoid paying for more waste treatment capacity
than is actually needed nationwide, EPA requires that fore-
casts of population for each facilities planning area be con-
sistent with national and state projections. The state
water quality agency usually prepares local population
projections for inclusion in individual Facilities Plans.
These forecasts are to be submitted as part of the State
Water Quality Management Plan.
The U.S. Department of Commerce's Bureau of Economic
Analysis (BEA) has developed 1977 population projections for
each state which generally are to be used as the basis for
state and local forecasts. The state's own projections, if
prepared before June 26, 1978, may be used so long as the
forcast for the state for the year 2000 does not exceed
the BEA projection by more than 5 percent. If it does, the
state must either lower its projections or justify its higher
figure. The EPA Regional Administrator must request public
comment and may call a public hearing before granting a variance,
The state water quality agency, working with designated
208 planning agencies and other regional agencies, will break
down the state population projection into area forecasts. The
sum total of all the smaller area projections is not to exceed
the statewide forecast. If a 208 planning agency has already
developed a forecast for its area, it may be used so long as
its estimated population for the year 2000 does not exceed
the BEA breakdown by more than 10 percent.
For nonmetropolitan regions (not located in 208
areas), the state may set population projections? or, the
grantee can forecast its own population based on simple
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linear extrapolation of growth trends from 1960 to the
present, on telephone company or other business projections,
or on other documented estimates. The state will review
these grantee-developed forecasts for consistency with
overall projections.
The state must submit its breakdowns of state
population projections to the EPA Regional Administrator
for approval by October 1, 1979. Before submitting them,
however, the state must hold a public meeting. Once
approved, the totals must be used for areawide water
quality management planning as well as facilities planning
and needs surveys. All Facilities Plans prepared under
Step 1 grants awarded 6 months after EPA approval of state
forecasts must adopt the appropriate state-approved fore-
cast .
A community's population 20 years hence will equal
its present population, plus births and in-migration over
those years, minus deaths and out-migration.
Projections are essentially "short cut" techniques
for making assumptions about the unknown parts of that
equation.
For example, the U.S. Census Bureau keeps at least
eight "series" of population projections, all using different
assumptions about the national fertility rate (children per
woman) (but none recognizing illegal immigration to the United
States). BEA population projections are based on the Census
Bureau's Series E projection, which assumes a fertility rate
of 2.11. The national rate has actually been running at about
1.8 in recent years, but many demographers believe it is about
to rise.
A community might have valid reasons to assume
fertility rate different from Series E; or it might believe
it was attracting large numbers of illegal aliens and wish to
incorporate that fact in its projections. Once the state has
completed its initial forecasts, it will obviously be diffi-
cult to change them. But if you want to lower (or raise) the
population projection for your facilities planning area, re-
member that water quality management planning is a continuous
process. Part of the process should be a formal set of
procedures to amend decisions made previously.
How much wastewater will the population generate?
Basically, future need for sewage treatment capacity
is determined by multiplying total population times waste-
water volume per capita. (Ehere are, however, other variables
involved.) Recent studies suggest that sewage flows often
fall into the range of 50-80 gallons per capita per day (gpcd).
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Many facilities in the past have been designed to accom-
modate flows at inflated rates of 100-125 gpcd— the
difference being costly excess capacity in the waste-
water system.
New EPA cost-effectiveness guidelines impose stronger
controls on how wastewater flows may be estimated.
Where does industry fit into the facility
sizing picture?
Most communities include industries, many of which do
or potentially could discharge industrial wastes into the
municipal sewer system. These wastes, depending on their com-
position, can make biological sewage treatment processes less
effective, impair operation of physical/chemical systems, and
introduce substances that can cause problems in sewers (fire,
corrosion, explosion), sludges, and land treatment systems.
Treatment of these wastes almost invariably will require
modification of treatment processes. However, joint treatment
of community and industrial wastes may also produce benefits:
economies of scale, reduced costs to domestic users and oper-
ational improvements. (Nutrients in domestic sewage may aid
the biological treatment of industrial wastes, for example.)
Each community will have to decide what seems best in
its case; it will particularly have to consider the impact new
industry will have on existing treatment facilities and pro-
cesses. Note, for example, that a single small new industrial
user might introduce a compound into the treatment system that
makes land application of sludge inadvisable—leaving the com-
munity with a brand new headache over what to do with the stuff,
What federal (and state) requirements
apply to industrial users?
Since industrial wastes may "upset" or damage waste-
water treatment plants, EPA has issued general standards for
pretreatment of these wastes if they are introduced into
publicly-owned treatment works. State or local government
may adopt more stringent controls; but in any case, EPA will
apply national "best available technology" treatment standards
to a range of hazardous and toxic substances.
EPA will require each agency operating a federally-
assisted facility (or its "parent" local government) to
adopt and enforce a municipal ordinance governing industrial
use of its plant. Under EPA guidance, it must establish
limitations for specific pollutants contained in industrial
discharges. Furthermore, as a condition to federal grants,
the locality must adopt a program to manage its ordinance
that includes regular monitoring and enforcement of national
standards.
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What about commercial and industrial wastewater flow?
In addition to industrial plants, wastewater loads
must be estimated for all existing and planned business
establishments, churches, schools, and similar facilities.
Controlling factors here will be the community's policies
and plans governing new commercial and industrial growth,
and actions taken to reduce industrial waste flows.
Industrial flows, according to EPA regulations, must
be calculated by adding together flows from industries that
now use existing treatment works, after considering ways to
reduce such flows. Letters of intent are required to docu-
ment anticipated future industrial users, as specified in
EPA's industrial cost recovery guidelines. Unforeseen in-
dustrial growth is allowed to a maximum of 5 percent of
total design flow—10 percent for towns with populations
less than 10,000—or 25 percent of the total industrial
flow, whichever is greater.
How is the total wastewater flow estimate calculated?
For the design of treatment works, total average
annual flows are projected based on expected future popu-
lation, per capita use, impacts of water conservation,
current industrial activity and the allowance for unanti-
cipated industrial growth. It is also necessary to cal-
culate the Average Daily Base Flow (ADBF)—the flow ex-
pected daily from residences, nonresidential sources,
commercial sources, institutional sources, industries
to be served by the works (plus allowances for future
industries), and reasonable infiltration/inflows.
EPA guidelines specify two methods for projecting
the ADBF from combined residential, commercial and insti-
tutional sources. The preferred method is to rely on water
use records, multiplying per-capita flows for the existing
sewered population times the projected populations. Seasonal
visitors to a community, for example, for employment or recre-
ational purposes are converted to full time resident equiva-
lents by using the following multipliers:
day-use (short term) visitor (0.1 - 0.2)
seasonal visitor (0.5 - 0.8)
No allowance is permitted for future increases in per-capita
flow. It is assumed that flow reduction measures will be
introduced.
If no water supply and wastewater flow data are
available, the ADBF can be estimated by a second method,
multiplying a gallon per-capita-per-day (gpcd) allowance
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(not exceeding those in the following table) by the esti-
mated total populations to be served. The tabulated gpcd
allowances, based on several studies of'municipal water
use, include estimates for commercial, institutional and
residential sources.
GPCD
• Non-SMSA* cities and towns
with projected total 10-year
populations of 5,000 or less 60-70
• Other cities and towns 65-80
The EPA Regional Administrator may approve exceptions
to these allowances where more than 25 percent of the flow
comes from commercial and industrial sources.
Is it better to seek reduced flows or
to build "reserve" (growth) capacity?
EPA will require the community to make a cost-
effectiveness study to find out which is cheaper: under-
taking water conservation measures or building extra capa-
city into the wastewater treatment facilities.
In this cost-effectiveness analysis, every facility
plan is required to study, at a minimum:
1) Flow reduction from existing residential,
commercial and institutional sources, based
on retrofit of water meters, toilet dams and
low-flow showerheads. Such reductions must be
subtracted from the ADBF (unless the ADBF from
the area is less than 70 gpcd, the current popu-
lation of the applicant is under 10,000,000 or
the area is exempted by the EPA Regional
Administrator because it already has an effec-
tive existing flow reduction program).
2) Flow reduction 10 to 20 years hence achieved
through changes in local ordinances, building
codes or plumbing codes to require water con-
servation devices and practices, and from public
information programs.
The costs, cost-savings and effects of public education
measures, pricing policies and regulatory approaches to
water conservation are to be calculated for the 20-year
planning period.
Standard Metropolitan Statistical Area.
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The net cost of proposed flow reduction programs are
to be compared with the net financial and energy savings. The
Facilities Plan must include a description of how and when
these programs will take effect, as well as assignments of
responsibility for management and enforcement to governmental
jurisdictions.
It should be noted that while EPA is fairly conservative
in its interpretation of an acceptable ADBF, it does not require
a strong flow reduction program to ensure that per capita
consumption assumptions are never exceeded; it only requires
that a public information program be developed to emphasize the
benefits of flow reduction. Nor does EPA provide funds to
institute a water conservation program. The adoption adoption
of many other flow reduction measures (even cost-effective ones
will occur only if they have public support and the sewer grantee
has the authority to implement them (or the cooperation of another
governmental entity that has authority). When the grantee is an
independent sewer authority without other community management
responsibilities, this implementation link may be difficult to
make.
Cost-effective flow reduction programs will save the
community both money and resources: Reduced per capita water
consumption means reduced need for treatment capacity, which
in turns means lower capital and operational costs.
But active public involvement at the local level will be
needed to drum up public and political support for the program
that brings those savings.
What about future land uses?
Your community's assessment of its future land uses
will partly determine capacity, location and service areas
of the recommended treatment plant. Local and regional
land use and development plans provide a framework for
facilities planning, as does the 208 planning process (des-
cribed in Chapter II) . Facilities Plans also must conform
to the Water Quality Management Plans developed under Section
208. As discussed in Chapter I, after October 1, 1979,
certain critical decisions generally must have been made
through approved Water Quality Management Plans.
Yet the water quality management process is not
static. Water Quality Management Plans must be reevaluated
each year through a formal continuing planning process.
Citizens should have ample opportunity to obtain amendment
of a WQM plan where desirable.
As a concerned citizen, you will want to use the
facilities planning process as a chance to review land-use
planning decisions, some made as long as 20 years ago,
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that fail to consider environmental issues. Too often the
208 planning process has simply ratified rather than re-
evaluated existing land use plans. Before allowing those
land-use decisions to be literally set in concrete, you
should carefully review the assumptions concerning future
land uses that become part of the Step I process.
The sewer issue
Chapters II and VII deal with the impacts of sewer
construction. In brief, new sewers may stimulate new
development and generate new wastewater loads.
As was discussed in Chapter II, there are basically
three types of sewers associated with transporting sewage to
a central treatment facility: interceptor sewers; collector
sewers; and lateral sewers. Interceptor sewers are the essen-
tial large collector of sewage that gather waste from a number
of neighborhoods and communities. The location and capacity of
an interceptor sewer will frequently determine where new neigh-
borhoods will be built. The EPA Construction Grants Program
will help to pay for sewers that are a part of an approved,
cost-effective treatment system.
Collector sewers are those that collect sewage from
within a neighborhood itself. Collector sewers to new continu-
ities generally are not fundable under the Construction Grants
Program. You should be aware, however, that collector sewers
may be fundable through other federal programs. Lateral sewers,
the hook-ups from homes to the collector sewer, are not eligible
for construction grant funding under any circumstances.
Even when sewers are not a cause of growth in a
community, they certainly influence the location of growth.
Equally important, when the size and quality of sewers are
out of sync with the capacity of the treatment system, in-
adequate controls on hook-ups to the sewers may lead to
overloaded treatment works.
The costs of a sewer system arise mostly from acquiring
rights-of-way, laying pipes, and building pumping stations. It
costs little more to install a large diameter sewer than a small
one; there is thus strong temptation to build reserve or growth
capacity into the system.
In 1972 and 1977 amendments to the Clean Water Act,
Congress decided that construction grant money could be used
to pay part of the cost of local growth. The sizing issues
discussed earlier determine the cost-effective reserve capacity
of a federally funded waste treatment facility.
As mentioned above, interceptor sewers may be funded by
EPA, and under certain limited conditions, so may collector
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sewers. EPA has the authority, however, to strictly regulate
the use of such grant funds.
Collection systems will only be funded, according to EPA
regulations, when they are used to replace or rehabilitate an
existing system or are needed for a new system in a community
that existed before October 18, 1972 and has sufficient treat-
ment capacity. The collection system also must conform with
208 plans, environmental laws and executive orders, and may
not provide capacity for new homes or environmentally sensitive
lands such as wetlands, floodplains or prime agricultural lands.
"Appropriate and effective grant conditions, (e.g. restricting
sewer hook-up) should be used where necessary to protect these
resources from new development." [40 CFR 35.925-15]
Neither interceptor nor collector sewers may be
constructed with federal funds if they are destined to
serve primarily industrial users.
What controls will EPA exercise regarding
the location of interceptor sewers?
Recognizing that hook-ups to oversized interceptor sewers
that connect large tracts of vacant land to regional treatment
facilities are a major cause of unplanned growth, EPA regulations
require that interceptor sewer routes be planned and staged care-
fully. Unless the sewers are demonstrably necessary to alleviate
existing problems, the cost-effectiveness guidelines state, they
"should not be extended into environmentally sensitive areas,
prime agricultural lands and other undeveloped areas (density
less than one household per acre)." Whenever it is decided that
an interceptor through such areas is the most cost-effective
alternative to connect several communities, EPA requires the
grantee to reassess carefully the need and reevaluate and miti-
gate the interceptor's primary and secondary environmental im-
pacts. As with collector sewers "appropriate and effective grant
conditions (e.g. restricting sewer hook-ups) should be used where
necessary to protect environmentally sensitive areas or prime
agricultural lands from new development." [40 CFR 35 Appendix
A, 8]. Mitigating measures to protect environmentally sensitive
areas and prime agricultural land from new development are to be
included in the NPDES permit so that they can be easily implemented,
In the past most interceptor sewers were planned for a 50-
year-plus service period. New EPA regulations call for federal
financial assistance for a 20-year period unless the grantee
demonstrates that a planning period not exceeding 40 years is
consistent with approved water quality and other land use plans
and will reduce overall environmental impacts.
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If EPA refuses to fund certain kinds of sewers,
can they still be built?
EPA regulations cover that part of a treatment system
that will be built with construction grant funds. A community
may decide, however, to build certain sewers and additional
treatment capapcity with its own money. In this situation EPA
will still pay for the part of treatment works which it deter-
mines represents the most cost-effective sollution to the water
quality problem. Any additional costs must be covered by the
community. (see "What costs are eligible for federal financial
assistance through the Construction Grants Program?")
There are other federal grant and loan programs that
may pick up some of the cost of a collection system not other-
wise fundable through EPA. The Farmers Home Administration,
HUD's Community Development Funds and the Economic Development
Administration of the Department of Commerce all have water
and sewer grant and/or loan programs. Adminstered under
different criteria, these programs may provide financial
assistance where EPA cannot.
What geographic areas will the facility serve?
Final decisions concerning the service area of a sewage
treatment facility (or facilities) are effected enormously by
the cost-effectiveness analyses conducted on the alternatives
selected for in-depth study. Each alternative may not only
involve different technologies, but also different service
areas, or a number of different service areas.
This basic question of geographic area must be answered
by the community itself, with advice from the engineer and the
water quality specialist. The answer is often arrived at with
difficulty—engineers might prefer a topographic service area
where wastewater can flow by gravity to a central point; water
quality planners have preferred the management control of large
regional plants, at least in recent years; and the Federal Water
Pollution Control Act also has been biased toward regional solu-
tions. Local politicians and government officials generally recog-
nize land within their political jurisdiction as the service area.
Selecting the service area is by and large a political process.
A decade ago, the small neighborhood sewage treatment
plant was generally regarded as a root cause of the American
water pollution problem—poorly designed, cheaply constructed,
improperly maintained, run by the mayor's brother-in-law and a
couple of high school dropouts. So there was a strong trend away
from small systems into larger centralized facilities served by
major trunk sewers; these could be professionally staffed and
economically operated. Of course, centralized facilities
dumped a lot of effluent at one particular point—a problem
sometimes overcome by applying space-age technology and large
110
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quantities of energy (advanced waste treatment). Then planners
discovered that those extensive trunk sewer systems generated
rapid suburban sprawl, sometimes in areas where no one really
wanted it—and inflation, scarcity of materials and the energy
crisis combined to render advanced waste treatment expensive.
All of which suggests that there is no one best answer to the
service area question.
In simplest terms, the service are question is this:
Do you 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 do you 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 community.
Small-scale service area options
The smallest scale wastewater facility service area is
the individual septic system, compost toilet or similar innova-
tive system. In 1977 the Clean Water Act recognized these indi-
vidual systems as a valid option under the Construction Grants
Program. But it is a limited option, and is clearly explained
in the legislative language: "A grant may be made ... to con-
struct a privately-owned treatment works serving one or more
principal residences or small commercial establishments con-
structed prior to, and inhabited on (December 27, 1977) when
(EPA) finds that 1) a public body . . . eligible for a grant
. . . has applied on behalf of a number of such units and
certified that public ownership of such works is not feasible;
2) such public body has entered into an agreement with (EPA)
which guarantees that such treatment works will be properly
operated and maintained and . . . includes a system of charges
to assure that each recipient of waste treatment services under
such a grant will pay its proportionate share of the cost of
operation and maintenance (including replacement) and; 3) the
total cost and environmental impact of providing waste treat-
ment services to such residences or commercial establishments
will be less than the cost of providing a system of collection
and central treatment of such wastes."
Since cost-effectiveness is a controlling federal cri-
terion for service area and treatment mode decisionmaking, a
community might well be forced to select centralized treatment
even if it would prefer individual systems. (Of course, the com-
munity could always choose to forego federal grant funds, or to
add additional local money to the 75 percent federal share of
what would have been the most cost-effective solution, and re-
quire the private construction of individual systems of quality
sufficient to meet federal and state standards—but the political
and economic implications of that route loom large indeed.)
111
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If individual systems aren't a viable option, then
attention must shift to some sort of centralized 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" facil-
ities in each neighborhood, not interconnected by develop-
ment-stimulating trunk sewers. '
"Package plants"—essentially delivered by the manu-
facturer in ready-to-plug-in-and-operate condition—can
deliver high quality treatment. 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 low-technology
central treatment facilities, such as stabilization ponds
or land application systems, which serve small areas and
restrict growth. The 1977 amendments to the Clean Water
Act set 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 munici-
palities." 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 treat-
ment, fewer effluent discharge points 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 bene-
fits. 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 facili-
ties plan. Second, a project designed to solve water quality prob-
lems of regional scope will probably draw a higher priority
rating from the state than smaller projects. Third, depending
on what service area alternatives are studied, a regional plan
may be most likely to meet federal cost-effectiveness criteria.
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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 le'vels 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 interjuris-
dictional agreements and flow allocations that can be difficult
to negotiate and achieve. Perhaps such problems can be most read-
ily addressed by determining what entity is going to be responsi-
ble for constructing and operating the regional facilities—and,
of course, controlling them. Will the facilities, for example,
be provided by a central city? And if so, to what extent will
that mean that the central city can control land use and indus-
trial development decisions in suburban jurisdictions being
served by the facilities?
Or should all the jurisdictions being served get
together and create a new institutional entity to construct
and operate the facilities? If so, what powers will the new
entity have—how will it respond to the individual wishes of
each jurisdiction? Such questions are not always answered
easily, particularly when the jurisdictions to be served
have conflicting philosophies about growth and public
finance.
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 on
facility service area and facility sizing. As the number of
variables is reduced, the selection of treatment process may
become more and more an engineering and economic decision.
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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 distri-
bution, land values, geology, climate, and similar factors.
With no attempt to discuss the full range (or combinations)
of options, some of the most basic alternatives are described
below:
1. The Option of No Facility; Are New Facilities Required?
The first step in facilities planning is to determine
whether new wastewater treatment facilities are in fact
required—or if existing facilities can somehow be made to
make do. Some communities will not need new faciltiies;
identified problems might be corrected by repairs or im-
provements in the existing system or by modifying the
treatment process now in use. Whether new facilities
are needed will be decided, by-and-large, by addressing
four subsidiary questions:
What water quality and/or related problems have been
identified?
The water quality problem could have been discovered
by a laboratory analysis of community lakes, streams, or
groundwater—with such findings as high concentrations of
fecal coliform bacteria, a toxic substance or other industrial
waste, nutrient enrichment, or a deficiency in dissolved oxygen,
Or maybe the effluent discharged from an existing facility
does not meet EPA's national minimum standards for secondary
treatment in terms of biochemical oxygen demand, suspended
solids, and pH, or some other standard incorporated in its
NPDES permit.
Air pollution from a sludge incinerator may be a
problem, or change in sludge chemistry attributable to the
new industrial plant that just moved into the community.
Perhaps the local government wants to free itself from a
court-ordered moratorium on new sewer hook-ups because the
existing sewage treatment plant is operating at capacity
(and not yet causing any water quality problems).
Can performance of existing facilities be improved?
Perhaps the existing sewage treatment plant can meet
federal and state requirements by spending more money on
operation and maintenance, thereby improving overall perfor-
mance and reducing interruption of service. Maybe existing
personnel are poorly trained or too few in number. Perhaps
adding new chemicals to the existing process will make it
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more efficient. Or, if the community's problem is attri-
butable to faulty private septic systems, perhaps a munici-
pal ordinance setting maintenance requirements will do the
trick.
Where sewers already exist, EPA requires a special
sewer system evaluation ("infiltration and inflow" analysis)
as part of each Facilities Plan. If sewer joints are faulty,
pipes cracked, or manholes improperly constructed, ground-
water and rainwater can get into the sewer system in such
volume as to overload the sewage treatment plant and/or
render treatment ineffective. Should this be the case,
rehabilitation of the sewer system may solve—or help
to solve—the water quality problem.
Flow equalization is not a treatment process per se,
but a structural technique to improve the effectiveness of
secondary and tertiary treatment plants and reduce the cost
and size of any new plants. Large holding basins are built
to catch wastewater flows and deliver them to the treatment
plant in a steady flow, thereby improving the performance of
the plant. Without such controls the flows and strength of
the wastewater vary during the day, beginning to increase
substantially about 10 a.m. and then decreasing again
rapidly about 10 p.m.
Can industrial users of the system
reduce their load?
Over the last decade, industrial pollution of America's
waters has been reduced substantially in many cases by a change
in industrial processes—different chemicals used, materials
and by-product recovery, water conservation, closed systems,
and other techniques. Industries discharging effluent through
publicly owned treatment facilities may be able to assist in
solving a community's water quality problem by incorporating a
process change to alter the nature and volume of their effluent.
The Clean Water Act offers financial incentives—through reduc-
tions in "Industrial Cost Recovery Payments"—to industries that
conserve water and reduce total sewage flows.
Industrial wastewater may also be "pretreated" (at the
industry's expense) before delivery to the community.
Can water conservation programs reduce
or eliminate the need for new capacity?
Water conservation can reduce the amount of water used
and then discharged into the treatment system. Public education,
pricing policies and regulation, all of which must be considered
in the cost-effectiveness analysis of any new construction, may
in some cases obviate the need for such new construction. Water
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conservation is discussed in more detail earlier in this chapter,
2. "Traditional" Wastewater Treatment Options
This term, not generally used by water quality
specialists, refers to a system that:
• delivers wastewater to a central wastewater
treatment facility (which may be simply a
stabilization pond system);
• subjects the wastewater to a series of physical,
biological and chemical processes (which in the
case of advanced waste treatment may produce
a very high degree of pollutant removal); and
then;
• discharges effluent to a stream, river, or other
body of receiving water.
Depending upon the technology used and money spent, such
treatment may deliver effluent of extremely high quality —even
up to drinking water standards. It removes heavy metals and
other toxic chemicals from wastewater (leaving them in sludge)
and rapidly returns water to the surface hydrologic system,
making it available for downstream use. And since it can be
carried out on relatively small sites—from a few acres (rarely)
to a couple of hundred at most—traditional treatment can be
fitted into virtually any community.
Traditional treatment commonly relies heavily on
technological approaches and can therefore be quite expen-
sive, particularly when high levels of pollutant removal
are required. It may "waste" effluent, particularly when
well-treated effluent is discharged into waters polluted
by other sources. It can create serious problems of sludge
management (see below) and may be inefficient in putting
nutrients and other valuable treatment "by-products" to
beneficial use.
If a pollution problem has resulted from inadequate
treatment by a facility, in most cases modifications can be
made to provide higher levels of treatment, such as adding
secondary treatment to a primary system or adding phosphorus
or nitrogen removal to a conventional secondary plant.
If a community has no centralized collection and
treatment system, or if upgrading its existing treatment
facility will not achieve the desired pollution reduction
or has other major nonmonetary costs, another alternative
is to build a new centralized treatment facility.
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In evaluating whether and how to expand and upgrade
an existing facility or build a new one, communities should
take into account the future possibility of adding waste-
water reclamation facilities and modular increments for
water reuse.
If a central treatment and disposal alternative is
selected, communities will have to choose the size of the
treatment plant, ranging from a small "package plant" to
a large regional facility; the service area; staged develop-
ment of the system, and the treatment technology.
Traditional, centralized treatment systems are of
three general types: primary, secondary and advanced waste-
water treatment. Primar y treatment removes those pollutants
that either settle or float—usually about 60 percent of the
raw sewage and suspended solids and 35 percent of the bio-
logical oxygen demand (BOD) (see Glossary). Soluble pollu-
tants are not removed. Federal law requires municipalities
to provide at least secondary treatment unless a waiver has
been granted for a deep water ocean discharge.
Secondary treatment removes more than 85 percent of
the BOD and suspended solids by stimulating the natural
decomposition of the waste matter, but it does not remove
significant amounts of nitrogen, phosphorus, chemical oxygen
demand (COD), or heavy metals, nor all pathogenic bacteria
and viruses.
Thus, advanced waste treatment (AWT) may be needed—
chemical treatment, filtration and disinfection.
Tables 4 and 5 summarize the available secondary and
advanced waste treatment alternatives. Table 6 relates
the available alternatives to requirements for pollutant
removal. For further information on the various centralized
treatment processes, see EPA's "Alternative Waste Management
Techniques for Best Practicable Waste Treatment," October,
1975 (MCD-13) .
3. Centralized Physical/Biological Chemical Treatment and
Land Application of the Effluent
In this alternative, wastewater is processed as in
traditional treatment, to a primary or secondary level, but
the effluent is applied to the land, not discharged to a
waterway. Federal law requires consideration of land
application as a sewage treatment alternative. This method
may provide an alternative to secondary treatment or to
constructing an advanced wastewater treatment system.
(In some cases, state public health laws require secondary
treatment before land application. The necessity for this
prior level of treatment is a subject of much controversy.)
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TABLE 4: SECONDARY TREATMENT
Adapted from EPA Technology Transfer, Enviroranetal Pollution Control Alternatives: Municipal Wastewater
Treatment
Process
Trickling Filter
rock rredia
synthetic
Activated Sludge
Advantages
Basic simplicity,
Handles wide range of
sewage flows.
Relatively easy to
operate and
maintain ,
Low energy require-
ments (150 kwh/mg)
Versatility - handles
wide variety of
wastewater
compositions.
Disadvantages
Affected markedly by
tenps ,
Less efficient in
removing BOD and SS
Requires careful
operation,
High energy require-
ments (625 kwh/mg!
Space Costs*
Requirements per gal
1 acre/MGD 40-50<:/1000
gals (1 MGD)
15-20C/1000
gals (10 MGD)
0.5 acres/MGD 45-55«/1000
gals (1 MGD)
20-25C/1000
gals (10 MGD)
per family**
$4.20-5.2S/mo
$1.60-2.10/mo
$4.75-5.80/mo
$2.10-2.60/mo
Effluent
Quality
Removes
up to
85% of
the BOD
and 80%
of the
suspended
solids
High efficiency in
BOD removal,
Lower capital costs
than TF.
Lower space require-
ments
Oxidation Ponds
Easy to construct,
operate and maintain,
Inexpensive to
construct and
maintain.
Effective in removing
pathogens
Large space require-
ments ,
Requires periodic
removal of algae
(can be expensive)
35 acres/MGD $2000/acre (larger than 25 acres)
85 acres/MGD S6000-8000 (less than 5 acres)
(excludes land costs)
CH-M costs = 25% of TF or AS
process
Costs of algae removal can range
as high as 10% per 1000 gals
Biodisc
No sludge or effluent
recycle streams.
Low maintenance,
Relatively high
degree of treatment.
Requires fewer process
decisions by
operator
Must be covered from
elements,
Little long term
operating experience
in U.S.,
Moderate energy
requirements
(400 kwb/mcr)
0.5 acres/MGD
Somewhat lower than activated-
sludge
Activated
Biofilters
Combination of fixed
microbial growth
and high concentra-
tion of suspended
growths provides
stable operation
ajid minimizes
process upset,
Can be added to
existing activated
sludge plant.
Requires less area
than TF plant,
Less sensitive to
cold temp effects
Supplemental aeration
process often needed
to meet secondary
standards,
Little operating
experience in U.S.,
Relatively high energy
requirements
(500 kwh/mg!
0.5 acres/MGD
* Average annual costs based on 1375 prices (capital and operating costs amortized over 20 years at 7% interest rate).
** Based on estinate of 350 gals/day for the average residence.
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TABLE 5: ADVANCED TREATMENT
Adapted from EPA Technology Transfer, Environmental Pollution Control Alternatives: Municipal Wastewater
Treatment
Process
.Phosphorus
- coagulation
- sedimentation
- land treatment
Filtration
COD Removal
- carbon
absorption
- land treatment
Advantages
Well proven, reliable
removal of BOD and
S3, simple process
control,
Substantial removals
of heavy metals ,
bacteria, viruses
Provides means for
controlling
suspended solids
content of secondary
effluent.
Well proven, readily
automated, requires
little operator
attention , and
little space
Removes organic
materials that
cannot' be removed
by biological
Space
Disadvantages Reouirenents
General larger quanti-
ties of chemical
sludge ,
May result in addition
of dissolved solids
to wastewater
Generates a backwash
waste stream which
must recycled to
plant
Expensive unless 300-500
carbon is regen- sq ft/MGD
crated and recycled.
Regeneration equipment
Costs (1975 Dollars)
per gal per family
'
154/1000 gals Si.60/mo
(1 MGD)
6.54/1000 gals $0,70/mo
(10 MGD)
354/1000 gals S3.70/mo
(1 MGD)
114/1000 gals S1.15/mo
(10 MGD)
Effluent
Quality
Removes
up to
95% BOD
and
99% SS
COD Removal
- carbon
absorption
- land treatment
Nitrogen Control
- biological
nitrification
- ammonia
stripping
- ion exchange
- breakpoint
chlorination
Land Treatment
(may also
be utilized
as secondary
treatment)
Removes organic
materials that
cannot' bs removed
by biological
secondary treatment ,
Can tolerate wide
variations in flow
or wastewater
quality, requires
little operator
attention; requires
little space
Generates no signifi-
cant added sludge ,
No objectionable
side effects
Lowest cost method.
simplest to operate.
reliable, small
space needs
High efficiency.
readily controlled,
Not affected by temps.
nitrogen can be
recovered for
fertilizer
High efficiency, low
space requirement.
low capital costs.
disinfectant
capacity, minimizes
disposal problems
Provides advanced
degree of treatment
without generating
any cheaical sludges,
Recycles water and
nutrients for pro-
pr3ducti'.'-3 uses,
No use of chemicals,
Preservation of large
open spaces ,
Low operating expenses
with potential
economic returns
from sale of crops
Expensive unless 300-500
carbon is regen- sq ft/KGD
erated and recycled.
Regeneration equipment
is not readily
adaptable to small
plants (less than
3 MGD)
Regeneration process
requires careful
operator control.
Energy requirements
high 500 kwh/mg
Requires more space, 0.3-0.6 acre/
Can be upset by toxic MGD
materials ,
Energy - 925 kwh/mg
Affected by cold 700 sq ft/MGD
weather ,
Need to remove lime
deposits in towers.
Energy - 1000 kwh/rag
Complicated equipment, 1000 sq ft/MGD
high capital costs.
Energy - 100 kwh/ms
Increases chloride 500 sq ft/MGD
content in waste-
water,
Requires large
quantities of
chloride
Requires large land 100-600 acres/
area . MGD
Still relatively new
process; little data
available on proper
design of process for
particular circum-
stances
Energy requirements vary
1COO-2500 kwh/mg
354/1000 gals $3.70/mo
(1 MGD)
114/1000 gals $1.15/mo
(10 MGD)
304/1000 gals $3.15/
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Table 6
BOD AND
SUSPENDED SOLIDS
DISINFECTION
PHOSPHORUS
REMOVAL
TERTIARY SUSPENDED
SOLIDS REMOVAL
AND BOD REMOVAL
i-Rock Media
Trickling Filter —L Synthetic media
-Activated sludge —
-Conventional
Tapered aeration
Step aeration
Complete mix
Contact stabilization
Extended aeration
Oxidation ditch
Pure oxygen
-Oxidation ponds and aerated lagoons
-Rotating biological contactors
-Activated biofilters
-Physical-chemical treatment
CChlorination
Ozonation
r Coagulation-sedimentation
«- Land treatment
^-Coagulation-sedimentation
Filtration
Microscreening
I-Land treatment
r-Primary process
Secondary process
Tertiary process
—Biological-chemical
COD REMOVAL
NITROGEN
REMOVAL
[Activated carbon-
Land treatment
•Granular
•Powdered
-Biological nitrification-denitrification
rAmmonia stripping
Ion exchange
-Breakpoint chlorination
-Land treatment
ORGANIC SLUDGE
HANDLING
AWT CHEMICAL
SLUDGES
I—Land application (fertilizer)
[-Digestion -—
—Dewater
pBury
| Land application
I (fertilizer)
-Dewater —,——burn
-Wet air oxidation
Recovery and reuse
Disposal
• Dry
fertilizer
Summary of available alternatives relative to requirements for
pollutant removal.
Source: "Environmental Pollution Control Alternatives: Municipal
Wastewater," EPA, May, 1976
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One method of land application, spray irrigation
systems, removes pollutants by a soil-crop system, leaving
the nutrients as fertilizer and effluent as moisture for
the crops. Treatment is provided by natural processes as
the effluent moves through the soil. Application rates
will vary with the types of soil, climate, crops, and
quality standards were runoff occurs. Secondary treatment
and subsequent use of effluent for surface irrigation results
in pollutant removals equivalent or superior to those produced
by other advanced water treatment processes: BOD, 98 percent;
COD, 80 percent; suspended solids, 98 percent; nitrogen, 85
percent; phosphorus, 98 percent; metals, 95 percent; and
microorganisms, 98 percent. About 600 communities in the
United States reuse municipal wastewater treatment effluent
in surface irrigation systems, mostly in arid and semiarid
regions.
Applied effluents are considered valuable resources.
For example, in Lubbock, Texas, where irrigation water is
scarce, 15 million gallons per day of secondary effluent
is applied to 2,300 acres of wheat, barley, oats, rye,
cotton and grain sorghum. Crop yields exceed those
achieved with conventional irrigation.
In Muskegon, Michigan, 6,300 acres planted mostly
with corn are irrigated by the secondary effluent from a
$42 million, 43-3 mgd project. Crop yields were as high
as 92 bushels per acre in 1974 and produced an income of
$368,000. Water collected from underdrains beneath the
the irrigated area is of extremely high quality.
A second land disposal method, called infiltration-
percolation, achieves nearly complete infiltration of the
applied water into the soil, thus, allowing greater appli-
cation rates. All runoffs are controlled and groundwater
recharged. Ideally, the application area for this method
should be nearly flat, with a water-tolerant species of
grass maintained and harvested as necessary. Typical
removal of pollutants from secondary effluent are BOD,
85-99 percent; suspended solids, 98 percent; nitrogen,
0-50 percent; phosphorun, 60-95 percent; and metals
50-95 percent.
In a third method of land treatment, called overland
flow, wastewater is sprayed over the upper edges of sloping
terrain and flows slowly downhill through the grass and
other vegetation. The vegetation, not the soil, is the
primary filter. According to EPA research, typical removals
are BOD, 92 percent; suspended solids, 92 percent; nitrogen
70-90 percent; phosphorus, 40-80 percent; and metals, 50
percent. Clay soils and moderate slopes are best suited
to this technique. As the effluent flows down the slope,
some if it infiltrates the soil, a small amount evaporates
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and the remainder (as much as 50 percent of the flow) goes to
collection channels before discharge. The grass filters out
the suspended solids, and the organics are oxidized by the
bacteria living in the vegetation. In the United States this
method has been used primarily for treating high-strength
wastewater, such as that from canneries; it is used for
municipal waste treatment in Australia.
4. Waste Treatment and Reuse of Purified Water
Especially in arid regions where water is too
valuable to be disposed of after treatment, wastewaters
can be cleaned to varying degrees by physical/biological/
chemical means in a central treatment plant and then reused
as cooling or process water for industry and utilities, as
recreational or municipal water supplies, and, as discussed
earlier, agriculture and recharge of groundwater (including
prevention of saltwater intrusion along the coastline) .
Degree of waste removal will depend on the use and cost of
the reclaimed water.
In theory, at least, wastewater effluent may be used as a
source of drinking water, though public health officials in this
country generally are nervous about the prospect. (Effluent is
reused directly for drinking water at Windhok, South Africa, and
drinking quality effluent from Virginia's Upper Occoquan plant
will be discharged indirectly into a water supply reservoir.)
5. On-Site Waste Treatment and Disposal
Other alternatives to collection and central treatment
systems include septic tanks, mounds, holding tanks, small
aerobic treatment plants or other on-site treatment and sub-
surface disposal systems serving one or more principal resi-
dences or small commercial establishments. Small towns or widely
dispersed sections of larger cities might find these alternatives
attractive and feasible, as might communities hoping to minimize
the impact of sewage treatment on growth. These on-site systems
frequently will be less expensive than a centralized system.
The on-site alternative has become increasingly attractive
since the 1977 Clean Water Act extended federal grant funds to
either publicly or privately-owned on-site works under certain
conditions. Individually-owned systems, designed to abate an
existing pollution problem, must serve principle residences or
small commercial establishments in existence as of December 27,
1977. A Facilities Plan prepared by a qualified local applicant
must have certified that the individual system is cost-effective,
that public ownership of the treatment works is not feasible, and
that the treatment works will be properly operated and maintained
(see Chapter III).
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6. Sludge Management
Unfortunately, the pollutants removed from wastewater by
traditional treatment do not vanish into thin air—they become
a messy, mostly-organic substance called sludge. The higher the
degree of treatment, the more sludge accumulates. In many com-
munities—particularly large metropolitan areas—the worst waste-
water treatment headache is what to do with the sludge. Indeed,
sludge management systems can absorb 30 to 50 percent of the
capital costs of a wastewater treatment plant.
Consideration of sludge management alternatives will be
part of the analysis of every treatment system.
The chemical makeup of sludge must be known before dis-
posal options can be studied. Sludge from systems receiving in-
dustrial waste often contain toxic chemicals or other components
that require careful management. The only option open to many
communities is some combination of incineration and landfill—
though incineration to generate electricity, or pyrolysis (heat-
ing in the absence of oxygen in order to produce useful gases
and organic compounds) may soon become practical alternatives.
Ocean dumping of sludge is being phased out under federal laws.
More and more communities are disposing of their sludges
by "land application"—if they are fortunate enough to have facil-
ities that produce sludge which meets standards for toxic chemi-
cals, salts, heavy metals, and pathogenic organisms. Though too
low in nutrients to be a high-quality fertilizer, sludge is a
good soil conditioner—good enough that most communities using
land application disposal are able to find farmers willing or
even anxious to offer their private property as the disposal
site. Some communities take the additional step of composting
their sludge before application to the land—this makes the
sludge easier to handle and destroys almost all pathogens.
Late in 1978, EPA will issue new sludge management
alternative guidelines and limitations to be followed in
facilities planning.
(Table 7 summarizes sludge treatment techniques.)
How Is the Final Sewage Management Alternative Selected?
When the sewage treatment alternatives capable of meeting
a community's specified effluent limitations have been identified,
their monetary and other costs are compared. This comparson of
alternatives, which leads to final selection, is completed within
the framework of a cost-effectiveness analysis, the details of
which are specified by EPA regulations and described in the
following pages.
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TABLE 7
Treatment
Process
SLUDGE TREATMENT TECHNIQUES^
Adapted from EPA Technology Transfer, Environmental Pollution Control Alternatives: Municipal Wastewater
Advantages
Disadvantages
Costs
Conditioning
- chemical
- heat
Facilitates separation of
solids and liquids
$ 3-30/ton (chemical)
$20-40/ton (heat)
Thickening
- flotation
- gravity
$ 4-26/ton (flotation)
$ 4-10/ton (gravity)
Stabilization (not
necessary for burning)
f-
- anerobic
- aerobic
'Breaks down organic solids
bio-chemically, more
stable, more dewaterable
Produces useful by-product
(methane)
More stable operations,
Recycles fewer pollutants
to plant
Sensitive to variations
in sludge feed
Produces supernatent
which must be recycled,
Higher power costs, does
not produce methane
$3Q-4Q/ton (anerobic)
$30-50/ton (aerobic)
to
Dewatering
- sandbeds
- vacuum filters
- centrifuges
- pressure filters
Simple to operate and maintain
Smaller space requirements
Not affected by weather
Large space requirements
Affected by weather
Reduction
- incineration
- wet air oxidation
Eliminates dewatering step
Minimizes air pollution
potential
Creates toxic liquid which
must be recycled,
Complex maintenance
problems
$40-60/ton (oxidation)
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What is cost-effectiveness?
Cost-effectiveness is simply a description of how well a
system achieves its objectives (the specified effluent limita-
tions, in this case) in terms of its overall cost (economic,
social, environmental). When it authorized federal construction
grants, Congress built in cost-effectiveness analysis as a way
to assure that those grants produce the maximum clean water
possible per tax dollar invested without creating significant
other problems.
According to recently published EPA guidelines, the most
cost-effective waste management solution is the one with the
lowest overall monetary costs (including capital, operation and
maintenance costs over a 20-year period, calculated as lowest
"present worth" or "equivalent annual value") that meets all
federal, state and local requirements (such as water quality
standards, NPDES permit requirements, water reuse or subsurface
disposal requirements) without adverse non-monetary costs.
In cost-effectiveness analysis, all feasible types of
waste management systems (listed in this chapter) are screened
to identify those likely to meet all federal, state and local
requirements. The alternatives that qualify are then analyzed
to determine which might be the most cost-effective. In accor-
dance with federal guidelines, monetary costs are calculated for
each qualifying alternative, and non-monetary costs are quanti-
fied, if possible, or described qualitatively, usually during
the environmental assessment process of the Facilities Plan
(described on the following pages.) Nonmonetary costs might
include primary and secondary environmental effects, implemen-
tation capability, energy and resources use, reliability and
flexibility. The lowers cost alternative without other over-
riding problems is deemed most cost-effective.
The level of detail and sophistication required for this
final analysis will vary with the size and importance of the
project.
What are the monetary costs of wastewater
management alternatives?
Monetary costs, the primary factor in determining cost-
effectiveness, can be broken down into two categories: capital
construction costs, and operation and maintenance (O&M) costs.
All capital costs—those required for initial construction or
major improvement of interceptors, wastewater treatment, dis-
charge or reuse facilities, sludge handling equipment, repair
on existing sewers—are eligible for federal grant assistance.
(See "What will the federal government pay for?" Chapter IV)
Specifically, capital costs include:
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1) all contractors' costs of construction,
including overhead and profit,
2) cost of land if it is an integral part of
a treatment system or if it is needed for
storage of waste prior to treatment,
3) relocation, and right-of-way and easement
acquisition,
4) design engineering, field exploration and
engineering services during construction,
5) administrative and legal services including
costs of bond sales,
6) start-up costs, such as operator training,
7) interest during construction,
8) contingency allowances.
O&M costs of each alternative over the 20-year
planning period are also calculated in the cost-effective-
ness analysis, although these costs are not covered by
federal grants. (Some state governments provide assistance
to municipalities to cover part of the O&M costs.) O&M
costs include labor, chemicals and other materials used
in the operation of a facility, routine replacement of
equipment and parts, and energy. Energy is a growing
cost in wastewater management systems and the 1977 Clean
Water Act direct the EPA Administrator to "encourage waste
treatment management methods, processes and techniques
which will reduce total energy requirements."
Offsetting revenues
In addition to the dollar costs associated with
alternative treatment systems, some waste management
techniques produce revenues that should be calculated
against outlays to produce net monetary costs. For
example, selling sludge for soil conditioning, marketing
crops grown on public lands with applied effluent, selling
effluent to farmers or industries, reduced costs of public
water supplies, and selling reclaimed water to industries
all provide financial benefits that are calculated in net
monetary costs.
How is "present worth" or "equivalent annual value"
calculated?
EPA guidelines provide that monetary costs of
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alternative systems are to be expressed as "present worth"
or "equivalent annual value." Present worth (PW) is an
economic method of determining how much money would be
required now to pay for all anticipated costs (capital
and O&M) during a specific period of time. Thus while
federal funds are available only for construction costs,
these funds are awarded only for the most economical
project overall.
Present worth assumes that money received today,
if not spent, will be invested at the prevailing interest
rate and the value of the money at some future time will
equal the original investment plus interest. For example,
if a $100 expenditure will be made two years from now, the
PW of this expenditure is the amount of money that will
be worth $100 in two years if it is invested today at
the prevailing interest rate.
The present worth of total costs equals the sum
of the present worth of all capital and O&M costs over the
20-year period of the project. (See Appendix A for a
further description of present worth.)
"Equivalent annual value" is another way to express
project costs; it is expressed on an annual basis and not
for the complete 20-year costs. The equivalent annual
cost is the constant annual payment that is equivalent to
the present worth if it is discounted each year and added
over the 20-year life of the project.
If the present worth is secured in a lump sum
through a bond issue and repaid with interest in equal
annual payments, the payments would equal the annual cost.
What interest or discount rate does the
federal government allow?
In making present worth calculations (and in other
cases where interest or discount rates are used), EPA
currently allows a 6-5/8 percent discount rate. (The
discount rate is the assumed interest rate used to cal-
culated the present worth of future money.)
The interest during construction of facilities
is I x 1/2 PxC where:
I = the interest or discount rate
P = the construction period in years
C = the total capital expenditures.
If the construction period will be greater than three years,
interest during construction is calculated on a year-by-year
basis.
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Is an inflation factor included in cost-effectiveness
analysis, as allowed by federal guidelines?
Sometimes. Wage and price inflation usually is not
considered, under the assumption that the rise in wages and
prices will be roughly constant for all projects. An in-
flation factor is allowed, however, in two areas—natural
gas prices and land values. The price of natural gas is
to be escalated at a compound rate of 4 percent annually.
In calculating the salvage value of land, the land value
is to be appreciated at a compound rate of 3 percent
annually during the planning period. Lands not held in
simple, however, (such as a right-of-way easement) are not
assumed to have appreciated at the same rate. The salvage
value of these easements is assumed to be the prevailing
market value of the easement land at the time of the cost-
effectiveness analysis.
What service life is allowed by federal guidelines
for treatment works?
In calculating the service life of treatment facil-
ities for cost-effectiveness analysis, the following shall
be used:
land
wastewater conveyance
structures (includes
collection systems,
outfalls pipes,
interceptors, force
mains, tunnels, etc.)
other structures
(includes plant
buildings, concrete
process tankage, basins
lift stat'ion structures,
etc.)
process equipment
auxiliary equipment
= Permanent. Land is assumed
to have an appreciated salvage
value after the treatment
facilities are no longer used.
(See "inflation factors" above.)
= 50 years .
= 30-50 years .
= 15-20 years.
= 10-15 years.
All structures may have a salvage value if the
anticipated useful life of a treatment facility is less
than 20 years. The same may be true for equipment, if it
can be demonstrated that a market exists for that equipment,
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The present worth is reduced by the present worth of the
salvage value of facilities and land at the end of the
project period.
What are typical cost factors for each major
wastewater management alternative?
The cost considerations for three major wastewater
management alternatives are discussed in some detail 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 reuse wastewater.
The cost considerations of improvements of existing
facilities are too complex to generalize. The basic questions
of sizing and service area, discussed earlier and below, will
obviously affect costs. In the case of excessive infiltration/
inflow, a sewer system evaluation will determine cost-effective
sewer rehabilitation 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 construction. 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 facilities, which include house connections, laterals,
and submains. Of the total cost of a gravity-flow sewerage
system, lateral sewers usually 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
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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 lining up separate populated
areas by interceptors and force mains to create regional
system.
(a) Types of waste treatment technology selected.
Treatment plant costs are governed by volume of wastewater
and the type of wastes to be removed. EPA has developed
general cost estimates for treatment systems that remove
wastes by means of secondary treatment (trickling filters,
activated sludge and oxidation ponds or lagoons) and by
disinfection and advanced waste treatment (phosphorus
removal, filtration, carbon absorption, nitrogen control
and land treatment). General estimates are also available
for flow equalization and sludge treatment and disposal.
(For information on the various factors leading to costs
see EPA 625/5-76-012.)
(b) Industrial wastes and pretreatment. A muni-
cipality should examine the kinds of the industrial wastes
discharged to its public system to find out whether it is
more cost-effective for the community to treat these wastes
in a municipal system and then bill the company for that
cost, or whether the company should pretreat the wastes
before discharging them to the central system. While the
makeup of residential and commercial wastewaters is re-
latively constant, industrial discharges can be highly
variable and require quite different removal technologies.
Industrial waste frequently contains materials that actually
may damage the biological process of a municipal waste treat-
ment system,
(c) Size of the treatment plant. The size of the
treatment facility is a major cost factor, and is determined
by present and expected future population, per capita waste
generation, industrial flows and excess capacity needed to
accommodate growth. When deciding the size of its treatment
plant, the community should consider economies of scale in
construction and O&M and the expected wastewater flow over
the life of the facilities.
The total costs for secondary wastewater treatment
plants, both capital and O&M costs, as a function of average
flow treated, are shown in figure 1. (This figure was developed
from cost data that may be out of date. It is included here
because the principle illustrated is still accurate. It should
also be noted that no general figures can be simply extrapolated
to a specific situation, as all cost factors are quite site-
specific.)
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This chart shows substantial economies of scale in both
construction and O&M with greater economies accruing to large
plants than to small plants. Phosphorus removal is not subject
to such significant scale economies, particularly in O&M, since
the largest cost is for chemicals which do not respond to scale
economies.
Economies of scale are the major argument used in favor
of building regional treatment plants. However, the high mone-
tary cost of building collection systems and excess capacity
for future users (which must be borne by current users) are
often brushed aside by the decision to build a regional facility,
When is a regional treatment facility cheaper
(in monetary costs) than several smaller ones?
Regionalization—the tying together of separate areas
by construction of interceptors, trunk sewers and force mains
for treatment at a large central plant—may be appropriate if
the savings that result from a larger treatment plant offset
the added costs of collection.
Many other environmental and land use considerations
may signficantly affect a regionalization decision.
Generally, as the number of treatment plants decreases,
so does the average cost of treatment; average costs of waste-
water transport increase. The distance that was.tewater can be
economically transported varies greatly with the size of waste-
load, the size of the receiving community and the terrain over
which sewers must be built.
A further point to consider: The discharge of large
amounts of effluent at a single point may have a different
impact on receiving waters than the discharge of the same
quality effluent in smaller amounts at a number of points.
.Where can package treatment plants be used?
At the other end of the scale from regional facilities
are package treatment plants that serve a small, contained
population^ such as an outlying suburb or small town. Package
plants are small facilities that are partially or completely
preasembled by a manufacturer and shipped to the designated
location. They can provide primary, secondary or advanced
waste treatment, though most are secondary, and come in various
sizes—small ones for a single household, larger models to treat
up to one million gallons per day. Package plants are usually
less expensive than comparable facilities of the same size
constructed in place. On the other hand, they often suffer
from inadequate operation and maintenance.
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FIGURE 2: TOTAL COSTS OF SEWAGE TREATMENT
100 j
so
60
40
OS
o
o
•a
o
o
e
3
I
secondary treatment
phosphorous
removsil
O 2O 40
average flow treated (mgd)
GO
80
100
Note: Costs adjusted to June 1975; amortization computed at 6 percent interest over 15-
year Ii*'e.
Sou.-'.'e: Adapted from Robert Smith and Richard G. Eilers, "The Economics of Con-
soli'Iatinu Sewage Treatment Plains by Means of Interceptor Sewers and Force Mains"
(.U.S. Environmental Protection Agency, April 1971). pp. 41 and 70.
Reprinted by permission of the publisher, from
LAND USE AND THE PIPE by Richard D. Tabors, Michael H.
Shapiro, and Peter P. Rogers.
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(d) Service area. The size of the area to be served
by sewers and treatment facilties is closely related to the size
of the treatment plant—the larger the area that pipes wastewater
to the treatment plant, the larger the capacity of the plant
must be. Defining the service area is partly a matter of costs,
as well as environmental, political and administrative factors.
If the service boundaries conform to natural boundaries—streams
or riverbasins—cheaper, gravity-flow sewers can be used instead
of force mains.
The economies of scale of a large treatment plant must
be weighed against the possible higher costs of servicing larger
areas of low density using interceptor sewers and force mains
to connect natural basins to a regional treatment plant.
Overall effects of including low density areas in the
service district may be positive. By servicing an area currently
using septic tanks, ground water pollution may be avoided.
Before the 1977 Clean Water Act was passed, the decision
whether to include an area with existing individual septic fields
in a new sewered region was frequently made not on the basis
of cost-effectiveness, but rather on the fact that federal funds
were available for sewers but not for septic fields.
Replacing septic systems with sewers can lead to a host
of associated environmental problems (the effects of new growth,
or of concentrated effluent discharged in environmentally sen-
sitive areas). Now that federal funding may pay to correct pro-
blems in individual septic systems, the merits of including areas
served by septic fields in larger sewage treatment service areas
can by evaluated more realistically.
The costs of sewers are pertinent in deciding service
area boundaries. These costs, which include excavation and pur-
chase and laying of the pipes, will vary according to soil type,
depth of the trench dug, size of the pipe, minimum slope, minimum
flow velocity, location of construction and groundwater level.
Topographic factors also are important: costs are reduced if
natural drainage basins are used, since adequate flow velocities
are achieved naturally, without the need for deeper trenches.
Laying pipe through rock rather than ordinary soil can push up
excavation costs considerably. Cohesive soils are less expensive
to excavate than loose soils. Flat areas and steep slopes cost
more to sewer than moderate slopes, since they require greater
excavation to meet minimum and maximum velocity needs. It also
costs more to lay sewers in developed areas than in open country:
streets must be dug up and replaced, utility lines moved and
traffic rerouted.
Sewer construction involves several cost tradeoffs. The
greater the service area, the greater the length of pipe required.
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For gravity sewers, greater pipe length means greater average
depths and thus higher excavation costs. For force mains,
the longer the pipe, the more energy required for pumping.
There is a further tradeoff for gravity sewers.
Increased flow results from larger pipes and from greater
slope made possible by deeper trenches. But larger pipes
cost more than smaller ones, and deeper trenches cost more
to excavate.
Nevertheless, major economies of scale are achieved by
increasing the size of gravity sewers. One estimate is that
every doubling of capacity reduces the cost per 1000 gallons
per mile by 29 percent.
In general, per capita collection costs usually increase
with the size of the service area. Population densities tend
to decrease on the urban fringes and per capita collection costs
increase greatly as densities decrease.
(e^ Staging. Which is cheaper, building new capacity
through small expansions—every 10 years, for example —-to meet
increased need, or building capacity for 20 years growth now?
To determine the most cost-effective time to install
collection and treatment capacity for a future population, it
is necessary to compare the "present worth" of expenditures
made in different staging schedules.
The practice of discounting future dollars in financial
planning means that dollars spent in the future are valued less
than dollars spent today—supporting the argument that expend-
itures should be deferred as long as possible. Economies of
scale in treatment facilities also favor longer design periods
with larger, but fewer, expansions. But as interest rates rise,
the optimum design period decreases, since higher interest rates
cause immediate expenditures to be given more relative weight.
The design period also decreases with increasing growth rate,
because as growth increases so does the investment needed to
provide excess capacity for a given time period.
Changing land-use patterns also will affect the length of
the design period. Laying sewers in a currently undeveloped area
will be cheaper in real terms than sewering the area later when
it is built up. This factor, like economies of scale, favors
longer design periods. Because of the disruption factor, building
interceptors in stages is generally more difficult and expensive
than staging treatment plants. Furthermore, if construction is
delayed on treatment plants, new and cheaper waste management or
water conservation technology may become available. Also, when
inflation rates are high, some communities consider it cheaper
to construct excess capacity now, paying off low-interest bonds
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with devalued dollars and avoiding inflated construction
prices later.
What requirements do EPA guidelines place on
staging a treatment plant or interceptor?
The revised EPA cost-effectiveness guidelines provide
that three alternative staging periods should be evaluated for
treatment plants—10 years, 15 years and 20 years—and that the
alternative with the least present worth or average annual cost
be selected. Another selection method provided by the guidelines
suggests that the staging not exceed the best period according
to this table:
Staging Periods for Treatment Plants
Flow growth Maximum Initial Staging Period
Factor (20 yrs)* Qo 1MGD
1.3 or less 20 years
1.3-1.8 15 years
Greater than 1.8 10 years
A municipality may stage construction for a shorter
period if adequately justified, but in no case for less than
10 years, because intervals that short do not allow enough time
for planning, application for a federal grant and construction.
Any sizes or capacities of proposed treatment plant
components that exceed the minimum reliability requirements
spelled out in EPA's technical bulletin "Design Criteria for
Mechanical, Electric, and Fluid System and Component Reliability"
must be approved by the EPA Regional Administrator.
EPA's proposed policy on the staging of interceptors,
citing the influence on growth of interceptor location and length,
states that interceptor routes shall be planned primarily to serve
existing households. An interceptor may be provided in the initial
stage to phase out or eliminate existing point source discharges
and to accommodate flows from existing households. Otherwise,
interceptors shall not be extended into environmentally sensitive
areas, primary agricultural lands and other undeveloped areas
(densities of less than one household per two acres) .
Ratio of wastewater flow expected at end of
20-year planning period to initial flow when
plant is expected to become operational (Q20/Qo) .
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When planned interceptors are routed through
undeveloped areas to link two or'more communities, EPA
requires that the need for such systems be reevaluated,
and alternative waste treatment systems be reexamined.
In addition, the grantee must analyze and mitigate
secondary impacts of such interceptors. Additional
interceptors or extensions to interceptors may be added
in the future to phase out additional point source
discharges or to handle expected flows from new house-
holds. The location and sizing of interceptors shall
not conflict with other approved environmental plans,
such as 208 and air-quality plans.
EPA's proposed policy requires the sizing of
interceptor pipes to be based on a 20-year staging
period. The interceptor may be sized for a 40-year
period only if it can be demonstrated that larger pipe
is consistent with projected land-use patterns and that
overall environmental quality would be improved.
When estimating peak flows in interceptors,
consideration shall be given to:
® daily and seasonal variation in pipe flows,
timing of flows and pipe storage effects;
© feasibility of off-pipe storage to reduce
peak flows;
® use of an appropriate peak flow factor that
decreases as the average daily flow to be
conveyed increases.
How is the community likely to react to the com-
bination of federal funding and federal regulation?
EPA's proposed sizing and staging policies (which
will determine the eligibility for federal funds of all
parts of the Facilities Plan) appear to take a sizable
step away from previous promotion of centralized regional
treatment facilities. The cost-effectiveness guidelines
explicitly recognize that nonmonetary factors may in
fact overwhelm the monetary incentives to regionalize.
The monetary portion of the cost-effectiveness analysis
might not be as clear cut as it once appeared. There is increas-
ing evidence that in many situations a smaller scale treatment
facility carefully designed to serve existing populations and
existing problems may prove to be less costly than large regional
facilities. Now that federal funds may be used to pay for a
greater variety of these small scale systems, they may receive
renewed attention.
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In spite of the new regulations and guidelines that
encourage smaller facilities serving realistic populations
and flows, the fact remains that the availability of federal
dollars to cover 75 percent of the cost of facilities may be
a tremendous incentive for a community to build the largest
possible waste treatment facility.
Since there is no guarantee of future federal funds for
treatment works and interceptor expansion, community decision-
makers may face a difficult economic trade-off. If a newly con-
structed facility turns out to have too little capacity to keep
up with actual population growth, for example, the community may
have to pay all the costs of future expansion. On the other hand,
building a facility now with far too much capacity for existing
populations and future growth can mean that current residents
will have to pay high initial user charges to support the unused
capacity. This latter situation could prompt a strong push for
new growth to reduce per capita user charges.
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 waste-
water, spray irrigation equipment or other land application
devices, and underdrains to recover renovated water.
Table 8 summarizes the characteristics of the three main
types of land application systems.
The cost of these systems will vary depending on land
costs, land application methods and transport methods. EPA
estimates that for 1 mgd capacity, costs may range from 20 cents
per 1000 gallons ($2.10 per month per home) to $1.09 per 1000
gallons ($11.45 per month per home), while at 10 mgd, they range
from 14 cents per 1000 gallons ($1.50 per month per home to $1.00
per 1000 gallons ($10.50 per month per home). The cost of trans-
porting wastewater to the site is not included.
Detailed cost curves for each of these land application
systems components are available from EPA in "Costs of Wastewater
Treatment by Land Application" (June 1975).
Land treatment offers many cost advantages. A very ad-
vanced degree of treatment is possible without generating any
chemical sludges or using chemicals or activated carbon. Recycled
water, nutrients and crops grown on the treatment area have market
value. Large open-space areas are preserved with potential for
multiple recreation use during the non-irrigation season. Land
appreciates in value and represents a future resource to the com-
munity. Operating costs are less than for other tertiary proces-
ses. As a substitute for secondary treatment, (when state laws
permit) land application can bring substantial cost-savings.
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(source: EPA, "Costs of Wastewater Treatment by Land Application, JE '75J
Table 8
COMPARATIVE CHARACTERISTICS OF IRRIGATION, INFILTRATION-PER-
COLATION, AND OVERLAND FLOW SYSTEMS FOR MUNICIPAL WASTEWATER
Factor
Irrigation Infiltration-
low-rate hicrh-rate Percolation Overland flow
Liquid loading
rate, in./wk
Annual Appli-
cation, ft/yr
Land required
for 1 mgd flow
rate, acres *
Application
techniques
Vegetation
required
Crop
Production
Soils
Climatic
constraints
Wastewater
lost to:
0.5-1.5 1.5-4.0
4 to 120
2 to 4 4 to 18 18 to 500
280-560 62-280
Spray or surface
Yes
Yes
2 to 62
Usually
surface
No
Excellent Good/fair Poor/none
2 to 9
8 to 40
28 to 140
Usually
spray
Yes
Fair/poor
Moderately permeable Rapidly per- Slowly per-
soils with good pro- meable soils meable soils
ductive capacity when such as sands, such as clay
irrigated and sandy loams loams and clays
Storage often needed Reduce loadings Storage often
in freezing needed
weather
Evaporation and
percolation
Percolation
Surface run-
off and evap-
oration with
some perco-
lation
Expected
treatment
performance
-BOD & SS
removal
-Nitrogen
removal
-Phosphorus
removal
98+%
85+%
80 to 99%
85
0
60
to
to
to
99%
50%
95%
92+%
70
40
to
to
90%
80%
* Dependent on crop uptake
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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 ground is frozen.
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 commu-
nity must decide whether or not to include outlying sites in a
sewage service area. As described in Chapter IV, the funding
of individual systems is now eligible for federal funds under
certain circumstances. The question often is: Is it cheaper
for a source to use on-site disposal, or be sewered?
Typically, septic tank costs include the tank, houseline,
distribution box, absorption field, operation and maintenance
(pumping and inspection) and the cost of financing. Per capita
costs can be as low as $60 a year or as high as $150 a year,
depending on system needs.
Soil conditions are a key cost factor. If soils are not
conducive to good subsurface disposal, on-site disposal costs
go up.
In addition to costs, the quality of treatment provided
by on-site systems must be calculated. Sewer service may turn
out to be more appropriate, even if more expensive for both
technical and institutional reasons. For example, maintenance
of groundwater quality may be a problem with on-site systems.
In addition, it may be difficult for a central governmental
body to assure the required maintenance of the individually-
owned systems, as well as monitoring programs that will allow
necessary surveillance of water quality.
What Are the Nonmonetary Factors in Choosing the Sewage
Treatment Alternative? How Are They Vfeighed?
EPA's cost-effectivenes guidelines provide that before
reaching the decision that one alternative is the most cost-
effective, planners must weigh monetary factors against non-
monetary considerations. Nonmonetary factors which are to be
quantified, if possible, or otherwise qualitatively described,
include primary and secondary environmental effects, implemen-
tation capability, energy and resource use apart from the econ-
omic consequences, reliability and flexibility of the system.
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What primary and secondary environment
effects must be weighed?
Primary effects—those directly related to
location, construction and operation of the project—
include impacts on ground and surface water quality,
air pollution from incinerated sludge, odors, loss of
open space or primary agricultural lands to treatment
plant sites, destruction of wildlife or fisheries habi-
tats, loss of historic or other vulnerable or valuable
areas, erosion and noise during plant construction, and
disruption of residences and traffic during sewer exca-
vation.
The impacts of land treatment systems—positive
or negative—-include effects on soil and vegetation,
possible ground water recharge, breeding of undesirable
animal or insect life, and changes in ground and surface
water quality. Positive environmental effects may include
irrigation waters for parks or golf courses and associated
recreational benefits, creation of greenbelts, preservation
of open spaces, or control over community growth. Reclama-
tion of sterile soils, such as strip-mined areas, and re-
pulsion of saltwater intrusion into aquifers by ground-
water recharge are further possible benefits. Reclaimed
waters also may provide valuable supplies for municipal-
ities, industries and recreation.
Both positive and negative environmental considera-
tions are to be included in the cost-effectiveness analysis,
developed more specifically in the environmental assessment
and, if required, spelled out in detail in the Environmental
Impact Statement (EIS).
The assessment must take into account health and
safety considerations such as potential hazards at the plant
and its immediate vicinity, or at a disopsal site or land
treatment area. Transport of materials and effluent should
be examined in this light, as should the health aspects of
discharges, land treatment and reuse of pollutants and
wastewaters.
Secondary effects are defined as indirect or
induced changes in population, economic growth and land
use and the environmental effects resulting from these
changes. These effects may be much more significant than
the primary ones, though more difficult to predict and
quantify accurately.
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Sewers and wastewater treatment facilities are
key growth determinants in urban areas, sometimes having
greater effect on land use than highways or zoning. How
much excess capacity to build into treatment works, the
drawing of service area boundaries and staging of con-
struction are key decisions that can encourage or dis-
courage growth (as discussed earlier in this chapter).
For communities that need and want growth, some
facilities decisions can stimulate very positive economic
and social opportunities. But in areas already
pressed by rapid population growth and land-use changes,
some wastewater management decisions may exert unwanted
development pressures. In a fast growing region, for
example, an interceptor laid across one of the few
remaining open areas can bring strong pressures to
build on that area. In this case, it may be more
desirable to provide a package treatment plant--even
though it costs more—than to include the outlying
suburb in the service area by extending the interceptor.
Secondary environmental effects from growth
and sprawl are numerous: air pollution from traffic to
new suburbs, shopping centers, large industrial parks or
recreation centers; excessive energy consumption; water
pollution generated by runoff in newly built-up areas.
Paving over groundwater recharge areas might lead to
long-term lowering of the water table and consequently
reduced municipal or industrial water supplies. Un-
favorable service area decisions or construction of
oversized interceptors or regional facilities may
induce unwanted urban development that infringes on
open space, recreational areas, historic sites or
primary agricultural lands. The location of treatment
plants also can be indirectly related to development
impacts, since these facilities affect the location of
interceptors.
Ways to mitigate adverse environmental effects
are described in Chapter VII.
How are environmental factors analyzed?
Potential environmental impacts of proposed
projects are identified and discussed in an Environmental
Impact Assessment (EIA), which is an integral part of
every facility plan. If the EIA indicates that the re-
commended alternative will cause significant environmental
impact, then a full Environmental Impact Statement (EIS)
will be written by EPA under the requirements of the
National Environmental Policy Act.
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The Environmental Impact Assessment is prepared
during local facilities planning as part of the analysis
of different sewage management alternatives, usually
(though not always) by the same consultant who prepares
the Facilities Plan itself. The EIA differs from the EIS
in its level of detail, scope of analysis, and in the
government jurisdiction responsible for implementing it.
The content of the EIA is the substantive basis for the
decision by EPA to prepare a full Environmental Impact
Statement.
What are the contents of the Environmental
Impact Assessment?
Regulations governing the preparation of impact
statements require the following information in the EIA:
1) description of the existing and future
environment without the project, including
adequate documentation of these descriptions!
2) an environmental, social and economic
evaluation of waste treatment alternatives
with special attention to long-term impacts,
irreversible impacts, and induced impacts
such as development; and
3) a description of primary and secondary
environmental impacts of the proposed action,
including any unavoidable impacts and any steps
that might be taken to mitigate and minimize
adverse impacts.
If EPA decides to prepare an EIS, the information
contained in the environmental assessment will be used to
prepare the larger document.
How and when does EPA decide to prepare an
Environmental Impact Statement?
When a grantee's EIA is completed, EPA reviews
it to determine whether or not to conduct a full Environ-
mental Impact Statement. If EPA finds potentially signifi-
cant adverse environmental impacts not immediately amenable
to mitigation, the EPA Regional Administrator gives notice of
intent to prepare an EIS.
EPA's regulations require that an EIS be prepared
for a facilities plan under the following circumstances :
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1) the plan will induce significant
development and land-use changes?
2) major parts of the treatment works are
located on productive wetlands or will signi-
ficantly and adversely affect the habitat
of endangered species?
3) the treatment works will have significant
adverse affects on public lands and recre-
ational and historic opportunities?
4) the treatment works will have a significant
adverse affect on air or water quality,
noise, and/or on fish and wildlife habitat?
5} the effluent limitation for pretreatment
works reflects water quality standards that
are insufficient to protect "present or
future uses?"
6) the treatment works will cause significant
social dislocations (such as population
displacement or destruction of a residential
area) or will adversely affect significant
amounts of possible agricultural land,,
If it is apparent at the outset of facilities
planning that significant adverse environmental impacts
will occur, EPA may decide at that time to conduct a full
EIS.
In a cooperative approach called "piggybacking,"
EPA may arrange at the outset of facilities planning for
the community's consultant in effect to prepare the EIA
and EIS at the same time. EPA personnel will work with
the consultant throughout his study, dealing with problems
as they arise. When an EIS is "piggy-backed," a community
is assured that a full consideration of environmental
impacts is conducted throughout the facilities planning
process. In addition, delays in the award of a Step 2
grant caused by tacking on the EIS to the middle or end
of Step 1 are minimized.
If EPA determines that a sewage treatment project
will not result in significant environmental impacts with
significant adverse affects, the Regional Administrator will
issue a formal ffegative Declaration to allow for public re-
view of that decision. This Negative Declaration must be
issued 15 days before any administrative action which moves
the project forward to another stage. A brief environmental
appraisal must be available for public review at the time
the Negative Declaration is issued.
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How will I know i£ an Environmental Impact Statement
is to be developed for my community's Step 1 grant?
Although the criteria for preparing an EIS would
seem to give appropriate attention to all projects where
significant environmental impacts are anticipated, a closer
look at the regulatory language reveals a great deal of
flexibility for interpreting these criteria. The fact is,
EPA prepares an EIS for only 5 percent of construction
grants projects. The limited resources available to EPA
and the existence of public controversy are more likely
to determine which projects are scrutinized than are
objective environmental criteria.
EPA retains responsibility for preparing the EIS'—•
even when a program has been substantially delegated to
the state—yet, the state water quality agency is likely
to play a significant role in the decision to undertake it.
The state agency certifies the adequacy of the EIA and
will inform EPA if there appear to be significant adverse
environmental impacts. The details of coordinating dele-
gated state agency programs with EPA's responsibility for
the EIS are not yet fully resolved, but it seems likely
that EPA will rely on information provided by the state
agency in making its decision,
What are the contents of an
Environmental Impact Statement?
The Environmental Impact Statement will contain much
of the same information contained in the Environmental Impact
Assessment—but in more detail. EIS regulations require the
following information in the body of the statement:
1) background and description of the
proposed action;
2) alternatives to the proposal action
(including the alternative of no action);
3) a description of the short and long-term
primary and secondary environmental impacts
of the proposed action;
4) adverse impacts that cannot be avoided
if the project goes forward;
5) the relationship between local short-term
uses of the environment and maintenance
and enforcement of long-term productivity;
6) irreversible and irretrievable commitments of
resources to implement the proposed action; and
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7) problems and objectives raised by
other governmental entities.
What factors influence a system's
reliability and flexibility?
The reliability of a collection, treatment and
disposal or reuse system refers to the probability that
the system will meet its objectives. Traditional, well-
tested treatment devices that are well operated rank high
on the reliability scale since their operating and design
parameters are well known.
For example, a major advantage of a trickling
filter secondary system is its basic simplicity, which
permits incoming loads of pollutants to vary over a wide
range during the day without causing operating problems.
This minimizes the need for operator skills. The mechanical
equipment is also simple, and energy requirements are low.
(But treatment efficiency falls off considerably when
temperatures drop in the winter, and the system may cause
insect and odor problems.)
As another example, phosphorus removal by coagula-
tion-sedimentation is a simple, well-proven process that
provides reliable removal of BOD and suspended solids.
(But large quantities of chemical sludge are generated.)
In times of energy shortages, excessive energy
requirements may affect reliability of the system. Some
land application systems, for example, require considerable
amounts of power to move wastewater from its source to the
land treatment site.
A system that incorporates flow equalization measures
may improve the overall efficiency and reliability of the
treatment process.
The flexibility of a system refers to its capa-
bility to meet future needs—expansion of treatment capa-
city, extension of sewers to service new areas, or upgrading
the level of pollutant removal by adding new components.
For example, can modular components be added for phosphorus
removal, nitrogen removal or different sludge handling pro-
cesses? Alternative systems should also be evaluated for
their flexibility in converting from treatment and dis-
charge systems to wastewater reclamation and reuse or
pollutant reuse.
The most flexible alternative of all may be the
one most conducive to cost-effective staging of treatment
plant construction.
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What Political/Institutional Factors Influence the Choice of
a Wastewater Treatment Alternative?
Governmental institutions have a major impact
on whether and how well waste management alternatives
are implemented, since agencies of government—federal,
state and local—ultimately approve the final alternative
and implement it through financing, construction, user
charges, industrial cost recovery schemes, and operation
and maintenance. Before EPA will approve a Facilities Plan
(prior to awarding a Step 2 grant), implementation and
management authority either must be held by appropriate
governing bodies or be available soon.
Besides legal authority to implement a facility
plan, local or regional agencies or special districts must
show the ability to finance construction, operation and
maintenance to meet federal and state requirements.
As a matter of practical politics, local govern-
ments favor local control over wastewater management
services within their boundaries. This attitude may
work against a regional treatment alternative or
against land treatment in some outlying areas because
distributing the costs of a regional system among the
local jurisdictions is often a touchy subject in local
politics. If a suburb currently is served by a package
treatment plant or on-site facilities for instance, its
residents and officials aren't likely to want to pay to
be connected to a large urban system, despite the fact
that their participation makes the regional system more
viable.
Local treatment facilities that must be approved
by a regional planning or policy body may encounter
opposition if local objectives conflict with regional
growth, land-use, or water quality goals. If approval
of a treatment alternative is not likely to be forthcoming
from the necessary jurisdictions, the alternative will be
rejected as "unimplementable."
What legal considerations affect the choice
of a sewage treatment alternative?
When choosing a treatment option, planners
must be aware of constitutional and statutory require-
ments of federal, state and local governments which can
make a difference in whether a plan will be implemented.
In addition to the water quality laws and regulations
discussed previously, planners should observe the follow-
ing legal provisions:
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Federal government. To receive a federal
grant, an applicant must meet many legal requirements
such as the Environmental Impact Statement requirements
of the National Environmental Policy Act and laws that
forbid discrimination on the basis of race, color,
national origin or sex. See Chapter I for a list of
some of these federal requirements.
State and local governments . Many states have
laws and constitutional provisions that could affect
the choice of a wastewater management alternative .
For example:
• Water rights provisions, particularly in
Western states, can affect the viability of land treat-
ment systems. A system that reduces flow in the water-
course for a downstream user may violate the water rights
of that user.
• Public health laws may affect disposal of
sludge, restrict the application of effluents to lands
for irrigation or subsurface disposal, or limit building
of ponds if they encourage mosquito or rodent populations
Other public health concerns for land application include
possible drifting of aerosol, potential spread of infec-
tion, bacterial contamination of vegetables, and ground-
water pollution.
Most detrimental health and hygiene aspects of
land application can be greatly reduced by proper waste-
water pretreatment and handling of effluents.
• Most states have laws and regulations that
govern on-site waste disposal facilities and municipal
water supplies, whether from reused waters or other
sources.
• Land use and comprehensive planning laws of
state or local governments may require that municipal
facilities conform to comprehensive land-use plans or
other land-use requirements, or be approved by regional
or other substate government agencies.
« ,Energy use and conservation provisions of
state governments may apply in certain jurisdictions.
• States also have a variety of laws and
constitutional provisions that govern powers of local
governments, such as financing authority, acquisition
rights and ownership capability; some provisions of
wastewater management may need special authorization
from state government.
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How Is the Wastewater Management System Financed?
How the various alternatives are to be financed,
the eligibility of a system for federal assistance
and the financing of costs not covered by grants are
crucial considerations in selecting the best management
system. For example, if two alternatives are equally
cost-effective but one has greater construction costs
which are eligible for federal funding, and the second
has greater O&M costs, which must be borne locally, a
community probably will choose the former.
The costs eligible for federal funding were
discussed in Chapter IV. Financing the local share
of construction and operation and maintenance costs
presents a complex set of issues (see Chapter II) .
How will a community finance its share
of construction costs and O&M costs?
After federal construction grant funds are
received, 15 to 25 percent of construction costs
(depending on the level of state assistance) will
remain to be financed. Added to this will be O&M
costs, which the federal government does not finance,
though there are federal requirements to develop a
satisfactory O&M plan as a condition of receiving the
construction grant. Frequently, system components that
are not eligible for federal funding can drive the local
share of costs to well over 25 percent.
Local costs can be financed in a number of ways:
with general tax revenues, special assessments on property
value, frontage assessments, connection fees, lot size
assessments, user charges, and industrial cost recovery.
Several of these revenue-raising devices can be used
simultaneously to finance different portions of a
sewerage system.
Some communities require developers to install
lateral sewers and house connections? the developers then
pass the costs on to home buyers. Local jurisdictions
may divide up financial responsibilities with towns
responsible for mains and submains, special sewer
districts for laterals and the county for the inter-
ceptors and treatment plant. By special agreement, a
large city may treat the wastes of a surrounding rural
county once the county collects the wastes.
Financing devices vary in economic efficiency,
equity, ability to raise adequate funds and administrative
simplicity. For example, using general revenues spreads
treatment costs among all taxpayers and imposes no marginal
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costs on users—and consequently ranks low on economic
efficiency. By contrast, periodic service or user
charges, based on the extent of use or some surrogate
measure of use, provide an incentive for the user to
reduce his discharge to the sewer system. Thus, user
charges are said to be economically efficient.
Another revenue mechanism, taxes based on
property values, can be imposed once or periodically.
Connection fees—one-time expenses to be paid
when the user begins service—are usually flat charges
baed on lot size and frontage. They may be imposed once
or periodically, but in either case provide no incentive
to reduce the load on the wastewater management system.
Ad valorem assessments imposed by service
districts (such as a sanitary district or local govern-
ment) on property within a special district are a form
of property tax paid by residents of the service area.
They can be a one-time tax or a periodic levy. Ad
valorem taxes are more specific to actual users of
treatment facilities than general revenues but are
not as closely related to use as service charges.
Special districts have used these ad valorem taxes
to pay for debt amortization (of the community's share
of capital expenses) and O&M expenses.
From 1974 until passage of the 1977 amendments,
the federal government did not allow the use of ad valorem
taxes to satisfy user charge requirement of the Federal
Water Pollution Control Act. In 1977, however, Congress
approved their use as residential and small nonresidential
user charges if EPA approves.
User charges are variable assessments based on,
actual discharges to sewers, or surrogate measures such
as fees based on water use, which is metered in many cities
A percentage of the water bill thus can be levied for
wastewater management. (Water use is closely but not
directly tied to wastewater discharges since some water
may be used in the yard or garden.) Wastewater flow ,
meters may be economical for use on industrial or large
commercial sources of wastewater to accurately assess
user charges.
What are the user charge provisions of federal law?
Every federally-funded project must have a system
of user charges to assure that each recipient of waste
treatment services will pay his proportionate share of
the cost of O&M, including replacement of equipment to
maintain capacity and performance over the life of the
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facility. User charges are intended both to provide
an economic incentive to pollution sources to control
wastes and to promote self-sufficiency of O&M at the
treatment works. Factors such as strength, volume and
delivery flow rate characteristics are to be considered
in developing a user charge system.
Itesidential user charges can be assessed by
metering sewage or water supply, ad valorem taxes or
other systems in which the user is notified of the portion
of his payment attributable to waste treatment services.
If meters are not used, users with similar flows and
wastewater characteristics may be grouped into categories
and user charges set so that each class pays its propor-
tional share of treatment costs.
User charges must be reviewed annually and
adjusted to reflect actual O&M costs. Charge systems
must be authorized in municipal law. Quantity discounts
to large users are not permitted—savings resulting from
economies of scale are apportioned to all users or user
classes. If user charges are based on a percentage of
the water use charge, the water charge must be based on
a constant cost per unit of consumption.
EPA regulations (Appendix B, 40 CFR Subpart E,
Part 35) provide three model user charge systems (described
in more detail in Appendix A to this book) .
What are industrial cost recovery (ICR) provisions?
In addition to user charges to cover O&M costs,
industrial users must pay a share of construction costs
attributable to the control of specific pollutants they
discharge that otherwise would not enter the system.
Small industrial users are exempt if they discharge
no more than 25,000 gallons per day of sanitary waste
(or its equivalent in process waste) that does not
disrupt operation of the treatment plant or the utility
of sludge.
During each year of the industrial cost recovery
(ICR) period—30 years or the useful life of the treatment
works, whichever is less—the industrial user must pay its
share of the total amount of the federal grant, divided
by the recovery period that is allocated to his use. At
a minimum, the industry's share must be proportional to
the ratio of its flow to the flow capacity of the treatment
works. Strength and volume must also be considered in
setting ICR charges.
The industrial user's share shall include only
that portion of the grant attributable to the part of
the treatment works he actually uses or has reserved for
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future use. Unallocated treatment works capacity is
not charged to him. The grantee (the community or region)
retains 50 percent of the industrial user charges and sends
the remainder to the U.S. Treasury. A minimum of 80 percent
of the resulting local income plus interest must be used
solely for expansion or reconstruction of treatment works
associated with the project. The remaining 20 percent
(of the 50 percent) may be used at the discretion of the
grantee.
Considerable controversy has surrounded implementation
of the industrial cost recovery requirements, particularly
in communities that have sought to encourage industrial
development and want to offer cost-free pollution control
as an added incentive.
Industry in fact already receives a substantial
federal subsidy when it treats its waste in a federally-
funded, publicly-owned treatment works—industrial users'
share of the facility's cost cannot be charged interest
on its share of the capital investment in the treatment
facility. (Just imagine the size of your total house
payment if it contained no interest component.)
Nonetheless, in 1977 amendments Congress directed
EPA to study the efficiency of and need for payment by
industrial users and report back within 12 months. Fur-
thermore, during the 18-months following the date of the
1977 amendments, EPA cannot require grant applicants to
enforce ICR provisions. Charges for these 18 months will
be due after that period unless Congress changes the ActM
A Case Example ^Choosing the Alternative
This is the actual case of a small town in the
Southeast that currently has no public management of
wastewater. The facts and circumstances are taken from
the town's facility plan and presented here to show how
treatment alternatives are evaluated.
The town's population: 3150. A Water District
provides water service to 436 people through 170 water
meters, of which 150 are located in the town itself.
The District includes 19 small businesses, one factory
and an elementary school. The District proposes to
provide sewerage service—it has prepared a 20-year
wastewater facilities plan and applied to EPA for grant
assistance.
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The planning area is about 2,300 acres. Over-
flowing septic tank systems are the only source of
wastewater discharges—-there are no known point sources
of wastewater effluent. About 20 percent of the homes
are located on soils with very low permeability, which
probably causes the periodic failure of the septic tanks.
The area's population is relatively stable, and the
District currently has a moderate growth rate, adding about
four customers a year. The factory, however, plans to expand.
Population is expected to grow by 50 to 100 percent in the
next 20 years.
The District sees a public wastewater system as a
key ingredient for future growth and improvements and as
remedy for the current disposal practices, which generate
health hazards and environmental pollution.
Some wastewater management alternatives were
initially rejected. Upgrading existing facilities—more
than 130 septic tanks and pit privies, inadequately designed
and poorly maintained-~to current septic tank technology
was considered impracticable, because the impermeable soils
were expected to make individual disposal systems inadequate.
Regional solutions were much too costly—as the
nearest existing treatment facility is 17 miles away.
The capital costs of sewers, force mains and pumping
stations to deliver the District's small flow to that
plant would exceed $1 million, nine times the cost of
any local alternative.
Monetary Evaluation
The District analyzed the complete spectrum of
waste treatment alternatives and evaluated four basic
alternatives in detail. Cost-effectiveness analyses
were prepared for these choices:
® Alternative No. 1. A conventional gravity
sewer system with a central treatment faci-
lity. The least expensive treatment option
was an oxidation lagoon, followed by an in-
filtration-percolation land treatment system.
Another option-—aerated reactor tanks followed
by soil infiltration-percolation—was rejected
as slightly more expensive.
® Alternative No . 2 . Similar treatment process,
but most of the sewer system would employ
effluent sewers, where solids in wastewater
are removed by septic tanks and stored near
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each source, and only the liquid effluent
from the septic tanks it pumped to the central
treatment site. The effluent sewer system
consists of interceptor tanks and siphons
or heavy duty sump pumps, with small
diameter plastic sewer lines carrying
effluent to a central oxidation pond for
additional treatment.
• Alternative No . 3 was developed to further
reduce total costs. It involves the use of
short stretches of "effluent sewer" (similar
to sewers in Alternative No. 2) but the septic
tank effluent would be carried directly to a
disposal site. At least 122 customers would be
grouped on short sewers and the effluent disposed
of at 22 separate "community" sites. It is also
recommended that new individual disposal systems
be provided for an additional 22 customers. Pro-
vision of services to the elementary school and
to the factory would be an option that would not
affect the relative costs of the four alternatives
but could reduce the average charges per customer.
Even without the school and industry sharing the
costs, the user costs for this alternative would
be significantly lower than for the previous two
—user costs were estimated to be just 58 percent
of those required for Alternative No. 2, while
present worth was about 21 percent lower than
Alternative No. 2 and 42 percent lower than
Alternative No. 1.
• Alternative No . 4 was considered for purposes of
comparison. It consisted of on-site disposal for
the all of the 144 customers included in Alternative
No. 3. Critical problems of implementation and
design caused this alternate to be rejected.
The present worth calculation for the four alternatives
follows:
ALTERNATIVE NO . 1
A. Conventional Sewer System:
Present Worth - Gravity System
Initial Capital: $339,600
Operating Costs, year 1-20: 9,000
Salvage Value at end of 20 yrs: 169,800
PW of initial capital: 339,600
PW of operating costs= $9,000x11.354= 102,186
Total: $441,786
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Less: PW of Salvage Value=
$169,800 x 0.3045 = (-) 51,704
Net Present Worth: $390,082
Present worth is calculated by adding up initial
construction cost, operating costs, (when operating costs
change during the 20-year period, two costs and two factors
are used; these are then multiplied by a factor converting
operating costs to a present worth) . The present worth of
salvage value and land is then subtracted. (These costs
are presented here in summary form. In an actual Facilities
Plan the construction costs would be broken down in more
detail, as shown in Table 7.)
B. Two-acre lagoon:
Initial Construction Capital $69,990
Land Capital (may be donated) 10,500
Present Worth of Operating-
Maintenance Cost, yrs. 1-20=
$1,000 x 11.354 11,354
Total $91,844
Less: Salvage Value at 20 yrs.:
-(23,340 + 10,400) x 0.3045 = (-) 10,274
Net Present Worth $81.570
C. Disposal Basin:
Present Worth—Infiltration Basin
Initial Construction Capital $16,770
Present Worth of Expansion Capital=
$3,200 x 0.552 1,766
Present Worth of Annual Operation &
Maintenance, yrs. 1-10=$3,000x7 .317 21,951
Present Worth of Annual Operation &
Maintenance, yrs. 11-20=
$4,000x7,317x0.552 16,156
Total $56,643
Less: Present Worth of Salvage Value
of Permanent Improvements and Land
at 20 yrs.: (1,920+7,060)xO.304 (-) 2,730
Net Present Worth $53,913
Before selecting an infiltration basin, sand filtra-
tion and spray irrigation were considered as disposal tech-
niques. These were rejected as more costly than infiltration.
TOTAL COSTS (components A, B, C) ALTERNATIVE 1. $525,600
ALTERNATIVE NO. 2. Effluent Sewer System with Central
Oxidation Pond and Infiltration Basin
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Sewer System
Initial Construction Capital $196,700
Present Worth of Expansion Capital 18,018
Present Worth of Constant Operating
Cost = $5,860 x 11.354 66,534
Present Worth of Varying Operating
Cost = $40 x 85.594 3,424
Total Present Worth of Sewer System $284,676
(Initial Capital) $98,350 x 0.3045 29,948
Present Worth of Salvage Value of
Expansion Capital $33,000 x 0.237 (-) 7,820
Total Salvage Value (-) $37,768
Present Worth of Treatment Lagoon
(from Alternative No. 1) 31,600
Present Worth of Disposal Basin
(from Alternative No. 1) 53,900
Net Present Worth $382,000
ALTERNATIVE NO. 3. Community Subsurface Disposal System
Initial Construction Capital $226,800
Present Worth of Expansion Capital 43,243
Present Worth of Constant Operating
Cost = $6,110 x 11.345 69,372
Present Worth of Varying Operating Cost:
$60 x 85.594 5,136
Subtotal $344,551
Less: Present Worth of Salvage Value:
(75,600 + 61,700) x 0.0345 (-) 41,807
Net Present Worth $302,744
These calculations assume a 74-gallon per capita
wastewater flow and an average occupancy rate of 2.7 persons
per household. All existing septic tanks would be modified
or replaced to provide two settling compartments and improved
design of overflowdevices. The unit cost for this improve-
ment is $200. An electric pump would be installed near or as
a part of each septic tank. Homes were grouped in several
patterns to meet the sometimes conflicting goals of lowest
cost, simplicity of operation, disposal in more suitable
soils and amenability to future growth.
All on-site or off-site wastewater facilities would
be publicly-owned and managed, including septic tanks, sewers
and treatment-disposal facilities. Public management is
considered essential to overcome poor on-site subsurface
disposal. Easements or subsurface development rights would
be purchased from private land owners.
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ALTERNATIVE NO. 4. Community Management of Individual
On-Site Disposal
Initial Construction Capital $190,200
Present Worth of Expansion Capital 41,000
Present Worth of Constant Operating
Cost = $5,000 x 11.354 56,770
Present Worth of Varying Operating
Cost = $60 x 85.594 5,136
Subtotal $293,106
Less: Salvage Value at 20 yrs. =
($63,400 + 18,000) x 0.3045 (-) 24,786
Net Present Worth - $268,320
Total on-site disposal by individuals eliminates
part of the land acquisition and ownership costs raised
in Alternative No. 3. Only utility easements would be
needed to provide access to facilities for maintenance
and repairs by the Water District.
SUMMARY OF PRESENT WORTH FOR THE FOUR ALTERNATIVES
Alternative
Item 1234
Sewers
Treatment
Disposal
Total
$390,100
81,600
53,900
$525,600
$246,900
81,600
53,900
$382,400 $302,700
$268,300
By avoiding the costs of sewer construction and
maintenance, Alternative No. 4 would have the lowest capital
and operating costs, therefore, the lowest present worth.
However, about 20 percent of existing occupied structures
are located on soils that severely limit on-site disposal.
The next lowest in present worth was Alternative
No. 3, the community subsurface disposal system, which was
11 percent more expensive than No. 4. However, the cost
estimates of Alternative No. 3 were more likely to be
accurate since it had fewer uncertainties in construction
and operation. Thus, nonmonetary factor were more signifi-
cant in deciding between the two.
Nonmonetary Evaluation
Primary and secondary environmental effects. All
four basic alternatives would meet the effluent criteria and
other environmental criteria. In the actual Facilities Plan
the environmental effects were qualitatively evaluated in
detail and then assigned a number from 1 (best) to 4 (worst).
(The quantified environment effects of the four basic alter-
natives are summarized in Table 8.)
Alternatives No. 1 and No. 2 had considerably larger
erosion losses because of construction of conventional gravity
sewer systems and lagoons with disposal in an infiltration
basin. Alternatives No. 1 and No. 2 tended to produce signifi-
cantly more noise because of sewer construction.
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As for development effects, conventional gravity
sewers were considered to stimulate slightly more growth
and new industry to move to an area where excess capacity
exists in a sewerage system. Thus, Alternative No. 1 was
considered to have greater potential for secondary impacts
than 2, 3, and 4. However, this is a rural community, and
other factors, such as labor supply, transportation, etc.,
are at least as influential on growth as sewer service.
Thus, all alternatives were considered to have only slight
secondary impacts.
Implementation. All alternatives could be implemented
legally by the Water District. Alternatives 3 and 4 are less
common techniques, therefore, could require additional time for
local, state and federal approvals. However, since Alternatives
1 and 2 may require a trained operator, and in any case require
more local funds, potential users may object to the user charge.
Since the Water District would operate wastewater ser-
vices, and is an organization known to and generally approved
by local users, it is likely to perform satisfactorily to imple-
ment construction, operation and maintenance, as well as collec-
ting user fees and recovering industrial costs. Also, Water
District Commissioners would have legal authority to require
use of the system. The fourth alternative is likely to be par-
ticularly difficult to implement since 20 percent of the homes
are located on soils with low permeability.
Generally, none of the alternatives has any overwhelming
advantage for implemention.
Alternative No. 2 was considered better than No. 1,
since removing 70 percent of suspended solids and 50 percent
of BOD in the interceptor tanks reduces the organic load in
the stream and reduces the environmental effect of accidental
discharges from the sewer system. Alternative No. 3 was consid-
ered ecologically sound since accidental sewer discharges are
minimized and nutrients are returned to the land.
Alternatives 3 and 4 also avoid the need to upgrade
treatment facilities to meet changing standards for effluent
discharges to surface waters. Alternative No. 3 minimizes system
complexity and reduces O&M costs. Alternatives 3 and 4 also
have more rational planning of community growth since strip
growth could be encouraged by conventional sewers. Alternatives
3 and 4 would not produce odors, while odors may occur from
a treatment facility.
In general, environmental effects did not differ greatly
for the four alternatives, partly because of the small size
of the project, lack of truly sensitive environmental features
and the relatively slow rate of growth.
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Plan Selection. Public hearings were held on
the alternatives after the costs and effects from each
were predicted. Generally, Alternative No. 3 was pre-
ferred due to lower total cost and simplicity of opera-
tion. The cost of community wastewater management was
thought to about equal the cost of privately maintaining
and replacing existing septic tank systems—about $7 per
month for an average user charge. By contrast, the con-
ventional sewers and central treatment was expected to
cost $15 per month.
Alternative 3 was selected by the community and
funded by EPA.
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CONTENTS
CHAPTER VI
Page
Whar Are the Broad Requirements for Public Involvement
Under the Clean Water Act? 161
What's In It for You? Why Get Involved? 161
Incorporating public values 162
Better plans 162
Assuring reasonable costs .... 162
Added community benefits .162
Voter support 163
Resolution of controversies ... 163
Which Major Federal Regulations Give You Access to the
Facilities Planning Process? 163
The Basic Public Participation Program 165
The Full-Scale Public Participation Program (FSPP) 167
Other public participation requirements applicable
to the basic and full-scale programs 170
How Will Public Participation Regulations be Enforced?
Who Will Enforce Them? 172
How Will Regulations Affect What Happens in Your
Community? • 173
How Should a Public Participation Program Be Developed?
What Will Be Its Major Components? 174
Who is the public? 177
What Are the Public Participation Tools? 178
What Problems Might Be Encountered in the Implementation of
Public Participation Requirements?
A historical perspective
Institutional resistance
-------
What Are the Rewards of Public Involvement in the Facilities
Planning Process?
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CHAPTER VI
PUBLIC INVOLVEMENT IN FACILITIES PLANNING
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 deci-
sion-making. These requirements are found in Section
Public participation in the development,
revision, and enforcement of any regula-
tion, standard, effluent limitation, plan,
or program established by the Administra-
tor (of the Environmental Protection Agency)
or any State under this Act shall be pro-
vided 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 prob-
lems, unless they pose some personal threat to him, his family,
or his community. A foul-smelling treatment plant in the neigh-
borhood, sewage seeping up in the street, or escalating treat-
ment costs will grab his attention. But not planning. But when
you get right down to it, wastewater facilities are essential to
a community. They can significantly enhance or degrade its en-
vironment, depending on how well they are planned.
Good planning means more than just professional compe-
tence. It means considering a community's character, its en-
vironmental 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
Some portions of this chapter are based on manuscript written
by Char White.
161
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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 pro-
ject's long-term benefits.
- Incorporating public values
Local residents often have a more intimate understanding
of particular community problems than the staff or consultants
working on 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 determin-
ing 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
pollution 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 responsi-
bility for it. They will be the ones who will walk the extra mile
to secure added benefits--shoreline protection, swimming, boating,
biking, and so on—that make the difference between an ordinary
project and an outstanding one.
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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 referred to here have not yet been promul-
aated, but are in final stages of approval at EPA, and
should appear in final form in the Federal Register in
February.
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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 EPAs 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-
tions:
« 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;
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» 40 CFR Subpart E, Part 35.929-2(e): General
Requirements for all User Charge System;
• 40 CFR Subpart E, Part 35.940-l(t)i Allowable
Project Costs?
o 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
must:
1. develop a public information program designed
to bring about public involvement from the earliest stages of
the decision-making process. This program must:
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• be a continuing program that provides
policy, technical information and assis-
tance, and that highlights significant
issues?
• 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.
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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 situations
and screening alternatives (but before selecting the actual al-
ternatives to be evaluated during cost-effectiveness analysis).
A reponsiveness summary must be prepared and distributed 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 signifi-
cance 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 conditions:
• 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;
Public Involvement Activities Guide.
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• where the advanced wastewater treatment
(AWT) is required to mee"t 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
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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.
e 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-
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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 on pages 164 and 165. 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.
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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 docu-
ment copied for $.25 a page, a local government grantee or his
consultant should not charge you $2 a page to copy that docu-
ment. 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 satis-
factory, you may wish to complain to the EPA Regional Adminis-
trator (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 nbt 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 determina-
tions 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 at the hearing; and
171
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• 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-
sulted ;
• 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
that 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
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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 TheseRegulations Affect What Happens in Your
Commun i ty?
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 eligibi-
lity 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;
173
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• the significant publics in your community
in fact participate in the facilities
planning process;
• the publics that are asked to be involved are
sufficiently informed of the issues to partici-
pate affectively; and
• the views of the public are listened to and
responded to by the grantee and his consultant.
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
development.
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 development of the Plan
of Study is not eligible for construction grant funds. None-
theless, this early outline will be extremely important since
its 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 work-
plan 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 spend on public participation in Step 1
planning.
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Tables 9 through 15 at the end of this chapter are
designed to help you to develop a Plan of Study outline and a
workplan. Table 1, 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 10 through 15 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 grant-
ee in your community to use some version of these model work-
plans in its submissions to EPA. (Please note that these work-
plans were designed for communities of roughly 5,000-10,000
people. Your public participation workplan may vary consider-
ably depending upon the size of your continuity 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 outsets
1. identifying major community issues to be
addressed during facilities planning, including among others—
• growth, land-use issues;
9 sensitive environmental areas;
• costs to the community and per household;
and
« 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;
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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
involvement.
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 time's. 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,
176
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may be more affected than others depending on the proposed
project.
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
measures.
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
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the facility and provide for mitigation of site and odor
problems.
What Are the Public Participation Tools?
Public participation can cover a wide range of activi-
ties designed to inform and involve the public. Most of the
mechanisms of public participation fit into one of three cate-
gories, as indicated by the Chart below: *
Education/Information Review/Reaction Interaction/Dialogue11
Newspaper Articles
Radio and TV Programs
Speechs and
Presentations
Field Trips
Exhibits
School Programs
Films
Brochures
Newsletters
Reports
Letters
Conferences
Public Hearings Workshops
Survey
Questionnaires
Public Inquirers
Public Meetings
Special Task Forces
Interviews
Advisory Boards
Informal Contacts
Study Group
Discussions
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 unde-
standing; and
c. Provide access to planning documents and other
relevant information;
**
Katherine P. Warner, "Public Participation in Water Resources
Planning," University of Michigan, Ann Arbor, 1971.
The book entitled Municipal Wastewater Management;
Public Involvement Activities Guide, designed as a companion
piece to this book, describes in more detail various public
involvement tools.
178
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d. Provide information on opportunities for public
participation; and
e. Elicit reaction to potential decisions.
In a program for the general public, these points are
listed correctly in describing order of priority. An informa-
tion program aimed at the organized public, however, would give
its greatest emphasis to the last three purposes and, ideally
ttrnii 1 fl inr'liiHo an arlrli 4- i rma 1 i~>n VT-\«~IOC* •
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 knowledgable about inter-
pretating statistics, computerized data, and highly sophisticated
reports. Such groups should be given opportunties 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
within the framework of EPA regulations, be creative in your
interpretation of these regulations. Certain parts of the re-
gulations may be more flexible than is initially apparent. For
example, both the basic and full-scale public participation pro-
grams require public meetings to consider the issues raised at
specific decision points. A public meeting, however, is simply
a gathering of individuals to interact face-to-face. There are
many different kinds of public meetings. For example:
• meetings designed to accomplish a task;
• meetings designed to identify and negotiate
conflicts;
• open forums simply intended to air a variety
of viewpoints; and
• large mass meetngs 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;
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* an already scheduled town meeting may focus its
attention on facilities planning issues needing
resolution.
Even the apparently rigid structure and roles of advisory
committees specified by regulation sometimes lend themselves to
flexible interpretation. Variations can be expected in different
communities in:
• membership (what economic interests
are represented? What types of local
government officials, of public inter-
est representatives?)
• size (will the advisory committee
have 10 members of 30 members?)
• roles and responsibilities (will the
advisory committee have some respon-
sibility for the execution of the
public involvement program? To what
degree will the advisory committee
periodically expand its membership
through ad hoc task forces?)
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
1 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.
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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 requirement^ that did exist (i.e., a
public participation summary that would allow an approving
agency to make a judgment concerning the adequacy of public
involvement) were virtually ignored. EPA never issued cri-
teria for judging the adequacy of public involvement programs.
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.
1 !
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.
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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
regulations;
• the large number of federal regulations that
local and state governments already have to
deal with in the Construction Grants Program;
and
® 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
alternative?
o a lack of understanding of how to interpret
public participation regulations on the part
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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
conditions:
• lack of understanding of how the facilities
planning process touches the lives of the
people in the community;
0 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.
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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
chapter).
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;
9 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.
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1.
Decision Points
State delineation
of facility plan-
ning areas.
oo
cn
2.
Criteria for state
priority list.
Table 9
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.
c)
a) Factsheet
b) Public hearing (with
30 days' notice)
a)
c) Responsiveness summary b)
submitted to EPA.
c)
d)
e)
Issues to be
Resolved
Are boundaries suf-
ificent to assess
potential environ-
mental impacts?
Do they allow for
maximum treatment
options?
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-
ority?
Are rural pollution
problems being ad-
dressed?
How are priorities
established within
"set asides."
Recommended Public
Participation
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
interested.
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
Responsiveness
Summary to hearing
d) Summary of agency
response to citizen
input.
Are innovative and
alternative systems given
given high priority?
Discussion
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 whack 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
3. State priority
list.
Public Participation
Requi rements
a) Circulate statewide a)
information about
priority list (or any
major revision thereto).
b)
b) 30-day advance notice
before public hearing
4. Preapplication
Conference.
None,
oo
5. Selection of
engineer.
None.
a)
b)
c)
a)
b)
c)
Issues to be
Resoloved
Does list relate to
established, cri-
teria?
Are innovative solu-
tions fully funded?
Recommended Public
Participation
a) Pact sheets which indi>-
cate the nature of pol-
lution problem and the
scope of the proposed
project.
b) Direct mailings to
groups and individuals
known to be interested.
c) Public notification
hearing thru press,
media and mailings.
Responsibilities of
state and local
governments.
Time schedule.
Explanation of pro-
cess and require-
ments .
Does engineer have
experience with inno-
vative treatment
systems?
a)
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?
of
d) Summary of agency re*-
sponsiveness.
a) Establish a Citizens'
Advisory Committee.
If CAC is established.
Advisory Committee
interview with engineer
candidates; or, if no
CAC yet, establish an
Engineer Selection
Committee
Distribute information
about candidates and
their previous exper-
ience .
Discussion
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-
ingful.
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-
ence.
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 a.t'this point.
-------
Decision Points
6. Plan of Study.
(POS)
Public Participation
Requi r einent s
Notify and consult
with public.
Develop brief outline
of public participa-
tion program.
7.
A-95 Review of
POS
Clearinghouse
comments
00
8.
State review of
POS.
Review adequacy of
public participation
outline in P.O.S.
Issues to be
Resolved
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
tasks.
c) Reasonable cost
estimates.
Recommended Public
Participation
a) CAC, if established
should review POS and
make recommendations
for public participa-
tion.
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 th
-------
Decision Points
8. State review
of POS
cont'd.
9. EPA review
of POS
(May principally
be State Review
in the case of
of a delegated
program)
Public Participation
Requirements
d)
00
00
10. Award of Step
I grant.
a) Review ade- a)
quacy of public
participation
work element in
POS
b) Determine whether b)
public participa-
tion program should
be Basic or Full
Scale.
c) How will the Faci-
lities Planning
Process be coor-
dinated with 208
planning?
a) Hire public parti- a)
cipation coor-
dinator*
b) Grantee informs b)
public of oppor-
tunities to serve
on Citizens Ad-
visory Committee
(CAC)*
c) Establish CAC*
Issues to be
Resolved
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
list.
Is public participa-
tion adequately pro-
vided for?
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?
Recommended Public
Participation
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.
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
specialist.
Discussion
Use the media to publi-
cize the controver.sy
only after you have
determined differences
cannot be resolved thru
discussions and nego-
tiations.
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.
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
-------
10.
Decision Points
Award of Step
I grant.
cont'd.
00
vo
11.
Infiltration/
inflow Analysis
Public Participation
Requirements
d) Develop mailing
list of inter-
ested and
affected indi-
viduals.
e) Establish staff
contact for CAC
(May be public
participation
coordinator}
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
project
h) Develop and Insti-
tute a public in-
formation program
i) Establish informa-
ation depository
j) Train CAC members*
None
c)
d)
a)
b)
Issues to be
Resolved
Have the appropriate
issues for public
involvement been
identified?
What kinds of infor-
mation will facili-
tate public involve-
ment?
Recommended Public
Participation
Discussion
what parts of the
system need rehabi-
litation because of
groundwater leakage?
Might rehabilita-
tion take the place
of new sewage treat-
ment capacity?
a) CAC review and com-
ment.
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
situation.
Public Participation
Requirements
a) Consult with
public after 30
days notice
a)
b) Hold a public meet-
ing*
c) Prepare and distri-
bute Responsiveness
Summary
(these requirements b)
must take place no
later than Decision
#15)
c)
V£>
O
13. Environmental
Assessment
(See #12)
a)
Issues to be
Resolved
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
sources of these
flows known?
d)
Recommended Public
Participation
A public participation
speciaiist 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
situations
2) sensitive environ-
mental and social
concerns.
Have all environmen-
tally sensitive area
within planning
boundaries been
adequately consi-
dered?
See recommended participa-
tion in steps 12, 13, 14,
15 and 16.
Discussion
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
action.
t-
vi
c
The Environmental assess-
ment is an analysis of tha
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
-------
13.
Decision Points
Environmental
Assessment
cont'd.
Public Participation
Requirements
b)
14.
vo
Decision to
"Piggy-back" an
Environmental
Impact Statement
(EIS)
(See #12)
c)
a)
Issues to be
Resolved
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
assessment?
Recommended Public
Participation
15.
Assess future
situation.
(See *12)
a) Mid-Project*
Evaluation by EPA
(or State) of com-
pliance with public
participation re-
quirements .
a)
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?
CAC reviews and makes
recommendations.
Workshop or public
meetings to discuss
issues.
Fact sheets should be
prepared and dissem-
inated.
Discussion
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 "raid project" point.
-------
Decision Points
15. Assess future
situation
cont'd.
Public Participation
Requirements
Issues to be
Resolved
b) Are population
projections con-
sistent with BEA*
projections or with
significant new
growth being planned
for?
Recommended Public
Participation
d) Interest newspaper
in doing feature
article.
Discussion
16. Cost Effective-
ness analysis
a) After 30 days
'notice, public
meeting
b) Responsiveness
summary
10
to
c) Are planned future
industrial flows
adequately documented?
Are they consistent
with community plans?
a) Is the planning
period reasonable?
b) Are the maximum
number of alterna-
tives being, con-
sidered?
c) To what degree are
flow and waste level
forecasts accurate?
Does the facilities
plan contemplate an
aggressive Flow
Reduction program?
d) Has appropriate atten-
.±ion 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.
a) CAC review of impor-
tant decision points
and recommendations
on same.
b) Public meetings and
workshops, including
CAC grantee and con-
sultant participation.
c) Fact sheet and other
information dissemin-
ated.
d) On large projects
public may need to
be reached through
neighborhood meet-
ings, telephone
committees.
Public scrutiny of alter-
natives prior to the en-
gineers' preliminary
selection of an alterna-
tive is very important.
The cost 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
-------
16.
Decision Points
Cost Effective-
ness analysis
cont'd.
Public Participation
Requirements
CO
17.
Sewer System
Evaluation Survey
Survey
None.
18.
Historical and
Archeological
investigations.
None.
Issues to be
Resolved
e) Which alternative e)
has the least mone-
tary cost 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?
Recommended Public
Participation
Encourage the use of
speakers bureau, mul-
timedia presentations,
community options dis-
play at organizational
meetings.
Request that special task
forces be set up if major
issues need more concen-
trated scrutiny.
Discussion
Brief CAC on progress
of evaluation.
Keep public aware of
progress through mail-
ings of newsletters
and informational
material.<
a) Are historic or archeo-a)
logical sites affected
by the alternatives
chosen?
b)
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
possible.
-------
19.
Decision Points
Selection of
Alternative
20.
A-9 5 review of
Facility Plan
*>•
Public Participation
Requirements
a) 30 days notice
before public
hearing.
b) Final respon-
siveness summary
with evaluation
by grantee of
effectiveness of
public partici-
pation program.
a)
b)
Issues to be
Resolved
Is the selected
alternative the
most cost-effec-
tive alternative
to meet community
needs?
To what degree
have the environ-
mental social and
economic impacts
of the recommended
alternatives been
mitigated?
Clearinghouse
comment.
a)
b)
Is plan in accord
with all areawide
plans?.
Will the alternative
selected eliminate
the problem?
Recommended Public
Participation
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
program.
a) Request to'be heard
during review if plan
is felt to be inade-
quate or public input
has not been adequate-
ly considered.
21.
State review of
Facility Plan.
(See 122 below)
a)
Does plan comply with a)
basin and 208 planning?
Present comments to
state agency if in
disagreement with
selection of alter-
native.
Discussion
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.
b) Ask state to notify public
of certification or refusal
of plan and the basis for
its action.
-------
22.
Discussion Points
EPA review of
Facility Plan
(May be princi-
pally state re-
view in case of
delegated pro-
gram)
23.
Environmental
Impact Statement
ui
24.
EPA Award of
Step 2 grant.
Public Participation
Requirements
a) Evaluation of
adequacy of
public parti-
cipation pro-
gram.
b) If public par-
ticipation found
inadequate recom-
mended remedial
actions.
Public hearing.
a)
Issues to be
Resolved
Is the alternative
cost effective?
b) Have all require-
ments been met?
c) Has adequate public
participation
occurred?
d) Should an environ-
mental impact state-
ment be prepared?
a)
b)
a)
b)
c)
Have all possible
alternatives inclu-
ding "no action" re-
ceived adequate con-
sideration?
a)
b)
Have environmental
impacts of all options
been adequately c)
assessed?
Can negative impacts
of recommended alter-
natives be mitigated?
d)
(Award contingent on Step a)
1 approval.)
a) Consultation with
public regarding
necessity of addi-
tional public par- a) User charge system
ticipation.
b) Public participa-
tion workplan if
additional PP
deemed necessary
b) Industrial cost
recovery (ICR) system.
b)
c)
c) Inform public of
financial impact of
user charge system.
Recommended Public
Participation
Make known any comments
or views not expressed
in foreworded Facility
Plan.
Request agency notifi-
cation of determina-
tion of plan.
CAC involvement in
weighing environmental
factors and determining
alternatives.
Widespread dissemina-
tion of information.
Workshop and meetings to
discuss impacts, alter-
natives.
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.
Discussion
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
cont'd.
25. Step 3 grant
award.
Public Participation
Requirements
d) Consult with public
prior to adoption
of user charge and
Industrial cost
Recovery system.
Issues to be
Resolved
Recommended Public
Participation
None.
a) Any primary impacts a)
of construction such
as noise, soil erosion,
air pollution, runoff, b)
CAC should continue
to function as needed.
Periodic information
on progress, user
charge/ICR ordinances,
or implementation
should be disseminated.
Discussion
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-
pleted.
vo
-------
Table 1O
DECISION POINT
Grant Award
Select Engineer
Information Program
Public Participation
workplan
jgvgjljoj^
Assessment of present
and future situation
VO
Consideration of
Alternatives
Submission of Final
Plan to town
Town Approval State/
EPA Review and EIS
Decision
TECHNIQUE
MODEL
PLAN OF STUDY OUTLINE
BASIC PROGRAM (town of 10,000)
SCHEDULE
Public notice
Identify public liaison on grantee/
consultant staff2
Public notice to media and mailing
list of depository and materials
available
Identify key interests and develop
project mailing list
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
project1
wk. 1
wk, 2
wks. 6-7
wks. 3-4
wk. 5
Interview 208 PAC members3 mos.
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
- Develop and distribute factsheets3 mos. 7-9
- Notice of public meeting^
- Public meeting1
~ Prepare article for local newspaper 3
- Agency responsiveness summary
- Distribute factsheet 3
- Not ice of public hearing
- Public hearing
- Agency responsiveness summary ^
- Final responsiveness summary ^ mo. 11
Note :
^Required by proposed Part 35
2 Required by proposed Part 25
3 Meets a performance standard of Parts 25 and/or 35
STAFF SUPPORT
Grantee and/or
consultant
TARGET AUDIENCE
Consultant,
Public liaison
on grantee or
consultant staff
Key citizen leaders who
express interest in
participating
Mailing List
Consultant
Consultant
Public liaison
Consultant
Public liaison
Public liaison
Public liaison
Public liaison
Public liaison,
consultant,
grantee
Public liaison
Public liaison
Public liaison
Public liaison
Consultant,
grantee
208 PAC members
Public health officer,
town engineer, town
planner, regional plan
ners, conservation cam-
mi ss ion member s, repre
sentative of local in-
dustry , chamber o f com-
merce, etc.
Mailing list
PTA , JC's, Grange, LWV
Available to general
public, prepared for
EPA
Mailing list
Mailing list
General public
General public
General public-
Mailing list
Ma i1 ing list
General public
-------
Table 11
DECISION POINT
1. Step 1 grant award
TECHNIQUE
PUBLIC PARTICIPATION WORKPLAN
BASIC PROGRAM (town of 10,000)
Hire public liaison
Develop mailing list
Develop Public Participation Workplan
Distribute PPWP and Fact Sheet
SCHEDULE
wks. 1-6
Public: liaison
TARGET AUDIENCE
General public
2. Assessment of
present and
future situation
Interview 208 PAC and/or CAC members wks. 9-10 Consultant
- 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
In-terview key local officials and citizens wks. 11-12 Consultant
- identify major water quality problems/
issues
- identify community goals and objectives
Members of 208 PAC and
CAC
Public health officer
Town engineers,
Planners
Conservation Commis-
sion members
Industrial discharger;
Chamber of Commerce
vo
00
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
activities
- identifies staff contacts
wk. 13
Public liaison
General public
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
Attend various local group meetings^ wks, 17-20
Get on the agenda of various civic
crroups ' 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
Public liaison on
consultant or
grantee's staff
All registered Voters
wks. 15-16 Public liaison
Consultant/public
1 iaison
PTA, JC'st Grange,
League of Women
Voters. Sierra Clnb
Prepare agency responsiveness summary
- 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
wk. 22
Public liaison
Note: f Required by proposed Part 35
Required by proposed Part 25
^Meets a performance standard of Parts 25 and/or 35
-------
V£>
VO
Table 11 cont'd.
DECISION POINT
3. Consideration of
Alternatives
4. Submission of
Final Plan to town
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 environmental7 impacts of each •*
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 ^
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 Summary* wk. 48
Place on file at local libraries, Town
Hall
STAFF
.SUPPORT
Public liaison
Public liaison
Consultant, pub-
lic liaison,
grantee
Public liaison
Public liaison
Public liaison
Public liaison
Public liaison,
consultant,
grantee
Public liaison
Public liaison
TARGET AUDIENCE
Mailing list
Mailing list
General public
General public
EPA
Mailing list
General public, mailing
list
General public
General public
EPA
Note: 1 Required by proposed Part 35
2 Required by proposed Part 25
3 Meets a performance standard of Parts 25 and/or 35
-------
Table 12
BUDGET
BASIC PUBLIC PARTICIPATION PROGRAM
Salaries
Public Liaison
Consultant Staff
Secretary
Travel
$.15/mile - approx. 1,000 miles
Printing
Postage
Phone
TOTAL
Notes:
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
students).
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.
200
-------
Table 13
DECISION PQIMT
Award of Step 1 Grant
1. Engineer selection
2. Initiate prelim-
inary stages of
public participa-
tion plan of study
(work element of)
MODEIi
PI.AH OF STUDY
FULL-SCALE PUBLIC PARTICIPATION
SCHEDULE
a) public notice ' wk. 1
b) informal meeting w/key interests
a) grantee hire public participation wk. 2
coordinator
b) consulting firm designates public liaison^ wk. 2
c) begin to develop mailing list2 wks. 1-3
d) deposit key documents in town library
e) public notice regarding availability of wks. 1-3
documents
f) establish citizen advisory committee1 ' wk. 3
1) notice to mailing list and media
of opportunity to become member
2) notice to mailing list and media
of finally selected members.3
g) public notice w/factsheet of first CAC wk. 3
meeting to review public participation
workplan. Factsheet will describe project,
Notice will include list of advisory com-
mittee and engineer. ^
h) train advisory committee members and wk . 6
grantee in one-day workshop. Purpose
will be to briefly review town's water
quality problems, need for action, role
of CAC, types of conflicts and tradeoffs
likely. Establish goals of CAC. Workshop
run by grantee and consulting engineer.
3. Review public parti- a) Public CAC meeting to review public partici- wk . 5
cipation work element.
Develop public par-
ticipation workplan
pation workplan
STAFF
SUPPORT
grantee
grantee
consultant
grantee
grantee
public part.
coor.
grantee
b) Revised public participation workpIan
sent to EPA1
wks. 6-7
public part.
coor.
grantee
Grantee,
public part.
coor .
public part.
coor.
TARGET AUDIENCE
Range of community interest
that will ultimately be
on advisory committee
environmental
c ivic
business
1 a bo r
Volunteer community leader
w/organlzational skills
and knowledge of water
quality
All those private and public
interests with a potential
interest in the Facility
Plan. Some of the list
will be obtained from the
208 agency.
Mailing list media
Members of local org(aniza-
tions such as:
League of Women Voters
Chamber of Commerce
Sierra Club
Tax Payers Association
Local Union
Minority Group *
Mailing list
Newspapers
CAC members, engineer,
town officials, state
officials
Broad range of community
interests, CAC, consul-
ting engineer, grantee
representative
Note: ^Required by proposed Part 35
-------
Table 13 cont'd.
DECISION POINT
Development of Facility
Plan
TECHNIQUE
SCHEDULE
STAFF
SUPPORT
TARGET AUDIENCE
1. Assess current
situation
O
1-0
2. Assess future
situation
3. Consideration of
alternatives
Cost-Effective-
ness analysis
4. Engineer's Recom-
mendation on Pre-
ferred Alternative
5. Town Approval
6. Application for
Step 2 Grant
a) begin monthly newsletter^
b) informal consultation/interviews3
c) joint 201-208 staff and CAC meeting3
a) field trip3
b) speakers bureau3
c) series of workshops on special issues^
1) Sensitive Environmental Areas
2) Residential and Industrial Growth
d) public meeting 1
e) agency responsiveness summary1
a) factsheet on alternatives2
b) speakers bureau continues 3
c) CAC mid-study briefing3
d) public meeting^-
e) agency responsiveness summaryl
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 i
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
coordinator
public participation
coordinator, consult-
ant's public liaison
public participation
coordinator, grantee
rep., consultant
staff and public
liaison
public part. coor.
CAC, consulting
engineer, grantee
rep.
public part, coor.,
consultant, public
liaison
CAC, public part.
coor., consultant
liaison, grantee rep.
public part. coor.
public part. coor.
as previously
described
consulting engineer
staff
public part. coor.
public part. coor.
public part. coor.
grantee, pucilc
part. coor.
public part. coor.
public part. coor.
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
group
General public and
special interests
EPA, state participants
in meeting
General public
CAC, grantee, public
groups
General public
EPA, participants in
meeting
General public
Mailing list, civic
organizations, local
government
general pucixc
EPA, state, hearing
participants
CAC members, grantee
rep.
Note: Required by proposed Part 35
Required by proposed Part 25
Meets a performance standard of Parts 25 and/or 35
-------
Table 14
MODEL
DECISION POINT
Development of Facility
Plan
1. Assess current
Situation
o
OJ
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
situation.3
iii. Jo.-.at 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
liaison^
STAFF
SUPPORT
public part. coor.
TARGET AUDIENCE
All interested persons
from the region
CAC, consulting engineer
grantee representative
Use 208 mailing list
public part. coor.
consultant, public
liaison
public part. coor.
public part. coor.
grantee rep. con-
sultant staff and
public liaison
Public health officer
Town engineers
Industrial dischargers
Conservation Commission
members
Other knowledgeable
citizen leaders
Citizens Advisory Commit-
tee and interested
members of general
public
Engineers, grantee rep-
presentative, key CAC
members
c)
"Clean Water News", Vol. 2 3
- summarize preliminary findings of
assessment
- identify key areas of social/economic/
environmental conflict to be affected
by Facilities Plan
- notice of field trip to problem areas
wk. 12
public part. coor.
General public
Note: 1 Required by proposed part 35
2 Required by proposed part 25
3 Meets a performance standard of Parts 25 and/or 35
-------
Table 14 cont'd.
DECISION POINT
2. Assess future
situation
TECHNIQUE
NJ
O
it*
3. Consideration of
Alternatives
Cost-Effectiveness
Analysis
a) field trip focusing on areas of future
conflict3
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
SCHEDULE
mos. 3-6
wk. 16
wks. 12-24
c) send out notice of public meeting with
factsheet 2
d) "Clean Water News", Vol. 3 3
- key issues in future assessment study
- what existing land-use plans and popu-
lations projections mean for Facility
Plan
- what does the 208 plan say about the
future?
- preliminary ideitification of treatment
alternatives
- notice of public meeting
e) series of special interest workshops to
discuss key issues and alternatives3
f) public meeting with CACl
- 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
g) agency responsiveness summary 1
h) Clean Water News, Vol. 4 3
- summarize results of public meeting
- describe agency responsiveness summary
a) Clean Water News, Vol. 5, J 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
alternatives
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
STAFF
SUPPORT
public part. coor.
public part. coor.,
grantee rep.,
consultant liaison,
CAC
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., Civic groups
grantee rep., con-
sultant liaison
public part, coor., General public,
grantee rep., con- special interests
sultant liaison
public part. coor.
public part. coor.
public part. coor.
public part. coor.
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-
ant
General public, CAC,
grantee
EPA
-------
Table 14 cont'd.
DECISION POINT
4. Engineer submits
recommendation of
preferred alterna-
tive to town
officials (mo. 11)
TECHNIQUE SCHEDULE
a) notice ,of public hearing received 30 wk. 4J-
days in advance*1
b) factsheet summarizing final recommenda- wk. 41
tions and notifying of upcoming hearing 2
c) public hearing (possibly town meeting) on Wk. 45
recommendations and draft EIS 1
STAFF
SUPPORT
public part. coor.
public part. coor.
grantee
TARGET AUDIENCE
Newspapers, mailing list
general public
General public, mailing
list
O
Ui
5. Town approval of
Facility Plan and
submission to State
and EPA
6. Application for_
Step 2 Grant
a) notify public3
- 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
EPA
State agency
General public
CAC
-------
Table 15
BUDGET
FULL-SCALE PUBLIC PARTICIPATION PROGRAM
Salaries
Public Participation Coordinator
Assistanc Public Participation Coordinator
Secretary
Consultant Liaison
Advisory Committee Budget
Travel
Clerical Support
Technical assistance
Staff Travel
Printing
Postage
Phone.
TOTAL
Notes:
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 volunteer assistance is utilized
(for example, the survey outlined in the Plan of
Study could be distributed by local high school
students).
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.
206
-------
Table 15 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.
207
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CONTENTS
CHAPTER VII
MITIGATING PRIMARY AND SECONDARY IMPACTS
OF WASTEWATER TREATMENT FACILITIES
Page
What Are Primary and Secondary Impacts? 211
Why Should Primary and Secondary Impacts be Considered? . . 212
How is the Appropriate Mitigation Measure Selected? . . . . 213
What Mitigating Techniques Are Available? 213
How Feasibly Can These Measures be Implemented? 217
Who Has Responsibility for Implementation? 220
What Authority and Capabilities Are Available to
Ensure Implementation? 220
What is EPA's Role? 223
Case Studies 225
Block Island, Rhode Island 226
North Fremont County, Idaho 233
O A f\
East Bay, California .....
-------
CHAPTER VII
MITIGATING PRIMARY AND SECONDARY IMPACTS
OF WASTEWATER TREATMENT FACILITIES
The construction of a sewage treatment facility is
most often associated with two types of impacts—primary
and secondary—which can be both positive and negative.
While some negative impacts are inevitable, most can be
avoided or mitigated if recognized early enough in the
facilities planning process. In fact, federal law requires
that negative impacts be identified and all reasonable
steps be taken to limit their consequences. Some of the
ways to mitigate negative impacts are explored in this
chapter, using case studies where possible to illustrate
various approaches.
What Are Primary and Secondary Impacts?
Primary and secondary impacts are defined and
discussed in Chapter II. To review briefly, primary
impacts are relatively easy to identify as those that
can be attributed directly to the proposed action.
They include: environmental impacts resulting from
construction and operation of the facility, (erosion,
sedimentation, noise); economic impacts associated with
construction and operation (capitalization, O&M costs,
user charges, etc.); and social impacts such as traffic
disruption during construction or decline in property
value of land near the plant.
Secondary impacts are those resulting from in-
direct or induced changes in community land-use patterns,
population or economic growth and subsequent environmental
effects of those changes. They are often long term and
difficult to identify. While primary impacts are diretly
related to the construction process and specific construc-
tion activities, secondary impacts result from the place-
ment, sizing or staging of interceptor sewers and the
provision of reserve capacity in those sewers. Secondary
impacts might include:
A. Changes in the timing, density, type and
location of residential, commercial and
industrial development, or changes in the
use of open space or other categories of
land. The provision of public sewage
capacity is known to encourage growth,
particularly in areas where sewage treat-
ment would otherwise not be feasible.
This chapter was written by Marissa Roche.
211
-------
The cumulative results of these impacts
may or may not adversely affect the en-
vironment.
B. Changes in air, water, noise, solid
waste or pesticides pollution stemming
from the induced changes in population and
land use. Induced changes potentially could
aggravate the water pollution problem which
the treatment facility was designed to
remedy, or could create new pollution problems
from effluent disposal or nonpoint sources of
pollution.
C. Damage to sensitive ecosystems (wetlands,
habitats of endangered species) or culturally
important areas (parks, historic sites) re-
sulting from changes in population densities
and land use.I/
Why Should Primary and Secondary Impacts be Considered?
Consideration of primary and secondary impacts
and mitigating measures is required by federal law during
planning and construction of sewage treatment facilities.
Specifically, the 1977 Clean Water Act Amendments [Sec.
511(c)(l)3 make clear that National Environmental Policy
Act (NEPA) requirements for Environmental Impact Statements
(as well a all other NEPA requirements) apply to the Con-
struction Grants Program.
This means that in situations where EPA determines
that the potential impacts of a proposed sewage treatment
facility will be "significant and adverse," EPA must con-
duct an Environmental Impact Statement (EIS). The EIS
must include not only a discussion of all the potential
primary and secondary impacts (positive and negative),
but also must identify "protective and mitigative measures
to be taken ... to reduce or compensate for any environ-
mentally detrimental aspect of the proposed action."
(40 CFR 6.304).
Other federal environmental laws (i.e., Clean Air
Act, Endangered Species Act) also apply to the EPA Con-
struction Grants Program (they are listed in Chapter I).
These laws require EPA to ensure that proper steps are
taken to mitigate adverse impacts on specific natural
and cultural resources such as floodplains, aquifers
212
-------
and water recharge areas, and archeologic or historic
sites. EPA has developed regulations and guidance to
help its own staff and its grantees to comply with the
requirements of these other laws (40 CFR Parts 6, 30, 35,
Program Requirements Memoranda 75-26, 75-27, 75-31, 76-4,
7 6—5)•
How Is the Appropriate Mitigation Measure Selected?
There are usually several measures available
to mitigate a particular primary or secondary impact.
Yet, since community situations differ, the effective-
ness of particular mitigating measures will also vary.
It is important to select the measure that best meets
the particular needs of the community involved.
Several key questions should be considered when
selecting the appropriate mitigation methods:
1) What range of possible mitigation measures
is available?
2) How feasibly can these measures be adopted?
(Can existing laws be applied or must new
ones be developed? What are the costs of
implementing mitigating measures, and who
will pay?)
3) Who will be responsible for implementing the
measure? (construction contractor, local
government, EPA)
4) What authority and enforcement capabilities
exist?
These questions will be addressed in the following
pages.
1) What Mitigating Techniques Are Available?
Primary impacts. Primary impacts such as noise,
odor, erosion and sedimentation are generally short-lived
and/or relatively easy to identify and mitigate. The many
mitigation options generally coincide with the three stages
of project development; site selection and design, plant
construction and plant operation.
The first step in mitigating primary impacts involves
careful site selection and design based on a detailed survey
of such factors as site topography and geology, compact site
planning, odor and aerosol sources, noise sources and main-
tenance and access requirements. There are three basic
strategies for environmentally sound site planning and design:
213
-------
a) Advantageous use of positive site features
(i.e., prevailing winds or seasonal solar
angles, vegetation that can serve as a
natural screen or buffer).
b) Design of necessary facility elements to
avoid or minimize environmental compatibility
problems (i.e., extend outfall pipe to a water
depth that will preclude easy accessibility
and enhance diffusion of effluent).
c) Addition of special design elements not
necessary for plant function but rather
to solve environmental compatibility pro-
blems (e.g., construction of esplanade
along river bank adjacent to facility to
enhance recreational access to river._2/
One or a combination of these strategies may be
employed in any facility design.
The second step involves careful control over
construction activities. Many methods are available
to minimize construction impacts, including:
• careful timing of construction activities
(to coincide with stream low-flow periods,
thus minimizing turbidity or sedimentation
impacts; or to avoid the nesting period of
certain indigenous animal populations)
• immediately restoring and revegatating
disturbed areas to minimize erosion
• using electric motors to minimize noise
• using an archeological consultant to ensure
that archeological resources are recovered
or left undisturbed
• periodically wetting down unpaved surfaces
to minimize dust
• continually cleaning up general site debris
and screening construction activities as
much as possible to minimize esthetic impacts.
A third step in minimizing primary impacts concerns
214
-------
actual operation of the treatment facility, in this case
mitigating measures include such provisions as: '
• adoption of odor and noise control
measures within the plant
• adequate treatment and disposal of sludge
to minimize odor
• design of emergency backup system to
mitigate damages resulting from mal-
function
• monitoring equipment to evaluate impact
of discharge on receiving waters
• construction of permanent erosion control
structures
» adoption of specific erosion and sediment
control measures as standard O&M procedures^/
Secondary impacts. Secondary impacts specifically
linked to the construction of sewage treatment and collec-
tion facilities are usually long-term consequences that
are difficult to predict. In fact, to distinguish com-
munity changes caused by construction of a particular
facility from changes that would have occurred naturally
often involves 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 available to indicate how
effective any proposed mitigation measure can be in the
long run.
According to present policy, the community served
by the planned facility has the primary responsibility
for identifying secondary impacts and developing appro-
priate mitigating measures. EPA has compiled a list of
such measures. It includes:
• Phasing and orderly extension of sewer service.
Rather than initially extending sewers to
presently undeveloped areas, potentially
encouraging rapid growth and sprawl, sewer
extensions might be phased in over several
years and/or restricted to areas of greatest
need.
215
-------
• Project changes. The reserve capacity of the
facility might be reduced based on revised
population projections, or the project design
might be changed from a single regional system
with interceptors to several smaller systems
servicing only existing growth areas.
• Improved land-use planning. Communities might
develop or improve land-use plans to identify
areas suitable for development as well as those
which are environmentally sensitive. Plans
should be accompanied by appropriate land-use
regulations (zoning, subdivision ordinances)
and fiscal planning for extension of public
services which ensure that new.development
wll be compatible with the plan. •
* Better coordination of planning among communities
affected by the project. It is important that
all communities affected by a project coordinate
their land-use planning efforts. Secondary impacts
of a sewage treatment facility are seldom limited
to the boundaries of the community within which
it exists. Sensitive environmental areas, for
example, even if under the jurisdiction of several
communities, should be protected from growth by
compatible land-use restrictions.
• Sewer use restrictions. The number and type of
sewer hook-ups can be restricted. For example, if
the final decision necessarily involves interceptor
sewers that traverse an environmentally sensitive
area, the number of new sewer hook-ups permitted
from those areas can be carefully limited.
* Modification or adoption of environmental programs
or plans. In urbanized areas, increased air pollution
resulting from induced population growth may be one of
the most significant secondary impacts of a new sewage
treatment facility. States are already required by
the Clean Air Act to develop Air Quality Maintenance
Plans, and many are already involved in the process.
Strategies identified in existing Air Quality Main-
tenance Plans (improved mass transportation, automo-
bile disincentive programs) which apply to a particular
facilities planning area should be adopted or modified
according to the projected impacts of the new facility.
« Improved land management controls to protect water
quality. Ideally, a good Section 208 water quality
management program (see Chapter I) should include the
necessary land management controls to protect future
216
-------
water quality in a given facilities
planning area. However, in areas where the
208 plans have not been implemented or are not
considered adequate, measures such as state
or local erosion control and sedimentation
programs and flood plain and coastal zone
management programs may exist or can be
adopted to ensure that the water quality
impacts of new development, induced by the
sewage treatment facility, will be minimized.
2) How Feasibly Can These Measures be Implemented?
Once the range of possibilities has been considered,
it is important to consider how feasible it is to implement
a particular mitigation measure. In many cases, primary
impacts can be handled routinely by the facility designer
or construction contractor through careful site design or
environmentally sound construction practices. EPA has
outlined general engineering principles and specific
minimum engineering efforts that must be incorporated
in the Step 1 Facilities Plan. (Program Requirements
Memorandum, PRM, No. 78-1, "Erosion and Sediment Control
in the Construction Grants Program"). These requirements
should ensure that at least the major primary impacts
(soil erosion and sedimentation) of plant construction
are minimized.
Secondary impacts, on the other hand, often can be
mitigated 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 controls. In situations where state
or local land-use controls such as floodplain ordinances,
air quality maintenance plans, Section 208 water quality
management plans or comprehensive growth management plans
are in effect, it may be relatively easy to control secon-
dary impacts simply by enforcing existing plans and ordi-
nances. In situations where adequate land-use controls
do not exist (which is more often the case), a community
may be required to adopt necessary measures to success-
fully mitigate secondary impacts. If communities involved
in a Step 1 planning project are unresponsive to the idea
of land-use controls or are more concerned with stimulating
economic development than maintaining environmental quality,
mitigation of secondary impacts can be difficult to achieve.
Existing local land-use plans may not be an adequate
basis for proposed mitigation measures. Plans should be
reviewed carefully to determine how effective they will be
in regulating future development and thus minimizing secon-
dary impacts. Some land-use plans simply are too general
217
-------
to provide adequate protection; others may be based
on exclusionary zoning practices that could at some
point be challenged in court. Relying on mitigating
measures based on these kinds of inadequate land use
plans may prove to be folly. Instead the community
might consider adopting one of the alternative measures
discussed here.
Timing is a key element for successful imple-
mentation 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 the Facilities Plan is completed
and construction is underway, it may be extremely diffi-
cult and costly to make design changes.
A chart of the stages involved in the development
of a wastewater facility (Table 16) outlines where in the
planning process key decisions are made. From the moment
the state places a project on its Priority List right
through to the point where the plan is actually in
operation, there are opportunities for concerned citizens
to raise the issue of primary and secondary impacts.
However, as the project moves from the planning to the
design and then to the construction phase, the oppor-
tunities to introduce mitigating measures are greatly
reduced.
Another consideration that affects feasibility is
the co&t to the community of implementing a particular
measure. Some mitigating measures, such as reduction in
facility size or service area, may actually bring down pro-
ject costs. Others may increase the total cost slightly
or have no cost effect at all (for example, siting the
facility to exploit prevailing winds as a natural odor
control or using existing trees on site as a natural
screening device.) Or, 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 a grant-eligible item; hence, the
community share of these costs would be minimized.
However, some mitigating measures may require
community expenditures that are not considered grant-
eligible. Take for example the situation where a com-
munity is considering construction of an interceptor
sewer across a wetlands area because it is less expen-
sive than other alternatives, which all involve pumping
the sewage uphill. To discourage future development on
these wetlands, the community might consider purchasing
them (particularly if a sewer use restriction is con-
sidered to be illegal). However, the costs of acquiring
those wetlands would not be covered by the construction
218
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Table 16
Preappli cation
Stage _
o State places
project on
TYPICAL STAGES OF DEVELOPMENT IN A MUNICIPAL WASTEWATEP TREATMENT FACILITIES PROJECT
Design Stage Construction Stage
Facilities Planning
Stage
o Applicant selects
consultant.
o Appl icant and con-
sultant have pre-
application con-
ference with State
end LPA.
o Applicant prepares
plan of study and
sulr.iits to A-95
Review Process.
Application for Step o
I grant submitted to
St?^1 and EPA includ-
ing the plan of study
for review and approval.
Consultant prepares
facilities plan in-
cluding an environ-
mental assessment.
i
Facilities plan is sub-
mitted to A-95 Review.
Consultant conducts i
public hearing on the
facilities plan.
tfA and State review
and approve facilities
plan.
EPA prepares environ- o
mento1 Impact state-
ment, if necessary,
or declares none is
needed in a negative
declaration and en-
vironmental appraisal.
Public hearing 1s con-
ducted as part of EIS
process when required.
Consultant prepares
and submits appli-
cation for Step ri
grant to State and
EPA for approval.
EPA may condition
StepIT. grant on
mitigating secondary
impacts.
Consultant prepares
and sumbits plans
and specifications.
EPA and State re-
views and approves
project plans and
specification
In projects where
there 1s no Step
I, NEPA require-
ments would still
have to be performed
prior to awarding
the Step II or Step
III grant.
Consultant prepares
and submits appli-
cation for Step HI
grant to State and
EPA for approval.
EPA may condition
StepISX grant on
mitigating secondary
impacts
Grantee advertises
for construction
bids selects re-
sponsive low bidder,
submits all bids in
tabular form to
State and EPA for
approval, and upon
Approval awards
'contracts.
Project is
constructed.
EPA and State
conducts final
inspection.
EPA conducts
final audit and
makes payment.
Operation and
Maintenance Stage
Plant operated
and maintained
for life of
project.
State and EPA
make operation
maintenance
and permit
compliance
inspections.
o Municipality
collects sewer
service charges
and promulgates
sewer use
regulations.
Secondary Impact* from the Wastewater Facilities Program
An EPA case studies series, EPA Office of Land Use Coordination.(unpublished)
-------
grant, meaning the community share of total project
costs might be very high.
On the other hand, the community might decide
to mitigate potential growth impacts on the wetlands
by relocating the interceptor sewer outside the envi-
ronmentally sensitive area. (This action would
require changes in the project design.) If such an
alternative is a "cost-effective" solution, then the
federal government, not the local community, would
absorb the greatest share of the additional costs.
3) Who Has Responsibility For Implementation?
An equally important consideration is who will
have ultimate responsibility for implementing mitigation
measures. In most situations, quite a few government
agencies, organizations and individuals may be involved,
and it is therefore important that their respective roles
be identified and that the wastewater management agency
have the capacity to coordinate their efforts to make
sure the job gets done successfully.
For example, the construction contractor may
be the logical one to implement environmentally sound
construction practices to minimize the primary impacts
of construction. But the wastewater management agency
would be the one to implement specific measures required
to mitigate impacts of operation, and the local govern-
ment generally will have responsibility for implementing
land-use controls. A list of impact mitigation measures
(Table 17) prepared as part of the draft Environmental
Impact Statement for the North Monterey County Facilities
Plan illustrates the range of possible implementing en-
tities to be considered. (The North Monterey Facility
Plan called for a secondary treatment and discharge
facility with an option to use some or all of the
treated effluent for irrigation.)
4) What Authority and Capabilities Are Available To Ensure
Implementation?
The Step 1 plan must demonstrate, among other
things, that the authorities which will implement the
plan have the necessary legal, financial, institutional
and managerial authority and resources to carry out con-
struction, operation and maintenance. In terms of miti-
gating primary and secondary impacts, then, the plan must
show that the authorities identified to implement specific
mitigation measures have the necessary qualifications to
do so.
220
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221
TABLF 17
SUMMARY - IMPACT MITIGATION MEASURES
ilitigation
Possible
Implementing
Entity(ies)*
INSTRUCTION IMPACTS
o Source control of noise, air emissions, dust.
o Avoid, minimize removal of vegetation; keep disturbed
area as small as possible, reseed.
o Reroute, control flow of traffic.
o Avoid construction through critical wildlife habitat,
scenic areas, agricultural land.
OPERATION IMPACTS
Soils-Agriculture
o Utilize highest level of wastewater treatment possible,
implement source controls.
o Practice deep soil tillage
o Increase water applications to leach salts.
o Blend water sources.
o Irrigate only at night
Water Quality
o Increase irrigation efficiency to reduce agricultural runoff.
o Pretreat agricultural runoff before discharge
o Utilize highest level of wastewater treatment possible,
implement source controls.
o Install tile underdrains in wastewater irrigation areas.
o Dewater sludge prior to landfilling.
Public Health
o Avoid wastewater irrigation in the vicinity of domestic
wells.
o Line all wastewater storage ponds with impermeable materials.
o Install tile underdrains in wastewater irrigation areas.
o Follow wastewater irrigation guidelines of State Department
of Health, Title 22 of California Administrative Code.
o Utilize highest level of wastewater treatment and
disinfection possible.
o Implement vector control program at reservoirs through
local mosquito abatement districts.
Resources
o Utilize those treatment processes with lowest chemical
and energy requirements.
o Select pipeline routes, treatment plant location with
least pumping requirements.
o Utilize digestor, landfill-generated methane for treatment
plant energy source.
Wildlife, Vegetation
o Maintain summer flow in the lower Salinas River by:
1. Pumping groundwater near Salinas.
2. Pumping regional plant effluent upstream for discharge.
3. Retain Salinas plant wastewater discharge to river.
Construction
contractor
Construction
contractor
Construction
contractor
MPWPCA
MPWPCA
Local farmers
Local farmers
Local farmers
MCFCWCD, CID,
local farmers
Local farmers
Local farmers,
RWQCB
MPWPCA
Local farmers
MPWPCA
MCEHD,
local farmers
MPWPCA
Local farmers
MCEHD, CDH
MPWPCA
MPWPCA, NSVMAD
MPWPCA
MPWPCA
MPWPCA
MPWPCA, City
of Salinas
MPWPCA
City of
Salinas,
MPWPCA
ARB California Ail Resources Board
-DH California Department of Health
-ID Castroville Irrigation District
W5 California Department of Fish and Game
JPA u. S. Environmental Protection Agency
221
KBUAPCD Monterey Bay Unified Air Pollution
H
Control District
MCBS Monterey County Board of Supervisors
MCEHD Monterey County Environmental
Health Department
-------
TABLE 17 cont'd.
Mitigation
Possible
Implementing
Entity(ies)*
4. Additional upstream water releases.
o Use of treated wastewater for habitat enhancement on
Department of Pish and Game wildlife area.
o Utilize highest level of wastewater treatment possible,
implement source controls.
Economics
o Implement least costly treatment and disposal
alternative possible.
o Limit treatment facilities sizing to that level considered
grant fundable by EPC and SWRCB.
o Eliminate as much infiltration/inflow as possible.
o Initiate water conservation and wastewater flow
reduction programs.
GROWTH-RELATED IMPACTS
General - Land, Water, Wildlife, Vegetation Resources
o Size wastewater treatment facilities for existing service
area population only.
o Encourage high density development in newly urbanized
areas.
o Encourage infill rather than peripheral development or
sprawl.
o Utilize Williamson Act land protection.
o Implement a wastewater reclamation alternative to
augment local water supplies.
o Modify general plans and zoning ordinances to protect
recognized valuable resources, i.e., rare and endangered
plants, wildlife, unique vegetation.
Air Quality
o Adopt more stringent vehicle emission standards.
o Adopt more stringent point source emission standards.
o Control development of new industrial sources of pollution
through general plan and zoning amendments, changes in
conditional use permit procedures.
o Reduce overall vehicle travel by:
1. Modifying general plans and zoning ordinances to
encourage infill and reduce urban sprawl.
2. Design new residential areas to facilitate bus service.
3. Improve local transit service, encourage carpooling.
4. Encourage new development planning that facilitates
non-motorized travel.
o Invoke temporary treatment plant flow limitations until
alternate mitigations are devised.
MPWPCA,
MCFCWCD
DFG, CDH,
MCEHD
MPWPCA
MPWPCA
MPWPCA
MPWPCA, local
public works
departments
MPWPCA, SWRCB,
RWQCB, local
government,
public at
large
MPWPCA
Local planning
agencies, city
councils, MCBS
Local planning
agencies, city
councils, MCBS
Local planning
agencies, city
councils, MCBS,
local landowner:
MPWPCA
Local planning
agencies, city
counc ils, MCBS
EPA, ARB
MBUAPCD
Local planning
agencies, city
councils, MCBS
Local planning
agencies, city
councils, MCBS
Local planning
agencies, MPT
Local government
MPT
Local planning
agencies
EPA, SWRCB
MCHCKCD Monterey County Flood Control and Water Conservation District
MPT Monterey Peninsula Transit
KPWPCA Monterey Peninsula Water Pollution Control Agency
NSVKAD Northern Salinas Valley Mosquito Abatement District
RWQCB Central Coastal Regional Water Quality Control Board
SWRCB California State Water Resources Control Board
222
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In situations where a single community is the
wastewater grant applicant, it may be relatively easy
to demonstrate that the necessary powers and resources
do, or will soon, exist to implement mitigation measures.
The applicant may, for example, simply describe existing
land-use regulations that will be applied or indicate
its intentions to institute necessary growth management
practices.
With regional facilities, however, the grant
applicant often may be a single community applying on
behalf of several others in the system. In this case,
the applicant probably would not have the authority to
implement mitigation measures outside its own political
jurisdiction. Or, the applicant might be an interjuris-
dictional authority (special district) created for the
express purpose of handling wastewater management pro-
blems for a particular area. Such an entity generally
is granted very specific and often limited powers to
carry out its single purpose mission. As a result,
most of the measures available to mitigate impacts
(particularly secondary impacts) would be beyond
its, authority to implement.
A grant applicant that represents such an
interjurisdictional authority may be required in its
Step 1 plan to demonstrate that appropriate mitigation
measures will be implemented by securing written agree-
ments from each of the participating jurisdictions,
confirming their commitment and capability to carry
out the proposed measures. Negotiating such juris-
dictional agreements can often be difficult.
What Is EPA's Role?
EPA has the ultimate responsibility and authority
to make sure appropriate mitigation measures are implemented.
No design or construction grant will be issued unless EPA is
satisfied that the proposed Facilities Plan has addressed any
and all controversial environmental issues. In effect, by
controlling the purse strings, EPA offers a very attractive
carrot that could ultimately influence land-use decisions
in communities across the country.
EPA has developed a series of regulations and
guidelines to amplify the agency's policy on mitigating
secondary impacts of sewage treatment facilities. One,
for example, states that when:
. . . secondary effects of a project can
reasonably be anticipated to contravene an
environmental law or regulation, or a plan
or standard required by an environmental law
223
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or regulation, the Regional Administrator
shall withhold approval of Step 2 or Step 3
construction grants until the applicant revises
the plan, initiates steps to mitigate the adverse
effects or agrees to conditions in the grant document
requiring actions to minimize the effects.5/
Another, acknowledging the importance of wetlands
and the need to protect them from the impacts of construction
grants programs, states that:
. . . it shall be the policy of this Agency
not to grant Federal funds for the construction
of municipal wastewater treatment facilities or
other waste treatment associated appurtenances
which may interfere with the existing wetland
ecosystems, except where no other alternative
of lesser environmental damage is found to be
feasible.6/
The EPA Regional Office has the responsibility for
ensuring that potential primary and secondary impacts are
considered from the very beginning of the facilities planning
process. (The attitude of the Regional Office toward minimizing
environmental impacts will determine how seriously mitigating
measures are considered.) During the preapplication conference,
which precedes issuance of a Step 1 grant, EPA staff should
raise the issue of potential impacts with the applicant and
his consultant and indicate what range of mitigation measures
are available. If the potential impacts appear to be signifi-
cant, EPA may require that a full EIS (rather than an Environ-
mental Impact Assessment) be prepared to accompany the Step 1
Facilities Plan.
If mitigation measures proposed in the Step 1 plan
fail to satisfy EPA concerns and EPA can determine that
the proposed project is likely to contravene an existing
federal, state or local environmental law or regulation,
the Regional Office may condition a Step 2 or Step 3 grant,
for example, on the stipulation that the local jurisdiction
adopt certain specified growth management measures. Or, if
a Step 2 or Step 3 grant has already been approved, EPA may
withhold future payments, initiate a court injunction, ter~
minate the grant and recover unexpended EPA funds or take
other action necessary to ensure that the secondary impacts
are addressed
224
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Grant conditioning, however, can be imposed
with mixed results. In situations where local offi-
cials recognize the need for land-use controls but have
not been able to muster enough public support, an EPA
grant condition may provide them with the ideal oppor-
tunity to institute land-use controls without jeopardi-
zing their political support; EPA, in other words, becomes
a convenient scapegoat. On the other hand, communities
that see EPA grant conditions as direct interference
with local home rule may be uncooperative in developing
and/or enforcing the necessary land-use controls.
In fact, the conditioning of grants on the adop-
tion of land-use measures raises a series of legal and
political questions in terms of how far EPA can go in
controlling what would be local land-use decisions.
Furthermore, if not properly instituted, grant conditions
can create a considerable administrative burden for EPA
Regional Offices that must oversee local adherence to the
conditions. Consequently, most grant conditions to date
have been written so as to reinforce existing state or
local legislation thereby leaving the administrative
responsibilities with the local government involved.
CASE STUDIES
The experiences of three communities that have
been involved with wastewater management facilities
planning are examined in the following pages. Because
community experience in dealing with secondary impacts
is rather limited and effective mitigating measures are
often difficult to implement, these case studies will
focus primarily on the mitigation of these secondary impacts,
This detailed exploration of community experience
should provide valuable insight into the kinds of issues
raised and the types of conflicts which must be resolved.
However, as with all case studies, there are limits on
extrapolating from one experience to another. Every
community is unique, and it is important to recognize
that an approach which works well in one community may
be unsuccessful in another.
The three case studies discussed here are taken
directly from existing case study materials prepared by
the EPA Office of Land Use Coordination, with only minor
modifications. They were chosen to reflect a range of
geographic conditions, community sizes and project types,
and to illustrate a variety of measures for mitigating
secondary impacts.
The Block Island, Rhode Island, case study involves
a very small, self-contained community (year-round popula-
225
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tion: 500) supported by a sizable summer tourist busi-
ness. The community had no existing sewage treatment
facility and was experiencing serious problems
with septic tank failures. In North Fremont County,
Idaho, the situation involved a fairly extensive rural
recreation area (over 600,000 acres) that had been ex-
periencing increased development pressures. The area
was served only by individual on-site septic systems,
many of which were malfunctioning due to high ground
water table conditions. Finally, the East Bay, Calif-
ornia, case study involves the design of a subregional
wastewater treatment, conveyance and disposal system
serving several communities and a primarily urban
population of pver 400,000 people in the San Francisco
Bay Area.
Each case study includes a brief description
of the community or service area, its water quality
problems and the proposed solution. The discussion
focuses on major land-use issues raised by the project
and the mitigating measures considered and adopted,
including an evaluation of the effectiveness of those
measures in cases where a project has been completed.
Block Island, Rhode Island
The community
Block Island (New Shoreham Township), located
on Long Island Sound roughly 10 miles off the coast of
Rhode Island, is a relatively small island of approxi-
mately 11 square miles. The island supports a small
year-round population of about 500 residents. However,
during the summer, the resident population increases to
1,700 and on a typical summer day another 1,000 - 2,000
tourists may be visiting the island.
Development on the island has been concentrated
in the Old Harbor Area (see map). Old hotels, inns,
rooming houses, restaurants and shops are clustered
along the old harborfront; within a few blocks of the
harborfront houses are spaced further and further apart,
and stone walls enclose bayberry heath and abandoned
pastureland. About 1.5 miles to the northwest, smaller
scale, newer development has taken place in the New
Harbor Area. The remainder of the island is largely
open heath, pasture, numerous ponds and inland wetlands
—of the island's nearly 7,000 acres, over 5,000 are in
heath and open pasture, and another 1,000 acres are in
water and wetland.
In 1972, the island adopted a Comprehensive
Community Plan (CCP), which was prepared by the Rhode
226
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227
FIGURE 3
Source: "Mitigating Secondary Impacts from the Wastewater Facilities
Program: An EPA case studies series," EPA Office oi; Land
Use Coordination (Unpublished).
-------
Island Department of Community Affairs in consultation
with the island's Town Council and Planning Board.
The goals and policies outlined in the CCP include
protecting environmentally sensitive lands and natural
areas, preserving the rural New England character of
the island and confining development to lands with
good subsurface drainage suitable for septic tanks.
The plan also cites the marked upturn in construction
of new summer houses as a warning to plan wisely to
protect the island's future environment and charm.
In 1973, New Shoreham updated its 1967 zoning ordi-
nance to conform with the new plan and to ensure the
protection of wetlands, ponds and streams.
The problem
Until the late 1960 's, the primary wastewater
disposal method on the island was on-site sewage systems
with either subsurface disposal or, more often, direct
discharge of raw wastewater into the ocean. In the early
1970's, a ban on raw ocean discharge necessitated a switch
to subsurface disposal.
The high density in the Old and New Harbor areas,
however, did not allow enough land for adequate subsurface
disposal, particularly during the peak summer season. New
construction, which was increasing at the time, placed
additional strain on the capacity of the soils. As a
result, many on-site system failures occurred, creating
a situation that was esthetically displeasing to the
residents and also represented a potential community
health hazard.
Proposed solution
Because of the town's serious sewage disposal
problems, island officials hired a consulting engineering
firm to study the situation and develop tentative plans for
a municipal collection and treatment system. Based on the
consultant's report, which was presented in February 1972,
New Shoreham began application proceedings for federal
aid. The town then contracted with the same engineering
firm to design, supervise construction and start operation
of the waste disposal system recommended in their report.
The initial plan submitted to EPA in August 1973
as part of their Step 2 grant request called for construc-
tion of a secondary wastewater treatment plant, interceptor
sewers, two pumping stations, associated force mains and
an outfall sewer off the breakwater near Old Harbor. The
system (0.28 MGD) was designed to serve both the Old and
New Harbor Areas (Stage I) with provisions to serve the
area south of the Old Harbor in the future (Stage II).
228
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Based on the Environmental Impact Assessment
submitted by the town to EPA in April 1974, EPA's Region I
office initially determined that environmental concerns
had been considered in the final design of the plant, and
therefore issue a Negative Declaration on the project.
However, by mid-September the project had become the sub-
ject of serious public controversy. Citizens discovered
that the project would not only cost $2.6 million more
than originally estimated, but would also have serious
growth implications for their community. The EPA Regional
Office, recognizing the serious nature of the citizen's
concerns, reversed its decision and decided to proceed
with an Environmental Impact Statement.
Issues raised
Both the draft and final Environmental Impact
Statement discussed in some detail the project's possible
secondary land-use impacts. Based on development pressures
along the island's coastline and proximity to the North-
east's recreation demand centers, construction of sewer
lines and waste treatment capacity could predictably
encourage growth within the service area. A major con-
cern, however, was that such growth could take place at
an accelerated rate if the sewer systems were permitted
to expand with complementary changes in zoning densities,
either by variance, special exceptions or by law amendment.
The draft and final EIS warned that, based on the experience
of other island resort communities and depending on the
strength of development demand to force zoning changes
and further expand treatment capacity, an extreme growth
situation could result in the following secondary impacts:
• Impose resort complexes and residences
on wetland and shoreland ecosystems and on
flood hazard areas. Especially adverse would
be encroachment upon the salt water marshes
of the Great Salt Pond embayments as well as
freshwater marshes; also vulnerable would be
the south shoreline of Great Salt Pond and
extensive areas in the south-central sector
of the island proposed for "conservation"
or "open space recreation" in the CCP.
• Facilitate condominium and high-density
residential development in the extensive
open moors, which are dotted with small
lakes, to the southwest of New Harbor.
• Intrude upon the character of open space,
marsh and upland vegetation and general
sense of openness of the Great Salt Pond
area and the view of Great Salt Pond and
Block Island Sound.
229
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• Stimulate medium-density residential
development (1-acre lots) on the extensive
"low density residential" and "conservation"
areas southeast and south of Old Harbor that
were proposed in the CCP. These areas em-
brace perched freshwater marshes, ponds,
water supply recharge areas and the pic-
turesque pasture-bayberry moor vistas of
Old Harbor and the ocean from the Upland
Plateau.
• Greater numbers, densities, and range of
activities on the island would have an
overall adverse impact on the high quality
of the existing environment in the follow-
ing ways:
(a) on water quality through runoff
from additional paved and impermeable
surfaces, through some erosion and
sedimentation of fragile ponds and
wetlands associated with construction
and continuing earth disturbance, and
through additional solid waste-septage
disposal and septic system operation
—all associated with a higher level
of development;
(b) on noise levels through additional
vehicles, lawnmowers and human activities;
(c) on air quality through additional motor
vehicles and power boats;
(d) on visual appeal of sweeping vistas
of sea, sand and sky; of rolling moors,
pastures, ponds and vegetation;
(e) on fragile ecosystems; salt and fresh
water marsh associations, dunes
associations and upland plant and
animal associations.
The alternatives
The proposed project alternatives were carefully
analyzed to ensure that an extreme growth situation would
not occur and that the above impacts would be avoided.
The analysis concentrated on what were considered the four
most practical choices.
Alternative A. Construction of the project
proposed by the applicant's consultant, which
includes a treatment facility and collection
230
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system to serve the Old and New Harbor
sections of the island (Stage I) with
provisions to serve the area south of
Old Harbor in the future {Stage II).
Alternative B. Construction of the project
(Stage I) without provisions for sewering
the area south of Old Harbor in the future.
Alternative C. No sewer construction, but
a comprehensive program for the rehabilita-
tion of individual septic systems.
Alternative D. Construction of a treatment
facility and collection system for the Old
Harbor area only, with rehabilitation of indi-
vidual septic systems in the New Harbor area.
The draft EIS recommended against allowing the
situation to remain unchanged (the "do nothing" alternative)
and against trying to solve the problem simply by upgrading
existing individual septic systems (Alternative C). Also
rejected was the original proposal (Alternative A) which
was about to be enacted when the citizens raised their
protests. This alternative was eliminated because wetlands
and other environmentally sensitive areas made up a large
portion of the area proposed to be sewered by Stage II.
The draft EIS recommended two alternatives:
• The first would provide sewers in both
commercial areas of the island, but
eliminate the "Phase II extension" into
residential areas contained in the orignal
proposal (Alternative B).
• The second would provide public sewage
capacity only in the dense Old Harbor
commercial area and rely on improved
septic systems in the less dense New
Harbor area (Alternative D).
Of those two alternatives, the draft concluded
that the second (D) was most appropriate. Pressures for
induced growth would be minimized, particularly along the
the strip between the two harbors. However, due to comments
received on the draft, largely due to the insistence by the
Rhode Island Department of Health that septic systems could
not be made adequate in the New Harbor area, the final EIS
recommended the first of the two alternatives (B), advo-
cating that both commercial areas be serviced by public
sewers rather than the Old Harbor alone.
231
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Mitigation
Scaling down the originally proposed project
design represented the first mitigating measure.
Eliminating Alternative A reduced the size of the
service area and meant that the project would not
induce growth on wetlands and other environmentally
sensitive lands within the originally proposed Phase
II area. Service was thereby restricted primarily to
the Old and New Harbor communities. The question
remained, however, of protecting environmentally
sensitive lands, primarily wetlands on the periphery
of the two harbors, as well as lands adjacent to inter-
ceptors carrying wastes from the New Harbor to the
treatment plant in the Old Harbor.
The second mitigating measure involved a specific
condition to protect these areas from encroachment by new
facilitated development. EPA's responsibility for protec-
ting wetlands has been clearly enunciated in the agency's
Wetlands Policy Statement published in the Federal Regi-
ster on May 2, 1973 (Fed. Reg., Vol. 38, No. 84, pages 10834-
5). The Policy Statement includes the following wording:
• "In its decision processes, it shall be
the Agency's policy to give particular
cognizance to and consideration to any
proposal that has the potential to damage
wetlands ..."
« "In compliance with the National Environmental
Policy Act of 1969, it shall be the policy of
the Agency not to grant Federal funds for the
construction of muncipal wastewater treatment
facilities or other waste treatment associated
appurtenances which may interfere with the
existing wetland ecosystem, except where no
other alternative of lesser environmental
damage is found to be feasible."
EPA's Region I office therefore decided to condition
the grant to protect wetlands by partially controlling the
distribution of the limited amount of new growth the project
may facilitate. The condition reads as follows:
"The Town (New Shoreham) shall not permit
any person to discharge wastewater into any
collection line, lateral sewer, interceptor or
other means of conveying wastewater to the
treatment plant if such wastewater originates
from any building, facility or other manner of
construction which is hereafter erected or other-
wise placed, in whole or in part, upon land which
is a wetland area within the means of G.L.T.I.
232^
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Title 2, 2-1-13 and 2-1-14 (Supp. 1974)
(Rhode Island State Law). This condition
is deemed to be for the protection of Wet-
land areas and shall constitute a bilateral
agreement between EPA and the Town which
may be enforced by any person who has an
interest in the protection of such wetland
areas, including year-round and part-time
residents of Block Island."
It is important to note that the above condition
reaffirmed Rhode Island law on the protection of wetlands
and that it supports policies enunciated in the local com-
prehensive plan and zoning ordinance.
North Fremont County, Idaho
Community or planning area
The Island Park area of North Fremont County,
Idaho, is a key recreational area in the state. Located
near the Grand Teton and Yellowstone National Parks, it
has become an increasingly popular summer and winter
resort area. The proposed service area, which actually
includes four development subareas, includes 601,000
acres, of which 596,000 acres are owned by the U.S. Forest
Service and Bureau of Land Management. One thousand seven
hundred acres are owned by the state, leaving only 2,300
acres in private ownership.
The problem
Like other recreational areas across the country,
the Island Park area was experiencing increased development
pressures. However, much of the private land available for
development was not suitable for on-site septic systems
because of high groundwater tables. No public sewage
treatment facilities existed. In fact, most of the pre-
sently developed areas are located along rivers and lakes
where groundwater tables are high. EPA and many of the
existing subsurface county water quality studies indicated
that subsurface waste disposal systems were malfunctioning,
causing considerable contamination of subsurface high water
by septic tank drainfill effluent and creating a serious
public health problem.
in addition, land suitable for development was
nff^n located away from presently populated areas, and
dev^lopmenfin these areas would, according to the EIS,
"create a sprawl into environmentally sensitive areas
with serious adverse impacts on the vegetation, would-be
habita^and degradation of waters from ^osion an^ run-
off." Because the county had no zoning or other similar
233
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land use regulations, it lacked the powers required to
control this type of sprawl.
Development of solution
The EPA Regional Office was involved in the very
early planning stages of the Island Park treatment facility.
In preapplication meetings held in the spring of 1974, EPA
discussed with the grantee and consultant the need for a
thorough environmental assessment. The possibility of con-
troversy, the nature of the sensitive environment and the
potential for significant land use changes identified the
project from its early stages as a candidate for an EIS.
The proposed Facilities Plan submitted to EPA for
Step 2 grant approval involved individual collection,
interceptor and treatment facilities for each of four
sub-areas in the Island Park area. The facilities would
be located in areas of concentrated existing or predicted
future development. The project would be constructed in
phases with the total costs ($6,941,500) spread out over
20 years. The capacity for each sub-regional system
would range from roughly 50,000 gpd to 250,000 gpd/
Issues raised
In the fall of 1974 the Regional Office conducted
a field study review, evaluating secondary impacts of the
proposed project. The field study resulted in a recommen-
dation to the Regional Administrator that an EIS be pre-
pared. After review of the Step I plan, the Regional
Administrator concurred, declaring that the EIS should
address the following concerns:
1. The extent to which continued recreational
development will impact the area resources;
2. The extent to which the availability of
sewage facilities will facilitate land-
use changes or growth rate changes;
3. The absence of local land-use planning
that might serve to control development
or mitigate adverse impacts; and
4. Significant adverse secondary effects on
the ecosystem in general and especially
on fish and wildlife habitat.
A draft EIS was prepared in August 1975, and the
final EIS was later issued in January 1976. The EIS process
served as a vehicle to bring out comments from a number of
agencies, organizations and concerned individuals. Concern
for adequate mitigation of secondary land-use impacts was
234
-------
FIGURE 4
Source: "Mitigating Secondary Impacts from the Wastewater Facilities
Program: An EPA case studies series," FPA Office of Land
Use Coordination (Unpublished).
235
-------
voiced in many of the responses to the draft EIS.
The U.S. Department of the Interior stated in a
letter dated November 11, 1975, commenting on the draft
EIS; "Much of what now makes the Island Park Area (Fremont
County) a scenic, and esthetic and recreational attraction
would be lost if the sewage system is constructed and develop-
ment of further subdivisions is allowed. A more detailed
discussion of the proposed project's secondary environmental
impacts on the quality of recreation experiences in the
Island Park Area would aid in project assessment."
The Idaho Department of Health and Welfare recommended
in their November 3, 1975, letter that the final EIS should
address the secondary impacts of induced growth in much
greater detail than that given in the draft. The letter
went on to offer the following comment: "We must emphasize
that to be completely effective the project should be con-
structed in conjunction with a comprehensive land-use plan
for the area. This would serve to limit growth and develop-
ment in the area and ensure that the project achieves its
objective! of reducing water pollution."
The Idaho League of Women Voters also indicated a
concern about unplanned sprawl and the secondary land use
impacts of the proposed project. In its October 27, 1975,
letter the League stated: "... we do wonder about the
statement that development will tend to be confined to those
areas having a regional system. May we suggest that without
proper countywide planning and zoning, development is going
to continue wherever an enterprising developer believes it
is economically feasible." These and other comments served
to highlight the possible secondary impacts involved and
underlined the need for effective mitigation measures.
Mitigating measures
The major secondary impacts were resolved both through
through changes in the design and location of the facilities
themselves and through conditioning the Step 2 and Step 3
grant on the county adopting growth management measures.
As the first mitigation measure, after early consul-
tation with the EPA Regional Office, the consultant decided
to plan for smaller treatment systems to serve the problem
areas of greatest development activity as opposed to the
originally proposed single regional system with connecting
interceptors. This decision would tend to limit induced
growth to areas previously committed to development rather
rather than encouraging'sprawl along interceptor routes or
into environmentally sensitive areas.
236
-------
The smaller systems would be developed in
phases. The construction of each phase would depend
on the severity of the local contamination problem and
the_size of the population to be served. The combined
design technique of phased construction and individual
facilities with limited reserve capacity would minimize
the problem of induced growth associated with large
facilities that have uncommitted excess capacity.
Preliminary cost estimates were prepared for
a large regional system alternative serving all four
sub-areas. No formal cost/benefit analysis was per-
formed on this alternative, however, since it was
screened from further consideration during early
phases of facilities planning. This was done for
several practical reasons: (1) There was considerable
separation and distance between sub-areas. Transmission
costs would be prohibitive and technical problems would
result when trying to move low off-peak volume of sewage
long distances. (2) Sub-regional phasing recognized the
practicable limits of cost to users. User charges of a
large regional system would have been prohibitive during
early development of service areas with scarce concentra-
tion of connections. (3) Sub-regional phasing recognized
the reality of the State of Idaho's priority system, i.e.,
with limited funds available to the state for the Con-
struction Grant Program and with the project service a
developing recreational area, the likelihood of obtaining
priority for full funding of a large regional system was
questionable. Phasing permitted funding over a period of
several years. (4) In the absence of land-use controls
in an area with significant growth potential, sub-regional
phasing permits on-going evaluation of growth impacts and
adjustment of projects for later phases as necessary. This
in itself is a meaningful measure available to mitigate
adverse impacts. If adverse impacts do result and do
appear to be unavoidable, later phases of the project
could be reconsidered by both the applicant and EPA.
The grant condition was the second mitigating
measure. It was evident that a certain amount of growth
would occur within the service area of the proposed sub-
regional facilities. In the absence of planning, such
growth would predictably occur in a haphazard fashion
with adverse environmental impacts. The key to managing
this growth to avoid further environment degradation was
the extent to which Fremont County developed, adopted and
implemented an effective, comprehensive land-use with
companion zoning ordinances.
With proper planning and management, EPA felt
that the provision of a sewage system would help pro-
tect environmental quality and at the same time ensure
237
-------
that development occurred in a way that would be
sensitive to environmental problems. The EPA Regional
Office therefore concluded that the following grant
condition was necessary:
Fremont County shall, in accordance
with the State of Idaho Local Planning
Act of 1975 (Chapter 65, Title 67,
Idaho Code), develop and properly adopt
a comprehensive land-use plan and imple-
menting zoning ordinances applicable to
the project area. The comprehensive
plan shall include the participation
of land-use management agencies in its
formulation, implementation, and regular
review and evaluation. Agencies con-
sidered for participation shall include
such agencies as the Idaho State Land
Board, the Idaho Department of Fish
and Game, the Forest Service, U.S.
Department of Agriculture, and the
Bureau of Land Management, U.S.
Department of the Interior. This
condition shall be applicable to the
Step 2 design grant and, as the project
progresses, shall be carried over to apply
to the Step 3 construction grant award.
Payment beyond 80 percent on the Step 3
construction grant shall be contingent
upon the satisfaction of this condition.
Regional justification for requiring that the
county adopt a comprehensive plan and zoning ordinance
was based on requirements in the Idaho Local Planning Act
of 1975. That act calls for each county planning commission
to adopt a comprehensive land-use plan. Section 67-6508 of
the Idaho Code specifies that:
"It shall be the duty of the planning
or planning and zoning commission to
conduct a comprehensive planning pro-
cess designed to prepare, implement,
and review and update a comprehensive
plan . . ." (emphasis added).
In similar language, Section 67-6511 requires each
county governing board to adopt a zoning ordinance:
"Each governing board shall, by
ordinance . . . establish within
its jurisdiction one (1) or more
zones or zoning districts where
238
-------
appropriate. The zoning districts
shall be in accordance with the
adopted plan" (emphasis added).
The Idaho Local Planning Act was unclear, however.
about (1) what actions the state might take in the event
that a county did not develop the required measures or
(2) the question of establishing a timetable for counties
with no planning or zoning to comply with the requirements
of the Act. Nonetheless, the EPA Regional Office felt that
it was clearly the intent of the Act to institute compre-
hensive planning and zoning at the local level and that
the growth condition reinforced that intent.
ContinuingDevelopment
Because of the consultant's heavy workload (and
partly due to loss of the consultant's office in the
Teton Dam failure and flooding), the Step 2 grant was
not awarded until June 30, 1976. The county, state and
federal agencies accepted the grant conditions as pro-
posed in the final EIS. Fremont County had not completed
their comprehensive plan when designs and engineering
specification for the facilities were completed in mid-
1977, so the grant conditions were transferred to the
Step 3 grant.
Construction on the project was scheduled to
begin in the spring of 1978, with a draft comprehensive
plan expected to be ready at about the same time. (The
draft comprehensive plan must be finished before 25 percent
of the construction has been completed or else EPA will
withhold further funds.) Development of the comprehensive
plan has been slowed because newly elected county commis-
sioners had to be re-educated about the project, and be-
cause a great deal of public resistance exists to the
concept of planning.
Despite their resistance to developing a compre-
hensive plan, the county commissioners felt obligated to
proceed, primarily because the potential loss of federal
construction funds would represent a significant financial
burden to the county. According to schedule, then, the
final comprehensive plan should have been completed by
the fall of 1978, or before construction on the project
is 80 percent complete. If not, then EPA has the option
to withhold final payments.
Even assuming the county does develop an acceptable
comprehensive plan, however, there is no guarantee that it
will be used as intended to mitigate the secondary growth
impacts of induced development. Unless the county is
committed to the idea of controlling and directing growth
within its boundaries, the comprehensive plan may become
239
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no more than an expensive set of colorful maps
which, like many other similar plans, sit on office
shelves collecting dust.
East Bay, California
The community
On February 15, 1974, the East Bay Dischargers
Authority (EBDA) was formed as a joint powers authority
to implement a subregional wastewater treatment conveyance
and disposal program in the East Bay area adjacent to
eastern San Francisco Bay (see maps). (The program would
eliminate six shallow shoreline discharges of moderately
treated, chlorinated effluent from the eastern shore of
Lower and South San Francisco Bay.) The EBDA is composed
of two incorporated cities and three sanitary districts
in southwestern Alameda County, including the City of San
Leandro, the Oro Loma Sanitary District, the Castro Valley
Sanitary District, the City of Hayward, and the Union
Sanitary District (serving Union City, the City of Fremont,
and the City of Newark).
The service area includes a 1975 population of
456,300. Although much of the area is urbanized, a con-
siderable amount of open space and agricultural lands
still exists, including the area within the San Francisco
Bay National Wildlife Refuge and prime farmlands in the
Fremont area.
The problem
Although water quality in the entire bay system
has been improving over the last several years as the
result of improved point source control, some beneficial
uses of the bay waters are still impaired. These include
a restriction on shellfish harvesting for human consumption.
Dissolved oxygen depression and toxicity are other localized
problems in the bay, attributable to municipal discharges.
Localized pollution conditions persist around much of the
bay shoreline where surface discharges of treated effluent
occur.
Proposed solution
The Phase I project would improve water quality
along the east shoreline of the south area of the bay by
providing a deepwater central bay discharge point to replace
shallow shoreline discharges and thus permit increased
dilution of effluent. The project also would eliminate
two discharges of moderately treated sewage to sloughs
upstream from the San Francisco Bay National Refuge and
240
-------
provide wastewater reclamation opportunities in the
East Bay.
Planning for the Phase I Prolect officially
began in 1971. The preliminary steps of the facilities
planning stage were completed prior to EPA involvement.
On November 12, 1974 , EPA made a Step 2 grant offer to
EBDA for the eligible portion of EBDA's facilities
planning, as well as other preliminary planning.
The major part of the EBDA project developed
under the Step 2 grant included construction of a force
main interceptor and outfall system with a 1995 peak
wastewater flow (PWWF) design capacity of 185 ragd,
extending approximately 31 miles from the site of the
existing Union Sanitary District Irvington wastewater
treatment plant in the south portion of the City of
Fremont to a discharge point in north-central San
Francisco Bay. It also included the conversion of
Union Sanitary District's existing treatment plants
at Irvington and Newark to raw sewage pumping stations
and the consolidation of Union Sanitary District's
wastewater facilities at an expanded Union-Alvarado
treatment plan with a 1987 average daily waste flow
(ADWF) design capacity of 19.5 mgd,
The three existing plants for the City of Hayward,
Oro Loma-Castro Valley Sanitary District and the City of
Leandro, with a combined 1987 ADWF design capacity of
40.5 mgd,, would discharge secondary treated effluent
to the EBDA interceptor. The interceptor and outfall
were sized to take in additional PWWF of approximately
19.7 mgd from the Livermore-Amador Valley Water Manage-
ment Agency? which consisted of the cities of Pleasanton
and Livermore, and the Valley Community Services District,
all of which are located outside the EBDA service area,
EPA's review of the environmental assessment
required of EBDA as part of the Step 2 planning process
revealed an insufficient investigation of possible secon-
dary land-use issues. As a result, EPA decided to issue
an EIS and asked the EBDA member agencies to submit
mitigation proposals for land-use issues identified
during EIS preparation.
The EIS analysis concluded that the project is
not a direct causative element in the location or rate
of future growth. However, construction of the wastewater
treatment system will remove existing constraints to develop-
ment and accommodate a projected 23.9 percent population
increase—from 456,300 in 1975, to 565,700 in 1995, Many
241
-------
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DISCHARGERS AUTHORITY
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ENVIRONMENTAL
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-------
land-use impacts resulting from this projected
population increase can be classified as secondary
land use impacts. These impacts fall mainly into
three categories? those affecting water quality
and the aquatic environment, those affecting air
quality, and those affecting agricultural and
open lands.
A population increase could have an indirect
impact on nonpoint source of pollutants to the South
Bay ecosystem, affecting local biology and water quality.
Permeable land surfaces would be covered with impermeable
surfaces such as streets and buildings. Surface runoff
would increase over the next 20 years as development
occurs. The main aquatic habitats adversely affected
by an increase in surface runoff would be those shore-
line areas located in the southern half of the study
area—principally the salt marshy salt pond and mudflat
habitats within the present boundaries of the San
Francisco Bay National Wildlife Refuge. These habitats
provide great potential for human esthetic enjoyment as
open space and are of considerable biological value,
providing homes to many species of animals, some of them
rare and endangered.
A population increase has the potential to ad-
versely affect air quality, since the type of develop-
ment likely to occur would add considerably to the total
vehicle miles traveled (VMT) in the area. (Approximately
21.1 million VMT would be generated daily by vehicle trips
to, from and within the EBDA study area in 1995. This is
a 21 percent increase over 17.4 million VMT in 1975.)
Federal air quality standards are currently not being met
in the project service area.
Even assuming certain reductions in air pollutant
emissions per VMT over the next 20 years, it appears that
federal standards would continue to be violated.
Residential and industrial development is projected
to occur on prime agricultural land in the study area to
accommodate the anticipated increase in population. Of
the estimated 19r600 acres designated for future residen-
tial use by local governments, 5,900 acres are prime
agricultural land, of which about 5,000 acres can be
expected to be developed during the 1975 to 1995 period.
A major portion of the absorbed agricultural land would
be in Fremont if development is allowed in the Northern
Plain area. Projected industrial development would absorb
from 250 to 1,100 acres of an additional 3,160 acres of
prime agricultural land that is now designated for indus-
trial use by existing public policy.
244
-------
Other potential indirect impacts include
increased mudslide and seismic damage resulting from
development of areas both west and east of the presently
developed corridor.
Mitigating Measures
Following publication, public review and comment
on the draft EIS, preparation and approval of a mitigation
plan became a major ElS-related project activity. The
work program for secondary impact mitigations was pri-
marily directed at two major groups: (1) regional and
subregional agencies, and (2) local county and city
governing bodies and agencies. This approach was
necessary because neither EBDA nor its constituent
sanitary districts have any control over land-use plan-
ing, public or private transportation, or other signifi-
cant factors contributing to air pollution. Further,
they have little or no power to implement secondary air
quality mitigating measures (EIS p. XVII-8).
The most beneficial and long-term mitigating
measures were those tied to state and regional planning
programs, such as the State Air Quality Maintenance Plans
(AQMP), State Implementation Plans (SIP's) and the Asso-
ciation of Bay Area Government (ABAC) 208 water quality
management planning. However, because these programs
were not yet in effect, EPA required for phase I con-
struction funding only that EBDA strive for short-term
(4-5 years) mitigating measures, conceding that the
"local general purpose government was the proper agency
to propose and mitigate potential air quality emissions
by strategies tailored to the local agency's capabilities,
capacity, ability and resources to implement such measures'
(EIS, XVII-9).
As a result of EBDA efforts, resolutions were
passed by the local general purpose governments to per-
form additional studies, implement specific infrastructure
investment proposals, and implement land-use measures.
The applicant—EBDA—will be required by Step 2 and 3
grant conditions to take all reasonable steps to achieve
implementation of these measures.
Because the major projected secondary impact of
the EBDA project was increased air pollution from auto-
mobiles, primary emphasis was placed on reducing projected
vehicle miles traveled (VMT) within the EBDA Study Area.
A number of mitigation measures were proposed by the EPA
Regional Office as parts of two major strategies. The
first strategy is in two parts, /Transportation Mitigations
A and B: Transportation Mitigation A is a change or im-
provement of existing transportation facilities and ser-
vices, and Transportation Mitigation B is a plan for auto
245
-------
use disincentives. The second strategy, Land Use Mitigation
C, would reduce impacts by altering current land use policies
and regulations. Best mitigation results occur when Mitigation
C is used in conjunction with Mitigations A and B.
The following charts show the main mitigation measures
suggested by EPA and agreed to by the local general purpose
governments. Because some condensing and rewording was
necesary to prepare the charts, some measures may appear
different from the original measures submitted. A more
exact assessment of measures actually planned for mitigation
by the cities is available in the final EIS. A key feature
of the mitigation measures is a commitment to participate in
the areawide Air Quality Maintenance Planning effort.
The EPA Regional Office has suggested curtailing the
loss of agricultural and open lands by deferring any further
development on large scale sites with prime agricultural soils
until completion of a study of the economic value and need
for such lands. The Regional Office has also proposed that
the communities reevaluate the areas now designated for resi-
dential development on the hillsides—-with special reference
to potential safety hazards for road and utility linkages
needed to serve those areas-—in an effort to mitigate possible
mudslide and seismic hazards. However, there is no indication
that the grantee or general purpose governments will agree at
this time to the mitigation measures, and EPA Region IX does
not believe it has the authority to require the measure.
Although the new longer outfall pipe is expected to
improve water quality along the east shore of the bay, there
is no existing plan for mitigating the project's secondary
land-use impacts on water quality and the aquatic environment.
Mitigation is, however, expected to be accomplished by imple-
menting the Bay Area 208 Areawide Waste Management Plan.
246
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TABLE 18
VWT Reduction Strategy i 1
Transportation Mitigation A
Improvement of Existing Transportation Facilities
San Leandro
Hayward
Union
City
Newark Fremont
ro
1. Extend Rapid Rail Service; add new
service areas, bus stops and/or routes.
2. Provide transit rights-of-way: peak
or 24 hr. transit lines and busways.
3. Redesign terminals, stations, and
bus stops to improve functionality.
4. Establish local transit service
districts and improve existing service.
5. Incorporate subscription and charter
service into local transit. Incorporate
subscription/vanpool services at
large employment centers.
6. Develop bicycle routes,
7. Permit and encourage use of local,
short-range, low-power vehicles.
8. Coordinate schedules, fares, and
transfers among systems.
9. Improve services information
system.
10. Improve transit pricing structures,
including generally lowered fares,
and reimbursement of transit costs
to shoppers.
X
X
X
X
X
X
X
X
X
X
X
Source: 'Mitigating Secondary Impacts from the Wastewater Facilities'program:
an EPA case studies series, Office of Land Use Coordination.
-------
TABLE 19
to
*»
CO
VMT Reduction Strategy # 1
Transportation Mitigation B
Auto Use Disincentives
San
Leandro
Hsyward
Union
City
ITawark
Fremont
1. Control parking supply. x
Reduce and limit public
and employee parking on-street
and in suburban lots.
2. Promote car-pooling by providing
special bus/carpool lanes, preferential
job sites parking, other free parking
3. Encourage/require flexible
and staggered work hours.
4. Make downtown area parking
requirements (for city planning)
substantially less than city-wide
standards.
x
-------
TABLE 20
VMT Reduction Strategy # 2
Land Use Mitigation C
San Leandro Hayward
Union
City
Newark
Fremont
to
1. Increase planned intensity x
of all land use activities
near transit stations and major
transit corridors.
2. Require minimum levels of x
land use intensity to be
developed near transit stations
and major transit corridors.
3. Phase location of development x
with respect to transit access.
4. Increase planned intensity and x
variety of land use activities
in major activity centers.
5. Regulate minimum levels of land use
intensity to be developed in major
activity centers.
6. Have site plan review allowing x
city to require buffer zones.
x
x
X
X
X
X
-------
FOOTNOTES - CHAPTER VII
1. Mitigating Secondary Impacts from the Wastewater Facilities
Program: An EPA Case Study Series, Office of Land Use
Coordination, p. 4, unpublished report.
2. Direct Environmental Factors at Municipal Wastewater
Treatment Works, EPA 430/19-76-003, January 1976, p. 6.
3. Final Environmental Impact Statement, East Bay, California
Dischargers Authority Wastewater Treatment Facility,
1976, Chapter XVII.
4. "Consideration of Secondary Environmental Effects in the
Construction Grants Process," EPA PRM 75-26.
5. Ibid.
6. "Protection of the Nation's Wetlands," 38 FR, May 2, 1973,
p. 10834.
7. Mitigating Secondary Impacts from the Wastewater Facilities
Program: An EPA Case Study Series, Office of Land Use
Coordination.
250
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APPENDICES
-------
APPENDIX A
Calculations of Present Worth
If the interest rate is 5% then the present Worth can
be calculated as follows:
After the first year, the investment of Present Worth will
be valued at PW x 1.05;
After the second year, the investment increases by another
5% and is equal to (PW x 1.05) x 1.05 = PW x (1.05)2. But
this must equal $1.00; thus:
PW x (1.65)2 = $1.00 or
PW x ($l.dd/ (1.05)2 = $0.91.
Thus, $0.91 is the present worth of the receipt or expen-
ditures of $1.00 two years from now.
»
A general formula for calculating PW using any interest
rate is:
PW = E
where E = some expenditure
i = interest rate in per cent
100
n = the number of years from now that expenditure
will be made.
If the project life is 20 years, then
PW = C0 + G^WX + C2PW2 *..-C20PW20
+ Oiy^PWi * OM2QpW20
where C = capital costs
OM = operation and maintenance costs
Equivalent Annual Cost = ^PW) (i)
253
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User Charge Systems
Appendix B of the EPA regulations (40 CFR 35) provide
three model user charge systems which are given below.
(1) Model No. 1 - If the treatment works is primarily flow
dependent or if the BOD, suspended solids, and other pollutant
concentrations discharged by all users are approximately
equal, then user charges can be developed on a volume basis in
accordance with the model below:
Ct
Cu = (Vu)
Vt
(2) Model NO. 2 - When BOD, suspended solids, or other pollutant
concentrations from a P^er exceed the range of concentration
of these pollutants in normal domestic sewage, a surcharge
added to a base charge, calculated by means of Model No. 1,
can be levied. The surcharge can be computed by the model below:
Cs = £BC (B) + Sc (S) + PC (P)J
Vu
(3) Model No. 3 - This model is commonly called the "quantity/
quality formula":
Cu = Vc Vu + Be Bu + Sc Su + PC Pu
Ct = Total operation and Maintenance (O&M) costs per unit of time.
Cu = A user's charge for O&M per unit of time.
Cs = A surcharge for wastewaters of excessive strength.
Vc = O&M cost for transportation and treatment of a unit of
wastewater volume.
Vu = Volume contribution from a user per unit of time.
Vt = Total volume contribution from all users per unit of time.
Be = O&M cost for treatment of a unit of BOD.
Bu = Total BOD contribution from a u&.er per unit of time.
B = Concentration of BOD from a user above a base level.
Sc = O&M cost for treatment of a unit of suspended solids.
Su = Total suspended solids contribution fro-m a user per unit
of time.
254
-------
S = Concentration of SS from a user above a base level.
PC - O&M cost for treatment of a unit of any pollutant
Pu = Total contribution of any pollutant from a user per unit
of time.
Pt = Total contribution of any pollutant from all users per
unit of time.
P = Concentration of any pollutants from a user above based level.
255
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APPENDIX B
GLOSSARY
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.
^_Tre^ - 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 J7alorem tax - A value added tax such as a property tax.
Advanced waste_br_eatment/tertiary treatment - Provides
id^itionaT~Tr^a±iient~"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 xs discharged.
Average Flow - The average quantity of effluent which
~~~~~Interir~tKe treatment system .over a given time period.
Usually expressed as average daily flow.
Best Available Technology (BAT) - The degree of pollutant
----~ of the highest level
of technology economically achievable. BAT standards are
required for all toxic and nonconventional pollutants by
July'l, 1984, unless a variance is obtained.
Best Practicable Technology_iBPT)_ - The degree of pollutant
been granted by EPA
25?
-------
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
techniques.
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.
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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
waters.
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 (EIS) - A detailed analysis
of the 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
acceptable.
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.
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Gr antj-E 1 igib le - Refers to costs of planning and constructing
a treatment facility which may receive federal funds under
the EPA Construction Grants program.
Hou s e connec^on_^^_ho^e^at^^^Is_}_ - This is the point of
____
contact between the user and the treatment system.
Industrial_Co^st_jRecovery - A provision in the 1972 FWPCA
whicTTIr eqo I res~Tndui°t r i e s 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.)
Inf i It ration/In . flow - 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.
Ma in/gujamjijji - 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 PoILution^_i_s_charge. _ ^Elimin.atJ^on System (NPDES )
The e f f iTielvtr^dTsljh^^ she s ' 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 Pollutarvts - Pollutions which do not enter
the water from any~dTice"rnable , confined and discrete
conveyance but rather wash off, run off or seep from
broad areas of land.
_Cr^^ - 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) .
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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
conduct.
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.
Priority list - 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.
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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.
SepticTank - 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
, treatment.
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 sewers, physical
facilities employed to transport, treat, and discharge
sewage.
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.
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Suspended Solids (SS) - Small particles of solid pollutants
in 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
treatment.
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
wastes.
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
treatment.
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
achieved.
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 treatment improvements) and
enforcement plans, and an anti-degradation statement
to protect existing high quality waters.
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