United States
Environmental Protection
Agency
Water
Water Planning
Division - WH-554
Washington, DC 20460
                          November 1980
Summary Proceedings

Atlanta, Georgia
June 4-6, 1980
  National Water Quality
  Management Conference

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         SUMMARY  PROCEEDINGS
       NATIONAL WATER QUALITY
        MANAGEMENT CONFERENCE
          Atlanta,  Georgia
           June 4-6,  1980
       Water Planning Division
 Office of Water Program Operations
U.S. Environmental Protection Agency
       Washington, D.C.  20460

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                                FOREWORD


     The First National Water Quality Management Conference was held
in Atlanta from June 4 through 6, 1980.  Participants from EPA
Headquarters, from the Regional Offices, and from State and areawide
Water Quality Management Agencies met to review and discuss where the WQM
Program has been, what results it has gained, and where it is headed.

     The conference was organized around seven tracks which ran concurrently.
Six of the tracks addressed major components of the WQM Program:  agriculture,
facility planning/advanced waste treatment, financial management assistance,
ground water, urban runoff, and silviculture/construction.  A seventh track
offered discussions of the major policy issues affecting the Program.

     For three days, the conference provided a chance for free and open
communication between the people who make the program work.  Participants were
able to exchange ideas, air concerns and grievances, learn from the
experiences of other agencies, comment on program goals and direction, and,
at the end, come away with a better understanding of the WQM Program, and a
stronger sense of unity.  In this regard, the conference was a success.  Not
every question was answered, not every problem was resolved, but people from
throughout the Program were able to take a look at each other, to listen to
each other, and to find out just a little better than before what their
purpose and mission are all about.

     Speaking for myself, the Conference gave me a good deal of insight into
the major concerns and issues at the regional, State, and local  levels.  At
the same time, I felt that many participants discovered quite a lot about
the job we at EPA face in managing a national program and in dealing with
the twists and turns of the Federal budget process.  Overall, the Atlanta
Conference provided a valuable experience, and all of us, I felt, became
much more aware of what's going on with the WQM Program.

     Because the conference served so well as a communication tool, and
because the initial response has been so favorable, I am looking forward to
our next national conference in Chicago in October 1981.  At that time, we
can examine the progress we've made since Atlanta and determine what remains
to be done.
                                          Peter Wise, Acting Director
                                          Water Planning Division

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                                  TABLE OF CONTENTS


OPENING DAY ADDRESSES 	     1

       Introductory Remarks
         Peter L. Wise	     2

       Notes from a Regional Administrator
         Rebecca Hanmer	     3

       Who Needs Apocalypse, Implementation Now
         Merna Hurd	     5

       State Perspective on Water Quality Management Planning
         Charles Jeter   	   12

LUNCHEON ADDRESSES  	   15

       RCWP: A Cooperative Effort
         Winston L. Wilson	   16

       Sunrise, Sunset,  and If Only We Were Rich Men
         Mayor David H.  Shepherd	   21

 POLICY FORUMS   	   25

       SESSION 1:  Implementation and Evaluation  	   28

       SESSION 2:  The Next Five Years	   31

       SESSION 3:  State/EPA Agreements 	   35

       SESSION 4:  Small and Alternative Waste Treatments Systems 	   40

       SESSION 5:  Regulatory vs. Non-Regulatory Programs ... 	   41

       SESSION 6:  Self-Sustaining Planning 	   44

       SESSION 7:  Point/Nonpoint Source Priority 	   47

       SESSION 8:  Developing Effective Work Programs 	   50

 NATIONWIDE URBAN RUNOFF PROGRAM  	   55

       SESSION 1:  An Overview of NURP	   58

       SESSION 2:  NURP Objectives	   61

       SESSION 3:  NURP Case Studies	   64

       SESSION 4:  Case Study; City County Perspective   	   67

       SESSION 5:  Evaluation and Control Measures  	   68

       SESSION 6:  Pilot Studies of Large Cities  	   69

       SESSION 7:  Session Summary  	       72

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AGRICULTURE PROGRAM  	    75

      SESSION 1:  Model Implementation Projects   	    78

      SESSION 2:  Model Implementation Projects   	    80

      SESSION 3:  Clean Water Programs 	    82

      SESSION 4:  Water Quality Monitoring and Evaluation   	    85

      SESSION 5:  Nonpoint Source Studies  	    87

      SESSION 6:  Other Agriculture Water Quality Efforts   	    89

      SESSION 7:  Agricultural Water Quality Practices 	    92

GROUND WATER QUALITY PROTECTION PROGRAM  	    99

      SESSION 1:  Consultant Seminar   	   102

      SESSION 2:  Ground Water Protection Programs 	   103

      SESSION 3:  Managing Irrigation  	   107

      SESSION 4:  Legal Issues in Ground Water Management   	   109

      SESSION 5:  State Ground Water Protection Programs    	   Ill

      SESSION 6:  Ground Water Protection in the Southwest  	   115

      SESSION 7:  Summary Session  	   118

FINANCIAL ASSISTANCE MANAGEMENT PROGRAM  	   121

      SESSION 1:  FMAP Case Studies	124

      SESSION 2:  FMAP Case Studies	127

      SESSION 3:  Financial Issues and Approaches in Wastewater Facilities
                  Planning	129

      SESSION 4:  FMAP Case Studies	132

      SESSION 5:  FMAP Case Studies	136

      SESSION 6:  Financial Considerations in Facilities Management   ....   138

      SESSION 7:  A Framework for the Future	139

FACILITY PLANNING. AWT PROGRAM	   141

      SESSION 1:  National AWT Issues  	   143

      SESSION 2:  Making AWT Decisions 	   144

      SESSION 3:  Making AWT Assessments 	   145

      SESSION 4:  Case Studies of AWT	150

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SILVICULTURE AND CONSTRUCTION PROGRAMS 	   I53






      SESSION 1:  Cooperation Promotes Better Water Quality  	   156




      SESSION 2:  Sediment Control in Construction Activities  	   159




      SESSION 3:  Government Involvement in Construction to Improve BMPs . .   163




CLOSING REMARKS  	   167




EVALUATION SUMMARIES  	   171




CONFERENCE ATTENDANTS   	   179

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                                           THUMB INDEX
OPENING DAY ADDRESSES
LUNCHEON ADDRESSES
POLICY FORUMS
NATIONWIDE URBAN RUNOFF PROGRAM
AGRICULTURE PROGRAM
GROUND WATER PROTECTION PROGRAM
FINANCIAL MANAGEMENT ASSISTANCE PROGRAM
FACILITY PLANNING AWT PROGRAM
SILVICULTURE AND CONSTRUCTION PROGRAMS
CLOSING REMARKS
EVALUATION SUMMARIES
CONFERENCE ATTENDANTS  (NAMES AND ADDRESSES)

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OPENING DAY ADDRESSES

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                          INTRODUCTORY REMARKS

                               Peter Wise
     This conference marks the first time in many years, certainly
since the mid-70s, that representatives of EPA, other Federal agencies,
the States, and areawide agencies have had the opportunity to sit
down together to talk about the present state of the Water Quality
Management Program and its future.

     The aim of this gathering should be open discussion and the
sharing of ideas.  We all have important questions.  What is really
going on at the local level?  the State level?  What pressures do we
feel at the Federal level from Congress?  from the Office of Management
and Budget?

     As we all know, this is the important period when program plans
are being certified and approved.  Over 200 have completed this
process.  But funding is tight, and much work remains.  Not all the
institutional arrangements have been made; not all the technical
answers have been found.  The process and funding of implementation
are proving difficult.  These are the kinds of questions this conference
is designed to tackle -- technical, institutional, financial, and
policy issues.

     Some folks here feel they have come to see a funeral  for 208,
and others have come thinking that this is a good time to start
getting the program moving again.  We need to leave here with a
mutual  understanding of where we are and in what direction we should
go to meet our common objectives.

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                  NOTES FROM A REGIONAL ADMINISTRATOR

                Rebecca Hanmer, Regional Administrator
                            EPA  Region IV
     It's a pleasure to look out and see so many friends here.  I do
consider myself at heart a water quality person.  The greatest learning
experience in my professional career was the two years I spent with
the Water Quality Standards staff in the mid-60s.  It was at that time
that I learned some things that all  of you may have learned — that
water quality management (WQM) is in many ways environmental manage-
ment, that the concepts we deal with in water quality management are
very, very broad.

     In the Southeast we have water in abundance but not always in
the right place at the right time.  We have serious challenges ahead:

     •  the loss of our productive topsoil,

     •  the effects of growth and development,

     •  the maintenance of water pollution control  facilities already
        built, and

     •  toxic substances.

     I would like to speak to you briefly about challenges we all
face in the WQM Program and, in closing, mention two other serious
water quality management issues which affect and are affected by WQM.

     In terms of WQM, Region 4 has come a long way in experience
and training.  So now, just as we've gotten good at the job, where do
we go from here?  As you know, the money is decreasing.  The assumption
was that the States would have ample resources to pick-up their
planning responsibilities under the Section 106 program grants.  But
these grants aren't growing.  We aren't even keeping up with inflation.
EPA has assigned 208 funding priority only to nonpoint source
categories, although some people feel we haven't finished with other
areas of the program.  To some extent there has been recentralization
of decision-making on funding priorities.

     My staff and I feel it is important, particularly at this time,
for areawide agencies to do a better job tying water quality manage-
ment into the local comprehensive planning process -- a process which
has already existed for decades.  As you know, zoning decisions greatly
affect water quality and are based on a comprehensive plan, as are
subdivision regulations.  So far, at least in Region IV, only a few
jurisdictions have adopted WQM plans as part of the local comprehensive
plan.

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     Also, we should consider tying HQM planning into other nonpoint
source programs in a more effective way.  We should encourage more
memoranda of understanding with other Federal agencies.  As our funds
decrease, we could perhaps ask for more of their funds.  This means
that we have to do a good job of convincing people that WQM is part of
-their mandate, a part of their goals, and an aid to their effective-
ness.  There may be opportunities where overlap is taking place, where
we can identify and use other programs to greater advantage — for
example, the U.S
. Geological Survey.

     WQM planning, as I said earlier, moves beyond its program boundaries
in response to real problems that were never really limited to surface
water quality problems.  For example, some of the WQM plans resulted
in very good surveys of solid waste management practices, some have
dealt with ground water protection, and some even addressed air
quality and toxics.

     There are two more issues involving WQM that I feel  are very
important from the regional  perspective.

     First, we must have one set of water quality goals for a State, and
one realistic perception of the major water quality problems.  We
must also understand that WQM planning, construction grants, State
and Federal regulations, permits, and other activities are tools and
not ends in themselves.  We need to achieve a common agenda which
allows us as managers to find the most cost-effective tools to get the
job done.  For too long, we've let the tools determine the goals of
the program rather than the opposite.

     Finally, it's time that we put a good deal  of our attention
and resources into strengthening the water quality standards for the
future.  In 1967, in order to get standards on the books, we made
many compromises -- saying to ourselves that we would come back later,
evaluate them, and make them better.  We never did.  As in many
environmental programs, we were largely disbanded after the initial
standards were set, even though they were based on scanty, sometimes
untested information.

     These standards, however, are the goals we all work  towards.  They
will last long after the facilities we build have been changed, and
the permits we issue have been reissued, and the plans we make have
been revised and updated.  If we do not make our standards more
adequate, usable, and realistic, and if we do not make them the back-
bone of our planning efforts, WQM planning and all  other water
protection programs will lose their credibility and their value.

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                    WHO NEEDS APOCALYPSE?--IMPLEMENTATION NOW
                                                           \

                                   Merna Hurd
                       Associate Assistant Administrator
                         for Water and Waste Management
   Let me begin with a question.  If you were asked to rewrite the
Clean Water Act, how would you do it?  What directions would you have
it take?  What priorities would you give it particularly when you have
limited  money?  Most importantly how would you go about carrying it out?

   Coming to grips with our environmental ills over the past several
years has been like peeling off the layers of an onion.  Each layer we
draw back has revealed new and more insidious varieties and sources of
pollutants, as well as additional problems in dealing with each other as
human beings.

   Until very recently our environmental "reflexes" have been set to
handle those pollution problems that we could neatly conceptualize and
isolate.  So, if the oceans are threatened, we place a deadline on dumping
at sea.  If a municipal treatment plant can't handle heavy metals, we
establish pre-treatment standards.  If hazardous wastes are being disposed
of irregularly, we propose regulations--another set outside of the Clean
Water Act.  If drinking water quality is lagging, we slap a program on that
too.

   Nonpoint and point sources were to be addressed collectively in the
WQM plan several years ago, initially in urban-industrial areas.  This was
expanded from State border to State border, and then we dropped back down to
nonpoint sources.

   Currently the agency is pursuing superfund legislation, to provide the
resources to deal with abandoned hazardous waste sites and spills.

   This is where the 80!s begin after an era of legislative response and
innovation.  We are approaching an era begging for administrative creativity.
I want to address some of the management approaches that I personally
believe we must develop in the long run to deal with our environmental
problems.  But, since our program addresses WQ management, we'll look first
at the past and immediate future.

   I want to divide my discussion today into five major points.

   1.  How are the accomplishments of this program perceived by other
       people?

   2.  What are present Congressional attitudes and activities?

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     3.   What must be accomplished in WQM over the next  three years?

     4.   What are the politics of implementation?

     5.   What lies beyond 1983?

Accomplishments

     How successful have we been?  Over the last six years,  226 agencies
received $360 million and we spent something less  than $300  million.   As
of last week, 203 WQM plans have been approved;  183 have been certified.
But I want to be blunt, planning programs are not  popular in Washington.
Two years ago it was touch and go whether this program would survive
through all the budget process including EPA's,  OMB's and the Congress's.
There will always be people who believe plans accomplish very little.   I
disagree.  Plans are necessary so that you know where to put your resources.

     By October of this year, 370 local governments and 20 States have
passed laws and ordinances to implement part of the WQM plan.  These  laws
address a number of problems:  sediment and erosion control, construction
priorities, septic system management, aquifer protection, and land use
measures.

     The WQM program has also led to significant cost savings for many areas.
As we pointed out last year during the Congressional oversight hearings,
208 WQM planning has to date saved over $500 million for State and local
governments by reducing costs for municipal waste treatment--more than the
amount spent on the entire WQM program.

     When I've traveled around the country, I've also found  example after
example of real accomplishments.  Many States are directing  some of their
agricultural monies to areas they have decided have priority.

     One of the most encouraging interagency agreements I've seen is  the
one between EPA and the Department of Agriculture.  There has been a  real
change of attitude.  I think we have both had an impact on each other.  They
have given us details to work on in regional offices which have helped
tremendously with the implementation of our programs.  Now I see that
several States have developed cost-sharing programs to help implement
agricultural programs and, in the case of Wisconsin, other programs on non-
point source of pollution.

     We have been moving into the ground water area.  There are several
very good programs.  For example, there are now projects dealing with
nitrates in Nebraska and copper problems in Arizona.  New York and New Jersey
are both developing excellent comprehensive ground water programs.

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     We're moving into stormwater management.  We're looking at the problems
of on-lot systems.  Connecticut is studying  sewer avoidance so that we
will be able to look at the cost impacts on small communities.

     So I see some very good work being done.  There are many technical
problems, but it is a very complicated program and it covers a lot of
different personalities; this means handling turf issues between different
agencies.

Congress

     As an update on Congressional attitudes and activities on the WQM
program, I can say the following:

     •    PUBLIC WORKS COMMITTEE.  They have been supportive and want to
          give the program time to work.

     •    APPROPRIATIONS.  It was a struggle last year but we finally got
          our budget.  Last year's oversight hearings were generally quite
          positive toward the program.

     *    AUTHORIZATION.  Both the House and Senate have supported us with
          more money than in the previous bill.  We will face authorization
          and whether to continue the program again in 1983.  Next year the
          construction grants will be up for authorization.  There will be
          an examination at that time of what we have accomplished.  I do
          not expect major problems.

     •    APPROPRIATIONS. I am pleased that the 106 and 108 programs have
          not taken budget cuts, that we have had the support.  Of course,
          our programs are under close scrutiny at this time and there is
          competition even between our environmental programs.

     •    CHANGING CONGRESSIONAL MEMBERSHIP.  Muskie in the Senate with
          budget and public works has been very supportive of the water bill.
          He has influenced a lot of Senate decisions.  Cleveland of
          New Hampshire has retired and several others are facing very tough
          elections.  Leadership will be completely different and this will
          affect our programs.

What Must Be Accomplished?

     I project an optimistic future.  Funding support is likely to remain
about the same; big expansions in the Program are unlikely.  Continued
support, however, will mean several things:  plans must be implemented;

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nonpoint source issues must be adequately handled; the resources we have
must be better managed.  Ultimately, the water will have to become cleaner.
That's the final measure of success.

     What will the role of EPA be?  Is it to oversee monies to make sure
it's spent well?  Is it as a regulatory agency, to make sure we have those
permits out there?  Actually, I always hoped it would be more than these,
rather as a store of knowledge and provider of technical assistance.  Of
course, I'm not saying that we know it all, because we don't.  But we do have
strength, from my observations in the last several years, in areas where we
have a great deal of weakness nationwide, e.g., financial management, ground
water, wasteload allocations and modeling, etc.  We have brought together
a group of experts to assist projects developed out in local and State
government.  You will then have access to some technical expertise.  This
will be the most difficult task in the next couple years:  how to take
that information and transfer it?  Part of this conference is to stimulate
you to go back, try something a little different, exchange ideas and tell
us how it works.  So in the next three years, we need to document problems
in more detail and how to solve them.

Politics of Implementation

     Implementation is politics.  There's no question that you know that
already.  You work in state and local agencies, but you do not make the
final decisions.  You have to go to the politicians who will commit the
monies for implementation.  Our politicians have to be convinced that our
proposals will benefit  the community.  But we have to 'learn to deal better
with these people.  We usually present all this technical information on
impacts to water quality.  But we have to look at the financial impacts.
How much is it going to cost if we don't do something?  I don't mean just
the impact on water quality or fish, but will it cost more if we don't take
care of the problem in the future?  Who is going to pay for it?  How do we
finance it?  How do we allocate the cost?  What are the impacts on the users
and how much guff will come back to the politicians over the telephone
line?

     I see many examples when we look at past projects.  If you start
documenting sewer extensions for example, you can show the amount of money
that a county or city has paid over the last few years on septic system
failures, how much it  cost the community and who really has been paying
for it.  If you can present this to the politicians, particularly with the
strong public support behind you, you can show why it's so important to
pay for manpower to regulate the construction of those systems.  You also
have to describe the various methods to pay for them.  I firmly believe
that the weakest part of most of our plans has been economics and financial
management.

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     We also need to understand the relationships between Federal, State
and local financing.  Incremental borrowing of money obtained by local
levels of government through tax-free municipal bonds is much more
economical and less inflationary in the future than the same amount of
money spent at the Federal level through deficit financing.  There's no
question that the Federal government provides some incentives to get
programs moving, as well as often being the scapegoat.  But some things
just aren't going to happen politically at the State or local level unless
there is a hammer over somebody's head or perhaps some kind of technical
assistance.  So each level of government has an important role but we must
become expert in this area to develop the kinds of financing we need in
State and local government.

What's Beyond 1985?

     So far, I've spelled out some of the program directions which have
taken place in the last year.  So now, I know you're all concerned about
"what's beyond 1983?"  Will there be water quality management?

     There has to be water quality management.  Water resources are one
of our basic resources in this country and we simply must manage it; so we
must develop those programs.  There will have to be changes.  We simply
have to grow and that has an impact on our jobs and relationships among
some of our people.  But those changes will have to occur gradually over
time.  Pre-planning will prevent chaos.

     There are some changes happening right now which will have a significant
impact on the WQM Program.  Over the past few weeks, the Water Planning
Division at EPA moved from the Office of Water Planning and Standards to
the Office of Water Program Operations.  What does this mean for all of you?
It means that responsibility for planning and management under Sections 201
(step one) and 208 will be located in our shop under the general heading
of WQM.

     In addition, a major effort called Construction Grants 1990 is underway.
I am in the process of moving into one of the deputy slots in this program.
My area will be planning and policy.  I've since been put on as the
Chairman of the 1990 Construction Grants Project.  It's whole purpose is to
revamp the construction grants program.  We're looking at the short-term
and long-term purposes of the program, in other words, defining the whole
water quality management process including:

     e    funding options (eligibilities)

     e    continuing operations (can we cut down on the time it takes to go
          through grants process?)

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     •    compliance (what can we do to avoid compliance problems by
          treatment systems?)

     •    planning (wasteload allocations, water quality standards,
          nonpoint sources)
          (How are we going to deal with the toxic strategies for
          standards?)

     •    institutional (what is the role of WQM plan?)

Over the next four or five months we will try to bring as many of you and
others involved to look at some of these issues and decisions.

     The main challenge of the next decade, I feel, is to refine and
coordinate the programs which were erected in the previous decade, to
develop an integrated and comprehensive management strategy, and most
importantly, to develop systems to safely dispose of the pollutants which
we have learned to screen out of our waterways.

     Chris Beck initiated several efforts to lay the groundwork to achieve
these goals.  Specifically,

     1.  a construction grants program,

     2.  the institutionalizing of methods to properly control hazardous
         wastes,

     3.  a plan of attack on the next generation of toxic substances,

     4.  a comprehensive ground water strategy.

     These strategies do not constitute every major water quality considera-
tion which will be heard in the 80's, but they do represent important
areas whose total development over time is inevitable.

     With these new areas of concern and the on-going implementation
activities I've described,  the WQM Program still has a good deal of work
ahead.  The reports of our untimely demise have been greatly exaggerated.
Still, many of you have heard references to the 1983 sunset of the 208
legislation.   This needs some clarification.

     The Clean Water Act requires reauthorization for FY 1983 which begins
in October 1982,  a mere two years and four months away.  This means re-
authorization activities will begin soon.   In 1981, a new Congress will
be in session.   Senate and House staffers will review the WQM Program
throughout 1981.   Mark-up hearings on new legislation will start sometime
                                      10

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in early 1982 and, if there are no hitches in the process, new legislation
should be passed in late summer to go into effect on October 1.  Even if
the Program were not to be reauthorized, FY 81 and FY 82 funding would
still carry over for some time—which accounts for references to program
sunset in 1983 and even 1984.

     I feel strongly that we must all work jointly to prepare for next
year's look at the Clean Water Act.  Big changes may be forthcoming, but
there will be a water quality program.  We need to help shape and guide
these changes by providing assistance to those people working on the
bill, by providing leadership at the State and local levels, and by all
of you Keeping your individual Congressional delegations aware of what's
going on.  They have to hear from you that the WQM Program's continuation
is vital.

     Sometimes I stop and wonder if all our efforts will make any difference
at all?  Yet, when you look at where we are today, you see a different
picture.  We're actually doing something now about nonpoint sources of
pollution.  People say we haven't done anything about ground water except
in individual States, but we are moving forward on ground water management.
Many States have their own programs and State/EPA Agreements are the
first step to have all of us look at all the programs together.  Maybe
much of it has to do with timing and just working one step at a time.  We
are all faced with a great challenge which in some ways I really welcome.
I look forward to working with you over the next several years in whatever
capacity I can.
                                          11

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         STATE PERSPECTIVE ON WATER QUALITY MANAGEMENT PLANNING

      Charles Jeter, President, Association of State & Interstate
                 Water Pollution Control Administrators
     Today,.! would like to address two major concerns which affect
the direction of the overall water pollution control effort, concerns
which,  I think, extend to the entire issue of improving environmental
quality.

     First,  I would like to talk about two aspects of program
integration:

     t  the  integration of EPA, State, and local regulatory programs
        as they apply to clean water, clean air, hazardous waste,
        safe drinking water, and similar programs.

     •  the  interrelationships between EPA programs and those
        primarily associated with resource conservation agencies.

     WQM planning may have been weakened, because many people believed
that it focused on only a narrow range of water quality problems
rather  than the broader environmental picture.  One of the basic
laws of ecology applies to our environmental  regulations, that is,
everything is tied to everything else.  While this has been a
particularly important concern in the passage of environmental
regulations, implementation of a well coordinated set of diverse but
interrelated environmental programs remains doubtful.  For example,
the impacts of the Clean Water Act, the Clean Air Act, and the Safe
Drinking Water Act can sometimes conflict.  Decisions in one area
have not always been weighted in terms of the environmental impacts
in other areas.  Removal of pollutants from surface water under the
Clean Water Act led to sludges which when incinerated affected air
quality and when disposed of on land affected ground water quality.
Compounding these interrelationships were the changes in emphasis in
some environmental control programs.  Previously air and water pollution
were stressed; nowadays, the two national priorities are hazardous
waste and ground water pollution.

     These kinds of problems have led to administrative efforts to
integrate the particular programs.  The State/EPA agreement has
attempted to look at various aspects of problems which individual
programs could not handle alone.  This effort has been fairly effective
but it is again an administrative effort to implement the complex
tangle of environmental  legislation.
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     Another critical area  in  program  integration  is the  relation-
ship of EPA and State agencies with  local  planning agencies,  primarily
local councils of government.  Most  of the money for environmental
protection is spent at the  local  level.  To make this effort  work,
you need the local agencies, local public  support, and local  planning.
Ways to integrate local comprehensive  planning with WQM efforts should
be explored.  Local governments can  do some things that the Federal
and State levels can't.   Land  use planning and siting requirements
come to mind.  Through these kinds of  legal mandates, local govern-
ments can improve their communities  by making water quality con-
siderations a part of their normal planning activities.

     Another type of critical  relationship exists  between EPA and
the resource conservation agencies where both share their expertise
to solve water quality problems.   This includes diverse groups such
as the Soil Conservation  Service,  the  U.S. Forest  Service, National
Association of Conservation Districts, the Agricultural Stabilization
and Conservation Service, and  others.  These agencies have an existing
structure with invaluable historical expertise.  Many of the  practices
they have promoted for years to manage resources help control water
'pollution as well.  They  also  have a better rapport with their con-
stituents that can give them an edge over  regulatory agencies in
carrying out a program.   These agencies are looked on with favor since
their  resource management efforts can  provide direct benefits to
local  people.  You can sell resource control much  easier than environ-
mental control.  Linking  the two  by  having conservation agencies
give proper consideration to environmental problems, however, is one
way to achieve both.  Although their basic responsibilities are not
water  quality, if we, as  environmental managers, work with them, we
will all come out ahead.

     We can talk about regulations,  legal  problems, and other com-
plications, but  if you don't have the  spirit of working together,
if you don't have cooperation  between  all  levels of government, and
if you don't have good relationships between environmental and
resource conservation groups,  none of  us will get  very far with our
water  quality efforts.  A spirit  of  mutual understanding  and  trust is
vital.

     The second  broad issue I'd like to talk about today  is the refine-
ment of basic cause and effect relationships, that is, improving the
"state of the art" as to  what  pollutants at what concentrations cause
what effects.  For example:

     •  what materials cause concern and in what concentrations?

     t  what kinds and amounts of materials affect aquatic life
        cycles?

     •  what environmental  damages are occurring now that won't be
        obvious  for 20, 30, or 40 years?
                                         13

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     •  what  should be the minimum  priority of contaminants  in  our
        drinking water suppies?

     •  what  is the impact of nonpoint source pollutioon  and  how  good
        are our control systems?

     t  how valid are water quality limits for various  pollutants?

     t  how valid are our predictive modelling techniques?

     t  what  is the present quality of our ground water resources
        and what protection is needed?

     Our knowledge of these and other areas is such that  we either
overreact, underreact, or we aren't quite sure what to  do.  Whether we
discuss issues of water quality standards, predictive modelling,
classification of streams, or nonpoint source control measures, we
must decide whether we have a problem and to what extent  it is one.
Most of the people we deal with are reasonable and are  amenable to
solving real  problems.  But we must correctly identify  these  problems,
and be able to support the approaches we take towards solving them.
For example,  a technical gap in justifying national water quality
standards, particularly national ones, will create real problems.

     In this  decade, environmental  protection requirements are under
close scrutiny.  People are questioning them.  If we are  not  able to
show that our decisions are balanced, that they solve real problems,
then our whole program will suffer.

     We must  take a look in a fair, unbiased, and candid way at our
modelling techniques.  How good are they?  Are they usable, and what
do we do in the absence of a usable model?  Spelling out cause-effect
relationships is vital to the 208 Program.  Many times, 208 planners
and managers  have consciously tried to come up with WQM plans in the
absence of a  good foundation.  But how can you plan water quality
if the numbers keep changing and if you get continual  disputes over
numbers.  Accepting approaches that may not be technically justified
can come back to haunt us.

     In closing, I'd like to emphasize the need  for integration,
understanding, and cooperation among environmental  protection
programs,  State and local  agencies, and resource conservation agencies.
We also need  to look at our priorities and make  sure that we have
the information we need to make correct decisions.
                                        14

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                                                          I
LUNCHEON ADDRESSES
         15

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                      RCWP:  A COOPERATIVE EFFORT

        Winston L. Wilson, Deputy Under Secretary of Agriculture
                         for Commodity Programs
     On January 18, 1979, EPA and USDA renewed an agreement to share
employees, funds and facilities to accomplish an important job.  That
job includes cleaning up rural waters, protecting important farm and
forest lands from development, creating sound pest control programs,
and cooperating in other areas of mutual  interest.

     Specifically, the agreement signed by Secretary Bergland and
Administrator Costle commits the two departments to share information,
use one another's facilities, transfer funds, loan employees, and
review one another's programs.

     In keeping with the spirit of that agreement, I am pleased to
have this opportunity to share some thoughts and information with you
on one of the most important areas of EPA/USDA cooperation -- the Rural
Clean Water Program (RCWP).

     Producing any major rural conservation benefit requires a great
deal of cooperation, not only among the agencies involved, but also
among the agencies and the farmers, the taxpaying public, and a
large number of others who have a hand in conserving the quality of
our natural resources.

     Through cooperation with farmers, a great deal of soil  and water
conservation has been accomplished over the past 40 years under various
USDA programs.  One such effort is the Agricultural Conservation
Program (ACP).  Through ACP we have gained valuable experience in
utilizing a unique farmer-elected committee system to gain cooperation
in conservation efforts at the grass roots.

     Many of you are probably familiar with ACP -- perhaps from
first-hand experience — since the practices carried out through ACP
have been the model best management practices in our joint efforts
with EPA during the past few years.

     The newest conservation effort, the Rural Clean Water Program,
offers us an excellent opportunity to show what can -- and must -- be
achieved with teamwork.

     My background as a Texas wheat and cotton farmer gives me a
special appreciation for the value of teamwork, and the value of
water.  And, you can understand why I was pleased to read a statement
by EPA Assistant Administrator Eckhardt Beck in a recent issue of the
"Water Quality Management Bulletin."  Since I agree with his conclusions,
I gladly quote a portion of his comments:
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     "There is more than a business relationship between a farmer and
the land.  There is also an environmental relationship.  Farmers
intuitively grasped the concept of 'ecology1 long before it attained
its present vogue.  They had to if they hoped to survive.  And although
you will rarely read about this in the newspapers, today's farmers
are probably doing more than ever to help clean up the Nation's lakes
and streams.  Much work remains, however.  In several areas, soil
erosion from American farms now exceeds that of the Dust Bowl days
of the 1930's, and much of it finds its way to our waterways."

     As Mr. Beck pointed out, much needs to be done.  It's going to be
a big job -- one that will surely test our ability and willingness
to work together.  To even begin to meet the challenge of cleaning
up our rural water supplies, we will need a cooperative effort at
every level -- federal, state, and local.

     Since we began the Federal agricultural conservation effort 40
years ago, our population has grown from about 120 million people to
some 220 million.  Our agriculture has grown from many small farms
with relatively few head of livestock, relatively little use of
fertilizer and virtually no pesticides, to fewer, but much larger,
highly-mechanized operations with concentrations of large numbers of
livestock and extensive use of a wide variety of agricultural chemicals.

     Through erosion, drainage and leaching, residues from agricultural
operations have become a major source of nonpoint source water pollu-
tion in many areas.  Without proper methods of conservation and control,
it follows that these pollutants will continue to contaminate streams
and lakes, and adversely affect our nation's water supplies far from
their sources.

     The problem becomes all the more acute when we recognize that
just a few years from now, we'll need significantly more water than
we use today.  All of which points up the need to protect and manage
the quality and quantity of our water supply.

     This was the reasoning that prompted the Congress to appropriate
$50 million for an experimental Rural Clean Water Program specifically
geared to improving water quality.  One of the objectives is to glean
more precise information regarding both the nature and magnitude of
the problem.  Another is to identify the practices that have the
greatest potential for solving the problem.  Unlike many other water
quality efforts, it is not an erosion control program, or a water
conservation program, per se.

     RCWP will provide long-term financial and technical assistance
to enable private landowners and operators to install and maintain
best management practices to control agricultural pollution.  The
program will share up to 75 percent of the cost of BMPs that reduce
the amount of pollutants entering a stream or lake.  Practices that
do more to increase agricultural production than to control pollution
are not eligible.  Nor are practices aimed primarily at flood control
or those which do not have a significant impact on the quality of
receiving waters.

                                        17

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     The $50 million appropriated in the current fiscal  year will
remain available until  it is spent,  and we've requested  $20 million for
fiscal 1981.  RCWP is intended to supplement ACP and other existing
programs, particularly in areas that have not made full  use of ACP
or where there's a critical  need to  improve water quality.

     I'd like to emphasize that RCWP is an experimental  program in
more ways than one.  If it is to be  on-going --  particularly in these
budget conscious times -- all of the agencies involved must demonstrate
to the Congress that they can, as a  group, give  the taxpayers their
money's worth in cleaner water and an improved environment.

     The success of RCWP depends on  the combined efforts and co-
operation of a number of agencies.  The Agricultural  Stabilization
and Conservation Service is the administering agency. Selection of
best management practices will be made with the  concurrence of the
Environmental Protection Agency.  The Soil Conservation  Service is
coordinating all technical services  of the various groups.  These
include the Forest Service,  Cooperative Extension Service, Farmers
Home Administration, Economics, Statistics and Cooperative Service,
Soil Conservation Districts, State and areawide  water quality planning
agencies, soil and water conservation agencies,  and others.  Last,
but not least, are the cooperating landowners and operators.

     In consultation with EPA, Secretary Bergland approved 13 Rural
Clean Water projects in March.  These initial  projects were selected
from 64 applications that had been submitted to  the Department last
summer under the Clean Water Act of  1977.

     I'll run through them briefly:

     Alabama -- Lake Tholocco in Dale and Coffee Counties,

     Delaware -- the Appoquinimink River Basin in New Castle County,

     Idaho -- Rock Creek in  the south-central  part of the state,

     Illinois -- Highland Silver Lake in Madison County,

     Iowa -- Prairie Rose Lake in Shelby County,

     Kansas -- the Upper Wakarusa River project  in Shawnee, Osage
     and Wabaunsee Counties,

     Louisiana -- the Bonne  Idee project in Morehouse Parish,

     Maryland -- Double Pipe Creek in Carroll  County,

     Michigan -- Saline Valley and Mill  Creek,

     Tennessee -- Reel foot Lake in northwest Tennessee and part of
     its watershed in Fulton County, Kentucky,

     Utah -- Snake Creek in  Wasatch  County,

     Vermont --  St. Albans Bay, and
                                        18

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     Wisconsin -- the Lower Manitowoc River watershed  in the east-
     central part of the state.

     About 3,300 eligible farms are located in the 13  project areas.

     These particular projects were selected not only  to encompass a
broad geographic range, but also to include as wide a  range of non-
point source pollution problems as possible.  A major  goal of this
experimental program is to develop and test procedures to control
pollution from a number of sources -- salinity, sedimentation, agricultural
chemicals and nutrients, irrigation, animal wastes, and so forth.  We
view RCWP as a proving ground for new tools to improve water quality --
tools that reflect the dramatic changes in farming and the newer,
greater demands made on the nation's water supplies.

     But that's still in the future.  Right now, state and local
coordinating committees are completing plans of work for each project
that will outline the overall strategy to be taken and the specific
practices that will be needed.  EPA and USDA will jointly approve
best management practices for the projects after they  are developed
at the local level.

     Some BMPs will involve improved management.  Others will require
design and engineering work.  Some examples of those likely to be
included in the project areas are:  conservation tillage, sod water-
ways, filter strips, terracing systems, fertilizer and pesticide
management, animal waste control or management systems, diversion
structures, and irrigation water management.

     After we've received and approved all the plans — which is
realistically only a short time down the road -- we'll know how much
money, if any, we have left over out of the $50 million.  If there is
a significant amount, we may be able to move on additional project
applications later this summer.  As I mentioned earlier, the original
13 projects were selected from applications submitted under the Clean
Water Act of 1977.  New projects will be developed by the local
rural clean water coordinating committees and submitted through the state
coordinating committee for national  committee approval.  Local
recognition of the problems is a most important element of RCWP,
because there must be an acknowledgement of critical  water quality
problems as well as a local commitment to solve the problems.  The
key to the success of the program is not only cooperation at the
national  and State level, but cooperation and commitment on the part
of local  people.

     Meanwhile, we'll  be allocating funds on a project-by-project basis
as each plan of work is approved.  We have received most of the plans
for review.  Once these are approved, the farm plans and contracting
can begin.   And, it's conceivable that many farmers will begin putting
in the actual  practices this summer.
                                        19

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     RCWP is a voluntary program.   All  farm owners or operators of
privately-owned farmland in the project areas may participate if their
activities significantly contribute to  water quality problems.

     Participating farmers must enter into a contract agreeing to carry
out an approved water quality plan on their land.  Water quality
plans will be developed with help  from  SCS and approved by the Soil
Conservation District.  Depending  on the best management practices
specified in the plan, RCWP contracts will  run from 3 to 10 years.
However, all cost-shared practices must be maintained for at least
5 years after they are installed,  or for the lifespan of the practice
if that is longer.

     ASCS county committees will  approve RCWP contracts and administer
cost-share payments.  There is no  annual payment limitation, but each
producer will be limited to $50,000 during the life of the project.

     That is not the end of the rural clean water process, however.
Far from it, I can assure you the  results of the program are going to
be carefully analyzed and evaluated as  a joint effort by USDA and
EPA.  Our water resources, present and  future, are too vital to do
otherwise.

     We want to determine what works best in different situations and
how effective the program is in improving water quality.  A comprehensive
monitoring program will concentrate on  selected project areas.  From the
results, we hope to make national  projections about the cost-effectiveness
of best management practices and the program's overall  impact.  And
by comprehensive I mean keeping close tabs on water quality in the
selected areas for up to 15 years.

     If the program meets its objectives, we will not only develop
policies and procedures for controlling agricultural  nonpoint source
pollution, we will also achieve offsite public benefits.  And that,
after all, is our primary objective —  to improve the environment
by keeping pollutants out of our water, preventing fish losses, enhancing
water quality, reducing costs to cities and towns for water purification,
and providing new and improved water recreation areas -- in other
words, community-wide benefits.

     As I mentioned earlier, this  is an important job, not only because
it should be done, but also because the Clean Water Act directs
the EPA to seek fishable, swimmable waters nationwide by 1983.  And,
while there is much that EPA can do, the elimination of the largest
pollution source -- agricultural  runoff -- cannot be accomplished in
a short time by a single agency.

     We welcome this opportunity to continue our joint efforts with
EPA and others to apply all of the expertise in a coordinated effort.
It is vital  that we make the Rural Clean Water Program experiment a
success.

     Working together, we have the tools to get the job done.
                                        20

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            "SUNRISE, SUNSET, AND  IF ONLY WE WERE RICH MEN!"

              Mayor David H. Shepherd, Oak Park, Michigan
     This talk has a title — SUNRISE, SUNSET, AND IF ONLY WE WERE
RICH MEN!  I come before you today as a mayor, a local elected official
— one who has been involved in regional matters for some time and in
208 almost from its beginning.  I look out among you and I see many
people who I've met and worked with, people who are with regional
agencies, people who are with EPA, people who are with States, but I
don't recognize any of you as mayors.  That puts me in the smallest
minority position of all -- one.  So, before I talk about water quality
management and 208 in particular, let me help you with your education
by telling you what it takes to be a mayor today.

     Truthfully, it takes a bit more to be a successful  mayor.  It
takes a commitment to the job in all of its facets and the willingness
to speak out.  It is in my effort to be a successful  mayor that I
appear here to speak out on 208.  Let me make one point abundantly
clear -- I , as a mayor, do not intend to see 208 die.  I say this,
not because I need something to do, but rather because I believe that
it is the most successful of all the environmental programs.  No other
program has had as much support, interest and input from local elected
officials as 208 has.  No other environmental program is defended
by local elected officials as 208 is.  If the water quality management
program works at all, it will be due to the support given by the local
elected officials.

     I believe that it was in 1972 that the Congress and EPA should
have learned this.  It was during this year that the EPA established
transportation control measures in many cities so that air quality
might be improved.  Unfortunately, there was no prior consultation or
discussion with the governments of the cities affected.   I happened
to be with mayors of two of these cities when they got the news.
There is no way that I can describe to you their anger.   Needless
to say, the program failed.

     Any environmental program that does not involve the local elected
officials is not going to be successful, especially wastewater manage-
ment.

     I speak to wastewater management because of the way that we must
finance the costs of cleaning up the water.  Sure, the federal
government will pay 75% of construction costs and has paid up to 100%
of planning costs.  Some states will also help with construction
costs.  But when we get down to the operating and maintenance costs,
they fall completely upon the local  citizens as charges  on their water
and sewage bills.  And who has to face the people with rate increases
and construction bond issues?  The local  elected officials -- not
those in the federal  or state apparatus but those who have to face
the local electorate regularly, or get out of the business of govern-
ment.  How many of you have received calls at two in the morning from
someone protesting a water bill?  Well, I have and it's  not a pleasant
experience.
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     If we are to be successful  in reaching our goals, we must
improve our process.  We must have a partnership of Federal, State,
and local governments.  We cannot let one run roughshod over another.
We must particularly recognize and enhance the role of the locals.
Many of the failures in 208 must be credited to the states for the ways
in which they have hampered the 208 agencies.  An example of this is
the remark that I heard from a state person to a 208 agency staff
member — "You are going to fail and then we'll get the program totally
back."  One of the major problems, and one of the glories, of 208 is
that it has brought about a new set of institutional arrangements.
It has forced a new actor onto the stage — the local  elected official,
working through his or her regional agency.

     And this new kid on the block has not always been welcome.
Tremendous turf battles have taken place and, in fact, are continuing.
For example, in Michigan, it was not until we appealed politically
and directly to the governor that we got our 208 agencies designated.
The local elected officials' problem is best exemplified by a remark
 made to me by someone now with HUD.  This person was unhappy with an
act of a board and told me that "That's what happens when you let
elected officials make decisions."

     Well, we do make decisions.  We make them every day.  Consciously
or subconsciously, we are constantly re-evaluating our communities'
priorities.  And the truth of the matter is that this is the way our
system works.  But if we are to make good decisions, we must not be
only well-informed on the options available, but we must be assured
that our action will be backed up.  We cannot always depend on the
states for backing.  We must depend on this backing from EPA.  I don't
want to leave the impression that EPA doesn't give backing.  It does.
SEMCOG's designated management agency program may very well have
failed if it had not received a letter from Region V explaining the
sanctions for non-compliance with the 208 program and the circumstances
under which they would be invoked.

     Now let me try to answer some very basic questions.  First, is
clean water worthwhile?

     One of my favorite quotations is "We do not inherit the earth
from our fathers, we borrow it from our children."

     Water is one of our most precious resources and it is renewable.
We do not, and should not have to apologize to anyone, at any level,
about our efforts to do the job that we are all involved in.  Surely,
we've made mistakes these past few years.

     t  Congress made mistakes when it set 1983 as the date to have
        all of the waters fishable and swimable and gave us 2 years
        to do the planning.

     §  EPA made mistakes in delaying and switching guidance and
        presenting inconsistent support geographically and functionally,

     •  Some states made mistakes  in resisting, sometimes tenaciously,
        giving up some of their turf to areawides.
                                        22

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     t  And yes, even areawides made mistakes in not being sensitive
        to the inherent conflicts with well established state agencies
        and the need for integrating political, financial and manage-
        ment analysis with technical analysis -- and, I might add,
        asking for consistency from EPA, while pleading for flexibility
        because we're all different.

     But could we have really expected much different?  This was a
fantastically complicated challenge that Congress set before us
requiring new political and institutional arrangements, sophisticated
technical anaylsis, and the finding of adequate staffing simultaneously
throughout the country -- I think it's a wonder we did as well as we
did, and I'm willing to say that to my congressman, my senator, OMB,
and the president himself.  So let's stop faulting each other and get
back to the basic premise that protecting the waters of this country
is a worthy endeavor.  Let's get on with it!

     Secondly, have we completed the task?  Obviously no; or have we
even completed the beginning? — well, maybe.

     The waters are not clean but they are improving.  Many initial
plans are certified, but not completed.

     We feel we did a good job in southeast Michigan — but we have
15 river basins, 4,600 square miles with almost 5 million people, 59
treatment plants, 1,400 square miles of active agriculture, and 234
units of government to deal with..  We've come a long way, but we have
a long way to go, and 2 to 3 years is not going to give us enough
time to complete the planning work that needs to be done, particularly
the political and institutional arrangements.  One day we sit down with
the mayor of Detroit, then the next with the the supervisor of a
rural farming township and try to convince them to take a regional
perspective.  That ain't easy, friends!

     I submit that we can make a case for continuing planning, and that
we should take it to our representatives and senators individually
and to our various organizations.  We all know the funding bind that
every level of government is in, but I insist we shouldn't give up
because of that.  We have something worthwhile to sell, and if we
don't sell it, who will?  We need more planning time and money.  Let's
make our best case and give it our best try.

     Third, is areawide planning logical?  I'm absolutely convinced
that the social-economic-political complexes that characterize our urban
and rural areas represent the logical level for planning.  That does
not mean that, in some cases, the state might not do that planning as
has been done so far.  Unfortunately there appears to be evidence that
some areawides have not done the job for a variety of reasons.  But
where areawides have responded to the task, I think there is a greater
chance for success simply because the ultimate decision-makers, local
government, are closer to the planning action.  They are more a
part of it and will  tend to support the recommendations.
                                        23

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     Now to my title:  SUNSET OR SUNRISE:

     One of the speakers yesterday said he thought maybe sunset wasn't
bad because it would give us a chance to restructure the program and
get a new start.  I disagree.  I think the sunset mentality is dangerous
to the health of water quality management, because there is no end,
no sunset to the need to attain and maintain water quality.  Yet we
have heard that the law contains a sunset provision.  We, and others,
have researched the law and find no such provision.

     You see we went from "it was always Congress1 intent that we
phase out 208 planning" to "we need to promise a sunset to save the
program" to "there's a provision in the law itself".  It reminds
me of the words of Dr. James Boren, a humorous analyst of the
bureaucratic process -- "if a mistake is made often enough, it becomes
policy".

     I don't mean to second guess EPA on their approach to Congress.
I'm willing to concede they may have saved the program by promising
sunset.  But I am saying that sunset is not logical if we are going
to do the job Congress mandated us to do.  Let's start talking about
how we restructure 208 rather than sunset.  That's a defeatist philosophy
and I'm not ready to be defeated.

     Another reason I do not want to risk a "temporary sunset" is that
we will lose the momentum we have, jeopardize the institutional
links we hammered out, and above all, lose alot of the credibility
we established.  And that has far reaching consequences for every
one of us.

     How do we achieve sunrise?

     Yesterday, someone said we should look to the transportation
program in which Congress built a comprehensive, cooperative and
continuing planning program tied directly to implementation.  And it
works.  It should be closely examined for possible adaptation to the
208 process.

     I agree with previous speakers that there should be some local
sharing of costs, but I firmly believe that there must be a continuing
federal presence in the program to provide substantial financial
assistance — as well as to provide a uniformity of standards among
the states.

     We need some carrot, some stick, and above all a belief that
what we're doing is good for this country.  If we don't believe it —
who will?

     Merna Hurd and Peter Wise Wednesday asked for support.  I'm ready
to pledge mine.  But in return, I ask EPA for leadership.  We need a
policy conference that includes elected officials, citizen activists,
and technicians -- and not 1 or 2 years from now -- we should start work
very soon to develop a restructured program to insure that we don't all
fade away into a golden sunset somewhere in the west.

     Thank you
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                                                     I
POLICY FORUMS
     25

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                                      POLICY FORUMS
SESSION 1:  Implementation and Evaluation

            Significant Implementation Policy
            and Continuing Funding/Tracking
            and Evaluating
David Ziegler, Moderator

Michael O'Toole                28
Charles Spooner                29
Gerald Kinghorn                30
SESSION 2:  The Next Five Years

            Introduction

            The Next Five Years
Peter Wise, Moderator

Peter Wise

David Terry
John Doyle
Larry Walker
31

31
32
33
SESSION 3:  State/EPA Agreements

            Opening Remarks

            State/EPA Agreements
Loretta Marzetti, Moderator

Loretta Marzetti

Rebecca Hanmer
Eugene Seebald
Peter Machno
Ray Dunn
35

37
37
38
39
SESSION 4:  Small and Alternative Waste
            Treatment Systems

            Opening Remarks

            Small and Alternative Waste
            Treatment Systems Strategy
Paul Kraman, Moderator
Paul Kraman

Peter Ciotoli
Keith Dearth
Don Niehus
40

40
40
40
                                           26

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SESSION 5:  Regulatory Vs. Non-Regulatory Programs

            Conservation District Participation
            in Meeting Clean Water Goals

            Maine's Regulatory Program for
            Agriculture

            Legislative Perspective on Regulatory
            Programs
 Carl Myers,  Moderator

 Robert Williams


 Al  Prysunka


 Larry Morandi
41
42
42
SESSION 6:  Self-Sustaining Planning

            Opening Remarks

            Paying for Self-Sustaining Planning
Robert Hardaker, Moderator

Robert Hardaker

Pat Brunet
Terry Trembly
44

44
46
SESSION 7:  Point/Nonpoint Source Priority

            Point/Nonpoint Source Priority
David Ziegler, Moderator

Thomas Elmore                  47
John Nessell                   48
Donald Theiler                 48
SESSION 8:  Developing Effective Work Programs

            Introductory Remarks

            Overview of Work Program Guidance

            Regional Perspective on Work
            Programs

            How Can You Tell the Good Guys
            from the Bad Guys Without A
            (Work) Program?
Rita Horgan, Moderator

Rita Horgan

Robert Teska

Anthony Conetta


John Promise
50

50

52


52
                                           27

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SESSION 1 -- DAVID ZIEGLER,  MODERATOR
                              Significant Implementation Policy and
                           Continuing Funding/Tracking and Evaluating
        Michael O'Toole
             In New York State,  significant implementation means that local,  county,
        State or Federal agencies have taken steps  outlined in 208 plans to
        minimize or correct current water quality problems or to prevent small
        problems from becoming large ones.   The State prepared 208 certification
        documents which tabulated the following information:

             •    the plan recommendations

             •    the portion of the study  area in  which  the  recommendation applied

             •    the location in the 208 plan  where  the  recommendation  was described

             e    State action on the plan  recommendation

             »    proposed designation of management  agencies

             •    scheduled implementation  dates, and

             •    State action on the management  agency recommendations.

        DEC regional and central  office staff use these certification documents  to
        track implementation.   In 1979,  DEC outlined  the  following implementation
        process in designated 208 areas:

             •    DEC and areawide staff identify and prioritize plan recommendations
                  to be pushed over the next 5  years.

             «    DEC and areawide staff review the management  agency actions  to
                  date on priority problems.

             »    DEC and areawide staff meet with  the designated management agencies
                  and obtain written implementation commitments,  identify and  resolve
                  obstacles toward implementation and work  with the management agency
                  to obtain implementation.

             In FY 1980,  DEC submitted its  first  annual implementation report  to
        EPA Region II.
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     There have been a number of implementation successes in the State.
However, there are many 208 recommendations that will take several years
to implement.  208 does not address simple problems, and many recommenda-
tions involve changes in bureaucracies and law which take time.

     EPA must demonstrate to Congress the success of 208 and the need for
increased 208 funding in order to rescue the only program which can perform
the planning needed to reduce the cost of gaining and maintaining water
quality.
Charles S. Spooner

     In Water Quality Management Planning, EPA Headquarters plays the role
of funding advocate before OMB and the Congress as well as program overseer,
setting general direction to focus institution building and technical
studies to meet the requirements of legislation.  To perform this function
EPA must have current information on where grant funding is being spent, as
well as information on the environmental improvement it promotes.

     Existing tracking systems have concentrated on the progress of grant
awards, and on the outputs from grant activities.  These two ways of looking
at grant tracking can be characterized as either procedural or product track-
ing.  Too little time has been spent interpreting this information to expose
successes in institution building and environmental improvement.  To do this,
the existing tracking systems must become more widely used and respected as
a source of information about the programs useful to those with program
responsibility at various levels.  Such systems will facilitate EPA budget
preparation and the refinement of guidance.

     The Office of Water and Waste Management which oversees the EPA Water
Quality, Drinking Water and Solid and Hazardous Waste programs is now in
the process of devising such a system.  It will be based on categories of
work planned in grant applications, and will support the program functions
at all levels and provide information needed to support the interpretation
and evaluation of progress in environmental quality.
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Gerald Kinghorn

     Areawide agencies can track implementation on a continuous one-to-
one basis.  The Salt Lake County areawide agency, since it is a part of
county government, "owns" its problems and is immersed in the political,
economic, and environmental conditions of the area.  Local government is
very volatile and the development of personal relationships is key to
areawide effectiveness and progress.  If people change, relationships must
be reformed, which takes time.  If tracking is solely tied to forward
movement and does hot encompass the "two steps forward and one step back"
progress of the real world, it will be a big mistake.

     The environmental measure of progress is the finest measure.   If there
is no environmental improvement, the locals will not support the program.
We must be committed to research and to building a data base.   You can
continue to refine the processes through research.  One mandate is huge,
virtually to change the world as we know it.  It will be a long process,
probably without an end.  We should not get discouraged.
DISCUSSION

     Out of the discussion came several recommendations for a tracking
system:

     •    trust must be built into the system,

     •    it needs to be flexible and individualized,

     •    tracking should use existing information,  e.g.,  quarterly reports,
          305(b), and 5-year Needs Assessment.

     Moreover, EPA should recognize the importance of  local support.   To
maintain that support, it needs to have consistent policy.
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SESSION 2 -- PETER WISE, MODERATOR
                                          Introduction

                                           Peter Wise
             The purpose of this policy forum is to discuss changes that EPA, the
        States, areawide agencies, and other program participants will experience
        in the WQM program in the next five years.  Discussion and dialogue are
        the main points of this session.

             EPA is gradually changing its management of the water quality program,
        moving toward an integrated, streamlined problem-solving process.  The
        State/EPA Agreement is an example of these changes.  Two major changes
        occurred in the WQM program in FY 79.  First, the agency directed 208
        grants in FY 80 and beyond almost totally to NPS controls.  Second, the
        administration raised the concept of 208 sunset, necessitating development
        of a restructured WQM program.

             There are two handouts to assist those interested in this policy forum:
        "1990 Construction Grants Strategy Outline" and "Draft Work Program for
        Developing a "Restructured" Planning Program".
                                       The Next Five Years
        David Terry

             The imminent prospect of the sunset of 208 grants causes some short-
        term problems at the State level.  Specifically:

             •    things are hectic; the State must now do a lot of work at once;

             •    turf fights have already resulted from the pressures of restructur-
                  ing the program;

             •    uncertainty within the program makes it hard to recruit and train
                  staff;

             e    competition for limited funds has resulted in increased paperwork
                  and conflict;
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     •    there is a new emphasis on immediate, implementation-oriented
          success stories, and

     ®    outsiders have started to view 208 grants as "lame ducks".

     In spite of these problems, the restructuring of the WQM program
presents some opportunities.  The prospect of a joint 106/208 work program
would allow States to use all their management tools (Five-Year Strategies,
Needs Assessments) in a coordinated way and to achieve better staff coordin-
ation.  Also, the States and EPA may achieve better communication and
coordination.

     In conclusion, water quality problems exist and won't go away with
208 sunset.  It is in the Federal, State, and local interest to address
program problems now.  The problem-solving process remains essentially the
same, with or without 208 grants.
John Doyle

     This is a personal view, an individual observation of one who works on
Capitol Hill on matters related to the WQM program.   Generally, many of the
controversies and problems with the WQM program in the last five years have
been turned around by the present national managers.   In looking at the next
five years, it is useful to look separately at 1980-82 and at 1982 and
beyond.

     1980-1982   Sections 106,  208, 314, 104,  112, and 517 of the Act come
up for reauthorization in FY 80.  The House and Senate have passed separate
bills reauthorizing these programs for two years.   The appropriations should
be close to the President's FY  81 budget request.   Sections 205(c), 205(e),
and 205(i) come up for reauthorization in FY 81.  There is likely to be some
controversy regarding changes in these provisions, but I do not anticipate
statutory changes until later.

     1982 and beyond   The section 207 construction grants authorization
expires in FY 82.  There is much political and economic uncertainty associat-
ed with this expiration.  A possible change in approach would be a shift
away from the approach in the 1972 Act,  which was  a 10-year program complete
with deadlines and stringent requirements.  One alternative would be a
20 to 30-year $170 billion program with an emphasis  on hazardous wastes and
ground water protection.

     Key points to remember, in my opinion, are that  the ultimate sunset of
208 grants is unlikely from a Hill perspective and that a major rewrite of
the Clean Water Act is likely in FY 82.
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Larry Walker

     Restructuring the WQM program should involve two key changes:  re-
focusing the program on achievement of the water quality goals of the
Act, and increasing the responsibility of State and local governments.

     With respect to refocusing the program on water quality goals, the
process EPA has set up to meet the water quality goals is ineffective.
EPA must define what clean water is, not dictate how to achieve clean
water.

     In the area of the responsibilities of State and local government, EPA
should reduce the present 75 percent Federal share for 208 grants to
50 percent.  This change would increase local responsibility and decrease
Federal problems with control of grant funds.

     There is a strong need to integrate the WQM program better.  Construction
grants, nonpoint source controls, toxic controls, and permits should be
better integrated.  EPA should remove some of the restrictions from con-
struction grant funds, for example, expand their use beyond municipal treat-
ment works construction.  The emphasis should be on the improvement of water
quality, not the construction of physical structures.


Discussion

     The discussion involved three topics:  the impacts of possible 208
sunset; the roles of those involved in the WQM program; and similarities
and differences between WQM and other Federal, State, and local programs.

     With respect to 208 sunset, one commenter asked whether we should
accept sunset and restructure the WQM program or fight the sunset idea.  The
panel replied that the 208 grants had almost been killed in FY 79, and that
EPA had only been able to forestall that by promising not to award the grants
after FY 83.  But, the panel said, planning is a continual process whether
it is called "208" or something else.

     Another commenter said that EPA has a problem with asking Congress to
reauthorize various functions without documented proof of clean water
benefits.  However, he said, results in the areas of stormwater and ground
water are not immediate.  The panelists acknowledged this problem, agreeing
it was necessary to document results to obtain funds.

     A third commenter said that base-level funding to keep local agencies
involved in planning is crucial.  He said that, when revising the Act,
Congress should consolidate all the planning provisions of the Act into a
                                    33

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single system,  with the objective of cleaner water.   The panel made no
response to this comment.

     With respect to roles,  one commenter said that  the 100 percent Federal
share for 208 grants in the  mid-70's did little to encourage all levels of
government to share in solving problems.  Another said that States, area-
wide agencies,  and local citizens should organize and discuss what it really
needed at the local level.   A third said that States now have a better idea
of their priorities and are  capable of doing a better job than before the
208 program started.  The panelists agreed that the  100 percent Federal
share in the early years did cause problems, but were unsure what the best
Federal share was.  A commenter from North Carolina  said that a 50 percent
Federal share would be "devastating" to  the planning program in that State.

     A final comment on roles was that the need for  cross-cutting authority
leads toward a block grant concept, in which EPA doesn't dictate what to
spend the money on, as much  as what results to obtain.   The panel basically
agreed with this position.

     In the area of the WQM  program and  other Federal programs, it was
suggested that EPA consider  transportation planning  as a model for planning
in the restructured program.  It was also suggested  that EPA emphasize more
coordination with USDA and State programs for funding wastewater facility
construction.

     Several commenters said that the national policies of other agencies
are sometimes in direct conflict with EPA's policies.  HUD, for example, in
stimulating new construction, is on a "totally different wavelength."  The
commenters felt that EPA does not coordinate well with other public agencies.
They said leadership was needed at the Federal and State levels, along with
an exploration of new ideas  and multi-disciplinary approaches.

     One commenter asked how the restructured WQM program might consider
relationships among water quality planning, land use planning, air quality
planning, and other related  efforts.  The panel replied that one of the
fundamental shortcomings of  the program today is the lack of comprehensive,
integrated planning.  On Capitol Hill, the words "land use planning" can
cause a bill to sit on the shelf, however.  Although the WQM program must
look at the big picture, the panelists said, this may not be the same as a
totally integrated approach  that combined water regulation, hazardous waste
regulation, and other efforts in one basket.  Balance is necessary.
                                    34

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SESSION 3 -- LORETTA MARZETTI, MODERATOR
                                         Opening Remarks

                                        Loretta Marzetti


             FY 81 marks the third year in the evolution of State/EPA Agreements.

             •    In FY 79, SEAs were encouraged, but not required, and included
                  Clean Water Act programs only.  Thirty-two Agreements were
                  signed.

             •    In FY 80, SEAs were required for programs under the Resource
                  Conservation and Recovery Act and the Safe Drinking Water Act,
                  as well as the Clean Water Act.  All 57 State and Territorial
                  Agreements were signed.

             «    In FY 81, the SEA process is being expanded to cover all EPA
                  programs.

             SEAs are designed to be key management tools which top managers in EPA
        and States can use to focus attention on priority activities and problems.
        The goal of the SEA process is to maximize the use of available resources
        to solve priority environmental problems.

             In FY 80, some of the major WQM priorities are related to delegations,
        construction grant needs, operation and maintenance, 208 plan updates,
        residuals/sludge management, nonpoint sources and water quality standards.
        For the most part, these priorities are more along programmatic lines, than
        of a problem-solving nature.

             Admittedly, there have been problems with the start-up of the State/EPA
        Agreement process.  In the summer of 1979, we conducted a regional
        assessment of the SEA process to determine progress and problems in develop-
        ing the FY 79 and FY 80 Agreements.

             As far as achievements, we found that:

             •    A few cross-cutting, problem-oriented issues are being addressed
                  (such as development of a multi-faceted approach to attacking
                  a radiation problem in the State of Florida, cleaning up St. Alban's
                  Bay in Vermont, Webster Lake in New Hampshire, addressing a toxics
                  problem at Charles City, Iowa and development of a multi-media
                  Approach to attacking urban problems in Boise, Idaho).
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     o    The Agreements are being  used  as  management tools by top
          level managers.

     o    The SEAs have improved coordination and communication within
          the States.

     o    Coordination and communication between the Regions and States
          is improving.

     Areas needing improvement include:

     o    More emphasis on environmental problem-solving  activities both
          within and across program lines.

     ®    Better integration of SEA development  into EPA  and State planning
          and budgeting processes.

     o    Improved tracking and evaluation  procedures.

     ®    Further EPA commitments in addition to providing  grant awards.

     ®    Better reflection of SEA  priorities in the grant  application and
          work plan.

     •    Improved public involvement in SEA development.

     The FY 81 SEA Guidance was built upon  the experience of States and
Regions, and the input we obtained  from  our regional assessment.  The
Guidance specifies roles and responsibilities, presents a suggested schedule
for developing SEAs and includes discussions on  format, content and tracking
of SEAs.

     The purpose of this panel is to stimulate further discussion on the
need for and value of State/EPA Agreements,  how  to factor in WQM priorities
and how to improve the process to make it work better in  the future.
                                    36

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                             State/EPA Agreements
Rebecca Hanmer

     State/EPA Agreements as Management Tools.  Region IV breaks SEAs down
into two parts:  a management section highlighting top-level management
issues and a compilation of work programs.  The management section satisfies
a selective, active management concept, which is especially good for
management to understand complex multi-program issues.  The second portion
of the SEA provides information on how the States are spending money in the
priority areas and on more routine grant related activities.

     SEAs have proven of great value to staff and importance for public use.
They allow States to talk one-on-one with EPA and "get everything out on
the table."  They also provide a mechanism to define programs accurately.
Once completed, they make development of work programs much easier.

     State/EPA Agreements as Problem-Solving Tools.  The SEAs are useful
because they help avoid the tendency of States and EPA to lose track of
environmental problems.  They direct efforts to a few key issues effectively.

     WQM and the SEAs.  Many tough issues still facing the WQM program can
be solved with SEAs, for example, controversies of population projections
and 201/208 relationships.  The 305(b) report should be the basis for select-
ing environmental problems for solution.  The SEA is largely responsible for
integrative approaches like the one in St. Albans Bay.  Because of SEAs,
program linkages are occurring between CWA, RCRA, and SDWA programs.
Gene Seebald

     The New York SEA incorporates all State water programs.  It consists of
an executive summary (the formal agreement) signed by the Commission of the
DEC and the EPA Regional Administrator; five-year strategies for each dis-
crete element of the State's water program; and an annual work program.

     In FY 81, New York is embarking on its third SEA update.  The State and
EPA focus the SEA on program-oriented strategies rather than problem- or
project-oriented issues.
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     Advantages of the SEA.  The SEA has resulted in better coordination
 and  communication between New York State and EPA.  It has also resulted
 in some reduction of paperwork, but more emphasis is required on this
 aspect.

     The SEA is a management tool used by top level managers in the DEC.
 It is  totally integrated into the Department's budget and planning process.
 It reflects Statewide environmental priorities, and includes an output-
 oriented tracking and evaluation system.  The SEA helps the State give the
 public a full description of the State's water quality priorities and
 programs.

     Disadvantages of the SEA.  The SEA development process is evolving
 into a year-round effort.  EPA must make meaningful input,  particularly
 through mid-year reviews, to ensure that the SEA is a useful management
 tool for all levels of management.

     Effort is needed to reduce SEA paperwork and streamline the process.
 The SEA was not intended to contain a complete level of program description
 for all program elements.  The SEA should incorporate other program planning
 documents by reference.

     New York State makes a total commitment for WQM program planning and
 priorities in the SEA.  EPA--both at the Region and Headquarters—must
 make a comparable commitment.   EPA managers at all levels must be totally
 conversant with SEA strategies and objectives.
Peter Machno

     SEAs can either be very useful,  or a waste of time.   Their value
depends on belief in the spirit of the SEA process.   SEA  negotiations must
be truly two-way, with commitments made by both parties.

     The areawide agency perspective  is necessary to the  SEA process.  Area-
wide agencies represent local environmental needs best.   The areawide
agencies should be made accountable for certain SEA priorities  and commit-
ments, and should co-sign the SEAs with the State and EPA.
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Ray Dunn

     State/EPA Agreements represent a device to force top level management
attention on high priority problems and issues.  The types of priorities
SEAs address are in transition from programmatic to problemmatic issues.

     The advantages of SEAs are that they represent a cooperative process
and a comprehensive approach to environmental problem solving.  They
provide for flexibility, assign resources, provide a means to track
progress on issues, and give the States a forum to express their needs.

     In the area of tracking and evaluation, EPA and the States should give
more emphasis to effective management tracking.  To date, many SEAs have
had weak goal statements and task definitions.  This has made it difficult
to track commitments.  Several Regions are tracking SEA commitments quarterl;
via written reports and meetings, others through mid-year reviews.


Discussion

     A questioner asked, "What level of public participation is required in
the SEA process?"  The panel answered that the SEA guidance strongly encour-
ages public participation as part of developing SEAs.   In addition, the
regulations of the various grant programs covered by the SEA process require
public participation.  Yet, public participation is a difficult subject which
is still causing problems.  The FY 81 SEA Handbook includes suggestions and
examples of successful approaches.  In some States, advisory committees have
been re-structured to serve as focal point for public input.  In Maine, TV
spots helped promote public involvement.

     A commenter said that even with the use of citizen advisory committees,
there is still not enough public involvement.  The panelists agreed, saying
that SEA priorities are often not "sexy" issues and,  therefore,  attendance
at public meetings is often less than desired.

     Another questioner asked if funding restrictions  on some EPA grants
didn't hamper the integrated problem solving approach of SEAs.   The panelists
conceded that while funding limitations, such as those seen in section 208
of the Clean Water Act, do complicate things, there is still sufficient
flexibility to negotiate Agreements.

     A final comment was that late guidance from EPA has resulted in delayed
development of SEAs.  The panel recognized this as a problem early in the
initiation of the SEA process,  but cited improvements  in EPA guidance to
correct this problem.   The FY 81 Operating Year Guidance came out in February,
1980.   Also, EPA published the FY 81 SEA Handbook in Mid-March to assist with
SEA development.
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SESSION 4 -- PAUL KRAMAN,  MODERATOR


                                        Opening Remarks


             Paul Kraman opened the session by outlining the relationship of small
        and alternative systems to nonpoint source problems.  He noted that septic
        effluent was identified as a major source of stream pollution in suburban
        King County, Washington.   The importance of proper management of septic
        systems was also highlighted as essential to protection of ground water.
        He pointed out that some areas are simply not suited for the environment-
        ally sound use of septic systems as a permanent  waste treatment system.
                    Small and Alternative Waste Treatment  Systems  Strategy


             Peter Ciotoli reviewed his firm's  findings  in determining  the problems
        and issues of small systems' management.   He presented an  overview of the
        management responsibilities which must  be taken  on in developing  a success-
        ful small system management program.  He concluded with a  description of
        some model approaches which are in use  and the findings of case studies.


             Keith Dearth followed this with  a  review of the 201 construction grant
        program's requirements as they relate to small systems.  He spent some time
        in detailing the R/A set aside program, as well  as the educational programs
        underway to develop national expertise  in the use  of small systems.


             Don Niehus concluded the session with a summary of the elements of the
        Water Planning Division's small system  strategy.  The strategy  was available
        to the session's participants.  It presents a background to the use of small
        systems around the country.  He noted that the focus of the strategy is to
        educate planners, engineers and officials, to use  prototypes to test
        management and financial techniques,  and to assist in the  development of
        State level small systems programs.
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SESSION 5 -- CARL MYERS, MODERATOR
               Conservation District Participation in Meeting Clean Water Goals

                                        Robert Williams
        Major Points
                  Land use regulatory provisions still exist in about one half of
                  State Conservation Districts' laws.  They seldom have been
                  exercised.  Sediment and erosion control plans are required for
                  construction activities in most new legislation.  Enforcement
                  procedures vary greatly.

                  The 1973 Model Act, with 42 Governors' Conference Seminars around
                  the country, helped encourage new State legislation for construc-
                  tion erosion.

                  Conservation Standards include soil loss limits, conservation
                  plans, and may require that no soil leave the site.

                  Permit System works for construction because of existing
                  permitting systems.

                  For agriculture, States have cost-sharing programs, but only two
                  have regulatory backup.

                  Conservation Districts believe that both regulatory and voluntary
                  programs must include research, education, technical assistance,
                  and financial assistance for agriculture components.

                  A State or local control program should begin with adequate funding
                  and committment to the basics in the above, and only when addition-
                  al experience is gained should a regulatory tool be considered.

                  Conservation Districts firmly believe that regulatory authority
                  should be used only at the State or local level, if it proves
                  to be necessary at all.
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                   Maine's Regulatory Program for Agriculture

                                  Al Prysunka
Major Points
     •    Animal waste,  lake eutrophication problems,  poultry problems
          related to ground water nitrates, and extremely excessive erosion
          for such crops as potatoes,  all brought about Maine's new programs.

     •    Some organizational problems with various agricultural aid
          agencies required clarification and consistency at the State level.

     •    The first option the State program considered was to follow
          Pennsylvania's system and require each farm  to have a soil
          conservation plan.  This did not get selected.

     »    The option selected exempted farmers from prosecution under
          the existing general pollution legislation if he or she had a
          conservation plan approved by the State Environmental Quality
          Board, and Conservation District.  No enforcement has taken place
          yet.  Process  can be activated by a complaint from anyone.  Cost-
          sharing must be available to help correct problem.

     a    Maine's regulatory program should be effective if enforced;
          visible control activities may be necessary  to ensure that
          compliance is  the common perception, which can be encouraged by
          word-of-mouth.
                Legislative Perspective on Regulatory Programs

                                 Larry Morandi


          Most legislatures prefer non-regulatory programs.   Consensus must be
          developed to pass legislation.  There is accountability to
          constituent interests that are directly affected by regulatory
          programs.  Effects eventually get back to legislatures (source of
          accountability).
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Comments
          Legislatures are very conscious of budget needs and regulatory
          programs that cost money.

          State recommendations have pushed non-regulatory methods because
          of limited knowledge base and local support.

          Only a very few jurisdictions have recognized urban runoff
          regulatory needs.

          Various State regulatory programs require cost-sharing to be
          available for enforcement provision.  Other financial alternatives
          such as tax credits for BMPs have been proposed.

          Resistance to water quality regulatory programs is clearly
          evident in the western U.S., since their concerns are primarily
          directed towards water supply.  Water quality is seen as restrict-
          ing access and supply.
          Training is needed for conservation plan development,  as well as
          financial incentives (particularly for water quality aspects).

          Enforcement procedures may be low priority for State attorney
          generals to carry through courts.

          User charges are being devised in relation to urban runoff or
          stormwater management with respect to impervious areas on
          development sites (e.g., King County, Seattle, Washington).

          Public support of sediment control is diluted by the belief that
          any land disturbance will result in uncontrollable erosion and
          sedimentation.

          Threat of regulation is effective in control programs.  An example,
          the forest industry in Georgia perceived imminent regulation if
          it did not recommend a non-regulatory program.

          Cost-sharing and other incentives are preferable over sanctions.
                                    43

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SESSION 6 -- ROBERT HARDAKER,  MODERATOR
                                        Opening Remarks

                                        Robert Hardaker


             For State and local governments to continue to plan for improved
        water quality, they must begin to look to their own sources of funding.
        Whereas EPA planning funds are being reduced, new problems such as
        hazardous waste disposal are emerging which increase the costs of planning.
        A Financial Management Assistance Survey indicates the following sources
        of funds:  local appropriations, department budgets, taxing programs,
        special sewer user charges, recreation fees, interest group sponsorship
        of special studies, interagency funds, State funds, and Federal grants.

             Salt Lake County, Utah provides an example of a local government
        institutionalizing a flow of funds for water quality planning.  The WQM
        program had enough local support to enable the County Commission to pa,ss
        a tax to fund a budget approved by the Water Quality Council.  The levy
        approach was selected after several other funding mechanisms were
        researched.
                            Paying for Self-Sustaining Planning
        Pat Brunet
             In developing its WQM plan, SEMCOG interpreted the Clean Water Act and
        EPA regulations as requiring development of a self-funding mechanism as a
        prerequisite to plan approval.  Consequently SEMCOG examined a number of
        alternative methods of allocating costs among local governments.  The
        methods considered were based on volume of sewage flow, population, assess-
        ed valuation, number of septic systems, non-sewered areas, and various
        coordinations of these factors.  Financing alternatives were analyzed
        according to six criteria:  equitability, political acceptability, economic
        feasibility, collectability, legality, and public acceptability.

             The alternative selected was based on a combination of sewage flow
        (80%) and land area  (20%).  Sewage flow, which can be roughly linked to
                                              44

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point source pollution, was not considered by itself to be an equitable
basis for funding.  Since land, urban and rural, also contributes to
pollution, SEMCOG decided to include it in the formula.  Municipalities
and districts managing sewage treatment plants have each entered a
contract with SEMCOG whereby they collect 1/3 cent per 1,000 cubic feet of
wastewater that is treated.  An upper limit of 1 cent per 1,000 cubic feet
was placed as a cap to alleviate concerns over an unconstrained budget.
If charges were set at the upper limit, $450,000 per year could be collect-
ed.  The 20 percent portion of local funding based on land area (and hence
a rough link to nonpoint source pollution) is raised by the counties
picking up their share of the total area allocation based on the percent
of the county's area to SEMCOG's area.

     SEMCOG took a hard line in ensuring that this local funding mechanism
would be instituted.  It told communities that 201 funding is contingent
on these agreements with designated management agencies operating sewage
treatment plants.  This position was backed up by a strongly worded letter
from the EPA Region V Deputy Administrator to Senator Riegle of Michigan.
Consequently, agencies operating sewage treatment plants now must contribute
a share of the cost of water quality planning.  The designated management
agencies contribute the 25 percent local match for 208 grants.  If necessary
SEMCOG will be able to raise 100 percent of its planning costs from
designated management agencies, largely by increasing the sewage treatment
fee to 1 cent per 1,000 cubic feet.

     The speaker closed his remarks by wondering why this sort of funding
arrangement was not developed by other 208 agencies, given the emphasis
on self-funded planning in the Clean Water Act and EPA regulations.   He
felt that Section 208 was intended primarily to set up a process for manag-
ing water quality.  He stressed the need for EPA to emphasize the develop-
ment of institutional arrangements leading to initiatives such as taxes
on impervious surfaces in new developments rather than demonstration projects
testing specific BMPs.  He also emphasized the need for an improved Federal-
State-local partnership in developing such institutional arrangements.
                                    45

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Terry Trembly

     The planning area covers two counties and 34 municipalities.  The
area is primarily rural, including national forest land and portions of
Rocky Mountain National Park.  The economy of the area is largely based
on irrigated agriculture (over 500,000 acres) and cattle raising.

     Rather than discuss in detail the mechanism for raising funds for
continuing planning at the local level, the speaker emphasized that it is
essential for 208 planning to be effective in order to gain local support.
To be effective, certain basic principles for 208 planning must be kept
in mind:

     »    Environmental management is a process rather than an output.
          Improving or protecting water quality is only one aspect of
          environmental management, and some problems may take years to
          correct.

     •    208 planning should encourage governmental efficiencies and
          communication at all levels.  Whereas water pollution control
          used to be just a Federal and State government function, 208
          is a vehicle for local governments to communicate with State
          and Federal agencies and legislatures on an equal basis as well
          as a vehicle for local governments to communicate with each other.

     0    Outputs of 208 planning must be meaningful.  For example, in the
          past by providing technical assistance to small communities in
          evaluating facility plans, 208 agencies have been able to save
          those communities a considerable amount of money.  Through such
          assistance, the WQM program can prove its worth and earn credibil-
          ity and trust.

     •    The accountability of a 208 planning program must be ensured so
          that it remains valuable to those it serves.

     e    Rather than spread itself too thin, a 208 planning program should
          focus on just a few key issues.

     •    A 208 planning program should prescribe both short- and long-term
          action strategies.

     Turning to funding mechanisms, LWRCOG, unlike SEMCOG, relies on
voluntary support from member governments.  There is an annual dues assess-
ment, part of which is based on water pollution control activity.  During
                                    46

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        the  past  two and a half years,  over $80,000 has been collected.   Member
        governments  are motivated to contribute by the opportunity to have addi-
        tional  water pollution control  expertise at the local level and  by the
        desire  to avoid the threat of federal intervention if water quality
        management responsibilities are not taken seriously at the local level.
        If the  current level of voluntary support continues, it may be possible
        for  LWRCOG to require payment of fees in the future.
SESSION 7 -- DAVID ZIEGLER,  MODERATOR


                               Point/Nonpoint Source Priority


        Thomas Elmore

             The WQM Agencies in the West are mixed in their opinion  of  the  208
        policy which restricts funding to nonpoint sources.  Generally,  rural
        areas support the policy,  and urban areas  do not.  The  NWCCOG enthusiastic-
        ally supports the policy,  because our problems are NPS  problems.  Those
        Colorado COGs which  are experiencing increased growth and  development,
        however, do not favor it.

             Even with 208 directed only at NPS planning,  it has barely  scratched
        the surface of the problem.  The alternatives for  point source funding at
        the areawide level are 1)  no funding, 2) local funding, or 3)  pass through
        of Section 205(g) funds.  An incentive to  local funding would be a
        provision for local  administration of point source implementation programs.

             Under 208 policy, the definition of hydrologic  modifications should
        be broadened to include instream flow modifications  and point source
        implications, e.g.,  irrigation scheduling  and point  source dilution.
                                            47

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John Nessell

     NPS are a significant problem in New England.  However, it is not
useful to compare the importance of point source vs. nonpoint source
pollution.  The problems should be identified source by source, and programs
should be implemented to control them.  208 is viewed as a NPS program in
New England.

     In the industrial States of New England, the greatest perceived NPS
problems are urban runoff and hazardous waste disposal.  In the rural
States, agricultural practices, on-lot disposal systems, and salt storage
are the major NPS problems.

     Generally, there is not a funding limitation for point source
problems.  The point source programs are already established and institu-
tionalized.  However, funding is needed for stream flow maintenance,  the
effects of impoundments, and wasteload allocations.

     Vermont is starting to integrate 208 into the State Water Pollution
Control Program and Agency.  This will probably turn the Federal Program
into a State program.  The Agency,  however,  considers implementation  very
expensive and is seeking funding sources for this phase of its NPS programs.
Donald Theiler

     The speaker was very opposed to the NPS policy.   208 is not a point
source or nonpoint source program but an areawide comprehensive water
quality management program.   It is not the intent of  the law that 208
address only a portion of the pollution problem.   The law intended that
208 plans provide a framework for all CWA programs.

     He sensed a change in this policy.   He was  hopeful  that WPD will
allow State and areawides to determine the significant problems,  identify
funding sources, and if nothing else is  available, use 208 funds.

     Examples of the areas in which point source and  nonpoint source fund-
ing are required follow:

     •    paper mill pollution
                                    48

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     •    acid rain work

     •    sewer extension decisions

     •    PS/NPS evaluations for cost-effective integrated water
          treatment

     Another reason for point source funding from 208 is that it can
result in more dramatic success stories.  The water quality improvements
are more notable and, therefore, more impressive to Congress.


Discussion

     The discussion revolved around statements from representatives of
various State and areawide agencies in support of integrated PS/NPS 208
funding.  Representatives from Oklahoma, New York, Florida, and Texas
all spoke up in favor of integrated planning in 208 programs.

     Also two suggestions were made:

     •    The innovative and alternative 4 percent set aside should have
          more emphasis.  If a State does not use it, it should lose more
          than the 4 percent of its grant.

     o    EPA could use the OMB A-95 review to better coordinate 201 and
          208.
                                     49

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SESSION 8 -- RITA MORGAN,  MODERATOR
                                    Introductory Remarks

                                         Rita Morgan


             The purpose of this session is to discuss the .importance of work
        programs and how they can be more effective.  A final draft of the Water
        Planning Division's work program guidance is expected in the near future.
        This guidance consists of two sections:

             •    an overall discussion of work programs as  a management tool and
                  suggestions on format, and

             0    a section on use of systems tools for work programs.
                              Overview of Work Program Guidance

                                        Robert Teska


             Work programs are a key ingredient of a good water quality management
        framework.  They foster a disciplined approach toward managing, thereby
        coming to grips with'performance in accordance with the constraints of
        time, money, personnel, and other critical resources.

             The purpose of a work program is to guide the operation and performance
        of a mission-oriented agency over a limited period of time.   Such a program
        identifies targets and organizes work in pursuit of these targets.  Per-
        formance is measured by criteria indicating progress toward  targets.  Even
        though work programs are necessary, they can be very frustrating to prepare.
        Few people have had actual program management training.

             Work programs are useful in three ways:

             •    organizing work and allocating resources

             e    expediting internal management

             e    providing grant application support
                                             50

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The agency's management group has the primary responsibility for work
programs, but agency staff should be involved.

     The format and contents of a work program should reflect rules and
regulations published in the May 23, 1979 Federal Register  (40 CFR,
Parts 35, 130, 131).  Additional guidelines  (not requirements) are
suggested as a means to improve the process  and the product.  Overall,
work programs should:

     •    be reasonably uniform

     •    provide a valuable baseline for communication and analysis

     •    avoid jargon  (provide glossary if  necessary)

     •    have tracking capabilities

     •    use tabular summaries whenever possible

     •    use simple diagrams, charts, and maps whenever possible.

     The content of a work program should include:

     e    an overall summary (i.e., show relationship with Continuing
          Planning Process, State/EPA Agreement, and State grants)

     •    a discussion of the areawide agency framework

     •    a summary and evaluation of the current year program

     •    a description of activities by program elements (e.g., by task
          activity)

     •    applications of various management techniques (e.g., matrices,
          PERT, CPM, etc.).

     Work programs can provide several useful results.  They are excellent
for tracking performance.  They are useful for staff training, particularly
new staff.  They provide a simple accounting mechanism.  Lastly, work
programs are useful for supplemental funding requests.
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                    Regional Perspective on Work Programs

                               Anthony Conetta


     Work program development has been frustrating in the past and can
continue to be so.  Many revisions have often been necessary.   Last year
(FY 80) their quality varied greatly.

     Work programs should be viewed as a contract which identifies expected
products.  A major problem with work programs is that they don't always
specify outcomes.  While they should tell EPA what it will get for the
dollars invested, many work programs list only tasks and relationships.
They instead must concentrate on final products and tie them to environ-
mental problems.

     Region II is trying to streamline the work program process.  Grants
will not be awarded unless the applicant has a fully approved work program.
The phases of work program development include:

     »    pre-application stage (early discussion)

     »    work program summary (a very brief description of major objectives,
          activities, and costs), and

     •    development of final detailed work program.
              How Can You Tell the Good Guys from the Bad Guys
                          Without A (Work)  Program

                                John Promise
     As the last speaker at the last Policy Forum on the last day of the
Conference, the aforementioned speaker will take a "not-altogether-serious"
look at Federal, State, and local roles in developing work programs,
loosely based on the exploits of Dallas' most famous video family and its
leading protogonist, J.R.

     •    J.R. Ewing (evokes distrust, a villain) - Represents EPA
          Headquarters.
                                     52

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     o    Jock Ewing (power, the head of the family) - represents OMB.

     0    Sue Ellen (abused, shoved around) - represents the Regional
          Offices.

     9    Cliff Barnes (the underdog, always picked on by the Ewing
          family) - represents the States.

     »    Bobby Ewing (decent, helpful, likable) - represents the area-
          wide agencies.

     9    Allan Bean (hired by J. R. to do his dirty work)  - represents
          all the consultants hired by EPA.

     This "totally accurate and completely unbiased" story does have a
moral.  With all these characters, it is difficult to get anyone to agree
on anything.  It also depicts a top-down management approach.
Comments

     Comment:  EPA should stop changing policy (program direction)  in mid-
stream.  Grantees receive so much guidance it becomes difficult to know
what's required.

     Reply:  This concern is legitimate.  The grantees and the Regions have
in the past been faced with changing requirements and program direction
from Headquarters.  This problem was especially true during FY 1980,  as it
has been a transition year for the program as a whole.  In the future it
is expected that the program will stabilize and policy and guidance will be
issued well in advance of the upcoming year.

     Comment:  SCS uses a system similar to what Region II is doing,  in that
it is heavily oriented toward sitting down and negotiating future projects
early in the work program development process.

     Reply:  We support early discussions and development of work programs.

     Comment:  We grantees get tired of hearing what EPA wants for its money.
The work program process should be more of a two-way negotiation, not
just to satisfy what EPA wants.  The States have needs also!

     Reply:  Agreed--208 planning should be both a "tops-down" and "bottoms-
up" process.  The States do have a significant stake in the process and,
                                     53

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therefore, we hope that the work program negotiation process can be a
true two-way negotiation process -- similar to the way State/EPA
Agreements are developed.

     Comment:  The work program process as it currently stands requires
so much time for preparation and negotiation, that no time remains to
clean-up the environment.

     Reply:  We hope that this is not the case on a widespread basis.
Certainly, there are instances where revisions of work programs are
necessary.  This should be the exception, however, rather than the rule.
As Bob Teska noted in his presentation, an effective work program develop-
ment process should take no more than two to six person weeks.

     Reply:  (audience).  Current work programs and grant applications
procedures are not that burdensome.  From our perspective, as a grantee,
many of the other Federally funded programs are far worse.

     Comment:  EPA should spend more time playing an advocacy role --
tell OMB what we want the program to address.

     Reply:  We are spending more time in the advocacy role.  EPA has been
developing and utilizing contacts on the Hill.  Organizationally we have
staffed the Public Involvement Section Chief position with a person who
has previous experience working with Congressional offices and sub-committees.
EPA is also increasing its involvement with public interest groups.

     Question:  Why is the Water Planning Division spending its time looking
over the shoulder of the Regions to review work programs?  If WPD doesn't
trust the Regions, then maybe HQ should pull back the entire program to
Washington.

     Reply:  In any organization delegation of programs is ideal.  Yet
there are instances when the higher levels of the management structure
must verify that existing policy is being followed, especially in this
transition period, when the program is undergoing significant re-direction.
                                     54

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NATIONWIDE URBAN RUNOFF PROGRAM
I
              55

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                            Nationwide Urban Runoff Program
SESSION 1:  An Overview of NURP

            NURP Overview

            Data Management and Analysis
Dennis Athayde, Moderator

Dennis Athayde               58

Eugene Driscoll              60
SESSION 2:  NURP Objectives

            Priority Pollutants in Urban Runoff

            Planning Decision-Making and
            Implementation
Dennis Athayde, Moderator

Philip E. Shelley            61

Gail B. Boyd                 62
SESSION 3:  NURP Case Studies
            State Perspective on Urban Runoff
            Planning

            Areawide Agency Perspective on NURP:
            Metropolitan Washington, D.C. Area
Philip Shelley, Moderator

Madeline Snow                64
Austin Librach
65
SESSION 4:  Case Study:  City/County Perspective

            NURP Program in Salt Lake City
Philip Shelley, Moderator

Gerald Kinghorn
67
SESSION 5:  Evaluation and Control Measures

            Quality Assurance and Quality Control
            Within NURP

            Evaluation of Management Practices
Dennis Athayde, Moderator

Philip Shelley               68
Eugene D. Driscoll
68
                                           56

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SESSION 6:   Pilot Studies of Large Cities

            U.S.  Geological Survey Urban
            Stormwater Program

            Research and Development in Urban
            Runoff
Dennis Athayde, Moderator

David Lystrom                69
Richard P. Traver
71
SESSION 7:  Session Summary
            Relationship Between Urban Projects
            and Water Quality Control

            Clean Lakes and Summary
Philip Shelley, Moderator

Jan Lundgren                 72
Stein Bendixen

Dennis Athayde               73
                                           57

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SESSION 1 -- DENNIS ATHAYDE, MODERATOR
                                        NURP Overview

                                         Dennis Athayde


        Key Points

        1.  Background on Urban Runoff Program

             e    1974 - EPA sat back and waited for things to happen.

             e    1976 - Quarles felt too much was being asked for under the
                  comprehensive 208 plans.  Asked for 3 or 4 priority areas to be
                  identified by each 208.  Urban runoff identified as a priority
                  area by 93 States and areawides.

             »    1978 - All the Regions were visited and all 208 plans were reviewed.
                  From this review, felt that a nationwide program was needed.  This
                  was the beginning of NURP.

        2.  Financial considerations for the NURP Program

             o    The Needs Surveys showed billions of dollars are needed for the
                  control of urban runoff nationwide.

             e    Section 211 of Clean Water Act says no money is to be used for the
                  treatment of stormwater.  The Legislature will begin to look at
                  Section 211 for revision in March 1981.

             «    $50 million per year was given for 208 in general.  EPA Headquarters
                  has taken some of this money off the top and funded 30 urban runoff
                  projects.

        3.  How far have we come in the NURP program?

             e    28 projects funded.  Projects funded more heavily in cities east of
                  the Mississippi.  These are the cities where population, rainfall,
                  and runoff are the heaviest.  These types of cities are probably
                  where the majority of problems will be-

             e    Top level priority is given to projects where a beneficial use is
                  denied by urban stormwater runoff.  (example:  the Occoquan
                  Reservoir).

             e>    The most common problem identified in past 208 work is a standard
                  violation.  The most common pollutant found in urban runoff is
                  fecal coliforms.
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 4.   Where are we going with the NURP Program?

     The purpose of the NURP Program is to determine if urban runoff is
a problem of national significance.  The program tries to provide informa-
tion to Congress for the next round of amendments to the Clean Water Act.
EPA is trying to provide answers to questions such as:  is urban runoff a
problem of national significance, can it be controlled, how much will it
cost to control it, and should federal funds be used for its control?

Summary

     An initial review of all the 208 work plans took place in 1978.  From
this review urban runoff was identified as a potential problem in 93 areas.
However, most of the 208 work did not go into detail defining what a
problem was or how to control it.  After this cursory review it was
determined that a nationwide program was needed.

     The Nationwide Urban Runoff Program was developed to build up the
national data base on urban runoff and provide Congress with answers to
questions about urban runoff.  Through 28 projects nationwide EPA hopes to
find out if urban runoff is a problem of national significance.  If it is,
what do cities with urban runoff problems look like?  Can urban runoff be
controlled, what are the techniques for control and how much do they cost?
Should the control of urban runoff be paid for with federal dollars,
similar possibly to the RCWP program?

     The program is designed to be completed in mid-1983 with a Report to
Congress as the final output.

QUESTIONS AND ANSWERS

     Q.  How will technology transfer be handled in areas where there aren't
         NURP projects?

     A.  Right now, all the 208 work plans are being reviewed to determine
         non-NURP areas which are  studying urban runoff.  These areas will
         be contacted and their programs followed closely. Technical infor-
         mation that becomes available in the program will be transferred
         to these areas.  All data will be put into STORET  (a computer
         information system) and will be available for use by anyone.

     Q.  What will the NURP program do for current techniques in cost-
         benefit analysis?

     A.  Advancing current techniques in cost-benefit analysis is not one
         of the objectives of the program.  We haven't reached the point of
         determining the cost of benefits denied by urban runoff.  The only
         hope we have of advancing the current level of knowledge is coor-
         dination between NURP and the EPA Office of Analysis and Evaluation.
         We are working with them to document the costs associated with  the
         control of urban runoff.
                                       59

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     Q.   Is the NURP Program research or demonstration?

     A.   It is neither.   It was sold to OMB as a planning program.

     Q.   What is the status of the General Permit Program?

     A.   There is a General Permit Program.  EPA officials however, have
         been slow to enforce it because they don't know what to do.
         The Rosenthal decision said that you could require BMPs in the
         permits but there are no federal funds available for the control
         of stormwater.   The General Permit Program is currently on the
         lowest level of priority.
                        Data Management and Analysis

                                 Eugene Driscoll


     1.  Data management is extremely important in the NURP Program.  If
implementation is to be considered at some point down the road, the sig-
nificance of the urban runoff problem must be documented well.   Public Works
Directors hesitate to implement now because of the lack of knowledge.

     2.  The variability of urban runoff presents a problem in documentation.
A substantial amount of data is needed because of this variability, however,
no one project can collect the amount of data needed.  Because all types of
data will be coming from all types of cities, a system is needed to manage
all the data collected.  EPA Headquarters is currently developing this system
which is documented in the Data Management Manual.

     3.  The Data Management Manual outlines reporting formats for all data
that is being collected.  The data needs to be reported in a similar fashion
so any anomalies between cities are due to actual differences rather than
how data was collected or reported.

     4.  The manual covers reporting formats for fixed site data, precip-
itation and dryfall data, flow quality and loading data, receiving water
impact data and evaluation of BMPs.  These formats will provide a data base
with compatible inputs from all NURP projects as well as a framework for
uniform data analysis.
                                      60

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             5.  The  format  which  has  been  adopted  for  fixed  site  data uses  a
       four-level  reporting sequence  wherein  each  successive level  calls  for
       more  detailed information.   Level I  pertains  to the urban  area as  it
       relates  to  the surrounding area  and  Level II  is to summarize information
       as  it pertains to  the overall  urban  area.   Level  III  calls for maps  and
       summary  data  for specific  catchments or  sub-catchments within the  urban
       area.  Level  IV requires the greatest  degree  of detail concerning  land use,
       collection  systems,  street surface  characteristics, etc.   Precipitation
       and dryfall data will be reported in event  summaries.  Flow  and quality
       will  be  reported for each  sample analyzed.  Receiving water  impact data
       will  be  reported as  it becomes available as well  as BMP evaluation data.

             6.  The  manual  includes sample  formats for reporting  all data,
       information on the SYNOP program and STORET parameter codes.

             7.  The  Data  Management Manual  has  been  given to all participating
       NURP  projects, and it has  been requested that all data submitted for the
       NURP  program  be consistent with  these  guidelines.  Data must be submitted
       to  EPA Headquarters  quarterly.  It will  then  be entered into STORET  as
       soon  as  it  becomes available and has been checked.
SESSION 2  --  DENNIS  ATHAYDE,  MODERATOR


                            Priority  Pollutants  in Urban Runoff

                                     Philip E. Shelley


             The  Love  Canal  incident  and publicity over carcinogenic materials has
        raised  national  concern.   As  a  result, priority pollutants are becoming a
        major concern  within EPA.  However, we know very little about them.

             The  Monitoring  and Data  Support Division, EPA Headquarters, requested
        that  the  Nationwide  Urban  Runoff Program collect samples for analysis of
        priority  pollutants.  Originally, NURP projects only analyzed for those
        pollutants of  concern in each area, however, MDSD requested that each project
        spend $20,000  to analyze for  all 129 priority pollutants.  Further, because
                                            61

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of the attention the program was getting,  quantitative analysis was used
instead of merely testing for the presence or absence of a pollutant.

     Guidelines have also been developed which outline quality assurance
both in the field and in the laboratory.  These procedures increase the
cost of analysis but provide a more reliable number.   In such a contro-
versial area, we feel it is more important to stress  quality than
quantity.

     The MDSD will use data collected in NURP cities  in their nationwide
evaluation.  Although the $20,000 used by NURP cities is hardly enough
to determine a priority pollutant problem, it can determine their presence.
Once found, MDSD may go into some of these cities and do additional
sampling.  They can then try to identify the sources  of priority pollutants
in urban runoff.  So the purpose of the NURP sampling is not enforcement;
it is to determine the presence of pollutants, in what concentrations  and
from what sources.
                Planning, Decision-Making and Implementation

                               Gail B. Boyd
Key Points
     1.  The objectives of the Nationwide Urban Runoff Program are to
determine the nature, cause and severity of urban runoff problems.  Previous
conclusions under 208 were a little speculative.  They were based on a
meager amount of data.  We need to refine these past conclusions and
answer some of the questions that persist about urban runoff.

     2.  Within the NURP program, projects were selected based on the
existence of a problem.  Problem definition is on three levels:  1) denial
of beneficial uses, 2) violation of standards and 3) public concern.  The
denial of beneficial uses is the level we are concerned most with.  Un-
fortunately this link is hard to define.  Most of the NURP projects were
selected because of violation of standards.

     3.  In deciding if urban runoff requires further study in a particular
area, priorities must be set.  Are you interested in restoration of older,
dirtier areas or are you more interested in anti-degradation?  Do you want
to focus on areas that need cleaning up or  on areas where problems may
occur?  One can be just as important as the other.
                                     62

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     4.  The NURP program is very specific in terms of its objectives
and goals but the procedure for putting together a program designed for
urban runoff study is basically the same for any area.  The steps in the
process are as follows:

          •    Determine the present conditions of the receiving waters
               through field monitoring.

          •    Assess the significance of urban runoff problems.  Is urban
               runoff a significant problem or are its effects masked by
               other problems?

          •    Determine the dominant mechanisms of cause and effect.

          •    Determine the appropriate degree of control.

          •    Assess the applicability of candidate control measures.

          •    Decide, plan, implement.

     Some of these steps are easier said than done but theoretically this
is the process one should go through when trying to come up with a workable
control program for urban runoff.

QUESTIONS AND ANSWERS

     Q.  How will we actually determine the impact of urban runoff on re-
         ceiving waters?  I am a little skeptical that this is going to
         happen under NURP.

     A.  We are not saying that we will be able to determine the impact of
         urban runoff on Lake Michigan.  The receiving water we start with
         could be a tributary.  We need to focus on the smaller areas in
         which  we can actually see some answers.  Then we could possibly
         consider the tributary being studied as a point source to the
         stream or lake.  On the other hand some projects are very specific
         and will actually determine the effect of BMPs on the receiving
         water (example:  Castro Valley).

COMMENT

     At some point we need to do a financial analysis and assess the costs
of not doing anything.

RESPONSE

     We realize this option must be evaluated.   We plan on working with the
FMAP people in performing these cost-benefit analyses.
                                     63

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SESSION 3 -- PHILIP SHELLEY, MODERATOR
                        State Perspective on Urban Runoff Planning

                                       Madeline Snow
        Key Points
             1.  The State of Massachusetts has two NURP Projects focusing on the
        impacts of urban runoff on heavily used urban lakes.   The NURP portion will
        handle the assessment with implementation being funded through 314 Clean
        Lakes Restoration Program.

             2.  The State felt that urban runoff deserved more study, based on
        their past 208 work.  The conclusion of the earlier work was that urban
        runoff has a potential impact, but not enough information was available to
        recommend any controls.

             3.  When applying for the NURP grant, several criteria were used to
        select the actual project area:

                  o    Documented stormwater problem;

                  9    Baseline data available;

                  e    Public perception and interest;

                  •    Few combined sewer overflows or other factors;

                  •    Focus towards implementation,

                  9    Local matching funds available.

             Using these criteria, two project areas were selected—Lake Quinsigamond
        and Mystic River.  Lake Quinsigamond is located in the towns of Worcester
        and Shrewsbury.  The Upper Mystic Basin is located in the towns of Winchester
        and Woburn.  The focus of these two projects is to identify the stormwater
        contribution to the receiving water, identify the impact on the receiving
        water, and identify the controls and costs.  Both lakes are heavily used for
        recreation and have been the subject of extensive studies due to their
        recognized value.  Of particular concern are short-term impacts at beaches
        after storms and long term impacts of nutrient and metal loadings.
                                             64

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     Urban runoff is competing with other water quality issues in the
State.  For example, there are more controversial problems such as
combined sewer overflows and hazardous wastes near drinking water wells.
For this reason the case for urban runoff management must be made
convincingly.
                   Areawide Agency Perspective on NURP:
                    Metropolitan Washington, B.C. Area

                              Austin Librach
Key Points

     1.  The Washington Council of Governments 208 made a very extensive
assessment of nonpoint sources in the Washington, D.C. area, and at this
point they are ready to implement nonpoint source controls.

     2.  The Potomac Estuary is the basin of concern in the Washington
COG NURP project.  Billions of dollars have already been spent on upgrading
the treatment plants that discharge to the Potomac and its tributaries.
Even with this upgrading, it was determined that if there were no nonpoint
sources, the standards would just barely be met.  In fact, there are many
nonpoint sources, and the upgrading of treatment plants will not solve all
the water quality problems in the Potomac Estuary.

     3.  To get an idea of the magnitude of the nonpoint source problem,
Washington COG designed a program under 208 on present nonpoint source
loads and projected loads from nonpoint sources.

     4.  Watersheds were ranked according to nonpoint loading criteria.
These rankings were used to focus program goals, investigations, and imple-
mentation.  Several different land uses were then monitored.  This approach
is recommended when only limited resources are available.  In addition,  area
wide WQM agencies should consider certain measures to permit the most
effective use of NURP study data to analyze complex pollution management
problems.  These include:

          e    Development of flow-related water quality management programs
               to permit monitoring of nonpoint loads under a range of
               meteorological and seasonal/flow conditions.
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          •    Involvement of private industry representation at early
               stages of NURP investigations to gain their confidence
               in results and gain benefits from their experience relevant
               to BMP implementation and operation.

          •    Development of receiving water modeling tools capable of
               monitoring the long term responses of receiving water to
               highly variable,  nonpoint,  loading impacts under a variety
               of seasonal flow conditions.  Application of such tools is
               as essential as development of additional information on
               nonpoint load generation and BMPs if  any meaningful evalua-
               tions of the costs and effectiveness  of pollution management
               alternatives are to occur.

     After two years of sampling and analysis,  BMPs  were recommended.
Through the sampling under 208 it was found that background loads exceed
point and nonpoint source loads.  It was also found  that the nonpoint  load
will be the largest contributor after the treatment  plants are upgraded.

     The NURP Program is designed to refine this initial information and
help determine the tradeoff for treatment plants vs.  nonpoint source
controls.  Nine sites have been selected for BMP evaluation.

     One interesting aspect of the Washington COG NURP project is that part
of the local match is being provided by the National  Association of Home
Builders.  They are interested in the results of the  BMP evaluation and will
participate in the project.
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SESSION  4  --  PHILIP  SHELLEY,  MODERATOR
                              NURP Program in Salt Lake City

                                         Gerald Kinghorn
        Key Points
             1.   Salt Lake County, Utah, is interested in determining the magnitude
        of the urban runoff contribution into their receiving waters particularly
        the Jordan River, and the BMPs that exist for its control.

             2.   The Jordan River and its tributaries are classified for secondary
        contact recreation, cold-and-warm water fisheries, water fowl and other
        wildlife and for agriculture.  However, urban runoff contributes to de-
        gradation of these streams and water quality criteria are often violated.
        A series of canals exist which run parallel to the Jordan River.  There is
        an exchange of urban runoff and canal waters which tends to further degrade
        downstream waters.

             3.   Under the NURP Program, data for problem assessment and pollutant
        source identification will be collected for a variety of land uses.  Data
        will also be collected relative to the eastside canals (the canals are
        built directly in the urban area and the stormwater is discharged directly
        into the canals.

             4.  The United States Geological Survey (USGS) is conducting a river
        quality assessment study on the Jordan River.  The results will be closely
        coordinated with the NURP study.

             5.  The Best Management Practices to be studied in the area include
        modifications to existing detention basins, spreading of flows over wet-
        lands, catch basin modification and maintenance, public education and
        canal modification.  The canal modification involves the separation of
        urban runoff from the relatively polluted canal water.

             6.  The USGS will also be participating in the NURP portion of the
        study.
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SESSION 5 -- DENNIS ATHAYDE, MODERATOR
                    Quality Assurance and Quality Control Within NURP

                                        Philip Shelley
       Key Points
            1.  During the years 1962 - 1963, stormwater and combined sewer
       overflow data were studied.  It was concluded that despite billions of
       dollars spent, the limited amount of useful data was appalling.

            2.  When the Nationwide Urban Runoff Program was formulated, quality
       assurance was an integral part.  All projects must submit written
       quality assurance plans including the funds required.  To help with this
       plan, guidelines were given to all projects.

            3.  The NURP program is not alone in requiring quality assurance.
       Administrator Costle's memo of June 14, 1979, states that, "In order to
       assure that all environmental measurements done by extramural funding
       result in usable data of known quality, I am making the inclusion of the
       attached "Quality Assurance Requirements" mandatory for all EPA grants..."

            4.  The United States Geological Survey (USGS)  is participating in
       several of the NURP Projects.  In those areas,  USGS quality assurance
       procedures will be used.
                           Evaluation of Management  Practices

                                   Eugene D.  Driscoll


            The 30 projects supported by the  NURP  Program will  examine  a wide
       variety of Control  Measures  (BMPs).  The  speaker presented  a  matrix
       developed to help achieve  a  balanced distribution of problem  types,
       receiving waters,  and control  measures among  the individual projects.   He
       also presented a summary of  the management  practices which  are represent-
       ed in the program.
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            The rationale for  evaluation of  the cost and performance of a
       specific management practice  or  control measure which has been adopted
       is dictated by the need to generalize performance sufficiently to permit
       extrapolation of results from the particular unit monitored to other
       catchments and to the project's  overall urban area.  Similarly, the
       broader, national aspects of  the NURP program require that a sound basis
       be developed for the transferability  of such data to the other projects
       which comprise the overall NURP  program.  The objective of evaluation
       strategies, therefore,  goes beyond  simply describing how a particular
       control measure or practice performed in a particular location under a
       specific set of conditions.

            The speaker described the approach adopted for several of the management
       practices to be studied by NURP  projects.  Procedures selected for data
       monitoring and reporting, and for analysis of data, to respond to the need
       for  transferrability were also discussed.
SESSION  6  -- DENNIS ATHAYDE, MODERATOR
                     U.S. Geological Survey Urban Stormwater Program

                                      David Lystrom
            As secondary and advanced treatment for point sources have been
        implemented, the need to address nonpoint source problems has become more
        evident.  Because of growing concern about pollution from urban stormwater
        the Water Resources Division of the U.S. Geological Survey began emphasiz-
        ing water quality studies in urban areas in the early 70's.  Four pilot
        studies conducted by the U.S. Geological Service (USGS) in Denver, Miami,
        Philadelphia, and Portland, Oregon have shown that water quality loadings
        from urban runoff are highly variable in time and space.  Conclusions
        drawn from these studies and over 200 water management studies conducted
        under the Environmental Protection Agency's (EPA) 208 Program indicate
        the importance of an adequate nationwide data base defining stormwater
        quality and the effectiveness of controls.  Such a data base is the single
        greatest tool for coming to grips with urban runoff problems.
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     In August 1980 the USGS and EPA joined forces in an interagency
agreement to study urban stormwater nationwide.   As a result, USGS has
conducted nine major data collection and interpretation studies as part
of EPA's Nationwide Urban Runoff Program.  Four  more USGS/EPA studies
are in the planning stage.

     The purpose of these studies is to provide  local, State, and Federal
authorities with a sound basis for making stormwater management decisions.
Specifically, the objectives of these studies include:

          »    determining storm runoff loadings

          9    establishing a consistent and accessible data base

          e    developing methods for transferring data to unsampled
               watersheds

          0    testing management alternatives

     The approach used is to outfit typical urban watersheds with
instruments in each study area.  Local authorities in selected watersheds
will implement management controls such as street-sweeping and detention
storage.  Intensive rainfall, runoff, and water  quality data will be
collected during storms.  Statistical and deterministic models will then
be used to assess management alternatives and to estimate both storm and
annual loadings for unsampled watersheds in each study area.

     After the presentation, the question of program responsibility was
raised.  USGS Headquarters will provide training and models, while the
field offices will do the interpretive work.  Interim interpretive reports
for each study area will be prepared and will require local arrangements.
Headquarters will provide technical reviews and  local offices will publish
the reports.
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                 Research and Development in Urban Runoff

                             Richard P. Traver


     Quantifying pollution problems from urban and combined sewer overflow
and developing countermeasure controls is the mission of EPA's Storm and
Combined Sewer Pollution Control Research and Development Program.  It aims
to advance technology for urban stormwater and combined sewer overflow
treatment, control, and management.  This has involved the development and
demonstration of new and innovative systems as well as design manuals,
models, and methodologies.  Recent work has focused on analyzing toxic pol-
lutants and assessing impacts on receiving waters.  Countermeasure control
objectives include BMP evaluation and hardware development.

     Ties between receiving water quality and stormwater discharges must
be clearly established and delineated.  Quantifying the impairment of
beneficial uses and water quality objectives by such discharges is a major
goal.  Investigations are now being done to study pathogen concentrations,
nutrients, effects on biological communities, and toxicity problems from
metals, hydrocarbons, pesticides, and persistent organics.

     Recently, the Program began analyzing urban samples from ongoing
projects for priority pollutants.  Fifty-three pollutants have been
identified from 19 samples obtained from eight urban areas.  The most
frequently found priority pollutants are phenols, aromatic hydrocarbons,
PAHs, esters, and metals.

     A variety of models have been developed to assess urban stormwater
pollution and plan for its control.  Several preventive control technologies
are being investigated including porous pavements, street cleaning, wetlands,
and land management.

     A second area under study is collection system controls which pertain
to management alternatives for wastewater interception and transport.  These
include catchbasin maintenance and design, new sewer design, sewer flushing,
polymer injections, infiltration/inflow control, in-line storage, tide
gates, sewer system maintenance, and regulators.  In particular, the Program
is looking at uses for the hydrobrake, the swirl regulator/concentrator,
and the helical bend flow regulator/solids separator.  These last two pieces
of equipment have shown excellent potential for simultaneous quality and
quantity control.

     A third study area focuses on storage and sedimentation facilities.
Such facilities are typically simple in design and operation, can respond
without difficulty to random storm behavior, are relatively fail-safe, and
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        can operate in concert with dry-weather plants.   Disadvantages,  however,
        include large size,  large real  estate requirements and dependency on
        other treatment facilities for  dewatering and solids disposal.   A
        manual for planning  and designing facilities is  now being prepared.

             A final area of study is treatment alternatives.   Physical  treatment
        alternatives are primarily applied for removal of suspended solids from
        waste-streams.  They are of particular importance in treating settleable
        solids, suspended solids and floating material in storm and combined sewer
        overflows.  Other possibilities are biological treatment and disinfection.

             Engineering is  an art.  In looking for the  "better mousetrap" the
        Program has found that no single solution exists to the stormwater problem.
        An integrated systems approach  promises the best results.   More  work is
        needed to realize the full potential of the technologies being developed.
SESSION 7 -- PHILIP SHELLEY,  MODERATOR
                            Relationship Between Urban Projects
                                 and Water Quality Control

                              Jan Lundgren and Stein Bendixen
             The speaker's presentation outlined a four part methodology for
        planning urban stormwater projects:   1)  problem identification,  2)
        development of alternatives,  3) evaluation of alternatives,  and  4)
        development of implementation plans.

             Problem identification should include analysis  of pollutant sources
        and impacts, hydrologic characteristics  (water cycle flows,  time of
        concentration, etc.),  and capacity of sewers.  The speaker described
        networks and matrices  which summarized the system and pollutant  character-
        istics.   Some of the potential impacts which should  be considered include
        degraded drinking water supplies,  groundwater pollution,  flooding,
        erosion, inappropriate land use, and  impaired public health.   Pollutant
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sources to be considered include sewage treatment plants, stormwater,
raw sewage outfalls and overflows.  Pollutant constituents to be con-
sidered include phosphorous, suspended solids, BOD and heavy metals.
The relative contribution of each source to specific pollutants and
identified consequences should be determined.

     Control measures should be designed to meet specific pollutant re-
duction objectives.  The speaker described the goals utilized in Sweden.
The cost-effectiveness of various alternatives should be evaluated.  A
plan of action would include an implementation schedule and monitoring
program to observe changes in impact categories.  Information would be
supplied to the operating staff and decision makers.  Programs and
operating practices would be modified as appropriate.
                          Clean Lakes and Summary

                              Dennis Athayde
     The speaker summarized the Clean Lakes Program and discussed coordin-
ation with NURP (3 of 50 Clean Lakes projects are coordinated with NURP
projects).  The Clean Lakes program is more action-oriented than NURP.

     An overview of all the NURP presentations was provided.  Each
government level has a different perspective regarding potential outputs
from NURP.  While local units are largely interested in "getting over
the hump" to implementation, EPA is trying to determine whether urban
runoff is a significant problem from a national viewpoint.
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AGRICULTURE PROGRAM
         75

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                                       AGRICULTURE
SESSION 1:  Model Implementation Projects

            Challenge of Expanding Pollution
            Control Programs

            New York MIP
            Indiana MIP
Al Herndon, Moderator

Joseph Krivak
Dr. Mark Brown
Dr. Paul Robillard

Angela Preston
Joseph Hayes
78
78
79
SESSION 2:  Model Implementation Projects

            MIP Innovative Techniques - The
            Indiana MIP Biological Monitoring

            Washington MIP - Sediments
            Standards and Measurements
Doug Hawkins, Moderator

James Gammon


Clifford Eckhardt
80
81
SESSION 3:  Clean Water Programs

            Rural Clean Water Program
            Status and Future

            The O'Neill Principle:  A
            Precedent For A Federal
            Commitment to Cleaner Water
Nathan Chandler, Moderator

Allan Durrick


Dr. Kathleen 0. Camin
82
83
SESSION 4:  Water Quality Monitoring And
            Evaluation

            Storage Analysis and Evaluation
            of Water Quality Data

            Storage Analysis and Evaluation
            of Water Quality Data
Lynn Shuyler, Moderator
Dennie  Burns
Frank J. Humenik
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AGRICULTURE,  continued
SESSION 5:   Nonpoint Source Studies

            Lake Erie Wastewater Management
            Study

            Southeast Saginaw Bay Coastal
            Drainage Basin Agricultural
            Cost-Sharing Program Special
            Project
Al Herndon, Moderator

Stephen M. Yaksich
Virgil Bouck
Jim Sygo
87
87
 SESSION 6:  Other Agriculture Water Quality
            Efforts

            Various State Cost-Share
            Programs

            A Multi-Agency Cooperative
            Program to Reduce Soil Erosion
            and Improve Water Quality in
            West Tennessee

            Cooperation Between EPA and
            Cooperative Extension Service
Larry Ferguson, Moderator
James E.  Lake
James G. Dillard
J. M. Sprott
89
90
91
 SESSION 7:  Agricultural Water Quality
            Practices

            Other Agricultural Water Quality
            Efforts:  Various State Cost-
            Share Programs

            Agricultural Land Use Water
            Quality  Interaction:  Problems
            Abatement, Project Monitoring,
            And Monitoring Strategies

            State Implementation of
            Agricultural Nonpoint Programs
Walt Rittal, Moderator
Kenneth Bruene
Senator Forrest Schwengels
Dr. Jochen Kuhner
92
94
Robert C. Weaver
96
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SESSION 1 -- AL HERNDON, MODERATOR


                     Challenge of Expanding Pollution Control Programs

                                       Joseph Krivak


             We must restructure the current orientation of agricultural pollution
        control projects to develop good technology transfer between new and
        existing projects.

             Institutional support must be built to increase program outlays.  To
        really get the job done for major agricultural problem areas, we must find
        financial methods to fund necessary projects.  In addition, new fiscal
        policies such as a severance tax on agricultural products may be needed.

        QUESTIONS AND ANSWERS:

             Q.  How do we judge the success of special projects?

             A.  Document successful working institutional relationships;
                 Develop innovative practices and leadership; encourage and assess
                 local participation and commitment; and practice implementation.

             Q.  Do we need new programs to handle new funds?

             A.  No.  The objective is to get funds to those that need them.
                 It is new ideas that must be encouraged.
                          New York Model Implementation Projects

                            Drs. Mark Brown and Paul Robillard
             The watersheds included in the Model Implementation Program (MIP) in
        New York are demonstration areas providing water quality management agencies
        an opportunity to implement and evaluate nonpoint source controls.  The
        West Branch of the Delaware River provides an opportunity to look closely
        at different control measures appropriate to animal agriculture.  Eutrophic
        conditions in the West Branch have pointed up the need for point and non-
        point source c6ntrols (with a particular emphasis on phosphorous from
        dairy wastes).
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     Research programs have been set up to identify pollution parameter
loadings.  Earlier monitoring activities have indicated that barnyards,
manure spread fields and milkhouse waste all contribute nutrients to algal
blooms in the Cannonsville Reservoir.  However a clear relationship between
agricultural activities and nutrient enrichment in the reservoir has not
been established.

     Monitoring activities planned in the West Branch include sampling at
the Beerston site just above the reservoir, two barnyards on Steelbrook and
phosphorus transport studies along Platnerbrook.  Baseline data from these
activities will be used to develop more general computational methods for
estimating nutrient losses from barnyards and manure spread fields.  This
work will also provide a basis for estimating phosphorous delivery to
tributaries and in-stream changes in phosphorus attenuation.

     In summary, the planned monitoring and research activities in the West
Branch will yield base loading data from barnyards, manure spread fields
and milkhouse wastes.  It will also develop loading functions for estimating
nutrient delivery and transport changes.  With this information, innovative
low-cost BMPs can be developed to intercept these nutrients.
                   Indiana Model Implementation Projects

                     Angela H. Preston and Joe B. Hays


     The Indiana Heartland Model Implementation Project is the accelerated
program for implementing the Heartland Water Quality Management Plan in two
critical watersheds in central Indiana.  The agricultural nonpoint portion
of the Areawide 208 Plan identifies "sediment" as a major pollutant in 79
watersheds.  The 208 Plan establishes the priority areas in the eight-county
region for implementing "Best Management Practices" on a voluntary basis.

     The two MIP watersheds represent different nonpoint pollution situations.
Based on soil erosion estimates, Stotts Creek is the highest priority
watershed in the region.  Agriculture makes up 98 percent of this 40,000-acre
watershed.  The Eagle Creek watershed in contrast is over 100,000 acres in
size and contains a multi-use reservoir of approximately 1,300 acres.
Intensive agricultural production is the major land use in this watershed
with rapid residential growth occurring.

     The Heartland MIP involves a complex research effort which attempts to
link the application of BMPs to water quality.  The research includes an
extensive data base for spatial analysis and information exchange and a
biological assessment based on fish, plankton, insect, and benthic
population characteristics.  Water quality monitoring of two major streams
and two specific BMPs will test the accuracy of predicted data from the
computer model.


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             A major challenge of the MIP has been the successful establishment of
        a working network of agencies, institutions, and local groups to improve
        water quality through reduced nonpoint pollution.  Citizen involvement and
        landowner participation are essential for MIP objectives.

             During the initial phase of the MIP, Best Management Practices were
        selected to achieve the sediment reduction goals for each watershed.  Some
        newer and more innovative erosion control practices are given special
        emphasis, such as parallel terraces, conservation tillage, and sediment
        basins.  Program activities, special MIP-ACP funds, and greater cost-share
        rates have encouraged farmers to apply practices which protect their lands
        while improving water quality.
SESSION 2 -- DOUG HAWKINS, MODERATOR
                               Model Implementation Projects
               Innovative Techniques -- The Indiana MIP Biological  Monitoring

                                      James R.  Gammon
             The Indiana MIP includes the study of aquatic biota to assess improved
        water quality from the reduction of siltation from two watersheds devoted
        primarily to agriculture.   We established biological  sampling stations near
        the bases of major subtributaries of Eagle,  Stotts, and Rattlesnake Creeks
        in central Indiana.   Fish  and macroinvertebrate populations are being
        studied in relation to land use, riparian vegetation  patterns,  and stream
        morphology.

             Macroinvertebrates were sampled monthly from May through October by
        (1) three Surber samples in riffles and (2)  hand-net  sweeps along 10 m.
        shoreline.  The laboratory preserved samples in 70 percent ethanol contain-
        ing rose bengal stain.  Individuals were identified,  counted, and weighed.
        The data was stored  on computer disc and will be analyzed by specially
        developed programs.

             Fish were collected with a 30-foot electric A.C.  seine having 2-foot
        long, bare copper electrodes spaced at about 2^ foot  intervals, and powered
        by a 115 VAC,  1350 watt generator floated on styrofoam.  At each end, hand
        electrodes were used to probe undercut banks and roots.  During collecting
        the seine is stretched across the stream and moved from downstream to upstream
        followed by netters  and the generator.  Stunned fish  are placed in a live
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net upon capture and, at the end of the run, identified, weighed, and
measured. They are placed in a holding net while a second, and then a
third, collecting run is made.  A regression of catch in weight per pass
versus the previous cumulative catch yields an estimate of the standing
crop.  The use of numbers rather than weights produces less satisfactory
results.  The data is stored on computer disc file and used to obtain various
population parameters including Shannon diversity. Standing crops are
calculated as kg/hectare surface area.

     The length, mean width, mean depth, bottom composition, canopy,
and adjacent land use is determined.  A composite index incorporating
both density and diversity may have value as an indicator of environmental
quality.  Relative abundance as determined by backpack electro-fishing
and seining will be examined in relation to standing crop estimates to
assess their potential value as general field tools.

     Problems in evaluating nonpoint influences have been the presence
of point sources of pollution including a landfill, faulty septic tank
areas, the bulldozing of segments of streams, etc., all of which must be
measured.
                Washington Model Implementation Projects -
                    Sediment Standards and Measurements

                           Clifford V. Eckhardt
     The MIP Project covers a total of 300,000 acres of irrigated lands
in the South Yakima Conservation District.  However, the project has been
narrowed down to a critical problem area in the Sulfur Creek Basin and
further divided into two priority areas, of about 12,000 acres each.
This affords a more concerted effort on the most serious sediment problems
and allows a more positive analysis of the implementation process.  The
Project deals entirely with surface irrigation runoff.

     One of the most important aspects of meeting water quality standards
is developing an effective system of measuring sediment loads during the
irrigation season.  Use of the Imhoff Cone has brought a reliable and
efficient system of on-site measurements.  This is a simple, efficient
and low-cost method of measuring solids in waterways or single crop rows.

     Several ongoing research projects correlate data procured by other
methods with that obtained by the Imhoff Cone.  This is necessary and
desirable so that historical data may be used for determining the effective-
ness of certain Best Management Practices being implemented in the MIP.
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             We classified runoff to determine if it exceeded permissable
        standards to meet water quality requirements.  These standards are based
        on randomly sampled data and on the percentage of farm units potentially
        affected.  As more data is collected, we may reissue these standards.
SESSION 3 -- NATHAN CHANDLER, MODERATOR


                                    Moderator's Remarks
             Perhaps 75 percent of the farmers in this  country have  not  heard of
        208.  There is a big information and education  job  to  be  done, primarily
        by Extension,  to inform farmers of water quality  programs.   Some current
        trends in agriculture such as absentee ownership  and a cheap food policy
        make conservation programs difficult.
                       Rural Clean Water Program:   Status  and  Future

                                       Allan Durrick
             Our laws are passed to  improve  the  quality  of  life for  the  citizens.
        Our jobs as government employees  are made more difficult because we have
        a democracy.  According to Fisher Ames,  "An  autocracy  is like an efficient
        sailing ship and a democracy is like a raft--it  never  sinks  but  your feet
        are always in the water."

             The USDA was originally established because of the country's  concern
        for an adequate food supply.   Concern about  environmental problems came
        later when pollution became  evident  as a side effect of production.

             There are several reasons for USDA  involvement in environmental quality:

             •    Farmers are causing pollution  problems.

             •    Resource protection and environmental  quality programs are
                  similar.
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     •    USDA agencies have experience in administering conservation programs.

     •    Many conservation practices are also water quality practices.

     Economic incentives for farmers are needed for BMPs when there are
more benefits for others than to farmers themselves.  A strong information
and education program will be needed to convince farmers to invest some
of their own money in water quality practices.

     We will need monitoring and evaluation of the RCWP since some things
we will try may not work.  In general, all agency programs need a periodic
evaluation, and the whole ACP program is currently under evaluation.

QUESTIONS AND ANSWERS:

     Q.  How are ASCS and SCS getting along these days?

     A.  Good.  We don't always agree but we meet and resolve issues.

     Q.  Barry Baldwin, an Extension Engineer from Florida, stated he was
         frustrated with preparing project proposals, such as for RCWP,
         when so little money is available.

     A.  Durrick stated that he understands the problem and is not
         promoting new RCWP proposals.

     Q.  Why is RCWP an experimental program?

     A.  Walt Rittall stated that Congress reauthorized 208(j) but has not
         made a new appropriation.  The current "experimental" RCWP received
         a 1980 appropriation under USDA authorities.  Its experimental nature
         relates to its testing ways of administering programs and the cost-
         effectiveness of BMPs.
                 The O'Neill Principle:  A Precedent for a
                    Federal Commitment to Cleaner Water

                         Kathleen 0. Camin, Ph.D.
     While the Rural Clean Water Program provides a major step towards
reducing nonpoint source pollution, the Federal government should extend
its commitment even further.  I believe the O'Neill project in Northern
Nebraska, sets a national precedent for minimizing nonpoint source water
pollution in federally related projects.

     The construction of this dam by the U.S. Water and Power Resources
Service (WPRS) would impound water from the Niobrara River for use in
irrigating about 77,000 acres.
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     The WPRS defined a study area of 386,000 acres of which 110,000 acres
of corn are now irrigated with groundwater through center pivot irrigation
systems.  If the project is constructed, the study area will include
202,000 irrigated acres, 115,000 acres irrigated with groundwater and
69,000 acres irrigated with project water.  Fertilizer is applied in
irrigated areas in liquid form in small amounts when the seed is planted
(about S-7 pounds per acre) and later applied through the irrigation
system in liquid form with an average total of about 180 pounds per acre.

     As part of the supplemental EIS, WPRS provided projections of nitrate
levels in the project area, with and without the project.  They found
that groundwater concentrations would be 31 milligrams per liter nitrate
with the project and 163 milligrams without the project after 100 years.
Dilution of the groundwater with low nitrate water taken from the Niobrara
River would cause this large reduction.

     However, we were concerned about the accuracy of these estimates and
about the lack of substantive efforts to minimize the nitrate burden on
groundwater in the area.  A special task force determined that the dilution
was not quite so dramatic.  Their figures showed levels of 25.7 milligrams
vs. 31.7 milligrams per liter nitrate with and without the project
respectively.  The project then only brought about marginal reductions in
the nitrate burden.

     A second task force met to develop mandatory BMPs for all farmers
receiving proj ect waters.  Once landowners were convinced that EPA did
not just want to create another bureaucracy, they supported the work.
Contracts between the WPRS and irrigation and reclamation districts were
developed which required water users to:

     •    attend a short training course on irrigation scheduling.

     •    use soil moisture measuring equipment.

     •    institute and maintain an irrigation scheduling program so
          that irrigation water does not move below the root zone.

     •    not apply fertilizer during the fall and winter.

These contracts set a strong national precedent for using mandatory BMPs
on federal projects.  We hope the lessons learned will be widely used.

     On the regional level, we are encouraging Best Management Practices
whenever possible:

     •    On the proposed North Loup unit in Nebraska agreements identical
          to those on the O'Neill project are in place.

     •    At Burlington, Iowa, the Department of Defense and the State of
          Iowa now require the use of minimum tillage by farmers leasing
          some 9000 acres of Army Ammunition Depot land.
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            Finally, we will encourage the Federal Executive Board and the
       Federal Regional Council  (both of which coordinate efforts for various
       Federal agencies in the region) to recommend that all member agencies
       require BMPs in those areas where they have jurisdiction.

            The Federal government has little statutory authority to deal with
       nonpoint source pollutants.  The States are beginning to pull ahead in
       this area--all four States in Region VII have some State cost-sharing
       programs for implementing BMPs.  However, EPA is currently in the process
       of proposing a national agreement with the WPRS to require agreements
       similar to the one negotiated on O'Neill  on all their projects.  Similar
       agreements could be drawn up with the Departments of Agriculture, Defense,
       Interior,  and other Agencies that own or use large amounts of land.
       They can, in fact, be used for all appropriate Federal projects.
SESSION 4 -- LYNN SHUYLER, MODERATOR
                  Storage Analysis and Evaluation of Water Quality Data

                                      Dennie Burns
       The speaker discussed aspects of the Rural Clean Water Program (RCWP),
       Section 208(j) of the Clean Water Act as amended (P.L. 95-217).  The
       intent of Section 208(j) is to control agricultural nonpoint source
       pollution through cost-effective Best Management Practices (BMPs) in
       order to improve water quality.  The program provides long term financial
       (usually 75% of costs) and technical assistance by the Department of
       Agriculture's Conservation Service to farm owners or operators in areas of
       critical pollution problems.  Basically however, the RCWP is an inter-
       governmental effort which will involve participation of agencies other
       than EPA and_USDA.

            Agricultural water pollution control has been a major problem in
       the United States and will require $19 billion in current dollars to
       control over the next 20 years.

            Each of 13 projects chosen to participate will be monitored, analyzed
       and evaluated as to the effects of using BMPs.  Reductions will be sought
       in pesticide, agricultural chemical waste, fertilizer and sediment pollution.
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     Analysis of a particular stream pollution problem includes a look
at the history of the problem, the most serious impacts of the pollutants,
transport dynamics, biological habitat and the time it takes to alleviate
or eliminate the problem.  The effects of agricultural pollutants on
lakes will also be studied.

     Ultimately these projects will be used as models for new and
reorganized projects elsewhere.
           Storage Analysis and Evaluation of Water Quality Data

                             Frank J.  Humenik
     The speaker delineated tentative agreements on a cooperative EPA
and USDA grant to develop a pilot program for tracking water quality
improvements resulting from agricultural nonpoint source controls.  The
Cooperative Extension program at North Carolina State University will
conduct this training and evaluation program while the work base will be
the Department of Biological and Agricultural Engineering.   He presented
general details of the three major program activities dealing with 1)
training for RCWP programs, 2)  monitoring and evaluation of nonpoint
source control programs, and 3) development of a national evaluation and
tracking system to evaluate agricultural nonpoint source control programs.
Specific emphasis will be given to the national evaluation and tracking
system which will develop a data management and analysis system to
evaluate RCWP projects and associated agricultural nonpoint source control
programs on a water quality and agricultural production basis.  This
program will provide a data and evaluation capability to make decisions
concerning the cost-effectiveness of program recommendations and will
provide a data base for policy decisions and accountability needs.
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SESSION 5 -- AL HERNDON, MODERATOR


                          Lake Erie Wastewater Management Study

                                   Stephen M. Yaksich


            The Lake Erie Wastewater Management  Study  (LEWMS) was authorized by
       Public Law 92-500, Sections 108(d) and  (e) which directed the Secretary
       of the Army to develop a wastewater management  program for the  environ-
       mental repair of Lake Erie.  The  Buffalo  District was directed  to perform
       the study.  The most critical problem for Lake  Erie was identified  as
       cultural eutrophication or enrichment by  nutrients, particularly phos-
       phorus.  Since programs to control municipal  and industrial point sources
       of phosphorus were already underway, the  LEWMS  concentrated on  diffuse
       sources of phosphorus which account for 50 percent of the phosphorus of
       Lake Erie.

            In order to study possibilities for  diffuse source pollution control
       the Lake Erie Study developed a Land Resources  Information System (LRIS).
       The LRIS is a geographic grid cell information  system which contains geo-
       referenced data on land use, soil phases, hydrologic and geo-political
       location.  This data base has facilitated application of the Universal
       Soil Loss Equation  (USLE) to a variety  of land  management scenarios which
       have a potential for reducing diffuse source  phosphorus production  from
       the cropland of the Lake Erie Basin.  Of  the  six scenarios evaluated
       against existing conditions, three show promise for producing significant
       reductions.  A "good farm management scenario"  in which soil loss is
       constrained to the T or soil loss tolerance factor, a minimum tillage
       scenario and a mixed minimum and  no-tillage scenario produced ranges of
       total phosphorus reductions of  24 to 30 percent, 28 to 42 percent,  and
       42 to 62 percent, respectively.   Additionally,  the maximum reduced  tillage
       scenario can be achieved with a net farm  income increase of about seven
       percent.
                       Southeast Saginaw Bay Coastal  Drainage Basin
                     Agricultural Cost-Sharing Program Special Project

                                 Virgil  Bouck and Jim Sygo


             The  ASC  County Committees of Tuscola and Huron Counties  are currently
        implementing  a voluntary cost-sharing program for soil and water conserva-
        tion  practices that have been designed to minimize  impacts from agricultural
        runoff.
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     The project has had support from all local USDA agencies, ASCS, SCS,
SCO, CES, FMHA, Michigan Department of Natural Resources,  the County
Board of Commissioners, and the East Central Michigan Planning and
Development Region (208 Agency).

     The Agricultural Cost-Sharing Program (ACP) project resulted from the
recommendations generated by the local 208 Plan.  The project purpose is
to demonstrate the impact of the best management practices on the quality
of water and aquatic organisms found in Saginaw Bay.   Delivery of soil loss
to the Bay is very high in this area due to the predominant southwesterly
winds and the extensive drainage network that has been developed in this
area.

     Efforts in reducing the loadings of sediment and nutrients to
Saginaw Bay are highlighted by the encouraged use of conservation tillage
systems in areas that are identified as hydrologically active.  Energy
costs for the producer can also be reduced with these tillage systems.
Modeling results have shown that soil losses must be reduced below
acceptable SCS levels if the water quality of Saginaw Bay is to be improved.

     EPA has recently funded the Areawide Water Quality Management Planning
Agency to monitor and evaluate the effectiveness of utilizing conservation
tillage systems to reduce the amount of soil loss within the study area.
Load reductions will be extrapolated from demonstration plots to estimate
the total sediment and nutrient load reduction expected for the Study Area
resulting from the use of conservation tillage.  A mathematical simulation
model developed by the 208 Agency will be used to determine the resulting
impacts in the near-shore area of the Bay.

     The project will ultimately be utilized to identify whether a State
program in Michigan is necessary to improve the quality of rivers, inland
lakes, and near-shore zones of the Great Lakes that are being heavily
affected by agricultural contributions.
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SESSION 6 -- LARRY FERGUSON, MODERATOR
                          Other Agricultural Water Quality Efforts:
                              Various State Cost-Share Programs

                                        James E. Lake
            The National Association of Conservation Districts which serves as
       the national spokesman for  the nation's  2,950 Conservation Districts
       appreciates the opportunity to participate  in this National Conference
       On Water Quality Management.

            Conservation Districts are charged  with the responsibility to carry
       out programs for the  conservation of  soil,  water and related resources at
       the local  level.  State Soil Conservation Agencies, which are a part of
       State government, assist Conservation Districts in carrying out their
       responsibilities.

            The goal of Conservation Districts  and State Soil Conservation Agencies
       for some 40 years has been  to keep soil  on  the land, where it is a product-
       ive resource, and out of the water, where it is often a pollutant or a costly
       nuisance.  With this  background and philosophy, it was only natural that
       Conservation Districts and  State Soil Conservation Agencies would become
       a part of  the nation's major assault  on  water pollution that grew out of
       Section 208 of P.L. 92-500, the Clean Water Act of 1972.  As a result,
       Conservation Districts and/or State Soil Conservation Agencies in 41 States
       entered into formal agreements with State Planning Agencies to develop the
       agricultural portions of the various  States' Water Quality Management Plans.
       This has resulted in  Conservation Districts and/or State Soil Conservation
       Agencies being designated in most State  Agricultural 208 Plans as the
       Management Agency(s)  responsible for  implementing the plans.

            Still lacking from the 208 thrust,  however, were the resources, especially
       economic resources, necessary to implement  the plans.  Conservation Districts
       and State  Soil Conservation Agencies  have learned from their forty-some years
       of experience that the essential elements of a voluntary program to encourage
       private landowners and land users to  adopt  and implement practices to control
       soil erosion whether  it be  for the protection of the soil resource base or
       for water  quality improvement are:  information and education, technical
       assistance, and cost-sharing.  Of these  three elements the one which is usual-
       ly in the  shortest supply,  at least from Federal sources, is cost-sharing
       funds.  To help offset the  deficiencies  in  cost-sharing dollars from the
       Federal government several  State Soil Conservation Agencies and Conservation
       Districts  have sought and received State and local funds for cost-sharing.
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       A Multi-Agency Cooperative Program to Reduce Soil Erosion and
                  Improve Water Quality in West Tennessee

                             James G.  Oillard


     West Tennessee is one of the most erosive areas of the U.S.  The 21
counties that lie between the Tennessee and Mississippi Rivers comprise
25 percent of the land area in Tennessee, yet have 64 percent (1.6 million
acres) of the serious sheet and gully erosion in the State.  Average soil
loss on cropland is estimated by SCS to be 40 tons per acre per year, with
some fields losing as much as 120 tons annually.

     In 1978, TVA joined forces with USDA and State agencies, under the
auspices of the Tennessee Rural Development Committee, to develop a compre-
hensive program to reduce erosion and improve water quality in west Tennessee.
A 6-phase program was developed and implemented in 1979.  The major program
components and their objectives are:

     •    Resource management conservation farm demonstrations (a) to demon-
          strate current technology available to maintain acceptable soil
          losses and improve water quality; (b) to demonstrate how conservation
          measures can be adapted to a commercial farming operation without
          adversely affecting income and promote their wide-scale adoption.

     •    An accelerated information and education program on erosion control
          and water quality improvement (a) to create and improve awareness
          of soil erosion and water quality problems by the general public,
          landowners and farm operators; and (b) to aid landowners and farm
          operators in making improved land use and conservation treatment
          decisions.

     »    A small resource conservation management area program or programs—
          an extension of the resource management conservation farm program
          to hydrological units (watersheds or drainage areas) of 1,000 to
          2,500 acres in size.   A drainage area of this size will provide
          information about the effects of farm management and conservation
          practices on water quality at the point of discharge.

     •    Development of large resource conservation management areas similar
          to the small RCM area program.  Watersheds consisting of from
          10,000 to 200,000 acres.

     «    Completion of soil surveys in seven counties which do not have
          soil surveys.

     «    National ACP Special  Project - to achieve widespread soil conser-
         . vation in specially selected project areas.
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         Cooperation Between EPA and Cooperative Extension Service

                               J. M. Sprott


     EPA has had close working relationships with SCS and ASCS during the
last few years.  Since at this time 208 plans are being completed and
certified, and education is usually identified as a major part of the
implementation program, it  „ appropriate that the Cooperative Extension
Service Service get more involved in rural water quality programs.

Cooperative Extension Service

     Cooperative Extension is funded from Federal, State, and local sources.
Many current USDA programs and agencies were first explained to farmers by
Extension such as ASCS commodity programs, farm cooperatives, Soil Conser-
vation Districts, rural electrification and irrigation districts.  Because
of its local organization new programs are adopted gradually, but when local
county agents suggest new practices, they are quite effective in changing
methods and attitudes.

Current Programs in Water Quality

     Improved Use of Pesticides - CES devotes considerable effort, in
cooperation with EPA and State agencies, to three pesticide programs:  IPM
(Integrated Pest Management), Pesticide Application training, and Pesticide
Impact Assessment.  IPM is designed to make more specific use of needed
pesticides.  An estimated $50 M was saved by farmers in 1979 due to this
program.

     Planning and Technical Assistance - Local agents have helped States'
water quality agencies set up planning committees.  Extension staff advise
farmers on design of feed-lot pollution control, rural sewage systems,
fertilizer recommendations, and conservation tillage systems.

     Special Water Quality Projects - Extension is designated to carry out
information aspects of RCWP and other projects and to provide technical
assistance for management-type BMPs.

     Extension Liaison at EPA - Extension has, through EPA support, a liaison
position at EPA Headquarters.  Two additional positions are being established
in Kansas City and Chicago.

     National Water Quality Workshops - Tentative plans have been made to
hold several staff workshops on management-type BMPs and water quality
programs methods in 1981.  Approval by Extension Directors for four 3-day
workshops is necessary before plans are confirmed.
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             Question:   How can we get the limited amount of cost-sharing funds to
                        be designated to critical areas?

             Answer:     208 has been helpful in giving priority to problems.   As a
                        result, Conservation Districts are making water quality a
                        major item of their work.  They are encouraging county ASCS
                        committees to fund BMPs in critical areas.                  \

             Mr.  Sprott noted that cost-sharing can be a double-edged sword.   Farmers
        can become dependent on cost-sharing,  and when funds are not available, the
        practices are not carried out.  This happened in Texas when agricultural lime
        use was almost discontinued after ACP  payments were eliminated.   In the
        Lake Tholocco RCWP project, demonstrations are being emphasized.
SESSION 7 -- WALT RITTAL, MODERATOR
                         Other Agricultural Water Quality Efforts:
                             Various State Cost-Share Programs

                       Kenneth Bruene and Senator Forrest Schwengels
             The State of Iowa has taken leadership in developing an aggressive
        erosion control program to maintain the productive capacity of its land and
        to improve the quality of its water.  Although current soil erosion estimates
        reveal that average soil losses are occurring at a rate greater than twice
        the established soil loss limits,  Iowa legislators recently approved a
        20-year master plan called "Iowa Soil 2000" with the goal of achieving
        established soil loss limits- by the end of the century.

             Iowa has expended $31,550,000 in a soil erosion control cost-share
        incentive program since 1973.  The cost-share program elements include:

             •    a 75 percent cost-share incentive for land treatment above
                  designated publicly-owned lakes.

             •    a 75 percent cost-share payment to help landowners comply with
                  soil loss limit administrative orders.
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     e    a 50 percent cost-share incentive for land treatment through
          allocations administered by Iowa's 100 soil conservation districts.

     •    a per-acre payment to landowners participating in a crop residue
          management demonstration project in selected watersheds.

     •    a 60 percent cost-share payment for group landowners'  participation
          in watershed soil conservation plans.

     «    an incentive program for summer construction to compensate land-
          owners for crop losses sustained during the crop growing season by
          installing erosion control practices.

     •    a wind erosion control incentive payment program for installation
          of windbreaks or maintenance of year-round crop residue cover.

     •    potential matching fund programs from other federal sources such
          as the U.S. Department of Agriculture and Environmental Protection
          Agency sources, such as rural Clean Water Program,  Clean Lakes
          Program, and ASCS special projects.

     Legislation passed in 1971 enabled locally-elected soil  conservation
district commissioners to establish soil loss limits for the  State's nearly
1,500 soil types.  The legislation established a procedure through which
adjacent property owners could file sediment damage complaints.   The district's
administrative order, subsequent court order, and penalty provisions for
handling soil loss complaints have been upheld by the Iowa Supreme Court.
Amending legislation passed in 1980 strengthens the role of soil conservation
district commissioners by enabling them to take their own initiative in
resolving excessive erosion problems without first receiving  a complaint.

     Program development and implementation has been accomplished by working
with a local leadership structure of 500 soil conservation district
commissioners in Iowa's 100 soil conservation districts, with programs
oriented to soil erosion control, and through 162 conservancy district
advisory committee members, who are developing programs oriented to water
management in the State's six major river basins.
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             Agricultural Land Use Water Quality Interaction:
     Problems Abatement, Project Monitoring,  and Monitoring Strategies

                             Dr. Jochen Kuhner


     To assist the RCWP, arrangements were made with Meta Systems to conduct
a relatively small study of the interaction of agricultural activities and
water quality.  The study examined 1) the relationship between agricultural
land uses and pollutant production, 2) the relationship between management
practices and pollution abatement, 3) criteria for selecting projects, 4)
problems involved in monitoring these projects, and 5) strategies for
handling these problems.  The results are provided in "Agricultural Land Use
Water Quality Interaction:  Problem Abatement, Problem Monitoring, and
Monitoring Strategies," available from EPA's Rural Nonpoint Source Section.

     Three tasks were addressed:

     •    General categorization of agriculturally related NPS pollution
          problems which affect various receiving waters, and  outlining of
          potential remedies through modification of practices and introduction
          of new practices and/or practice combinations.

     •    Discussion of the requirements, method, and limitations of
          individual project monitoring.

     •    Consideration of the process/strategy of selecting projects for
          detailed monitoring/evaluation (M/E) across the United States
          under the Rural Clean Water Program.

     The basic idea underlying the report was that potential remedial actions
on the land must be geared to existing water quality (WQ) problems.  Thus
only those agricultural land uses and practices that appear to cause WQ
problems should be modified, and the degree of modification or the intro-
duction of new practices must be determined by needed water quality improve-
ments.  This necessitates a "2-track" system for technical evaluation
(Figure 1).  First, after the water quality problem and its indicators have
been described, the sources of the problem must be detected and the potential
modifications of the pollutant load through measures analyzed.  Second, the
desirable water quality must be identified and the reduction in pollutant
input necessary to achieve the water quality goal computed (including possible
instream measures).  Third, the two tracks must be compared in order to
determine which measures are capable of reducing the input load so that
the water quality goals are met.  Whether the measures are implementable
must finally be determined in socio-economic and institutional terms.  This
scheme requires the identification of cause-effect relationships, the
analysis of the pathways of pollutants, and the gearing up of  monitoring/
                                    94

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evaluation efforts, after preliminary analysis, to the particular water
quality problem and its land/water setting.

     In discussing the problems in selecting and monitoring RCWP and/or
other agricultural pollution control projects, the consultants found
several problems for consideration.

     Monitoring Requirements:

     c    Prior to setting up a monitoring program, it is essential to
          chart the pathways that pollutants take to waterways.

     •    Assess lab capabilities so that handling too many samples does
          not become a problem.

     e    Managers should not shy away from spending time and money on
          selecting a good monitoring program, considering their importance
          to a successful management project.

     •    Quality assurance programs may also be needed.

     Cautions in Selecting Intensive Monitoring Projects:

     ®    The value of historical data on a given project area may be
          limited particularly for approving a project.  It doesn't explain
          the cause/effect relationship in selecting BMPs, and may not
          address current conditions.

     •    Avoid selecting projects for intensive monitoring which have
          mixed land uses.

     •    Minimize the number of farms in the study area since each farmer
          must be contacted and dealt with.

     •    Avoid having more than one drainage basin in a project area.
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          State Implementation of Agricultural Nonpoint Programs

                             Robert C.  Weaver
     This is a report of preliminary findings of a review of State
agricultural nonpoint source programs developed under Section 208, Clean
Water Act.  The review was conducted by Harbridge House Inc., for the
Water Planning Division of the U.S.  Environmental Protection Agency.   The
purpose of the review was to provide information to EPA so that it could
examine program nonpoint programs.  All States were interviewed and most
reported that agricultural nonpoint  pollution is at least a significant
nonpoint problem.

Implementation Methods

     While most States have adopted  a voluntary approach, 46 indicated
that State water pollution abatement law extended to agricultural nonpoint
sources.  Few indicated that such authority would be used unless sources
were pinpointed and harm demonstrated.

     Almost all States have adopted  Statewide education and technical
assistance elements as cornerstones  of their voluntary program.  But  the
number of States using more direct methods is markedly lower:  15 States
have adopted and are implementing some form of State funded cost-sharing
to assist installation of conservation practices; 11 States have adopted
an active regulatory approach requiring in many cases enforceable conser-
vation plans or use of conservation  practices.

Implementation Status

     Forty-two States indicated that some implementation of agricultural
programs had begun.  Many of these States are relying on continuation of
current technical assistance efforts by the Soil Conservation Service.
Another key statistic is that 34 States have identified and ranked priority
or critical problem areas, and it is in these areas where the greatest
effort to encourage the adoption of  conservation measures will occur.

     The survey indicated that:

     •    Most States rely on local  soil conservation districts as the
          primary implementing agency.  Yet these districts lack profession-
          al staff and financial resources to do the job.  At least 2,133
          additional technicians are needed, estimated in part by the
          National Association of Conservation Districts.

     •    Nearly 43 percent of the States said that they have no estimate
          of State or district personnel needed for implementation.
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•    Finally, most States confirmed that use of conservation practices
     will depend on the level of Federal cost-sharing.  Increased
     levels may in some cases ease opposition to State regulatory
     programs.

Key questions which remain:

•    What are the impacts of plan implementation on the taxpayer and
     on State and local governments?

•    Will there be a federal commitment to cost-sharing beyond an
     experimental program?  Will there be a larger program as written
     in the Clean Water Act or will there be a clear message to the
     States to find their own answers?

•    What incentives other than cost-sharing are available?

•    From where will additional resources come for staff needs,
     particularly for the conservation districts?

•    How will federal programs and requirements mesh with State and
     local programs?
                               97

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GROUND WATER PROTECTION PROGRAM
              99

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                     Ground Water Quality Protection Program
SESSION 1:  Consultant Seminar
            Consultant Seminar
Jerry Kotas, Moderator--

David Miller                 102
SESSION 2:  Ground Water Protection Programs

            Cape Cod Ground Water Protection
            Program

            Statewide Ground Water Protection
            Plan
Charles Rossoll, Moderator

Paula Magnuson               103
Mark Possidento
105
SESSION 3:  Managing Irrigation
            Irrigation Scheduling to Reduce
            Nitrate Contamination of Ground Water
Larry Ferguson, Moderator

Larry Ferguson               107
            Irrigation Tail Water Disposal in Idaho    Kenneth Dunn
                             108
SESSION 4:  Legal Issues in Ground Water Management

            Legal and Institutional Issues at the
            State and Local Levels
Jerry Kotas, Moderator

Edward Selig
109
SESSION 5:  State Ground Water Protection Programs

            Development and Implementation of the
            New Jersey Statewide Ground Water
            Management Program
Anthony Conetta, Moderator

Marwan M. Sadat              Hi
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           Development of a Comprehensive Ground
           Water Remedial and Protection
           Strategy for Michigan
Andrew Hogarth
113
SESSION 6:  Ground Water Protection in the
           Southwest

           New Mexico Ground Water Regulation-
           An Overview

           Development of a Ground Water
           Protection Program  in  the Globe/
           Miami Copper Mining Area, Arizona
Roger Hartung, Moderator
Douglas Schneider            115
Dean Moss                    116
SESSION  7:  Summary Session
Jerry Kotas, Moderator
           Ground Water Protection:  A
           Summary
                             118
                                         101

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SESSION 1 -- JERRY KOTAS, MODERATOR
                                      Consultant Seminar

                                         David Miller


             In order for 208 ground water prototype projects to be successful,
        several problems must be addressed:

             e    The levels of data on which planning decisions should be based
                  must be decided.

             o    A system must be found to rank the severity of ground water
                  problems on a State or national level.

             »    Standards for surface water quality may be ineffective in
                  managing ground water because geology is highly variable from
                  area to area.

             •    There are no quick, effective and low-cost solutions and there-
                  fore no quick evaluations of management practices.

             •    Highly technical ground water expertise is lacking.

             Solution of a ground water problem requires:

             •    careful collection of the right data over a sometimes lengthy,
                  period of time, and,

             •    a good understanding of the ground water flow system before
                  classifying land uses to control pollution.  Ground water is much
                  more vulnerable to polluting land uses in recharge zones than in
                  discharge zones.

             The speaker referred to planning approaches taken on Long Island as
        examples.  Long Island ground water supplies have become polluted due to
        population pressure and broad use of septic systems. The problem was not
        noticed because only high quality deep water supplies were tested and these
        are now running out.

             Example 1:  Large recharge basins for stormwater runoff were built to
        return freshwater to the aquifer and prevent saltwater intrusion.  However,
        better data collection could have revealed that saltwater intrusion was
        not really a problem and could have prevented ground water pollution from
        poor quality stormwater.
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         Example 2:  Because septic systems were  thought  to  cause  nitrate
    contamination of ground water, central sewage treatment  plants and
    collector systems were built.  Too  late,  farming was  discovered to be  the
    cause.  One large treatment plant built to protect  groundwater was built
    in the wrong place, serving a ground water discharge  rather  than a re-
    charge area.  Not only has ground water been  used consumptively leading
    to dried-up streams in the discharged area, but the recharge area (where
    the problem originated) was not protected.

         The speaker described the 208  approach.   The existing monitoring  system
    was modified to get more useful data.  This data is used to  define hydro-
    geologic zones for:

         •    protecting high quality areas,

         e    "writing off" extremely degraded areas, and

         e    designating ground water  discharge  areas  capable of  handling
              uses such as landfills with minimal damage  to  ground water quality.
SESSION 2  -- CHARLES ROSSOLL, MODERATOR
                       Cape Cod Ground Water Protection Program

                                     Paula Magnuson
         The ground water protection  efforts on Cape Cod demonstrate that much
     can be accomplished at the  local  level with little reliance on direction
     or funds from the state or  EPA.   The geology of Cape Cod is glacial --
     consisting of glacial moraines, outwash plains, and kettle ponds.  The
     water table is shallow, with a maximum depth of 400 feet in the middle of
     the Cape.  Saltwater intrusion is not a major problem, since  it only occurs
     in a limited way on the outer Cape.  Sewage is treated primarily through
     septic systems, with a few  small  areas sewered.  Most wells are in the
     center of the Cape.
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     With the exception of a State law providing some protection within
a 400 foot radius of wells, the State of Massachusetts has not taken an
active role in ground water protection.  Because of the number of small
political entities on the Cape, comprehensive solutions will ultimately
involve the creation of various inter-municipal districts.  The major
sources of ground water pollution are:  1)  landfills (many of which are
in the center of the Cape near major wells),  2) exposed road salt stock-
piles, and 3) the storage of chemicals used by light industries which,
because of their small volume, may not be covered by State and Federal
toxic or hazardous waste programs.

     Major recommendations of the 208 Water Quality Management plan include
exercise of local authority to protect water supply recharge areas and to
control special nonpoint sources.  The plan presents a methodology for
identifying primary well recharge areas on the basis of well capacity and
estimated recharge rates.  Traditional hydrologic approaches to recharge
area definition is not useful in the area since the entire land mass is
permeable and recharges the ground water.  The plan calls for regional
planning and technical assistance, with periodic review of the need for
stronger regional authority.

     The Cape Cod Planning and Economic Development Commission (CCPEDC)
has provided assistance to the towns in protecting the quality of their
ground water supplies.  CCPEDC has identified recharge areas for existing
and potential wells and then developed zoning maps for seven towns to protect
them.  Throughout this effort CCPEDC has worked closely with the local
boards of health which in many cases will administer the zoning ordinances,
once passed.  The Commission has also helped towns to develop ordinances
regulating the underground storage of fuel and chemicals.  So far three
towns have passed such ordinances.

     CCPEDC's work with the town of Bourne illustrates its approach to
protecting ground water quality.  CCPEDC made a determination of the re-
charge area for the town's water supplies.  In order to do this, a USGS
system of recharge area identification was used.  Well pumping capacity
and up-gradient inflow were estimated.  An attempt was made to be as in-
clusive as possible.  Once the recharge area was defined, watershed pro-
tection district zoning was imposed as an overlay to existing zoning.
This additional zoning included some operational factors covering such
priorities as storage of toxic chemicals.  It also included a limit on
the amount of sewage discharged into the ground, borrowed from a nitrate
loading formula used on Long Island.  The town of Bourne adopted the
whole regulatory package recommended by CCPEDC.  In other towns CCPEDC
recommended minimum lot size zoning as well, as a means of protecting
ground water from septic systems.
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     The speaker concluded that ground water quality can be protected
effectively through initiative at the local level.  Local governments
cannot always rely on EPA for funding.  If necessary, they will be able
to come up with the funds necessary for ground water protection.  CCPEDC,
once self-sufficient financially, may be able to provide high quality
assistance to the towns on the Cape for ground water protection for as
little as $60,000 per year.
                    Statewide Ground Water Protection Plan

                                 Mark Possidento
     The Connecticut Areawide Waste Treatment Planning Board, which is
 separate from the State Water Quality Agency, administers the Statewide
 208 program.  The Board distributes 208 funds to 15 regional planning
 agencies for areawide planning.  Since Connecticut began its 208 planning
 later than most States, the control of nonpoint source pollution has always
 been the focus of the program.  Perhaps that is why Connecticut has made
 the protection of ground water from nonpoint source pollution a priority
 earlier than most other States.  The elements of the Connecticut 208
 program for ground water protection follow.

 Goals

     The program focuses on aquifers needed for public water supply,
 usually those with stratified drift in stream valleys.  The aquifers are
 protected by local land use regulations.

 Ground Water Program Development

     Contamination sources and sites were  assessed Statewide.  While ground
 water quality is mostly good, problems are caused by waste disposal sites,
 transport of fuels, land application of chemicals, road salts, and septic
 systems.

     Categories of aquifer needs for public water supply were identified:
 aquifers for current public water supply,  aquifers for future use, and
 aquifers with potential but no immediate use planned.
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     Recharge areas were classified as:  primary (located directly over
an aquifer), secondary, (in upland areas adjacent to the aquifer), and
tertiary, (in drainage areas upstream of the aquifer).  The first two
areas are considered direct recharge areas, and the third is considered
indirect.  The program recommends that only direct recharge areas be
protected.

     A mechanism for local aquifer protection was chosen, that is, pro-
tecting recharge areas through local zoning ordinances.  The Statewide
planning agency developed a model zoning ordinance which prohibits solid
waste disposal, septage disposal, road salt storage, underground storage
of fuels, and industrial or commercial enterprises handling hazardous
wastes.  The model ordinance limits residential development to about one
acre per household and limits agricultural activities to specified best
management practices.

Implementation

     This is a voluntary program.  The Statewide planning agency approaches
a town and  explains the importance of protecting ground water recharge
areas.  The town then identifies water supply and protection needs.  Then
the town develops and implements zoning regulations which are incorporated
into its plan of development.

Limitations

     Sometimes the quality of ground water for one town depends on land
use activities in another town up-gradient which may not be willing to
implement controls.  Also there  is a lack of information on the degree to
which residential development affects ground water quality.  One part of
the northwestern area of the State with a large recharge area needs more
recharge modeling before effective controls can be applied.  So far, out
of about  100 towns located in critical recharge areas, 15 towns have been
approached  by the Statewide planning agency about the possibility of de-
veloping  controls.  To date, two of these towns have  adopted zoning
ordinances  similar to  the model  ordinance.
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SESSION 3 -- LARRY FERGUSON, MODERATOR


          Irrigation Scheduling to  Reduce  Nitrate  Contamination  of Ground  Water

                                     Larry Ferguson


           High nitrates have been  discovered  in the  ground  water  in  the
      vicinity of Grand Island, Hall County, Nebraska,  the  location of the
      project.  It is believed the  nitrates are a  result  of  the  application  of
      nitrogen fertilizer with irrigation  in a corn-raising  area with highly
      permeable soils and a shallow aquifer.   The  project involves reducing
      the amount of fertilizer applied  without reducing crop production.   The
      high-nitrate ground water is  pumped  from the aquifer and placed on the
      land, percolates through the  soil, and returns  to the  aquifer with reduced
      nitrate levels.  A nominal  amount of nitrogen fertilizer is  added to the
      water.  Three steps are involved  in  this process:   1)  soil analysis  to
      provide an index to nutrients in  order to achieve the  maximum crop yield
      without excessive fertilization,  2)  irrigation  well monitoring  to analyze
      for nitrogen and other agricultural  chemicals,  and  3)  irrigation scheduling
      which allows enough water for the plants without  excessive percolation
      and leaching.

           Agriculture Extension  Specialists are working  with the  farmers  to
      implement irrigation water  management and nitrate management.   A cost-
      sharing program has been established to  encourage use  of BMPs.   Public
      meetings have been held, a  newsletter published,  and audiovisual materials
      developed.  A number of local and national agencies have been involved:
      USDA, ASCS, SCS, FHA, EPA,  University of Nebraska,  Cooperative  Extension
      Service, several resource districts,  etc.  One  reason  for  the success  of
      this project has been the building of a  wide base of support.   There are
      now 11,000 acres signed up  this year for involvement in the  project.

           The 208 Ground Water Prototype  is a part of  the whole project.  It
      supports an education and information program,  and  an  intensive monitoring
      program which includes three  levels:   1) 65  irrigation monitoring wells,
      2) concentrations of wells  in high nitrate and  low  nitrate areas and in
      areas where BMPs are applied  and  not applied, and 3) wells around tail
      water re-use pits.
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                   Irrigation Tail Water Disposal in Idaho

                                Kenneth Dunn


     Idaho presently has the legislative authority to regulate the
quantity of ground water pumped.  Idaho is a conservative State where
regulation is not readily accepted.   The State does, however, have
diversion control authority for ground water and well construction re-
quirements.  The Department of Water Resources, the agency designated
to handle ground water, recently adopted rules and regulations for
the disposal of wastes into aquifers.

     The Snake Plain aquifer is a large aquifer, 11,000 square miles, with
good water quality.  It is up to 7,000 feet thick and transfers water
readily.  The aquifer needs protection.  The State's approach has been to adopt
rules and regulations.  Although the statutory authority has existed since 1971,
it was not until nine years later that regulations were formally adopted.
These regulations state that any water injected into an aquifer must be
"of drinking water quality; any water injected above an aquifer must reach
drinking water quality before it enters the aquifer; wells must be sealed
and cased, and if new drinking water wells are installed, dischargers
must upgrade their operation to protect drinking water.

     The 208 ground water prototype project will examine the alternatives
to irrigation tail water disposal.
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SESSION 4 -- JERRY KOTAS, MODERATOR


             Legal and  Institutional  Issues  at  the  State  and  Local  Levels

                                        Edward Selig


          The management requirements of ground water  and surface water are
     very different.  Surface water management  has  a long legal  history,
     particularly for navigable waters.   Ground water  law is  not nearly so
     extensive, and ground water protection  has typically been associated
     with overlying land uses.  The States have,  to date,  been responsible
     for ground water regulation, focusing on not endangering drinking  water.
     The Federal role in ground water management has not  been legislated, but
     several laws now on the books provide a fragmented approach--working on
     a source by source basis.  The WQM Program does not  yet  contemplate
     comprehensive ground water planning, but the signals may be changing.
     Serious concern has been voiced  that EPA will  ram ground water management
     down the throats of State and local government.  The Federal level must
     recognize that States will "call the tune" with respect  to  ground  water
     protection, particularly program implementation.

          The management problem can  be divided in two:

          •  What do we do about ground water already  polluted?

          •  What do we do about future threats to ground water?

          Two areas of  law address present ground water issues.  The first is
      common or tort law which deals with issues of nuisance,  strict liability,
      and negligence.  These  issues may create a much bigger incentive to
      dischargers to comply with pollution standards than  any  regulation.  Many
      cases are working  their way through the courts which will have a big impact
      on ground water protection.  Who is responsible for  pollution  which developed
      in spite of state-of-the-art controls twenty years ago?  How do we determine
      responsibility when multiple sources cause damages?   How do we determine injury?
      For example, if  1  ppb benzene in a well leads  to  its closing,  what is the  damage
      if no one is hurt? How do we prove causality? All  these questions can have
      far-reaching implications.

          The second  legal area is water law.   Five major water  rights  systems
      are relevant with  respect to ground water:

          Unrestricted  Use -- one owns all the  water under his or her land,
     and can use it as  desired as long as it isn't wasted; effects  on neighbors
     do not matter.
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     Riparian Rights -- overlying land owners have rights to reason-
able use of underlying water as long as downstream or downflow users
are not unreasonably affected.

     Appropriated Rights -- "first in time; first in right;" prior
users have right to ground water (not just from beneath their lands) for
beneficial uses; priority rights can sometimes be bought and sold.

     Correlative Rights -- rule applied in time of scarcity for cutback
management to ensure priority uses (e.g., California).

     Modern Permit Systems — combinations of the preceding used to
issue permits for users.

     Within the legal structure, there are many overlaps, questions, and
unknowns.  The legal problems resulting from ground water/surface water
interrelationships, for example, are still not understood well enough to
manage.  Do riparian owners have a right to clean ground water after it
has been contaminated?  If a polluting landfill is ordered to pump its
leachate, what are the rights of well owners downstream whose wells are
drying up?

     A single integrated system is needed to manage both water quality and
quantity, that is, a means to reasonably control withdrawals and ensure
clean water.  In addition, limited zones of contamination may be unavail-
able.  Some aquifers or parts of aquifers may be "written off" and the
migration of their contaminants controlled.

     For preventing future ground water problems, several tools may be
needed.  Specific technical controls can be developed on a source by source
basis.  The Resource Conservation and Recovery Act will also creat pressure
to close open dumps and ensure the safety of others.   These efforts can be
limited, however, by vague, bad, or unenforced regulations, understaffing,
too many sources, and unidentifiable sources, etc.

     Ground water standards are one possibility for aquifer protection.
Hydrogeologic factors, however, may make meaningful standards impossible.
Standards may also allow aquifers to be polluted to higher levels.

     Standards developed for overlying land uses are a more sensible and
easily-implement approach.  We must ask what we are using the ground water
for now and in the future in order to set control measures.  State and
local governments are key factors because they determine land use.  An
interesting project is underway in Florida where water quality districts
are being created to protect ground water.  Dade County has a "cone of
influence ordinance" which specifies variable controls depending on
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       distance from wells measured in days.  For the most part, State and local
       governments are lax or complacent in the attitudes toward ground water
       protection.  A strong public education is needed to get them moving.
SESSION 5 -- ANTHONY CONETTA, MODERATOR
                 Development and Implementation of the New Jersey Statewide
                              Ground Water Management Program

                                    Dr. Marwan M. Sadat
            Numerous instances of loss of domestic water supplies have caused
       the Department of Environmental Protection (DEP) to recognize the serious
       ground water situation.  The Bureau of Ground Water Management (BGWM),
       with about 25 geologists and hydrologists works to isolate pollution
       sources, and recommends containment methods.   BGWM hopes to stop managing
       giound water problems on a "crisis by crisis" basis by expanding its
       number of employees.

            The 300 or more landfills in New Jersey are actually dumps which
       should be regulated by RCRA but are not.  Each landfill contributes about
       600,000 gallons to the ground water each year, or the equivalent of
       32,000 gallons per day per acre of raw domestic sewage plus hazardous
       material.  Ineffective Solid Waste Management Act Regulations have been
       on the books since 1972 but officials feel that only a discharge elimination
       system will force operators of landfills to comply.

            Ground water discharge permits currently require compliance with:

                 •    ground water discharge effluent standards,

                 •    ground water quality standards.

            A ground water management program should include:

                 •    ground water standards,
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          e    pollution control permit program regulations for discharges,

          e    subsurface sewage disposal regulations,

          e    development of permit process methodology,

          •    publication of guidelines for spray irrigation, percolation
               lagoons, landfills, sewage and septage land disposal,
               petroleum sludges.

          ©    development of computerized data base monitoring systems
               and trend analyses,

          »    development of area specific siting criteria, and

          •    development of a model program on anti-degradation.

     The State believes that ground water quality standards are essential
to the permit system and that permit conditions must be enforceable.
Computerized data bases are important to back up a multitude of monitoring
stations.  The initial prototype program should issue some 50 permits by
the end of 1980.   Results will be evaluated after a reasonable time.

     The New Jersey permit system differs from the Federal system because
it requires two steps:

     1)  a discharge allocation certificate (DAG) for 18 months,

     2)  a permit to operate after the facility is constructed and meets the
         mandates of the DAC.

     The State is emphasizing protection of certain aquifers, especially
the Pine Barrens and aquifer recharge zones in Middlesex County.
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            Development of a Comprehensive Ground Water Remedial
                    and Protection Strategy for Michigan

                               Andrew Hogarth


     Little attention has been given to ground water quality in Michigan
because of abundant and usable surface supplies.  The control that exists
has been in the form of the NPDES permit program, and fill licensing, a
computerized monitoring program, and a discharge permit program.  However,
over 250 contaminated ground water sites have been uncovered forcing the
State to take a strong enforcement posture.  About $17 million has been
spent in response to date.

     Among major ground water contaminants are hazardous chemicals, pri-
marily chlorinated hydrocarbon residuals.  The Hooker Chemical Company in
Montague, Michigan was sued for discharging these residuals for 20 years.

     The Michigan Department of Natural Resources (DNR) has until now
involved itself in "crisis management" and priorities have not always been
properly addressed.  Politics often interfere with rational decisions, and
resources for cleanup are woefully inadequate.  It is hoped that the
continuing 208 planning program will generate solutions to these problems
and use both remedial and preventive action.  Its objectives are:

     •    documentation of current ground water management systems,

     •    determination of needed resources,

     •    development of thorough ground water quality background/information,

     •    evaluation of the current system's ability to prevent ground
          water contamination,

     •    development of alternative ground water protection mechanisms,

     •    use of "sample" case  contamination studies and  evaluation  of   those
          yielding maximum, beneficial, remedial results,

     •    coordination of numerous State agencies and  definition of  their re-
          sponsibilities  (the DNR alone consists of three bureaus  and seven
          divisions) through written interdepartmental agreements.

     The kinds of  ground water  issues  to be addressed  fall  in  five basic
categories:  remedial action, pollution control, resources  available,
information base(s) needed, and program management.
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     These are further defined by the DNP as:

Remedial

     «    problem prioritization

     e    evaluate criteria for adequate cleanup

     •    examine funding mechanisms

Pollution Control

     •    ground water standards (the State currently has ground water
          "rules")

     •    hydrogeologic survey

     •    land use controls

     e    legislative needs

     •    alternative approaches

Resources Available

     •    manpower needs (critical—now have about 200 hydrogeologic
          projects being conducted in the State with only about 10
          geologists-hydrogeologists to oversee all projects)

     •    funding for ground water data systems critically in shortfall

Information Base(s) Needs

     »    resource definition

     e    laboratory needs

     •    monitoring needs

     «    assessment of current technology

Program Management

     •    staff training needs--particularly ground water geologists and
          hydrog eolegists
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            •    interagency coordination needs

            •    public information and education

            The Michigan Department of Natural Resources now gives ground water
       protection a very high priority.
SESSION 6 -- ROGER HARTUNG, MODERATOR


                      New Mexico Ground Water Regulation—An Overview

                                       Douglas Schneider


            New Mexico ground water regulations are believed by many to be among
       the most comprehensive in the nation.  The importance of preserving ground
       water quality is clear because the State has a total of 20 billion acre-
       feet of which 4.4 billion are beneficially useful reservoirs.  While
       88 percent of all domestic usage is supplied by ground water, the greatest
       use of ground water is for agricultural purposes.

            The regulations are designed to control discharge onto or below the
       surface of the ground to protect all ground water of the State having a
       concentration of TDS less than 10,000 mg/1 and which is used or may potentially
       be used for domestic and agricultural water supply.  The regulations will
       also protect those segments of surface waters which are gaining because
       of ground water inflow and will allow degradation of ground water up to
       the limit of the standards.

            Two central aspects of the regulation are numerical ground water
       standards and discharges permits.  The regulations require a permit for
       all discharges initiated 120 days after the effective date of the regulations.
       A previously existing discharge must have a permit only if so required by
       the Environmental Improvement Division .  A discharge plan must also be
       submitted which will demonstrate that the proposed discharge will not cause
       ground water quality standards to be violated.  Monitoring must also be
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undertaken to assure that any problem is identified and corrected.  The
method of assuring compliance is left to the discretion of the discharger.

     The State recently completed a comprehensive Surface Impoundment
Assessment funded by EPA.  The assessment revealed 108 cases of suspected
or documented contamination of ground water.  All are from facilities that
existed prior to the implementation of the ground water regulations.  One
significant deficiency in the regulations, however, is the lack of standards
for toxic organic compounds.  The Environmental Improvement Division plans
to use 208 funding to develop numerical standards for selected toxic
substances.
              Development of a Ground Water Protection Program
               in the Globe/Miami Copper Mining Area,  Arizona

                                  Dean Moss
     The Globe/Miami copper mining area is a priority 208 Continuing
Planning project for both the State of Arizona and EPA.

     Arizona is very dependent on ground water supplies  for domestic,
industrial and agricultural needs.  Tucson is currently  totally dependent
on ground water until completion of the Central Arizona  Project (CAP).
However, its completion depends on the development of ground water over-
draft controls because overdraft occurs at an alarming rate.  Water is
used primarily for irrigation, but ground water supplies 60-70 percent of
all domestic use.

     The copper mining industry in the Globe-Miami area  is a basic industry,
fundamental to the state's welfare.  It has a 100 year history of control
by powerful political interests.  All operations of the  industry pollute
both surface water and ground water.  Following precipitation, the pH of
some surface waters is as low as 2.  The intensity and extent of mining
over the last century precludes placing responsibility on any one company.
Copper pollution in ground water has led to abandonment  of many wells and
even to recovery of copper from various wells which formerly supplied
potable water.  Copper plating of pumps and well casings is common.
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     The economy of the Globe/Miami area is totally dependent on the mining
industry and politicians are very reluctant to interfere with current
mining practices.  Because of water ownership and water rights conflicts,
the Central Arizona Association of Governments (CAAG) "208" Areawide Plan
proposed a Mineral Extraction Task Force (METF).  Composed of all key State
agencies and industry representatives, METF formed a committee to develop
a work plan.  EPA, while not completely satisfied with the plan agreed to
go forward with its basic concepts and approaches (so as not to alienate
the mining companies) as long as the plan was to be expanded in the
future.  The plan's key elements are:

     •    definition of needed background information

     0    recognition of need for an independent, experienced, objective
          consultant

     •    setting up of a water sampling network

     e    drilling of additional test wells if needed

     •    fixing of ground water pollution responsibility

     •    development of a management plan incorporating elements of
          initial "208" Areawide plan

     •    enforcement by State following a suggested compliance schedule.

     The State  and CAAG will play key roles in administering the project and
working with  environmental groups and mining companies.  The U.S. Bureau of
Mines will probably contribute around $100,000, and mining companies may
contribute another $150,000.
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SESSION 7 -- JERRY KOTAS, MODERATOR


                             Ground Water Protection:  A Summary


             Summarizing David Miller's remarks from an earlier session,
        Jerry Kotas stressed the importance of understanding ground water flow
        options before planning for controls.  Hydrogeologic zoning must be
        applied in addition to regular zoning.  For example, in ground water re-
        charge areas pollutants may descend straight down and then move laterally,
        running through several aquifers before reaching the surface again.
        Monitoring programs should be designed to answer specific questions, be-
        cause often the wrong data is collected.  Samples obtained from existing
        supply wells can be unreliable because of the mixing of water from
        different origins.  When attempting to prevent or reduce ground water
        pollution, it may take many years to observe the results of various controls.
        For example, it took ten years on Long Island to determine the effects of
        sewering.

             Kotas emphasized that each State must consciously decide how it wants
        to use its ground water resources.  In some situations it may make sense
        to "write off" portions of aquifers and encourage activities detrimental to
        ground water to cluster in those areas.  Also, States may want to use
        various techniques to contain contamination in particular areas.

             The Water Planning Division at EPA is encouraging the development of
        a variety of approaches for ground water management, recognizing that it
        may take years to determine how successful any one approach is at improving
        water quality.  Among these approaches are institutional arrangements,
        specific Best Management Practices (BMPs), and overall management strategies.
        Examples of these approaches have been presented at this conference--
        voluntary arrangements to reduce nitrate levels in Hall County, Nebraska
        and leachate from copper mining operations in the Globe/Miami area of
        Arizona, development of ground water standards in New Mexico, and develop-
        ment of land ordinances in Connecticut and on Cape Cod to protect drinking
        wat er.

             The Water Planning Division is not developing a "model" State ground
        water program to be applied everywhere.  Because hydrogeologic, institution-
        al, and legal situations are extremely diverse, each State must develop its
        own management approach.  The Federal Government will handle the worst
        sources of pollution on a national basis, through such authorities as the
        hazardous waste disposal provisions of Subtitle C of the Resource
        Conservation and Recovery Act.
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     Summarizing Ed Selig's remarks from an earlier session, Kotas
noted the importance of controlling land uses as a means of protecting
ground water quality.  Any legislative or regulatory approaches to
protect ground water quality should be based on ground water flow systems
and the concept of hydrogeological zoning as described by Miller.  State
and local authority to manage ground water quality and quantity should
be extensive, as should such authority for managing surface water quality
and quantity.  Planning agencies should consider carefully how much and
what kind of data is necessary for the development of effective controls
and at what points other agencies and industries can help.

     Kotas stated that all waste containment structures leak, no matter
how carefully constructed and how thick the seemingly impermeable barriers.
Therefore, although we must try to construct containment systems that do
not leak, it is always important to locate them in places where they will
do the least damage when they do leak.  In other words, planners must
always be aware of the ground water flow system when developing controls.

     Dr. Marwan M. Sadat of New Jersey made the point that hazardous waste
should never be placed in the ground.  If above ground when the container
eventually  leaks, it can be repaired and monitored.
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FINANCIAL MANAGEMENT ASSISTANCE PROGRAM
                  121

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                         Financial Management Assistance Program
SESSION 1:  FMAP Case Studies

            Moderator's Remarks

            Introduction to FMAP

            Connecticut Sewer Avoidance
            Program

            Connecticut Sewer Avoidance
            Program
Paul Kraman, Moderator

Paul Kraman                  124

James Murray                 124

John Flynn, Jr.              125


Mark Possidento              125
SESSION 2:  FMAP Case Studies
            Moderator's Remarks
            Wisconsin's Approach to Wasteload
            Allocation and Advanced Waste
            Treatment

            Prove, Utah:  Facilities
            Rationalization Program
Eric Eidsness

Eric Eidsness

Don Theiler
Larry Scully


Homer Chandler
127

127



12D
SESSION 3:  Financial Issues and Approaches
            in Wastewater Facilities Planning

            Panel Discussion
John Petersen, Moderator
John Flynn                   129
John Wander                  130
William Lament               130
James Murray                 131
                                         122

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SESSION 4:   FMAP  Case  Studies
           SSES  and  Regionalization Program:
           the  208 View

           SSES  and  Regionalization Program:
           the  Sewer District View

           Financial Policy Affects Water
           Pollution Control  Costs:  Septic
           Systems  in New Castle County,  Delaware
Eric Eidsness, Moderator

Robert Purcell               132
William H. Mull
Darryl Goehring
Bernard Dworsky
133
134
134
SESSION 5:   FMAP  Case Studies
            King  County,  Washington:   Surface
            Water Management Utility  Program

            Clark County,  Washington  Storm and
            Surface Water Utility Program
William Lament, Moderator

Donovan Tracy                136
John Ostrowski
137
SESSION 6:   Financial  Considerations in
            Faci1i t ies Management

            Panel  Discussion
James Murray, Moderator
John Wander
Keith Dearth
138
139
SESSION 7:   A Framework for the Future
            Panel  Discussion
John Wander, Moderator

Robert Hardaker
John Flynn Jr.
William Lamont
John Petersen
139
139
139
140
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SESSION 1 -- PAUL KRAMAN, MODERATOR
                                     Moderator's Remarks

                                           Paul Kraman
             The Financial Management Assistance Program was created to assist
        WQM agencies with integrating financial, institutional, and technical
        considerations in the development and implementation of water quality
        management plans.

             To date, FMAP has provided management assistance to ten local
        planning programs.  Based on this work, a series of publications called
        "FMAP Tools" have been prepared which present the financial and institutional
        techniques developed.  Various public interest groups will disseminate
        these tools to a primarily non-technical audience.

             In FY 81, additional FMAP projects will be undertaken to deal with
        the financial and institutional aspects of nonpoint source pollution
        problems on agriculture, urban runoff, and ground water.
                                      Introduction to FMAP

                                          James Murray


             FMAP was created to help local officials and WQM agencies implement
        water quality plans.  Financial and institutional considerations are
        often the principal roadblocks to a plan or project's success.

             WQM recommendations must be reflected in local budgets to ensure their
        implementation.  At this level of government, environmental programs must
        compete with many other public needs.  With inflation, it has become
        increasingly difficult for  local revenues to meet the demand for public
        services.  Local financial  decisions tend to be short-term and attuned to
        local politics.  Implementation is not a sure bet even when a proposal is
        cost-effective.  Local officials must be shown that it is clearly beneficial
        and affordable.
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     The FMAP experience has shown that public officials need to be more
involved in the early stages of WQM planning.  Consideration of financial/
institutional factors should be at an increasing level of detail as the
planning progresses.
                     Connecticut Sewer Avoidance Program

                               John Flynn, Jr.


     Septic systems can be effective if properly planned and maintained.
Based on the Connecticut experience, an FMAP Tool was developed to help
local officials and managers compare conventional and alternative waste-
water systems.  Entitled, Wastewater Treatment Systems:  A User's Guide
to Feasibility Analysis of Conventional and Alternative Systems, this
tool briefly presents institutional alternatives for managing wastewater
systems, including the allocation of responsibilities for system approval,
operation, maintenance, and regulation.  It also identifies a range of
costs assuming different levels of State and Federal funding.  Estimated
costs include those for system repair, inspection, pumpout, replacement,
septage disposal, and ground water monitoring.
                     Connecticut Sewer Avoidance Program

                             Mark C. Possidento
     In January of 1978, the Connecticut General Assembly passed legisla-
tion enabling communities to plan for the avoidance of sewers.  The Sewer
Avoidance Program (SAP) allows local jurisdictions to create a Water
Pollution Control Authority and to prepare an "Executive Water Pollution
Control Plan" which evaluates the feasibility of alternative wastewater
treatment systems for a town.

     The water pollution control planning which occurs in the Connecticut
SAP is not the same as in a 201 Facilities Plan.  The results of the SAP
are general plans to make future wastewater treatment systems consistent
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with planned land use patterns.  If sewers are inconsistent with the
desired land use plans, then the town determines how to avoid sewers in
those areas where they are inappropriate.  The SAP does not require the
same detailed level of analysis as a 201 Facilities Plan and is not
subject to the same regulations.

     The thrust of the Connecticut SAP, a voluntary program, is that land
use planning should precede rather than follow the construction of
specific wastewater treatment systems.  Each participating town, therefore,
must develop a water pollution control plan which supports and is consis-
tent with the land use plans for the town.

     To assist towns in the analysis of alternative systems a "Manual" was
prepared by Touche-Ross, Inc., as part of an FMAP project which provides
a set of procedures for making such an evaluation.  This guide assists
planners and officials in analyzing alternative wastewater treatment
systems in terms of their technical, institutional and financial feasibility.

     Because the scope of this manual is much more limited than the scope
of a 201 Facilities Plan, it is an effective tool for both planners and
decision-makers in providing:

     •    a method which makes financial comparisons between septic systems
          and sewers meaningful, even allowing for the capital cost of
          replacing failed septic systems;

     •    a systematic approach to making the institutional decisions
          regarding a septic system management program;

     «    a step-by-step, fill-in-the-blanks workbook approach to financial
          analysis which breaks complex analysis down into elementary steps
          and ensures that all cost components have been considered.
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SESSION 2 -- ERIC EIDSNESS, MODERATOR
                                    Moderator's Remarks

                                       Eric Eidsness
            The speaker opened this session with a brief statement showing that
       full consideration should be given to a variety of technical, financial,
       and institutional alternatives in meeting stream standards based on
       wasteload allocations.  He also explained that economic, financial, and
       management elements play an important role in evaluating regionalization
       alternatives.
                       Wisconsin's Approach to Wasteland Allocation
                               and Advanced Waste Treatment

                               Don Theiler and Larry Scully


            Don Theiler discussed the technical alternatives to meeting stream
       standards which are being examined in Wisconsin's Fox Valley area.  Since
       1972, Fox Valley's ten paper mills have installed expensive waste treatment
       equipment, and along with the area's four cities, have complied with the
       Clean Water Act.  By 1977, they had reduced the amount of organic waste
       they had dumped into the river by 90 percent.  Even so, dissolved oxygen
       levels still do not meet the water quality standards of the Clean Water Act,

            Rather than have the mills cut oxygen by 50 percent and thereby force
       some out of business, alternatives were first examined to conventional
       treatment.  These include instream aeration, flow-related and temperature
       related permits, rolling averages, cluster discharge, and flow regulation.
       With help from FMAP, compliance cost estimates were developed for each
       alternative.  The results indicate that the required treatment levels can
       be met with the alternatives at a cost of $11 to $19 million per year less
       than that for conventional treatment.

            Theiler explained that the burden lies with the local public agencies
       and industries along the Fox River to develop an intergovernmental system
       which can operate any or all of the technical alternatives.
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     Larry Scully's presentation outlined the methods used in comparing
costs of the various technical alternatives.   He discussed a step-by-step
financial management process which should parallel the technical waste-
load allocation process.

     e    For the stream segment, identify municipal and industrial
          dischargers and examine existing costs for water pollution control.

     e    Estimate existing annual costs for  homeowners in each muni-
          cipality, the capability of the municipality to incur more debt,
          and industry's ability to support more control facilities.

     e    Estimate the cost and impact of complying with the proposed
          allocations (base cost).

     e    Assess the economic, technical, and administrative feasibility
          and impact of implementing the base wasteload allocations.

     ©    Develop compliance cost estimates for discharges for each
          alternative strategy, as well as estimates of expected impacts
          and the dischargers' ability to pay.

     «    Select a cost-effective regulatory  strategy considering:
          reliability, environmental impacts, economic impacts,  energy
          impacts, enforcement, and administration.

     •    Develop implementation plan for each affected municipality and
          industry; prepare financial plan, user costs, debt requirements
          and alternative funding plans.

     e    Examine alternative sources of funding for industry and municipality.

     0    Implement the wasteload allocation  process.
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              Provo, Utah:  Facilities Rationalization Program

                                 Homer Chandler
     The speaker explained in detail the complex technical issues which
ultimately led to the failure of the sewage system regionalization effort
in Provo, Utah.  In the first place, there was no agreement on the stream
standards which the communities would have to meet.  This issue is obvi-
ously crucial to determining comparative treatment costs, but the parties
involved could not agree.  There was also some variation in the way cost-
effectiveness analyses were conducted.  As a result, the analyses produced
contradictory results.

     The speaker pointed out the apparent economic development benefits
tied to a sewage system's available capacity.  In addition, communities
may have identity problems which arise from contracting with another
community for sewage treatment service.

     Chandler concluded by stressing the need to agree on both stream
standards and cost-effectiveness anlysis standard.  Most importantly, local
elected officials must be kept up-to-date through each and every step in
the regionalization analysis and evaluation.
SESSION 3 -- JOHN PETERSEN, MODERATOR
                     Financial Issues and Approaches in
                       Wastewater Facilities Planning


     This session provided a discussion of the financial issues which
can affect wastewater facilities planning and the approaches available
for dealing with them.  The participants, as a panel, reviewed their
individual experiences in trying to integrate technical plans, financial
plans, and local budgets.

     John Flynn identified three major constraints to effective imple-
mentation of a WQM plan.

     Technical Constraints:  What tasks must be physically carried out to
solve a given water quality problem?  What information is needed?
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Financial Constraints:  From where will the money come?  Who will pay?
Are there equity issues involved?  Will the plan or project create
cash flow problems?

Institutional Constraints:  What level of government is best suited to
do the job?  How will the new programs mesh with existing government
agencies and responsibilities?  How can several jurisdictions be brought
together to handle a joint problem?

     John Wander cited Industrial Cost Recovery and user charges as
examples of how technical and financial analyses have been successfully
integrated.  In both these cases, costs and charges have been developed
based on levels of collection and treatment.  For ICR, calculations were
needed of how much and what kinds of wastes industries discharged into
public sewer systems.  Based on this, charges were developed based on
an individual industry's proportionate share of public treatment costs.
Thus, the problem of assessing a pollution problem and paying for its
control were tied together.

     William Lamont presented a list of ten planning issues which played
an important part in all the FMAP projects.

     •    Effectively managing the planning process.

     o    Involving policy makers early in the process.

     •    Involving the public.

     «    Establishing the need for  action.

     •    Balancing the scope of  the analysis.

     •    Integrating  the various technical analyses  conducted.

     •    Emphasizing  simple  analytical methods.

     •    Disclosing  financial  information as  soon  as  possible.

     •    Stressing  financial  equity.

     •    Assigning  institutional responsibilities.
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     James Murray concluded the discussion with an explanation of the
elements of a good financial analysis.  These include:

     •    Program Cost Analysis—identifying program costs for each
          affected institution by type of activity (capital, construction,
          administration, etc.) and projecting them for five years or more
          into the future.

     •    Funding Alternatives—identifying available funding sources from
          all levels of government.

     •    Institutional Arrangements — identifying and assessing agencies or
          institutions to implement plans based on their financial
          capabilities.

     e    Financial Plan—assembling a flexible decision-making document
          for achieving implementation; should contain, at a minimum,
          funding or pricing policies, fund sources and mechanisms, identi-
          fication of implementing agencies, and projected costs.

     o    Burden Analysis—determining the ability of the institutions
          involved and individual system users to pay the costs.

     e    Risk Analysis—determining how much unit costs of a project may
          vary if the underlying assumptions, such as inflation or phasing,
          changed; also called sensitivity analysis.

     e    Secondary Impacts—assessing the secondary effects of a project
          or plan which may affect budgets or local institutions;  a new
          interceptor for example, may increase demands for other services.
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SESSION 4 -- ERIC EIDSNESS, MODERATOR
               SSES and Regionalization Program:  the 208 View

                               Robert Purcell
Role of Land-of-Sky Regional Council

     The Council is the designated 208 water quality management planning
agency for North Carolina Region B (Buncombe, Madison, Henderson, and
Transylvania Counties and their municipalities).   Management recommenda-
tions are an important aspect of the 208 Plan for Region B,  in accordance
with EPA management agency designation (MAD) requirements.  In developing
the 208 plan, the Council brought together representatives of the
Metropolitan Sewerage District (MSD) and all owners of collector lines in
Buncombe County.  The jurisdictions agreed at this and later meetings to
study sewer system consolidation, including how to finance rehabilitation.
This study became part of the Council's 208 continuing planning program,
with the Council providing staff and consultant support through its 208
grant and with assistance of EPA's 208 Financial  Management  Assistance
Program (FMAP).  Staff roles have included overall coordination and public
information activities.  The Council, as a neutral party, serves to
facilitate negotiations as well as to provide information.

Implementation of 208 Plan Recommendations

     This study is essential to implementing the  208 plan recommendation
for a coordinated management system for point and nonpoint source control.
A coordinated system requires a workable number of individual agencies
performing specific functions.  A single agency responsible for municipal
sewerage facilities in Buncombe County would be the simplest, most workable
arrangement from a purely management standpoint.   Such an arrangement can
only be achieved, of course, if it is financially and politically acceptable
to all entities concerned.  The sooner acceptable arrangements are achieved
for rehabilitating and maintaining these sewerage facilities, the sooner
exfiltration, bypasses and surcharges can be eliminated, cutting down
greatly on pollution of the French Broad River and its tributaries.

Use of Financial and Management Analyses to Evaluate Alternative Solutions

     Legal, financial, and management analyses have been and continue to be
primary aids for determining what alternatives are acceptable to carry out
the goals of 208 planning.
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         SSES and Regional!zation Program:  the Sewer District View

                               William H. Mull
Background and Overview

     The Metropolitan Sewerage District (MSD) was established in 1962,
under new State legislation, to provide wastewater treatment services
in Buncombe County.  It has a ten member board, appointed by the local
political bodies within the district boundaries.

     The MSD does not own the collector lines connected to its system.
These are owned by local government entities, sanitary districts and
private religious organizations.  As a result, the MSD does not have control
over the maintenance and rehabilitation of the collector lines connected
to its facilities.  The collector system badly needs rehabilitation.
Infiltration and inflow (!§!) are serious problems.  The MSD's sewer
system evaluation  survey (SSES) is determining the extent of I&I.   The
208 program and the Financial Management assistance Program (FMAP)  are
looking at management and financial alternatives to carry out rehabilitation.

Management Issues Related To System Consolidation and Rehabilitation

     Major issues include financial integrity, and ownership of easements
and rights-of-way.

     The MSD is fiscally sound.  To suddenly become responsible for
financing the rehabilitation of collector lines could, however, "bankrupt"
the agency.

     There are questions concerning who owns some of the collector lines,
as well as a lot of unanswered questions concerning easements and rights-
of-way.  To accept ownership of collector lines without clear title to the
lines, easements and rights-of-way could cause grave legal and financial
difficulties for MSD when rehabilitation, replacement or maintenance is
required.

     Other management issues include how decisions would be made for fur-
ther extension of the system if MSD were to own all collector lines.
(Currently the county can build a new sewer line to serve a new subdivision
or industry).
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Insights Gained

     MSD, the Land-of-Sky Regional Council and all sewer collector owners
have been working together for more than a year, developing and analyzing
information.  Each system owner now has a better idea of its share of the
sewer system extension, rehabilitation and maintenance required for the
next twenty years.  Each entity has an idea of how the costs will affect
the average homeowner.

     Sewer rates in the county have been kept artificially low because very
little has been spent for maintenance.  A corrective program will cause a
substantial increase in sewer rates.  Still, the rates could be kept at a
reasonable level compared to other jurisdictions.  Further decision-making
will be aided by knowing more about costs and costs per user.
           Financial Policy Affects Water Pollution Control Costs:
                Septic Systems in New Castle County,  Delaware

                     Darryl Goehring and Bernard Dworsky


     New Castle County has tried to install more equitable pricing  to restore
the basic law of supply and demand in its sewer service program.   Financial
policy affects waste treatment costs.  Non-uniform service charges
distribute costs disproportionately to benefits.  Because of this,  the
demand for services may be greater than they have to be.

     The actual cost for sewer extensions in the county to relieve  failing
septic systems has been estimated at $8,400 per connection.  This figure
did not include the capital cost of interceptor lines or the treatment plant.
It reflected the cost of collectors and trunk lines built specifically for
the sewer extension.  This cost was projected to increase to $11,200 per
connection for fiscal years 1980 through 1982.  By contrast the average
connection fee collected from each homeowner was about $750.  Adding in
$1,000 for a plumber to do the job, the total cost for the homeowner of
connecting to the sewer is about $1,750, far lower than even the estimated
$2,500 to $3,500 needed to rehabilitate the failing system.

     Basically, there were two major problems.  There was a substantial
user charge subsidy of sewer extensions for septic relief projects; and the
cost-effectiveness analysis of relief projects did not give adequate atten-
tion to the full range of alternatives to public sewerage systems.
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     Recommended solutions include:

          •    increasing the connection fee for extensions  to  $3,000
               per connection—which,  added to the $1,000 it costs  for a
               plumber to connect a home to a sewer,  makes the  total  cost
               quite competitive;

          «    changing the connection fee from a front footage charge
               to a flat fee;

          «    maintaining voluntary connection to the sewer except when
               mandatory connections are the only way to make an extension
               financially feasible,

          »    performing cost-effectiveness analyses for each  septic
               relief project involving more than ten homes  or  extension
               costs of more than $8,000.

Note:  The recommendations were adopted by the County Council as an ordinance
       on August 26, 1980.
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SESSION 5 -- WILLIAM LAMONT, MODERATOR


             King County, Washington: A Surface Water Management Utility Program

                                        Donovan Tracy


             A surface water management program for King County, Washington began
        in the early seventies with the completion of an areawide analysis of
        physical needs.  A detailed sub-area basin plan and financial analysis
        followed as a 208 demonstration project.  The comprehensiveness of the
        areawide analysis and the detail of the basin study were brought together
        with the help of the Financial Management Assistance Program (FMAP) to
        provide the best possible financial strategy to implement a countywide
        surface water management program.

             Rapid suburbanization has caused streambank erosion, flooding, and
        a number of water quality problems.  A basin plan for Juanita Creek
        prepared under 208 recommended wetland preservation, stream channelization,
        and a number of non-structural controls.  An original cost estimate which
        was widely mentioned proved much too low upon further analysis.  Detailed
        capital and 0 § M costs were developed for the range of recommendations.

             A revenue program was developed based upon the relative contribution
        to the problem from different land use categories.  Single family equival-
        ents were developed and verified in the field for different land uses
        relative to surface imperviousness.  The original intent to assess all
        property proved not politically viable.  Since revenues could be generated
        from fewer groups, recommendations were scaled down to keep potential costs
        reasonable.

             The program was delayed pending financial analysis.  Some actions
        could have been implemented concurrently.  If basin recommendations were
        extended countywide, the budget impact would be significant.  Activities
        must be subsidized until they can become self-supporting.  The county has
        opted for a phased approach.  Implementation in Juanita Creek Basin is
        being looked at as a demonstration prior to countywide application.
        Potential benefits of the program need to be more clearly articulated to
        achieve public and political support.

             The financial analysis of King County's program has focused princip-
        ally on the questions of "who should pay?" and "how much?"  It was found
        that certain financial parameters had much different implications whether
        applied on a sub-area or on an areawide basis.  After an exhaustive analysis
        of financing the sub-area basin plan, a financial review of the earlier
                                            136

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areawide analysis was undertaken, initially just to check the appropriat-
ness of the sub-area's financial policies for other sub-areas.  Only then
was it discovered that the seemingly fair rate structure developed for
the demonstration sub-areas had profound consequences when applied
countywide.  The financial burden would shift disproportionately to
publically-owned properties and to open space lands and therefore conflict
with other county interests and programs.  In addition, administrative and
other overhead costs continued to plague the sub-area analysis because of
their high proportion of the total service delivery costs (only 34 cents
of each dollar would go toward actual surface water improvements).  It
became apparent that the final matters of the financial program should be
resolved on an areawide basis.  The result has been the development'of a
uniform countywide financial approach which does not sacrifice the merits
of sub-area problem analysis, planning and public involvement.

     Any program to implement nonpoint source pollution control depends
heavily on a defensible financial analysis.  Questions of equity, compat-
ibility with other government objectives, and risks must be painstakingly
addressed.  However, the final question of "is it worth it?" must be left
to those who are elected to decide just such questions.  The planner,
engineer, or financial analyst can only attempt to identify the benefits
of action—something that despite all our tools is still exceedingly
difficult in the area of surface water management and probably nonpoint
source control in general.
    Clark County, Washington:  A Storm and Surface Water Utility Program

                               John Ostrowski
     Support was obtained for a county stormwater management program before
the program was fleshed out.  In particular, an agreement between the City
of Vancouver and Clark County on respective stormwater management responsi-
bilities had not been worked out.  A decision was made to set up a special
public utility despite the lack of public accountability in rate
determination.

     A tight deadline was established to develop a financial program.  FMAP
technical assistance enabled this objective to be achieved.
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             Establishing cleanup/control objectives was initially needed.   Then
        a program to meet these objectives was developed.   In part because
        expected benefits could not be adequately documented, the initial year's
        activities will include implementation of non-structural controls and
        additional analysis of possible capital improvements.

             The financial and institutional arrangements  were developed in view
        of the relative contribution to the problems and anticipated benefit from
        the program.  Institutional flexibility will be necessary as the county
        urbanizes.
SESSION 6 -- JAMES MURRAY, MODERATOR


                      Financial Considerations in Facilities Management
             Jim Murray explained that the purpose of this panel  session was to
        present and discuss the major points at which financial  issues should be
        considered as a small community goes through the facilities planning and
        construction process and to indicate the potential for and limits of the
        use of 201 funds in small alternative waste treatment management.

             John Wander explained that local officials need education and an
        early warning system as they work their way through the  grants process.
        He shared the experience of small communities in Texas,  including problems
        identified by the state agency in dealing with small communities.  He also
        gave details on Texas' efforts to improve the situation,  including prepar-
        ation of a financial issues guide.  It was found that many communities are
        extremely limited in their staffing to deal with complex WQM planning and
        grants programs.  Also, WQM experts should be aware that typical local
        officials only have a limited involvement with water pollution control
        grants problems.

             The success of the WQM effort is dependent on these local officials
        making the right decisions at the right times.
                                            138

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            Keith Dearth stressed the need to educate local officials on the
       potential of small alternative and innovative waste treatment systems.
       He shared some of the financial consequences which have occurred in
       small communities which place the sole reliance on conventional collection
       and treatment systems.

            Dearth briefly reviewed some of the creative and innovative facility
       planning studies which EPA has received.  He noted that local officials
       should be aware that a locally financed non-conventional treatment system
       may be less expensive to develop and manage than a federally-assisted
       conventional system.
SESSION 7 -- JOHN WANDER, MODERATOR


                                  A Framework for the Future
            This wrap-up session focused on the future of the 208 program and FMAP.
       Robert Hardaker presented the Federal perspective and emphasized that
       Congress and OMB have given the entire 208 program a brief period of grace
       in which to prove that WQM programs can be implemented.  Given the prospect
       of increasing fiscal restraints, however, this objective must be accomplished
       with less money.  Therefore, there is a need to maximize successes in
       technology transfer and implementation, FMAP included.

            From the local perspective, William Lament stressed the fact that the
       success of 208 depends largely upon local governments helping other local
       governments.  Documents such as the FMAP publications serve a useful
       function according to Lamont, but the key to implementation is local
       governments following the lead of others, and nothing will prove as
       successful as peer matching.

            John Flynn cited on-site systems as an important emerging issue with
       financial ramifications.  Technical information in this area is rather well
                                          139

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developed according to Flynn, but the institutional and financial
analyses are not yet developed.  Given that septic systems are now being
viewed as an acceptable, indeed desirable, alternative to expensive
central treatment facilities, there is an emerging need to develop pro-
cedures and techniques to compare the cost-effectiveness of central versus
on-site systems.

     Finally, John Petersen discussed the vast amounts of capital being
expended on pollution control and the need to allocate resources cost-
effectively.  In addition, communities must be aware that the Federal
grants program will not continue forever and that long-term financial
analysis must be built into WQM plans to ensure continuing implementation.
                                    140

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FACILITY PLANNING AWT PROGRAM
                                                             I
             141

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                            FACILITY PLANNING AWT PROGRAM
SESSION 1:  National AWT Issues
            AWT Review Process
Carl Myers, Moderator

Myron Tiemens           143
SESSION 2:  Making AWT Decisions

            An Overview for AWT Decision Making

            Use of Models for total Maximum Daily
            Load Projections
Narindar Kumar, Moderator

Ken Young               144

Ron Sharpin             145
SESSION 3:  Making AWT Assessments

            Estuary Assessment, Potomac River

            A Holistic Lake System Assessment
            A Comprehensive PS/NPS River
            System Assessment
Carl Myers, Moderator

John George             145
John Marlar
James S. Kutzman

John Hobrla
146
                                                                                    148
 SESSION  4:  Case  Studies of AWT
             Setting Nutrient  Limits for  the
             Great  Lakes

             Determining  Appropriate Treatment
             Needs  Beyond Secondary

             Kalamazoo  River Study
Narindar Kumar, Moderator

Don Urban               150
 Forest Westall
 Richard  G.  Simms
151
151
                                          142

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SESSION 1  --  CARL MYERS, MODERATOR


                                    AWT Review Process

                                       Myron Tiemens


          The speaker, addressing the Advanced Waste Treatment (AWT) review
     process, emphasized EPA and Congressional concern over the high cost of
     AWT reviews and subsequent reports.  EPA issued policy and procedural
     guidance for reviews of proposed AWT's in March 1979 calling for regional
     review of small projects, as well as Headquarters' review for projects having
     incremental costs more than $1,000,000.  Issues considered during project reviews
     addressed such factors as:

          «    attainability of beneficial stream uses

          9    development of standards criteria

          e    adequacy of water quality analyses upon which effluent limits
               are based

          9    ammonia toxicity of effluent

          •    financial impact of the project upon the affected community

          •    cost effectiveness of facilities planning issues.

          Briefly, past reviews resulted in the examination of 57 projects
     representing a combined cost of 2.1 billion dollars.  About one-half of
     these resulted in recommended funding deferrals of certain proposed
     treatment processes.

          Policy changes have been proposed due to complaints about project
     delays and "unnecessary" review requirements.  The criticism culminated in
     a suit brought by the State of Illinois challenging elements of EPA review
     policy on the Galesburg Project.  An out-of-court settlement was effected
     April 20, 1980, with EPA agreeing to revision of AWT review policy and
     procedures.  The proposed policy will be published for review and comment
     in the Federal Register, June 20, 1980.  With respect to small projects
     (incremental costs under $3 million), elements of the revision will streamline
     the review process by screening on the basis of household cost impact.  This will
     exempt about 90% of the projects from detailed review.  Water quality standards
     will not be reviewed except for those projects exhibiting significant cost
     impacts.  M6re realistic financial impact criteria for potentially
     high-cost projects will be developed.
                                             143

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             Other proposed changes, not directly related to the agreement will
        allow regions to 1) prepare draft reports for EPA Administrators'
        signature and 2) encourage reviews to take place before, or immediately
        after, the start of facility planning.

             In the future, reviews are likely to continue in FY 81 under revised
        policy guidance.  Several important changes in the water quality standards
        program will be proposed.
SESSION 2 -- NARINDAR KUMAR, MODERATOR
                              An Overview for AWT Decision Making

                                           Ken Young


             The speaker presented the results of 60 case studies regarding the
        AWT decision process with emphasis on the role of nonpoint source (NTS)
        pollution.  In spite of problems, such as lack of uniformity in data
        collection and presentation as well as modeling errors,  the analysis
        identified the following:  the distribution of NFS problems by source,
        distribution by number of States per region, distribution by natural
        setting, and typical impacts on natural systems.   In addition to these
        general findings, two special case studies were presented as examples of
        the difficulties in finding solutions to NFS problems:   West Point Reservoir
        (Atlanta) and DuPage River Basin (Illinois).  Economic  tradeoffs were also
        discussed in terms of the cost per acre for various types of treatment  and
        prevention,  including streetsweeping, nitrification, phosphorous removal,
        nitrification and filtration, agriculture, and storm tanks.  Finally, the
        speaker indicated that future study will focus on dilution problems, toxic
        issues, planning conflicts, and economic issues.   The consensus of the  dis-
        cussion which followed was that efforts to get a handle on the tradeoffs
        between point source and nonpoint source problems are encountering a number
        of difficulties and that the answers are not coming easily.
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                   Use of Models for Total Maximum Daily Load Projections

                                         Ron Sharpin


            The speaker's presentation focused on the use of simulation models.
       It included an identification of the major technical steps as well as  the
       factors to be considered in choosing a water quality model.   MSI's
       experience with the choice and use of water quality models was then discussed,
       emphasizing the problems associated with data limitations.  The discussion
       which followed served to underscore the nature and magnitude of the problems
       encountered with modeling in Colorado and elsewhere, and concluded that  it
       is only one tool, but a most useful one in many situations.
SESSION 3 -- CARL MYERS, MODERATOR


                       U.S.  Geological Survey - Potomac Estuary Study

                                         John George


            The U.S.  Geological Survey is making one of the first  comprehensive,
       multi-disciplinary studies of an estuary--the Potomac River.  The  speaker's
       review illustrates some of the problems in assessing large-scale estuaries.
       The portion of the Potomac between Chain Bridge and Point Lookout  is  rough-
       ly 100 channel miles  long.  Water quality problems were first identified  in
       the estuary around the time of the Civil War.  Population growth since  then
       worsened the problem.   In the 1950s,  observers noted floating mats of blue-
       green algae, some of  which extended for hundreds of yards.  Continued de-
       terioration in the 1960s further damaged the esthetic and recreational  value
       of one of the Nation's most visible rivers.  During this decade, President
       Lyndon Johnson articulated the goal of making the Potomac swimmable.  The
       upper Potomac is especially significant as a source of drinking water supply
       for the Washington, D.C., metropolitan area.  By 1966, the  amount  of  fresh
       water inflow available from the Potomac was about equal to  the amount being
       consumed in the metropolitan area.
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     The Potomac study is part of a series of river quality assessments that
U.S.G.S. began in 1973.  It was meant to be a problem-oriented assessment
of water quality in a unique hydro logic system, and was intended "to
provide a scientific basis for evaluating impacts on river quality for which
alternative plans of action can be judged."

     The Potomac Estuary Study has the following objectives.

     •    assessment of the impact of man-made changes in hydrology of the
          tidal Potomac;

     •    identification and elaboration of the basic chemical,  physical,
          and biological mechanisms governing life cycles in tidal rivers
          and estuaries in general;

     •    calibration and verification of mathematical flow and  transport
          models to support ecological models of phytoplankton dynamics,

     •    development of new or improved techniques for the study of tidal
          rivers and estuaries.

     Three main elements of the Potomac study are nutrient sources and
transport, bottom sediments, and biology.  Specialists from many disci-
plines are needed to assess a body of water which is a sink for  almost
everything coming into it.
                      A Holistic Lake System Assessment

                     John T. Marlar and James S.  Kutzman
     How do we assess lakes and the relationship between selected influences
on lakes and their response, particularly in regard to water quality?

     In selecting an assessment approach, one must keep several key factors
in mind for the results to be accepted and used.  First, does the approach
fit the magnitude of the decision for which the analysis will be used?
Second, does it fit the type of lake under consideration?  Finally, will
it produce an answer that makes sense and can be used by the appropriate
decision-makers?  The following are different types of water quality
assessment techniques for lakes that we have used:
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     1.  Classical Limmological Approach - This approach relies on lengthy
periods of measurements and accumulation of physical, chemical, and bio-
logical data to analyze present conditions and mechanisms within a lake.
This approach is often expensive, lengthy, and is heavily dependent upon
the skill, experience and reputation of the investigator.  Also, the
audience or decision-maker who receives the information must have a fairly
high level of sophistication in limnology in order to interpret results.
These types of studies can leave unanswered questions and are not suitable
for producing results in a short period of time.

     2.  Unfettered Mathematician's Approach - This approach basically
attempts to describe all of the possible primary reactions and energy
transformations occurring in the aquatic environment in mathematical terms.
The result is numerous parallel and interrelated equations which can only
be solved by computers with extremely large storage capacity.  Many of the
rate parameters and indeed some of the physical parameters in these models
can not be independently observed or measured.  Available data collection
programs are usually inadequate to determine the various input values.
This often results in utilizing standard textbook values which may or may
not be appropriate to the lake under consideration.  The resulting equations
may no longer adequately represent the lake and erroneous conclusions can
be drawn.

     3.  Input-Output Approach - This approach tries to select the minimum
number of parameters by which a particular situation can receive an overall
assessment.  The hypothesis is that a "probable" prediction can be reached
by comparison and observation against similar situations.  Another basic
assumption is that there exists a limiting factor which controls the system,
particularly for nutrients entering a lake.  This approach allows the
determination of which nutrient should be controlled and allows for reaching
practical conclusions in a relatively effective manner.

     In the past 10-15 years several input-output models have been developed
and are in active use, e.g., the Vollenweider, Larsen-Mercier, and Dillon
approaches.  During the period of 1975-76, the Region IV EPA staff undertook
a study to compare the results of approaches 1 and 2 to determine their
relative merits and usefulness as decision-making tools.  The three input-
output approaches as well as the Reservoir Ecologic Model,  EPAECO, were
examined in some detail with respect to a specific lake and the results
were compared.

     Either approach, EPAECO or the Dillon and Larsen-Mercier, supported a
conclusion that phosphorus control would improve water quality in the
specific lake.  Further work appeared to be needed to make the Vollenweider
approach more applicable to Southeastern lakes and reservoirs.
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     Following this comparative work, we reassessed the practicality of
using the Ecological Model, EPAECO, its voracious appetite for data, and
its scientific limitations.  Some of the coefficients and parameters in
the model could not be measured independently, and its hydrodynamics were
found to be lacking.

     Based on these considerations, we elected to put it back on the shelf.
Since 1975-76, we have, however, continued our attempts to fit the tools
available to the problems at hand and the resources available.  An acute
awareness of public understanding and acceptance of decisions which affect
their quality of life as well as their pocketbooks influenced our choice of
the approach.

     The input-output approach predicted a rather bleak picture of the
quality of Southeast lakes and reservoirs.  However, the observed quality
did not often confirm predictions.  The Vollenweider approach did predict
accurately the same relative rank order of the lakes by trophic class and
the extremes.  The model was then improved to reflect better the observed
conditions.
               A Comprehensive PS/NPS River System Assessment

                                 John Hobrla
     Portage Creek is a tributary of the Kalamazoo River, which flows west
from Michigan's Lower Peninsula into Lake Michigan.  The 7-day, 10-year
low flow of the Kalamazoo River at Kalamazoo is about 250 cubic feet per
second.  The Kalamazoo River has a long history of water quality problems,
particularly in the stretch downstream of Kalamazoo.  Through the 1960's
and 1970's, the gradual increases in waste treatment efficiency were
continually counterbalanced by higher waste loads.

     In the Portage Creek study area, there are two municipal dischargers,
three industrial dischargers, and a storm sewer outfall.  The Kalamazoo
wastewater treatment plant was by far the dominating influence on the water
quality of the Kalamazoo River.  During drought flow conditions, the
Kalamazoo effluent makes up about 20 percent of the river flow.  Its
design flow is about 34 million gallons per day.  About 40 percent of the
inflow to that plant came from paper mills and pharmaceutical industries.
Most of these inputs were very high in BOD and suspended solids.  They ex-
ceeded the treatment capacity of the plant during the study, and the average
effluent BODs from the plant was about 90 mg/1, with  ammonia nitrogen
averaging about 3 mg/1.
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     Two paper mills in the area run around the clock, six days per week.
Their wastewater is treated by a primary clarifier, and under normal con-
ditions, it makes up 15 percentvof the drought flow of Portage Creek.  Two
other specialty paper mills, which operate continuously, treat wastewater
with flow equalization, pH adjustment, and primary settling.  Because
their NPDES permit at the time of the study set no limits on ammonia ni-
trogen discharge, these plants were using ammonia nitrogen as part of
their pH adjustment process.  At one point their ammonia nitrogen dis-
charge was in the range of 35-40 mg/1.  A truck transmission plant discharged
domestic wastes and contact cooling water to the Kalamazoo municipal
system.  The plant's direct discharge contributed almost no oxygen demand,
but did contribute significant amounts of phosphorus because of detergent
used in a polishing operation.  A power plant upstream stores cooling
water in a large impoundment and discharges spent cooling water below the
dam.  The plant's average discharge represents about half of the drought
flow of the creek.  This can have serious impact on stream temperature (up
to 32° celsius downstream of the plant in 1972).

     An extensive flow, temperature, and chemical quality monitoring program
was undertaken to document stream quality under low-flow, high-temperature
conditions, to investigate the impact of each discharge,  and to calibrate a
water quality model for dissolved oxygen.

     One general finding was that water quality deteriorated rather rapidly
downstream at Kalamazoo, particularly below the municipal treatment plant.
Dense growths of aquatic plants were found throughout the study area.
Nutrient levels in the Kalamazoo River were found to be excessively high,
even at the upstream stations.  Chlorophyll values were highest upstream of
Kalamazoo, below the power plant impoundment,  and increasing turbidity
downstream was believed to depress algal growth.   Some 13 kilometers of
the study area failed to meet the proposed Michigan dissolved oxygen
standard (daily minimum of 5 mg/1 at 7-day, 10-year low flow).

     Once the model had been calibrated, it was used to simulate stream
response to a variety of low-flow conditions.   It predicted that current
discharge levels would produce zero dissolved oxygen (DO) under drought-flow
conditions.  With all point source dischargers meeting permit conditions,
DO levels would be no better than 3.6 mg/1.  Even when effluent from the
Kalamazoo plant and the paper mills received the most stringent treatment
technologically feasible (4 mg/1  BOD^ and 0.5 mg/1 ammonia nitrogen),  DO
levels only increased to 4.4 mg/1 -- still not enough to  meet the proposed
5 mg/1 standard.   These simulations pointed toward the conclusion that it
would be impossible to meet the proposed standard without reducing the
effect of aquatic plant respiration.  When photosynthesis and respiratory
effects were reduced 30 percent (in addition to the most  stringent treatment),
simulations indicated that the proposed standard would be met.   As higher
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         levels of treatment were reached for carbonaceous  and nitrogenous oxygen-
         demanding materials, plant respiration became by far the dominant influence
         on dissolved oxygen.  In this situation,  it appears that more would be
         gained by reducing plant respiration than by reducing biochemical and
         nitrogenous oxygen demand, although the precise relationship between
         decreased nutrients and increased DO was not quantified.

              The study led to two major recommendations.  The Kalamazoo wastewater
         treatment plant and the two specialty paper mills  should provide treatment
         sufficient to achieve 10 mg/1 BODs and 2 mg/1 ammonia nitrogen.   Efforts
         should be increased to control nutrient inputs to  the river from both
         point and nonpoint sources.  It was felt that an active program of nutrient
         control could be much more cost-effective than high level treatment of
         oxygen demanding wastes.
SESSION 4 -- NARINDAR KUMAR, MODERATOR
                         Setting Nutrient Limits for the Great Lakes

                                             Don Urban
              The speaker presented an overview of the joint efforts of the U.S.  and
         Canada to set nutrient levels for the Great Lakes with special emphasis  on
         decreasing the level of phosphorus.  The Phosphorous Management Strategy
         Task Force has recently reviewed the models which had been established to
         achieve that reduction, and has determined that the effluent limits were
         probably not sufficient to meet the target loads and that removal of less
         than .75 mg/1 is not ecomomically feasible.  In light of these findings,
         the task force has recommended a staged approach for future phosphorus
         removal in the Great Lakes,
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          Determining Appropriate Treatment Needs Beyond Secondary

                               Forest Westall


     The speaker discussed North Carolina's success in establishing a
procedure for determining appropriate needs for greater than secondary
treatment.  The presentation included a description of the organizational
and programmatic aspects of that State's WLA program, the technical and
procedural aspects of the program, and the information typically contained
in AWT/AST review packages.
                            Kalamazoo River Study

                              Richard G. Simms
     The speaker presented a paper describing the findings of a case study
regarding the relative impacts of point source and nonpoint source pollu-
tion on the Kalamazoo River.  It was the author's contention that the
contribution of stormwater runoff was largely ignored, and that less
expensive, more cost-effective alternative solutions were not adequately
considered.  As a result, a large amount of capital may have been unneces-
sarily expended on AWT.
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SILVICULTURE AND CONSTRUCTION PROGRAMS
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                             SILVICULTURE AND CONSTRUCTION
                                     SILVICULTURE
SESSION 1:  Cooperation Promotes Better Water Quality

            Introduction

            Highlights of Cooperation Between the
            Forest Service and the Environmental
            Protection Agency in Relation to Water
            Quality From Forested Lands

            The Current Interagency Agreement

            The Vermont Experience:  Cooperation
            Between Government and Industry

            Industry Cooperation in the 208 Process
Robert Raisch, Moderator

Robert Raisch              156

Einar L. Roget             156
J. Eggleston

John Nessel


Fred Hauessler
157

158


159
                                     CONSTRUCTION
SESSION 2:  Sediment Control in Construction Activities

            Introduction

            EPA Construction NPS Seminar Program

            EPA and Conservation Districts:  Prior
            EPA Activities in Construction NPS
            Control

            An Overview of Georgia's Erosion and
            Sediment Control Program

            Case History of the 1975 North Carolina
            Sedimentation Pollution Control Act
Robert Thronson, Moderator

Robert Thronson            159

Robert Williams            160

David Firor                160
Kenneth Obenauf
Alfred M. Duda
161
162
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SESSION  3:   Government  Involvement  in  Construction        Robert  Thronson, Moderator
            to  Improve  BMPs


            Basis for a Continuation of  EPA's              Robert  Thronson            163
            Construction NFS Regulatory  Program

            Evaluating  and Assessing BMPs                  William Bellinger          164

            County Involvement  in Erosion                  Carol Barrett              165
            Control Programs
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SESSION 1 -- ROBERT RAISCH, MODERATOR
                                        Introduction

                                        Robert Raisch
             Mr. Raisch summarized the status of the 208 silvicultural elements and
        discussed future needs.  The majority of 208 silvicultural plans are
        completed, and have typically been prepared by State forester's offices,
        which identified management and research needs.  Some of these are:  BMP
        effectiveness testing, educational programs, and future assessment of the
        effects of forest management activities.
         Highlights of Cooperation Between the Forest Service and the Environmental
             Protection Agency in Relation to Water Quality from Forested Lands

                                       Einar L. Roget


             In the past, cooperative efforts between the Forest Service and the
        Environmental Protection Agency have been informal through technical assistance,
        interagency work groups, and program evaluation.  An exchange of technical
        expertise by detailing men to strategic locations was initiated in 1974.
        Beginning in 1975, the two agencies entered into several formal agreements
        which have resulted in various publications, a procedural handbook, policy
        statements, and a new cooperative effort among Federal, State and private
        interests in water quality from forested lands.

             Previous interagency agreements generally addressed research and
        development needs and economic impact assessment.  The current 1979 agreement
        describes specific responsibilities and several cooperative programs.  Under
        the agreement, the Forest Service will provide overall leadership in
        technical assistance for silvicultural NPS control projects.  EPA will
        provide financial assistance and environmental review.  The programs outlined
        are related to Forest Service projects:  Forest Incentives Programs and
        Agricultural Conservation Programs Resource Planning Act review, State water
        quality and forest management planning coordination, and the development of
        a silviculture NPS training package.

             According to Mr. Raisch future cooperation between the Forest Service and
        the Environmental Protection Agency is needed to formulate air and water
        quality regulations affecting silviculture, to establish water quality
        standards for nonpoint source pollutants, to initiate a national program for
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water quality management training at all levels, to develop working
agreements necessary to enhance the 208 continuing planning process, to
meet the unique needs of our wetlands, and to determine how effective our
efforts have been in these and other areas in improving water quality from
forested lands.

     Mr. Raisch foresees continued involvement by the Forest Service.  As
new air and water regulations and standards are developed, it would like to
provide technical assistance as it relates to silviculture. The future needs
for additional evaluation of BMP effectiveness and NPS training also
outline future Forest Service involvement.  It is interested in and committed
to continued cooperative activities with EPA.
                      The Current Interagency Agreement

                                Jim Eggleston


     The current interagency agreement was signed by Deputy Administrator
Blum and Forest Service Chief McGuire in February 1979.  According to
Mr. Eggleston, it specifies roles agreed to in the areas of RPA and FIP/ACP
review, land resource planning, and NPS training needs.  EPA reviews EPA
documents as they are released and provides the Forest Service with an
assessment of their water quality concerns.

     This agreement integrates water quality planning and forest resource
planning on two levels:  in National Forest management and in State Forester's
offices.  A committee will review the development of one of the first
National Forest land management plans.  Three cooperative State programs
will identify planning linkages at that level.  Water quality is considered
in newly developed FIP and ACP guidance.

     A national work group will assemble an NPS training package to inform
policy makers, management staff, and the loggers and operators about the
water quality impacts of silvicultural activities.  Each course will
recommend the use of accepted BMPs.  A pilot State is scheduled to be
chosen and funded to implement and evaluate the package.
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    The Vermont Experience:  Cooperation Between Government and Industry

                                 John Nessel
     Erosion and sedimentation problems which result from logging operations
in Vermont are localized rather than widespread.  The major area of concern
is in the northeast portion of the State where large commercial operations
have had an impact on water quality in some headwater streams of the
Connecticut River.  A 50-megawatt wood-fired electricity generating
facility is currently under consideration in Burlington, the largest popula-
tion center in the State, and an area where water quality impacts are
already a concern.  The size and location of this facility, coupled with the
fact that more intensive harvesting methods will be employed to procure the
wood, has led to serious public and State concerns about the potential for
erosion and impacts on water quality of such an operation.

     Vermont has adopted a voluntary approach for minimizing forestry-
related erosion and sedimentation problems.  The plan, developed by the
Vermont 208 Water Quality Planning and Management Program,  includes the
self-policing of logging jobs by members of a Statewide timber-cutters
association; the development of a pocket sized booklet on Best Management
Practices for timber cutting and hauling; the co-sponsorship of annual
workshops on erosion control by the forest products industry; the loggers
association; and the State; the drafting and distribution of model timber
sale contracts which include erosion control clauses, and an audio visual
presentation on the potential water quality impacts of forestry and how to
avoid them.

     The non-regulatory approach was well received in the forestry community.
Area committees of private and industrial landowners were organized to
investigate water quality complaints instead of having additional State
staff monitor logging activities.  Since the plan has been in effect for
only one year, it is still too early to evaluate its overall effectiveness.
Nevertheless, State water resource investigators who are familiar with
logging practices in Vermont have reported a better attitude and higher
level of responsibility on the part of loggers.  Problems encountered have
been resolved more quickly and effectively than in the past.
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                        Industry Cooperation in the  208 Process

                                    Fred Hauessler
          Mr. Hauessler was an industry representative on the Georgia Forestry
     Task Force which developed the Georgia 208 forestry element.  The Task
     Force concluded that forests generally have a positive influence on water
     quality, forest practices are not a significant NPS of pollution, and
     BMPs should be recommended for implementation in a voluntary, non-regulatory
     program for sediment control.  The speaker further emphasized the commitment
     by the forestry industry to review 208 recommendations and support 208
     reauthorization.  He advised that future  208 direction should remain
     flexible, consider non-regulatory control programs, and pursue the testing
     and evaluation of BMPs.
SESSION 2 -- ROBERT THRONSON, MODERATOR
                                      Introduction

                                     Robert Thronson
          Mr. Thronson provided  a  general  introduction  to the format of  the
      session and described  the effects  of  excess  sediment loads and erosion
      resulting  from  construction activities.   BMPs are  available  to adequately
      control the problem.   As a  result,  EPA  actively  encourages development of
      State regulatory programs to  ensure implementation of  these  BMPs.
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                    EPA Construction NPS Seminar Program

                               Robert Williams


     NACD and EPA have worked together since 1972 to give water planning
agencies and officials an understanding of conservation districts and
to involve conservation districts in water quality management.

     Under an existing EPA grant, NACD is helping States to conduct a series
of construction NPS seminars which encourage them to examine the problems
generated by land-disturbing activities in developing areas and to chart
a course of action to deal with them.  These seminars also give conservation
districts and WQM Areawide Agencies the chance to exchange information and
to work together for effective control.

     When asked why there is no cost-share funding for construction as there
is in agriculture, Mr. Williams responded that the nature of the industry
differs from agriculture in three ways:  there is no similarly existing
delivery system, there are no easily identifiable cost-sharing individuals,
and the builder can recover costs in the market place.
EPA and Conservation Districts:  Prior EPA Activities in Construction NPS Control

                                 David Firor


     Since  1937 almost 3,000 conservation districts have been organized to
encourage local land owners to apply conservation practices in exchange for
various forms of assistance.  The districts are assisted technically by
the Soil Conservation Service of the USDA and are represented to various
Federal agencies and to Congress by the National Association of Conservation
Districts.  EPA has seen  the Districts as a valuable resource  because of
their 40-year history in  sediment control and their already-developed
delivery system.

     In 1972, NACD participated with other groups in preparing a model
State act for sediment and erosion control.  It was published in the
Council of  State Governments' "1973 Suggested State Legislation", Volume 32,
issued in September 1972.

     Also in that year NACD received an EPA grant to conduct sediment and
erosion control institutes in 40 States.  These institutes
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     o    encouraged recognition of each State's current sediment and
          erosion problems.

     e    reported on new State sediment control legislation.

     o    reported on current Federal legislation and responsibilities
          of EPA.

     »    presented the model State act.

     9    encouraged development of programs and legislation to control
          the problem.

     Twenty States, plus the District of Columbia and the Virgin Islands,
enacted some form of sediment and erosion control legislation after the
institutes.
        An Overview of Georgia's Erosion and Sediment Control Program

                               Kenneth Obenauf


     From construction activities in Georgia, the major nonpoint source
water pollutant is sediment.  On April 24, 1975, the Governor signed into
law the "Erosion and Sedimentation Act of 1975", calling for a permit program
to control sediment runoff from land-disturbing activities.  While the Act
contains many exemptions, its primary purpose is to control the major
sediment producers including large construction sites such as shopping
centers, subdivisions, and industrial sites.  The Act's requirements can be
preempted
by county ordinances and requires the review and approval of the
local soil and water conservation districts.

     During the past session of the General Assembly, Georgia's Act was
further strengthened by a review of city and county permit and enforcement
programs by soil and water conservation districts.  Another important
amendment established enforcement procedures for Georgia's Environmental
Protection Division.

     A recent assessment of Georgia's erosion and sediment control program
indicated no city or county was without problems.  However, for each problem
encountered, it was soon discovered some other city or county had found a
successful solution.  In addition it was learned that the success of a
program was not dependent on severity of penalties but rather the effective-
ness of the inspection program.
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     When considering expenses in complying with erosion and sediment
control requirements, one should remember it is cheaper to keep soil in
place than to remove it from another location later.  With the recent
amendments, Georgia's program will soon rank among the best in the nation.
 Case History of the 1973 North Carolina Sedimentation Pollution Control Act

                               Alfred M. Duda


     Like many sunbelt States, North Carolina is experiencing phenomenal
economic growth and rapid development.  Construction activities associated
with urbanization expose more than 15,000 acres at almost 5,000 sites each
year.   In 1973, the North Carolina Sedimentation Pollution Control Act was
passed  by the General Assembly to establish a Statewide program for the
control of soil erosion on construction sites.

     The North Carolina Department of Natural Resources and Community
Development administers the Act through ten field engineers.  Seventeen
of the  State's 100 counties and 27 municipalities have programs, with the
DNR having authority over State projects.  Agriculture, mining, and forestry
activities are exempt.  Required control plans must be submitted 30 days
prior to the initiation of work and must include five standards:  1) a
buffer  zone to trap sediment, 2) provision for a cut-and-fill angle less
than that required for vegetation growth, 3) ground cover planted within
30 days of termination, 4) allowance for a 10-year recurrence interval
rainfall event, and 5) the water release velocity must not be erosive.

     Several measures have been used to assess the performance of the
sedimentation control program.  Seven water quality studies were undertaken
 (using  measurements of sediment transport or aquatic biological monitoring)
under the State's 208 Planning Program.  The studies demonstrated that
despite the use of some erosion control practices, insufficient use of
several key practices resulted in serious water quality damages from the
eroded  sediment.  Field surveys of erosion on landfills and construction
sites,  an inventory of enforcement actions, and a poll of persons know-
ledgeable in erosion control were conducted.  The results indicate that
while the use of some erosion control practices is now more widespread
than in previous years, the control of sediment is still insufficient on many
construction sites and landfills.  Deficiencies exist in the use of several
key types of sediment control practices, in timely maintenance of the
practices, in submission of erosion control plans, and in achieving prompt
compliance with the Act.
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           The Act carries a limited police power, so enforcement varies by
      county.  A majority of surveyed construction and government personnel
      thought the Act more than 50 percent effective.  Most of the university
      and conservation community surveyed believe it to be less than 50 percent
      effective.  The gross number of erosion control plans have decreased over
      the last two years.

           An increase in staff, a strong enforcement policy, several legislative
      amendments to the  1973 Act, and a genuine concern for erosion control by
      local governments  would make the erosion control program more effective in
      protecting water quality and aquatic life in North Carolina.  Most of these
      needs can apply to erosion control programs in other areas as well.
SESSION 3 — ROBERT THRONSON, MODERATOR


         Basis for a Continuation of EPA's Construction NFS Regulatory Program

                                     Robert Thronson
           Public participation is essential to ensure the development and
      implementation of an adequate control program as well as to provide a
      sufficient base of support.

           BMPs should not be "set in concrete".  They should remain flexible to
      allow for local conditions and changes.  A development strategy should
      encourage State legislation and involve special interest groups, State and
      local agencies, and the public.

           EPA Headquarters role should be to provide grants to NACD, and to
      provide guidance and technical assistance to the regions, States, and other
      groups.

           Regional EPA role should be to encourage local engineering and
      contract groups' participation, to support State personnel, and to aid in
      problem identification.

           Regulatory program needs have been defined by a study of institutional
      aspects of erosion and sediment control.  They include the need for:
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     *    effective public participation in problem identification,
          planning, and implementation;

     «    provision of cause-and-effect information to public;

     e    involvement of engineering, contracting,  and building organizations,

     e    multi-disciplinary expertise by water quality and soil conservation
          agencies.

     Local technical assistance may be more responsive to local politics
than to local needs, and enforcement is frequently a low priority or
has low funding.
                        Evaluating and Assessing BMPs

                              William Bellinger


     The Federal Highway Administration (FHWA), Demonstration Projects
Division, in Arlington, Virginia has held water quality monitoring and BMP
evaluation workshops in many areas of the U.S.  Most Federal highway projects
allocate 5 to 8 percent of budget on erosion control activities.

     Examples of BMPs:

     e    Properly designed and placed siltation fences.

     &    Properly designed log dams.

     e    Properly installed and maintained hay bales.

     Basic rules for BMP improvement:

     e    Control measures must be planned and designed well in advance of
          construction.

     e    Control measures must be included in the plans and specifications
          for the project.

     e    Periodical inspection and maintenance are essential.
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     Basic principles for erosion and sediment control:

     o    Reduce area and duration of construction disturbance (Federal
          limit 17 acres before negotiating).

     o    Protect the bare soil--vegetating is most important—seed
          and mulch very quickly.

     •    Reduce velocity of runoff--roughen surfaces, terrace,  wattle.

     •    Reduce volume of runoff—construct berms and dams.

     «    Provide drainage facilities to control runoff.

     «    Trap or filter out sediment before it leaves construction area.

     Generally, the use of BMPs are well known.  They should  be  evaluated
for effectiveness and redesigned as required.
               County Involvement in Erosion Control Programs

                                Carol Barrett


     Why aren't there more effective programs?  Probably because there is
a built-in resistance to change and limited funds in the counties.

     What are the requirements for program development?

     •    General public concern to justify initiation of a program.

     •    State enabling legislation, though it can be difficult to obtain.

     A good county program requires:

     e    Good staff which establishes a positive working relationship with
          the construction community.

     e    Trained personnel (full time).

     e    BMPs as part of rezoning.

     e    Adequate financing (a self-supporting fee structure is desirable)
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     •    Effective inspection and enforcement.

The key element in an effective program is inspection and enforcement.
Performance bonds and review boards for new permits have been found
effective in many communities.

     What is the future for county involvement?

     Without Federal support and State concurrence, little action will
probably result, or other major issues (e.g. hazardous wastes) may divert
the public's general interest.
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CLOSING REMARKS
     167

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                            CLOSING REMARKS

                               Peter Wise
     This conference achieved what we had hoped, an intense exchange of
ideas, information, and opinions.  This cross-fertilization helped
everybody understand better where we are and where we're headed.

Where Are We?

     There are many good water quality programs.  I think this con-
ference pointed out that we've accomplished a great deal.  We've
done an excellent job of identifying water quality problems and
designing solutions for them.  The Program has come a long way.
Take ground water, for example, ten years ago we didn't even know
what data to collect.

     Today we've finished more than 200 WQM plans, and as a result,
we have a good idea what our most important point and nonpoint source
water quality problems are.  This conference has shown that many of
you are pursuing innovative ways of solving your local problems.
I was impressed with the number of technical sessions with people
talking about their successes and boasting about what they have
done in 208.  That's terrific.  While we recognize that we still
don't have all the technical answers, we've gained a handle on most
of them.  And now we're working many of the financial, institutional,
and communication questions that remain.

Where Are We Going?

     Speculating about the future, the assessment John Doyle made
at his policy session makes good sense.  He noted that the next two
years, the short-term future, call for a period of relative stability
as we fill in the data gaps in our plans and begin implementing them.
This doesn't mean we can't make changes.  We can and will build
sound, financial management approaches into all our projects:  NURP,
ground water, agriculture, etc.  I think we can also improve
communications, make our interpretation of policies and regulations
more consistent, and clarify the relationship of 201 and 208 activities.

     In the longer term, 1982 and beyond, we will see reauthorization
of the Clean Water Act.  We can expect considerable change, and we
must find ways not only to adapt to these changes but to help shape
them.  We have a tremendous opportunity in rewriting the Clean Water
Act.  But this will depend on what you do -- by the performance of
your projects, by the input you give us, by how well you make your
successes known, and by how actively you deal with your elected
officials.  Congress makes the final decision, but we can all have
a hand in shaping it.
                                         168

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     Another long-term consideration, it has become clear that non-
point sources will demand a major share of our attention if we are
to protect water quality nationwide.  If WQM planning is to work, it
must be comprehensive.  We are not a point source program only.  This
is the case we have to make to Congress.

Commitment and Challenge

     Once we recognize that we are all on the same side, I think
we can successfully restructure  the Program.  We must work together.
We at EPA are committed to working more closely with States and area-
wides.  Let me stick my neck  out and promise that we will have another
WQM Conference next year.  Let's get back together and  look over
what we've done in the coming year so that we can be together when
we give Congress our recommendations for the program.   I think it
makes good sense to widen the participation at the next conference.
We can also go out to various sections of the country and have similar
sessions with elected officials, public interest groups and the like.

     This conference has been enormously successful.  I think we need
to remember that our success  as  a group depends on achieving our goals
and solving common problems.

     Let's start working on  them now.
                                         169

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EVALUATION SUMMARIES
                                                         I
        171

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              WQM NATIONAL MEETING - EVALUATION FORM SUMMARY


     Of the approximately 400 people who attended the National Meeting
in Atlanta 56 (14%) have mailed or handed in evaluation forms.  The break-
out of responders is as follows:

          11   Federal
          10   State
          26   Areawide/local
           9   Other

     The most heavily attended session indicated by the 56 responses was the
Next Five Years (31 people).  This was followed by Point/NFS (28);  Ground
Water (24); and NURP (22).

     Our evaluation form requested that these persons identify what they
would like to have on the agenda for next year's conference.  The most
repeated subjects were Policy (changes; interpretations,  etc.);  Ground Water;
and Public Participation (particularly local elected official  involvement) .

     Most people had no major objections to the way the conference  was run
and we received many positive comments.  Some changes they would like to see
next year are less session overlap; limited speaking time—more discussion
time; top EPA and Congressional attendees; and advance handouts and abstracts.

     The "best run" sessions, according to the responses were  NURP, Ground
Water and the Next Five Years, but keep in mind these were also the most
heavily attended by the responders.  FMAP, Self-Sustaining Planning and
SAWS also received favorable comments.  John Doyle and Mayor Shepherd were
by far the most impressive speakers and were hailed by many of the
respondents.

     There were various concerns/questions which were not answered  and a lot
seems to revolve around the future of the program--EPA recommendations for
funding and criteria for future programs; flexibility in the programs; what
happens after plan approval; and no clear WQM direction.   This is an area
we really need to "hit on" for next year's conference.  Everyone should
leave with an idea of where they are headed.

     The evaluation form requested a ranking by program of the most important
areas of concern for the State or community of the responder.   At all levels
(Federal-State-local), education, municipal services, health and transporta-
tion ranked the highest.  Environment ranked in the middle.  In the environ-
mental field, water pollution control ranked highest followed  by toxics,
                                     172

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hazardous wastes and solid waste.  We also requested a ranking in the water
quality field.  While the priorities varied at all levels, the same
general categories (with the exception of hazardous wastes) were mentioned
in the top three by all the responders.
     Federal

     State

     Local

     Other
    #1

Industrial PT

Agriculture

Municipal PT

Drinking Water
    #2

Drinking Water

Industrial PT

Ground Water

Agriculture
     #3

Ground Water

Municipal PT

Drinking Water

Hazardous Wastes
     The last question on the evaluation form addressed the future of the
WQM program.  Since the responses are wide-ranging, they are attached in
their original form.
                                     173

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                            FUTURE OF WQM PROGRAM


•  Agencies must plan and implement sound ecological plans, recognizing
   the various interactions, for river basin size areas.  This must be
   irrespective of the 100's of programs.  EPA is driven by programs
   and the accompanying funding.  (USDA-Region)

e  A more comprehensive program after FY 82.  Rewriting of CWA.  Combined
   effort of both PS and NPS.  (EPA-Headquarters)

•  See gradual public acceptance of higher Environmental Quality Standards
   and individual responsibility for behavior.  (EPA-Headquarters)

•  Gloomy.  Based on presentations by Mayor Shepherd, guest speaker and
   several areawide agencies there must be numerous resolution of
   funding problems.  (Dept. of Air Force)

•  I'm biased!  In my view WQM and EPA are inextricable.  (EPA-Region)

•  To deal with those problems caused by toxic and hazardous wastes and
   their effect on ground water and also the total impact of urban
   storm runoff.  (EPA-Region)

®  It looks fairly bleak unless some sort of continued funding of 208 and
   208(j) is obtained.  (EPA-Region)

•  Without 208, 106, 314 and BMP cost-sharing increases along with
   continued emphasis on State cost-sharing, there won't be much cleanup
   on planning and significant BMP implementation.  This, of course,
   Headquarters already knows.  (EPA-Region)

•  I don't see sunset at all, but instead strength from retrenchment and
   slow demonstration of 208's value in ground water, constituency (for
   clean water) maintenance and, (I would like to see) more active
   involvement in toxics.  It would be nice if NURP's generate the hope of
   more liberal use of 201 funds for NPS contracts by 1982.  (Consultant-Env)

•  The work on water quality improvement will continue but there will be
   more emphasis on controlling soil erosion to improve water quality and
   to maintain crop production.  A balance between the two will come about
   later.  (University)

e  WQM is going to be reduced funding-wise and glamour-wise due to our
   shifting energy economics.  Strong and effective WQM can continue if
   knowledgeable, reasonable people are kept in the agencies.  1 hope that
   law and rule changes will remove WQM as a legal tool for construction-
   ists and preservationists.  (Agri Eng, Assoc Prof)

e  A 25 Federal/25 State/50 local program with bottom up control  (Areawide)

®  I don't know what EPA is thinking about for the (Areawide) restructur-
   ing 90's.

                                    174

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•  If WQM is to survive it must become the dominant policy mechanism
   for all EPA and State programs affecting water quality.  EPA seems
   determined to narrow the program.  (State)

•  I don't know what EPA has outlined—since those changes.  I do think
   that WQM, including planning, will have a bleak outlook unless area-
   wides, States and Federal agencies commit to solving real environmental
   problems and not welfare for white collar workers.  EPA must commit to
   sanctions as well as to achieve goals.  (State)

•  PS pollution should not be totally forgotten under 208.  (State)

•  WQM must continue and broaden to cover all water quality problems.  The
   most complex problems, especially NPS and groundwater protection will
   be the hardest to solve and take the largest time to see results.
   These problems must be kept before the public in order for the public
   to support their cleanup and control.  (State)

•  I cannot grasp EPA's future concepts.  I don't feel EPA knows what its
   future is.  This uncertainity only leads to noncommittal efforts  by
   locals.  They feel if they only hang on and ignore the program, it will
   go away.  The program must be assertive and the program must clean up
   water quality of both PT and NPS problems.  (State)

•  Need to have more integration-funding for water quality problems  not
   PS vs. NPS, etc.  The emphasis should be on improving water quality not
   on funding of pet projects.  (State)

•  The future for WQM must be the development of a comprehensive WQM plan-
   ning process that deals with the complex problems left.  Construction
   of municipal STP's will be minimal.  Need big attention paid to cause
   and effect relations and careful cost-effective analysis before precious
   financial resources are committed.  Need careful prioritization of the
   problems that will be addressed.  Can't rely on standardized solutions.
   Large attention will be paid to protecting drinking water sources and
   less to do for fish.  Toxic contamination of risk assessment will replace
   reliance on traditional WQS.  (State)

•  I feel that implementation and progress toward improved water quality
   will be much slower than indicated or planned by EPA.  (Areawide)

•  There must be a continuing WQM program with some continuing Federal
   financial assistance and oversight.  States are in economic competition.
   Some will ignore environment if they are allowed to.   (Areawide)

•  Can never end, just change color.  (Areawide)

•  Ground water protection should be emphasized.  (Areawide)

•  I think approximately 30-40 million will be available for water quality
   planning after FY 83.  (Areawide)
                                     175

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»  I need about one person-year funded to get our DMA's moving.  It is
   necessary to examine the existing situation in each case, identify
   specific changes needed and assist the DMA's in making those
   changes.  Until this is done our 208 plan will not be implemented
   on a comprehensive scale.  Local resources can pay a share of this,
   but not the whole thing.  (Areawide)

•  Increasing in detail of analysis; growing stronger.  (Areawide)

•  WQM must become an integral part of comprehensive Land Use planning.
   I envision an environmental block grant to be a logical goal of the
   future in terms of Federal funding assistance to aid some local  areas
   in achieving the objective stated above.  After 1983 - I hope this
   will be EPA's "future program".  (Areawide)

•  I see the necessity for restructuring the program along the model of
   transportation planning.  This would involve continued funding for
   management planning to States and areawides, imposition of NFS
   control responsibilities on DMA's as a condition of receiving construction
   grants from EPA, prioritization of a block of grant funds--by areawides
   on an annual basis (just like the transportation improvement program)
   and imposition on DMA's by EPA of responsibilities for partial support.
   (Areawide)

9  Senator Muskie in October 1979 said that environmental programs  may
   have to take a back seat to Defense and energy for several years--
   I believe him.  (Areawide)

«  Much work to be done--areawides need minimum level of support to
   maintain management network and to continue implementation.  EPA has
   seemed to outline a future of demonstration projects which will  not be
   transferable to our agency because we will be gone.  (Areawide)

•  Why has the program changed direction so many times in its history?
   This has resulted in false starts and wasted time and money at the
   local level.  It is also responsible in part for the uncertainty of
   the future 208 faces.  Will continuing support from the Fed be forthcoming?
   If it is not, the future may be nil.  Also, will EPA tell localities that
   they must support areawide planning or lose 201 money?  This is probably
   the only way that local support will become a reality for continuing
   planning.  Also nationwide coordination is necessary to go with State
   and areawide coordination.  EPA needs to clean up its act and help the
   locals to do likewise.  (Areawide)

•  I agree with some of the speakers that anything is possible.  I believe
   the greatest problem factor will be the State of the general economy.
                                     176

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«  A period of  struggle and effort  to maintain  WQM.   Primarily because
   of economic—energy concerns  and the  difficult  complex nature of
   the WQ problems  (the easy, obvious problems  deal with largely, now
   more involved, more intangible ones to be  addressed).  Will require
   sound technical work, strong  management  and  forceful leadership.
   The EPA approach is far too reflective of  OMB than of the need and
   problems in  the field.  (Areawide)

<*  Depends on developing and maintaining a  professional comprehensive
   water quality management approach.  Without  it you will doom the
   program you  wish to save.  (Areawide)

•  Nationwide program and concept,  and program  in selected agencies with
   large municipalities has a good  future.  However, in medium and small
   sized communities (i.e., under 50,000) the future is dismal.  There
   is no money  for new police cars  and fire trucks and WQM is considered
   non-essential.  This makes for a high staff  turnover rate, low salaries,
   lack of continuity and no clear  direction.   The future for WQM in
   small communities could be through a  system  of field offices of EPA
   (like SCS and extension services) with staff aiding local communities
   in WQ decisions.  (Areawide)

a  There will be increasing emphasis on  collecting the data needed to
   show that WQ improvements are occuring as a  result of implementation
   of WQM plans.  (Areawide)

e  Responsibility for WQM is a local issue.  The 208 program should serve
   to accentuate this responsibility through education of local
   governments  and citizens.  (Areawide)

e  Death of the program in '83.  Rebirth as a funded implementation program
   under a new  CWA.  (Areawide)

»  I know it is not wise--but I remain an optimist.  (Chairman,  PAC)

«  Unless sanctions are involved by EPA as prescribed by the regulations,
   the program  will lose momentum and support.  (Areawide)

9  Has to be ongoing program.  The  answers or solutions won't all come
   quickly.  (Areawide)

9  Solution of  NPS of pollution will require more effort to implement--
   particularly in agricultural areas.  More cost-sharing funds are
   needed to create farmer incentives to participate voluntarily.
   (Cooperation exten.  Univ.)
                                    177

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0  I see the future as being very project specific and success story
   oriented.  However, this narrower view somewhat restricts the
   undertaking of complex multi-year projects that while important
   may not be as "flashy" or as easy to solve as smaller scale, success
   story oriented projects.  (State official)

»  Concentration on institutional issues where this is necessary to ensure
   that plan recommendations can be carried out by an agency with
   necessary authority and capabilities; funding for voluntary NFS control
   programs with funding tied to 208 plan and 208 agency;  monitoring only
   on a selective basis to ensure quality control and effectiveness at
   various BMP's under different circumstances; regulations imposed on
   significant problems; sanctions held in the background,  but used
   sparingly—so that cooperation and volunteerism are encouraged but
   you don't get peoples' backs up; a recognition that the majority of
   remaining pollution comes from a collection of many sources.  Education
   and attitude changes are needed.  Regulation can only be effective for
   the big, bad, ugly and obvious.  (Areawide official)

a  I cannot second guess EPA.  I don't believe EPA knows what direction
   it will be going in for the future.  That depends upon which way the
   wind happens to be blowing in the future.  (Areawide)

»  Will have to push PP if EPA wants to change WQM to implementation
   instead of planning.

e  Federal Government maintains lead in technical research, developing
   WQ criteria, information transfer,  technical and financial assistance
   in planning and implementing special projects.  States  conduct or
   provide technical assistance to local agencies in conducting enforcement
   programs and special regional scale studies.  Local agencies would be
   responsible for "putting it all together" coordinating  technical studies
   and management programs at the watershed level,  working with local
   enforcement agencies whose authority was vested at the  minor civil
   division level by State enabling legislation.  EPA in intensifying its
   relationship with State environmental programs has recognized the
   importance of local agencies in program implementation.   EPA must,
   however, ensure that areawide agencies are fully "plugged into" the
   process.  Areawide agencies are vital for effecting WQM program
   implementation, as an adversary relationship between local and State
   governments has often developed when States mandate local-level programs
   insensitive to local-resource needs for effective program establishment,
   operation and maintenance.  EPA must take an active role, as promised,
   to ensure that States do not unilaterally diminish the role of areawide
   agencies in order to acquire large shares of limited Federal program
   funds.
                                     178

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CONFERENCE ATTENDANTS (NAMES AND ADDRESSES)
                    179

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Kathleen C. Adgate
Acting Director, Office of
  Planning and Evaluation
State of Maryland Water
  Resources Administration
Tawes State Office Building, D-2
Annapolis, MD  21401

C. Stephen All red
Director, Department of
  Water Resources
State Office
450 West State Street
Boise, ID  83720
                 Health Engineer
 Aldo  Andreoli
 Principal  Public
 Suffolk County
 Department of  Health  Services
 Veterans Memorial  Hospital
 Hauppauge,  NY   11787

 Barry J. Appleby
 208 Project Director
 Volusia Council of Governments
 125 East Orange Ave.,  Room  305
 Daytona Beach,  FL   32014

 Cecil  R. Armstrong
 EPA Forest  Service Liaison
 U.S.  Environmental  Protection Agency
 1860  Lincoln St.,
 Denver, CO  80295

 Dennis  Athayde
 Implementation  Branch
 Water  Planning  Division
 U.S.  EPA
 401 M  Street, SW   WH 554
 Washington, DC  20460

Alan W. Avery, Jr.
 Principal Planner
Ocean County Planning Board
119 Hooper Avenue
Toms River, NJ  08753
 Fred Banach
 Sanitary Engineer
 CT Department of Environmental
   Protection
 122 Washington Street
 Hartford,  CT  06115

 Tom Barlow
 Senior Staff
 Natural  Resources Defences
   Council,  Inc.
 1725 I Street,  NW,  Suite  600
 Washington,  DC  20006

 Carol  Barrett
 Project  Director,
 National Association  of
   Counties  Research,  Inc.
 1735 New York Avenue,  NW
 Washington,  DC   20005

 Kenneth A.  Bartal
 Chief, Office of Comprehensive
   Water and  Wastewater Planning
 PA Department of Environmental
   Resources
 P.O. Box 2063,
 Harrisburg,  PA   17120

 Dr.  David B.  Beasley
 Assistant Professor
 Agric. Engineering Dept.
 Purdue University
 West Lafayette,  IN  47907

 Scott A. Beaumont
 Consultant
 Touche Ross/FMAP
 1700 Market  Street
 Philadelphia, PA  19103

 Eckardt C.  Beck
Assistant Administrator,
Water & Waste Management
U.S. EPA
401 M Street, SW
Washington, DC  20460
                                       180

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Patty Bubar
Environmental Engineer
Environmental Protection Agency
401 M St., SW
Washington, DC  20460

Stephen Bude
Chief, Water Quality Studies
Michigan Department of
  Natural Resources
Steven J. Mason Building
8th Floor
P.O. Box 30028
Lansing, MI  48909

Theodore B. Burger
Deputy Director, Bureau of
  Water Pollution Control
Nassau County Department of Health
240 Old Country Road
Mineola, NY  11501

Dennie G.  Burns
Director,
Office of  Water Quality
Soil  Conservation Service
U.S.D.A.
P.O.  Box 2890
Washington,  DC  20013

David  Burr
208  Project  Director
Southwest  Florida Regional
   Planning Council
2121  West  First Street
Fort  Myers,  FL  33901
 John  P.  Burt
 Environmental  Engineer,
 SCS South  Technical  Service
   Center
 P.O.  Box 6567
 Fort  Worth,  TX  76115
Dr. Kathleen Camin
Regional Administrator,
U.S. EPA  Region VII
1735 Baltimore Street
Kansas City, MO  64108

Charles J- Carelli
Chief Water Quality Planning
Washington State Department
  of Energy
Olmpia, WA  98507

Stephen P. Carlson
Coordinator  208 Planning
University of California
  Cooperative Extension
237 Veihmeyer Hall
Davis, CA  95616

Michael Carnevale
203 Water Quality Program
  Planning Supervisor
Department of Environmental
  Quality, Water Quality Division
Hathaway Building
Cheyenne, WY  82002

Juliet Carroll
208 Planner
Land of Sky Regional Council
P.O. Box 2175
Asheville, NC  28802
Homer Chandler
Executive Director,
Mountainland Association
  Governments
160 E. Center Street
Provo, UT  84601

Nathan Chandler
Agricultural Advisor to
  EPA Administrator,
U.S. EPA
401 M Street, SW A!00
Washington, DC  20460
of
                                        181

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Richard B. Bell
Manager, Water Res. & Waste
  Management Section
600 So. Commonwealth Ave., Ste. 1000
Los Angeles, CA  90005

William Bellinger
Project Manager
Demonstration Projects Div.,
Federal Highway Admin.
1000 N. Glebe Road
Arlington, VA  22201

Stein Bendixen
VBB-Stockholm
2, Linnegatan
P.O. Box 5038
S. 10241 Stockholm
Sweden

Robert D. Bishop
208 Coordinator
Soil & Water Conservation
  Division
Santa Fe, NM  87501

Kenneth R. Blan
SCS Detail to EPA Region VII
WQP Branch
324 East llth
Kansas City, MO  64106
Virgil Bouck
Executive Director,
Agricultural Stabilization and
  Conservation Service
850 South Hooper
Caro, MI  48723

Gail Boyd
Environmental Engineer,
Woodward-Clyde Consultants
Three Embarcadero Center
Suite 700
San Francisco, CA  94111
Donald J. Brady
  Agency
Room 811 E WH 554
401 M Street, SW
Washington, DC  20460

Donald W. Brady
Assistant Director/208
  Project Director
South Alabama Regional
  Planning Commission
P.O. Box 1665
Mobile, Alabama  36601

John F. Brennan
208 Director
Atlanta Co., NO Government
Guarantee Trust Building
Atlantic City, NJ  08401
 >«>
Dr. Mark Brown
Research Scientist,
N.Y. State Department of
  Environmental Conservation
59 Wolfe Road
Albany, NY  12233

Jacqueline Bruemmer
Environmental (208)
  Planning Program Manager
Southwestern Illinois Metropolitan
  and Regional Planning Commission
203 West Main St.,
Collinsville, IL  62234

Kenneth Bruene
Dept. of Soil Conservation
Wallace Building
Des Moines, IA  50319

Pat Brunet
Environmental Program Director
Southeastern Michigan
  Council of Governments
8th Floor, Book Building
1249 Washington Blvd.
Detroit, MI  48226
                                         182

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Gould Charshee
208 Technical Director
Baltimore Regional Planning
  Council
2225 North Charles Street
Baltimore, MD  21218

Peter Ciotoli
Senior Planner
Roy F. Weston, Inc.
Weston Way
Westchester, PA  19380

Douglas Clark
Assistant Director,
Monitoring and Planning
  Element
N.J. Department of
  Environmental Protection
P.O. Box 2809
Trenton, NJ  08625

Deborah J. Collins
Information Assistant,
Public Involvement Section,
EPA, Water Planning Division
401 M Street, SW
Washington, DC  20460

Anthony Conetta
208 Project Officer
U.S. EPA  Region II
26 Federal Plaza
Room 1009
New York, NY  10007

Edward G. Councill
Environmental Supervisor  IV
Kentucky Department for
  Natural Resources
  Division of Water Quality
1065 U.S. 127 Bypass South,
Century Plaz
Frankfort, KY  40601
Darryl E. Cook
Water Resources Planning
  Engineer
Virginia State Water Control
  Board
2111 N. Hamilton Street
Richmond, VA  23221
Samuel A. Covington
Director of Management Planning
Metre-plan
Continental Building
100 Main Street
Little Rock, AR  72201

Dan Crevensten
Consultant
Municipality of Anchorage
6771 Sherwood Ave.
Anchorage, AK  99504

Joseph A. Davis
Writer/Editor
EPA, Water Planning Division
1202 Hemlock Street, NW
Washington, DC  20460
Paul E. Davis
Head, Office of Planning
Minnesota Pollution Control
  Agency
1935 W. County Road, B-2
Roseville, MN  55113

Ronald J. Darling
Environmental/208 Coordinator
Tri County Regional Planning
  Commission
2722 E. Michigan
Lansing, MI  48912

Richard G. Dearsley
Forestry Specialist
EPA  Region X
M/S  466  1200 Sixth Avenue
Seattle, WA  98101
                                         183

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Keith Dearth
Chief Assistance and Review
  Branch
Facility Requirements Division
Office of Water Programs
  Operations
U.S. EPA
401 M Street, SW  WH 554
Washington D.C.  20460

Margaret DeGrassi
Director, Water Quality Planning
Ark-Tex Council of Governments
P.O. Box 5307
Texarkana, TX  75501

Robert W. Delzell
Water Quality Specialist
(EPA) USDA, Soil, Conservation
  Service (SCS)
215 Fremont Street
San Francisco, CA  94105

Merle Derdall
Director, Environmental Resources
Lower Rio Grande Valley
  Development Council
First National Bank Building,
  Suite 205
McAllen, TX  78501

Mark Derichsweiler
Enviromental Engineering
  Assistant II
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK  73152

David Dijull
Assistant Director, Energy &
  Environmental Division
South California AOG
600 South Commonwealth Ave.,
  Suite 1000
Los Angeles, CA  90005
Dr. James G. Dillard
Agricultural Economist,
F115 National Fertilizer
  Development Center
Tennessee Valley Authority
Muscle Shoals, AL  35660

Elvidio V. Diniz
Manager/Senior Engineer
Espey Huston & Associates
2500 Louisiana Blvd., NE,
  Suite 310
Albuquerque, NM 87110

Bob Donaghue
Environmental Planner
Southwest Florida Regional
  Planning Council
2121 West First Street
Fort Myers, FL  33901

John S. Doyle, Jr.
Assistant Minority Council
  for Water Resources
House Public Works and
  Transportation Committee
2165 Rayburn House Office
  Building
Washington, D.C.  20515

Mi mi A. Drew
Environmental Speciality IV
Bureau of Water Management
2600 Blair Stone Road
Tallahassee, FL  32301

Eugene Driscoll
Principal,
E.D. Driscoll and Associates
101 Maneto Avenue
Oakland, NJ  07436
                                       184

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Dr. Alfred Duda
Environmental Scientist,
N.C. Department of Natural
  Resources and Community
  Development
P.O. Box 27687
Raleigh, NC  27611

Ray Dunn
Management Consultant,
Linton and Company,  Inc.
1015 18th Street, NW
Washington, DC  20036

Robert H. Dunn  III
Environmental Protection Agency
Room 811 E  WH554
401 M Street, SW
Washington, DC  20460

Alan Durrick
Director, Conservation  and
   Environmental Protection
   Division
Agricultural Stabilization  and
   Conservation  Service
P.O. Box 2415
Washington, DC  20013

Roger F. Duwart
Environmental Engineer,
   Water Quality Branch
Environmental Protection Agency
JFK Federal Building
Boston, MA  02203

Bernard Dworsky
Administrator,
New Castle County Water
   Resources Agency
2701 Capital Trail
Newark, DE  19711

Doris S. Ebner
Manager, Community & Environmental
   Planning Department
Houston-Galveston Area  Council
3701 W. Alabama
Houston, TX  77027
Clifford V. Eckhardt
District Manager,
South Yakima Conservation
  District
1112 Highway 12
Sunnyside, WA  98944

Rodney Eder
Manager IV
Memphis/Shelby County Office
  of Planning & Development
125 N. Main, Room 419
Memphis, TN  38103

Linda E:ichmiller
Chief, Evaluation Section
Policy and Evaluation Branch
Water Planning Division
U.S. EPA
401 M Street, SW  WH554
Washington, DC  20460

Frederic Eidsness, Jr.
Vice President,
Briscoe, Maphis, Murray and
  Lament, Inc.
2336 Pearl Street
Boulder, CO  80302

Peter D. Elliott
Water Quality Planner 208
Southwestern Michigan Regional
  Planning Commission
2907 Division Street
St. Joseph, MI  49085

William R. El man
Executive Director
Fox Valley Water Quality
  Planning Agency
1919 American Court
Neenah, WI  54956

Thomas Elmore
Water Quality Management
  Coordinator,
Northwest Colorado Council
  of Governments
P.O. Box 739
Frisco, CO  84443
                                        185

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W.F. Esmond, Jr.
Assistant Division Director
NYS Environmental Conservation
50 Wolf Road
Albany, NY  12233

Gerald L. Esposito
Planner, Department of Natural
  Resources and  Environmental
  Control,  Division of Environmental
  Control,  Planning Section
P.O. Box 1401, Tatnall Building
Dover, DE   19901

Ed  Fagerland
Metropolitan Council
300 Metro Square Building
St. Paul, MN   55101

Connie Ferguson
Water Quality  Coordinator,
South Central  Michigan
  Planning  Council
Connors Hall
Nazareth College at Kalamazoo
Kalamazoo,  MI  49074

Larry Ferguson
208 Coordinator,
Water Division
U.S. EPA/Region  VII
324 East llth  Street
Kansas City, MO  64106

Jim Ferris
Central Iowa Regional
Association of Local  Government
P.O. Box 10392
Desmoines,  IA  50309

Richard Field
Chief, Storm and Combined
  Sewar Section, EPA
Municipal Environmental
  Research  Laboratory
Edison, NJ  08117
David Firor
Southern Region Rep.,
  Conservation Districts
745 Prince Avenue
P.O. Box 606
Athens, GA  30603

Paul E. Fisher
Project Director
Hampton Roads Water
  Quality Agency
1436 Air Rail Avenue
Virginia Beach, VA  23458

James P. Fleischmann
Senior Planner
Palm Beach County
  Area Planning Board
2300 Palm Beach Lakes Blvd.,
Suite 200
West Palm Beach, FL  33409

John Flynn, Jr.
Manager,
louche Ross & Co.
1700 Market Street
Philadelphia, PA  19103

Art Fokakis
ATCOG TAPAC Committee Member
Ark-Tex Council of Governments
P.O. Box 5307
Texarkana, TX  75501

Kenneth V. Ford
Director of Environmental and
  Natural Resource Planning
Central Florida Regional
  Planning Council
515 E. Boulevard; P.O. Box 2089
Bartow, FL  33830

Roger Ford
Chairman, ATCOG TAPAC Committee
Ark-Tex Council of Governments
P.O. Box 5307
Texarkana, TX  75501
                                        186

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Floyd Forman
Environmental Planner
Valley Regional Planning Agency
Derby R.R. Station,  12 Main St
Derby, CT  06418

Robert L. Fox, Jr.
Environmental Engineer
Environmental Protection Agency
301 S. Park
Helena, MT  59601

Leila 0. Gainer
Federal Liaison
National Association
  of Regional Councils
1700 K Street, N.W.
  13th Floor
Washington, DC  20006

Dr. James R. Gammon
Zoology Department
DePauw University
Greencastle, IN  46135

John George
District Chief of Georgia
  Water Division
U.S. Geological Survey
6481 Peachtree Industrial  Blvd.
Doraville, GA  30360

J. Dale Givens
Administrator, Water Pollution
  Control Division
LA Department of Natural
  Resources, Water Pollution
  Control Division
P.O. Box 44066
Baton Rouge, LA  70804

Michael M. Glusac
Executive Director
Southeast Michigan Council
  of Governments (SEMCOG)
800 Book Building
Detroit, MI  48226
Darryl R. Goehring
Senior Planner,
Newcastle Country Water
  Resources Agency
2701 Capital Trail
Newark, DE  19711

Felipe A. Gonzales
208 Planning Coordinator
New Mexico State Forestry
Land Office Building
Santa Fe, NM  87501

James E. Gutman
Chairman, Public Advisory
  Commi ttee
Baltimore Regional Planning
  Council, 208 Program
233 Wiltshire Lane
Severna Park, MD  21146

A. Barlett Hague
Chief, Environmental Studies,
  Water Quality Branch
Environmental  Protection Agency
JFK Federal  Building
Boston, MA  02203

John Hamby
Planner I
Metropolitan Planning Commission
4th Floor, City/County Building
Knoxville, TN  37902

R. Bruce Hammatt
WLF Biologist II
LA Department of Natural
  Resources, Water Pollution
  Control Division
P.O. Box 44066
Baton Rouge, LA  70804

Edwin Hammett
Director of Regional Planning
Toledo Metropolitan  Area
  Council of Governments
123 Michigan Street
Toledo, OH  43624
                                        187

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Rebecca Hanmer
Regional Administrator
U.S. EPA  Region IV
345 Courtland Street, NE
Atlanta, GA  30308

Lowell Hanson
EPA/Extension Liaison
EPA
Water Planning Division WH 554
401 M Street, S.W.
Washington, DC  20460

Robert Hardaker
Chief, Operations Branch
Water Planning Division
U.S. EPA
401 M Street, SW  WH 554
Washington, DC  20460

Rhett Harrell
Assistant Director
Government Finance Research
   Center/Municipal Finance
   Officers Association
1750 K Street, NW
Washington, DC  20006

John S. Harrington
Director of Planning
Metroplan
Continental Building
100 Main Street
Little Rock, AR   72201

Roger Hartung
Chief, Water Program Branch,  EPA
First  International Bldg.
1201 Elm Street
Dallas, TX  75270

Doug Hawkins
Soil Conservationist,
Water Division
U.  S. EPA  Region  IV
345 Courtland Street, NE
Atlanta, GA  30308
Joseph Hayes
MIP Coordinator,
Soil Conservation Service
U.S.D.A.
Suite 2200
5610 Crawfordsville Road
Indianapolis, IN  46224

Rosemary Henderson
Public Participation
  Specialist
U.S. EPA  Region VI
First International Building
1201 Elm Street
Dallas, TX  75270

Al Herndon
Nonpoint Source Coordinator,
U.S. EPA  Region IV
345 Courtland Street, NE
Atlanta, GA  30308

Patricia A. Hill
Chief, Public Involvement
  Section
  Water Planning Division
Environmental Protection Agency
401 M Street, SW
Washington, DC  20460

Richard M. Hobrla
Environmental Engineer
Michigan Department of
  Natural Resources
P.O. Box 30028
Lansing, MI  48909

Andrew Hogarth
Section Chief,
Ground Water Compliance &
  Special Studies  Section
Michigan Department of
  Natural Resources
Stevens T. Mason Building
P.O. Box 30028
Lansing, MI  48909
                                        188

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Tommie J. Holder
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA  19106
Ed Holland
Water Quality Specialist
Triangle J Council of
  Governments
P.O. Box 12276
Research Triangle Park, NC  27709

R. Michael Holmes
208 Planner
Volusia Council of Governments
125 Orange Ave., Room 305
Daytona Beach, FL  32014

Rita Horgan
Policy Development Section
Policy and Evaluation Branch
Water Planning Division
U.S. EPA
401 M Street, SW  WH 544
Washington, DC  20460

John Howland
Chief, Water Quality Planning
Missouri Department of
  Natural Resources
P.O. Box 1368
Jefferson City, MO  65101

Commissioner Nancy Huey
Commissioner
City of Cocoa Beach
448 Carmini Dr.
Cocoa Beach, FL  32931

Dr. Frank J. Humenik
Associate Department Head
  in Charge of Extension
North Carolina State University
Raleigh, NC  27607

Merna Hurd
Director,
Water Planning Division
Office of Water Planning
  and Standards
U S. EPA
401 M Street, SW
Washington, DC  20460
Edward J. Hustoles
Planning Director
Southeast Michigan Council
  of Governments (SEMCOG)
800 Book Building
Detroit, MI  48226

Charles E. Hutson
Water Resources Planning Engineer
Virginia  State Water Control
  Board
P.O. Box 1143
Richmond, VA  23229

Dr. Raymond A. Hogum
Agronomist, Soils
Auburn University
111 Extension Hall
Auburn University,  AL  36849

Paul W. Icke, Jr.
Environmental Protection Specialist
U.S. EPA, Heaquarters
401 M street, SW
Washington, DC  20460

Arthur L. Jenke
Hydrologist
Environmental Protection Agency
4th & M Streets, SW
Washington, DC  20460

Charles R. Jeter
President, ASIWPCA and
Chief, Wastewater & Stream
  Quality Control
S.C. Department of Health
  and Environmental Control
2600 Bull Street
Columbia, SC  29201

Ted L. Jones
Assistant Director, Agricultural
  Industry
Ohio Cooperative Extension
  Service
2120 Fyffe Road
Columbus, OH  43210

Robert J. Karwowski
208 Project Manager
GLS Region V Planning &
  Development Commission
1602 West Third Avenue
Flint, MI  48504
                                       189

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Paul B. Kelman
Chief, Environmental Planning
  Division
Atlanta Regional Commission
230 Peachtree Street, NW
  Suite 200
Atlanta, GA  30303

Donald S. King
Assistant Director
Central Connecticut Regional
  Planning Agency
12  Landoy St.
Bristol, CT  06010

C.  Morgan Kingdom
Acting Chief,
Environmental Branch, Office
  of Management & Budget
New Executive Office Bldg,
Room 8222
1726 Jackson Place, NW
Washington, DC  20503

Gerald Kinghorn
208 Project Director,
Salt Lake County Department
  of Water Quality and Water
  Pollution Control
Country Complex Building
2033 South State Street
Salt Lake City, UT  84115

Jerry Kotas
Environmental Protection
  Specialist
Water Planning Division
U.S. EPA
401 M Street, SW  WH 554
Washington, DC  20460

Paul Kraman
Chief, Financial Management
  Section
Operations Branch
Water Planning Division
U.S. EPA
401 M Street, SW  WH 554
Washington, DC  20460
Joseph Krivak
Director, Criteria and
  Standards Division
U.S. EPA
401 M Street, SW  WH 585
Washington, DC  20460

William J. Kruse
Environmental Division Manager
Lower Raritan/Middlesex County
  Water Resource Management
  Program/MCPB
40 Livingston Ave.,
New Brunswick, NJ  08901

Catherine Kuhlman
Water Quality Management
  Coordinator
Region IX
215 Fremont Street
San Francisco, CA  94105

Dr. Jochen Kuhner
Consultant,
Meta Systems, Inc.
10 Hoiworthy Street
Cambridge, MA  02138

Narindar Kumar
Section Chief,
Facilities Management Section
Water Planning Division
U.S. EPA
401 M Street, SW  WH 554
Washington, DC  20460

James Lake
Program Specialist,
National  Association of
  Conservation Districts
Route #1
Woodburn, IN  46797

William Lament, Jr.
Vice President,
Briscoe,  Maphis, Murray
  and Lament, Inc.
2336 Pearl Street
Boulder,  CO  80302
                                        190

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John Lampe
Manager
Water Quality Planning
Seattle Metro
821 2nd Avenue
Seattle, WA  98104

William N. Lane
Director of Environmental
  Planning
Dane County Regional
  Planning Commission
Room 114, City/County
  Building
Madison, WI  53709

Ronald L. Lauster
Nonpoint Source Coordinator
Environmental Protection Agency
1201 Elm Street
Dallas, TX  75270

Austin Librach
Director, Department of
  Water Resources
Metropolitan Washington
  Council of Governments
1875 I Street, NW
Washington, DC  20006

Bruce Lindahl
Soil Conservationist
EPA
1860 Lincoln
Denver, CO  80295
Charles F. Lucas
Director, Regional Development
Ark-Tex Council of Governments
P.O. Box 5307
Texarkana, TX  75501

Jan Lundgren
VGG-Stockholm
2, Linnegatan
P.O. Box 5038
S-10241 Stockholm
Sweden
John Lutz
Planner II
Metropolitan Planning Commission
4th Floor, City/County Building
Knoxville, TN  37902

Dave LyStrom
Hydrologist,
Surface Water Branch
U.S. Geological Survey
12201 Sunrise Valley Drive
Reston, VA  22092

Burt C. MacKenzie, III
Water Resources Planning
  Engineer
Virginia State Water Control
  Board
P.O. Box 11143
2111 N. Hamilton Street
Richmond, VA  93230

Peter S. Machno
Program Manager, Water Quality
  Enhancement
Municipality of Metropolitan  Seattle
831 Second Avenue,
Seattle, WA  98104

Robert H. MacPherson
Manager/Planning Section
Department of Natural Resources
  & Environmental Control
Division of Environmental
  Control, Planning Section
P.O. Box 1401, Tatnall Bldg.
Dover, DE  19901

Paula Magnuson
208 Water Resources
  Coordinator,
Cape Code Planning and
  Economic Development
  Commission
1st District Courthouse
Barnstable, MA  02630
                                       191

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C. Thomas Male
Associate Sanitary Engineer
NYS Department of Environmental
  Conservation
50 Wolf Road
Albany, NY  12233

Edward Maranda
Special Assistant
Metropolitan Council
300 Metro Square
St. Paul, MN  55104

William E. Markley, III
Natural Resources Engineer IV
South Dakota Department of
  Water & Natural Resources
Pierre, SD  57501

John Marlar
Water Quality Management
  Coordinator,
U.S. EPA  Region IV
345 Courtland Street, NE
Atlanta, GA  30308

Richard H. Marston
Assistant State Conservationist
U.S. Department of Agriculture,
  Soil Conservation Service
1370 Hamilton Street,
P.O. Box 219
Somerset, NJ  08873
          Martin
          Director/Consultant
Samuel R.
Technical
JFURP
Regional Planning Council
2225 North Charles Street
Baltimore, MD  21218

Loretta Marzetti
Chief, Policy Coordination/
  SEA Section
Policy & Evaluation Branch
Water Planning Division
U.S. EPA
401 M Street, SW  WH 554
Washington, DC  20460
                                             Robert J. Massarelli
                                             Water Resources Director
                                             Brevard County Water Resources
                                               Department
                                             2575 N. Courtenay Parkway
                                             Nerrutt Island, FL  32952
Eugene A. Mattis
Water Quality Management
  Coordinator
U.S. Environmental Protection
  Agency, Region III
6th and Walnut Streets
Curtis Building
Philadelphia, PA  19106

Dan Mayencek
Central Arizona Association
  of Governments
1810 Main Street
P.O. Drawer JJ
Florence, AZ  85232

Fred McCamic
Planner
208/Planner
Guarantee Trust Building
Atlantic City, NJ  08401

Lawrence E. McCormick
Environmental Institutional
  Coordinator
LR/MC Water Resources
  Management Program
40 Livingston Ave.,
New Brunswick, NJ  08901

Timothy J.  McGarry
Deputy Director
Richmond Regional Planning
  District Commission
6 North Sixth St., Suite 500
Richmond, VA  23219

Daniel McGillicuddy
208 Program Coordinator,
Department of Environmental
  Quality Engineering
Leverett Saltonstall Building
                                       192

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Peggy D. McNeil!
Chairman, Mercer Co. (N.J.)
  208 PAC
  Mercer Co., (N.J.) 208
39 Linwood Circle
Princeton, NJ  08540

Edward  K. McSweeney
Chief,  Water Quality Branch
Environmental Protection Agency
JFK Federal Building
Boston, MA  02203

Stuart  Meek, AICP
Program Manager for Regional
  and Environmental Planning
Miami Valley Regional
  Planning Commission
117 South Main St., Suite  200
Dayton, OH  45402

James W. Meek
Acting  Chief, Operations Branch
Water Planning Division  (WH-554)
401 M Street., SW  Rm 811E
Washington, DC  20460

Gordon  L. Mel 1 encamp
208 Program Director
Chattanooga Area Waste
  Management Program
104 City Hall Annex
Chattanooga, TN  37402

Sarah Meyland
Co-Executive Director
N.Y. State Legislative Commission
  on Water Resource Needs of
  Long  Island
43 South Middle Neck Road
Great Neck, NY  11021

David Miller
Partner,
Geraghty and Miller, Inc.
North Shore Atrium
6800 Jericho Turnpike
Syossett, NY  11791
Charles T. Mizell, Jr.
Regional Planner/Valley
  Regional Office
State Water Control Board
P.O. Box 268
Bridgewater, VA  22812

E.J. Monke
Professor
Purdue University
Agriculture/English Department
Purdue University
West Lafayette, IN  47907

Steve W. Monn
208 Project Director
Arkhoma Regional Planning
  Commission
523 Garrison Avenue,
P.O. Box 2067
Fort Smith, AR  72902

Timothy J. Monteith
Water Resources Engineer
Great Lakes Basin Commission
P.O. Box 999
Ann Arbor, MI  48106

Mr. R.A. Moore
Environmental Scientists
  Agency
401 M Street, SW
Washington, DC  20460

Larry Morandi
Project Director
Water Quality Management
National Conference of State
  Legislators
1405 Curtis Street
Suite 2300
Denver, CO  80202

David Moreau
Chief, City and Regional
  Planning Department
University of North Carolina
1601 Fountain Ridge Road
Chapel Hill, NC  27514
                                       193

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Dennis K. Morris
Director of Planning
Crater Planning District
  Commission
P.O. Box 1808
Petersburg, VA  23803

Patricia S. Morris
Program Analyst
U.S. EPA
401 M Street, SW  (WH-554)
Washington, DC  20460

William  Dean Moss, Jr.
Planning Director
Bureau of Water Quality
  Control, Arizona Department
  of Health Services
1740 W.  Adams,
Phoenix, AZ  85007

Larry Mugler
Environmental Services Director
Denver Regional Council
  of Governments
2480 W.  26th Avenue,  Suite  200B
Denver,  CO  80211

James A. Murray
President,
Briscoe, Maphis, Murray
  and Lament, Inc.
2336 Pearl Street
Boulder, CO  80302

Carl Myers
Chief Implementation  Branch
EPA, Water Planning Division
401 M Street, SW  WH-554
Washington, DC  20460
John  Nessel
Water Resources  Planner
Agency of  Environmental
   Conservation
Department of Water  Resources
Montpelier,  VT   05602
Don Niehus
Environmental Protection
  Specialist, Financial
  Management Section
Water Planning Division
U.S.  EPA
401 M Street, SW  WH-554
Washington, DC  20460

Michael P. Nolin
Principal Planner
New Hampshire Water Supply &
  Pollution Control Comm.
Hazen Drive,
Concord, NH  03301

Kenneth Obenauf
Staff Engineer
Georgia State Soil and
  Water Conservation Comm.
P.O.Box 8024
Athens, GA  30603

Gary L. Oberts
Senior Environmental Planner
Metropolitan Council
300 Metro Square
St. Paul, MN  55101

G. Marvin O'Hara
Planner
Fourth Planning &
   Development District
615 South Main Street
Aberdeen, SD  57401

Robert Oros
Planner  II
Broward  County Planning  Council
1600 S.E. 10th Terrace
Ft. Lauderdale, FL  33316

John Ostrowski
Assistant Director of
   Utilities and Engineering
Clark  County, Washington
P.O. Box  5000
Vancouver, WA  98663
                                       194

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Michael O'Toole
Director, Wastewater
  Management Bureau
N.Y. Department of
  Environmental Conservation
50 Wolfe Road, Room 422
Albany, NY  12233

J. Robert Owen
208 Coordinator
Colorado Division of  Planning
1313 Sherman Street
Denver, CO  80203
Alan H. Plummer, Jr.
President
Alan Plummer and Associates,
504 W. Abram
Arlington, TX  76010

Mark C. Possidento
Administrator, Connecticut
  Areawide Waste Treatment
  Planning Board
209 Court Street
P.O. Box 1088
Middletown, CT  06457
Inc.
Jacqueline  Parnell
Environmental  Planner
Hawaii State  Department
  of Health
645 Halekauwila St., 3rd  Floor
Honolulu, HI   96813

John Petersen
Director, Government
  Finance Research Center
Municipal Finance Officers
  Association
1750 K Street, NW
Suite 650
Washington, DC  20006

John W. Peterson
Soil Conservationist
SCS on Detail  to EPA HQ
  Water Planning Division
401 M Street,  SW
Washington, DC  20460

Dick Phillips
Environmental  Engineer
SCS
401 M Street, SW
Washington, DC  20460

Deborah R. Pile
Water Quality Planner
MN. Pollution Control Agency
1935 W. Co.  Rd. B2
Roseville, MN  55113
Angela Preston
NIP Coordinator
Indiana Heartland Coordinating
  Commission
7202 North Shadeland Avenue
Indianapolis, IN  46250

John Promise
Director of Environmental
  Resources
North Central Texas Council
  of Governments
P.O. Drawer COG
Arlington, TX  76011

Al Prysunka
Division Director
Water Quality Evaluation and
  Planning
Department of Environmental
  Protection
State House
Augusta, ME  04330

Robert Purcell
208 Project Officer
Land of the Sky Regional
  Counci1
P.O. Box 2175
Ashville,  NC  28802
                                       195

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Robert Ralsch
Area Director
Southeastern Area
U.S. Forest Service
1730 Peachtree Road,
Atlanta, GA  30309
NW
Mark Rey
National Forest Products Assoc.
1619 Massachusetts Ave., NW
Washington, DC  20036

Walt Rittal
Section Chief
Rural NPS Section
Water Planning Division
U.S. EPA
401 M Street, SW  WH-544
Washington, DC  20460

Dr. Paul Robillard
Support Specialist,
N.Y. State College of
  Agricultural & Life Sciences
Department of Agricultural
  Engineering
Cornell University
Riley-Robb Hall
Ithaca, NY  14853

Lawrence Robinson
Program Coordinator
Department of Environmental
  Quality, Water Quality
  Division
Hathaway Building
Cheyenne, WY  82002

Elnar Roget
Deputy Chief,
State and Private Forestry
Forest Service, U.S.D.A.
P.O. Box 2417
Washington, DC  20013

Charles Rossoll
Ground Water Coordinator,
U.S. EPA, Region I
JFK Federal Building
Room 2203
Boston,  MA  02203
James W. Rudisill
Accountant III
City of Atlanta
68 Mitchell Street
601 City Hall
Atlanta, GA  30303

John H. Runyon
Administrator
Township of East Brunswick
1 Jean Walling Civic Center
East Brunswick, NJ  00816

Dr. Marwan M. Sadat
Assistant Director
Water Quality Management
P.O. Box CN029
Trenton, NJ  08625

Robbi J. Savage
Executive Director
Assistant of State &
  Interstate Water Pollution
  Control Administrators
  (ASIWPCA)
444 N. Capitol Street, NW
Suite 330
Washington, DC  20002
                        Joan Schaum
                        Environmental  Protection
                          Specialist
                        EPA
                        401  M Street,  SW
                        Washington, DC  20460

                        James D.  Sartor
                        Vice President
                        Woodward-Clyde Consultants
                        #3 Embarcadero Center
                        Suite 700
                        San Francisco, CA  94111

                        Douglas  Schneider
                        Environmental  Program
                          Manager
                        Water Quality  Planning Section
                        New Mexico Environmental
                          Improvement  Division
                        P.O. Box  968
                        Sante Fe, NM  87503
                                         196

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Franklin R. Schutz
Principal
Franklin R. Schutz
  Consulting Engineers
P.O. Box 8922
Asherville, NC  28814

Larry Schwartz
208 Project Manager
Waccamaw Regional Planning
  and Development Council
P.O. Box 419
Georgetown, SC  29440

corest Schwengles
State Senator
R.R. Number 2
Box 247
Fairfield, IA  52556

Larry Scully
Manager
Peat, Marwick, Mitchell  & Co.
1990 K Street, NW
Washington, DC  20006
Eugene Seebald
Director,
Division of Pure Waters
N.Y. State Department of
  Environmental Conservation
5 Wolfe Road
Albany, NY  12233
Herbert M. Seely
Financial Officer
Volusia Council of
  Governments
125 E. Orange Ave.,
Daytona Beach, FL  32014

Edward I. Selig
Consultant
7 Ashmont Road
Newton, MA  02168
Ann M. Shafor
Director of Planning
Miami Valley Regional
  Planning Commission
117 South Main Street
Dayton, OH  45402

Ron Sharpin
Environmental Engineer,
Meta Systems, Inc.
10 Hoiworthy Street
Cambridge, MA  02138

Clayton B. Shedrow
SSN 252-74-1301
South Caroline Department of
  Health & Environmental  Control
2600 Bull Street
Columbia, SC  29201

Dr. Philip Shelley
Director, Energy and
  Environmental  Systems
EG&G Washington  Analytical
  Services Center  Inc.
2150 Fields Road
Rockville, MD  20850

David Shepard
Mayor of Oak Park
SE Michigan COG  (SEMCOG)
800 Book Bid.
Detroit, MI  48226

Lynn Shuyler
Chief, Animal Production
  Section
Robert Kerr Environmental
  Research Laboratory
U.S. EPA
P.O. Box 1198
Ada, OK  74820
                                         197

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Linda Simio
Water Quality Planner
Department of Environmental
Quality Engineering
100 Cambridge Street
Boston, MA  02202

Linda M. Simkanim
Planner, Water Quality
Enhancement Section
Water Quality Planning
  Division
Municipality of Metropolitan
  Seattle
821 Second Avenue
Seattle, WA  98104
James Smack
Sales Manager
Luck Quarries,  Inc.
Richmond, VA

Wi Hi am Gary Smith
Environmental Engineer
Moore, Gardner  & Associates,
P.O. Box 14327
Baton Rouge, LA 70816
Inc.
John J. Smith
Water Quality Management Coordinator
U.S. EPA, Region  II
26 Federal Plaza
New York, NY  10007

Dr. Wang H. Smith
Director of Center for
  Environ. & Natural Resources
  Programs
University of Florida
3038 McCarty Hall
Gainesville, FL  32611

Lester Snow
Central Arizona Association
  of Governments
1810 Main Street
P.O. Drawer JJ
Florence, AZ  85232
Madeline Snow
NURP Project Director,
Massachusetts Department of
  Environmental Quality
  Engineering
Levprett Saltonstall Building
100 Cambridge Street
Boston, MA  02202

Robert C. Somers
Assistant Director
Division of Conservation
Department of Natural Resources
  & Environmental Protection
1121 Lousiville Rd.
Pine Hill Plaza
Frankfort, KY  40601

Catherine L. Spain
Economist
Government Finance Research
  Center
Municipal Finance Officers
  Association
1750 K Street, NW
Washington, DC  20006

Kenneth Speicher
Writer/Editor
Environmental Protection
  Agency HQ
WH  554
401 M Street, NW
Washington, DC  20460

Jeffrey Spence
Water Quality Coordinator
Central Florida Regional
  Planning Council
515 E. Boulevard;
P.O. Box 2089
Bartow, FL  33830

Charles Spooner
Environmental Program
  Manager
Development Sciences, Inc.
P.O. Box 144
Sagamore, MA  02561
                                         198

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Dr. J. M. Sprott
Director
Cooperative Extension Service
Auburn University
Auburn, AL  36830

Richard D. Stalker
Director, Environmental Planning
Palm Beach County Area Planning Board
West Palm Beach, FL  33409

Jerry Steinberg
Water Resources Engineer
Water and Air Research
P. 0. Box 1121
Gainesville, FL  32602

Carlos A. Stenneth
Environmental Planner
Houston-Galveston Area Council
3701 West Alabama
Houston, TX  77027

James L. Stokoe
Regional Planner
Land-of-Sky Regional Council
P.O.  Box 2175
Asheville, NC   28802

Timothy  Stuart
Monitoring and  Data  Support
   Division
U.S.  EPA
401  M  Street,  SW WH  554
Washington,  DC   20460

Al Sundquist
General  Manager
   Water  Systems Division
Department  of  Public Works
Government  of  American Samoa
Pago Pago,  A.S.   96799
Jim Sygo
208 Director, East Central
  Michigan Planning and
  Development Region
500 Federal Avenue
Castle Building, 2nd Floor
Saginaw, MI  48606

Jeffrey A. Taylor
Water Resources Planning Engineer
Virginia State Water Control Board
P. 0. Box 11143
2111 N. Hamilton
Richmond, VA  23230

Jimmie R. Taylor
Ark-Tex Council of Governments'
  TAPAC Committee Member
Ark-Tex Council of Governments
P.O. Box 5307
Texarkana, TX  75501

Hugh Teaford
President
Teaford Engineering Association
500 Poplar, Suite 6
Memphis, TN  38117

David Y. Terry
208 Project Coordinator
Mass. Dept. of Environmental
  Quality Engineering
100 Cambridge Street
Boston, MA  02202

Robert Teska
President
Robert B. Teska Associates
627 Grove St.
Evanston, IL  60201

Donald Theiler
208 Coordinator
Wisconsin Department of
Natural  Resources
P.O. Box 450
Madison, WI  53701
                                        199

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Frank I. Thomas
WFL Biologist II
Louisiana Dept. of Natural
  Resources, Water Pollution
  Control Division
P.O. Box 44066
Baton Rouge, LA  70804

Richard Thomasello
Vice President
Airan Consultants, Inc.
120 South Olive Avenue
Suite 706
West Palm Beach, FL  33401

Robert Thronson
Implementation Branch
Water Planning Division
U.S. EPA
401 M Street, SW  WH 554
Washington, D.C.  20460

Myron Tiemens
Office of Water Program Operations
U.S. EPA
401 M Street, SW WH 595
Washington, D.C.  20460

Donovan Tracy
Director of Planning
Department of Planning and
  Community Development
W217 King County Court House
516 3rd Avenue
Seattle, WA  98104

Debbie Treanor
Project Scientist
FX Browne Association
10875 Grandview Suite 2265
Overland Park, KN  66210

Terry Trembly
208 Coordinator
Larimer-Weld Regional Council of Govts.
201 East 4th Street
Loveleand, CO  80295

John W. Tucker, Jr.
Chief, Water Quality Management Section
EPA, Region VIII
1860 Lincoln Street
Denver, CO  80295
John Underwood
Chief, Water Planning
Environmental Protection Agency
1200 - 6th Avenue
Seattle, WA  98101

Don Urban
Nonpoint Source Coordinator
U.S. EPA, Region V
230 South Dearborn Street
Chicago, IL  60604

Brent E. VanMeter
Acting Director, Planning &
  Standards Division
Water Facilities Engineering Service
Oklahoma State Dept. of Health
P.O. Box 53551
Oklahoma City, OK  73152

Helen A. Waldorf
Regional Planner
Montachusett Regional
  Planning Commission
150 Main Street
Fitchburg, MA  01420
Larry Walker
President
Larry Walker Associates,
820 - 4th Street
Davis, CA  95616
Inc.
Richard E. Walker
208 Water Quality Program Manager
Southeastern Utah Assoc. of Governments
P.O. Drawer AI
Price, UT  84501

Robert Walker
Natural Resource Specialist
University of Illinois
330 Mumford Hall
Urbanna, ILL  61801

Thomas D. Walker
Planner Ill/Project Manager
  208 Program
Broward County Planning
  Council
1600 S.E. 10th Terrace
Ft. Lauderdale, FL  33316
                                       200

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John Wander
Principal
Peat, Marwick, Mitchell & Co.
1990 K Street, NW
Washington, D.C.  20006

James B. Warnock
Financial Analyst
City of Atlanta, Department
  of Finance
68 Mitchell Street
Atlanta, 6A  30303

Joan Warren
Office of Intergovernmental
  Relations
U.S. EPA
401 M Street, SW  (A101)
Washington, D.C.  20460

Robert G. Wasp, P.E.
Senior Engineer/208 Project
  Director
Westchester County Health Dept.
  208 Agency
150 Grand Street
White Plains, NY  10601

R.G. Watkins
Assistant Sales Manager
  Georgia
Vulcan Materials  Company
P.O. Box 80730
Atlanta, GA  30366

Pat Watt
Municipal Finance Officers
  Association
1750 K Street,  NW
Washington, DC  20006

Robert C. Weaver
Consultant
Harbridge House,  Inc.
238 Medford Drive
San Antonio, TX   78209

Denise Wehunt
208 Graphics &  Production
  Chief
Chattanooga Area  Waste
  Management Program
104 City Hall Annex
Chattanooga, TN   37402
Forest Westall
Department of Natural and
  Economic Resources
Division of Environmental Management
P.O. Box 27687
Raleigh, NC  27611

Lyman F. Wible
Chief Environmental Planner
Southeastern Wisconsin Regional
  Planning Commission
196 N. East Avenue
P.O. Box 769
Waukesha, WI  53187

Betsy Wigington
Associate Planner
Middle Georgia Area Planning &
  Development Commission
711 Grand Building
Macon, GA  31201

Gary Williams
Chief, Water Quality
  Management Branch
U.S. EPA  Region V
230 South Dearborn Street
Washington, D.C.  20250

James Williams
Deputy Secretary of Agriculture
Office of the Secretary
Administration Building
Washington, D.C.  20250

Robert Williams
Director of Special Projects,
National Association of Conservation
  Districts
1025 Vermont Avenue
Suite 1105
Washington, D.C.  20005

Peter Wise
Deputy Director
Water Planning Division
US EPA
401 M Street, SW  WH-544
Washington, D.C. 20460

Kenneth C. Wiswall
Senior Project Engineer
Roy F. Weston, Inc.
West Chester, PA   19380
                                       201

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Robert L. Wong
Chief Environmental
  Planning Division
Air Force Regional Civil
  Engineer, Eastern Region
526 Title Building
30 Pryor Street, SW
Atlanta, GA  30303

Robert L. Wydra
Director of Planning
Southwestern Illinois Metropolitan &
  Regional Planning Commission
203 West Main Street
Collinsville, IL   62234

Dr. Stephen Yaksich
Chief, Water Quality Section
U.S.  Army Corps of Engineers
Buffalo  District Office
1776  Niagara Street
Buffalo, NY  14207

W. Dean  Yancey
Assistant Director of Water & Sewer
City  of  Ashville
P.O.  Box 7148
Asheville, NC   28807

Douglas  Yoder
208 Project Director
Dade  County Environmental
   Resources Management  Department
090 SE 1st Avenue
Miami,  FL  33131

Ken Young
President
GKY & Associates
Suite 311
Atrium Building
4900  Leesburg  Pike
Alexandria, VA   22302

David Ziegler
Chief,  Policy  Development Section
Water Planning  Division
U.S.  EPA
401 M street,  SW  WH  544
Washington,  D.C.   20460
                                        202

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Rick Arrington
Sales Manager
Davidson Minerals Properties
Gainesville Stone Company  (Coopers)
Gainesville, GA

L. B. Baldwin
Professor of Agricultural  Engineering
University of Florida
3038 McCarthy Hall
Gainesville, FL  32611

John Cain
Chief, Water Quality  Planning
  Section
Wisconsin Department  of
  Natural Resources
Box  7921
Madison, WI  53707

Richard M. Czaplinski
Chief Water Resources  Planner
Agency of Environmental  Conservation
  Department of  Water  Resources
State Office Building
Montpeilier, VT  05602

Dr.  Rick Garrity
Urban Environmental Coordinator
City of Tampa
4th  Floor N.
Municipal Office Building
City Hall Plaza
Tampa, FL  33602

Jeanne Jackson
Aid  to Governor
Office of the Governor
Little Rock, ARK 72201
Joseph P. Kirk
Senior Planner/208 Coordinator
S.C. Appalachian Council of Governments
Drawer 6668
Greenville, SC  29606

Robert A. Kull
Mercer County Planning Division
Trenton, NJ

Peggy D. McNeill
Chairman
Mercer Company/208 PAC
39 Linwood Circle
Princeton, NJ  08540

Lydia Moreda
Project Manager
Tampa Urban Runoff Study
Department of Public Works
City of Tampa
4th Floor North, City Hall Plaza
Tampa, FL  33602

W. H. Mull
Engineer-Manager
Metropolitan Sewerage District
  of Buncombe County
P. 0. Box 7157
Asheville, NC  28807
                                        203
                                                         *U.S.,GOVEBNMENT PRINTING OFFICE:1981 341-082/204

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