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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) ------- OPENING DAY ADDRESSES ------- 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. ------- 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. ------- 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. ------- 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? ------- 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. ------- 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; ------- 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. ------- 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?) ------- • 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 ------- 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 ------- 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. 12 ------- 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 ------- • 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 ------- I LUNCHEON ADDRESSES 15 ------- 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: 16 ------- "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 ------- 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 ------- 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 ------- 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 ------- "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. 21 ------- 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 ------- 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 ------- 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 24 ------- I POLICY FORUMS 25 ------- 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 ------- 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 ------- 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. 28 ------- 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. 29 ------- 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. 30 ------- 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; 31 ------- • 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. 32 ------- 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 ------- 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 ------- 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). 35 ------- 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 ------- 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. 37 ------- 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. 38 ------- 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. 39 ------- 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. 40 ------- 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. 41 ------- 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). 42 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- • 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 ------- 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 ------- 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. 51 ------- 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 ------- 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 ------- 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 ------- NATIONWIDE URBAN RUNOFF PROGRAM I 55 ------- 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 ------- 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 ------- 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. 58 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 65 ------- • 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. 66 ------- 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. 67 ------- 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. 68 ------- 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. 69 ------- 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. 70 ------- 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 71 ------- 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 72 ------- 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. 73 ------- AGRICULTURE PROGRAM 75 ------- 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 85 86 76 ------- 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 77 ------- 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). 78 ------- 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. 79 ------- 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 80 ------- 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. 81 ------- 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. 82 ------- • 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. 83 ------- 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. 84 ------- 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. 85 ------- 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. 86 ------- 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. 87 ------- 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. 88 ------- 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. 89 ------- 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. 90 ------- 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. 91 ------- 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. 92 ------- 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. 93 ------- 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 ------- 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. 95 ------- 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. 96 ------- • 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 ------- GROUND WATER PROTECTION PROGRAM 99 ------- 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 100 ------- 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 ------- 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. 102 ------- 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. 103 ------- 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. 104 ------- 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. 105 ------- 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. 106 ------- 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. 107 ------- 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. 108 ------- 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. 109 ------- 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 110 ------- 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, 111 ------- 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. 112 ------- 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. 113 ------- 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 114 ------- • 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 115 ------- 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. 116 ------- 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. 117 ------- 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. 118 ------- 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. 119 ------- FINANCIAL MANAGEMENT ASSISTANCE PROGRAM 121 ------- 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 ------- 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 139 139 139 140 123 ------- 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. 124 ------- 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 125 ------- 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. 126 ------- 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. 127 ------- 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. 128 ------- 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? 129 ------- 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. 130 ------- 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. 131 ------- 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. 132 ------- 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). 133 ------- 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. 134 ------- 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. 135 ------- 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 ------- 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. 137 ------- 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 ------- 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 ------- 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 ------- FACILITY PLANNING AWT PROGRAM I 141 ------- 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 ------- 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 ------- 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. 144 ------- 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. 145 ------- 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: 146 ------- 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. 147 ------- 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. 148 ------- 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 149 ------- 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, 150 ------- 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. 151 ------- 152 ------- SILVICULTURE AND CONSTRUCTION PROGRAMS I 153 ------- 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 161 162 154 ------- 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 155 ------- 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 156 ------- 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. 157 ------- 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. 158 ------- 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. 159 ------- 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 160 ------- 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. 161 ------- 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. 162 ------- 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: 163 ------- * 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. 164 ------- 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) 165 ------- • 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. 166 ------- CLOSING REMARKS 167 ------- 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 ------- 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 ------- EVALUATION SUMMARIES I 171 ------- 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 ------- 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 ------- 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 ------- • 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 ------- » 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 ------- « 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 ------- 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 ------- CONFERENCE ATTENDANTS (NAMES AND ADDRESSES) 179 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- |