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TABLE 1
LISTING OF CANDIDATE MITIGATION MEASURES
CATEGORY 1: CHANGES TO THE WASTEWATER FACILITY
1.1 Reduction in Capacity of the Wastewater
Treatment Plant
1.2 Reduce Capacity of Collection System
1.3 Increase Capacity of Wastewater Treatment
Plant to Accomodate High Density Growth in
Areas Where Air Quality Can Accomodate It
1.4 Reduce Service Area By Shortening Interceptors
or Eliminating Spurs or Segments
1.5 Stage Construction of Treatment Plant or
Collection System
1.6 Disallow Non-Eligible Excess Capacity in
Collection System
1.7 Change Pattern of Collection System
1.8 Use Alternative Treatment Technology
CATEGORY 2: LAND USE STRATEGIES
2.1 Require Development of Comprehensive Local
Development Plans
2.2 Sewer Tap Allocations and Use Restrictions
2.3 Zoning Controls on High Emissions Industries
2.4 Encourage (Require) Concentrated Growth
2.5 Coordination of Housing and Transportation
Planning
2.6 Use of Buffer Zones (Special Area Protection)
2.7 Performance Controls on Development
2.8 Rp^pyi i arp C o n s isjt^iut—R&gJ..OBg'wr^e^.EQ.pu 1 a t ion««\
Seajgctions _
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TABLE 1
LISTING OF CANDIDATE MITIGATION STRATEGIES
(Continued)
2.9 Collateral Growth Policy Agreements with
Adjacent Communities
2.10 Plan Streets and Roads to Reduce Vehicle
Travel
2.11 Statements from Developers Regarding In-
direct Sources
2.12 Dispersion of New Sources
2.13 Capital Investment Programs
2.14 Short and Long Range Annexation Plans for
Defined Urban Service Areas
2.15 Detailed Planning of Regional Activity
Centers
2.16 Coordination of Federal Housing Financing
to Favor Air Quality Goals
CATEGORY 3: EMISSIONS REDUCTIONS
3.1 Emissions Controls on Stationary Sources
3.2 Auto Emissions Inspections and Maintenance
3.3 Local General Purpose Anti-Air Pollution
Programs
'3.4 Public/Private Transportation Programs
3.5 Auto Use Disincentives
3.6 Street Cleaning
3.7 Emission Density Zoning
3.8 Economic Development Policies
3.9 Emergency Powers
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TABLE 1
LISTING OF CANDIDATE MITIGATION STRATEGIES
(Continued)
CATEGORY 4: OTHER RELATED MEASURES
4.1 Annual (Incremental) Dispersement of
Funds
4.2 Air Quality Monitoring
4.3 Planning Support
4.4 Requirements for Regional Planning
Coordination
4.5 Progress Reporting on Air Programs
4.6 Changes in Effective Grant Ratios
4.7 Direct Grants to General Purpose Govern-
ments
4.8 Indirect Source Review for Wastewater
Facilities
4.9 Modify Environmental Review Procedures
4.10 Marginal Cost Pricing of Utilities
4.11 Program Monitoring
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1.0 CATEGORY 1: CHANGES TO THE WASTEWATER FACILITY
1.1 Reduction in Capacity of the Wastewater Treatment Plant
Description: This measure is generally formulated as the
maximum capacity (or _flow in million gallons per day) into a
wastewater treatment facility for which EPA will provide funding.
It is usually imposed by EPA Regional Offices directly upon the
grant applicant, after an evaluation of population projections
used in the Facilities Plan (Step 1) and after the cost effec-
tiveness analysis of each alternative.
For example, the facility plan developed for the Falling
Creek Wastewater Treatment Facility in Chesterfield County,
Virginia called for the expansion of an existing facility from
6 mgd to 12 mgd. An EIS that reevaluated the population projec-
tions, water consumption figures was done. No cost savings were
found for the 6 mgd expansion over two 3 mgd expansions. While
the cost differential was slight, the potential burden to tax-
payers of not realizing the higher flows through rapid growth
was found to be significant. The conclusion of this analysis
was to fund a 3 mgd expansion of the existing plant. This would
allow an evaluation of the need for the additional 3 mgd half-way
through the planning period. If the higher growth projections
materialize, then the plant can be expanded. However, no commit-
ment was made by EPA to the future expansion.
In Monterey, California*, the planned capacity of a regional
wastewater treatment plant was reduced from 26 mgd to 22 mgd,
based upon the findings that the original capacity would permit
an increase in sewered population within the service area that
would in turn increase vehicle travel and point source air pol-
lution in excess of ambient air quality standards. This reduc-
tion in capacity in effect should act to limit the maximum sewered
population, and thus VMT.
*North tMonterey County Facility Plan, prepared by -the Mont-
erey Peninsula Water Pollution Control Agency (August 1977).
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Both of these examples show reductions in plant capacity
imposed as the result of the fall EIS process. However, this
mitigation measure may also be negotiated with the grant appli-
cant after the preparation of an environmental assessment. If
successfully negotiated, a negative declaration is issued, allow-
ing the project to proceed with detailed design of the scaled-
down facility.
Technical Effectivenessg To the extent that the availabili-
ty of treatment plant capacity is a critical factor in limiting
development (and thus maintaining air quality)j a unit on excess
capacity at a new or expanded facility is presumed to limit the
amount of development that can occur within the service area.
In turn, this should limit the potential impact on air quality
within the service area. However, there do not seem to be any
follow-up studies of any of the service areas in which this mit-
igation measure has been imposed.
Implementability: This mitigation measure is relatively
simple to implement. The criteria that EPA can use in the eva-
luation are established in the cost-effectiveness analysis guide-
lines*, and are generally based on the reasonableness of population
and flow projections used in the analysis and the potential bene-
fits of staging the construction. New draft regulations published
under the 1977 Clean Water Act are much more specific in terms
of defining "reasonableness" and appropriate staging periods.
These new procedures should make decisions on the amount of cap-
acity to be funded less discretionary, and easier to implement
in the future.
Administration: The attractiveness of plant capacity reduc-
tion as a mitigation measure is that it is relatively easy to ad-
minister. It is a measure that is imposed early in the facilities
planning process, before resources have been extensively committed
*40 CFR 35.9 Appendix A.
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to a larger project. Enforcement is also relatively simple, as
the measure is one way of determining the size of the federal
grant for a particular project, applicants have the right to
build additional capacity, although at their own expense. EPA's
staff time involved in implementing this measure is marginally
small, as the analysis is done for every project. Additional
time may be required where extensive negotiations as to the most
cost-effective capacity are required. This should be increasing-
ly rare as the criteria for determining the most cost-effective
capacity are tightened.
Social and Economic Impacts: Generally unknown, as no mon-
itoring has been attempted.
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1.2 Reduce Capacity of Collection System
Description: This measure has been used for projects that
involve only an expansion of a facility's collection system.
It is similar to the reduction in treatment plant capacity both
in effect and in the way it is implemented.
For example, in Rockaway Valley, New Jersey, the capacity of
a proposed interceptor reconstruction project was limited based
upon an assessment of population projections used in the facility
plan analysis. Capacity was reduced to allow the interceptor to
serve only population expected in the service area until a new
(or expanded) treatment facility comes on-line. The area is
already under a building ban; the tight allocation of reserve
capacity was seen as a way to ensure protection of public drink-
ing water supplies and protect environmentally sensitive lands
from over-development.
Technical Effectiveness: As with the reduction in treatment
plant capacity described above, this measuer should at least lim-
it the ability of the collection system to induce growth that
can lead to secondary air quality impacts. However, in areas
where demand for development is high, the air quality in sur-
rounding communities may suffer due to increased VMT as low
density development with on-site systems becomes the only accep-
table form of development. However, monitoring data is not
available for this measure, so the actual technical effective-
ness is not known.
Implementability: This measure is implemented in the same
way as the reduction in treatment plant capacity described above.
Administrative Costs: Same as for the reduction of treat-
ment plant capacity.
Social and Economic Impacts: Due to the lack of monitoring
data, these are unknown at present.
10
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1.3 Increase Capacity of Wastewater Treatment Plant to Accomodate
High Density Growth in Areas Where Air Quality Can Accomodate
It
Description: This measure is being considered for implemen-
tation in the Aliso Water Management District in California. It
is the result of a study of VMT resulting from a grant condition
restricting flows into the Aliso facility imposed in February,
1977. The study found that VMT increases could range from 4%
to 33%, as local demands for housing could only be met through
decentralized new construction outside of the facility's ser-
vice area. By allowing unrestricted flows to the facility, high-
er density development can be permitted in the service area, and
VMT increases can be minimized.
The original mitigation measure (flow restrictions) was
imposed by California's State Water Resources Control Board as
a condition of approval for construction grants funds for the
facility. The condition specified that the flow restrictions
shall remain in place for five years unless adverse air quality
impacts resulting from the condition are demonstrated.
Technical Effectiveness; As a new grant condition (or
the removal of the flow restrictions) has not yet been imposed,
the technical effectiveness of this measure cannot be assessed.
Implementabi1ity: In a narrow sense, this condition could
be simple to implement, as it is basically a "non-action", as
the agency would refrain from imposing flow restrictions. How-
ever, this runs contrary to local growth objectives, and detailed
management strategies may have to be negotiated with communities
who are members of the wastewater management district.
Administrative Costs: This measure is the result of a
detailed analysis of housing market conditions in the Aliso
facility's service area and in areas not served both within and
without Orange County. The analysis had to first determine
VMT and the resultant air quality impact associated with three
residential development scenarios. This was then compared to
11
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VMT expected from unconstrained development. Another type of
administrative cost has been that involved in the reversal of
a decision to impose flow restrictions on this facility: staff
time for the initial analysis of impacts and for negotiating
the first grant condition as well as the second should be in-
cluded.
Social and Economic Impacts: As the measure has not yet
been implemented, no information on social or economic impacts
upon area households and firms is available.
12
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1-4 Reduce Service Area By Shortening Interceptors or Elimina-
ting Spurs or Segments
Description: This measure has been used in several areas
as a method of reducing the potential of a facility for inducing
growth. In the case of Block Island, Rhode Island, the measure
was imposed to minimize the impact of development upon land over
the Island's major drinking water aquifer and wetland. Types of
development that could potentially be induced included resort
complexes, high density condominium developments, and medium
density (single family housing on 1-acre lots) development on
these sensitive areas. The measure took the form of a condition
on the proposed facility's Step II/III grant, following the
findings of an EIS. The condition prohibited discharges to the
collection system from wetland areas as defined by Rhode Island
law, and generally supported growth objectives as outlined in
the island's comprehensive plan and zoning ordinance.
In another case, an interceptor spur serving an area developed
at relatively low densities near Ocean City (Maryland) was elim-
inated from a facility plan involving the expansion of the area's
treatment plant, the construction of an additional plant and the
expansion of the interceptor system. In this shore area, the
induced development from the facility as originally designed was
expected to exacerbate traffic congestion on the highways and
bridges leading to the resorts, and to tax the existing water
supply system in the area. The area eliminated from the collec-
tion system was the least densely developed land within the
service area (i.e., it was zoned for development densities of
less than ten people per acre). This measure was implemented
by EPA during the relatively early planning phases of this
facility project.
Technical Effectiveness: like reductions in capacity of
treatment plants and collection systems. This mitigation meas-
ure would appear to limit the collection system's potential for
inducing development. However, its true technical effectiveness
13
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may depend on the grantee's ability in the long run to maintain
service area boundaries that are smaller than the hydrologic
drainage basin that the system is located within. As long as
capacity is available at the treatment plant, it is technically
possible to extend conventional gravity sewers anywhere within
the hydrologic service area. Where development pressures are
sufficinetly high, political pressure may be brought to bear
upon the grantee, a political entity. Data on the true techni-
cal effectiveness of this measure does not appear to be available.
Implementability: As with the capacity reduction measures,
this type of mitigation is usually negotiated with the grantee
in the early stages of the planning process as the environmental
and economic impacts of the original plan first become evident.
Adminsitrative Costs: same as for capacity reduction miti-
gation measures.
Social and Economic Impacts: In theory this measure should
eliminate some typical economic impacts of building wastewater
facilities, as service would not be proviced to the less densely
developed areas which are more costly to serve. Moreover, there
is no monitoring data available to base an assessment of actual
impacts upon.
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1.5 Stage Construction of Treatment Plant or Collection
System
Description: Under the current cost effectiveness regulations,
shorter staging periods for plants and collection systems are
already being mandated. Standard planning periods are expected
to be 10 years for treatment plants, 20 years for collection
systems. Phasing of systems has aspects of both a mitigation
measure and an enforcement technique.
As a mitigation measure, it operates to decrease the amount
of reserve capacity of a system at any one time, thus putting
the brakes on accelerated development when the interim capacity
is (prematurely) reached. It allows more balanced regional
growth in that the distortions it might impose on the land market
can be minimized over the long term.
As an enforcement took, it gives EPA leverage of grantee
performance when the grantee returns for money to fund the second
phase of a project. This is increasingly the policy in Region
VIII, for one.
Technical Effectiveness: Shorter staging periods appear to
be an effective way to increase the efficiency of facility design.
Since the reserve capacity of systems built is reduced, so too
is the potential for secondary impacts. Additional planning
reliability is gained by the process since, when environmental
reviews of the second phase are conducted, actual secondary air
guality impacts associated with the first stages can be monitored.
Implementability: The trend to shorter phasing periods is
already well under way. Potential additional costs to grantees
are supposedly fully considered under the cost effectiveness
regulations.
Administrative Complexity: This measure is administratively
simple to implement, since it is effected largely by standardized
cost effectiveness calculations procedures.
Social and Economic Costs: Minimal.
15
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REFERENCES
Cost Effectiveness Regulations (Appendix A).
EPA. Urban Program Iniatives, "Analysis of New
Program Initiatives: Construction Grants Program
Modification Options to Minimize Sprawl." DRAFT.
March 1, 1978.
USR&E, Interceptor Sewers and Suburban Sprawl,
Lexington Books, 1976.
16
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1.6 Disallow Non-eligible Excess Capacity in Collection
System
Description: Under the cost-effectiveness regulations
(Appendix A, part 10), additional capacity beyond the cost effec-
tive capacity ("excess capacity") may be built at the community's
expense. However, Part 10(c) states specifically:
"The entire proposed project to be built shall be
assessed and determinations must be made that it is
in compliance with the National Environmental Policy
Act and all other applicable laws, regulations and
guidance. Particular attention should be given to
assessing the potential secondary environmental effects
of the project and to ensuring that air quality stan-
dards will not be contravened. The discharge of the
entire project must not cause violations of water
quality standards."
This mitigation measure, therefore, can be considered to be vir-
tually already in effect.
Technical Effectiveness: The technical effectiveness of this
measure is dependent on the quality of the impacts analysis con-
ducted on the facility plans. The measure will fail if the
community decides ultimately to fund an entire project by itself,
although that community would still have to apply for an NPDES
permit, which itself might be denied on environmental grounds
having to do with secondary effects. Ambiguity may exist where
NPDES authority has been delegated to the states: it has not been
resolved whether NEPA requirements apply to such state-level
permit reviews, and under some state environmental procedures,
environmental reviews of NPDES permits may be limited to water
quality effects only.
Implementability: This measure will be easy to implement.
The only instance in which it might fail has been alluded to
above.
17
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Administrative Complexity: The measure imposes burdens on
EPA to demonstrate that the environmental effects of the proposed
excess capacity will be significantly adverse.
Social and Economic Impacts: Uncertain.
18
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REFERENCE
Cost Effectiveness Guidelines.
19
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1-7 Change Pattern of Collection System
Description: Changing the pattern of an extensive collector
system results in changed land use patterns, as different parcels
of land are opened for development. In turn, this can result
in changes to both the distribution and the intensity ov air
pollution emissions. Changes in the distribution of emissions—
from both stationary and mobile sources—can result in changes
in ajnbient air quality due to differential absorption and dil-
ution of pollutants by land and winds. Changes in the intensity
of pollution emissions are associated with different road lengths
(which influence total VMT), and perhaps different development
intensities.
Technical Effectivness: The use of buffer zones, both to
dilute and absorb air pollution, is discussed under 2.7; it
can be an effective measure. However, the sensitivity analysis
of the Denver regional EIS failed to demonstrate significant
benefits accruing to changed patterns of facilities—and this
study dealt with the largest, and therefore presumably most
critical, regional development scale. A second and more soph-
isticated sensitivity analysis is being conducted for the new
versions of the Denver SIP; this may show more significant
benefits. It appears that modification of the patterns of single
201 projects may either have no significant effects on air pollu-
tion, or that the effects will be exceedingly difficult to model
convincingly.
Implementability: This measure appears difficult to imple-
ment, although we have come across no conscious use of it to
affect secondary air quality effects. Not the least problem,
as far as conventional systems go, would be conflicts between
terrain (which dictates much of the design of gravity flow
systems) and meteorological considerations.
Administrative Complexity: It appears to us that the
burden of analysis on EPA regional offices may be extensive,
20
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and that the demands on grantees might be severe, both in terms
of alternatives development (creating alternative municipal
development plans) and in terms of engineering expenses.
Social and Economic Impacts: These could be significant,
since the alternative development patterns could result in shifts
in benefits (increased land values) and costs (different costs
of servicing alternative areas). Analysis would have to be
specific to each project.
21
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REFERENCES
Denver E.I.S. and supporting sensitivity analysis.
22
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1.8 Use Alternative Treatment Technology
Description: Secondary impacts may occasionally be justifica-
tion for the use of an alternative technology with fewer growth
inducing features. Under the current cost effectiveness guide-
lines, alternative technologies must be explored. Conceivably,
if a Step 1 plan for a conventional system were to be evaluated
as having unacceptable environmental impacts by reason of second-
ary growth impacts, a broad reading of the phrase "cost effective"
could then be taken to include external social and environmental
costs, which, even if unquantifiable in whole or in part, might
point to the use of a different technology. At present, alterna-
tive technologies are also permitted 15% leeway in comparing costs
between themselves and conventional systems.
Technical Effectiveness: Given a situation where the alter-
native is technically possible, it may offer considerable benefits
in terms of reducing secondary growth.
Implementability: The prime issue here will be local responsi-
bilities and costs under the alternatives option, especially re-
garding long term operations and maintenance costs. Often alterna-
tive technologies offer lower operating costs, which should make
them attractive. Implementability of this option will vary from
situation to situation.
Administrative Complexity: Under the grant regulations,
alternative technologies must be explored where they are techni-
cally feasible. Assuming that such a feasibility analysis has
therefore been done by the engineer, much of the administrative
burden of evaluation will be taken care of. It would remain for
EPA to conduct new evaluations of the cost effectiveness of the
alternatives, with additional weight given to quantifiable and
unquantifiable social and environmental costs. How such evaluations
would fit into the guidebook produced under this contract is
complex, given overlapping evaluations in other contexts.
23
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Social and Economic Impacts: Impacts of alternative techno-
logies may be complex. Separate guidance materials being prepared
by EPA may cover these impacts in detail.
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2-0 CATEGORY 2: LAND USE STRATEGIES
2.1 Require Development of Comprehensive Local Development
Plans
Description: The Valley Forge EIS required the grantees,
as a direct condition, to:
o review and revise as necessary its comprehensive
land use planning effort to insure that the growth
inducement effects of the new sewer facilities are
taken into account and that the revised plans are
consistent with Federal, state, and local environ-
mental regulations such as Federal and state air and
water quality standards and the Pennsylvania Consti-
tutional Amendment of Environmental Rights...
o adopt and administer whatever ordinances are neces-
sary to implement the revised comprehensive plan...
o revise its portion of the 537 Sewage Facility Plan
to be consistent with the revised comprehensive plans
and set out a pattern of orderly community develop-
ment. Revised 537 Plans will be locally coordinated
and submitted to DER for approval.
In addition, detailed planning guidelines were proposed to coun-
ter the projects expected impacts, which included the probable
violation of particulate, carbon monoxide, and sulfur dioxide
standards. The measures proposed were tailored to the local
situation, but they are consistent with the general approaches
outlined elsewhere in this catalog. The critical point is the
grant's mandate of action in a situation where the locality
traditionally has complete discretion.
Thie approach should be contrasted to what happened in Beth-
any Beach, Delaware. Here, in the absence of a local comprehen-
sive plan, the EIS in effect appropriated the function: a con-
dition was attached to the grant which limited development in the
area to the maximum implicit in the current zoning:
Recognizing the impact statement to be a finite document and
in the absence of a current comprehensive land use plan
for the project area the current zoning classifications
in effect at the time of the release of this Supplement
are accepted as the basis for the Greater Bethany Beach
Sewerage System.
25
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This position by EPA was controversial, since it permitted con-
siderable growth in the area. The secondary effects of this
growth were feared by a number of residents, but Region Ill's
response was to inform the public that it could not challenge
the population projections implicit in the zoning, since to do
so would be to interfere with a local prerogative. Consequently,
local plans were enacted that took into, account the sensitivities
of certain areas vulnerable to fast growth (namely the beaches),
and revised downward the growth estimates inherent in the grant
condition.
The earlier model of Valley Forge was preferred over the
confusion of the Bethany Beach case in the Falling Creek facility
in Chesterfield County, Virginia:
EPA has maintained that special provisions must be taken
to assure that growth in the Swift Creek Watershed be man-
aged to minimize its deleterious effect upon the existing
conditions in both the Watershed and the Reservoir itself.
This commitment has evolved into the preparation of a model
"Swift Creek Watershed Management Plan", including basic
guidelines to be incorporated by the County.
The adoption of a County-developed management plan, including
the following minimum requirements, will be required as
a condition of the Step II grant award.
While this measure does seem to blur the integrity of local
prerogatives in land use planning, it does seem to offer a con-
venient response to a sticky problem. The ultimate question,
however, is the enforcement of the plans that are developed.
Technical Effectiveness: The guidelines proposed under
these examples included many of the standard measures to control
growth suggested later in this catalog. The ultimate effective-
ness of the planning requirements per se depends entirely upon
the implementation of the measures it contains. The wording
of the Valley Forge grant condition, with its requirement for
the adoption of ordinances developed under the plan, and for the
revision of facility plans to be consistent with them, appears
to be a strong approach.
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Implementability: The implementability of this measure
depends on local resources for the planning effort. If grant
funds were made available under Step 1, this could be expedited.
The ultimate implementation question remains the enforcement of
the plan itself.
Administrative Complexity: EPA's role in enforcing local
compliance with locally generated, but federally required, plan-
ning efforts, may be a difficult one. Commitment to oversight
of local performance would have to be long term.
Social and Economic Impacts: These impacts would be assoc-
iated not so much with the planning process itself as with the
contents of the plan. Given the guidelines contained in the
EIS's referenced above, this content would be controversial in
many situations.
27
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REFERENCES
Draft E.I.S.: Upgrading and Expansion of the Falling Creek
Wastewater Treatment Facility. Chesterfield County, Vir-
ginia. Prepared by U.S. E.P.A., Region III. August 1975.
Final E.I.S.: Upgrading and Expansion of the Falling Creek
Watewater Treatment Facility. Chesterfield County, Vir-
ginia. Prepared by EPA, Region III. March, 1975. Sections
outlining Swift Creek Watershed Management Plan.
Synopsis. Valley Forge Wastewater Treatment Facility.
Chester County, Pennsylvania. Prepared by U.S. E.P.A.,
Region III. September 1974.
Valley Forge Wastewater Treatment Facility, Chester County,
Pennsylvania. Final E.I.S. Prepared by U.S. E.P.A., Region
III. September 1974.
Mitigating Secondary Impacts From the Wastewater Facilities
program: An EPA Case Study Series. Prepared by the
Office of EPA Land Use Coordination. April 1977.
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2.2 Sewer Tap Allocations and Use Restrictions
Description: Sewer tap allocations or sewer use restric-
tions reduce or otherwise control secondary land use changes
by limiting access to the sewerage system. In Steamboat
Springs, Colorado, the issue was regionalization:
In accordance with the expressed wishes of the Routt
County Commissioners, an outfall tap restriction will be
instituted prior to the issuance of Step 3 grant funds.
This will limit access to the regional plant interceptor
line and prevent growth inducement inconsistent with
community goals.
This grant condition shall read as follows:
The secondary effluent transmission line or outfall
line between the existing lagoon system and Midway
site shall be restricted so as to prevent future con-
nections within the present unincorporated areas of
Routt County and areas outside the present boundaries
of the existing sanitation districts as of the date
of this grant... The above restriction shall apply
for a period of ten years or until Phase II expansion
is undertaken, whichever occurs first. The City of
Steamboat Springs shall take all legal means available
to implement this restriction.
Other sewer tap restrictions are now being advocated throughout
Region VIII as a means to control the growth inducing effects of
201 facilities, particularly in the interim period until regula-
tions under section 316 of the Clean Air Act are approved. These
use restrictions will spell out the number of taps to be awarded
annually, though the basis on which they are awarded is largely
open to local discretion, to the best of our knowledge.
Technical Effectiveness: Tap restrictions appear to be
powerful controls over land development in areas where sewer
availability is critical (alternative technologies are not in
use) .
Implementability; More data required for evaluation.
Administrative Complexity; From EPA's viewpoint, the
measure seems convenient to implement. Review of local sewer
29
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tap plans for legal and technial adequacy does not appear bur-
densome once general guidelines are developed.
Social and Economic Impacts: The purpose of the sewer tap
allocation is apparently to keep growth rates within predicted
(or traditional) bounds. As such, its impacts might be consid-
ered neutral. In practice, however, the measure is intended to
keep a brake on run-away development, which might be interpreted
negatively by local development interests.
30
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REFERENCES
Final EIS. Steamboat Springs Regional Service Authority
201 Wastewater Facilities Plan. U.S. E.P.A., Region III.
August 1977.
Mitigating Secondary Impacts from the Wastewater Facilities
Program: An EPA Case Study Series. Prepared by the Office
of EPA Land Use Coordination. April 1977.
31
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2.3 Zoning Controls on High Emissions Industries
Description: This approach has been suggested by Anderson-
Nichols in Environmental Assessment Manual—Wastewater Facilities,
but we have not been able to document it in the field. In general,
local controls over high emissions industries could be enacted
under zoning to counter any possible tendency of secondary growth
induced by 201 facilities to bring in unregulated new sources.
Technical Effectiveness: This seems theoretically to be
an effect control.
Implementability: Political opposition to any measure tha
would tend to reduce local economic growth seems likely. The
measure could be of use in PSD regions where local metropolitan
conditions make the community especially sensitive to relatively
small-scale emitters who might not be regulated by new source
performance standards under the Clean Air Act.
Administrative Complexity: Assuming that standardized
approaches could be worked out, this measure appears to require
little effort on EPA's part to oversee.
Social and Economic Impacts: These are the crux of the
problem. Few communities are likely to be willing to put
restrictions on incoming industry above and beyond those already
in force under the Clean Air Act.
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REFERENCES
Anderson-Nichols, Environmental Assessment Manual—Waste-
water Facilities. Prepared for EPA Region I, Boston,
Massachusetts. June 1978.
33
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2.4 Encourage (Require). Concentrated Growth
Description; Communities can concentrate new growth through
infrastructure development and zoning. By concentrating growth (e.g.,
limiting single family homes), the community will reduce total VMT.
Other methods of concentrating growth include cluster zoning,
PUD's and TDK's.
Concentrating growth to improve air quality is being used
in many communities including Simi Valley and Livermore-Amador
Valley, California.
Technical Effectiveness: Concentrating growth is effective
at reducing VMT. Where VMT is less of a factor (e.g. an indus-
trialized urban area) in overall air quality, concentrating growth
may not be applicable.
Implementability: Many of the institutional tools that can
be used to concentrate already exist. These include highway
development, new interceptors, and zoning controls. Implementa-
tion of a plan including concentrated growth is relatively easy.
Administration: As with results of many land use policies,
once the policies have been adhered to, there is little overt
administration needed.
Social and Economic Impacts: The social and economic impacts
resulting from concentrated growth per se are often negligible.
Related factors such as lack of open space can cause social ten-
sion, however.
34
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REFERENCES
Anderson-Nichols, Environmental Assessment Manual-
Wastewater Facilities, Prepared for U.S. Environmental
Protection Agency - Region I, Boston, 1978.
Draft Environmental Impact Statement on the Proposed
Wastewater Management Program for Livermore-Aniador
Valley, Alameda County, California, U.S. Environmental
Protection Agency, San Francisco, 1975, p. 4-99.
Environmental Carrying Capacity Case Study of Grand
County Area, Colorado, U.S. Environmental Protection
Agency, Denver, 1976.
Final Air Quality Maintenance Plan, Simi Valley County
Sanitation District.
Post-EIS Evaluation of the Bethany Beach Regional
Wastewater Treatment Plant, Sussex County, Delaware,
1972, p. 14.
Real Estate Research Corporation. The-Costs of
Sprawl. Prepared for the U.S. Council on Environmental
Quality, U.S. Department of Housing and Urban
Development and U.S. Environmental Protection Agency,
1974.
Urban Systems Research and Engineering, Inc. The
Growth Shapers. Prepared for the Council on
Environmental Quality, Washington, DC, 1976.
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2.5 Coordination of Housing and Transportation Planning
Description: VMT can be reduced by planning development
around public transportation. For example, Northglenn, Colorado
is installing new sewer taps in patterns that conform with future
proposed transit systems.
Effectiveness: The effectiveness of this measure will be
similar to the success of any mass transit system. In other words,
if planning development around public transit actually encourages
use of that public transit, then VMT will be reduced.
Implementability: No great obstacles are likely to slow coor-
dination of housing development and public transportation. How-
ever, raising the large amounts of capital necessary to construct
public transit may prove difficult. One method for such financing
was proposed in Contra Costa, California: charge housing developers
a per unit fee to support local transit development.
Administration: Here also administering a program of develop-
ment—transportation coordination should not prove difficult.
Assuring the proper initiation and operation of any sort of transit
system presents administrative problems of its own.
Social and Economic Impacts: Such a system of development
would have minimal social and economic impact.
Comments: In order to be even worthy of consideration as an
air quality measure, any plan for housing-transit coordination
must include advanced plans detailing how proposed transit system
will be initiated, financed, and operated.
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REFERENCES
Real Estate Research Corporation, The Cost of Sprawl,
Prepared for the Council on Environmental Quality,
the U.S. Departemtn of Housing and Urban Development
and the U.S. Environmental Protection Agency, 1974.
Planning Environment International, Central Contra
Costa Sanitary District Wastewater Treatment Facility
Expansion: Secondary Air Quality Impacts and
Mitigation Analysis, Prepared for J.B. Gilbert S
Associates, Inc., August 1975, p. 159.
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2.6 Use of Buffer Zones (Special Area Protection)
Description: Use of buffer zones will enhance air quality
in two ways. First, it will limit and/or concentrate develop-
ment and second, such zones serve as "sinks" for air pollutants.
Northglen, Coloardo and Livermore - Amador Valley, California,
are two areas making use of buffer and agricultural lands to
control air pollution.
Effectiveness: The use of buffer zones entails aspects of
many other mitigation measures (see 2.1, 2.5, 3.7). While many
of those measures are unproven, one study maintains that agri-
cultural land in Northglen, Colorado not only serves as a dis-
persion area for pollutants but also absorbed CO out of the
atmosphere.
Implementability: Assuming that the open space exists at
the outset, implementing such a control measure should not
present any major problems.
Administration: Administering this strategy requires
little effort once the buffer zones have been established. Future
political and economic pressures may make maintenance of open
space difficult, however.
Social and Economic Impacts: Creation of buffer zones
limits the use of large parcels of land. As a result, overall
land values can be expected to increase. Current land owners
will benefit from this trend while those seeking to develop
land near buffer areas will be forced to pay increased costs.
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REFERENCES
Draft Environmental Impact Statement on Proposed Waste-
Water Management Program for Livermore - Amador Valley,
Alameda County, California, U.S. Environmental Protection
Agency, San Francisco. 1975, p. 4-99.
Sheaffer and Roland, Inc. Northglen Water Management
Program, Vol. 5, prepared for the City of Northglen.
April 1978.
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2.7 Performance Controls on Development
Description: Petaluma, California and Ramapo, New York
are the pioneer cases of imposing what can loosely be called
performance limitations on development. In Petaluma1s case,
the link is fairly indirect—the imposed limitation on annual
housing starts is intended to be in phase with growth in muni-
cipal service capacity. In Ramapo's case,the links between
development and service capacity were made explicit via points
system, whereby developers need to show some minimal availability
of services—schools, sidewalks, solid waste disposal, water,
sewer and others.
The Contra Costa EIS includes a variant on this approach
directly applicable to mitigating secondary air quality impacts.
This is:
an incentive system to assist and induce proposers of dev-
elopment to achieve the objectives of VMT reduction and
trips reduction.. This measure is a point scoring system
which recognizes features of a proposal that contribute
tc the enhancement of transit, pedestrian or bicycle
transportation. The VMT/trips point system will improve
the conditions for use of buses and bicycles more conven-
iently and efficiently.
Three uses are suggested for the rating system:
1. A bonus arrangement tied to the number of points
scored, such as award of increased floor area ratio
or housing unit density;
2. Reduction in fees associated with approval of the
project;
3. A review mechanism for incorporation into the analy-
sis of VMT/trips impacts.
A suggested list of rating points was presented; one point could
be allotted for each of the following (this is in the context
of the San Francisco Bay Area):
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Sample VMT/Trips Point Ratings
o Within L±5 miles of a BART station.
o within I_,_0p0_feet_of a busstop served by at least 12
buses per day.
o Improves employment to housing ratio in a one-mile
radius toward a "natural ratio" of one job per em-
ployed resident. A socioeconomic match is required.
o Proposed residential units within 1.5 miles of a shop-
ping facility.
o Infill development (within incorporated area, already
developed on 50 percent of its perimeter)«
o Has bike lanes or paths connecting to major destinations.
o Has two or more land use types of activities within
a project.
o Proposed non-residential uses within 0.5 miles of an
eating facility.
Clearly, this points scoring system could be extended somewhat
into other areas of development performance. In the case of the
Vail grant agreement to control construction of fireplaces,
an alternative approach might have been to award bonus points to
new developments withiout fireplaces, or with particular fire-
place construction techniques. Parking or garage space might
also be limited.
Performance controls in the mode of Ramapo do tend to phase
growth in an orderly way, which can have air pollution benefits
indirectly. To the extent that the points system can aid in the
control of emissions, its air quality benefits become more direct.
Technical Effectiveness: We will have to weigh the bonus
system against the baseline case: reduced emissions per unit
might be outweighed by increasing the number of units built.
Also, technical effectiveness may also turn out to be marginal,
as the measure may only affect a fraction of the ultimate new
construction.
Implementability: We expect that this measure will prove
implementable only where communities are in favor of growth
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control strategies.
Administrative Complexity: If it turns out that the point
system can be routinely applied under specific circumstances,
and that its provisions are relatively uniform, then the admin-
istrative load on EPA to arrange it will be relatively small,
Social and Economic Impacts: Could increase the cost of
housing. Depending on the scope of 'the approach, it could
significantly slow development in some cases. If it were to do
so, it would not be advisable to impose the system for a single
purpose (air pollution), though if multiple goals were set out,
the measure might have significant ancillary air quality bene-
fits.
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REFERENCES
Planning Environment International and Herman D. Ruth and
Associates. Central Contra Costs Sanitary District Waste-
water Treatment Facility Expansion: Secondary Air Quality
Impacts and Mitigation Analysis. Prepared for J.B. Gilbert
and Associates, Inc. August 1975.
43
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2.8 Require Consistent Region-wide Population Projections
Description: This strategy consists of using the same
population projections in both 201 plans and SIPs. Consistent
population projections are likely to be required under Section
316 of CAA when applicable regulations are published.
Technical Effectiveness: The effectiveness of this meas-
ure lies in forcing the SIP to plan for the same population en-
visioned in the 201 plan.
Implementability; This action is bascially administrative;
implementation consists of notifying air and water quality and
other planners,
Administration: Once this measure is put into effect, the
offices responsible in the EPA and local planning agencies for
air and water quality planning will need to insure that indeed
population forecasts are consistent.
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2.9 Collateral Growth Policy Agreements With Adjacent
Communities
Description: In order to assure that neighboring communi-
ties do not emit pollutants that would interfere with their own
air quality efforts, some municipalities have considered agree-
ments on growth policy. For example, a community might ask a
neighboring community to insure that certain lands remain un-
developed in exchange providing that community a certain service.
This strategy has been discussed in Contra Costa County, Calif-
ornia.
Technical Effectiveness: The effectiveness of this measure
would vary according to the nature of the actual agreement.
Implementability: The degree to which any area can suc-
cessfully implement a program of this sort will vary with local
circumstances. No community will give up its control over de-
velopment to another town unless the inducement is worthwhile.
Administration: Once an agreement has been reached, ad-
ministration of this strategy is limited to abiding by the
agreement.
Social and Economic Impacts: These impacts will also vary
depending on the agreement. However, as with most agreements
limiting growth, the areas where growth is permitted or encour-
aged usually will enjoy increased value relative to the areas
where development is restricted. Because of this, few towns
would be likely to agree to limit their own development.
45
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REFERENCES
Draft Environmental Impact Report and Environmental
Impact Statement for Western Contra Costa County Waste-
Water Management Program. U.S. Environmental Protection
Agency, San Francisco, 1976.
Planning Environmental International, Central Contra Costa
Sanitary District Wastewater Treatment Facility Expansion:
Secondary Air Quality Impacts and Mitigation Analysis.
Prepared for J.B. Gilbert and Associates. August 1975.
46
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2.10 Plan Streets and Roads to Reduce Vehicle Travel
Description: Communities can reduce VMT by designing
roads and highways to account for likely driving demand.
Technical Effectiveness: There is no question that street
design effects VMT.
Implementability: Since most roads or highways are already de-
signed to minimize lane-miles and account for travel demand, this
strategy should not result in any change in planning.
Administration: See implementability.
Social and Economic Impacts: None.
Comments: This strategy is a positive contrast to auto
use disincentives (see 3.5).
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2.11 Statements from Developers Regarding Indirect
Sources
Description: In order to insure maintenance of air quality
standards, Summit County, Colorado has suggested requiring pros-
pective new developers to submit a statement with their develop-
ment plan stating that they have considered air quality mainten-
ance in the vicinity of the development and how they plan to
minimize emissions.
Technical Effectiveness: The effectiveness of this measure
depends on how realistic the developer is in assessing likely
emissions and whether or not he adheres to his statement.
Implementability: This strategy could be implemented only
over the objections of developers.
Administration: Statements from developers regarding air
quality could be required as part of the building permit process.
Social and Economic Impacts: The impacts of this strategy
would vary according to the measures that developers actually
did take to minimize emissions.
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REFERENCES
Ambient Analysis, Inc., Air Quality Assessment and
Projection for Summit County, Colorado, Prepared
for Summit County, Colorado, March 1976, p. 7
49
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2.12 Dispersion of New Sources
Description: Dispersing major stationary sources, espec-
ially along topographic lines, can also serve to enhance air
quality. This measure was suggested by Summit County, Colora-
do which includes many high altitude mountain valleys. Such dis-
persion not only insures that no particular area is inundated
with pollution but also that certain levels of the atmosphere
are also not saturated.
Technical Effectiveness: Any system for source dispersion
will also tend to disperse pollutants.
Implementability: The ability of a community to implement
such a measure is subject to question. For example, a community
might decide to locate municipal parking high on the valley wall
and use electric buses to transport people to and from their cars.
It is questionable whether the community has the authority to
require all private parking to be constructed and operated in
such a fashion.
Administration: Once this strategy is implemented, admin-
istration should be similar to that of conventional zoning pur-
poses.
Social and Economic Impacts: Dispersal of sources implies
dispersal of development. Accordingly, hardship may be placed
on those who must commute to their jobs and those commercial
developments that must attract business from either residents
or travellers that are passing through on highways set off at
a distance.
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REFERENCES
Ambient Analysis, Inc. Air Quality Assessment and Projection
for Summit Country, Colorado. Prepared for Summit County
Colorado, March, 1976. p. 8.
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2.13 Capital Improvement Programs
Description: Capital improvement programs can be used to
improve or maintain air quality if trip generation or VMT is
used as a criteria for their design. In other words, improving
or building parks near large residential sections, building bike-
ways or bus lanes all could become priority parts of a capital
improvement program that emphasizes air quality through reduced
VMT. Using capital improvement programs as a mitigation tool
has been discussed in Denver, Colorado and Contra Costa, Calif-
ornia.
Technical Effectiveness: The effectiveness of this measure
varies with the relative effect of any improvement measures.
Clearly, any measure proven at reducing VMT will be effective
at improving overall air quality.
Implementability: This measure can only be implemented
successfully with the full support of local public works officials
and those leaders responsible for capital improvements.
Administration: Such a program would add another step to
designing capital improvement programs: review for VMT reduc-
tion. If this measure were to be successful over time,
some sort of continuous review process beyond the planning
review might be required.
Social and Economic Impacts: Any item in the capital improve-
ment program that was added to improve air quality would either
require an increase in taxes or deletion of an alternative meas-
ure already in the improvement program. New taxes would place new
burdens on those taxed while deletion of any item in the improve-
ment program would mean fewer facilities for some segment of
the population. Of course, the new added improvement would
presumably benefit some segment of the population also.
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REFERENCES
Draft Regional Growth and Development Plan for the Denver
Region, Implementation Prospectus, Denver Regional Council
of Governments, November 1977.
Planning Environmental International, Central Contra
Costa Sanitary District Wastewater Treatment Facility
Expansion: Secondary Air Quality Impacts and Mitigation
Analysis. Prepared for J.B. Gilbert and Associates, Inc.
August 1975, p. 147.
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2.14 Short and Long Range Annexation Plans for Defined
Urban Service Areas
Description: In areas where significant amounts of unin-
corporated land exist, short and long range annexation planning
may be important as a land use tool for anticipating secondary
impacts: sequencing of growth into these areas is usually
dependent on availability of services. Advance planning of
annexation increases the certainty with which predictions of
secondary impacts can be made. It also informs regional plan-
ning groups as to when local governments will acquire authority
to effect locally implementable portions of the SIP (or other
applicable regional plan) in currently unincorporated areas.
Technical Effectiveness: This is rather an indirect
measure, and its technical effectiveness is doubtful. More
information is needed.
Implementability: Uncertain.
Administrative Complexity: Even if imposed as an external
requirement by EPA, the consequences of the proposed annexation
plans must be evaluated by EPA staff. This could be a signific-
ant burden, but there is insufficient information at present to
determine this.
Social and Economic Impacts: The political implications
of publication of long term annexation plans could be signific-
ant. Other social and economic impacts may exist, but we do
not have sufficient information at this time.
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REFERENCES
Draft Regional Growth and Development Plan for the Denver
Region. Implementation Prospectus. Prepared by Denver
Regional Council of Governments. November, 1977.
55
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2.15 Detailed Planning of Regional Activity Centers
Description: The Draft Regional Growth and Development Plan
for the Denver Region: Implementation Prospectus, recommends,
as part of their Local Alternative, the preparation of detailed
plans and implementation programs for regional activity centers.
Advance planning of this sort—one of a wide variety of planning
reforms suggested throughout the literature—should be seen as
contributing only indirectly to evaluations of secondary air
quality impacts.
Technical Effectiveness: Contributory only; impacts only
indirect and long term.
Implementability: Probably implementable only in regions
with strong existing regional planning agencies.
Administrative Complexity: Minimal.
Social and Economic Impacts: Insignificant.
Comments: Appears to be one approach back toward indirect
source review. Like many planning tools, there seems to be little
immediate benefit, but as part of a generalized good-faith effort
to cope with secondary impacts on a regional scale, this probably
»
is worthwhile.
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REFERENCES
Draft Regional Growth and Development Plan for the Denver
Region: Implementation Prospectus. Prepared by Denver
Regional Council of Governments. November 1977.
57
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2.16 Coordination of Federal Housing Financing to Favor Air
Quality Goals
Description: Since a variety of federal programs (FHA,
FMHA, VHA) fund residential development, one option that seems
potentially promising would be to coordinate funding preferen-
tially toward infill development. The Department of Housing
and Urban Development has demonstrated interest in infill dev-
elopment through a study to be funded this year to create an
inventory of infill lands, and to research the institutional
aspects of implementing infill development programs. Coordina-
tion of infill development programs implemented with preferen-
tial funding might be worked out under the Interagency Coordina-
ting Council; its principles and techniques could be incorpora-
ted into environmental evaluations of secondary impacts of 201
facilities.
Technical Effectiveness: Estimation of the technial
merits of infill programs will probably have to await preliminary
results of HUD's research.
Implementability: We have little data on the issues in-
volved, but would expect impacts of grantees to range from
slight to severe.
Administrative Complexity: The administrative burden appears
to fall mainly on the housing finance agencies and their local
offices.
Social and Economic Costs: These costs are among those to
be evaluated in a forthcoming HUD study.
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REFERENCES
EPA Urban Program Initiatives, Analysis of New Program
Initiatives: Construction Grants Program Modification Op-
tions to Minimize Sprawl. Draft. March 1, 1978.
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3.0 CATEGORY 3: EMISSIONS REDUCTIONS
3.1 Emissions Controls on Stationary Sources
Description: Emissions controls on stationary sources range
from conventional industrial air pollution controls to restric-
tions on timing and types of emissions. For example, requiring
state-of-the-art controls such as precipitators and scrubbers
on industrial stacks would represent a more conventional alter-
native. 0$$er measures in this category include special devices
for controlling fireplace emissions as proposed in Vail, Colorado
and designating "burn days" for agricultural waste in Simi Valley,
California.
Technical effectiveness: The effectiveness of this measure
varies according to the relative impact of stationary source
emissions. In other words, in areas where there are many sta-
tionary sources, this measure can be used to effectively enhance
air quality.
Implementability: The primary problems with implementation
of this measure are political and technical. While controls
such as scrubbers on precipitators may have proven effectiveness,
fireplace emission control devices, for example, are unproven
in wide use. Politically, implementation of this measure may
prove difficult due to opposition from local economic interests.
Since many stationary source controls involve capital and op-
erating expenses or restrictions in "freedom", planners may face
opposition to requirements for stationary source control.
Administration: Once stationary source control measures
have been agreed upon, administration becomes a matter of en-
forcement. When such measures include physical controls (e.g.,
scrubbers), building permits, emission permits or other in place
enforcement measures can be extended to cover stationary source
emissions. Restrictions on activities (e.g., burning), however,
require personnel for continual enforcement.
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Social and economic impacts: Social and economic impacts
can range from plant closings due to emissions restrictions
to increased jobs in construction and pollution equipment in-
dustries. Additional costs of new pollution control will, in
the long run, be passed along, at least in part, to the con-
sumer.
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REFERENCES
Simi Valley County Sanitation District, Final Air Quality
Maintenance Plan.
Contacts with Bill Geis, Wesley Wilson, EPA Region VIII,
regarding the Vail agreement.
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3.2 Auto Emissions Inspections and Maintenance
Description: Periodic inspections of automobiles and sub-
sequent enforcement of mobile source standards will lower over-
all air pollution in areas with high VMT. This measure has
been included in many areas attempting to control air degreda-
tion including Denver, Colorado; Simi Valley, California; and
Sonoma County, California.
Technical effectiveness: The effectiveness of this measure
is determined by the frequency of inspections and enforcements
and like most measures, the relative degree to which mobile
sources contribute to air pollution. Little monitoring has
been done to date to test the effectiveness of auto emissions
inspection and maintenance policies in specific areas.
Implementability: Mobile source inspections and maintenance
is easily implemented once enforcement agencies are budgeted
money and personnel. Auto emission inspections may also be
included as part of regular auto safety inspections required
in most states.
Administration; Administration of this control measure
requires additional money to pay for inspections and enforce-
ment of automobile maintenance.
Social and economic impacts: Likely impacts of mobile
source controls include the inconvenience to the owner of the
mobile source and any costs of compliance which also fall to the
source1s owner.
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REFERENCES
Planning Environment International, Los Angeles, Central
Contra Costa Sanitary District Wastewater Treatment Facility
Expansion: Secondary Air Quality Impacts and Mitigation Analysis,
August 1975, p.21.
EPA, Denver, Denver Regional Environmental Impact State-
ment for Wastewater Facilities and the Clean Water Program,
p.29.
Sirai Valley County Sanitation District, Final Air Quality
Maintenance Plan.
EPA, Washington, D.C., Integrated Land Use/Air Quality/
Water Quality Control Study for Sonoma County, California,
January 1977, p.VII-14.
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3.3 Local General Purpose Anti-Air Pollution Programs
Description: General purpose anti-air pollution programs
include public awareness and other non-legal efforts to curb
air pollution. A campaign to encourage residents to shop at
local stores which is intended to reduce total VMT and air pol-
lution is an example of this type of measure currently in use
in Westminster, Colorado.
Technical effectiveness: Clearly, the effectiveness of any
sort of general anti-air pollution program will vary according
to how many residents and/or polluters follow the intent of
the program. No monitoring of the effectiveness of such pro-
grams has yet been attempted. It is unlikely that voluntary
measures will be as effective as those required by ordinances
in most cases.
Implementability: These types of measures are easily im-
plemented if there are people willing to devote their efforts
to interesting the population as a whole.
Administration: Administration is limited to presentation
of the anti-air pollution program and reminding the population
of the program from time to time.
Social and economic impacts: Impacts will vary according to
the actual anti-pollution program. For example, programs aimed
at reducing VMT might have the impact of encouraging families
to seek recreation together and thus encourage family cohesion.
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REFERENCES
EPA, Denver, Comments on Two 208 Plans With Regard to Air
Pollution Issues, 1977, p.2.
Field Visit with Robert Ferguson and Dick Johnson of City
Westminster (Colorado) Department of Public Works.
EPA, Denver, Final Determination of Actions for the Denver
Regional Environmental Impact Statement for Wastewater Facilities
and the Clean Air Program, 1978.
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3.4 Public/Private Transporation Programs
Description: Following the general principle that reduc-
tions in automobile vehicles miles travelled will lead to reduced
total air pollution emissions, a variety of measures have been
suggested by which VMT can be reduced by attracting drivers to
public transporation, or by encouraging more efficient use of
auotmobiles. These measures fall into three general categories,
which may be implemented singly or in combination:
1. Transit system improvements, both trunkline and
local;
2. Transit operating improvements;
3. Carpooling/vanpooling programs.
The general theme of these measures is that they are aimed at the
public at large, and that they use a carrot rather than a stick
to achieve their ends.
Transit system improvements may include:
o Adding regional linkages to a system; expanding local
routes (may require addition of vehicles to local
fleet)
o Providing special services (e.g., to recreation areas,
shopping centers, schools, health care facilities,
airports)
o Lower fares and more efficient fare collection
° Express buses
o Terminal point amenities (shelters, benches)
o Exclusive transit rights-of-way (busways, auto-free
zones)
o Joint capital purchases among regional systems
o Joint maintenance facilities
o Improved traffic flow*
*The East Bay EIS considered traffic flow improvements, al-
though they may achieve short term emissions reductions, to be
counter-productive, since ultimately they reinforce auto-depen-
dency even as they contribute to speeded mass transit flow and
reduced vehicle idling time.
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Transit operating improvements may include:
o Increased frequency and capacity of service;
o Providing more bus stops;
o Extending hours of service;
o Educating riders about security measures or otherwise
seeking to increase safety and dependability of ser-
vice;
o Coordinating schedules, fare collection, and transfers
between transit modes.
Carpool/vanpool programs that are already in effect can be
improved by:
o Emphasizing their use in areas with concentrated em-
ployment and work trips;
o Providing better public information through municipally
support computer matching programs and employee partici-
pation plans;
o. Preferential treatment for carpool vehicles (special
lanes, metered highways with preferential access,
reduced tolls or free passage, free or preferred park-
ing) . Vanpool programs require the private or public
purchase of vehicles, which might be supported or
facilitated by a municipal program.
The East Bay EIS (p. VI-9) emphasizes the importance of non-
work related trips in strategies to attract new riders to transit:
they allege that more than 70 percent of all vehicle trips are
not for work purposes, and that these—being shorter than work
trips—have proportionately greater cold start/hot soak problems.
Measures aimed at this segment of ridership include:
o Off peak fare reductions;
o Travel stamp programs;
o Subsidized taxi service;
o Public education programs (TV, radio, newspapers);
o Dial-a-ride.
Technical Effectiveness: Technical effectiveness is depen-
dent upon actual changes in modal split (auto/transit) before and
after implementation of the measures. Technical effectiveness
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may be greatly increased by regional application of the measures
(coordination with other jurisdictions and transportation plan-
ning authorities); quantification of measures implemented purely
locally, especially in smaller communities, is difficult and
perhaps not meaningful. Data from EPA air programs evaluations
is expected to be available to evaluate this group of measures.
Implementability: Transit system improvements generally are
capital intensive; operating improvements may be less so, given
a suitable existing system. Coordination with federal, state,
and regional transportation authorities is expected to be a key
element in implementation; SIP planning involvement should prob-
ably be an integral element of most transit initiatives.
Administrative Complexity: We expect that implementation of
this measure will be in coordination with existing transportation
programs, and that EPA's involvement in design and negotiation
of these improvements will be slight. Local initiative may be
the key element; it may be EPA's responsibility to demonstrate
the mitigation benefits that will accrue locally to the particular
201 project in question.
Social and Economic Impacts: Depends on program and measures.
Generally considered positive in the literature.
Comments: Coordination with SIP transit planning seems to
be paramount, though certain measures (such as carpooling programs)
might be implemented independently at modest local cost with little
fear that future SIP transporation elements will be compromised.
For the most effective improvements, money is the big issue—it
is unlikely that any locality would launch major transit programs
simply to deal with secondary impacts of a 201 grant, though
perhaps that would be appropriate if the grant were sufficiently
large.
Improving transit system performance seldom seems to affect
modal split dramatically without parallel programs to discourage
auto use (see below).
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REFERENCES
East Bay Dischargers Authority Water Quality Management
Program, E.I.S.; Final Draft.
Air Quality Maintenance Plan: Simi Valley County Sanita-
tion District, Sept. 12, 1977.
Improving Environmental Quality through the Use of Local
Ordinances and Regulations, Urban Systems Research &
Engineering, Sept., 1976.
Levermore-Amador Valley Wastewater Program, Draft E.I.S.,
Oct. 1975.
Western Contra Costa County Wastewater Management Program,
Draft E.I.R. and E.I.S., Feb. 1976.
Supplement to Western Contra Costa County Wastewater
Management Program, Draft E.I.R. and E.I.S., Feb. 1976.
Central Contra Costa Sanitary District Wastewater Treatment
Facility Expansion: Secondary Air Quality Impacts and
Mitigation Analysis, Planning Environment International,
Aug., 1975.
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3 .5 Auto Use Disincentives
Description: Auto use disincentives are the opposite side
of the coin from transit improvements. They can include:
o Parking permit programs for local residents or employ-
ees of particular firms;
o Decreased parking availability on street (removing
meters);
o Higher meter rates;
o Local garage taxes;
o Control programs on parking lot capacity;
o Increased use of alternative side of the street parking;
o Decreasing local road capacities through selective
scheduling of highway construction, limiting ramp
capacity on limited access links, narrowing arterial
roadways, limiting land capacity of bridges or other
controllable links;
o Gas taxes, "smog" taxes, registration surcharges;
o Closing parking lots during peak morning hours;
o Auto-free zones.
Technical Effectiveness: Since the effect of auto use dis-
incentives may be more predictable in relation to modal split than
transit improvements of various kinds, air pollution benefits are
perhaps more readily quantifiable than they are for transit sys-
tem improvements. Quantification of benefits still seems diffi-
cult, however.
Implementability: From the grantees' point of view, these
measures are cheaper and easier to implement than most transit
improvements, and can often be financially self-supporting (through
increased revenues from parking, tolls, and fines). However, they
are politically unpopular, especially since benefits—even if
quantifiable—are not certain or dramatic, and since they are
extremely unpopular with motorists (resident parking permit sys-
tems may be the exception in communities that have large amounts
of inbound commuter traffic).
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Administrative Complexity: Administrative burdens from
EPA's side are likely to be slight, since programs must be ini-
tiated largely from the local end, and are likely to be implement-
ed in relation to regional-wide initiatives such as the SIP.
Social and Economic Impacts: Auto use disincentives are
often alleged to penalize local merchants.
Comments: Despite their unpopularity, auto use disincentives
may be effectively related to the grants program since they are
reasonably easy to implement, are self-supporting (not capital
intensive from the locality's point of view), and not likely to
contradict elements of the SIP.
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REFERENCES
East Bay Dischargers Authority Water Quality Management
Program, E.I.S.; Final Draft.
Air Quality Maintenance Plan: Simi Valley County Sanita-
tion District, Sept. 12, 1977.
Improving Environmental Quality through the Use of Local
Ordinances and Regulations, Urban Systems Research &
Engineering, Sept., 1976.
Levermore-Amador Valley Wastewater Program, Draft E.I.S.,
Oct. 1975.
Western Contra Costa County Wastewater Management Program,
Draft E.I.R. and E.I.S., Feb. 1976.
Supplement to Western Contra Costa County Wastewater
Management Program, Draft E.I.R. and E.I.S., Feb. 1976.
Central Contra Costa Sanitary District Wastewater Treatment
Facility Expansion: Secondary Air Quality Impacts and
Mitigation Analysis, Planning Environment International,
Aug., 1975.
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3.6 Street Cleaning
Description: In areas with TSP problems, street sweeping
may play an important role in reducing pollution emissions.
A local program could involve one or more of the following
elements:
o Increased frequency of sweeping
o Improved equipment (especially vacuum sweepers)
o Coordination of parking policies to facilitate
scheduling and improve effectiveness
o Implementation of towing programs in coordination
with parking programs.
Technical effectiveness: While our previous research (Im-
proving Environment Quality Through the Use of Local Ordinances
and Regulations, EPA, September 1976) indicates that vacuum
sweepers are more effective than brooms or flushing. The
Denver Regional Environmental Impact Statement for Wastewater
Facilities and the Clean Water Program shows mixed results for
mechanical broom sweepers, vacuum sweepers, and flushers.
The Steamboat Springs EIS also discusses street cleaning,
and points out its companion benefits for urban runoff pollu-
tion abatement.
Implementability: From the grantee's point of view, the
measure is reasonably easy to implement. The barrier may be
in purchase of new street sweeping equipment if it is needed.
201 money is not available for this purpose, but other federal
programs (such as the Community Development Block Grants
program) can fund such purchases.
Administrative complexity; Where street sweeping has been
mentioned for TSP abatement, the mode of implementation has
been some sort of informal agreement with the grantee to im-
plement improved programs. The administrative burden has thus
been slight so far, but could be greater if EPA were to be in-
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vovled in development of actual local programs (including recom-
mendations for revisions in local parking ordinances) or in
aiding communities in obtaining funding for necessary equipment.
Social and economic impacts: There are clear fiscal bur-
dens on localities to support an extended program, but impacts
on the community at large are positive.
Comments: Observed to be an issue in Region VIII. Where
TSP problems are really extensive, however, the source may not
be reintrained dust from automobiles, but rather natural erosion
of dry soils.
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REFERENCES
Urban Systems Research and Engineering, Inc., Improving
Environmental Quality Through the Use of Local Ordinances and
Regulations, EPA, September 1976.
Steamboat Springs Regional Sewerage Authority, Final EIS;
201 Wastewater Facilities Plan.
EPA, Denver Regional Environmental Impact Statement for
Wastewater Facilities and the Clean Water Program, 1978.
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3.7 Emission Density Zoning
Description: Emission density zoning is zoning parcels of
land for a pre-determined amount of pollution. In other words,
an area might be zoned for two tons of particulate matter per
acre per year. All building in that area would then be required
to conform to that zoning requirement. For example, for every
two tons of particulate matter that a factory expects to emit,
it must own an acre of land. Emission Density Zoning is a
theoretical idea and has not been applied in any community.
Technical Effectiveness: The effectiveness of emission den-
sity zoning is unknown.
Implementability: Any area seeking to implement emission
density zoning would face a number of obstacles. Since it has
never been tried before, such a community would have no experience
to work from. Further, there are a number of legal and technical
issues that would have to be resolved prior to zoning implementa-
tion. For example, what would happen if a factory wanted to
expand and there was no land available? Could a neighboring
homeowner sell his "rights" to emit the designated pollutant?
Administration: Presumably, once the zoning program was
underway and implementation problems were ironed out, adminis-
tration of the program would be similar to administering any
zoning ordinance. Some method of assuring compliance would be
necessary, however.
Social and Economic Impacts: The socio-economic impacts
associated with emission density zoning can only be postulated.
As with any zoning ordinance, this measure would alter greatly
the living patterns and lifestyles in many areas.
Comments; This measure could only be used effectively in
areas where little or no development has taken place.
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REFERENCE
Cosier, Peter C., IV. "Land Use Based Emission Strategies:
Their Promise and Problems," Planning Comment, Vol. 12,
#2, 1976, p. 31.
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3.8 Economic Development Policies
Description: Encouraging more economic development in area
where most residents commute to jobs or shopping may result in
less commutation and, thus, less VMT. This measure is currently
being tried in Simi Valley, California.
Technical Effectiveness; No effort has been made to date
to monitor the effectiveness of these types of economic develop-
ment policies. The effectiveness of this strategy cannot be
measured solely on its impact on VMT but must also account for
increased emissions from new industrial or commercial develop-
ment.
Implementability: In areas where increased economic activity
is desired by residents, implementing a policy of encouraging
new business should be an easy task.
Administration; The ability of a community to attract
new industrial new/or commerical activity varies with a great
deal of factors. Assuming that the area has sufficient resources
and land to advocate such a policy, it can encourage new growth
by organizing industrial zones, altering tax structures, and
simplifying local permit procedures.
Social and Economic Impacts; Increased commercial and
industrial activity would create economic prosperity through
new jobs, increased opportunities for individuals and new tax
revenue for the community.
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REFERENCE
Final Air Quality Maintenance Plan. Simi Valley County
Sanitation District.
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3.9 Emergency Powers
Description: In Air Quality Assessment and Protection for
Summit County, Colorado, we find the following reference to the
use of local emergency powers in regard to extreme air pollution
episodes:
Even if development is controlled according to a well-
conceived plan which assures good air quality virtually
all the time, there will be occasions when nature fails
to follow her usual course. Unusual periods of intense
stagnation can occur. It is reasonable to take unusual
measures to control pollution in these situations, meas-
ures which would not be acceptable routinely. It is
unreasonable to maintain development at such a low level
that there could be no problem under the most adverse
meteorological conditions. Therefore, controls which
can be imposed in a short time and which will cause as
little disruption of activity as possible must be con-
sidered. These can range from banning fireplace burning
during a few morning hours :to banning all automotive
traffic in the County except that which is absolutely
essential to health and welfare.
Such powers have been made a vital part of the Vail grant con-
dition; in this agreement, the city has the power to limit fire
place use during emergency episodes. This is linked to a general
program of public announcements regarding air emergencies.
This approach seems most appropriate where local meteoro-
logical conditions and local emissions sources combine to be
responsible for emergencies—i.e., where the use of emergency
powers bears a well defined relation to public health, safety,
and welfare. It may also be appropriate even where air pollu-
tion programs are regional in scale, although there coordination
with local SIP planning would be essential. In addition, espec-
ially in isolated locations with no region-wide air monitoring
program in effect, some local air quality monitoring effort would
be required.
Technical Effectiveness: Technical effectiveness of this
measure seems to be potentially very high, provided the powers
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are used conscientiously. We currently have no data on the
success of the Vail grant condition in implementing emergency
powers.
Implementability: Aside from the associated costs for
monitoring, the costs of implementing this measure seem low.
They would partially depend, of course, on the extent of en-
forcement efforts associated with the measure, and the frequency
of episodes.
Administrative Complexity: Since the context within which
the measure seems most appropriate would probably be both well
defined and comparatively rare, the administrative burden on
EPA to implement the measure seems small. There may, however,
be strong regional variations in thie use of this measure.
Social and Economic Effects: These would depend on the
nature of the powers used, as well as on the frequency of the
episodes. Unlike some of the more generalized measures, how-
ever, the impacts of emergency police powers can be fairly
clearly defined.
Comments: Requires some more data on actual use in Vail and
elsewhere, as well as significant legal research. A promising
measure .under special circumstances, however.
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REFERENCES
Vail, Colorado, Letter of Understanding regarding the
implementation of air pollution programs in relation to
201 grants.
Air Quality Impacts on County-wide Land Use Planning. Air
Quality Assessment and Projection for Summit County, Color-
ado, Final Report. Submitted to Summit County, Colorado,
Planning Department by Ambient Analysis, Inc. March 1976.
Relevant sections.
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4.0 CATEGORY 4: OTHER RELATED MEASURES
4.1 Annual (Incremental) Dispersement of Funds
Description: One of the most important problems in the
implementation of any mitigation measure is enforcement: once
a measure is agreed to, EPA has relatively little flexibility
in compelling performance short of suing for contract violations
in the rate instances where that might be possible.
The State of New Hampshire contributes matching funds to
local communities for 201 projects in annual increments that
help a community to meet debt service obligations on municipal
bonds sold to pay off the local share of a project. Since this
state contribution is not, unlike EPA's approach, a lump sum
amount, New Hampshire retains leverage over grantee management
of the facility over the life of the project. This was established
under Section 149B of New Hampshire's Revised Statutes. Matching
funds are available up to 20% of the total cost of the project,
meaning that the effective local share becomes as little as 5%.
Our contact indicated that there have been several cases where
the state has withheld principal and interest payments where the
system is not being properly operated or maintained, or where
the town has refused to add capacity the state thinks is needed.
Several warnings are given before actual withholding of funds
is resorted to.
Technical Effectiveness: Since this is an enforcement
technique, technical effectiveness is not a valid evaluation
criteria in relation to air quality.
Implementability: Adaptation of this measure on the national
scale would impose no implementation burdens on local governments,
except as noted under "Comments."
Administrative Complexity: If adopted, there would be no
administrative burden connected with this measure other than
continuing monitoring of grantee enforcement of an agreed mitiga-
tion measure. Obviously, this approach implies major revisions
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to current administration of the entire 201 program, however,
and is included here more for discussion than in the expectation
that it will be adopted.
Social and Economic Impacts: No data available.
Comments: The measure is a radical suggestion for the
grants program, but it appears to have utility far beyond the
scope of this project.
A major issue locally might be its impact on bond interest
rates: in New Hampshire grantees are given the advantage of
the state's AAA bond rating in floating their own bonds, but
given the strings attached to the money (i.e., the possibility
that debt service might be interrupted) we wonder if interest
rates might be pushed up if the idea were adapted to the 201
program.
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REFERENCE
Contact with Mr. Lindsay Collins, New Hampshire Water
Supply and Pollution Control Commission.
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4.2 Air Quality Monitoring
Description: Not suggested in any of the written materials
we have seen to date is the idea of requiring air quality mon-
itoring itself on a local level. This issue may be moot in
non-attainment areas, where extensive monitoring and modeling
may have been done in relation to SIP development, but it may
be very much alive in PSD areas, or in many parts of non-attain-
ment areas—particularly those where compliance with the 1982
deadline will not be possible for 0, and CO.
Summit County, Colorado, was mentioned to us during our
field visit in Region VIII as one location where an early air
quality study (which reached what were asserted by the state
public health board to be premature conclusions about suitable
mitigation strategies for TSP) was short on critical monitor-
ing data. The county has approached the state for funds to
monitor air quality, but the state has no available funds and
has referred them to EPA.
Monitoring requirements could be attached as conditions
to 201 grants in order to support a wide variety of direct
mitigation measures also attached to the grant, or otherwise
agreed to. At present, 201 funds could probably not be used
to purchase or operate monitoring equipment, but perhaps ways
could be found around this.
Technical effectiveness: This measure might be of critical
importance to assessing the technical effectiveness of exist-
ing measures and designing new ones.
Implementa-bility: Without money, this measure may be dif-
ficult to implement. If money could be made available from one
or more federal programs, there should be no difficulty in im-
plementing the measure.
Administrative complexity; So far we have not pursued the
matter of finding funding sources for such a measure. Adminis-
trative requirements for EPA, were such a measure advocated,
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could involve helping grantees locate funding for necessary
machinery and labor, designing an appropriate program (sam-
pling locations, sampling frequency, data formating for use
with specified modeling techniques, etc.), and assisting in
the evaluation of results. The burden could be substantial,
and could involve significant participation of other branches
of EPA outside of 201 and the environmental clearance section.
Social and economic impacts: Aside from the important
costs of setting up and operating the system, there are no
significant external costs associated with the measure that
we can anticipate.
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REFERENCES
Contact with John Spiegal, Colorado Department of Public
Health.
Ambient Analysis, Inc., Air Quality Impacts on County-wide
Land Use Planning. Air Quality Assessment and Projection for
Summit County, Colorado, Final Report, Summit County Planning
Department, March 1976.
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4.3 Planning Support
Description: We have observed that one of the most common
problems in dealing with secondary impacts, particularly where
projects are of moderate size or are being built in relatively
small communities, has been a lack of staff for planning to cope
with secondary impacts through one or more of the land use or
emissions reduction strategies mentioned in Section 2 and 3
above. Technical assistance for local planning purposes might
be one viable mitigation measure to consider in relation to 201
planning. In Step 1 planning local governments often need in-
creased staff time just to forecast secondary impact problems,
and even where problems are identified, resources are often
insufficient to set up specific response strategies.
Mechanisms by which planning assistance in various guises
might be made available to local communities have not been ex-
tensively explored, but they might include:
o Increased use of 201 Step 1 funds to expand environ-
mental assessments to include modeling of secondary
impacts, development of ordinances and plans to re-
spond to expected ranges of secondary impacts, and
other one-shot studies and staff expenses.
o Increased coordination of efforts between 208 and
201 programs for the explicit purpose of developing
adequate local responses to secondary growth and con-
sequent air quality impacts.
o Direct technical assistance to local governments
from EPA regional offices to cope with specific
problems related to secondary impact mitigation.
o EPA Regions mediating with other federal programs,
such as HUD 701 planning funds, to respond specific-
ally to secondary impacts of 201 investments. (At
present most 701 funds are going to regional plan-
ning agencies; this priority could be maintained, if
appropriate in a particular region, or might be mod-
ified by some kind of interagency agreement to re-
target some funds locally for this specific purpose.)
Technical Effectiveness: This is a general purpose support
mechanism whose technical effectiveness in terms of air quality
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improvements would be indirect and probably long term.
Implementability: From the point of view of the local gov-
ernment, this measure appears attractive, since it is a direct
economic benefit. Whether or not local governments would seek
it independently or accept it if offered might well depend on
the type of assistance offered—and the type of mitigation strat-
egy that that assistance is design to support.
Administrative Complexity: Administrative burdens on EPA
might be significant, though nothing specific can be suggested
until this measure is evaluated further.
Social and Economic Impacts: Expected to be positive on
the community.
Comments: Insofar as this measure may require modifications
to 201 regulations, interagency agreements, or similar headquar-
ters based changes in current policy, it seems doubtful that it
could be finalized by the time the proposed guidebook is to be
finished.
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4-4 Requirements for Regional Planning Coordination
Description: One of the more common strategies advocated
by EPA in the past has been increased local involvement in
regional planning efforts. This has been required independent
of any funding or other technical support.
The Denver Regional EIS includes the following reference:
Each general purpose government included in the service
area for which a grant is required, enters into a written
agreement with EPA and the State of Colorado to participate
in developing and implementing local air pollution control
measures as an enforceable portion of the State Implemen-
tation Plan (SIP).
Such requirements may be an integral part of the regulations
forthcoming under section 316 of the Clean Air Act.
Other regionwide coordination efforts in planning may be
far less specific than an enforceable written agreement. The
negative declaration written for the Cardiff Sanitation District
in California mentioned that, "the Board of Supervisors of the
County of San Diego, acting as the Board of Directors of Cardiff
and Solana Beach Sanitation Districts, adopted a resolution of
support for the AOMP effort to help assure consistency of air
and water quality planning." A more specific Memorandum of
Understanding between the Sacramento Regional Area Planning
Commission, the Sacramento Regional County Sanitation District,
the Californian State Water Resources Control Board, and the
California Air Resources Board has been signed to "consolidate
the air quality analysis of the Natomas Interceptor System Proj-
ect Report and EIR with the development of a regional Air Quality
Maintenance Plan, which will contain a detailed Air Quality Main-
tenance Area air quality analysis, to avoid duplication of effort
and enhance the quality of the air program; and to provide assur-
ance that operation within the Natomas Interceptor System sewer
service area will be consistent with the findings and recommenda-
tios of the adopted AQMP.
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The negative declaration for the treatment plant upgrading
at the City of Thousand Oaks, California, documented that the
city, "agreed to participate in the formulation of the Air
Quality Maintenance Plan currently being developed under the
direction of the Ventury County Air Pollution Control District,"
and a similar reference is contained in the Simi Valley, Califor-
nia, treatment plant upgrading project.
Technical Effectiveness: Planning and coordination is a
long range and indirect approach to improving air quality.
Whether or not measurable benefits can ever be attributed to
this sort of measure is hard to decide.
Implementability: Planning coordination measures do not
seem to impose significant burdens of localities, since we have
no records of any grantees objecting to such requirements.
Administrative Complexity: There appears to be no signif-
icant burden on EPA in arranging for grantees to participate in
these programs; where memos of understanding or grant conditions
are formally written up (as seems desirable), there may be a
small amount of administrative time spent.
Social and Economic Impacts: Relating to the measure it-
self, no impacts are visible.
Comments: Given the apparent low cost both to EPA and the
grantees of requiring this sort of planning coordination, the
long range benefits—even if indirect and variable from case to
case—are undoubtedly positive.
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REFERENCES
City of Thousand Oaks, Hill Canyon and Olsen Road Treatment
Plants Upgrading. EPA Region IX, Negative Declaration,
February 14, 1978.
City of Thousand Oaks, EPA Region IX, Environmental Impact
Appraisal in Support of a Negative Declaration (undated).
Upgrading Simi Valley Water Quality Control Facility,
EPA Region IX, Negative Declaration. May 6, 1977.
Enlargement and Upgrading of San Elijo Pollution Control
District Facilities. • EPA Region IX, Negative Declaration
April 4, 1978.
Memorandum of Understanding, Air Quality, Sacramento Region.
Sacramento Regional County Sanitation District, Sacramento
Regional Area Planning Commission, California State Air
Resources Board, California State Water Resources Control
Board, U.S. EPA, Air and Water Divisions. November-December
1977.
Denver Regional Environmental Impact Statement, Section
III, Significant Issues - Air Quality.
Secondary Impact of Regional Sewerage Systems. Sheehan,
Patricia Q., Commissioner, DCA. June 1975.
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4.5 Progress Reporting on Air Programs
Description: One obligation that does not often seem to be
spelled out in relation to mitigation measure implementation is
the responsibility of grantees to make specific reports to EPA.
The negative declaration issued to the Simi Valley Water Quality
Control Facility in Ventura County, California, did lay down
specific notification requirements in relation to ultimate Step 3
funding of their project. They were:
"In addition, an EPA grant condition will require
that prior to the award of a "Step 3" grant for
construction of this project, either the State Air
Resources Board (ARE) or the appropriate local
government entities must provide EPA with the
following:
a) an adopted air quality mitigation program to
offset the potential air quality impacts of
the proposed project;
b) a schedule providing for the earliest feasible
submittal to EPA of the adopted air quality
mitigation program, and the timetable for
implementing each specific measure; and
c) a schedule providing for the earliest feasible
submittal to EPA of the adopted air quality
mitigation program as a revision to the State
Implementation Plan (SIP) for air quality."
In relation to the Vail grant agreement in Region VIII, we noted
that there was no routine requirement for the community to report
back on its progress in effecting the terms of the grant condi-
tion; with the departure of the staff originally involved in
setting the measure up, there was no plan for seeing that the
ordinance required by the agreement was, in fact, enacted. Such
feedback would be an obvious way to monitor compliance, and would
be a prerequisite to enforcement.
Technical Effectiveness: No direct relation to mitigation
measures.
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Implementability: Such, requirements appear to us to impose
no significant burden on the grantee, though the extent of the
reports demanded is the key point, here.
Administrative Complexity; There would be no significant
burden on EPA to enact reporting requirements as adjuncts to
grant conditions; in fact, this measure would reduce EPA adminis-
trative burdens in enforcement.
Social and Economic Impacts: Insignificant.
Comments: As far as we can tell, this measure has no draw-
backs.
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REFERENCE
Upgrading Simi Valley Water Quality Control Facility,
(CA). EPA, Region IX, Negative Declaration. May 6,
1977.
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4.6 Changes in Effective Grant Ratios
Description: New Jersey's Department of Community Affairs,
in their report "Secondary Impact of Regional Sewerage Systems",
point out what many others have mentioned—the tendency of cheap
dollars to overinflate project designs at the local level. In
New Jersey's case, where the state contributes 15% of capital
costs and brings the effective matching rate up to 90%, they
argue:
Federal grant programs are viewed as windfall, one-shot
endeavors which local officials clearly understand from
their experience may never come their way again. It is
in 'the interest of the local municipality to obtain as
much as possible, and still be able to meet debt service
payments on the local share of costs. (p. 210)
This theme is well known; we quote New Jersey's perspective
merely to indicate that states may view it in the same way as
critics of the program at the national level. Given that EPA
has recently revamped its regulations regarding reserve capacity,
and in the light of the 1977 Clean Water Act amendments and com-
panion regulations, there appears to be almost nothing available
to use as a tool to further reduce the federal share to local
projects. Prospects might include:
o Agreements with states to limit their own contributions
to the program. Unlikely.
o Use of the priority lists to discourage projects with
high growth by putting such categories as collection
systems at a lower priority than treatment plants.
This approach seems opposite to most present orderings
of the priority lists, since they are meant to favor
the most "needy" projects.
Technical Effectiveness: Given the arguments advanced by
critics, lower effective matching rates would lead to projects
with less secondary impact potential. They would also tend to
lead to less cost-effective projects, by EPA's standards. In
terms of ultimate air quality impacts, the benefits are very
unclear.
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Implementability: Once in force, lower matching rates
would be self-implementing. Putting them into effect seems a
remote possibility, however.
Administrative Complexity: If the means of effecting a
lower matching rate were to involve new rules on eligibility and
priorities rather than a flat (legislated) reduction in the
percentage of the federal share, there would be a considerable
burden on EPA to adjust to the new rules.
Social and Economic Effects: Could possibly lead to a more
efficient allocation of national resources, but the issues are
complex .
Comments: There really seems to be nowhere to go with this
.issue, given recent amendments to the act and regulations. We
also doubt that systematic air quality benefits could be attri-
buted to such a strategy.
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4.7 Direct Grants to General Purpose Governments
Description: General purpose governments, unlike single
purpose grantees (sewer districts), have direct power over local
land use regulation and some forms of emissions reductions mech-
anisms. They are capable of much more flexibility in enacting
mitigation measures, and are much more accountable for enforcing
them.
Mechanisms to direct funds preferentially to general purpose
governments are not formally in use anywhere, to our knowledge.
Short of a change in the regulations or the act, it appears that
only the priority list could give greater weight to applications
by general purpose governments over those from single purpose
governments. Failing that, legal means might be available to
secure three-cornered contracts linking the local general purpose
government directly into the grant instrument. The Denver EIS
mentioned the problem, and usggested that formation of regional
services agencies could help solve it. State authority appears
to govern here.
Technical Effectiveness: This measure would significantly
increase the enforceability of grant conditions overall.
Implementability; Questionable. Must await legal evaluation
to determine if any approach to this strategy is possible without
significant changes to either the law or the regulations. Another
issue is how to handle necessary exceptions. From the local
viewpoint, this might be a very unpopular strategy.
Administrative Complexity: Not known.
Social and Economic Impacts: Presumed not significant, but
institution problems may arise.
Comments: We hope that the legal evaluation will provide
precedent and will help develop an implementable and flexible
approach.
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REFERENCE
EPA. "Denver Regional Environmental Impact Statement
for Wastewate'r Facilities and the Clean Water Program."
(Mpas and Draft Summary).
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4.8 Indirect Source Review for Wastewater Facilities
Description: With the delegation of indirect source review
(temporarily), to the states, the issue of whether or not sewers
and treatment plants can be considered indirect sources has been
put aside. However, evaluations of secondary air pollution
effects seems tacitly to consider these projects as secondary
sources. Formal consideration of these projects as indirect
sources of air pollution might improve the quality of environ-
mental review given to secondary impacts. EPA might seek written
agreements with state, regional, or local authorities that all
wastewater facilities be considered as indirect air pollution
sources for the purposes of environmental review. The Livermore-
Amador EIS advocates indirect source review on the local level:
Indirect Sources Review (ISR) such as the program which has re-
cently been terminated by the Environmental Protection Agency.
Such a program may prove to be more feasible at the local level
where it can be more easily tied to local plans. ISR involves
a review of major projects which msy contribute to the generation
of additional vehicular travel, thus contributing to the degrada-
tion of air quality. Such major projects may be highways or
shopping centers which would generate substantial new traffic.
Technical Effectiveness: The purpose of this measure would
be to direct increased attention to secondary air quality impacts
of wastewater facilities in environmental reviews at levels other
than federal (regional EPA offices).
Implementability: Imposes additional burdens on other govern-
ments for environmental review.
Administrative Complexity: Seems uncomplicated from EPA's
viewpoint, but issue is too broad for its consequences to be
easily understood.
Social and economic Impacts: Presumed insignificant.
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Comments: This measure should be given general legal
evaluation to determine what form, if any, is possible to imple-
ment.
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REFERENCE
Livermore-Amador Valley Wastewater Management Program.
Draft EIS. EPA Region IX. October 1975.
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4.9 Modify Environmental Review Procedures
Description; A number of sources have advocated explicit
consideration of air quality impacts in environmental review pro-
cedures for water-related projects.
The Contra Cost EIS makes the point that "in the absence of
any modifications of state or Federal law, it remains the preroga-
tive of the decision body (reviewing an environmental impact
report) to accept the EIR as adequate, without necessarily being
directed by its findings." Nevertheless, it refers to an environ-
mental impact assessment as an "information document," which
could go farther than it often does in specifying adverse air
quality, VMT or trip impacts associated with secondary development.
This, in turn, could support explicit recommendations of mitigation
strategies under yet-to-be-developed guidelines.
This:
"Might further specify the air quality change,
VMT changes or trip changes that constitute
significant impacts. This may be necessary to
deal with the argument that incremental changes
are not significant in proportion to the whole,
until critical thresholds are reached or
exceeded. Otherwise, the project furnishing
the first increment of impact which exceeds the
"significant" thresholds will bear the burden
not only of its own impacts but also of the
contribution of all its predecessors."
This is, in effect, a call for a document such as the guidebook
to be produced under this contract. It does, however, bring up
the issue of cumulative effects on a region-wide scale, and under-
scores the need to consider secondary impacts as a regional, not
purely a local, problem.
Technical Effectiveness: Not applicable.
Implementability: Proposal too vague to evaluate.
Administrative Complexity; Proposal too vague to evaluate.
Social and Economic Impacts: Proposal too vague to
evaluate.
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Comments: The Livermore Amador EIS also mentions this
approach in the following fairly cryptic passage:
"Adopt an air quality element within local
general plans. Such air quality elements
may establish the constitutionality of the
related measure."
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REFERENCES
Planning Environment International & Herman D. Ruth &
Associates. Central Contra Costs Sanitary District
Wastewater Treatment Facility Expansion: Secondary Air
Quality Impacts and Mitigation Analysis. Prepared for
J.B. Gilbert & Associates, Inc. August 1975.
Livermore-Amador Valley Wastewater Management Program.
Draft EIS. EPA Region IX. October, 1975.
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4.10 Marginal Cost Pricing of Utilities
Description: The Livermore-Amador EIS maintains that second-
ary impacts can be mitigated by the use of marginal cost pricing.
"Marginal cost pricing of utilities would be
similar in effect to the restriction of the
extension outside of existing centers. This
means would apply economic pressure on developers
to pay for the extra cost of extending facilities
beyond the existing service area. The legality
of such restrictions may be made more viable by
making such extensions dependent upon the achieve-
ment of air quality standards to the protection
of the communities general health and welfare.
Technical Effectiveness: Indirect, at best.
Implementability: The definition of this measure is unclear
enough that we cannot make any real judgments about implementa-
bility. If the measure is, in fact, somewhat along the lines of
the Ramapo, NY, point system for development (see 2.8 above), then
implementability would depend on having a willing grantee, for
there would be significant costs associated with its use.
Administrative Complexity: Assuming that a reasonably stan-
dard format could be recommended for widescale application, adminis-
trative requirements from EPA's end would be fairly small, we guess.
Social and Economic Impacts: The measure is too vague to
evaluate, but clearly the effects would be significant, at least
as they would affect local construction industries.
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REFERENCE
Livermore-Amador Valley Wastewater Management
Program. Draft EIS. EPA Region IX. October
1975.
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4.11 Program Monitoring
Description: Beyond the possibility of simply requiring
grantees to report periodically on various issues related to
mitigation is the need for EPA to actively monitor local programs.
In his flay 1, 1978, Memo on Urban Program Initiatives, the EPA
Administrator described the problem:
Grant conditioning cannot succeed without the monitoring
of project-related activities which continue after the
funds have been awarded. Monitoring after the fact iden-
tifies potential violations of grant conditions and other
binding agreements made between EPA and the grantee. EPA
will consider the option of developing a well-publicized
monitoring program. Such a program will also act as a
deterrent to inappropriate actions on the part of the
grantee.
This contract can aid in the development of such a monitoring
effort. To date we have no further information on the status
of this monitoring program, but will continue investigating it
and evaluating its form and content in line with the evaluation
criteria listed in a separate report.
Technical Effectiveness: Being an enforcement tool, this
measure's impact on air quality is indirect.
Implementability: Insofar as the program will be primarily
EPA's responsibility (absent reporting requirements on grantees),
its implementation should be simple.
Administrative Complexity: Depends on the design of the
program. Significant levels of effort will probably be required.
Social and Economic Impacts: No direct impacts. Indirect
impacts include simply the better enforcement of grant conditions.
These impacts should not be attributed to the enforcement or
monitoring programs.
Comments: This program already has EPA backing, and requires
further development and evaluation.
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REFERENCES
EPA Urban Program Initiatives, Analysis of New Program
Initiatives: Construction Grants Program Modification
Options to Minimize Sprawl. Draft. March 1, 1978.
Ill
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