INTEGRATING EPA'S AGRICULTURE AND
WATER GRANT PROGRAMS
A Comparison of 16 Programs that Protect
the Water Resource From Agricultural Contamination
United States Environmental Protection Agency
Office of Pesticide Programs
H7506-C
October 1992
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INTEGRATING EPA'S AGRICULTURE AND
WATER GRANT PROGRAMS
A Comparison of 16 Programs that Protect
the Water Resource From Agricultural Contamination
United States Environmental Protection Agency
Office of Pesticide Programs
H7506-C
October 1992
-------
Contents
Chapter Page
Abbreviations iii
1 Introduction and Recommendations for Using this Report 1
2 Summary of 16 EPA Agriculture and Water Programs and
Strategies 9
3 Regional Coordination Activities and EPA's Future
Integration Plans .. 29
Appendices
A Detailed Fact Sheets on Each of the 16 EPA Agriculture
and Water Programs and Strategies 35
B Comparison Matrices 107
C Results fron the Water/Pesticides and Toxics Regional
Coordination Survey 137
D EPA Agriculture and Water Integration Work Group
Members 159
E EPA Regional Program Contacts 163
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Abbreviations
Abbreviations
Programs and Strategies
1.
2.
3.
4.
CSGWPP
WHP
PSMP
Class V UIC
5. NFS
6. CNPS
7. PWS
8. NCW
9. NEP
10. CBP
11. SWPP
12. CLP
13. NPDES
14. CWA §106
15. APPS
16. NAP
Comprehensive Ground Water Protection Program
Wellhead Protection Program
Pesticides State Management Plan Program
Class V (Agriculture Drainage Wells) Underground Injection
Control Program
Nonpoint Source Program
Coastal Nonpoint Source Program
Public Water Supply Program
Near Coastal Waters Program
National Estuary Program
Chesapeake Bay Program
State Wetlands Protection Program
Clean Lakes Program
National Pollution Discharge Elimination System (specifically
the Feedlot Program under NPDES)
Clean Water Act Section 106 Program
Agriculture Pollution Prevention Strategy
Nitrogen Action Plan
Statutes
CWA
CZMA
CZARA
FIFRA
SDWA
RCRA
CERCLA
Clean Water Act
Coastal Zone Management Act
Coastal Zone Act Reauthorization Amendments
Federal Insecticide, Fungicide, and Rodenticide Act
Safe Drinking Water Act
Resource Conservation and Recovery Act
Comprehensive Environmental Response, Compensation, and
Liability Act
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Abbreviations
EPA Program Offices
OPPTS — Office of Prevention, Pesticides, and Toxic Substances
OGWDW — Office of Ground Water and Drinking Water
OWEC — Office of Wastewater Enforcement Compliance
OW — Office of Water
OWOW — Office of Wetlands, Oceans, and Watersheds
Other Federal Agencies
NOAA — National Oceanic and Atmospheric Administration
SCS — Soil Conservation Service
USDA — U.S. Department of Agriculture
USGS — U.S. Geologic Survey
Other Abbreviations
MCL — Maximum Contaminant Level
BMP — Best Management Practice
MOU — Memorandum of Understanding
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Chapter 1
Chapter 1
Introduction and
Recommendations for Using This Report
Chapter 1 provides background information on EPA's Agriculture and Water
Integration Project, including the purpose of the project and the progress of the
Agriculture and Water Integration Work Group. This chapter also provides
recommendations to federal and State staff for using this report and lists the programs
and strategies that were included in the project.
I. Background
Under various statutory authorities, the Environmental Protection Agency (EPA)
is responsible for carrying out a number of programs that address the problem of
agricultural contamination of the water resource -- e.g. the Pesticides and Ground Water
Strategy, the Nonpoint Source Program, the National Estuary Program, and the Clean
Water Act Section 106 Program. Many of these programs are implemented on the State
level, are funded in part by EPA grants, and contain similar goals and requirements.
In June 1991, senior managers in the Agency's Office of Water (OW) and Office
of Prevention, Pesticides and Toxic Substances (OPPTS) met to discuss the problems on
both the federal and State level that have resulted from a lack of coordination of these
programs. For example, while the programs are very similar in nature (e.g. they all focus
on preventing or addressing contamination of the water resource), they are authorized
under a variety of statutes and run by five different offices within the Agency. As a
result, the potential exists for duplication of effort on all levels of government and for
inefficient use of federal and State resources.
To address these problems, a staff work group was formed of over 20
representatives from eight EPA Headquarters and Regional offices to inventory all of the
Agency's programs and strategies that address the problem of agricultural contamination
of the water resource, and to develop recommendations for coordinating and integrating
activities in the EPA grant process. The specific charge given to the work group was to:
• Conduct an inventory of all of the Agency's programs and strategies
that protect the water resource from contamination by agricultural
practices;
• Compare the basic approaches and major components of each
program and strategy;
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Chapter 1
• Identify the similarities and overlaps among programs and strategies,
as well as the areas where they differ in their approach to protecting
the water resource; and
• Develop recommendations for increasing coordination of the
programs and strategies and their grant guidances.
In a separate but related action, EPA Regional Offices IX and X agreed to poll
all 10 Regional Offices on existing coordination of agricultural activities. The results of
this survey are summarized in Chapter 3 and the complete report on the survey can be
found in Appendix C.
The Agriculture and Water Integration Work Group met several times over the
summer and fall of 1991 and compiled detailed information on 16 EPA agriculture and
water programs affecting States. Over the winter and spring of 1992, briefings were held
for the Division Directors and Office Directors that provided oversight for the project.
The final products and recommendations of the work group are provided in the chapters
and appendices of this report.
II. Purpose of This Report and Recommendations for Using It
"Integrating EPA's Agriculture and Water Programs: A Comparison of 16
Programs that Protect the Water Resource From Agricultural Contamination" is a
compilation of the various products developed by the EPA Agriculture and Water Work
Group. They are intended to provide a comprehensive summary and comparison of 16
EPA programs and strategies relating to agricultural activities and water resources.
Although the report is not meant to replace statutes, regulations, programmatic guidance,
or grant guidance as the authoritative sources of EPA requirements and policies for each
program, it is intended to serve as a compendium of the general goals, requirements, and
benefits of these programs for Headquarters, Regional, and State staff who work on
agriculture and water programs. The detailed program fact sheets and comparison
matrices in Appendices A and B may be the most useful part of the report to federal and
State staff because they represent the only detailed and comprehensive resource to date
on all 16 programs and strategies.
Clearly, more work needs be done at EPA across programs to achieve common
goals such as protecting the water resource from agricultural contamination. This report,
however, is intended to be used as a starting point for federal and State-level staff in
identifying coordination and integration opportunities across EPA programs for increased
efficiency and effectiveness in protecting water resources from agricultural pollution. The
material presented in this report will be especially helpful in:
Coordinating EPA grant programs on the federal and State levels;
and
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Chapter 1
• Developing future federal and State strategies and policies for
protecting the water resource from agricultural contamination.
Coordinating EPA Grant Programs •- Questions to Consider:
Since this project's inception, one of its main objectives has been to assist EPA
staff who make decisions on grant awards to States. The information presented in this
report can assist federal and State officials in coordinating and integrating activities at the
State level and in better leveraging grant dollars to most effectively address their
agricultural contamination problems.
EPA staff can use the report to ensure that EPA and State efforts are not
duplicative or at cross purposes. The report identifies programs that provide similar
grants and support related protection efforts. Staff can check with other program offices
that address similar contamination sources and water bodies to ensure that EPA is not
funding a State activity that is also being funded by another EPA program office. On the
other hand, EPA staff also can use the report to check whether a program is funding an
activity that is in conflict with other EPA program requirements or funding sources.
Elimination of duplication and of efforts at cross purposes with each other will assist
EPA and the States in using existing limited resources in the most effective and efficient
way possible.
The following questions should provide a useful starting point for EPA staff as
they use this report to coordinate EPA grant programs and work with States on
preventing and addressing agricultural contamination of ground and surface water:
/ Are the States conducting the same or similar activities under a
different EPA program, and if so, are both programs providing
funds for that activity?
/ Do any of the States' specific activities conflict with goals another
program is trying to achieve? Will EPA be funding an activity that
actually conflicts with another program's goals and objectives?
/ Have the States thought through how they are going to coordinate
all of the agricultural activities in their water-related programs? Are
they using common program elements in a mutually supporting way?
Have the States chosen the right mix of EPA support from the 16
programs described in the report to address agricultural and water
problems in the most effective way?
/ Finally, how can EPA (at both the Headquarters and Regional level)
more effectively integrate its grant programs and/or guidances to
support the States' efforts to address agricultural and water
problems?
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Chapter 1
Developing Strategies and Policy:
EPA and the States will benefit from using this report to develop and coordinate
future programmatic guidance as well as agency-wide strategies and policies.
• EPA Headquarters: EPA program office staff may find the report a useful
starting point when looking broadly across programs and coordinating the
development of guidance documents as well as major policy decisions. The
report may be useful in determining where gaps in protection exist and
where the focus of existing efforts ought to be.
• EPA Regional Offices: Regional staff can use the report to coordinate and
integrate the activities of similar programs. The report could also be used
to develop Regional guidance to ensure the coordination of grants and
other activities to better protect water resources from agriculture-related
pollution sources.
• States: States can use the report to ensure that existing and future activities
move forward in a mutually supporting way. States may also find the
report useful in developing programs, choosing the right mix of EPA grants
and other support for addressing agricultural contamination of water
resources, and coordinating schedules for developing and submitting grant
applications to EPA.
III. Organization of the Report
This report is a compilation of the materials developed and insights gained by the
Agriculture and Water Integration Work Group since it first met in 1991. The report is
organized into the following chapters and appendices:
Chapter 2 -- Sixteen EPA Agriculture and Water Programs and Strategies:
Presents and compares general information on the programs, such as the
program goals and the waters targeted for protection, as well as the review
and approval processes for the 16 programs. It provides a sense of the
range of approaches taken and the various stages of development and
implementation of all the programs. In addition, it provides a brief
summary of the similarities and differences among programs.
Chapter 3 -- Regional Coordination Activities and EPA's Future Integration
Plans: Summarizes the Regional Coordination Survey conducted by Regions
IX and X and outlines EPA's future plans to further integrate and
coordinate agriculture and water programs.
Appendix A -• Program Fact Sheets: Contains an executive summary and 16 two-
page fact sheets on each of the programs, with detailed information on the general
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Chapter 1
approach taken (e.g. goal of the program, risks addressed, priorities for achieving
the goal, mandatory or voluntary, etc.) and the review and approval process (EPA
Headquarters and Regional roles, State agencies involved, program status, how
grants can be used, review schedule, etc.).
Appendix B -- Comparison Matrices: Compares the information collected in the
fact sheets across all programs in three sets of matrices. The first matrix covers
general goals and approaches; the second covers the review and approval
processes; and the third covers the components of a program that EPA requires
States to develop to receive grants.
Appendix C - Regional Coordination Survey: Contains the results from the
Water/Pesticides and Toxics Regional Coordination Survey that was conducted by
EPA Regions IX and X.
Appendix D -- EPA Work Group Members: Lists the Agency staff who participated
on the Agriculture and Water Integration Work Group and assisted in developing
this report.
Appendix E - Regional EPA Offices with Responsibility for Agriculture and Water
Programs: Lists the addresses and phone numbers of the EPA Regional Offices
with responsibility for carrying out the 16 programs.
IV. Programs and Strategies Covered
The table presented on the next two pages provides a brief overview of the 16
programs and strategies covered in the project and described in this report. The
programs and strategies are:
Ground Water Programs
I. Comprehensive State Ground Water
Protection Program
2. Wellhead Protection Program
3. Pesticides State Management Plans
4. Class V (Agriculture Drainage Wells)
Underground Injection Control Program
Ground Water & Surface Water Programs
5. Nonpoint Source Program
6. Coastal Nonpoint Source Program
7. Public Water Supply Program
Surface Water Programs
8. Near Coastal Waters
9. National Estuary Program
10. Chesapeake Bay Program
11. State Wetlands Protection Grant Program
12. Clean Lakes Program
13. National Pollution Discharge Elimination
System Program
14. Clean Water Act Section 106 Program
Strategies
15. Agriculture Pollution Prevention
Strategy
16. Nitrogen Action Plan
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Chapter 1
EPA Agriculture and Water Programs and Strategies
GROUND WATER PROGRAMS
Program & Authority
(1) Comprehensive State
Ground Water
Protection Program
(CSGWPP)
(CWA, SDWA,
FIFRA, CERCLA, &
RCRA)
(2) Wellhead Protection
Program (WHP)
(SDWA §1428)
(3) Pesticides State
Management Plan
(PSMP)
(FIFRA)
(4) U1C Program: Class V
Wells (Class V UIC)
(Ag Drainage Wells)
(SDWA §1421-1426)
Summary of Program
States develop and implement
CSGWPPs, which address all sources of
ground water contamination, in priority
fashion, using federal, State, and local
authorities.
States develop and implement land-use
controls and other preventive measures
for all sources of contamination within
wellhead protection areas.
For specified pesticides, States develop
and implement SMPs, which establish
management practices that allow use of
the pesticide while protecting the ground
water.
Affords protection of all underground
sources of drinking water from
contamination by well operations. States
may obtain primacy to implement the
program.
Agriculture-Related Activities
Provides framework for coordinating all
Agency ground water programs,
including Pesticide SMPs. To receive
EPA concurrence, States will have to
set priorities for addressing all sources
of contamination, including agricultural
sources.
Promotes BMPs and other controls of
agricultural sources of contamination.
Assisted SCS's Rural Well Protection
Project.
Promotes management of pesticide use
based on State's unique hydrological
and agricultural characteristics. Agency
is providing technical assistance on
assessment, monitoring, prevention and
response components of SMPs.
Through a rule-making process
(currently underway), agricultural
drainage wells will be addressed by a
series of agricultural BMPs
incorporated in CSGWPPs.
GROUND WATER AND SURFACE
WATER PROGRAMS
Program & Authority
(5) Nonpoint Source
Program (NPS)
(CWA §3 19)
(6) Coastal Nonpoint
Source Program
(CNPS)
(CZARA)
(7) Public Water Supply
Program (PWS)
(SDWA)
Summary of Program
Grant program which provides annual
grants to States to address NPS pollution.
Grant requirements are flexible, so States
can address NPS problems in a
prioritized fashion.
Development of Slate programs to insure
implementation of NPS management
measures to restore and protect coastal
waters.
States or EPA enforce drinking water
standards (MCLs) at the tap. Systems
can use a combination of prevention and
treatment to meet MCLs
Agriculture-Related Activities
To date, agriculture-related activities
have received the most funding.
Activities include assistance to farmers,
education on farming practices to
protect water quality and drinking
water quality, and cost sharing for
BMPs.
Addresses erosion/sediment control,
animal facility management, pesticide/
nutrient management, grazing
management, and irrigation
management.
MCLs have been promulgated for 25
pesticides and nitrogen compounds
Interest in agricultural activities focuses
upon MCL compliance and
vulnerability assessment.
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Chapter 1
SURFACE WATER PROGRAMS
Program & Authority
Summary of Program
Agriculture-Related Activities
(8) Near Coastal Waters
Program (NCW)
Begun as Agency Initiative aimed at
maintaining and enhancing NCW quality.
Currently implemented through Regional
NCW strategies and yearly work plans
which are supported by grants from
Headquarters.
Does not have specific agricultural
priorities. Activities addressing
agricultural sources can be included in
Regional NCW strategies, and can
include technical assistance, public
outreach, etc.
(9) National Estuary
Program (NEP)
(CWA §320)
For estuanes of national significance,
States develop and implement
Compliance Conservation Management
Plans (CCMPs) with Headquarters
supplying technical and financial
assistance.
Agricultural activities may be identified
in individual CCMPs.
(10) Chesapeake Bay
Program (CBP)
(CWA §117)
Region III and the Bay States work
together to implement projects which will
protect, restore, and enhance the Bay.
Grants are available for direct financial
assistance to farmers for BMPs.
(11) State Wetlands
Protection Grant
Program (SWPP)
(CWA §104(b))
Program provides grants to support the
development of State Wetlands
Protection Programs.
Agriculture is not identified as a
specific priority; however, agriculture-
related activities may be part of State
Wetlands Conservation Plans.
(12) Clean Lakes Program
(CLP)
(CWA §314)
Provides assistance to conduct lake
restoration, protection, and assessments.
Does not specifically require
agricultural activities; however, grant
funds can be used to implement
agricultural BMPs in lake watersheds.
(13) NPDES Program
(NPDES)
(CWA §402)
(40 CFR 122.23)
Focuses on developing and implementing
NPDES permitting program.
Developing a guidance to expand the
focus of feedlots permits to BMPs for
land application, manure storage, and
composting.
(14) Clean Water Act
§106 Surface Water
Program
(CWA §106)
Provides base program funding support
for a variety of State water quality
management activities.
Grants support some agriculture-
related activities, such as monitoring
surveys, printing of publications, and
ADP support.
STRATEGIES
Program & Authority
Summary of Program
Agriculture-Related Activities
(15) Agriculture Pollution
Prevention Strategy
(APPS)
Product of EPA strategic planning that
will set targets and monitor success in
achieving agricultural pollution prevention
goals.
Based on national commitment to
integrate existing programs addressing
agriculture-related pollution.
(16) Nitrogen Action Plan
(NAP)
Product of EPA strategic planning that
coordinates a number of EPA offices to
protect ground and surface water from all
sources of contamination by nitrogen
compounds through pollution prevention.
Focuses on reducing fertilizer use and
better controlling runoff and infiltration
from livestock operations. Activities
include technical assistance, education,
enforcement, and research. Nitrate
contamination of public and private
drinking water supplies is also a major
focus.
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Chapter 2
Chapter 2
Summary of 16 EPA Programs and Strategies
Chapter 2 summarizes and compares specific program elements, such as the program
goals and the waters targeted for protection, as well as the review and approval process
for State submittals for the 16 programs and strategies comprising this project. The
chapter also presents the range of regulatory and non-regulatory approaches and the
various stages of development and implementation of all the programs.
This chapter consists of three sections. The first section, "General Overview of
Programs and Strategies," provides a description of the general goals as well as the
regulatory or non-regulatory approaches used by the programs to protect waters from
agricultural pollution. The second section, "Review and Approval Process," discusses the
review process for State submittals for EPA grants under each of the 16 programs.
Finally, the third section provides the reader with a summary of the similarities and
differences of the programs and strategies.
I. General Overview of Programs and Strategies
This section provides general information concerning the following program elements
for each program and strategy included in this project:
A. Statutory authority;
B. State participation in development and implementation of the programs;
C. General goals and objectives;
D. Agricultural activities and priorities; and
E. State flexibility in addressing program requirements.
Additional detailed information on each program can be found in Appendix A and
Appendix B.
A. Statutory Authorities
The statutory authorities under which the 16 Agriculture and Water programs and
strategies operate determine, to a large extent, the characteristics of the various
programs, particularly in the review and approval process for awarding EPA grants.
There are three generally defined types of programs:
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(1) Those programs that operate under direct statutory authority;
(2) EPA policy approaches and strategies; and
(3) Programs that focus on specific geographic areas.
The statutory authority of the programs generally determines how each functions.
Programs with clear, well defined statutory authority tend to be relatively prescriptive in
terms of required participation, sanctions, and program requirements. Programs that are
the result of strategic initiatives tend to provide greater flexibility to the State.
• Ten of the programs derive authority from two statutes: the Clean Water
Act (7 programs) and the Safe Drinking Water Act (3 programs). One
program derives regulatory authority from the Federal Insecticide,
Fungicide, and Rodenticide Act, and one derives its authority from the
Coastal Zone Act Reauthorization Amendments of 1990.
• Eleven programs have direct statutory authority. They are the
Wellhead Protection Program, Class V UIC Program, NPS Program,
Coastal NPS Program, Public Water Supply Program, National Estuary
Program, Chesapeake Bay Program, State Wetlands Protection
Program, Clean Lakes Program, CWA §106 Program, and NPDES
Program.
• Five programs are not directly authorized under a specific statutory
authority but have been developed through an EPA strategic planning
process. They are the Comprehensive State Ground Water Protection
Program approach, Pesticides SMP Program (although FIFRA provides
authority to regulate the use of pesticides), Near Coastal Waters Program,
Agriculture Pollution Prevention Strategy, and Nitrogen Action Plan. The
Comprehensive State Ground Water Protection Program was developed by
a high-level EPA Ground Water Task Force. The Comprehensive State
Ground Water Protection Program, Agriculture Pollution Prevention
Strategy, and Nitrogen Action Plan rely on the coordination of several
programs.
B. State Participation
In general, programs that have direct statutory authority are more likely to be
mandatory State programs than programs that derive authority from several statutes, or
strategic .initiatives, which generally encourage voluntary State participation. In addition,
statutorily authorized programs tend to impose stiff sanctions for non-participation.
• Two of the programs encourage participation in exchange for State
primacy and grant funds (Class V UIC Program and Public Water
Supply Program). The result of non-participation is administration of
the program by the EPA Regional Office and a loss of grant funding.
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• Ten of the programs are voluntary, with non-participation resulting in
decreased or total loss of grant funding only (Comprehensive State
Ground Water Protection Program, Wellhead Protection Program, NPS
Program, Coastal NPS Program, Near Coastal Waters Program,
National Estuary Program, Chesapeake Bay Program, State Wetlands
Protection Program, Clean Lakes Program, and CWA §106 Program).
• Non-participation in the Pesticides SMP Program, also a voluntary
program, results in cancellation of the particular pesticide in the State.
• In the case of the NPDES Program, no action is taken for non-
participation.
• Non-participation in the Agriculture Pollution Prevention Strategy may
result in loss of funding, and varying sanctions across programs result
from non-participation in the Nitrogen Action Plan.
C. General Program Goals and Priorities
The goals of the various programs are generally consistent. Each of the programs
attempts to prevent and mitigate the impacts of pollution on water resources (ground
water, drinking water, surface water, lakes, bays, estuaries, etc.). The goals of programs
that operate under broad statutory authority generally include protection of water
resources, pollution prevention, and restoration of water resources. The goals of region-
specific programs focus on distinct geographical areas (e.g., Chesapeake Bay, lakes,
estuaries, near coastal waters).
The programs' priorities vary considerably depending on their focus and goals.
Specific programmatic priorities tend to be broadly defined and encompass a wide range
of activities. In spite of this, four priority activities are identified by many programs.
• Nine programs have identified technical assistance as a programmatic
priority (Wellhead Protection Program, Pesticides SMP Program, NPS
Program, Coastal NPS Program, Public Water Supply Program,
National Estuary, Chesapeake Bay Program, State Wetlands Protection
Program, and Clean Lakes Program).
• For five programs, the development of guidance for States is a major
priority (Comprehensive State Ground Water Protection Program,
Pesticides SMP Program, Wellhead Protection Program, Coastal NPS
Program, and Near Coastal Waters Program).
• Four programs identified outreach efforts to affected parties as a
programmatic priority (Comprehensive State Ground Water Protection
Program, Wellhead Protection Program, NPS Program, and National
Estuary Program).
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• Eight programs indicated that supporting States in program
implementation is a major priority (Pesticides SMP Program, Class V
UIC Program, NFS Program, Chesapeake Bay Program, State
Wetlands Protection Program, NPDES Program, and CWA §106
Program and Agriculture Pollution Prevention Strategy).
• Program definition is currently a major priority for the Comprehensive
State Ground Water Protection Program and the Nitrogen Action Plan.
D. Agricultural Activities and Priorities
Agriculture-related priorities and projects identified by each of the programs are
listed below:
• The Comprehensive State Ground Water Protection Program will
address all potential sources of contamination of ground water
resources, including all agricultural sources. The Office of Ground
Water and Drinking Water is currently coordinating with the Soil
Conservation Service (SCS), the Extension Service, as well as with
other EPA offices (i.e., OPP, OP A, OWOW), in managing the
Farmstead Assessment System project.
• The WHP Program promotes best management practices and other
controls for agricultural sources of contamination, and assists the Soil
Conservation Service in the Rural Well Protection Project.
• The Pesticides SMP Program addresses agricultural use of pesticides
and provides technical and financial assistance to States for developing
plans covering 12 basic components.
• The Class V UIC Program funds demonstration research projects and
has sponsored a forum on best management practices for agricultural
drainage wells.
• Agriculture-related NFS activities receive the bulk of the EPA grant
funding in the NPS Program. State funded activities include support
for technical assistance, educational programs, enforcement
mechanisms, and cost-share assistance for demonstration projects
related to agricultural contamination of the water resource.
• The Coastal NPS Program addresses agricultural nonpoint sources as
well as urban, silvicultural, and other nonpoint sources.
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• The Public Water Supply Program provides technical assistance and
training to public water supply systems to remove pesticides from
drinking water; and recently promulgated 25 pesticide maximum
contaminant levels (MCLs).
• The Near Coastal Waters Program coordinates agriculture-related
technical assistance activities, public outreach, and data and
information management.
• In the National Estuary Program, EPA's Oceans and Coastal
Protection Division (OCPD) is currently working with the Soil
Conservation Service to improve coordination and to provide technical
assistance to the Estuary Program's various Management Conferences.
• The Chesapeake Bay Program provides a significant amount of
financial assistance to farmers for installing agricultural best
management practices in the Bay States. The Program also provides
technical assistance, public outreach, research and modeling, and
reporting and data management.
• The State Wetlands Protection Program addresses agricultural sources
of contamination or degradation of wetlands and watersheds.
• The Clean Lakes Program provides technical and financial support for
installing agricultural best management practices in selected watersheds
where agricultural activities are contributing to a lake's water pollution
problems.
• The NPDES Program includes the development of guidances and
expansion of permits to best management practices for feedlots as
priority activities, but reported that currently there are minimal
program activities.
• The CWA Section 106 Program supplements the Nonpoint Source Program
funding for some agriculture-related activities.
• The Agriculture Pollution Prevention Strategy identifies pollution
prevention practices that will protect against contamination of water
from cropping, grazing, and confined feeding activities while assuring
the economic viability of food and fiber production.
• The Nitrogen Action Plan focuses on reducing fertilizer use and better
controlling runoff and infiltration from livestock operations.
Many of the Agriculture and Water Programs use technology transfer and public
outreach to prevent and mitigate the impact of agricultural pollution on water resources.
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In some cases, emphasis is placed on technology transfer of best management practices
(BMPs) for agriculture drainage wells or feedlots. In other programs, outreach efforts
occur in the form of guidance, training, and public education. Some programs also
provide cost sharing and support for technical assistance for installation of agricultural
BMPs.
E. State Flexibility in Addressing Program Requirements
The State role in setting priorities and the degree of flexibility in determining
program components varies among the programs. The State role does not necessarily
depend on the program's statutory authority.
• Eight programs provide States with a high degree of flexibility in
addressing program components. They are the Comprehensive State
Ground Water Protection Program, Wellhead Protection Program,
Pesticides SMP Program, Nonpoint Source Program, NEP, Clean Lakes
Program, and CWA §106 Program and the Agriculture Pollution
Prevention Strategy.
• Four programs allow States to play a moderate role in the
determination of program priorities. (Coastal NPS Program, Near
Coastal Waters Program, State Wetlands Protection Program, and
NPDES Program)
• The Public Water Supply Program provides a low degree of flexibility in
addressing program components, and the Chesapeake Bay Program
reported no flexibility.
• Two programs reported that State flexibility has yet to be determined.
(Class V UIC Program and Nitrogen Action Plan).
II. Review and Approval Process for Awarding EPA Grants
Many of the programs and strategies provide grants to States for addressing
programmatic priorities or provide primacy to States to implement the program with
EPA's assistance. The review and approval processes largely depend on the statutory
and regulatory authority of the program. For instance, programs with direct statutory
authority that encourage States to gain primacy tend to be more structured with a
defined review and approval process, while the EPA-developed strategies tend to have a
less definitive review and approval process. This section describes the review and
approval procedures for State submittals under each of the programs or strategies. This
section includes information concerning the following aspects of the review and approval
process for each program and strategy:
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A. EPA's organizational structure for implementing the program;
B. Program status at the federal and State level;
C. State activities supported by EPA grant funds;
D. Program review schedules;
E. Program review processes;
F. Process for Reviewing grant applications and making a final
determination;
G. Process for providing EPA feedback to the States;
H. Grant awards decision criteria; and
I. EPA oversight and program evaluation.
Additional information on each program can be found in Appendix A. Appendix B
provides concise comparison matrices on the 16 programs.
A. EPA's Organizational Structure for Implementing the Programs
Within EPA, the Office of Water is primarily responsible for the implementation and
development of the majority of programs that protect ground water and surface water.
• Fourteen of the programs are administered by the Office of Water in
the following offices: the Office of Ground Water and Drinking Water
(OGWDW), the Office of Wastewater Enforcement and Compliance
(OWEC), and the Office of Wetlands, Oceans, and Watersheds
(OWOW).
• The Office of Prevention, Pesticides and Toxic Substances (OPPTS),
implements one program, Pesticides SMPs.
• Region III administers the Chesapeake Bay Program.
There is also federal agency cooperation in several programs among EPA, the
United States Department of Agriculture (USDA), the United States Geological Survey
(USGS), the National Oceanic and Atmospheric Administration (NOAA), and other
agencies.
• The USDA and USGS play a role in working with States in the
Pesticides SMP Program, Comprehensive State Ground Water
Protection Program, NFS Program, Coastal NFS Program, and Clean
Lakes Programs.
• NOAA co-administers one program with EPA, the Coastal NFS
Program.
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Regional Offices are highly involved in working with the States in the review and
approval process. In many instances, the Regions review and approve State programs as
well as make determinations on grant awards. For some programs, EPA Headquarters is
involved in the review process and the final determination. The Regions tend primarily
to be responsible for the evaluation of State programs, while some oversight occurs at
the Headquarters level. Regions sometime take the initiative to develop a specific
solution to agricultural problems (i.e. Region VII has addressed the problem of atrazine
in the Southwest).
The specific State agencies involved in implementing the programs vary from State to
State. In general, the States' water quality, environmental, agriculture, natural resources,
and/or health departments tend to be involved, with several agencies sharing
responsibility for program development and implementation.
B. Program Status at the Federal and State Level
The status of State programs provides a useful method of analyzing the 16 State
programs. At the federal level, program status varies from initial policy development to
full implementation.
• At the federal level, eight programs are in the full implementation
phase. These programs include the Wellhead Protection Program, NPS
Program, Public Water Supply Program, National Estuary Program,
Chesapeake Bay Program, Clean Lakes Program, NPDES Program,
and CWA Section 106 Program. Of those eight, five are in the
"advanced" phase of implementation. Federal guidance, regulations,
and technical assistance are available for these programs. Presently,
EPA is assisting States in gaining primacy in these programs. The
National Estuary Program is in both the development and
implementation phases. Presently, 17 Compliance Conservation
Management Plans (CCMPs) are being developed under the NEP.
The Puget Sound CCMP and the Buzzards Bay CCMP are in the
implementation phase, while the remaining 15 CCMPs are still in the
development phase.
• The remaining eight programs are at various stages along the planning
and development phase at the federal level. For the Pesticides SMP,
Comprehensive State Ground Water Protection Program, Coastal NPS
Program, State Wetlands Protection Program, and Near Coastal Waters
Program, policy development and guidance development is still
occurring. The Class V UIC Program is currently developing
regulations and guidance to address agricultural drainage wells. The
Agriculture Pollution Prevention Strategy and the Nitrogen Action Plan
are still in the planning phase of development.
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A sign of program status tends to be the availability of program regulations and
guidance:
• Presently, nine programs have either regulations or guidance available
for State program development. These programs include the Wellhead
Protection Program, NFS Program, Public Water Supply Program,
National Estuary Program, Chesapeake Bay Program, State Wetlands
Protection Program, Clean Lakes Program, CWA §106 Program, and
NPDES Program.
• Guidance and regulations are in the development phase or under
consideration for seven programs. They are the Comprehensive State
Ground Water Protection Program, Pesticides SMP Program, Class V
UIC Program, Coastal NFS Program, and the Near Coastal Waters
Program and the Agriculture Pollution Prevention Strategy and
Nitrogen Action Plan.
Program status at the State level parallels program status at the federal level. In ten
programs a majority of States have achieved primacy or are working toward primacy.
• Wellhead Protection Program - 20 approved State programs;
• Class V UIC Program - 35 States have been granted primacy.
However, there currently are no specific Class V UIC Programs;
• Nonpoint Source Program -- all States have approved NFS
Assessments and Management Programs (in some cases only portions
of State management programs have been approved);
• Public Water Supply Program -- 55 States and territories have been
granted primacy;
• Near Coastal Waters Program -- five Regional strategies have been
developed (Regions I, IV, VI, IX, and X), and three Regional
strategies are being developed. In addition, in Region V, Remedial
Action Plans (RAPs) continue to be developed and implemented and
Lake-Wide Action Management Plans (LAMPs) are being developed
for Lake Michigan and Lake Ontario;
• National Estuary Program -- Puget Sound and Buzzards Bay are
implementing NEP's CCMPs. Another 15 CCMPs are under
development;
• Chesapeake Bay Program -- fully implemented at the State level;
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Chapter 2
• Clean Lakes Program -- 44 authorized States, 1 territory, and 15 Native
American Tribes participate;
• NPDES Program -- 39 approved State or territory NPDES programs;
and
• CWA Section 106 Program - all States receive grants each year.
The remaining six programs (the Comprehensive State Ground Water Protection
Program, Pesticides SMP, Coastal NPS, and State Wetlands Protection Programs and the
Agriculture Pollution Prevention Strategy and Nitrogen Action Plan) are not yet
implemented at the State level.
C. State Activities Supported by EPA Grant Funds
In order to determine where programs can better complement each other, it is
important to examine the types of program activities that each program funds.
• The Pesticides SMP Program provides funds for initial generic SMPs
before pesticide-specific SMPs are required to continue the use of a
pesticide.
• The Comprehensive State Ground Water Protection Program will
target financial assistance through the CWA §106 Program and
coordinate other EPA ground water-related grants to help promote the
development of State ground water protection programs.
• Implementation grants for the Class V UIC Program are available to
States that have accepted primacy; development grants are available to
Indian tribes.
• The NPS Program provides financial assistance to implement NPS
Programs and funds demonstration projects. In addition, Illinois used a
portion of the State's FY'91 NPS Program funds to develop a generic
SMP.
• The Near Coastal Waters Program funds development and
implementation of projects consistent with Regional Strategies.
• The Public Water Supply Program, Chesapeake Bay Program, and
Clean Lakes Program all provide funds for program implementation.
• The National Estuary Program provides five years of funding for
development of CCMPs. The Program requires States to develop a
funding strategy outlining options for implementation funding.
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• Grants for the development of new or enhanced State Wetlands
Protection Programs have been available since FY '91.
• NPDES grant funds are used for regulation of point source pollution
sources, including agricultural feedlots affecting surface waters.
• CWA §106 grant funds may be used for overall administrative and
program support for State water quality management programs.
• Grants to States for development of Coastal NPS Programs and the
Wellhead Protection Programs are authorized but have not yet been
funded by Congress.
• The uses of grants, if any, under the Agriculture Pollution Prevention
Strategy and the Nitrogen Action Plan have not yet been determined.
All but two of the programs (CWA §106 and Public Water Supply Program) that
receive funding have been funded for less than five years. Program funding, however,
varies widely and no consistently applied factors determine funding among programs.
• Grant funding provided by each of the programs in FY92 ranges from
$4 million (Near Coastal Waters) to $81.7 million (CWA §106).
• The total amount of grant dollars provided to States by all the
programs in FY'92 was $263 million, although not all was spent on
agriculture.
• All of the Pesticides SMP grants ($5 million), and 49.7% of the NPS
Program grants ($25 million in FY'91 -- FY'92 data are not yet available)
directly support agricultural activities. However, most of the programs
focus on threats to the water resource from many different sources of
contamination, the other programs were unable to provide information on
how much of their total grant funding was being used to support
agricultural activities on the State level.
• Three programs reported that grant funding is not yet being provided
by the Agency: the Wellhead Protection Program, the Agriculture
Pollution Prevention Program and the Nitrogen Action Plan.
In eleven cases, programs require State matching funds (Pesticides SMP Program,
Class V UIC Program, NPS Program, Coastal NPS Program, Public Water Supply
Program, Near Coastal Water Program, National Estuary Program, Chesapeake Bay
Program, State Wetlands Protection Program, Clean Lakes Program, CWA §106). The
required match varies from 5 percent for the Near Coastal Water Program to between 50
and 70 percent for the CWA §106 Program.
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D. Program Review Schedules
In general, the level of development of a program's review and approval process
depends on its current program status on the federal level. For example, programs that
have evolved beyond the planning and development phases into the implementation
phase are more likely to have a clearly identified review schedule and review process.
• Of the eight programs in the implementation phase of program
development, seven have formal review schedules. (Wellhead
Protection Program, NPS Program, Public Water Supply Program,
Chesapeake Bay Program, Clean Lakes Program, NPDES Program,
and the CWA §106 Program.) The National Estuary Program has not
yet established a schedule.
• Two of the review schedules of programs currently in the implementation
phase vary State-bv-State or bv grant program. (Public Water Supply
Program and Chesapeake Bay Program)
• The review schedule has not yet been determined for six of the
programs in the development or planning phases. (Pesticides SMP
Program, Comprehensive State Ground Water Protection Program,
Class V UIC Program, Coastal NPS Program, Agriculture Pollution
Prevention Strategy and Nitrogen Action Plan)
• The review schedule of two programs currently in the development
phase will vary by Region (Near Coastal Waters Program and State
Wetlands Protection Program).
E. Program Review Processes
To a lesser extent than with the review schedule, the more developed a program is,
the more likely that it has a defined review process on some level.
• All eight programs currently in the implementation phase specify a
review process. Four programs that are currently in the
implementation phase have review processes that vary State-by-State
(NPS Program, Public Water Supply Program, Chesapeake Bay
Program, and CWA §106 Program). The review process for the
National Estuary Program includes reviewing annual workplans. After
the five-year development phase, the States are on their own to
implement their CCMPs.
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• The review processes of six programs that are in the development or
planning phase have yet to be finalized (Comprehensive State Ground
Water Protection Program, Pesticide SMP, Class V UIC Program,
Coastal NPS Program, Agriculture Pollution Prevention Strategy and
Nitrogen Action Plan).
• The review processes for the Near Coastal Waters and State Wetlands
Protection Programs vary by EPA Region.
F. Reviewing Grant Applications and Making a Final Determination
In most cases, the Regions conduct program reviews. Similarly, Regions generally
provide final program approval, with or without concurrence from Headquarters.
• The lead program reviewer for eleven programs is the EPA Regional
Office (Pesticides SMP Program, Comprehensive State Ground Water
Protection Program, Wellhead Protection Program, Class V UIC
Program, Public Water Supply Program, Nonpoint Source Program,
National Estuary Program, Clean Lakes, NPDES Program, and CWA
§106 Program and the Nitrogen Action Plan). Of these programs, five
require EPA Headquarters' concurrence in at least the initial program
approval determinations (Wellhead Protection Program, Class V UIC
Program, National Estuary Program, Clean Lakes Program, and
NPDES Program).
• The Near Coastal Waters Program and the State Wetlands Protection
Program require EPA Headquarters review.
• The Coastal NPS Program will be reviewed by EPA Regions and
possibly EPA Headquarters, but this is not decided as yet. In addition,
the Coastal NPS Program requires NOAA review.
• The review process for the Chesapeake Bay Program varies depending
on the grant program involved.
• The process for making the final determination has yet to be developed
for the Agriculture Pollution Prevention Strategy.
G. Process for Providing EPA Feedback to the States
In general, the process for EPA to provide feedback to the States is not well defined.
In nine of the programs. Regions provide some sort of feedback to the
States (Pesticides SMP Program, Comprehensive State Ground Water
Protection Program, Wellhead Protection Program, NPS Program,
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Chapter 2
Public Water Supply Program, State Wetlands Protection Program,
Clean Lakes Program, NPDES Program, and CWA §106 Program).
For the WHP Program and the NPS Program, Regions provide States
with written as well as oral comments. In addition, for the NPS
Program in some cases, Regions hold negotiation sessions with States.
Feedback will occur during negotiation of the Comprehensive State
Ground Water Protection Program multiyear program plan and during
negotiation of yearly action plans between Regions and the States.
Feedback in the Pesticides SMP Program will occur during the initial
review of Generic and Pesticide Specific SMPs and during the SMP
updating process.
• The feedback process for the Chesapeake Bay Program varies by State.
• Feedback in the National Estuary Program is ongoing during the
development of CCMPs.
• Four of the programs do not yet have a defined feedback process.
(Coastal NPS Program, Near Coastal Waters Program, Agriculture
Pollution Prevention Strategy, and Nitrogen Action Plan).
• While feedback procedures are defined for the general UIC Program,
specifically procedures for Class V wells are still being developed.
H. Grant Awards Decision Criteria
The decision criteria used by EPA to award State grants vary considerably among the
programs.
• Eight programs rely on a formula for determining grant amounts
provided to States (Pesticides SMP Program, Class V UIC Program,
NPS Program, Public Water Supply Program, Near Coastal Waters
Program, Clean Lakes Program, NPDES Program, and CWA §106
Program).
• Progress towards developing and implementing the six strategic
activities of a Comprehensive State Ground Water Protection Program
will affect grant determinations.
• In five programs, the decision process for awarding EPA grants varies
based on the grant or the project (Wellhead Protection Program,
Chesapeake Bay Program, National Estuary Program, State Wetland
Protection Program, and Agriculture Pollution Prevention Strategy).
• Two programs do not yet have a process for awarding grants (Coastal
NPS Program and Nitrogen Action Plan).
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Chapter 2
/. EPA Oversight and Program Evaluation
Oversight and evaluation of State program implementation is generally the
responsibility of the Regions. The exact form that oversight takes, however, varies across
programs.
• Regions are responsible for oversight and program evaluation for the
Pesticides SMP Program, NPS Program, Public Water Supply Program,
Near Coastal Waters Program, State Wetlands Protection Program, and
NPDES Program.
• Regions and EPA Headquarters review/approve workplans annually for
the National Estuary Program and Coastal NPS Program. NOAA also
reviews Coastal NPS plans.
• States submit quarterly tracking reports for the Public Water Supply
Program and Chesapeake Bay Program, and periodic progress reports
for the Class V UIC Program.
• Under the Clean Lakes Program, Regions and EPA Headquarters
Clean Lakes Program staff conduct a technical peer review; maintain
contact with the State; perform site visits; and review scheduled status
reports.
• Under CWA §106 Program, Public Water Supply and UIC Programs,
Regional Offices conduct written evaluations.
• Oversight procedures have not yet been fully developed for the
Comprehensive State Ground Water Protection Program, Wellhead
Protection Program, Agriculture Pollution Prevention Strategy, and
Nitrogen Action Plan Programs/Strategies.
HI. Summary of Similarities and Differences
The 16 EPA programs and strategies, identified by the Agriculture and Water
Integration Project, provide States with a complex set of tools for addressing the impacts
of agriculture on surface and ground waters. The integration of these tools, however,
requires an understanding of their similarities and differences. This section provides a
brief summary of the similarities and differences in terms of the following key elements
of the 16 agriculture and water-related programs and strategies:
• Statutory Authorities and Goals;
• Priorities for Achieving Goals;
October 1992 Page 23
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Chapter 2
• Flexibility and State Participation;
• Review and Approval Processes;
• Level of Funding;
• Status of Programs and Strategies; and
• State Activities.
2.
3.
Ke,
CSGWPP
WHP
PSMP
Class V UIC
NFS
CNPS
PWS
NCW
NEP
10. CBP
11. SWPP
12. CLP
13. NPDES
14. CWA §106
15. APPS
16. NAP
to Program Abbreviations
— Comp. Ground-Water Protection
Program
— Wellhead Protection Program
— Pesticides Slate Management Plan
Program
— Class V UFC Program
— Nonpoini Source Program
— Coastal Nonpoint Source Program
— Public Water Supply Program
— Near Coastal Waters Program
— National Estuary Program
— Chesapeake Bay Program
— Slate Wetlands Protection Program
— Clean Lakes Program
— NPDES - Feedlot Program
— Clean Water Act Section 106
Program
— Agriculture Pollution Prevention
Strategy
— Nitrate Action Plan
Statutory Authority and Goals
is- The programs are
authorized under four
different statutes
(CWA, FIFRA,
SDWA,
CZMA/CZARA);
us1 Two programs are
mandatory - i.e. EPA
administers program if
a State fails to (PWS,
Class V UIC);
ra- Fourteen are voluntary
(CSGWPP, WHP,
PSMP, NPS, CNPS,
NCW, NEP, CBP,
SWPP, CLP, NPDES,
CWA §106, APPS,
NAP);
Four programs and strategies focus on ground water (CSGWPP, WHP,
PSMP, Class V UIC), five focus on ground water and surface water
(NPS, CNPS, PWS, NAP, APPS), seven focus on surface water (NCW,
NEP, CBP, CWA §106, CLP, SWPP, NPDES);
Goals of the programs cover protection of water resources, pollution
prevention, and restoration; and
Four programs focus on distinct geographic areas (CNPS, NCW, NEP,
CBP).
Page 24
October 1992
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Chapter 2
Priorities for Achieving Goals
» Program priorities include:
• Technical Assistance (9 programs)
(WHP, PSMP, NPS, CNPS, PWS, NEP, CBP, SWPP, CLP);
• Guidance Development (5 programs)
(CSGWPP, WHP, PSMP, CNPS, NCW);
• Outreach (4 programs)
(CSGWPP, WHP, NPS, NEP);
• Program Implementation (8 programs)
(PSMP, Class V UIC, NPS, CBP, SWPP, NPDES, CWA §106,
APPS); and
• Program Definition (2 programs)
(CSGWPP, NAP).
Flexibility and State Participation
us- Eight programs provide a high degree of flexibility to States in
addressing program components (CSGWPP, WHP, PSMP, NPS, NEP,
CLP, CWA §106, APPS);
•a? Four programs allow moderate flexibility (CNPS, NCW, SWPP,
NPDES); and
"*• Four programs provide limited flexibility, or are determining flexibility
(PWS, CBP, Class V UIC, NAP).
Review and Approval Processes
•a* Fourteen programs are administered by OW, one by OPPTS (PSMP),
one by Region III (CBP);
«r USDA and USGS are involved in five programs (PSMP, CSGWPP,
NPS, CNPS, CLP), NOAA in one (CNPS);
ra* Eight programs are in implementation phase, with most States
receiving grants and holding primacy (WHP, NPS, PWS, NEP, CBP,
CLP, NPDES, CWA §106); and
October 1992 Page 25
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Chapter 2
CT Eight programs are in some stage of development on both the federal
and State levels (PSMP, CSGWPP, CNPS, SWPP, NCW, Class V UIC,
APPS, NAP).
Level of funding
«• Grant funding provided by each of the programs in FY'92 ranges from
$4 million (Near Coastal Waters) to $81.7 million (CWA §106); and
•» The total amount of grant dollars provided to States by all the
programs in FY'92 was $263 million, although not all was spent on
agriculture.
» All of the Pesticides SMP grants ($5 million), and 49.7 percent of the NFS
Program grants ($25 million in FY*91 - FY'92 data are not yet available)
directly support agricultural activities. However, because most of the
programs focus on threats to the water resource from many different
sources of contamination, the other programs were unable to provide
information on how much of their total grant funding was being used to
support agricultural activities on the State-level.
Status of Programs and Strategies
CT All eight programs currently in the implementation phase specify a
review process (WHP, NFS, PWS, NEP, CBP, CLP, NPDES, CWA
§106);
us* Six programs in the development or planning phase have yet to finalize
review processes (CSGWPP, PSMP, Class V UIC, CNPS, APPS, NAP);
•s* Four programs have review processes that vary State-by-State (NPS,
PWS, CBP, CWA §106); and
ra- The review processes for two programs vary by EPA Region (NCW,
CWA §106).
State Activities
ra- States are asked to do similar things under many programs:
• Set goal (11 programs)
(CSGWPP, WHP, PSMP, Class V UIC, NPS, CNPS, NEP, CBP,
CLP, CWA §106, APPS);
• Define roles and responsibilities (8 programs)
(CSGWPP, WHP, PSMP, CNPS, NEP, CBP, CLP, CWA §106);
Page 26 October 1992
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Chapter 2
• Establish legal authorities (11 programs)
(CSGWPP, WHP, PSMP, Class V UIC, NPS, CNPS, PWS, NEP,
CBP, CWA §106, APPS);
• Establish prevention measures (10 programs)
(CSGWPP, WHP, PSMP, NPS, CNPS, NEP, CBP, CLP, CWA
§106, APPS);
• Provide public participation (10 programs)
(CSGWPP, WHP, PSMP, Class V UIC, NPS, CNPS, NEP, CBP,
CLP, CWA §106);
• Report on progress (9 programs)
(CSGWPP, PSMP, Class V UIC, NPS, PWS, CBP, CLP,
CWA §106, APPS);
• Provide resources (11 programs)
(CSGWPP, PSMP, Class V UIC, NPS, CNPS, PWS, NEP, CBP,
CLP, CWA §106, APPS);
• Monitor (10 programs)
(CSGWPP, PSMP, NPS, CNPS, PWS, NEP, CBP, CLP, CWA
§106, APPS);
• Enforce (9 programs)
(CSGWPP, PSMP, Class V UIC, CNPS, PWS, NEP, CBP,
CWA §106, APPS);
• Disseminate information (10 programs)
(CSGWPP, WHP, PSMP, NPS, CNPS, NEP, CBP, CLP,
CWA §106, APPS); and
• Respond to contamination (5 programs)
(CSGWPP, PSMP, Class V UIC, CBP, CLP).
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Chapter 3
Chapter 3
Regional Coordination Activities
and EPA's Future Integration Plans
Chapter 3 consists of three sections. The first section, "Regional Coordination
Activities," summarizes the results of the Water/Pesticides and Toxics Regional
Coordination survey that was conducted jointly by the Region IX Water Division and the
Region X Air and Toxics Division. The second and third sections, "EPA's Future
Integration Plans" and "Conclusion," outline the Agency's plans to continue addressing
the coordination of grant guidances and programs related to agricultural contamination
of the water resource over the next few years.
I. Regional Coordination Activities
As an additional source of information on how the Agency is currently coordinating
agriculture and water activities, and how EPA could improve coordination in the future,
senior managers in the Water and Pesticide Divisions of Region IX and X conducted a
survey of all ten EPA Regions on how each Region coordinated agriculture- and water-
related programs and activities.
The survey was conducted by contacting representatives in each of the EPA Regional
water and pesticide programs. The representatives were asked the following questions:
• What groups, task forces, etc., have been formally established within
your Region that facilitate cross-program coordination between water
and pesticide programs? What level of management is involved?
• Was there any specific effort in your Region to develop FY'92 program
guidance for States? If so, briefly describe the process?
• What actions did the Region take to promote (or require) program
coordination between water and pesticide programs at the State level?
• For EPA's agriculture-related programs, rank coordination between
water and pesticides in your Region.
• For the same list of program areas, list any barriers you can identify
which inhibit closer coordination and briefly indicate possible ways to
address these.
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Chapter 3
• Add any other Region-specific information you feel is relevant to
describing current program coordination efforts within the Region. We
are particularly interested in identifying what has worked and what
hasn't in this area, and any recommendations you may have to improve
coordination and communication.
The results of the survey indicate generally that Regional coordination of water and
pesticide programs focus primarily on ground water-related activities. The survey
indicates also that several Regions are just beginning coordination efforts on surface
water concerns. A brief summary of Regional responses to each of the survey questions
is provided below. A more comprehensive discussion of the responses is included in a
memorandum entitled Results from the Water I Pesticides and Toxics Regional Coordination
Survey, dated September 11, 1991 (Appendix C).
Groups that Facilitate Cross Program Coordination
All Regions have formally established multi-program ground water coordination
groups. Most of these groups were formed in the mid-to-late 1980s and included Branch
Chiefs and/or Division Director representatives. A few groups included Division
Directors.
Many Regions also have Regional task forces or groups for nonpoint source pollution
coordination. Other cross-program coordination groups include:
• Specific project or issue workgroups or committees;
• Specific geographic initiatives; and
• Risk reduction workgroups or committees.
FY 92 Integrated State Program Guidance
Coordination within the Regions on State program guidance most frequently occurs
in the ground water area. Specific examples of coordination and programs involved
include:
• In FY'92, Regions IV, V, and IX each worked to develop a joint water
and pesticides grant guidance, usually on ground water issues.
• In FY'92, Regions I, II, III, VI, VII, VIII, and X had some mechanism
within the Region to coordinate grants relating to ground water
protection. Some Regions established coordinated review of draft
grant guidances, and another Region developed its ground water grant
guidance through cross-program coordination.
• In FY'92, Region IX also established a workgroup to ensure that its
nonpoint source program guidance and grant funds addressed cross-
program and cross-media concerns.
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Chapter 3
Regional Actions to Promote State Coordination
Several Regions, through State workplans for ground water, pesticides, and nonpoint
source programs, required States to coordinate their water and pesticides programs.
Specifically, Regions worked with States to achieve one or more of the following
coordination activities:
• Inform the States that the Region expected the State programs to
coordinate;
• Work with States to identify attendance of multi-media meetings for
developing Pesticide State Management Plans;
• Require cross-program infrastructures to support the development of
Comprehensive State Ground Water Protection Programs;
• Require the State to identify a formal process that the State would use
to coordinate its programs; and
• Make funding contingent upon the development of a coordinated
program plan.
One of the benefits of State coordination is that some Regions would allow the lead
State agency to provide pass-through funds to appropriate agencies.
Regions also promoted State coordination through funding of special projects and
nonpoint source demonstration projects that require State coordination. Some Regions
required the use of CWA Section 106 funds to be used on cross-program issues and
some Regions conducted joint grant negotiations and evaluations. Regions are also
attempting to set an example for States by demonstrating effective coordination within
EPA at both the Regional and Headquarters levels.
Regional Ranking on Coordination
According to the survey, the strongest area of coordination among the Regions'
programs is between the ground water programs and the Pesticides State Management
Plans. The area which needs the most improvement is coordination on nonpoint source
programs.
Areas that present opportunities for coordination include special projects, joint
enforcement actions, wetlands protection, pesticides enforcement actions, water quality
risk studies, episodic issues, certification of pesticide applicators, geographic initiatives,
and sampling programs.
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Chapter 3
Barriers That Inhibit Coordination
The Regions identified a number of barriers that limit cross-program coordination at
the EPA Regional level, including:
• Differing grant award cycles and restrictions on funding;
• Lack of resources;
• Differing program goals and priorities;
• Lack of integration or coordination at EPA Headquarters level;
• Late release of necessary programmatic and grant guidances;
• Lack of formal or informal coordination mechanisms;
• Lack of information or commitment; and
• Limitations based on State mandates and regulations.
Several respondents suggested that these barriers also exist for many States. In
addition, State efforts at coordination are also limited by State agency mandates and
different EPA grant awards cycles and restrictions associated with funding.
Regional Coordination Efforts that Worked
A number of Regions stressed their success in coordination and noted that the
following actions enhanced coordination efforts:
• Coordinated development of Regional guidance for Pesticide State
Management Plans;
• Establishment of workgroups or committees, such as Regional ground
water policy committees, water quality or atrazine workgroups, or cross
agency committees;
• Use of a multi-program approach to pilot projects on pesticides in
ground water;
• Development of memoranda of agreements and/or joint program
guidance;
• Maintenance of open lines of communications at all levels with other
programs within the Region;
• Use of a coordinated approach to specific issues when conducting State
directors' meetings.
Page 32 October 1992
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Chapter 3
Recommendations for Improving Coordination
Experiences with coordination provided Regional Offices with valuable insights on
how to plan coordination efforts in the future, including:
• Coordinated response to information requests;
• Formalized coordination;
• Integration of national strategies at Headquarters;
• Development of guidance on use of coordination for handling potential
water pollution at past pesticides spill areas;
• Allotment of adequate resources; and
• Coordination of activities between EPA Regions and Headquarters as
an example to States.
II. EPA's Future Integration Plans
EPA's Office of Water and Office of Prevention, Pesticides, and Toxic Substances
will continue to work to coordinate and integrate agriculture and water-related programs
over the next few years. As the Agriculture and Water Integration Work Group
completed the materials summarizing and comparing the 16 agriculture and water-related
programs, it became clear that the most appropriate forum for developing specific
recommendations for increasing coordination of grant guidances over the next few fiscal
years is the Ground Water Policy Committee's State Programs Implementation Work
Group (SPIW), established by the Deputy Administrator. Recommendations for FY'94
grant guidance will be developed and coordinated in the following way:
or Ground Water Grant Guidance Coordination -- The work completed by the
Agriculture and Water Work Group addressing ground water grant
coordination will be integrated into the work being conducted by the State
Programs Implementation Work Group. The SPIW will have the
responsibility for developing recommendations for coordinating FY'93 and
FY'94 grant guidances. This is supported by all program offices involved.
The SPIW is not only currently addressing the coordination of grant
guidances as part of its responsibilities, but is made up of many of the
program office participants that worked on the Agriculture and Water
Project.
•& Surface Water Grant Guidance Coordination -- As national guidance for
primarily surface water-related grant programs is developed and/or revised,
the concerns of the Agriculture and Water Project regarding coordination
October 1992 Page 33
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Chapter 3
will be addressed. For example, the agricultural sections of the proposed
guidance for the new Coastal Nonpoint Source Program are being closely
coordinated with Pesticides, Ground Water and other offices. Future
revisions to the Nonpoint Source Program, Clean Lakes Program, National
Estuary Program, and other primarily surface water-related grant guidances
provide an opportunity for promoting synergism, mutually supportive
activities, and cost-efficiency among the various EPA programs addressing
agriculture-related water quality problems.
III. Conclusion
While this report was prepared as a starting point for EPA and State staff to use in
working to avoid duplication of effort and coordinate activities to protect the water
resource, clearly more work needs to be done across programs to achieve common goals
in the most effective way. Because much of the administration of these programs occurs
at the Regional Office level, a large part of the coordination effort should significantly
involve the Regions. As pointed out by the Regional Coordination Survey, the Regional
Offices are already moving ahead in the area of working together across programs to
achieve common objectives.
Many EPA Regions have in place inter-program committees that include a wide
range of programs (estuaries, ground water, pesticides, pollution prevention). These
committees provide an excellent opportunity to coordinate the various grants awarded by
different EPA programs to States to address agricultural pollution problems. Most
Regions are already committed to this approach. This report can provide initial support
to both EPA Headquarters and Regional Staff, as well as the States, as we continue to
work over the next few years to review carefully the Agency's water-related grant
programs and use inter-program committees or other coordination techniques to ensure
that these programs are consistent, mutually supporting, and effective.
Page 34 October 1992
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Appendix A
Appendix A
Detailed Fact Sheets on Each of the 16
EPA Programs and Strategies
Appendix A provides detailed information on the sixteen EPA agriculture and water
programs affecting States. The appendix contains an Executive Summary and 16 Program
Fact Sheets. The Executive Summary consists of a four page summary of all of the 16
programs and strategies, with highlights of agricultural activities. The 16 Program Fact
Sheets provide a general description as well as information on the review and approval
processes for each program and strategy.
October 1992 Page 35
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Appendix A
Contents of Appendix A
Page
Executive Summary 39
Program and Strategy Fact Sheets 45
(1) Comprehensive State Ground Water Protection Program 47
(2) Wellhead Protection Program 51
(3) Pesticides State Management Plan Program 55
(4) Underground Injection Control Program Class V Wells (AG Drainage) ... 59
(5) Nonpoint Source Program 63
(6) Coastal Nonpoint Source Program 67
(7) Public Water Supply Program 71
(8) Near Coastal Waters Program 75
(9) National Estuary Program 79
(10) Chesapeake Bay Program 83
(11) State Wetlands Protection Program 87
(12) Clean Lakes Program 89
(13) National Pollution Discharge Elimination System Program 93
(14) Clean Water Act Section 106 Program 97
(15) Agriculture Pollution Prevention Strategy 100
(16) Nitrogen Action Plan 103
October 1992 Page 37
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Appendix A
Executive Summary
October 1992 Page 39
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Appendix A
AGRICULTURE AND WATER PROGRAMS/STRATEGIES FACT SHEETS
Executive Summary
Program
Statutory Authority and Summary of
Program
Agriculture-Related Activities
Comprehensive State
Ground Water
Protection Program
Derives authority from §106 and §319 of
CWA, §1424(e) and 51428 of SDWA, as
well as CERCLA, RCRA, and FIFRA.
EPA's new GW Protection Strategy
establishes CSGWPPs as the Agency's
overall approach to adequately protect
ground water from contamination. The
Strategy recognizes the primary State role
in designing and implementing programs
to protect the ground water resource
consistent with distinctive local needs and
conditions.
The program will aid in agricultural
pollution prevention by establishing
priorities for preventive measures and
monitoring. OGWDW is involved in the
following agriculture-related activities:
investigating ground and surface water
interaction and toxic loadings of surface
water from pesticides and nutrients;
supporting the Farmstead Assessment
System and coordination with USDA.
Wellhead Protection
Program
Safe Drinking Water Act, Section 1428
The Wellhead Protection Program was
established to protect public ground water
supplies from contamination. The
program is based on the concept that the
development and application of land-use
controls and other preventive measures
can protect ground water.
The program office has not addressed
options for management of agriculture-
related sources in any of its publications,
but is interested in promoting best
management practices of the sources. At
the present time, the program office does
not have the resources to devote to such
an endeavor. In the past, the program
office has worked with the Soil
Conservation Service on their efforts to
produce a video on Rural Drinking Water
Well Protection.
Pesticides State
Management Plan
Program
FIFRA
The goal of the program is to manage the
use of pesticides in order to prevent
adverse effects to human health and the
environment and to protect the
environmental integrity of the nation's
ground water. State Management Plans
(SMPs) are the vehicles to achieve this
goal. EPA determines the pesticides that
require the SMP approach, while States
tailor their SMPs to their distinct
hydrogeological, agricultural, and
institutional conditions.
The program office provides grants to
States for FIFRA ground water activities
and is developing guidance documents
covering the fallowing aspects of SMP
development- (1) the 12 components of an
SMP, (2) EPA's review and approval
process, and (3) technical assistance on
assessment, monitoring, prevention, and
response to contamination. In addition,
the office is working with OGWDW to
ensure that SMPs are integrated into the
States' overall ground water protection
programs.
UIC Program: Class
V Wells
Safe Drinking Water Act, Section 1421-
1426
The UIC Program is primarily a State-
implemented program. The program's
goal is to protect all underground sources
of drinking water from contamination by
injection well operations, including
agricultural drainage wells.
Agricultural drainage wells are a small
segment of a larger group of injection
wells known as class V wells. These wells
are currently subject to the rule-making
process. The UIC program currently
envisions that the environmental nsfc of
agricultural drainage wells will be
addressed by a series of agricultural BMPs
incorporated in CSGWPPs.
October 1992
Page 41
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Appendix A
AGRICULTURE AND WATER PROGRAMS/STRATEGIES FACT SHEETS
Executive Summary
(continued)
Program
Statutory Authority and Summary of
Program
Agriculture-Related Activities
Nonpomt Source
Program
Clean Water Act, Section 319
Section 319 of the Clean Water Act
establishes a grant program that provides
annual grants to States to abate NFS
pollution from many sources. The grant
requirements are meant to be flexible, so
States can address nonpcmt source
pollution problems in a prioritized fashion.
There are no specific agricultural priorities
for Section 319 funding. However,
agriculture receives the most funding of
any NFS category. Examples of
agriculture-related activities include
technical assistance to farmers in
watershed projects, educational efforts on
good farming practices to protect water
quality, and cost sharing for agricultural
BMPs in demonstration projects.
Coastal Nonpomt
Source Program
Coastal Zone Reauthonzation
Amendments of 1990, Section 6217
The Coastal Nonpomt Pollution Control
Program was established to develop State
programs to insure implementation of
nonpoint source management measures to
restore and protect coastal waters.
Funding for the development of State
coastal NFS programs will be provided
through CZARA with support from CWA
$319 and §106 funds.
The proposed management measures
guidance for State coastal NFS programs
addresses 6 types of agricultural NFS
pollution, including: erosion and sediment
control, confined animal facility
management, pesticide and nutrient
management, grazing management, and
irrigation water management. State coastal
NFS programs will need to address each of
the agricultural nonpoint sources, as
appropriate in a given State.
Public Water Supply
Program
Safe Drinking Water Act
The Public Water Supply Program
establishes and enforces drinking water
standards under the authority of the Safe
Drinking Water Act. As a result,
maximum contaminant level (MCL)
standards have been promulgated for 25
pesticides, nitrogen compounds, and other
contaminants.
Agriculture-related activities include
implementation of Phase II Rule for 25
pesticides and nitrates, review of pesticide
occurrence data, and review of health data
for developing future regulations.
Near Coastal Waters
Programs
Product of EPA strategic planning
The Near Coastal Waters Program
establishes State- and federally-
implemented demonstration projects to
maintain and, where possible, enhance
near coastal water environmental quality.
Under the program, Regional strategies
for near coastal waters are developed and
implemented through coordinated EPA
Regional, State, and local efforts.
There are no specific agricultural priorities
in the NCW Program. However,
agriculture-related activities can be
included in Regional NCW strategies.
Agriculture-related activities can include
technical assistance, public outreach, data
management, and information
dissemination.
Page 42
October 1992
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Appendix A
AGRICULTURE AND WATER PROGRAMS/STRATEGIES FACT SHEETS
Executive Summary
(continued)
Program
Statutory Authority and Summary of
Program
Agriculture-Related Activities
National Estuary
Program
Clean Water Act, Section 320.
The National Estuary Program's goal is to
identify nationally significant estuaries
threatened by pollution, development, or
overuse, and to promote the preparation
of State-implemented Comprehensive
Conservation Management Plans
(CCMPs) to ensure their ecological
integrity.
Agriculture-related activities are outlined
and identified in each individual CCMP.
These activities may include transferring
scientific and management information;
promoting basin-wide planning to control
pollution; and overseeing development of
pollution abatement and control programs.
Chesapeake Bay
Program
Clean Water Act, Section 117.
The Chesapeake Bay Program's goal is to
restore and enhance the living resources
of Chesapeake Bay. The program is
administered by Region III and the
Chesapeake Bay States participate by
implementing programs and projects to
protect the Bay.
Approximately 30% of the funds awarded
as grants to State agencies are expended
for technical assistance, public outreach,
progress reporting, data management, and
research. The remaining funding is usually
spent on direct financial assistance grants
to farmers for BMPs installation. The
program has spent a total of $54.2 million
on installation of agncultural BMPs.
While agriculture is not identified as a
priority in the program, some agriculture-
related activities may be part of State
Wetlands Conservation Plans or watershed
protection demonstration projects.
State Wetlands
Protection Program
Clean Water Act, Section 104(b)(3).
The State Wetlands Protection
Development Grants Program supports
the development of new State wetlands
protection programs or enhancement of
existing State programs.
Clean Lakes
Program
Clean Water Act, Section 314.
The Clean Lakes Program provides
financial and technical assistance to States
to conduct lake restoration and protection
projects and State-wide lake assessments.
Clean Lake projects that qualify for
funding must be on publicly owned lakes
that offer public access and recreational
opportunities.
While there are no specific agriculture-
related regulations under the Clean Lakes
Program, some funds are being used by
States to implement agricultural best
management practices (BMPs) in
watershed areas.
NPDES Program
Clean Water Act §402. Feedlots
regulated under 40 CFR 122.23.
OWEC's primary focus through the
NPDES program has centered around
point source discharges which are
classified as major. Though certain
feedlots are subject to the program, they
are not major facilities. Also, the NPDES
program's emphasis in recent years has
been on controlling toxic pollutants.
However, the problems presented by
feedlots stem from contamination by
conventional pollutants (phosphorous,
nitrogen, etc.).
The priority for addressing feedlot
contamination is the development of a
permitting/enforcement guidance on
feedlots to expand the focus of permits to
best management practices (BMPs)
including land application, manure storage,
and composting.
October 1992
Page 43
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Appendix A
AGRICULTURE AND WATER PROGRAMS/STRATEGIES FACT SHEETS
Executive Summary
(continued)
Program
Statutory Authority and Summary of
Program
Agriculture-Related Activities
Clean Water Act
Section 106 Program
Clean Water Act, Section 106.
Section 106 grants provide base program
funding support for a variety of State,
interstate, territorial, and qualified Indian
tribes water quality management activities.
These grants fund a wide range of surface
and ground water management activities.
While Section 106 grants can and do
support some agriculture-related activities
(e.g. monitoring surveys, printing of
publications, ADP support, etc.), the bulk
of State nonpomt source implementation
efforts are support by grants under Section
319ofCWA.
Strategy
Summary of Strategy
Agriculture-Related Activities
Agriculture Pollution
Prevention Strategy
Product of EPA strategic planning.
The Agriculture Pollution Strategy relies
heavily on prevention. The Strategy sets
targets and monitors success in achieving
agricultural pollution prevention goals.
Largely a voluntary initiative focused on
addressing priority risks from agricultural
pollution not currently being addressed.
Included in the strategy is a national
commitment to integration of existing
programs addressing agricultural pollution.
Nitrogen Action Plan
Product of EPA strategic planning.
The NAP involves the coordination of a
number of EPA offices in order to protect
ground water and surface water from all
sources of contamination by nitrate and
related nitrogen compounds through
pollution prevention. Presently, the NAP
is sull in the planning and development
stages.
High priority activities include technical
assistance, education, new regulations,
increasing enforcement, and research. In
relation to agriculture, the plan will focus
on reducing fertilizer use and better
controlling runoff and infiltration from
livestock operations.
Page 44
October 1992
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Appendix A
Program and Strategy
Fact Sheets
October 1992 Page 45
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Appendix A
(1) COMPREHENSIVE STATE GROUND WATER PROTECTION PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-parucipation:
No direct statutory authority. Derives authority to protect ground water from
CWA §106 and §319, SDWA §1424(e) and §1428, CERCLA, RCRA, and
FIFRA. States have primary responsibility for implementing CSGWPPs.
To prevent adverse effects to human health and the environment and to protect
the environmental integrity of the nation's ground water resources. In determining
prevention and protection strategies, EPA will consider the use, value, and
vulnerability of ground water.
Currently used and reasonably expected drinking water supplies, both public and
private; and ground water closely hydrologically connected to surface waters.
All sources of ground water contamination.
State-developed process for setting priorities for ground water protection (based
on use, value, and vulnerability) is part of adequacy criteria.
Prioritized to limit risk of adverse effects to human health and the environment
first and second to restore currently used and reasonably expected sources of
drinking water.
Initial goals: 1) Establish a formal mechanism for coordinating authorities and
programs under federal statutes; 2) Identify the most valuable, vulnerable aquifers;
and 3) Evaluate or rank the highest priority sources.
For FY'93: 1) develop final CSGWPP elements & adequacy criteria;
2) establish program incentives; 3) integrate program with other EPA
programs/regulations; and 4) conduct outreach on CSGWPP.
Support development and implementation of CSGWPP approach and the WHP
Program, which address all potential sources of ground water contamination,
including agriculture. Depending on State priorities, this might include:
establishing priorities for preventatrve measures and monitoring programs through
assessments of aquifer sensitivity; source characterization; assessments of risks; and
consideration of use and value.
Policy integration: incorporate ground water protection policy approaches into
Pesticides and Ground Water Strategy, SMP guidance documents, Nitrogen Action
Plan, and other agriculture-related documents. Research: Water Quality Initiative
Technical Integration Group; review MASTER outputs; manage projects
investigating ground and surface water interaction and toxic loadings to surface
water from pesticides and nutrients. Technical assistance: Technical Assistance
Documents on methods of assessing aquifer sensitivity to pesticides; and
supporting Farmstead Assessment System and USDA's eligibility criteria on
wellhead areas for CRP.
States are encouraged to develop and implement CSGWPPs through EPA
outreach, technical assistance, coordination of EPA ground water-related grants,
and programmatic incentives (deference to State ground water priorities).
In FY'93 and beyond, Stales showing little or no progress towards developing and
implementing CSGWPPs receive reduced grant awards from each of EPA's
ground water-related programs.
October 1992
Page 47
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Appendix A
(1) COMPREHENSIVE STATE GROUND WATER PROTECTION PROGRAM
(continued)
General Overview of Program
Components required for
grants:
Degree of Slate flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/coordination
activities:
State must demonstrate it is making progress toward addressing all 6 strategic
activities: 1) Goals, 2) Priorities, 3) Responsibilities, 4) Implementation,
5) Information, and 6) Public Participation.
States have considerable flexibility in how ihey address each strategic activity. Too
soon to know the level of specificity the Agency will encourage the States to adopt.
No voluntary components. Strategic activities and adequacy criteria expected to be
sufficiently comprehensive.
States must use enforceable quality standards that minimally meet EPA drinking
water standards. States can establish their standards, if they are at least as
stringent as EPA's.
1) Participating in ground water "regulatory cluster" to coordinate ground water
decisions across regulations, offices, and media. 2) Working with OPP in
pesticides in gw-related issues. 3) Work with Nitrogen Action Plan and the
Pollution Prevention Strategy for Agriculture. 4) Develop coordination grant
guidance with OPP for F1FRA and CWA §106. 5) Consider and evaluate UIC
regulations for agricultural drainage wells.
The Policy Committee is the focal point for integrating ground water-related policy
of Agriculture/Water programs. Focus should be identification of I) common
agriculture-related activities, 2) available expertise, 3) existing coordination,
4} sources of funding, and 5) research focusing on resource protection.
Page 48
October 1992
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Appendix A
(1) COMPREHENSIVE STATE GROUND WATER PROTECTION PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HO and Regions:
Description of State agency involvement:
Current program status on federal level:
How grant funds are used:
Federal program guidance documents
and/or regulations:
Status of implementation on the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer
Review/approval process-
Review process:
Review/approval process-
Final determination:
HQ: Ground Water Policy Committee oversees implementation and
policy direction. Membership includes: OW, OSWER, OPTS,
OPPE, AO, ORD, OAR, OARM, OE, and OGC.
RO: Profile States' current ground water protection programs;
review EPA programs at Regional level; establish priorities,
milestones, commitments from all programs; and review and oversee
CSGWPP plans.
Lead agency to be determined. Likely a committee appointed by the
Governor. Role will be to 1) initiate dev. & imp. of CSGWPPs;
2) coordinate ground water activities; 3) characterize ground water;
4) set priorities; and 5) provide authority and resources.
Initial phase of implementation. Plan for implementation outlined
and Policy Committee established. Draft National Guidance will be
released in June 1992.
Financial and technical assistance provided to States for capacity
building for CSGWPP and related programs.
FY'92 CWA § 106 grant guidance and Supplemental Guidance for
Ground Water Protection assists States in developing and
implementing CSGWPPs. Will issue general guidance and
supporting documents in '92.
All States have Ground Water Protection Strategies. EPA cannot
concur with State programs until the CSGWPP approach is Gnalized.
FY '88 '89 '90
S (millions)
6.2 6.7 10.7
'91 '92 '93
TBD
12.2 12.9 C10 ta hemmed)
§106 of CWA. No State match. Other programs participating in
the CSGWPP approach will provide grant funds for the development
of CSGWPPs.
Schedule for submission will be determined State-by-State.
To be determined by Policy Committee. Regions likely to have lead
review role, with HQ assistance.
Policy Committee will define approach
CSGWPPs.
for review/concurrence of
To be determined by Policy Committee.
October 1992
Page 49
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Appendix A
(1) COMPREHENSIVE STATE GROUND WATER PROTECTION PROGRAM
(continued)
Review and Approval Process for Program
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program evaluation
role:
Use of environmental indicators:
Integration/coordination activities in the
review/approval process:
Suggestions for integration/coordination
activities in the review/approval process of
Ag/Water programs:
To be determined by Policy Committee.
In FYs '92, '93, grants awarded based on existing allocation
formulas. In FY '94, States showing exemplary progress will receive
increased amounts, States showing little or no progress receive lower
amounts. Strategic activities and criteria will serve as basis for EPA
review.
To be determined by Policy Committee.
To be determined by Policy Committee.
To be determined by Policy Committee.
Use Ground Water Policy Committee as a focal point for integrating
and coordinating Agency activities involving ground water and
agricultural programs.
Page 50
October 1992
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Appendix A
(2) WELLHEAD PROTECTION PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of Stale flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Authorized under the Safe Drinking Water Act Amendments of 1986 (SDWA),
Section § 1428. Primarily a pollution prevention program.
To protect ground water that is used or will be used for drinking water.
Surface and subsurface waters surrounding a well or wellfield that supplies a public
water system.
All potential sources of contamination located within a wellhead protection area.
States decide what sources they wish to focus on in their wellhead protection
efforts. There are no specific sources that must be addressed.
Focus on human health risks posed by drinking contaminated ground water.
Technical assistance and outreach efforts on the development of State WHP
programs. Recently expanded efforts include development of local programs and
implementation of State programs.
1) Establish a program tracking process; 2) Publicize successful case studies of
WHF implementation; 3) Develop guidance on the management of sources of
contamination within the transportation sector; and 4) Develop training materials
on the program for use by the Regions and States.
Agriculture has not been identified as a specific priority for the coming FY.
No such activities at the present time, but interested in activities that address
BMPs for agriculture.
States required by SDWA to develop a program.
Agency has no statutory authority to take action against the State or to run the
State's program. States without a program will not be eligible to receive grants.
SDWA sets specific components (elements). Elements listed in ag/water matrix
titled "Components of State Programs".
The exact way in which a State addresses program elements is very flexible.
Agency guidance is used to encourage States to develop those elements listed on
Table I. States have not added program elements beyond those that are required
by statute.
States not required to use specific EPA reference points.
WHP Program working to integrate with the UIC program (particularly Class V
wells) as well as with the PWS program. Efforts do not specifically focus on
agriculture although WHP is cited in OPP's Pesticides and Ground Water Strategy
as a geographic targeting mechanism. Other coordination efforts underway as an
outcome of the CSGWPP approach. (See fact sheet on Comprehensive State
Ground Water Protection Program.)
October 1992
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Appendix A
(2) WELLHEAD PROTECTION PROGRAM (continued)
Genera] Overview of Program
Suggestions for future policy
integration/
coordination activities:
Further use of WHP for guiding USDA water quality
priorities.
Page 52 October 1992
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Appendix A
(2) WELLHEAD PROTECTION PROGRAM (continued)
Review and Approval Process for Program
Roles of EPA offices m HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process--
Final determination:
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
HQ: GWPD is responsible for implementing the WHP Program. GWPD provides
technical assistance to the Regions, States, and localities; reviews State program
submittal concurrently with appropriate Region.
RO: Region has authority to approve a State WHPP, after HQ concurrence on
first two. Region works with the State to develop and implement the WHPP and
promote WHP at the local level.
Agency with prime responsibility vanes. Usually the Department of Health or
Environment. Role of the lead agency varies from State to State. State must
designate a lead agency in their WHPP submittal.
WHP Program m place since 1987 at which time federal resources were used to
provide technical assistance to assist States in developing their programs.
Currently, funds are used for development of local programs and implementation
at the State level.
Grant funds allocated in FY '91 were earmarked for municipalities, and allocated
through a competitive process. Over SO demonstration projects that developed
and/or implemented WHP Programs have been funded.
"Guidance for Applicant for State WHP Program Assistance Funds Under the
SDWA," 1987. (No funds for such State grants have been appropriated.)
There are 20 approved State and
FY
$ million
'88
—
territorial
'89
—
WHP Programs.
'90
—
No State grant funds specifically for WHP Programs.
ground water grants in CSGWPP fact sheet.
'91 '92 '93
...
See description of §106
States were required by SDWA to submit WHP Programs to EPA for review no
later than June 6, 1989.
Regions are responsible for reviewing State
Headquarters must concur with a Region's
WHP Programs foi approval, though
first two program approvals.
Upon receiving submittal, EPA has up to nine months to conduct a review.
Actual review process has not occurred exactly as required because many States
did not submit programs.
Governor notified in writing of program approval or disapproval. Written
comments will accompany a disapproval. State has six months to resubmit revised
program to EPA.
Comments and suggestions are given to a State m writing as well as in face-to-face
meetings. In FY '91, EPA began Special Wellhead Education and Assistance
Training, working with States to develop their programs.
Each element of a State's program is reviewed against
and guidance.
criteria set forth in statute
No State grants are given specifically for Wellhead Protection.
October 1992
Page 53
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Appendix A
(2) WELLHEAD PROTECTION PROGRAM (continued)
Review and Approval Process for Program
Integration/coordination
activities in the current
review/approval process:
WHP Program working to integrate with the UIC program (particularly Class V
wells) as well as with the PWS program. Efforts do not specifically focus on
agriculture. Other coordination efforts underway as an outcome of the CSGWPP
approach.
Page 54
October 1992
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Appendix A
(3) PESTICIDES STATE MANAGEMENT PLAN
General Overview of Program
Statutory authority and
description:
Goal of the program:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing ag. practices:
Agriculture-related activities:
Mandatory or voluntary State
participation-
Result of non-participation:
Components required:
FIFRA provides the statutory authority. The "Pesticides and Ground Water
Strategy" lays out EPA's approach to regulating pesticides with the potential to
contaminate ground water.
To manage the use of pesticides in order to prevent adverse effects on human
health and the environment and to protect the environmental integrity of ground
water.
Ground water which is currently used and reasonably expected sources of drinking
water; ground water closely hydrologically connected to surface water.
Pesticides, with a focus on agricultural pesticides.
States set priorities by designating their "currently used and reasonably expected"
sources of drinking water. EPA determines the pesticides requiring an SMP.
Same as comprehensive programs, but specific to pesticides -- risks to human
health and the environment, specifically health risks relating to currently used and
reasonably expected sources of drinking water, and ecological risks relating to
ground water closely connected hydrologically to surface waters.
Provide financial and technical assistance to States in developing SMPs.
For FY'92: 1) develop guidance documents on SMP adequacy criteria and the
review and approval process; 2} provide technical assistance to the States on the
assessment, monitoring, prevention and response elements of SMPs; and 3)
provide grants to States for developing Generic Stale Management Plans.
Same as above -• all of the program's priorities and activities relate to agricultural
practices, specifically pesticide use.
Technical Assistance - 1) developing Assessment, Monitoring, Prevention, and
Response; 2) working with ORD on developing a user-fnendly model for locating
vulnerable soils, and a guidance on monitoring strategies utilizing databases
available to States; and 3) working with OGWDW to develop a review of methods
for assessing the sensitivity of aquifers to pesticide contamination.
Outreach ~ participating in Headquarters and Regional discussions on SMPs and
comprehensive programs.
Data - working with ORD on 1) developing a guidance on using ARC/INRD-
based GIS and other geographically based software for pesticide management; and
2) enhancing OPP's Pesticide Information Network (PIN).
Research - working with ORD on 1) Geld test of DRASTIC performance; and 2)
surveying results of vulnerability assessment method Geld tests.
Program is voluntary until EPA issues a regulation for a specific pesticide at which
point the program is mandatory for continued sale and use of the pesticide.
Once EPA identifies a specific pesticide as requiring the SMP approach, State
must develop plan or be prohibited from the sale and use of pesticide.
12 components are required ~ see "Components of State Programs."
October 1992
Page 55
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Appendix A
(3) PESTICIDES STATE MANAGEMENT PLAN
(continued)
General Overview of Program
Degree of State flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/ coordination
activities:
States have considerable flexibility in how they will address each component. The
contents of adequate SMPs will vary in their extent and level of detail according to
the actual and estimated magnitude of the ground water contamination threat and
local conditions.
No voluntary components to the program. However, States may develop Generic
SMPs before Pesticide SMPs are required by EPA. In addition, States may
address in their SMPs specific areas not required by the Agency, (i.e., interstate
coordination).
A State must be at least as protective as the "Agency Policy on EPA's Use of
Quality Standards in Ground Water Prevention and Remediation Activities."
Participating in Agency's Ground Water Policy Committee. Working to ensure
consistency in approaches taken in other agriculture-related activities through
leading the Ag/Water Integration Project, participating on work groups, etc.
Continue use of Ground Water Policy Committee for coordinating and integrating
all ground water related activities. Promote advancement of Ag/Water Integration
Work Group products and grant coordination efforts of the Policy Committee and
surface water vehicle. Focus senior-level attention on need for additional
coordination/integration of Agency's surface water and agriculture programs as
well as surface water and ground water programs.
Page 56
October 1992
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Appendix A
(3) PESTICIDES STATE MANAGEMENT PLAN
(continued)
Review and Approval Process for Program
Roles of EPA offices in
HQ and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
Final determination:
Review/approval process-
EPA feedback:
HQ: OPP/PSPS finalized "Pesticides and Ground Water Strategy" in October 1991.
OPP/FOD will prepare SMP implementation guidance documents and work with
other offices on integrating SMPs into CSGWPP and related programs, assist
Regions in reviewing Generic and Pesticide SMPs, and evaluate program
effectiveness. OGWDW provides technical assistance to States on assessing
groundwater vulnerability and other SMP-related topics.
RO: Assist States in developing and implementing SMPs. Conduct review and
approval of SMPs and evaluate their effectiveness. Will dovetail with role in
CSGWPP approach.
No specific State agency is required to take the lead. Coordination among State
health, environment, agriculture, and water agencies is required. Gram funds are
provided to lead agencies for pesticides.
Pesticides and Ground Water Strategy released in October 1991; guidance
documents are scheduled for completion in 1992.
Grant funds supporting the initial planning stages of an SMP were provided in FY
'90 and '91 and will continue to be provided in FY'92 and beyond.
1) Pesticides and Ground Water Strategy; 2) Pesticides and Ground Water State
Management Plan Guidance Document; 3) Appendix A: Approval and Evaluation
of State Management Plans; and 4) Appendix B: Assessment, Prevention,
Monitoring, and Response Components of SMPs.
Implementation is in the initial stages. Over 55 States, Tribes, and territories have
begun to develop Generic SMPs. Pesticide SMPs have not yet been required by
the Agency.
FY
S million
'88 '89 '90 '91
™ — Ipj Jj
'92 '93
$5 TBD
FIFRA ground water grants.
Submittal schedule to be determined. Probably not required before 1994, though
States can submit Generic SMPs at any time for review and concurrence.
Regions will have primary responsibility for reviewing and approving SMPs.
SMP components
will be evaluated using the SMP Guidance and its appendices.
SMPs must address all 12 components. The level of protection must be adequate
to address the prospective magnitude of the State's risk of ground water
contamination and to protect currently used and reasonably expected sources of
drinking water. EPA will review and concur witb Generic SMPs if States
voluntarily submit them, while Pesticide SMPs must be approved by EPA in order
to continue the use of the pesticide.
During review, Region may ask a State to revise a plan that is
protect the resource.
not adequate to
October 1992
Page 57
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Appendix A
(3) PESTICIDES STATE MANAGEMENT PLAN
(continued)
Review and Approval Process for Program
Review/approval process-
Awards decision criteria:
Currently, grant funds are awarded to States using a formula based on ground
water susceptibility and pesticide use, not on a State's progress in developing an
SMP.
Agency oversight and program
evaluation rote:
Regions will evaluate the program to ensure that grant monies are going to their
intended purpose, and that SMPs are achieving the objective of protecting
currently used and reasonably expected sources of drinking water.
Integration/coordination
activities in the current
review/approval process:
Currently, most of the coordination occurs on a Region-by-Region basis. In many
Regions, the pesticides and ground water offices issued joint FIFRA and CWA
§106 guidance. Some Regions, such as Region 5, direct their States to use the
grant funds for a cooperative effort among the various State agencies involved in
ground water protection. In addition, HQ is working to better coordinate through
participation on the Ground Water Policy Committee's State Programs Work
Group and the Ag/Water Integration project.
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
Increase the consistency of coordination efforts across all Regions by requiring
Regional review teams of representatives from all ag/water programs to review and
approve all programs under the framework of comprehensive ground water
programs. Also, HQ should continue the use of the Policy Committee and its
work groups and charge a similar surface water group to develop
recommendations for additional coordination among the program offices and in
the development of guidance documents, Agency Operating Guidance, strategic
planning, STARS, etc.
Page 58
October 1992
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Appendix A
(4) UNDERGROUND INJECTION CONTROL PROGRAM
CLASS V WELLS (AG DRAINAGE)
General Overview of Program
Statutory authority and
description-
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Authorized under the SDWA of 1974 and amendments §§1421 - 1426. Primarily
a State-implemented program.
To protect Underground Sources of Drinking Water (USDWs) from
contamination by all types of injection well operations.
USDWs defined as an aquifer or portion thereof, supplying or capable of
supplying a public water supply system and currently supplies drinking water for
human consumption. WHP areas and Sole Source aquifer areas may be priority
areas for focusing limited resources.
All types of injection well operations, including industrial, municipal or hazardous
waste waters, agricultural chemicals, etc. This includes agricultural drainage wells
and irrigation return flow wells (Class V wells.)
Slates are responsible for implementing programs. There is no pnontization
within the statutory mandate of USDW protection. States are encouraged to
adopt minimum federal program standards. EPA administers the programs where
States decline.
Designed to address human health risks posed by the potential for contamination
of drinking water by injection operations.
Class V wells are a recent program priority. Currently subject to rulemakmg
process with proposal projected for late 1992; Agricultural wells are to be
addressed by BMPs in forthcoming regulations or guidances.
Wells discharging a variety of industrial wastes into Class V shallow disposal
systems. Priorities focus on continuation of implementation grants.
The focus of a limited set of special studies and investigations m States where
agricultural drainage wells are utilized.
Agriculture-related activities designed as demonstration research projects.
Sponsored a forum on agriculture Best Management Practices for agricultural
drainage wells in 9/91, to develop, review, and recommend appropriate controls for
the Class V regulatory development effort.
States are encouraged to adopt the minimum federal program requirements and
obtain primary enforcement responsibility (primacy).
EPA administers the UIC program in States that cannot or will not achieve
primacy. Currently administers 17 such "direct implementation" programs
nationally. Additional 5 States split program authority with EPA; Agency
administers programs on Indian lands.
Seven components required. Class V well requirements to be addressed under the
specific provisions of the current rulemaking effort.
Rule will likely set general regulatory performance standards but rely on program
guidance incorporated in CSGWPP approach.
N/A
October 1992
Page 59
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Appendix A
(4) UNDERGROUND INJECTION CONTROL PROGRAM
CLASS V WELLS (AG DRAINAGE)
(continued)
General Overview of Program
Use of "reference points":
Current rulemaking envisions use of MCLs as a reference point for many shallow
injection well operations. These are not, however, always achievable. Alternative
approaches include allowing operations to continue under a "variance" if States
incorporated certain BMPs into CSGWFPs.
Current policy-related
integration/coordination
activities:
Policy aspects of UIC agricultural controls will be coordinated as an integral
element of CGWPPs.
Suggestions for future policy
integration/
coordination activities:
Perhaps OPP could get registrants to gather data on pesticide content of water
disposed through agricultural drainage wells to improve control of pesticides and
to help OGWDW better tailor its approach to the Class V agricultural drainage
wells. Working with NFS program to evaluate tradeoffs for management of
nutrient-laden water drained by wells or other methods and to reduce contaminant
content of the discharges.
Page 60
October 1992
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Appendix A
(4) UNDERGROUND INJECTION CONTROL PROGRAM
CLASS V WELLS (AG DRAINAGE)
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process--
Schedule:
Review/approval process-
Reviewer:
Review/approval process--
Review process.
Review/approval process-
Final determination:
Review/approval process-
EPA feedback:
Review/approval process--
Awards decision criteria:
Agency oversight and program
evaluation role:
HQ: OGWDW is lead office. Responsibilities include: 1) Grant and workload
allocations; 2) regulation and guidance development 3) program oversight and
evaluation; 4) Approval of primacy applications and major program modifications;
and 5) technical assistance.
RO: Water Management Divisions are UIC lead office. Responsibilities include:
1) Grants management; 2) program implementation and enforcement in federally-
administered programs; 3) data management and program oversight; 4) evaluation;
and 5) reporting.
State role vanes. State environmental agencies will likely have overall responsibility
for program management and agricultural operations in particular. Variations in
these management structures occur via Memoranda of Agreement.
Advanced phase of implementation, except for Class V portion (including
agricultural drainage wells) to be addressed by new regulations.
Development grants were available to Slates from '78-'84. Since then only
implementation awards available. Where States have not accepted pnmacy,
responsible Region receives allocation. Development grants still available for
Indian tribes.
UIC program guidance # 42, Agency Operating Guidance, and General Grant
Guidance (40 CFR Part SO) are the framework for State assistance.
Agency administers 17 direct implementation programs nationally, an additional S
split program authority with EPA, 35 States have full program authority, and
Agency administers programs on Indian lands.
FY '88 '89
S million 1 1.5 10.5
SDWA grant funds.
'90 '91 '92 '93
11.2 10.5 10.5 TBD
If State rulemaking is required by new regulations, a 270 day adoption schedule
will be set.
Regions conduct preliminary review of changes in legal authority, HQs have
approval authority.
If regulations do not specify controls other than guidance for agricultural wells,
there would be no formal review process; success in implementation would be
judged during program evaluation visits.
Unlikely that primacy review process will be so complex as to warrant development
of cntena for major components.
Not applicable.
Formula based on population, land area, and injection well inventory. Minimum
allocation, $30,000.
Accomplished through tracking of progress reports against STARS commitments
and periodic (generally annual) reviews.
October 1992
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Appendix A
(4) UNDERGROUND INJECTION CONTROL PROGRAM
CLASS V WELLS (AG DRAINAGE)
(continued)
Review and Approval Process for Program
Integration/coordination
activities in the current
review/approval process:
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
Not applicable.
Comprehensive State Ground Water Protection Programs will serve as the
mechanism for integration. Also need to integrate activities with NPS program
and agricultural pollution prevention efforts.
Page 62
October 1992
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Appendix A
(5) NONPOINT SOURCE PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of Stale flexibility:
Voluntary components:
No direct statutory authority. §319 of CWA grant program provides annual
grants to States to abate NPS pollution from many sources (agriculture, mining,
urban, silviculture, etc.).
To demonstrate and implement effective methods of abating NPS pollution.
Program addresses both surface and ground water, but there is no generic type of
targeted waters. Each State negotiates annual geographic and programmatic
priorities for NPS activities with its Regional Office.
There are approximately 100 sources of NPS pollution which are eligible for §319
funding. Targeting is accomplished through negotiations with each State.
EPA does have some very general criteria, but these may or may not play an
important role in the actual negotiations.
Health and ecological risks are factors to be considered by the State and Region in
negotiating the annual grant.
The OW NPS guidance contains a number of program priorities (control
particularly difficult problems, implement innovative methods, control interstate
NPS problems, etc.). Actual priorities are the result of negotiations between
Regional Offices and States.
NPS grants are made primarily to abate NPS pollution, and grants fund technical
assistance, educational assistance, enforcement activities, monitoring, and cost
sharing for demonstration projects. Many of these activities take place in the
context of NPS watershed projects which reduce runoff or leaching from
agricultural and other NPS activities.
There are no specific agricultural priorities for §319 funding. However,
agriculture receives the most funding of any NPS category. Urban NPS receives
the second highest percentage.
Examples of activities include: support for technical assistance to farmers in
watershed projects; support for monitoring water quality in some watershed
projects; development of educational materials on good farming practices to
protect water quality; support for enforcement programs or for development of
regulations; and cost sharing for agricultural BMPs in demonstration projects.
Participation is voluntary. §319 of the CWA encourages States to develop NPS
programs by making available grants for NPS abatement. If a State does not meet
the eligibility requirements and does not apply for funds, it receives none. Once a
State begins to participate it must meet certain performance standards or face
reduced funding.
States do not receive grant money under §319 of the CWA.
Elements of each State's program are negotiated annually. In general all Stales
are expected to install BMPs, monitor the water quality results, conduct
educational programs, etc.
In general, the States have a lot of flexibility. The degree is primarily up to the
discretion of the Regions.
Everything is negotiated.
October 1992
Page 63
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Appendix A
(5) NONPOINT SOURCE PROGRAM
(continued)
Genera] Overview of Program
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/coordination
activities:
At this stage, standards do not play an important part in the NFS program.
None presently in progress.
Geographical priorities can be identified in each State (e.g., wellhead protection
areas or watershed areas) and the funds/efforts of several EPA programs focussed
on these areas. Ground water and pesticides staff could recommend to NFS staff
specific solutions to specific WQ problems which could be funded by §319. Hold
small meeting with representatives of programs with related statutory authority and
resources to potentially accomplish something significant. Regions currently have
sufficient resources and authority to address agriculture-related problems.
Encourage Regions to use this existing potential.
Page 64
October 1992
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Appendix A
(5) NONPOINT SOURCE PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
Final determination:
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
Integration/coordination
activities in the current
review/approval process:
HQ: The office responsible for §319 grants is the Office of
Water/OWOW/AWPD. The NFS Control Branch has the most direct
responsibility and is located in AWPD.
RO: Responsibility for NFS activities lies with the Regional NFS Coordinator who
is located in the Water Management Division.
The type of agency which is the lead State NFS agency vanes from State to State,
but in most cases K is the water quality or environmental agency. The types of
cooperating agencies vary, but agriculture is always a major issue.
Early stage of program development. Regions are currently following the OW
guidance.
By statute § 319 funds are used solely to implement NFS Management Programs.
The NFS program has no regulations. The OW guidance of 2/15/91 is regarded as
the final guidance for the program, although supplemental guidance may be issued
from time-to-time.
All States have approved NFS Assessments and Management Programs or at least
portions of Management Programs, and consequently are eligible for annual § 3 19
grants.
FY '88 '89 '90 '91 '92 '93
$ million — — 38 51 51 TBD
Funding is primarily from §319 appropriations and from State matching funds (the
minimum State matching 40%).
States submit grant applications on March 30; Regions provide responses to the
States by May 30; Regions award grants by August 15.
No HQ involvement. In most Regions ground water, wetlands, and other EPA
staff comment on draft applications
Each Region has its own process. The National NFS guidance provides general
guidance and a schedule.
The decision is the Region's. Almost all decisions are made at the Branch Chief
level with only contentious issues branch to WMDD.
The NFS guidance indicated that the Region provides a response to the State on
its application by May 30. EPA provides both written and oral comments and
conducts at least one negotiating session with the States.
Funds are distributed by formula based generally on extent of NFS pollution m
each State. Please refer to the guidance.
Oversight is the responsibility of the Region, and therefore vanes from Region to
Region. At a minimum, Regions require quarterly reporting from States and
conduct annual evaluations.
HQ has encouraged Regional NFS coordinators to request the participation of
ground water, estuary, and other program staff in reviewing §319 grant
applications.
October 1992
Page 65
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Appendix A
(5) NONPOINT SOURCE PROGRAM
(continued)
Review and Approval Process for Program
Suggestions for integration/
coordination activities m the
review/approval process of
As/Water programs:
Geographical priorities can be identified in each State (e.g., wellhead protection
areas or watershed areas) and the funds/efforts of several EPA programs focussed
on these areas. Ground water and pesticides staff could recommend to NFS staff
specific solutions to specific WQ problems which could be funded by § 319. Hold
small meeting with representatives of programs with sufficient, related statutory
authority and resources to potentially accomplish something significant. Regions
currently have sufficient resources and authority to address agriculture-related
problems. Encourage Regions to use this existing potential.
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October 1992
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Appendix A
(6) COASTAL NONPOINT SOURCE PROGRAM
General Overview of Program
Statutory authority and
description.
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation.
Components required for
grunts:
Degree of State flexibility:
The Coastal Nonpomt Pollution Control Program was established under §6217 of
the Coastal Zone Act Reauthonzation Amendments of 1990 (CZARA) enacted
on November 5, 1990. State implemented program.
To develop and implement programs to insure implementation of nonpomt source
management measures to restore and protect coastal waters
Coastal Waters including the Great Lakes.
1) agricultural runoff, 2) urban runoff, 3) suvicultural runoff, 4)
hydromodification, dams and levees, and shoreline erosion control, and
5) mannas.
States must at a minimum address the above referenced sources in EPA's
management measures guidance unless the State documents that one of the above
sources is not a problem in their State. States may also address other sources of
nonpomt pollution that they determine are important sources of nonpomt
pollution to coastal waters.
This program addresses both health and ecological risks through a variety of
management techniques.
Priorities for the program are focussed on the five major sources of nonpomt
pollution mentioned above.
1) Completion of management measures guidance by May 1992. 2) Completion
of program guidance by May 1992. 3) Provide technical assistance to State in
development of its State program.
Agriculture is considered the major cause of nonpomt source pollution in the
nation and will be given a priority in the development of Coastal Nonpomt Source
Programs.
The proposed management measures guidance addresses 6 types of agricultural
NPS pollution including: erosion and sediment control, confined animal facility
management, pesticide and nutrient management, grazing management, and
irrigation water management. State Coastal NPS Programs will need to address
each of the agricultural nonpomt sources, as appropriate in a given State.
Section 6217 says that States "shall" prepare and submit Coastal Nonpomt
Pollution Control Program to EPA and NOAA for approval. These programs are
to be implemented through revisions to both State coastal zone management
programs, approved under the Coastal Zone Management Act, and State nonpomt
source programs, approved under §319 of the Clean Water Act.
If either NOAA or EPA determines that a State has failed to submit an
approvable Coastal Nonpoint Program, then graduated penalties (10%-30%) will
be levied on both §306 coastal zone management grants, and §319 nonpomt
source grants beginning FY '96. No State will experience penalties to only one
program.
EPA has prepared proposed program guidance which lists the items that States
are required to include in their Coastal Nonpoint Programs.
States will have some flexibility in interpreting the program guidance to their
specific problems and circumstances.
October 1992
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Appendix A
(6) COASTAL NONPOINT SOURCE PROGRAM
(continued)
Genera] Overview of Program
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/coordination
activities:
Cannot be answered at this time, though some flexibility is anticipated.
Water quality standards are important "reference points'1 for this program and
States are encouraged to use them. Specifically, State Coastal Nonpoint Source
Programs must describe the process for identifying additional management
measures for specific land uses and for critical areas to address situations where
water quality standards are not being attained or maintained.
The same program office that is responsible for implementation of §319 of the
CWA also is responsible for implementation of CZARA, thus the policy aspects of
the two programs are being coordinated. Staff from a number of EPA Offices
and federal and State agencies are participating on workgroups to develop the
guidance for the program. In addition, coordination is occurring between EPA
and NOAA, as the program is jointly administered by these two agencies.
At the Regional level, greater coordination between nonpoint Source staff,
pesticides staff, and national estuary program staff would be helpful. Regions also
need to work with State water quality agencies and coastal zone agencies.
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Appendix A
(6) COASTAL NONPOINT SOURCE PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
find Regions:
HQ: EPA is jointly administering this program with NOAA. The Nonpomt
Source Control Branch within the Assessment and Watershed Protection Division
in OWOW is responsible for implementing the program including preparing
management measure guidance and working with NOAA on developing program
implementation guidance. NOAA has lead for developing program
implementation guidance.
RO: Regional Nonpomt Source Coordinators are responsible for implementing
the program including assisting States in developing coastal programs.
Description of State agency
involvement:
States are required to designate lead agency for each pollution source. The State
coastal zone management agency and designated nonpomt source agency will have
a dual and co-equal role and responsibility in developing and implementing a
State's Coastal Nonpomt Source Program. Several other State agencies will
contribute.
Current program status on
federal level:
The legislation was passed on Nov. 5, 1990; the program is in the initial program
development stage.
How are grant funds used:
Section 6217(h) authorizes NOAA to provide grants to States for development of
Coastal Nonpomt Source Programs.
In the development phase of preparing program implementation guidance and
technical management measures guidance.
Federal program guidance
documents and/or regulations:
Status of implementation on
the Stale level:
No State programs have been approved. Assuming deadlines are met, State
programs would be due on Nov. 5, 1994.
Program funding history:
FY
$ million
'88
'89
'90
'91
'92
'93
Program funding sources:
To date no funds have been appropriated. States provide 50% match for all
federal funds provided under §6217(h). Several other programs provide support
including: CWA §§106 and 319, USDA, and State agencies.
Review/approval process--
Schedule:
Assuming all deadlines are met, then States must submit programs by Nov. 5,
1994. Then EPA and NOAA will review the plans within 6 months.
Review/approval process-
Reviewer:
EPA at headquarters and Regions and NOAA at headquarters.
Review/approval process--
Review process:
To be determined.
Review/approval process-
Final determination:
To be determined.
Review/approval process-
EPA feedback:
To be determined.
Review/approval process-
Awards decision criteria-
To be determined.
Agency oversight and program
evaluation role:
EPA will use its existing approach to oversight used in the §319 CWA Nonpomt
Source Program. NOAA will use its approach to oversight under §306 of the
Coastal Zone Management Program.
October 1992
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Appendix A
(6) COASTAL NONPOINT SOURCE PROGRAM
(continued)
Review and Approval Process for Program
Integration/coordination
activities in the current
review/approval process:
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
Not at this time.
Regional NFS coordinators need to coordinate review and
Coastal Nonpomt Programs with ground water, pesticides,
other appropriate Regional staff.
approval of future State
coastal, wetlands, and
Page 70
October 1992
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Appendix A
(7) PUBLIC WATER SUPPLY PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Public Water Supply Supervision Program derives authority to protect ground
water from SDWA, Public Law 93-523, as amended. States are encouraged to
take primary responsibility for implementation of the program.
To provide safe drinking water at the tap to individuals who obtain their water
from regulated public drinking water supplies. Treatment is required for all
contaminant levels above the MCLs and treatment techniques which fail the
appropriate criteria. A watershed evaluation is required under the surface water
treatment rule. Prevention of future contamination through wellhead protection
and watershed protection programs is important.
Finished water for delivery through public water supply systems.
All contaminants that have MCLs, including 25 pesticides, nitrates, and coliform.
While States are encouraged to take primary responsibility for the program, the
States must follow the program priorities outlined m SDWA.
Public health risks associated with the pubbc drinking water supply.
Current contaminant priorities are microbiological contaminants under the Surface
Water Treatment Rule, Phases II and V organic and inorganic contaminants
(including pesticides and nitrates), and lead.
Enforcement of existing rules, technical assistance to small systems, and
maintaining statutory schedule for rule development.
Adoption of new Phases II and V regulations by States. Technical assistance,
training, and enforcement for compliance with agriculture-associated MCLs;
vulnerability assessments to reduce monitoring and support pollution prevention.
Technical assistance and training through the National Rural Water Association
and the Rural Community Assistance Program. Working with OPP to implement
Farm Bill provisions for pesticide recordkeepmg. Technical assistance to farmers
using the "Farmstead Assessment System" under an interagency agreement with
USDA. Finish Phase II Report from the National Survey of Pesticides in
Drinking Water Wells. Recently promulgated 9 new pesticide MCLs.
States are encouraged to take primary responsibility for implementation of the
program. Currently 55 States and territories have been granted primacy. States
have option of adopting a Vulnerability Assessment program.
States that do not have primacy do not receive grants for State program funding.
EPA takes over ihe operation of the program in non-primacy States. If this
occurs, PWSs will have to deal with two regulatory authorities instead of one.
EPA would also need to streamline the program - technical assistance would be
limited. The focus would be enforcement. System cannot receive monitoring
waiver in States that have not adopted a Vulnerability Assessment program.
Initial granting of primacy requires a State to have the proper legal authority to
implement the program, establish MCLs, monitoring and other primary
requirements no less stringent than EPA's federal regulations, and have adequate
resources. Two major annual requirements include: reporting of selected
information about each PWS in the State; and development of an acceptable
annual work plan.
October 1992
Page 71
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Appendix A
(7) PUBLIC WATER SUPPLY PROGRAM
(continued)
Degree of State flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/
coordination activities:
General Overview of Program
States traditionally have implemented programs much broader than that required
by EPA. However, these programs had less of a "water quality" orientation.
Degree of flexibility has not been determined by precedent. However, EPA
believes primacy requirements can be flexible under SDWA. Vulnerability
Assessments/waivers are optional.
States can and often do have more elaborate programs than required (e.g.,
training and technical assistance).
State regulations must be no less stringent federal regulations for MCLs.
Working to integrate PWS with EPA's Ground Water Strategy for the 1990's,
including integration of WHP into the new Ground Water Disinfection Rule.
Working to finalize report on Farm Bill integration activities. Region VII is
promoting a new cooperative approach between water suppliers and farmers to
reduce pesticide loadings to PWS and to avoid the need for costly treatment to
meet MCLs.
Work with USDA and EPA's Nonpomt Source Program to target watershed and
ground water protection activities toward vulnerable sources of drinking water
supplies. Revitalize coordination with FmHA for addressing small community
capital concerns. Develop coordination approach with OPP to address surface
water contamination from Atrazine and other pesticides in the midwest. Integrate
Vulnerability Assessment programs with Agricultural Policy, ground water
protection, and pesticide registration activities; use pesticide occurrence data to
establish priority list for future MCLs. Use current MCLs as reference point to
determine failure of current management approaches.
Page 72
October 1992
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Appendix A
(7) PUBLIC WATER SUPPLY PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HO
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are gram funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the Stale level:
Program funding history:
Program funding sources:
Review/approval process--
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
Final determination:
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
HQ: OGWDW is nationally responsible for implementing the program. OGWDW
develops the regulations and treatment techniques and provides implementation
guidance (including enforcement and compliance, grant allocations, technical
assistance, program priorities, etc.).
RO: Each Region has a Drinking Water branch which has Regional responsibility.
In some Regions, the PWS and ground water protection programs are combined
into a single branch.
State drinking water programs are either administered in a Department of Health,
Department of Natural Resources, or an Environmental Protection Agency. The
designated primacy agency has full responsibility for implementation at the State
level. This includes, but is not limited to, development of appropriate Stale
regulations, technical assistance, training, and enforcement and compliance.
Advanced phase of program implementation. Technical and financial assistance
have been provided for developing programs.
Federal grant funds are for program implementation only. Development grant
binds for the remaining States and territories or Indian tribes to develop programs
in preparation to apply for primacy are available on an as-needed basis. Pilot
demonstration grants and other funds are available for specific demonstration
projects only.
National Primary Drinking Water Regulations are contained in 40 CFR 141-143.
Other regulations (e.g. grants) are contained in the appropriate CFR sections.
Guidance documents are available for implementation of specific rules.
55 of the States and territories have been granted primacy. Two Indian tribes
have been approved for treatment as a State. An additional tribe is very close to
approval for treatment as a State.
FY '88 '89 '90
S million 33.45 33.45 39.82
'91 '92 '93
47.45 49.95 TBD
SDWA budget. States are required to meet at least a minimum match of 25%.
State's submission of its annual grant application is typically done in the spring with
final EPA Regional approval in the fourth fiscal quarter.
Regions.
Regions review HQ priorities and include them along with Regional priorities
Regions have the lead. RA signs off on the grants.
Regional offices maintain close coordination with the grant recipients
State grant funds are awarded based upon a formula.
October 1992
Page 73
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Appendix A
(7) PUBLIC WATER SUPPLY PROGRAM
(continued)
Review and Approval Process for Program
Agency oversight and program
evaluation role:
Integration/coordination
activities in the current
review/approval process:
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Wnter programs:
The Regions are directly responsible for performing oversight of each primacy
agent.
The Regions are aware of HQ's priorities and the importance of these priorities
being covered in the State grants.
Regions can emphasize priorities by establishing grant conditions, when negotiating
grants with the States; Vulnerability Assessment guidance; use PWS compliance as
an evaluation mechanism of success of programs; farm user group notification of
pesticide use to PWS (tie in with Vulnerability Assessment); national monitoring of
ground water and surface water (tie in with Vulnerability Assessment and waiver).
Page 74
October 1992
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Appendix A
(8) NEAR COASTAL WATERS PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Product of EPA strategic planning process of 1986. State- and federally-
implemented demonstration projects.
To maintain and, where possible, enhance near coastal water environmental
quality.
Inland waters to the head of tide, the territorial seas, including areas of greater
distance where necessary to protect coastal barrier islands and the mouths of
certain estuaries. The Great Lakes were included in the plan.
All point and nonpomt sources of water pollution as identified by the program.
States participate with EPA Regions in development of a Regional NCW strategy,
prioritizing waterbodies for remediation and restoration.
Health risks posed by sewage and industrial effluent, urban and agricultural runoff,
and contaminated ground water from point and non point sources. In upland
coastal watersheds risks addressed include habitat degradation and impairment to
living resources and ecosystems.
Regional strategies will identify the priorities for achieving goals. Development of
Regional strategies involves assessing coastal problems and then setting priorities
for remediation.
HQ and Regions in process of developing a NCW guidance document that will
provide guidance to Regions and States when developing Regional strategy.
New priorities will be consistent with NEP recommendations.
Strategy: 1) identifies and coordinates federal, State, and local government
technical assistance activities; 2) assists in outreach for local decisions: and 3)
coordinates locally managed data and information.
Voluntary program.
State will not receive NCW funds.
Based on goals and objects of National Coastal and Marine Policy. 80% for
implementation and 20% for development/enactment of base programs.
Too early to be determined.
Innovative pilot projects and demonstrations.
At this time there are no standards for "estuarme waters". There are standards for
fresh water and salt water that are in some cases the same and could be used in
an estuarme environment. States are required to use EPA "reference points" or
standards in any case where the law applies.
NCW Integrated Training and the Coastal Programs Handbook.
October 1992
Page 75
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Appendix A
(8) NEAR COASTAL WATERS PROGRAM
(continued)
Genera] Overview of Program
Suggestions for future policy
integration/coordination
activities:
Set up an mteragency steenng committee with high-level managers from each
agency as members, but with extensive technical support from the staffs of the
respective agencies. Need to provide clear incentives or rewards for coordinating
with other programs and helping other agencies.
Page 76
October 1992
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Appendix A
(8) NEAR COASTAL WATERS PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process--
Reviewer
Review/approval process-
Review process:
Review/approval process-
Final determination:
Review/approval process--
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
Integration/coordination
activities in the current
review/approval process:
HQ: OWOW/OCPD responsible for implementing all facets of program at the HQ
level.
RO: Regional NCW coordinators. Participating Regions have Dwsion-Branch-
Section structure that coordinate with the program activities at the State and
Regional level.
No requirement for designated lead agency which varies State-by-State. Usually,
agency(ies) that deals with Water Quality, Coastal, Environmental, or Natural
Resource issues. State and local governments are responsible for implementing
the program. Role involves developing a "Base Program Analysis" summarizing all
activities that influence the program.
Development phase.
Funds are used for both development and implementation
projects identified in the Regional Strategic Plan.
of demonstration
Guidance under development. Both Region and HQ responsible for development
of new Guidance.
Five NCW Regional strategies developed (Region I, IV, VI, DC, and X). 3
Regions are in the process of developing their strategies. Pilot projects are
underway in all 8 Regions.
FY
$ million
'88
...
'89
...
'90 '91
6.8
'92 '93
4.5 approx. TBD
Coastal Environmental Management fund §104(b)(4). NCW program grants
require a 5% match from the State.
Varies by Region.
EPA HQ reviews Regional strategy developed by Region with State input.
Region works with the State to develop projects based on the Regional strategy
and based upon criteria developed within the NCW Guidance document.
Approval or disapproval based on criteria established by the NCW Guidance
document.
Guidance under development. Previous years based on preliminary guidance.
Previous years awards based
programs.
on preliminary guidance. Enactment of base
HQ and Regions develop workplans together
Primary goal of NCW program is the coordination of base
States and local governments.
programs between
October 1992
Page 77
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Appendix A
(8) NEAR COASTAL WATERS PROGRAM
(continued)
Review and Approval Process for Program
Suggestions for integration/
coordination activities in the
review/approval process of
Aft/Water programs:
1) Institutionalize the review and approval process for Ag/Water programs. 2)
Develop national criteria and standards for bottom sediment and overlying saline
water which recognize difference between the ecology and Irving resources of
aquatic systems. 3) Agriculture should be viewed as an industry and the Agency
should develop technology-based effluent guideline discharge limitation regulations.
Page 78
October 1992
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Appendix A
(9) NATIONAL ESTUARY PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-panicipation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Use of "reference points":
CWA of 1987 §320. State implemented, includes demonstration projects.
To identify nationally significant estuaries threatened by pollution, development or
overuse, and to promote the preparation of Comprehensive Conservation
Management Plans (CCMF) to ensure their ecological integrity.
Those nominated by the Governors of States as "significant U.S. estuaries and
bays", including tributaries.
All sources of pollution, identified by each program during the "priority problem
identification" and "characterization" phases of the CCMP development.
States participate in NEP management conferences in the development of CCMPs,
prioritizing water bodies for remediation and restoration.
Health risks posed by sewage and industrial effluent, urban and agricultural runoff,
and contaminated ground water from point and non point sources upstream as
well as on the coast. Also, intended to monitor habitat, ecosystem, and living
resources.
Priorities are determined based on assessment of top problems within the estuary,
as determined by each State/EPA management Conference Agreement.
To achieve goal, program office activities include: 1) establish working
partnerships among federal, State, & local governments; 2) transfer scientific and
management information; 3) increase public awareness of pollution problems &
ensure public participation in consensus building; 4) promote basin-wide planning
to control pollution & manage living resources; and 6) oversee development of
pollution abatement and control programs.
Outlined and Identified by each individual program.
Technical information transfer during the planning process, no direct technical
assistance. NEP has data management policy for all data collected with NEP
funds.
Voluntary program. When a State signs a Conference Agreement it commits to
developing a CCMP.
State does not receive NEP funds.
CWA §320 outlines the 7 purposes of the NEP.
Moderate to high.
States are given the option to modify program to meet specific needs as long as
modifications do not conflict with the special conditions and requirements specified
by EPA in the Conference Agreement.
At this time there are no standards for "estuarine waters". There are standards for
fresh water and salt water that are in some cases the same and could be used in
an estuarine environment. States are required to use EPA "reference points" or
standards in any case where the law applies.
October 1992
Page 79
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Appendix A
(9) NATIONAL ESTUARY PROGRAM
(continued)
Current policy-related
integration/coordination
activities:
Suggestions for future policy
integration/ coordination
activities:
General Overview of Program
Participating States required to develop a Base Program Analysis. Also, States are
encouraged to review State and federal options for implementation funding and
demonstration project funding.
Set up an interagency steering committee with high-level managers from each
agency as members, but with extensive technical support from the staffs of the
respective agencies. Need to provide clear incentives or rewards for coordinating
with other programs and helping other agencies.
Page 80
October 1992
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Appendix A
(9) NATIONAL ESTUARY PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of Slate agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process--
Schedule:
Review/approval process-
Reviewer
Review/approval process--
Review process:
Review/approval process-
Final determination:
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
Integration/coordination
activities in the current
review/approval process:
HQ: OWOW/OCPD responsible for implementing all facets of the program at the
HQ level.
RO: Regional NCW coordinators. Participating Regions have Division-Branch-
Section structure that coordinate with the program activities at the State and
Regional level.
Lead agency varies State-by-State. Usually, agency(ies) that deal(s) with Water
Quality, Coastal, Environmental, or Natural Resource issues. Role involves
developing a "Base Program Analysis" summarizing all activities that influence the
program. Formal coordination is accomplished by the signatories to the
Conference Agreement.
Program is a planning process.
Technical assistance, financial assistance, and development of CCMPs.
CWA §320. Grant regulation 40 CFR 35 subpart(p). Functions are to identify
grant recipients, purposes, federal share, grant reporting, authorization of
appropriations, research, and application process. Several specialized guidances are
available.
CCMP development and implementation phase. Two completed and submitted
CCMPs, one accepted by the Administrator, the other with the State for revisions;
and 15 NEPs in the process of developing CCMP.
FY '88 '89
$ million — 12.9
'90 '91 '92 '93
16.1 15.1 15.6 TBD
CWA §320. One requirement of participation is a minimum 25% cost share.
—
Regional office and OCPD.
Regional office and OCPD review the annual workplans for consistency with the
requirements and special conditions established in the Conference Agreement.
If the workplan meets all criteria then
program funds are released to the State.
—
—
Agency workplans reviewed by both EPA HQ and Region. CCMPs must be
approved by Administrator after CCMP, EPA has role in monitoring effectiveness.
Working toward coordination based on program guidance: Federal Consistency
Review as required by CWA §320(b)(7).
October 1992
Page 81
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Appendix A
(9) NATIONAL ESTUARY PROGRAM
(continued)
Review and Approval Process for Program
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
1) Institutionalize the review and approval process for Ag/Water programs. 2)
Develop national criteria and standards for bottom sediment and overlying saline
water which recognize difference between the ecology and living resources of
aquatic systems. 3) Agriculture should be viewed as an industry and the Agency
should develop technology-based effluent guideline discharge limitation regulations.
Page 82
October 1992
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Appendix A
(10) CHESAPEAKE BAY PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Use of "reference points":
CWA of 1987 § 1 17. State implemented, includes demonstration projects.
To restore and enhance the living resources of the Chesapeake Bay. The 1987
Chesapeake Bay Agreement contains goals and priority commitments for living
resources; water quality; population growth and development; participation; public
access; and governance.
As defined by the watershed down to the Atlantic Ocean interface.
All point and nonpomt pollution plus atmospheric deposition of pollutants are
targeted for prevention and remediation, including agricultural runoff.
States participate in the 1987 Bay Agreement by implementing priority
management programs.
Health risks posed by sewage and industrial effluent, urban and agricultural runoff,
and contaminated ground water from point and nonpomt sources upstream as well
as on the coast Also, intended to monitor habitat and ecosystem, as well as living
resources.
Priorities specified in the 1987 Chesapeake Bay Agreement and its supporting
commitment (strategy) documents.
Installation of BMPs first priority and implementation of the program elements
receive a significant portion of the budgeted and expended CBP funds.
Program has spent S54.2 million on installation of agriculture BMPs.
Approximately 30% of the funds awarded as grants to Slate agencies are expended
for technical assistance, outreach education, progress reporting, data management,
research, and modeling, with the balance spent on direct financial assistance grants
to farmers for BMP installation.
Voluntary. Pennsylvania, Maryland, DC, and Virginia signed an Agreement in '83
committing them to cooperative efforts in implementing the program. '87
Agreement expanded '83 interstate agreement to include numerical goals and
achievements to be achieved by these same States.
None
All 12 components listed in Table I and more.
Each strategy and implementation plan goes through a scheduled reevaluation
every 3-4 years. They are not negotiable.
Integrated Pest Management as a pollution prevention program is one such
example of a new component. This will be incorporated into the Toxic Reduction
Strategy during the 1992 reevaluation.
At this time there are no standards for "estuarine waters". There are standards for
fresh water and salt water that are in some cases the same and could be used in
an estuarine environment. States are required to use EPA "reference points" or
standards in any case where the law applies.
October 1992
Page 83
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Appendix A
(10) CHESAPEAKE BAY PROGRAM
(continued)
Genera] Overview of Program
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/ coordination
activities:
Participating States are required to develop a Base Program Analysis. Also, States
are encouraged to review State and federal options for implementation funding
and demonstration project funding.
Set up an interagency steering committee with high-level managers from each
agency as members, but with extensive technical support from the staffs of the
respective agencies. Need to provide clear incentives or rewards for coordinating
with other programs and helping other agencies.
Page 84
October 1992
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Appendix A
(10) CHESAPEAKE BAY PROGRAM
(continued)
Revii- v and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process--
Reviewer:
Review/approval process-
Review process'
Review/approval process-
Final determination:
Review/approval process—
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
HQ: OWOW responsible for budget, development, and implementation of
program. Administrator's staff responsible for policy and interstate agreements.
RO: Region III, RA, and Chesapeake Bay Program Office are responsible for
program planning policy, legislation, etc.; and Chesapeake Bay Liaison Office is
responsible for program coordination, provision of technical assistance, etc.
State lead varies with each State/jurisdiction, but generally is found in Water
Quality, Coastal, or State environmental agency.
EPA is working with States in program implementation.
Administrator signed the Bay Agreements causing them to have the force of
regulations on the federal agencies. The MOU's are reflective of that, and each
agency contributes to the federal workplan each year.
CBP regulation CWA §117(b) Interstate Development Plan Grants provide an
overview of the grants award process. Specific grant guidance is developed each
year for each State.
The State and DC programs involving eight States and two DC agencies are fully
implemented.
FY '88 '89 '90 '91 '92 '93
$ million — 12.2 12.6 14.9 16.3 TBD
CWA §117. Requires a 50% match for all State and DC program grants.
Varies by grant program.
Varies by grant program.
Various grants (1 17, 319, 106, 205j(S), etc.) within the water media are given
extensive program review starting with grant guidance and ending with the scope of
work of the final grant application. The purpose of the review is to assure across-
the-board program integration.
Vanes by grant program.
Vanes by grant program.
Vanes by grant program.
State programs submit quarterly tracking reports showing point and nonpomt
source nutrient load reductions. Associated and support program deliverables such
as educational material, technology demonstration projects, etc., are reported on
the comparison quarterly reports. Environmental indicators are used to track
improvements.
October 1992
Page 85
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Appendix A
(10) CHESAPEAKE BAY PROGRAM
(continued)
Review and Approval Process for Program
Integration/coordination
activities in the current
review/approval process:
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
Not currently involved in any coordination efforts.
1) Institutionalize the review and approval process for Ag/Water programs. 2)
Develop national criteria and standards for bottom sediment and overlying saline
water which recognize difference between the ecology and living resources of
aquatic systems. 3) Agriculture should be viewed as an industry and the Agency
should develop technology-based effluent guideline discharge limitation regulations.
Page 86
October 1992
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Appendix A
(11) STATE WETLANDS PROTECTION PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted.
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities-
No direct statutory authority. Derives authority from Clean Water Act
§104(b)(3).
Development of new State wetlands protection programs or enhancement of
existing State programs.
Wetlands and other waters of the U.S.
All sources of contamination and degradation.
High.
Ecological.
Development of wetlands protection programs.
State Wetlands Conservation Plans, State CWA Section 404 assumption, and
watershed protection demonstration projects.
Not identified as priority.
May be part of State Wetlands Conservation Plans or watershed protection
demonstration projects.
Voluntary.
Funding not available.
Vanes.
Moderate.
Yes
No
(No response provided)
October 1992
Page 87
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Appendix A
(11) STATE WETLANDS PROTECTION PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
Final determination:
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
Integration/coordination
activities in the current
review/approval process:
HQ: Develops grant guidance with Regional input and
RO: Review and select projects to be funded.
review.
No specific State agency has lead. Types of agencies to be funded vary from State
to State.
Program is in early stages of development.
Develop new or enhance existing State wetlands protection programs.
No regulations. Grant guidance developed annually.
State interest has been high. 48 States have been funded.
FY '88 '89 '90 'S
$ million — — 1
>1 '92 '93
5 8.5 TBD
CWA budget; States are required to have a minimum match of 25%.
Grant applications were due to EPA Regional offices by February 3, 1992.
Regional offices select projects to be funded. HQ has a review role.
Each Region has its own process.
Regions award grants.
Regional offices maintain close contact with States. Regional offices report status
of grant activities to HQ.
Selection of grants is competitive.
Regions will evaluate/monitor projects to assure that grant moneys are going to
their intended purpose.
No formal coordination program; coordination may occur on a Region by Region
basis.
Page 88
October 1992
-------
Appendix A
(12) CLEAN LAKES PROGRAM
General Overview of Program
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Administered under Section 314 of Clean Water Act, as amended. Lake
restoration and protection program.
Provide financial and technical assistance to States to conduct lake restoration and
protection projects; conduct Statewide lake assessments.
Surface water: specifically, publicly-owned lakes that offer public access and
recreational opportunities. Clean Lakes Program Regulations prohibit use of
Section 314 funds for lakes that are solely drinking water supplies (i.e., offer no
recreational opportunities).
Non point sources of pollution targeted for prevention and/or remediation
activities. Clean Lakes Program Regulations prohibit use of Section 314 funds for
control of point sources of pollution.
States have a strong role in priority setting - they apply for funds for waters
(lakes) they want to protect.
Ecological risks, specifically habitat protection.
Financial assistance provided through four types of grants. Offer technical
assistance through various means. Support development of State lake programs.
Grants offered for Phase I - Diagnostic/Feasibility Studies of specific lakes; Phase
II - Restoration/Protection Implementation Projects for specific lakes already
diagnosed; Phase III - Post-Restoration Monitoring Studies; and Phase IV - Lake
Water Quality Assessments. Technical assistance offered through: 1) technical
documents; 2) operating clean lakes clearinghouse; and 3) sponsoring national
conferences and workshops.
No specific agriculture-related activities.
Phase II funds are being used by many States to implement agricultural BMPs in
watershed areas to minimize excess nutrients and sediments in lakes.
Not required to conduct Phases I-III. States statutonly (§314) required to report
(in 305(b) biennial reports) on certain aspects of lake water quality and their
efforts to control and mitigate adverse effects of pollution to lakes. Lake Water
Quality Assessment grants intended to assist in gathering and reporting the
required information.
Failure to comply with reporting requirements renders States ineligible for all
Clean Lakes funding.
Type of grant determines specific components required to receive grant funds. In
addition to the 8 components listed on Table I, Clean Lake grant applications
should include a description of public access to lake.
States have considerable flexibility « in EPA's 1980 Clean Lakes regulations,
minimum requirements are defined.
Diag- sing, restoring/protecting, and evaluating restoration efforts all voluntary.
Stati encouraged to include a citizens' volunteer monitoring program component
in Li i Water Quality Assessment grants.
October 1992
Page 89
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Appendix A
(12) CLEAN LAKES PROGRAM
(continued)
General Overview of Program
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/ coordination
activities:
Not required to use EPA reference points or standards to receive funds. Region
X encouraging States to use data gathered in Diagnostic Feasibility Study to
develop a TMDL prior to requesting Restoration funding.
There is close coordination between the Clean Lakes Program and the Nonpoint
Source Program at both HQ and in the Regions because the two programs are in
the same office organizationally. Region V has been in the forefront of Regional
coordination.
Encourage Regional offices to coordinate more consistently across all ten Regions,
and to follow Region V's example.
Page 90
October 1992
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Appendix A
(12) CLEAN LAKES PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
Final determination:
HQ: OWOW; Assessment & Watershed Protection Division issues annual
implementation guidelines; provides technical assistance; reviews and
approves/disapproves submittals; and issues funds to Regions for grant award.
RO: Water Management Division receive project submittals from States; review,
approve/disapprove, and prioritize submittals; award grants; serve as EPA Project
Officer in developing workplans and oversight of project implementation.
State water quality agency is lead agency in most but not all States. Role to
develop detailed workplans and coordinate all aspects of project implementation.
Agriculture, fish, and wildlife agencies may also be involved in project development
and implementation.
Program fully operational. Technical and financial assistance provided to States, as
described on previous page.
To conduct Phase I, II, and III projects and Statewide assessments.
CLP regulations (40 CFR 35 Subpart H, 1980) assist States in applying for grant
funds. CLP guidance assists States in implementing new (1987 CWA Reauth.)
elements of program. Annual implementation memo to Regions to assist States to
prepare their annual requests for funding.
44 States, 1 territory, and 15 Indian tribes participate. About 200 completed
projects and 450 active projects.
FY '88 '89
$ million 0.0 7.5
5.0 (demo)
'90 -91 '92 '93
8.7 7.0 7.0 TBD
3.8 (specific projects)
Agency receives CLP appropriation as Congressional add-on. States required to
match all CLP funding. Lake Water Qua). Assessment Grants and
Restoration/Protection Projects matched 50% by State, 50% by fed. Diagnostic
Feasibility Study and Post-Restoration Monitoring Studies matched 30% by State,
70% by fed.
HQ issues implementation memo to Regions with requirements, priorities,
schedule, and target Regional allocations. States submit requests for funding to
Regional offices during lst/2nd qtr. of each fiscal year. Region reviews,
approves/disapproves, and prioritizes State submittal within their target allocation
and forwards those approved to HQ at begin, of 3rd qtr. HQ transfers funds to
Region. Region awards grant by end of 4th qtr.
Regional Clean Lake coordinators and HQ Clean Lakes staff. Technical peer
review by scientists with expertise in lake restoration as needed for restoration
projects.
State submittals evaluated based on their compliance with CLP Regulations and
Guidance. Weaknesses may be addressed as special conditions to the grant award.
Regions forward approved submittal to HQs for a final programmatic review and
approval.
October 1992
Page 91
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Appendix A
(12) CLEAN LAKES PROGRAM
(continued)
Review and Approval Process for Program
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
Integration/coordination
activities in the current
review/approval process:
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
Regional Clean Lakes coordinator works with State at all stages of review process
to address weaknesses in their submittal. Region works with State to finalize
submittal.
Many Clean Lakes projects are expensive and require multi-year funding. Agency
and State work together and develop workplans and budget needs that can be
funded in 1-2 yr. increments as resources allow.
Regular contact with State, project sight visits, and scheduled status reports.
Coordinate efforts with SCS, USDA, and when appropriate with other federal
agencies.
Continue working on small watersheds areas and small projects, such as Rural
Clean Water Program, which has been successful in the past.
Page 92
October 1992
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Appendix A
(13) NPDES PROGRAM
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
General Overview of Program
Granted statutory authority under Clean Water Act. Granted regulatory authority
in 40 CFR 121 through 12S, 129, 136, and the 400 series. NPDES program
regulates all point source discharges to U.S. waters through permitting and
enforcement program which is implemented by 39 approved States and territories
and by EPA. Agricultural activities under NPDES program authority include
permitting of feedlots of 1000 or more animal units or other facilities determined
on case-by-case basis to contribute to water impairment (as defined in 40 CFR
122.23).
Overall goal to restore and maintain the chemical, physical, and biological integrity
of the nation's waters and ultimately eliminate the discharge of pollutants. Interim
goal is to make nation's waters fishable and swimmable.
Surface waters.
Point sources including stormwater targeted for prevention and/or remediation
activities; specifically, §402 of CWA focuses on establishing water-quahty-based
and technology-based requirements for point source discharges through NPDES
Permit program.
Under §304(1) of CWA, States identify waters which are not anticipated to attain
or maintain: 1) Water Quality Standards (WQSs) due to toxic pollutants; or 2)
water quality to assure protection of human health, public water supplies;
agricultural or industrial use; protection of shellfish, fish and wildlife; and allow
recreation in and on the water.
Protect human health, aquatic life, and wildlife. Few feedlot permits based on
water quality concerns, but tend to implement technology-based effluent limitation
guidelines (Effectively no discharge effluent limitation guidelines).
Focus on facilities impacting surface water quality.
Point source discharges which are classified as "Majors" due to size, nature of
discharge, or potential to cause a water quality impact. Focus on controlling toxic
pollutants.
Development of permitting guidance on feedlots to expand focus of permits to
BMP including land application, manure storage, and composting.
NPDES does not provide technical assistance or outreach to agricultural
community as a whole. Some States have programs to address this.
Voluntary, States encouraged by federal statute to develop a NPDES program.
No action taken against a State that does not develop/implement a program.
See CWA § 106 fact sheet discussion for grants information.
Minimum requirements specified but States have flexibility developing components
beyond minimum basic requirements.
States encouraged to adopt general NPDES permit authority components.
October 1992
Page 93
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Appendix A
(13) NPDES PROGRAM (continued)
General Overview of Program
Use of "reference points":
Current policy related
integration/coordination
activities:
States are required to adopt WQSs, but these are not related to
funds.
Not a primary focus at this time. OWEC is working with OPPE
identify ways of improving feedlot regulation.
receipt of grant
and OWOW to
Page 94
October 1992
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Appendix A
(13) NPDES PROGRAM (continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
Final determination:
Review/approval process--
EPA feedback:
Review/approval process--
Awards decision criteria:
Agency oversight and program
evaluation role:
HQ: OST develops technology-based effluent limitations guidelines, establishes
water quality criteria, and reviews and approves State WQSs. OWEC provides
oversight, technical assistance and policy development for NPDES permuting and
reviews.
RO: Oversee approved States and provide technical assistance. Carry out NPDES
in unapproved States and approves State permit programs along with HQ's
concurrence.
Lead agency varies from State to State. For contamination due to feedlots, State
versions of EPA, Department of Agriculture, and Soil Conservation Services.
39 approved State or territory NPDES programs. In area of program
implementation, EPA and Regions provide technical and financial assistance
through CWA §104 and $106 monies.
Regulation of point source pollution sources of surface waters.
Granted statutory authority under the Clean Water Act, Section 402. Granted
regulatory authority in 40 CFR 121 through 125, 129, 136, and the 400 Series.
Guidance documents for implementation of specific requirements are available.
39 approved State or territory NPDES programs. Arizona, Florida, Oklahoma,
South Dakota, and Texas interested in developing NPDES programs.
FY '88
S million
(KC CWA §106)
'89 '90
...
'91
...
'92 '93
...
For grants, see CWA §106 discussion. For NPDES program authorization, see
below.
After State submittal, EPA publishes elements of proposed State program in
Federal Register. Public comment period for public to comment on State
program. Public hearing period within State. Within 90 days of receipt of a
complete State program submission RA shall approve/disapprove program. If RA
disapproves program, he/she shall notify State of reasons for disapproval and
revisions to State program necessary for approval.
Concurrent review/approval process through EPA Regions and Headquarters.
See Review Schedule.
Concurrent final determination between Regions and HQs.
Because review/approval process is concurrent, EPA HQs and
feedback and interact throughout the process.
Regions provide
Requirements of CWA.
Regional offices oversee approved States. Headquarters oversee Regional offices
and in conjunction with the Regions, the States.
October 1992
Page 95
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Appendix A
(13) NPDES PROGRAM (continued)
Review and Approval Process for Program
Integration/coordination
activities in the current
review/approval process:
Not currently involved in integration/coordination activities.
Page 96 October 1992
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Appendix A
(14) CLEAN WATER ACT SECTION 106 PROGRAM
Statutory authority and
description:
Program goal:
Waters targeted:
Contamination sources
targeted:
Role of Slate in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Use of "reference points":
General Overview of Program
Derives authority from CWA §106 "Grants for Pollution Control Programs."
Federal grant program to support State water quality management programs.
To provide grants to States, inter-State agencies, and qualified Indian tribes for
overall administration and program support of their water quality management
programs.
Surface and ground waters; specific high priority waters can be selected during
grant negotiation process.
Virtually any source of surface and ground water pollution.
Overall priorities dictated by AOG and OW annual program guidance. States
delineate their priorities during grant negotiation process. Priorities may be
program-specific or geographic.
High risk activities (e.g. human health, aquatic life, and wildlife) would be
considered high priority in projects.
General priorities reflected in AOG: 1) To support establishment of tone water
quality standards, issue/reissue NPDES permits; 2) To maintain monitoring
programs, etc.
National priorities formulated into State-specific guidance by Regional offices for
use in negotiating annual grant agreements.
Primarily AOG and Region-specific guidance to each State.
Section 106 is not a primary funding source for agriculture-related activities.
Section 106 funds frequently support certain activities tunded as part of a larger
§319 efforts such as monitoring surveys, printing of publications, ADP support,
etc.
Voluntary, but once grant agreement signed §J06 funding support can be reduced
or withheld if certain obligations are not met or if State fails to implement certain
mandatory CWA requirements (e.g., adopting WQSs for toxics).
Sanctions (e.g., reducing or withholding a grant) available if State does not comply
with EPA's overall priorities and grant work program commitments.
15 program elements with outputs, resources, and milestones established for each.
(See Table I)
States have flexibility in shaping their annual 9106 grant programs but must
adhere to AOG and follow program regulations and guidance for statutonly
mandated activities funded under $106.
State can tailor its program around required program elements to customize
program to meet specific needs.
Not directly related to §106. States are required, however, by CWA to adopt
WQSs. States use EPA recommended criteria as basis for adopting standards but
are allowed to establish their own criteria if sufficient to protect designated uses of
that State.
October 1992
Page 97
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Appendix A
(14) CLEAN WATER ACT SECTION 106 PROGRAM
(continued)
Genera] Overview of Program
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/coordination
activities:
Participated in OPPE "Comparative-risk" pilot project to examine methods of
improving coordination of grant funds for high priority activities. Conducting a
State water quality management funding analysis to determine current use of grant
funds from several sources based on standard list of eligible activities.
Coordination of national guidance. Improve Regional/State grant
negotiation/project review process to stress need for improved coordination
between grant programs.
Page 98
October 1992
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Appendix A
(14) CLEAN WATER ACT SECTION 106 PROGRAM
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
HQ: Office of Wastewater Enforcement and Compliance provides overall grant
guidance via AOG.
RO: Water Management Division staff tailors AOG guidance to meet individual
State needs; negotiates grant agreements; and evaluates performance through on-
site written evaluations.
Description of State agency
involvement:
Lead agency typically State water quality agency. Depts. of Health and Agriculture
involved in some cases. States have the option to fund sub-State or local agencies.
Current program status on
federal level:
Ongoing program since 1972. Regions assign project officers to each State and
WMD staff are available to provide technical assistance.
How are grant funds used:
Overall administrative and program support for State water quality management
programs.
Federal program guidance
documents and/or regulations:
AOG and Region-specific guidance to each State. Section 106 regulations; 40
CFR Parts 35 & 130; Water Quality Planning and Management Final Rule.
Status of implementation on
the State level:
All 63 States, inter-State agencies, and territories receive grants each year. Also,
approximately 100 grants awarded to Indian tribes.
Program funding history:
FY
$ million
'88
61.0
'89
67.1
'90
72.6
'91
81.7
'92
81.7
'93
TBD
Program funding sources:
Section 106, direct appropriation. States required to contribute a level of effort
match; State contribution averages approximately 1/3 to 2/3 of total program.
Review/approval process-
Schedule:
June/July: States submit draft workplans. Sept./Oct.: States submit final workplans.
Jan-June.: Regions review programs.
Review/approval process-
Reviewer:
Regional Water Management Divisions (circulated to other programs as
necessary).
Review/approval process-
Review process:
Vanes from Region to Region, but most conduct structured review against
HQ/Regional priorities.
Review/approval process-
Final determination:
Regional project officer has lead, but Division Director/RA signs grant.
Review/approval process-
EPA feedback:
Written evaluations and continuous coordination between grantee and Regional
project officer.
Review/approval process-
Awards decision criteria:
Individual grant awards are determined based on work program development and
State grant targets that are determined by formula.
Agency oversight and program
evaluation role:
Written evaluations conducted by Regional Offices.
Integration/coordination
activities in ihe current
review/approval process:
As States submit annual grant work programs for Regional review, any
agriculture/water-related activities are typically reviewed in coordination with
NPS/Agnculture staff.
October 1992
Page 99
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Appendix A
(15) AGRICULTURE POLLUTION PREVENTION STRATEGY
Genera] Overview of Strategy
Statutory authority and
description:
Strategy goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing ag. practices:
Agriculture-related activities:
Mandatory or voluntary State
participation-
Result of non-participation:
Components required for
grants:
Degree of State flexibility:
Voluntary components:
Use of "reference points":
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/coordination
activities:
Request by Congressional Committee responsible for pollution prevention
legislation.
Protect human health and aquatic and terrestrial ecosystems while assunng the
economic viability of food and fiber production.
All waters.
All sources.
States have a lead role in identifying priority geographic areas.
Risks due to agriculture, largely drawn from Science Advisory Board report.
Still in draft; covers agriculture risks identified by Science Advisory Board.
All relevant EPA and USDA programs. Emphasis on measurable results.
Some practices to be identified for advancement nationally. Some practices
identified for use in specific watersheds.
Integrates with all EPA and USDA agriculture-related programs.
Program is voluntary. States encouraged to set priorities to guide federal agency
(e.g., USDA, EPA) spending.
Failure to set priorities which guide federal agency leads to less support.
9 program elements. Very general guidance at first, but potential for more
specific approaches.
Wide flexibility as long as goals are met.
Yes.
States required to use EPA "reference points" or standards (e.g., MCLs, WQSs) in
operating program. States allowed to use State standards if at least as stringent as
federal standards or in absence of federal standards.
Integration a major objective of strategy.
All proposed activities require EPA integration among EPA programs and with
USDA.
Page 100
October 1992
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Appendix A
(15) AGRICULTURE POLLUTION PREVENTION STRATEGY
(continued)
Review and Approval Process for Strategy
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process-
/Fmal determination:
Review/approval process-
EPA feedback:
Review/approval process-
Awards decision criteria:
Agency oversight and program
evaluation role:
HQ: Activities include: working with interested parties to set targets and attain
voluntary, nationwide reductions in use of hazardous substances; providing
information to reduce use of hazardous substances during registration of
pesticides; expediting registration of safer pesticides; identifying priority U.S.
ecological systems; setting criteria for identifying priority water quality problem
areas; setting criteria for certifying integrated chemical management firms; and,
working with other agencies to attain these and other objectives.
RO: Activities include: working with State water quality agencies to identify
priority areas; and providing some selective enforcement where priority problems
not adequately by voluntary programs.
State water quality agencies have the lead in identifying priority watersheds and
monitoring achievement of strategy targets for these areas.
Pollution prevention serves integrating function. Purpose is to target federal
program funds based on water quality and terrestrial, ecological priorities some of
which are set by States, others federal.
No formal link yet, but grants would be heavily influenced by any State priority
setting.
No guidance yet.
None yet.
FY '88
S million
'89 '90
...
'91 '92 '93
_
EPA may designate certain funds specifically for Pollution Prevention. However,
pollution prevention strategy will integrate several areas of federal & Slate
programs.
None yet.
None yet.
None yet.
None yet.
None yet.
None yet.
See Headquarter's and Regions' roles identified above.
October 1992
Page 101
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Appendix A
(15) AGRICULTURE POLLUTION PREVENTION STRATEGY
(continued)
Review and Approval Process for Strategy
Integration/coordination
activities m the current
review/approval process:
Suggestions for integration/
coordination activities in the
review/approval process of
Ag/Water programs:
Strategy to
serve an integrating function.
Integration is essential to the strategy, to focus resources on specific water
problem areas and critical ecological systems and to achieve targets.
quality
Page 102
October 1992
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Appendix A
(16) NITROGEN ACTION PLAN
General Overview of Strategy
Statutory authority and
description:
Strategy goal:
Waters targeted:
Contamination sources
targeted:
Role of State in setting
priorities:
Risks addressed:
Priorities for achieving goal:
Programmatic priorities:
Programmatic priorities for
addressing agricultural
practices:
Agriculture-related activities:
Mandatory or voluntary State
participation:
Result of non-participation:
Components required for
grants:
Degree of Slate flexibility:
Voluntary components:
Use of "reference points":
No lead EPA office, each of the following must take responsibility for related
activities: CWA, SDWA, and TSCA. OW, OPTS, ORD, OPPE, Regions and
States are involved in development and implementation. USDA offices with
related activities are participating as well.
To protect ground water and surface water from all sources of contamination by
nitrate and related nitrogen compounds through pollution prevention. To assure
that public and private drinking water quality is maintained.
Ground water, surface water, and public and private drinking water supplies.
Contamination from nitrates and other nitrogen compounds.
Health risks associated with nitrates in the drinking water supply. Ecological risks
from eutrophication of surface water bodies from high nitrate levels, especially in
coastal areas.
The high priority actions include technical assistance, education, new regulations,
increased enforcement, and research.
The Nitrogen Action Plan identifies high priority activities for each office and the
USDA. Providing incentives for trading pollution prevention for treatment of
PWS.
EPA Programs should focus on reducing fertilizer use and better controlling
runoff and infiltration from livestock operations through increased implementation
of BMPs m high priority areas.
EPA Programs should focus on reducing fertilizer use and better controlling
runoff and infiltration from livestock operations.
The type of activity and its statutory basis determines whether it is voluntary.
Funding for State programs or activities may sometimes be determined by whether
the State includes specific components in its program.
Depends on the type of activity and its statutory basis. Possible consequences for
States that do not participate range from no penalty to possible loss of State grant
funding.
Depends on the type of activity and its statutory basis.
Presently, it is to early to tell how flexibility in required components will be
incorporated.
At a minimum States are encouraged to include specific components in their
programs.
Use EPA reference points and standards in a number of ways, depending upon
the base program of which activity is a part. Overall objective is to assure that
water quality does not fail minimum federal standards and guidelines. This will
often, if not always, involve beginning action well before the federal limits are
approached.
October 1992
Page 103
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Appendix A
(16) NITROGEN ACTION PLAN
(continued)
General Overview of Strategy
Current policy related
integration/coordination
activities:
Suggestions for future policy
integration/
coordination activities:
Coordinating policy objectives through workgroups with nitrogen-related
regulations and a joint USDA/EPA committee.
NAP should be fully incorporated into the Agriculture Pollution Prevention
Strategy. Additional high priority NAP activities should be undertaken, even if not
a part of the Agricultural Pollution Prevention Strategy.
Page 104
October 1992
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Appendix A
(16) NITROGEN ACTION PLAN
(continued)
Review and Approval Process for Program
Roles of EPA offices in HQ
and Regions:
Description of State agency
involvement:
Current program status on
federal level:
How are grant funds used:
Federal program guidance
documents and/or regulations:
Status of implementation on
the State level:
Program funding history:
Program funding sources:
Review/approval process-
Schedule:
Review/approval process-
Reviewer:
Review/approval process-
Review process:
Review/approval process--
Final determination:
Review/approval process--
EPA feedback:
Review/approval process:
Awards decision criteria:
Agency oversight and program
evaluation role:
Integration/coordination
activities m the current
review/approval process:
Suggestions for integration/
coordination activities m the
review/approval process of
Ag/Water programs:
HQ: OW sets priorities and assures that resources are available and that offices
are accountable for completing tasks. OGWDW, OWOW, OWEC, OTS, OPP,
ORD, OPPE implement NAP activities in their programs.
RO: Work with States to coordinate and implement program elements and to
provide technical assistance.
State surface water, ground water, drinking water and pesticide regulatory agencies
will have lead responsibility. These agencies are usually found in State
departments of environment, natural resources, health, and agriculture.
Integrated NAP activities have not yet begun. A number of EPA offices
actively developing NAP components.
are
Still in the development process.
Draft NAP. In addition, a list of recommended guidance documents and
regulations is being developed.
Individual State and local nitrogen activities are in nearly every stage of
development. However, integrated NAP activities have not yet begun.
FY '88 '89 '90 '91 '92
$ million — — — — .5
OPTS for FY '92.
'93
TBD
To be determined.
To be determined.
To be determined.
To be determined.
To be determined.
To be determined.
To be determined.
None currently.
EPA programs need to address NAP priorities in their workplans, budgets, and
products each year. The NAP provides coordination, but more active commitment
from the programs is necessary.
October 1992
Page 105
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Appendix B
Appendix B
Comparison Matrices
Appendix B contains three sets of comparison matrices for the sixteen EPA
agriculture and water programs and strategies affecting States. The first matrix compares
the general goals and approaches of the programs. The review and approval processes for
awarding EPA grants are compared in the second matrix. Finally, the third matrix offers a
comparison between the required components of the State programs.
October 1992 Page 107
-------
Appendix B
Contents of Appendix B
Page
Matrix 1: General Overview of Programs and Strategies Ill
Matrix 2: Review and Approval Process 121
Matrix 3: Components of State Programs 131
October 1992 Page 109
-------
Appendix B -- Matrix 1
Comparison Matrices
Matrix 1:
General Overview of Programs and Strategies
October 1992 page
-------
Appendix B -- Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
General Overview
Program Element:
1 Statutory
Authority
2. Program Goal
3 Waters Targeted.
4 Contamination
Sources.
5 State Role in
Setting Priorities.
6 Risks Addressed-
7 Priorities for
Achieving Goal
8 Programmatic
Priorities.
9 Priorities for
Addressing
Agriculture
Practices1
Program/Strategy
CSGWPP
• EPA policy
coordination across
many programs
• GW Protection
• Pollution
prevention
• Ground water
- currently used &
reasonably
expected sources
of dw,
- closely
hydrologically
connected to sw
• All sources of
contamination
• High
• Human health
• Ecological
• Financial and
technical assistance
to Slates for
assessing gw and
ranking sources
• Develop guidance
• Flesh out
incentives
• Foster integration
of EPA programs
• Outreach
• Support
development and
implementation of
CSGWPPs. which
address all
potential sources of
contamination
Wellhead
Protection
Program
• SDWA §1428
• GW Protection
• Pollution
prevention
• Ground water
-- gw sources of
public water
supplies
• All sources of
contamination
• High
• Human health
• Technical
assistance
• Public outreach
• Develop tracking
process
• Publicize success
• Additional
guidance
• Training
materials
• Not identified as
a priority in
FY'92
Pesticides SMP
« FIFRA
• GW Protection
• Pollution
prevention
• Ground water
- currently used &
reasonably
expected sources
ofdw,
- closely
hydrologically
connected to sw
• Pesticides, with a
focus on
agricultural
pesticides
• High
• Human health
• Ecological
• Financial and
technical assistance
to States for
developing SMPs
• Develop guidance
• Technical
assistance
• Provide grants for
Genenc SMPs
• Coordinate w/
CSGWPP
• Develop guidance
• Technical
assistance
• Provide grants for
Genenc SMPs
• Coordinate w/
CSGWPP
Class V UIC Program
• SDWA §1421-1426
• GW Protection
• Ground water
•- "underground
sources of
drinking water"
• Agriculture
drainage wells
• Moderate
• Huinan health
• Ecological
• Agriculture well
regulation development
• Implementation grants
• Special studies and
monitoring
October 1992
Page 113
-------
Appendix B -- Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
General Overview
Program Element:
10 Agnculture-
Related Programs
1 1 Mandatory or
Voluntary
Program
12 Result of Non-
Participation
13 Number of
Components
Required:
14 Degree of
Flexibility
15 Voluntary
Components:
16 Use of "Reference
Points"
Program/Strategy
CSGWPP
• Technical
assistance
• Rural water
pollution
• Research
• Voluntary
• Reduced grant
awards
• 6
. High
• No
• Yes
Wellhead
Protection
Program
• None presently
• Mandatory
• Loss of funding
• 7
. High
. Yes
• No
Pesticides SMP
• Technical
assistance on
assessment,
monitoring,
prevention,
response
• Assist ORD w/
research and data
• Voluntary
• Prohibition of the
use and sale of
cenam pesticides
in the State
• 12
• High
• No
• Yes
Class V UIC Program
• Demonstration research
projects
• Voluntary
• EPA region administers
program
. 7
• To be determined
. Yes
• To be determined
Page 114
October 1992
-------
Appendix B -- Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Program Element:
1 Statutory
Authority:
2 Program Goal:
3 Waters Targeted'
4. Contamination
Sources:
5 State Role in
Setting Pnonues
6 Risks Addressed.
7 Priorities for
Achieving Goal
8. Programmatic
Priorities'
9 Priorities for
Addressing
Agriculture
Practices
10 Agnculture-
related
Programs-
Nonpoint Source
Program
• CWA §319
• Pollution Prevention
and abatement
• Surface and ground
water
• But no generic type
of targeted waters
• State negotiates
waters targeted with
Regions
• Over 100 categories
of NPS pollution
• High
• Human health
• Ecological
• Address difficult
problems
• Innovative methods
• State priorities
• Technical assistance
• Public outreach
• Abatement
• Monitoring
• Agriculture
programs receive
the most funding
• Agriculture
programs receive
the most funding
• Many types of
activities
General Overview
Program/Strategy
Coastal Nonpoint
Source Program
. CZARA §6217
• Coastal Water
Protection
• Restoration
« Coastal waters
• Great Lakes
Agricultural runoff
Urban runoff
Silvicultural runoff
Hydromodification
Mannas
• Moderate
• Human health
• Ecological
• Focus on sources me
ntioned above
• Guidance
• Technical assistance
to Slates
• Agriculture is one of
5 major NPS
addressed by
program
• Best available techn
ologies
• Slates to develop Co
astal NPSP to
implement ag and
NPS measures
r
Public Water
Supply Program
• SDWA
• DW Protection
• Finished water for
delivery through
PWS systems
• All sources that
have MCLs
• Moderate
• Human health
• Implementation of
the microbiological,
phase II organic
and inorganic, and
lead contaminants
• Technical assistance
to States
• Enforcement
• Technical assistance
• Training PWSs
• Technical assistance
• Training PWSs for
compliance with
agncultural-
associated MCLs.
Near Coastal
Waters Program
• EPA strategic
planning
• Maintain and
enhance near
coastal water
quality
• Inland waters to the
head of the tide
• Territorial seas
• Great Lakes
• All sources of
pollution
• Moderate
• Human health
• Ecological
• Habitat and living
resources
• Regional decision
• Development of
guidance
• As incorporated in
each Regional
strategy
• Coordinate
technical assistance
activities
• Public outreach
• Data and
information
management
October 1992
Page 115
-------
Appendix B -- Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Genera] Overview
Program Element:
1 1 Mandatory or
Voluntary
Program
12. Result of Non-
Participauon.
13 Number of
Components
Required.
14 Degree of
Flexibility
15. Voluntary
Components
16 Use of
"Reference
Points"-
Nonpoint Source
Program
• Voluntary
• All States
participate
• Loss of funding
• Vanes from State to
State
• High
• Yes
• No
Program/Strategy
Coastal Nonpoint
Source Program
• Mandatory
• Loss of funding
• 10
• Moderate
• To be determined
. Yes
Public Water
Supply Program
• States are
encouraged to take
primacy
• EPA region
administers
program
• Loss of grant funds
• 5
• Low
« Yes
• Yes
Near Coastal
Waters Program
• Voluntary
• Loss of funding
• To be determined
• Moderate
• No
• Yes
Page 116
October 1992
-------
Appendix B -- Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
General Overview
Program Element:
1 Statutory
Authority
2. Program Goal-
3 Waters Targeted-
4. Contamination
Sources.
5 State Role m
Setting Priorities:
6. Risks Addressed
7 Priorities for
Achieving Goal
8. Programmatic
Priorities:
9 Priorities for
Addressing
Agriculture
Practices
Program/Strategy
National Estuary
Program
• CWA§320
• To ensure the
ecological integrity
of nationally
significant estuaries
• "Significant"
estuaries and bays
• All sources of
pollution
• Very high
• Human health
• Ecological
• Habitat and living
resources
• Vanes by estuary, as
determined by each
State and EPA
• Government
coordination
• Information transfer
• Public outreach
• Planning
• pollution abatement
and control program
• As outlined and
identified by each
individual program
Chesapeake Bay
Program
• CWA§117
• To restore and
enhance the living
resources of
Chesapeake Bay;
• Maintain water
quality
• Chesapeake Bay
and surrounding
watersheds
• All sources
• Atmospheric
deposition of
pollutants
• Agricultural runoff
. High
• Human health
• Ecological
• Habitat and living
resources
• Specified in the
1987 Chesapeake
Bay Agreement
• Installation of
BMPs
• Installation of
BMPs for
agriculture
State Wetlands
Protection Program
• CWA §104(b)(3)
• Development of
new State wetlands
protection programs
or enhancement of
existing State
programs
• Wetlands and
waters of U.S
• All sources of
contamination
• High
• Ecological
• State Wetland
Conservation Plans
• State 404 assump-
tion
• Watershed Protec-
tion Approach
Demo Projects
• State Wetlands
Conservation Plans
• Stale CWA §404
assumption
• Watershed
protection
demonstration
• Not identified as
priority
Clean Lakes
Program
• CWA §314
• Lake restoration
and protection
• Lake assessments
• Publicly owned
lakes that offer
recreational
opportunities
• All sources of
pollution
. High
• Ecological
• Habitat protection
• Financial
assistance
• Technical
assistance
• Financial
assistance
• Technical
assistance
• No specific
agriculture-related
activities
October 1992
Page 117
-------
Appendix B - Matrix 1
AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
General Overview
Program Element:
10. Agnculture-
related Programs:
11. Mandatory or
Voluntary
Program:
12. Result of Non-
Panicipation:
13. Number of
Components
Required for
Grants:
14. Degree of
Flexibility
15. Voluntary
Components:
16. Use of "Reference
Points":
Program/Strategy
National Estuary
Program
• Information transfer
• Voluntary
• Loss of funding
• 7 purposes outline in
CWA §320
• Moderate/High
• Yes
• Yes
Chesapeake Bay
Program
• Technical assistance
• Public outreach
• Financial assistance
to farmers
• Research and
modeling
• Reporting and data
management
• Voluntary
• 12 plus
• None
• Yes
• Yes
State Wetlands
Protection Program
• May be part of
State WCP or
watershed
protection
demonstration
• Voluntary
• Funding not
available
• Varies
• Moderate
• Yes
• No
Clean Lakes
Program
• Grants used to
implement
agricultural BMPs
in watersheds
• Reduce nutrients
and sediments to
lakes
• minimize
pesticides
contamination
• Mandatory
biennial reporting
• Other elements
voluntary
• Loss of funding
• Varies by type of
grant
. High
. Yes
• No
Page 118
October 1992
-------
Appendix B - Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
General Overview
Program Element:
1 Statutory
Authority
2 Program Goal.
3 Waters Targeted'
4 Contamination
Sources:
5 Slate Role in
Setting Priorities.
6 Risks Addressed.
7 Pnonties for
Achieving Goal:
8 Programmatic
Pnonties.
9 Pnonties for
Addressing
Agriculture
Practices
10 Agriculture-related
Programs'
NPDES Program
. CWA§402
• Feedlots addressed
in 40 CFR 122.23
• Surface Water
Protection
• Pollution
prevention
• Surface waters of
the U.S.
• Point sources
• Stormwater
• Moderate
• Human health
• Ecological
resources
• Control of point
sources impacting
water quality
• Major point
sources
• Tone pollutants
• Guidances
• Expand permits to
BMPs
• None
Program/Strategy
Clean Water Act
Section 106
Program
. CWA§106
• To provide grants
for surface water
quality
management
programs
• Surface water
• All sources
• Moderate
• Human Health
• Ecological
resources
• Establishment of
tone water quality
standards
• Issuing permits
• Compliance/
enforcement
• Monitoring
programs
• Vanes by Region
and State
• Not a primary
source for
agriculture-related
activities
• Supplements §319
funding for some
agriculture-related
activities
Agriculture
Pollution Prevention
Strategy
• Request by
legislative
committee
• Protect health and
ecosystems while
assuring economic
viability
• All waters
• All sources
• High for geographic
priorities
• Health
• Ecological
resources
• Habitat
• Based on Science
Advisory Board
report
• All EPA and USDA
agriculture-related
programs
• Emphasis on
measurable results
• Some national,
some by watershed/
area
• Integrates with all
EPA and USDA
agriculture-related
programs
Nitrogen Action
Plan
• EPA Policy
coordination across
many programs
• SW & GW
Protection
• Pollution
Prevention
• Public and pnvate
drinking water
• Surface waters,
especially coastal
• Fertilizer
• Livestock
• Septic systems
• POTWs
• To be determined
• Human Health
• Ecological
resources
• Technical
Assistance
• Education
• Regulations
• Enforcement
• Research
• Varies for each
office
• Vanes for each
office
• Vanes for each
office
October 1992
Page 119
-------
Appendix B - Matrix 1
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
General Overview
Program Element:
11. Mandatory or
Voluntary
Program:
12. Result of Non-
Partiupation:
13 Number of
Components
Required for
Grants:
14. Degree of
Flexibility:
15. Voluntary
Components:
16 Use of "Reference
Points".
Program/Strategy
NPDES Program
• Voluntary
assumption by
States
• Permitting
program is
mandatory
• No action
• SeeCWA§106
• Moderate
• Yes for program
• No for grants
• Yes for program
• No for grants
Clean Water Act
Section 106
Program
• Voluntary
• Sanctions
• 15
• High
• Yes
• Yes
Agriculture
Pollution Prevention
Strategy
• Voluntary where
goals are met
• Loss of funding
• Selective regulatory
response
• High
. Yes
• Yes
Nitrogen Action
Plan
• Vanes across
programs
• Varies across
programs
• Vanes across
programs
• To be determined
• To be determined
• Varies across
programs
Page 120
October 1992
-------
Appendix B -- Matrix 2
Comparison Matrices
Matrix 2:
Review and Approval Process
October 1992 Page 121
-------
Appendix B -- Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
1 Lead EPA Office
2 EPA Regional
Involvement:
3 State Agencies
Involved
4 Current Program
Status on Federal
Level.
5 How are Grant
Funds Used
6 Program Guidance
7 Regulations'
8 Status of
Implementation at
State Level.
9 Years Funded.
10 Average Funding-
1 1. State Matching
Funds
Program/Strategy
CSGWPP
• Ground Water
Policy
Committee/OGWD
W/GWPD
. High
• To be determined
• National guidance
in 1992
• Program
development
• Complementary
programs
• FY'92CWA§106
grant guidance
• Supplemental
Guidance Tor GW
Protection
• Additional guidance
being developed
• None
• States & EPA are
defining a
"comprehensive"
program
• 5 years
• $ 9 million
• None
Wellhead Protection
Program
• OGWDW/GWPD
• Moderate
• Vanes State-by-State,
usually Health
• Assisting Stales
implement programs
• Financial assistance
for WHPP
development
• Demonstration
projects
• "Guidance for
Applicant for State
WHPP Assistance
Funds under SDWA"
• None
• 20 approved State
programs
• 30 under
development
• N/A
• Funded under §106
grants
• None
Pesticides SMP
• OPP
• High
• Coordination w/
Ag, Health, Env,
Water is required
• Initial stage of
implementation
• Planning stages of
SMPs
• The Pesticide and
Ground Water
Strategy
• SMP Guidance
Document, and
Appendices A &
B
• None
• Initial
development
• 49 States
developing
Generic SMPs
• 3 years
• $5 million
• 15% Stale match
Class V UIC
Program
. OGWDW/GWPD
• High
• Vanes State-by-
state
• Advanced phase
of implementation
• Implementation
• UIC program
guidance #42
. 40CFRPan50
• 35 States have
primacy
• 5 years
• $10.7 million
• 25% State match
October 1992
Page 123
-------
Appendix B - Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
12 Review/Approval
Process Schedule
13 Reviewer
14 Review Process
15. Final Determination-
16 EPA Feedback:
17 Awards Decision
Criteria'
18 EPA Oversight and
Program Evaluation
Program/Strategy
CSGWPP
• To be determined
State-by-State
• To be determined
• To be determined
• To be determined
• To be determined
• Based on progress
toward CSGWPP
• To be determined
Wellhead Protection
Program
• WHPP submittal
required by 6/19/89;
but submiltals are
still forthcoming
• Regions
• HQ must concur
• Nine month process
• States allowed to
resubmit
• Written as well as
oral feedback
• Vanes
• None at this time
Pesticides SMP
• To be determined
• Regional Review
Teams
• Each SMP will be
evaluated for
adequacy using
guidance and
appendices
• Regional
determination
• Regions provide
feedback
• SMP updating
process
• Formula based on
GW susceptibility
and pesticide use
• Regional
oversight to
monitor SMP
effectiveness and
grants
Class V UIC
Program
• Vanes by State
• Regions review
• HQs must concur
• Vanes by Stale
program
• Undecided
• N/A
• Formula
• States submit
progress reports
• Periodic reviews
Page 124
October 1992
-------
Appendix B -- Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
1 Lead EPA Office:
2 EPA Regional
Involvement'
3 State Agencies
Involved:
4 Current Program
Status on Federal
Level:
5 How are Grant
Funds Used
6 Program Guidance.
7 Regulations1
8 Status of
Implementation at
State Level.
9 Years Funded
10. Average Funding:
11 Slate Matching
Funds1
12 Review/Approval
Process Schedule.
13 Reviewer
14 Review Process-
Nonpoint Source
Program
• OWOW/AWPD
• High
• Vanes State-by-
Siate
• Initial phase of
implementation
• Assisting States
• Implementation of
State NPS
Programs
• OW guidance of
2/15/91
• None
• All States have
approved NPS
Assessments and
Management
Programs
• 3 years
• $47 million
• 40% Stale match
• Each Year, States
apply by 3/30
• Regions reply by
5/30
• Grants awarded by
8/15
• Regions
• Vanes by Region
Program/Strategy
Coastal Nonpoint
Source Program
• OWOW/AWPD
• High
• Vanes State-by-State
• Initial program
development stage
• Program
Development
• Proposed
management
measures and
program
implementation
guidance under
development
• None
• No Slate programs
have been approved
• N/A
• No funds to date
• 50% State match
• To be determined
• EPAandNOAA
• To be determined
Public Water
Supply Program
• OGWDW
• Moderate
• Varies State-by-
state, usually
Health
• Advanced phase of
implementation
• Implementation
• Available for
implementation of
specific rules
• 40 CFR 141-143
• 55 States and
territories have
been granted
primacy
• 15+ years
• $39 million
• 25% Stale match
• States apply in the
spring
• EPA approval in
fourth fiscal
quarter
• Regions
• Regions maintain
close coordination
with States
Near Coastal Water
Program
. OWOW/OCPD
• High
• Vanes Staie-by-
State
• Development phase
• Development and
implementation of
demonstration
projects
• Under development
• None
• 5 Regional
strategies developed
• 3 Regional
strategies being
developed
• 2 years
• $5 million
• 5% Stale match
• Vanes
• EPA Headquarters
• Vanes by Region
and by State
October 1992
Page 125
-------
Appendix B - Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
15. Final
Determination
16. EPA Feedback-
17 Awards Decision
Criteria
If) EPA Oversight and
Program Evaluation:
Program/Strategy
Nonpoint Source
Program
• Regional decision
• Written and oral
comments by
Region
• Negotiation
session
• Formula
• Regional
responsibility
Coastal Nonpoint
Source Program
• To be determined
• To be determined
• To be determined
• EPA and NOAA
Public Water
Supply Program
• Regional
determination
• Regions perform
oversight
• Formula
• Regional
responsibility
Near Coastal Water
Program
• Criteria established
by NCW Guidance
• To be determined
• To be determined
• Regions review the
annual workplans
submitted by Stales
• HQ role TBD
Page 126
October 1992
-------
Appendix B -- Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
1 Lead EPA Office-
2. EPA Regional
Involvement-
3 State Agencies
Involved
4 Current Program
Status on Federal
Level-
5 How are Grant Funds
Used.
6. Program Guidance
7 Regulations-
8 Status of
Implementation at
State Level.
9 Years Funded.
10 Average Funding:
1 1 Stale Matching Funds
12 Review/Approval
Process Schedule.
13 Reviewer.
Program/Strategy
National Estuary
Program
. OWOW/OCPD
• High
• Vanes State-by-
State
• Program is in the
planning process
• Financial
assistance
• Technical
assistance
• Development of
CCMPs
• Several guidances
• 40 CFR 35
Subpart (p)
• CWA §320
• CCMP
development and
implementation
phase
• 4 years
• $14 million
• 25% State match
• No schedule
provided
• Regional Office
and OCPD
Chesapeake Bay
Program
• Region III
• High
• Vanes State-by-
State
• Implementation
• Implementation of
priority
management
programs in PA,
MD, DC, and VA
• Specific grant
guidance is
developed each
year for each State
• CBP regulation
CWA §117(b)
• Fully implemented
• 4 years
• $135 million
• 50% Slate match
• Vanes by grant
program
• Vanes by grant
program
State Wetlands
Grant Program
. OWOW/WD
• High
• Vanes Stale-by-
State
• Development stage-
• Development of or
enhancement of
State wetlands
protection
programs
• Guidance
developed annually
• None
• 40 States have
received grants
• 3 years
• $4 8 million
• 25% State match
• Grant applications
due to regions by
2/3
• Regional office
selects
• HQ reviews
Clean Lakes
Program
• OWOW/AWPD
• High
• State water quality
agency is usually
lead agency
• Program fully
operational
• Technical
assistance
• Financial
assistance
• State-wide lake
assessment
• Clean Lakes
Program Guidance
• 40 CFR 35
Subpart H
• 44 States
authorized
• 1 territory
authorized
• 15 Indian tnbes
authorized
• Since 1974
• $9 0 million
• 30% Stale match
States apply 1st or
2nd quarter; EPA
response in 3rd and
4th
• Regions and HQ
Clean Lakes staff
• Technical peer
review
October 1992
Page 127
-------
Appendix B -- Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval
Process Element:
14 Review Process.
IS Final Determination:
16 EPA Feedback:
17. Awards Decision
Criteria.
18 EPA Oversight and
Program Evaluation
Review and Approval Processes
Program/Strategy
National Estuary
Program
• Annual workplans
reviewed for
consistency
• Regions and
OCPD
-
-
• Workplans
reviewed annually
by Regions and
HQ.
Chesapeake Bay
Program
• Review is to assure
across-the-board
program integration
• Vanes by grant
program
• Vanes by grant
program
• Vanes by grant
program
• Stales submit
quarterly tracking
reports.
State Wetlands
Grant Program
• Vanes by region
• Regional decision
• Regional staff
works with States
• Competitive
process
• Regions evaluate &
monitor projects
Clean Lakes
Program
• Based on their
compliance with
CLP regs/guidance
• HQs provides
final review/
approval
• Regional staff
works with States
• Clean lakes
regulations
• Regular contact
with State
• Project site visits
• Status reports
Page 128
October 1992
-------
Appendix B - Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
1 Lead EPA Office
2 EPA Regional
Involvement-
3 State Agencies
Involved
4 Current Program
Status on Federal
Level
5 How are Grant
Funds Used
6 Program Guidance.
7. Regulations
8 Status of
Implementation at
State Level-
9 Years Funded.
10 Average Funding-
1 1 Slate Matching
Funds
12 Review/Approval
Process Schedule.
Program/Strategy
NPDES Program
• OWEC and OST
(also OPPE for
feedlots)
. High
• Vanes State-by-
State
• Implementation
• Technical
assistance
• Financial
assistance
• Many guidances
• Model general
permit for
feedlots
• See CWA §106
for grants
. 40 CFR 121-125,
129, 136 & 400
series
• 39 approved
State or territory
NPDES programs
• See CWA §106
• See CWA §106
. See CWA §106
• EPA responds in
90 days after
submittal
• See CWA §106
Clean Water Act
Section 106
Program
• OWEC
• High
• Typically State
water quality
agency is lead
• Ongoing program
since 1972
• Program support
• Administrative
support
• Water Quality
Planning and
Management Final
Rule
• 40 CFR Parts 130
& 135, Section 106
• All Slates receive
grants eacb year
• Since 1972
• Averages $75
million over the
last five years
• Level of Effort
contribution
averages 1/3 to 2/3
of total
• Annual scheduled
review of grants
Agriculture
Pollution
Prevention Strategy
• OPPE
. High
• Pollution
prevention serves
integrating function
at federal level
• Initial development
phase
• To be determined
• No guidance yet
• None yet
• None yet
• None yet
• None yet
Nitrogen Action
Plan
• OGWDW
• Moderate
• Vanes State-by-
State
• Integrated NAP
activities have not
yet begun
• To be determined
• Draft NAP is
under review
• Additional
guidance and
regulations being
developed
• Being developed
• Integrated NAP
activities have not
yet begun
• 2 year
• $0 25 million
• None yet
• To be determined
October 1992
Page 129
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Appendix B - Matrix 2
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Review and Approval Processes
Review and Approval
Process Element:
13. Reviewer
14. Review Process:
IS. Final Determination:
16. EPA Feedback:
17. Awards Decision
Criteria:
18. EPA Oversight and
Program Evaluation:
Program/Strategy
NPDES Program
• Regional
Administrator
• See CWA §106
• States submit
program; EPA
responds in 90
days
• See CWA §106
• Regional
Administrator
• See CWA §106
• Feedback from
RA if program is
disapproved
• See CWA §106
• Requirements of
CWA
• See CWA §106
• Regions review
States
• OWEC reviews
Regions
Clean Water Act
Section 106
Program
• Regional Water
Management
Divisions
• Varies from
Region to Region
• Regional decision
• Written evaluations
and coordination
• Formula
• Written evaluations
conducted by
Regional Offices
Agriculture
Pollution
Prevention Strategy
"
—
™
Nitrogen Action
Plan
• To be determined
• To be determined
• To be determined
• To be determined
• To be determined
• To be determined
Page 130
October 1992
-------
Appendix B - Matrix 3
Comparison Matrices
Matrix 3:
Components of State Programs
October 1992 Page 131
-------
Appendix B - Matrix 3
Matrix 3, Components of State Programs, provides a comparison summary of the
program requirements for each of the 16 programs and strategies. The first column in the
matrix (Program Requirements) lists each of the 12 program requirements that are found
in one or more of the 16 programs and strategies. The remaining columns represent the 16
programs and strategies identified by the Ag/Water Integration Project. The information in
the second column indicates the strategic activity in the CSGWPP program that corresponds
to the program requirement. The information in the latter 15 columns indicates if the
program requirements are components of a particular program or strategy - a check mark
(/) indicates that the program requirement is part of the program or strategy, a double dash
(--) indicates the program requirement is not part of the strategy, and TBD indicates that
the program requirement has yet to be determined. For example, Goal, Legal Authorities,
Public Awareness and Participation, Records and Reporting, Resources, Enforcement
Mechanisms, and Response and Remediation are program requirements for the Class V
UIC Program. In addition, the Class V UIC Program does not require States to establish
a Basis for Planning and Assessment, and the program requirements for Roles, Prevention
Actions, Monitoring, and Information Dissemination have yet to be determined.
The program and strategy abbreviations used in the matrix are listed in the key below.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
CSGWPP — Comprehensive Ground Water Protection Programs
WHP — Wellhead Protection Program
PSMP — Pesticides State Management Plan Program
Class V UIC — Class V UIC Program
NPS — Nonpoint Source Program
CNPS — Coastal Nonpoint Source Program
PWS — Public Water Supply Program
NCW — Near Coastal Waters Program
NEP — National Estuary Program
CBP — Chesapeake Bay Program
SWPP — State Wetlands Protection Program
CLP — Clean Lakes Program
NPDES — NPDES - Feedlot Program
CWA §106 — Clean Water Act Section 106 Program
APPS — Agriculture Pollution Prevention Strategy
NAP — Nitrate Action Plan
October 1992
Page 133
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Appendix B — Matrix 3
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
Components of State Programs
Program
Requirements
1 Goal
2. Roles
3 Legal
Authorities
4 Prevention
Actions
5 Public
Awareness and
Participation
6. Records and
Reporting
7 Resources
8 Monitoring
9 Enforcement
Mechanisms
10 Basis for
Planning and
Assessment
1 1 Information
Dissemination
12. Response and
Remediation
Program/Strategy
Corresponding CSGWPP
Strategic Activities (SA)
SA-1 Establish goal
SA-3: Define roles,
authorities,
responsibilities,
resources, and
coordinating
mechanisms
SA-3
SA-4. Implement necessary
activities
SA-6: Public participation
SA-5- Information, collection
and management
SA-2. Establish priorities,
based on characteriza-
tion of the resource,
identification of
sources of
contamination, and
programmatic needs
SA-S
SA-4
SA-2
SA-6
SA-4
WHP
•J
J
J
V
/
V
V
--
PWS
--
J
-
—
>/
y
^
,/
-
--
--
NCW
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD = To Be Determined
October 1992
Page 135
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Appendix B - Matrix 3
EPA AGRICULTURE AND WATER PROGRAMS/STRATEGIES:
(continued)
Components of State Programs
Program
Requirements
1 Ooal
2. Roles
3 Legal
Authorities
4 Prevention
Actions
5 Public
Awareness and
Participation
6 Records and
Reporting
7 Resources
8. Monitoring
9 Enforcement
Mechanisms
10 Basis for
Planning and
Assessment
1 1 Information
Dissemination
12. Response and
Remediation
NEP
•J
y
,/
V
,/
--
^
V
^
V
N/
"
CBP
«/
/
,/
/
/
y
y
y
y
y
y
,/
Program/Strategy
SWPP
--
--
--
--
—
-
-
--
•-
"
-
--
NPDES
-•
-
-•
-
-•
--
--
-
--
—
-
-
CLP
,/
^
--
^
>/
v'
^
y
--
J
/
N/
^
V/
^
^
,/
-
APPS
•J
-
%/
^
-•
V
^
V
^
«/
^
-
NAP
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
Page 136
October 1992
-------
Appendix C
Appendix C
Results from the Water/Pesticides and
Toxics Regional Coordination Survey
October 1992 Page 137
-------
Appendix C
unneo Siaies Region 10
Environmental Protection 1200 &xtn Avenue
Agency Seanie WA98101
Reply to
Attention of: AT-081
MEMORANDUM
SUBJECT: Results from the Water/Pesticides and Toxics Regional
Coordination Survey
FROM: Gary O'Neal, Director
Air and Toxics Division
Harry Seraydarian, Director
Water Management Division
TO: Vic Kimm, Deputy Assistant Administrator
Office of Pesticides and Toxics Substances
Martha Prothro, Deputy Assistant Administrator
Office of Water
As a follow-up from the Joint Water/Pesticides/Toxics Meeting, Region 9 and
10 agreed to poll the other Regions on existing regional coordination on agricultural
issues. Attached is the consolidated response from all the Regions. Described below
are highlights.
General Observations
Since this survey focused on agriculture, most regional responses centered on
relationships between their pesticides and water programs. The Regions rarely
discussed coordination with their toxics programs.
Much regional effort with respect to coordination is focused in the area of
groundwater. Regions are just beginning coordination efforts on surface water
concerns.
Groups that Facilitate Cross Prooram Coordination
All regions had formally established multi-program ground water coordination
groups. Most of these groups started in the mid-to-late 1980s and included Branch
Chiefs and/or Division Directors representatives. Some groups included Division
Director representatives.
October 1992 Page 139
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Appendix C
The second most frequently mentioned category for regional task
forces/groups (4 Regions) is non-point source pollution. Other groups mentioned
included:
* Specific Project or Issue Workgroups/Committees such as National Pesticides
Survey, pesticides state management plans, agricultural policy, GIS technical
advisory committee, Farm Bill, data management, and pesticides/nitrates;
* Specific Geographic Initiatives, such as the Merrimack Initiative and Plane River
Enforcement Project;
* Risk Reduction Workgroups/Committees, such as Risk Coordination Committee,
Regional Comparative Risk Project, and Risk Reduction Opportunities Teams..
FY92 Integrated State Program Guidance
Coordination within Regions on state program guidance is most frequently used
in the ground water area. Specific examples are listed below.
* Region 9 developed joint FY 92 grant guidance for FIFRA and CWA Section
106;
* Region 5 developed FY92 joint grant guidance for the development of generic
state pesticides and groundwater management plans;
* Region 4 developed joint regional grants guidance for FY91 ground water and/
pesticides grant activities, with that guidance setting the trend for future years;
* Region 8's FY89 uniform guidance for ground water protection set the direction
for future years;
* Region 1 coordinated within the Region when developing regional guidance
document on the contents of a Ground Water Management Plan;
* Region 7 coordinated on grants with respect to groundwater management and
protection;
* Regions 3, 5, 6,10 coordinated reviews during the grant guidance development
specifically through providing drafts for each other's program to review, and
Region 2 reviewed the programs to assure that the objectives were consistent;
and
* Region 9 established a workgroup to assure their non-point source program
guidance and grant funds address cross-program and cross-media concerns.
Regional Actions to Promote State Coordination
The most frequent action that Regions took to promote coordination between
water and pesticide programs at the state level is requiring state coordination in
various program workplans for ground water, pesticides, non-point source.
Specifically, Regions would:
* inform the states that the Region expected the state programs to coordinate;
* work with states to identify attendance of multi-media meetings for developing
State Management Plans;
* require the development of cross program infrastructures to support Ground
Water Strategy development;
* require the State to identify formal process by which the State would use to
coordinate among its programs;
Page 140 October 1992
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Appendix C
* require within state coordination in the grants guidance;
* make funding contingent upon development of a coordinated program plan;
* allow the Lead State Agency to provide pass through funds to appropriate
agencies; and
* require the creation of coordinating committees.
Other activities included:
* stating the expectation that states would coordinate;
* funding special projects which required state coordination;
* requiring use of CWA Section 106 monies to be used on cross program issues;
developing joint grants guidance;
* conducting state/EPA meetings to promote working relationships and enhance
coordination;
* funding non-point source demonstration projects;
* conducting joint grant negotiations and evaluations; and
* setting an example for the states by demonstrating effective coordination within
EPA (both the Regions and HQs).
Regional Rankings on Coordination
The strongest areas for coordination among the regional programs is in the
groundwater programs and the state pesticide management plans. The area which
needs the most improvement is coordination on non-point source programs.
Areas which present opportunities for coordination include Special Projects,
Joint Enforcement Actions, Wetlands Protection, Pesticide Enforcement Actions, Water
Quality Risk Study, Episodic Issues, Certification of Applicators, Plane River
Enforcement Project, Sampling Programs (Heptachlor in fish, well sampling, etc.).
Barriers Which Inhibit Coordination
Barriers inhibiting coordination include:
limitations based on state mandates;
differing grant awards cycles and restrictions on funding;
lack of resources;
differing program goals and priorities;
slowness in OMB releasing the Pesticides and Ground Water Strategy;
lack of integration or coordination at HQ level;
late release of necessary guidance;
lack of formal or formal coordination mechanisms; and
lack of information or commitment.
What Worked
Actions which enhanced coordination within the Regions included:
coordinated development of regional guidance for pesticides state management
plans;
establishment of workgroups or committees such as regional ground water
policy committees, water quality or atrazine, or cross agency committees such
October 1992 page 141
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Appendix C
as the USGS National Water Quality Assessment Liaison Committee;
* use of multi-program approach to pilot projects on pesticides in ground water;
* development of lAGs with other agencies such as with USGS to develop
monitoring strategies and evaluation methods to assess ground water
vulnerability to pesticides contamination;
* development of MOUs with other programs within a region;
* development of joint program guidance;
* use of a coordinated approach to specific issues such as monitoring use of
aquatic biocides;
* conducting state directors' meetings; and
* maintaining open lines of communications at all levels with other programs
within the Region.
Recommendations for Improving Coordination
Regional recommendations for enhancing coordination included:
* coordinated responses to information requests;
* formalized coordination;
* integration of national strategies at HQ level;
* development of guidance on use of coordination for handling potential water
pollution at past pesticides spill areas;
•* allotment of adequate resources; and
* EPA's (both HQ and the Regions) presentation of united front to its states.
As can be seen by the responses, coordination within the Regions vary from
Region to Region vary, from program to program. We hope that the information is
useful to you in the Water/Agriculture Integration Project. If you or your staff have any
questions, please call Jayne Carlin at FTS 399-0890 or Audrey Shiieikis at FTS 484-
1866.
Attachment
cc: Regional Pesticides and Toxics Division Directors and Branch Chiefs
Regional Pesticides Section Chiefs
OPP: Steve Johnson, Kathy Taylor, Cathy Kronopulus
Regional Water Division Directors
Page 142 October 1992
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Appendix C
RESULTS FROM WATER/PESTICIDES AND TOXICS REGIONAL COORDINATION SURVE
1. What groups, task forces, etc., have been formally established within your
Region that facilitate cross-program coordination between water and
pesticides and toxics programs? What level of management is Involved?
REGION 1
National Pesticides Survey Task Force: This task force, composed of senior staff from Pesticides and
Toxics Substances Branch. Water Supply and Ground Water Management Branch coordinates on tasks
related to the National Pesticides Survey.
Non-Point Source Workgroup: This workgroup, composed of senior staff from the Waiter Quality Branch,
Pesticides and Toxics Substances Branch, Water Supply and Ground Water Management Branch.
reviews the Non-Point Source Strategy.
Farm BUI Workgroup: This workgroup, composed of senior staff from the Water Quality Branch.
Pesticides and Toxics Substances Branch, Water Supply and Ground Water Management Branch, is an
advisor to Workgroup.
Ground Water Policy Committee: This committee, composed of Branch Chiefs and/or Section Chiefs
from the Water Quality Branch, Pesticides and Toxics Substances Branch. Water Supply and Ground
Water Management Branch, advises management.
Memmack Initiative- Represented in this geographic initiative are section chiefs and senior staff from
Pesticides and Toxics Substances Branch, Water Supply, and Ground Water Management Branch, and
Water Quality Branch.
Chesoroeott Initiative: Represented in this geographic initiative are section chiefs and senior staff from'
Pesticides and Toxics Substances Branch, Water Supply and Ground Water Management Branch.
Data Management Workgroup: A senior staff member from the Pesticides and Toxics Substances
Branch advises the Ground Water Policy Committee.
REGIONS
The mechanisms which have been formally established to facDitate cross program coordination include:
Ground Water Steering Committee involving the Division Directors.
Protocol for cooperation between the Pesticides and Water Programs which was signed by the Branch
Chiefs.
Meetings between the Pesticides and Water Program Sections as needed, but at a minimum on a
quarterly basis.
Telephone communication between Pesticides and Water Program staff on a monthly basis to discuss
routine status. Communication on a more frequent basis concerning Issues.
REGION 3
Total Quality Improvement Workgroup: In November 1990, a regional Total Quality Improvement
Workgroup was established to improve coordination between project officers of all programs which
affect ground water and to integrate the objectives of EPA's newly released Comprehensive Ground
Water Protection Task Force Report into these EPA programs. The workgroup is chaired by the Ground
Water Protection Section Chief. Progress achieved to date includes: Identification of barriers to
achieving coordination and agreement on key times in the grant cycle when project officers should meet.
In addition, suggested grant guidance language was circulated to the different programs to help ensure
parallel coordination would take place with State counterparts. Because of the establishment of this
October 1992 Page 143
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Appendix C
workgroup, the Region is beginning to conduct a more comprehensive review across the agency of all
state workplans. outputs and progress reports that affect groundwater. including the pesticide program
NPS Task Force: Discussions between the Non-point Source (NPS) coordinator and staff have been
taking place regarding the establishment of a formal regional NPS Task Force.
Ground Water Steering Committee: The Region also has a Ground Water Steering Committee consisting
of the Deputy Regional Administrator, the Assistant Regional Administrator for Policy & Management and
Division Directors for the Water Management. Hazardous Waste Management, Environmental Services,
and Air, Radiation & Toxics Divisions. The senior management level group addresses development of a
comprehensive Regional cross-program plan for supporting the Agency's Ground Water Protection
Strategy and the recommendations of the Deputy Administrator's Ground Water Task Force. The FY91
Ground Water Protection Workplan for the Region was finalized on October 10.1990.
REGION 4
Ground-Water Coordinating Committee: At the time the Ground-Water Protection Branch (GWPB) was
established in 1985, a Ground-Water Coordinating Committee was organized. The committee was to
provide input into the development of the GWPB and was composed of representatives from all affected
programs. After the reorganization was completed, the committee was dissolved. The GWPB was then
charged with the responsibility to facilitate cross-program coordination of ground-water issues with other
programs.
Regional Agricultural Policy Committee: In FY 90, the Regional Administrator formed the Regional Ag
Policy Committee which includes branch and section chief representation from both the Water Division
and the Air. Pesticides and Toxics Substances Division. A major emphasis is improved relations and
program coordination among environmental and agricultural agencies and groups within the states. This
committee also targets environmental/agricultural issues to be addressed across program lines and with
the USDA agencies. The committee is chaired by the Chief of the Ground-Water Technology and
Management Section.
State Pesticide Management Plans: Although a group or task force has not been formally established.
the Ground-Water and Pesticides Programs are coordinating in the funding of state activities in support
of State Pesticide Management Plans (SPMPS). Through the personal involvement of Branch and
Section supervisors, the respective state programs are coordinating their efforts in support of State
Pesticide Management Plans.
REGIONS
Regional Ground Water Coordinating Committee: The main function of this committee is to coordinate
ground water activities in the Region, and includes representatives from the ground water and pesticides
and toxics programs.This committee, created in 1984, is composed of the Region's Division Directors
and Deputy Regional Administrator, and staff level Technical Subcommittee.
Staff Liaisons: The Ground Water Protection Branch has one staff person designated as the Branch's
Pesticide Liaison. The Pesticides Section also has one staff person designated as a Ground Water
Liaison. These liaison positions coordinate for their respective programs all ground water and pesticide
activities and work closely together in reviewing ground water and pesticide related documents.
RE&ON6
All levels of the Region 6 management team are involved in the cross-program coordination of
water and pesticides and toxics issues.
Division Directors Ground Water Steering Committee: Senior management is involved in cross program
coordination through the Division Directors Ground Water Steering Committee which is an ad hoc
committee that established regional ground water policy and to provide a mechanism for coordination
and inter-divisional issue resolution. Committee membership is composed of each Region 6 Division
Director, the Deputy Regional Administrator and is chaired by the Regional Administrator.
Pa8e 144 October 1992
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Appendix C
Regional Branch Chiefs' Ground Water Coordination Committee: This committee serves the purpose of
providing a forum for the identification and discussion of ground water issues and the free exchange of
program, technical and training information. Branch chiefs with program responsibilities that affect
ground water are members of the committee.
Ground Water /Pesticides/Agricultural Chemicals Coordination Committee: Staff level coordination is
achieved through the Ground Water/Pesticides/Agncultural Chemicals Coordination Committee which is
composed of designated staff members from each program that deals with pesticides or agricultural
chemicals in ground water. The committee is charged with the responsibility of coordinating ground
water, pesticides and agricultural chemical related programs in Region 6 at the staff level.
Ground Water /Pesticides/Agricultural Chemicals Coordination Protocol: The need for cross-program
coordination of water and pesticides and toxics programs has resulted in Region 6 developing the
Ground Water/Pesticides/Agricultural Chemicals Coordination Protocol document. The document
defines the roles and responsibilities of the various program offices in Region 6 and identifies the
appropriate staff members as contacts for the different programs.
Regional Nonpoint Source Task Force: Water and Pesticides program personnel have been actively
involved in the Regional Nonpoint Source Task Force. This task force reviewed grant proposals
submitted by the Region's States for dean Water Act Section 3l9(h) gram funds. The National Estuary
Program and Gulf of Mexico Program also have established similar work groups to facilitate cross-
program coordination within the Region.
The Region 6 Nonpoint Source Task Force was established to aid in the review and comment on the FY
91 319 grant applications and workplans. The reviews and comments were gathered from the pesticides
technical staff so as to facilitate the award to the most deserving projects. The level of management
involved was as follows* Division Directors were informed and participated with interagency memos.
Branch Chiefs, Section Chiefs and Technical Staff participated in the task force meetings.
Risk Coordination Committee: Chaired by the regional Public Water Supply Program from 1986 to 1989.
this committee served as a focus for infusion of risk concepts into Regional program activities. The
Committee accomplished this through monthly meetings in which various programs discussed how risk
concepts were handled in the programs, the maintenance of a 'risk' shelf in the library to provide a
central point for risk information materials, and principally through the Initiation of "Risk Assessment and
Decision Making Workshops.* About ten of these courses were presented and about 350 persons were
trained. All programs contributed lecturers and facilitators. These courses served to train professionals
from all Divisions. This Committee was formed by the Regional Administrator and received the support
of all Division Directors.
Regional Comparative Risk Prefect Human Health and Ecological Risk Committees: These committees
were formed to coordinate responses concerning the relative risk of 22 problem/program areas.
Committees were chaired by Section Chiefs, and other committee members were staff. Feedback on
approaches and recommendations on the process were provided by upper management. A follow-up
study is being conducted this year specifically designed to better define risk from pesticides on water
quality. This required, and wDI continue to require over the next two years, coordination between Water
Quality Management and Pesticide Branches.
National Pesticide Survey Regional Coordination Committee: This committee was established to facilitate
the Regional implementation of the National Pesticide Survey. The Committee members represented
water quality, water supply, ground water and the pesticide programs. One function was to coordinate
sample collection activities of Regional and State Pesticide and water program personnel. Laboratory
results were distributed to the States through the Regional Committee. This activity may be regarded as
the first in what has become a series of coordinated water/pesticides and toxics activities.
Soil Conservation Service Staff Member The Region 6 has a SoB Conservation Service staff member on
assignment to the Air, Pesticides and Toxics Division who acts as a liaison between the pesticides and
water programs.
October 1992 Page 145
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Appendix C
REGION 7
Deputy Division Director's Council: This council addresses strategic planning, multi-media enforcement.
33/50, etc.
Plane River Enforcement Project: A cross divisional project with the State of Nebraska to develop and
implement procedures with which the Plane River and its ecosystems can be protected and enhanced
Risk Reduction Opportunities (RR01 Teams: The Pesticides and Nitrates Workgroup is one of three
teams in Region 7 that is developing a detailed multi-year plan for specific multi-organizational, cross-
media activities. The Pesticides and Nitrates Workgroup has developed several project ideas which are
intended to produce measurable reductions In the risks posed by pesticides and nitrates to human
health and the environment in the Region. This group includes direct involvement from staff in both
Water and Air/Toxics/Pesticides Divisions, in addition to other federal and state agencies.
Water Quality Coordination Committee: This team was Initially formed in 1990 to:
1) familiarize and educate Division staff on the authorities, goals and activities of water and
pesticides;
2) share information pertinent to the Water Division and the Air and Toxics Division, water and
pesticides programs;
3) coordinate state grant, regulatory and enforcement activities related to pesticides in groundwater
and surface water.
4) assist the states in development of State Management Plans. The finalization of Pesticides and
Groundwater Strategy and the State Management Plan Guidance will enhance the workgroups
ability to provide direction to the states. It will also provide the foundation necessary for the
states to proceed more confidently and enthusiastically while developing their individual State
Management Plans.
The Water Quality Coordination Committee last met in July 1991 to review FIFRA groundwater grant
proposals from the state and to rank them on the basis of project proposals. The group includes
members from both the Water Management Division and the Air and Toxics Division.
Atrazine Workgroup: Consists of members from several Water Sections and persons from the Pesticide
Program Development Section to review and discuss atrazine issues affecting Region VII and develop
and recommend actions to be taken concerning these issues.
Grain Bin Group: Members from Water. Pesticides. Regional Council. Superiund. and the Lab meet
regularly to develop and implement a strategy to address the presence of Carbon Tetrachloride in the
groundwater of the Region's states. A flowsheet to coordinate the agency's action levels has been
developed and is being implemented. A policy paper was dratted and a sub-workgroup was formed to
determine what actions should be taken to resolve the immediate risks posed by carbon tetrachloride to
effected communities.
State Pesticide/Technical Advisory Committees: Usually formed by the State pesticide lead agency with
participation from both Air and Toxics and Water Divisions. All state agencies associated with
implementation of drinking water regulations and groundwater protection are actively involved in this
type of state coordination effort.
REGIONS
Ground Water Protection Coordinating Committee: In EPA Region 8. we established a ground water
protection coordinating committee to interact on a day-to-day basis in sharing information, planning
future meetings, and reviewing documents and proposals from all sources (i.e., states. USDA. EPA HOs,
etc.). One routine function of the committee is the routine joint review of grant work plans. This
committee, created in 1989. Includes primarily representatives from the Non-point source, ground water.
and pesticide programs with other programs included in specific instances. When the committee was
established, It was done so with the full support and counsel of the Regional Administrator and Division
Directors. It operates routinely and freely at the staff/Section Chief level with frequent support from the
Branch Chiefs.
Page 146 October 1992
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Appendix C
REGION 9
Ground Water Steering Committee: Region 9 established a Ground Water Steering Committee (GWSC)
in 1984 to provide overall policy direction and ensure coordination with the Region's programs that affect
ground water. The GWSC is comprised of the Directors of each of the Region's media divisions and is
attended by the Deputy Regional Administrator. Meetings are open to all staff, and representatives from
Water, Pesticides and Toxics programs are regularly in attendance.
Nonooint Source Integration Strategy Workgroup: The Nonpoint Source Integration Strategy Workgroup
(ISW) was formed in 1989. This workgroup involves representatives from Pesticides, Ground Water.
Surface Water, and other programs in the development and implementation of Regional Nonpoint Source
Program activities. The workgroup establishes program priorities and provides a staff-to-staff forum in
which program coordination can be facilitated. The workgroup is composed primarily of staff from the
participating programs.
State/EPA Agreement: State/EPA Agreement meetings are held twice a year between senior
management from all Region 9 divisions and high ranking officials from the respective state agencies.
These meetings serve the function of evaluating and prioritizing environmental areas of concern and
strengthening the cooperative working relationship between the state and EPA programs.
Pesticides in Ground Water Advisory Group: A Pesticides in Ground Water Advisory Group was formed
in FY 91 to identify review mechanisms, and provide technical assistance and guidance in developing
and reviewing State Management Plans. The group includes Section Chiefs and staff from the Ground
Water, Drinking Water. Underground Injection Control, Nonpoint Source, Hazardous Waste and
Pesticides Programs, as well as Regional Counsel.
GlS Technical Advisory Committee: Region 9 established a Geographic Information System (GIS)
Technical Advisory Committee on 3/13/91, which is composed of representatives from all Region 9
.media programs. This group will provide a forum for review of GIS projects dealing with agricultural
projects.
REGION 10
Ground Water Task Force: Formal cross program coordination between water and pesticides programs
is facilitated by the Ground Water Task Force. The Task Force membership consists of division directors
from all program divisions. The Deputy Regional Administrator is the chairman of the Task Force. A
Ground Water Committee, composed of section chief and staff level participants, operates under the
purview of the Task Force. Other ajj_h2£ work groups are formed to address special water/toxics issues
as appropriate.
October 1992 page 147
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Appendix C
2. Was there any specific effort in your Region to develop integrated FY 92
program guidance for states? If so, briefly describe process?
Coordinated Regional Guidance Document: The Ground Water Management Section, Water Quality
Management Section and the Pesticides Section worked together to develop a coordinated Regional
guidance document on the contents of a Pesticides in Ground Water Management Plan. This guidance
was then distributed to the state lead agencies in pesticides and in ground water. The Chiefs of the
Ground Water Section. Pesticide Section, and pesticide and Toxics Substances Branch held joint
meetings in each state with both these state lead agencies attending (Region 1).
Integrated Approach to Ground Water Management: Consistent Objectives: Due to limited resources.
there has been no effort to develop an integrated program guidance for the States. However, the
Pesticides and Water Programs have discussed the objectives of both programs guidance to ensure that
the workplans developed by the States identify an integrated approach to ground water management
(Region 2).
Cross Media Reviews: The Pesticide Program commented on the Ground Water Program grant
guidance, and the Ground Water Program commented on the Pesticide Program grant guidance
(Region 3).
Joint Regional Grants Guidance: Joint Regional Grants Guidance for the Ground-Water and Pesticides
Programs was developed for FY 91 grant activities. Although specific joint guidance was not developed
for FY 92. the intent of the FY 91 joint guidance did carry over in FY 92; FY 92 workplans will again be
reviewed jointly. It is important to note that the success of such coordination is not that guidance has
been issued, but that the commitment exists to ensure that the coordination required by the guidance is
implemented and that program follow-up occurs (Region 4).
Joint Guidance tor the Development of Generic State Pesticide and Ground Water Management Plans:
For FY 92. the Ground Water Protection Branch and Pesticides Section developed joint guidance for the
development of generic state pesticide and ground water management plans. This guidance updated
the previous joint guidance, dated December 1989. Items In the updated version included references to
the National Order for the Minimum Data Element Set for Ground Water and the Ground Water Task
Force Report (Region 5).
FY 92 FIFRA and CWA 106 Guidance: With respect to the FY 92 FIFRA and CWA 106 guidance, the
Pesticides Section had an opportunity to review and comment on the generic and state-specific
guidance, particularly on the pesticides and ground water language (Region 5).
State Program Workolan for Grants: As in previous years, and during the Regional FY 92 planning
process, State program workplan for grants are being routinely circulated to all appropriate program
offices for input. One mechanism that is effectively used to accomplish this coordination effort is the
Branch Chiefs Ground Water Coordination Committee (Region 6).
FIFRA Grants: Each State's FIFRA grant work program includes a provision for the support of the State's
development of a Comprehensive Ground Water Protection Program. All Region 6 ground water related
grant programs are being encouraged to support each State's development of a comprehensive
program (Region 6).
Cooperative Effort in GW Management and Protection: In FY 90, the Regional Division Directors for
Water and Pesticides/Toxics issued Regional guidance to Initiate a cooperative effort among the various
state agencies involved in groundwater management and protection. Both Divisions have discussed
ground water issues with the states and continue to buBd working relationships within the various state
agencies involved in groundwater management and protection. For both FY 91 and FY 92, these
Divisions have coordinated on grant activities to enhance program objectives under FIFRA and the Clean
Water Act. Further efforts are forthcoming, pending development of final guidance and strategies by
headquarters (Region 7).
Page 148 October 1992
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Appendix C
uniform Guidance: For FY92, there was no effort to develop integrated program guidance for the states
In FY89, the Region developed uniform guidance for ground water protection and held a joint conference
with Departments of Health and Agriculture to develop grant workplans that were integrated and
complemented the efforts of other Agencies. This initial effort set the direction for subsequent years.
With joint work plan review by the committee, this effort has been sufficient for the interim (Region 8).
Nonnoint Source Program Guidance: Nonpoint source program guidance to the states is developed by
the ISW to ensure that state programs address cross-media and cross-programmatic concerns (Region
9).
CWA Section 106- Additional Informal staff-to-staff coordination occurs in the development of Section
106 grant guidance and review of 106 workplan proposals (Region 9).
Joint Grant Guidance: The Pesticides and Ground Water Sections have developed joint grant guidance
to states outlining the activities that are eligible for funding under FIFRA and CWA Section 106. and
promoting a coordinated effon by both the state water and agricultural agencies in the development and
implementation of pesticides in ground water protection programs (Region 9).
Cross Program References: For FY 92. there was no specific effort In Region 10 to develop integrated
program guidance for States. However, surface and ground-water guidance emphasized pesticides as a
major priority for State/EPA funding. In FY 91. a letter clarifying the Pesticide Cooperative Agreement
Guidance was sent to State pesticide programs with copies to State ground-water programs. Office of
Ground Water comments on these letters were incorporated prior to finalization (Region 10).
October 1992 Page 149
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Appendix C
3. What actions did the Region take to promote (or require) program
coordination between water and pesticide programs at the state level?
Stated Expectation that States will Coordinate: During meetings with states, the state agencies were
informed that the Region expected the programs to coordinate. Follow-up meetings will be scheduled
this fall. State non-point source coordinators worked with state pesticide staff on 319 (h) proposals and
participated in joint meetings (Region 1).
Special Project Coordination: The region also coordinated a special project in Maine dealing with
pesticides in groundwater. This project enhanced the cooperation of all state agencies with groundwater
protection responsibilities (Region 1).
Pesticide Program Workolans: The Pesticide Program Workplans with the States Identify the attendance
of multi-agency meetings for the purpose of developing State Management Plans. These meetings
require close coordination between State level water and pesticide programs and their respective
constituencies (Region 2)
Section 106 Pesticides In Ground Water Monies: The Water Program required the use of Section 106
Pesticides in Ground Water money to be used on cross program issues in New York and New Jersey
(Region 2).
Cooperative Agreements: The Pesticide program cooperative agreements required development of
cross-program infrastructures to support Ground Water Strategy program development in each State.
Progress of this infrastructure development was monitored at mid-year and year-end grant reviews and
discussed at pre-SFIREG (State FIFRA Issues. Research and Enforcement Group) meetings held with ttie
State Lead Agencies (Region 3).
Pesticides in Ground Water Pilot Projects: These projects in Lancaster County, PA and Jefferson
County. WV are serving as demonstrations of how interagency workgroups involving state, local, and
federal agencies can successfully operate. These projects have greatly strengthened the water and
pesticides program coordination in these two states (Region 3).
FY92 FIFRA Grant Guidance: This guidance continues to encourage development of interagency and
cross-program infrastructures at the state level (Region 3).
FY92 Ground Water OVA Section 1061 Grant Guidance: This guidance reads as follows: The State
must identify the formal process which the State uses to coordinate among ground water, nonpoint
source, agricultural and health agencies to protect the State's ground water from pesticide
contamination. Those States not pursuing a pesticide management program will not receive the
pesticide component (16%) of the grant target* In addition. EPA progress reviews, conference calls.
and State meetings, were used to stress the need for coordination (Region 3).
Section 319: Under Section 319 grant guidance which requires within-state program coordination, the
Region reviewed the operating plans of each State's Nonpoint Source Task Forces. Comments were
made to strengthen the task forces where appropriate (Region 3).
State Management Plans: In FY90 and FY91, the Groundwater and Pesticides Programs met with
Environmental and Agricultural Commissioners in each state to discuss the requirements of State
Pesticides Management Plans (SPMP) under the Pesticides and Groundwater Strategy. These meetings
were followed up with meetings in several states with the program people (Region 4).
Joint Grants Guidance: Joint grants guidance in the Groundwater and Pesticides Programs dealing with
State Pesticide Management Plan activities has been issued (Region 5).
Page 150 October 1992
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Appendix C
NPS Workclans: The review of Section 3l9(h) Nonpdm Source WorVplans has been coordinated with
the Pesticides Program and other water programs in the Water Division. States were encouraged to
coordinate §3i9(h) proposals with other state and federal agencies for §319 program implementation. In
iact. work group or task force meetings were held by seven states to develop grant proposals. EPA
representatives attended some of these meetings (Region 5).
Generic State Management Plans: State FIFRA or CWA106 funding related to the development of
Generic State Management Plans is contingent upon the development of a Coordinated Program Plan.
This document is developed jointly by the State lead pesticides and ground water agencies. This
document is subsequently reviewed by both the regional pesticides and ground water programs (Region
5).
State Management Plans: In the FY 91 FIFRA grant, the State lead agency for pesticides were required
to provide pass-through funds to other appropriate State agencies which are involved in the protection of
ground water and/or pesticide use. During the FY 92 FIFRA grant negotiations, the States are being
asked to provide, at a minimum. 20 percent of the allocated FIFRA ground water monies, or services in
kind, to appropriate State agencies and organizations. These pass-through funds were intended to
promote cooperation and coordination in the development and implementation of States' management
plans for pesticides and ground water. A portion of the Clean Water Act Section 106 Ground Water
protection grant funds may also be used by State lead ground water agencies to support the
development and implementation of State management plans (Region 6).
National Guidance to Assess Water Sutmlv Vulnerability: national guidance on assessing vulnerability of
a water supply is being prepared. The water supply program has advised federal and State pesticide
and water programs of this provision of the Safe Drinking Water Act and has encouraged State water
supply programs to negotiate with other State water and pesticide programs to locate wells by latitude
and longitude and to provide the location of potential pesticide contamination problems (Region 6).
Coordinated Approach to Water/Pesticides Issues: Both EPA regional divisions initially met with the
State Pesticide Lead Agency Directors and water program managers to establish commitments from the
States to address pesticide/water issues in a coordinated approach. As a result, the states in the
Region have established pesticide/technical advisory committees that have participation from all state
agencies associated with implementation of drinking water regulations and groundwater protection.
Some of the state workgroups which have been formed include the participation of farmers,
environmental groups and agribusiness and are very actively involved In the state coordination effort
(Region 7).
State Pesticide Management Plan Guidance: The Region has established guidance for the development
of State Pesticide Management Plans for the protection of groundwater from pesticide contamination
(Region 7).
State Directors Meeting: Annually, a State Directors' Meeting is held by the Regional Administrator to
promote working relationships and enhance coordination. Participants include the State Agricultural
Departments. Departments of Health, and the Departments of the Environment (Region 7).
Coordinating Committees: One required element of the grant workplans is the creation of coordinating
committees in each state patterned after the non-point source task forces that each state has already
established. The Region anticipates that each State will develop formal agreements to institutionalize the
working relationships established through their coordinating committees (Region 8).
ISW. Joint Pesticides & Groundwater Guidance and Informal Communication: Promotes state level
coordination between water and pesticide program activities through the ISW. joint Pesticides and
Ground Water Guidance, and informal stafMo-staff communication (Region 9).
FY90/FY91 Nonoolnt Source Demonstration Projects: Cross programmatic coordination was particularly
important in the development of the FY90 and FY91 nonpoint source demonstration projects (Region 9).
October 1992 Page 151
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Appendix C
Groundwater and Pesticides Aoencv Coordination: Cross programmatic coordination was particularly
important in ensuring that activities by the ground water and pesticide state agencies are supportive of
each other (Region 9).
Joint Program Grant Negotiations: Pesticides and Ground Water staff have conducted joint program
gram negotiations and evaluations (Region 9).
State Groundwater Management Pi?n«t Pesticide cooperative agreement funds is supporting pesticide
program involvement in the development of several State ground water management plans. This
involvement is helping to build closer working relationships between State pesticide and ground water
programs (Region 10).
Pesticide and Nutrient Strategy: Funding from the Office of Ground Water is providing partial funding and
technical support for development of a multi-agency Pesticide and Nutrient Strategy in Washington State
(Region 10).
Pesticides in Ground Water/Surface Water: Ground Water grants call for coordination of funding and
activities among State agency programs to address pesticides in ground water and in surface water
issues (Region 10).
State Management Plans: Pesticide Cooperative Agreement Funding is being used by pesticide
programs to identify and describe other State and Federal programs that will be pan of a State
Management Plan for pesticides in ground water. The Slate water programs are a major part of this
effort (Region 10).
Vulnerability Assessment Work & Groundwater Monitoring: Groundwater and Pesticide Cooperative
funding is supporting basic vulnerability data development which will be a component of State
Management Plans (Region 10).
BMPs to Handle Pesticide Contamination: The Section 319 program is supporting major efforts in
development of Best Management Practices (BMPs) aimed at pesticide contamination of both surface
and ground water.
Meetings: Several meetings among State pesticide programs, groundwater programs and EPA have
been held. Most of these meetings were at the staff/middle management level but one meeting of State
department directors and EPA division directors was held (Region 10).
Pesticides in Groundwater/Suffaee Water State program reviews have targeted pesticides in ground
water and surface water issues for dose tracking. In a few instances, pesticide program staff have
accompanied ground water staff during State ground water program reviews and vice versa (Region 10).
State GW Program Profiles: The Regional Office has initiated profiling of State groundwater programs
that will identify the extent of coordination among agencies (Region 10).
Pa8e 152 October 1992
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Appendix C
4. For the following agriculturally related program areas, rank coordination between water and
pesticides and toxics in your Region from 1-5: (1-none to date; 2-some, but needs
improvement; 3-generally OK; 4-good with a few areas that need to be strengthened; 5-
excellent).
The strongest areas for coordination among the Regions is in the groundwater programs and the state pesticide management
plans. The areas which need the most improvement is coordination on non-point source programs.
Areas which present opportunities lor coordination include Special Projects. Joint Enforcement Actions. Wetlands Protection,
Pesticide Enforcement Actions. Water Quality Risk Study. Episodic Issues, Certification of Applicators. Plane River Enforcement
Protect. Sampling Programs (Heptachlor in fish, well sampling, etc.).
REGIONS
Groundwater programs
Grant Guidance
Non-point Source Programs
Well-head Protection Programs
State Pesticide Management Plans
Other (Please list) :
• Special Projects
• Joint Enforcement Actions
• Wetlands Protection
• Pesticide Enforcement Actions
• water Quality Risk Study
• Episodic Issues
• Certification of Applicators
• Platte River Enforcement Project
• Sampling Programs (Heptachlor in
fish, well sampling, etc.)
1
4
4
2
2
4
4
2
4
4
3
4
4
3
4
4
2
4
4
4
3
2
3
3
3
,•
5
3
2
2
5
5
2
2
6
4
3
4
4
4
4
4
3
7
4
4
3
4
4
4
4
4
8
9
5
4
5
4
/
4
10
4
2
3
3
4
October 1992
Page 153
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Appendix C
5. For the same list of program areas in Question 4, list any barriers you can identify which inhib
closer coordination and briefly Indicate possible ways to address these.
Time and Personnel Limitations: Prior to FY 91. time and personnel limitations in the Pesticides Section were a substantial
bamer. At this point, the Section has been able to expand and we expect to have more capabilities to interact with the Water
programs (Region 1).
Differences in Program Mandates: The differences in program mandates can impede a coordinated approach to ground and
surface water protection. FIFRA allows pesticides to be used as long as the benefit outweighs the risk. This is not always on a
parallel course with other programs where the legal application of a registered pesticide may be considered contamination if
residues in water exceed a specified level (Region 1).
Heavy Workload: The heavy workload in carrying out the basic mission of the programs makes It difficult to coordinate mow
effectively (Region 1).
Different Physical Location: The barrier which inhibits coordination Is the logistics of communication between the two branches
which are located in different physical locations. However, an increased effort is being made to reduce these difficulties (Regior
2)
Lack of Integration: The pesticide component of the Ground Water program's State grant guidance and the ground water
component of the pesticide program's State grant guidance should be more fully Integrated, and as identical as possible. This
should be accomplished at the HQs level for the basic guidance, with Regional concerns addressed jointly at the Regional level
(Region 3).
Release Pesticides in Ground Water Strategy: Since EPA's Pesticides in Ground Water Strategy has yet to be finalized and
released, States are very hesitant to start developing Pesticide in Ground Water Management Plans. Instead, the States are
focusing on what they call "safe" activities, such as monitoring ground water to determine the extent of the pesticides problem
and surveying landowners to identify pesticides used patterns. State do not want to start developing Management Flans that
may or may not be consistent with EPA's final Strategy and Guidance. EPA needs to finalize and release the Strategy and
Management Plan Guidance before the programs loses any more momentum (Region 3).
Differing Grant Cycles: Since the grant cycle for the Nonpoint Source program (Clean Water Act Section 319) is almost a year
behind the Ground Water and Pesticides programs. It sis difficult to carry out cooperative projects because of the timing of
funding (Region 3).
Differing Priorities: There are different priorities among the programs which poses a barrier to better coordination (Region 3).
Better Use of Committees: The Cooperative Extension Service's State Interagency Water Quality Coordinating Committees neec
to be better utilized to enhance coordination (Region 3).
MQUs within the Region: Coordination needs to be formalized through a MOU between Water Management Division and Air.
Radiation and Toxics Division (Region 3).
Release of Pesticides in Groundwater Strategy: A significant step toward Improving inter-program coordination would be for the
Pesticides and Groundwater Strategy to be finalized and released. Although selected elements of the Strategy are being workec
on by EPA and the states. fuU implementation of the Strategy is pending Its release (Region 4).
Lack ol Commitment or Information: Closer coordination among programs is often Inhibited by either the lack of commitment c
information. The emphasis on improving inter-program coordination should be through Increased communication of respective
program responsibilities, an understanding of the benefits to be derived from coordination, and, if needed, the use of program
guidance (Agency Operating Guidance, Office of Water Accountability System. STARS Measures, etc.) to ensure that the require
coordination is being pursued at both the Headquarters and Regional levels. Opportunities that benefit multiple programs and
efforts that have shared responsibilities (e.g.. the development of State Pesticide management Plans) should be assigned a high
Agency priority and then aggressively pursued (Region 4).
Resources Match Aoencv Priorities/Commitments: Agency commitments (e.g.. OWAS. STARS, etc.) should provide for setting
priorities based on Regional needs. Appropriate resource investments/disinvestments should then be made to respond to those
needs. The Watershed Initiative is an example of the need for such coordination and resource commitment (Region 4).
Page 154 October 1992
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Appendix C
Differing Goals and Restrictions on Funding; Barriers that inhibit cooperation between Pesticide Programs and Water Programs
result from the funding available from FIFRA and CWA/SDWA for each program. Since the use of such funding is guided by
these statutes, and some of the goals of each statute may conflict (FIFRA's risk/benefit analysis of the use of pesticides and
CWA/SDWA non-degradation goal for aquifers), non-cooperation between programs can result because the goals of each
program are different. Differences between FIFRA and CWA/SDWA need to be resolved in order for Pesticides and Water
Programs to be in complete cooperation (Region 5).
State Mandates and Limitations: The state agencies all operate under their own state laws. The states are not mandated to
share information among themselves. The separation of state agencies limits interagency communication and coordination. Of
course, there is the potential turf" battles that exist in state governments (Region 7).
Toxics Coordination: There has been little coordination with toxics related programs because those programs are oriented
towards specific sites. The States in the Region are still doing general vulnerability and pesticide use surveys and are not read>
to respond to specific problem sites (Region 8).
Grant Guidance: Coordination Is hampered because regional guidance and grant award schedules are dependent on national
guidance schedules and availability of grant funds. Schedules for issuance of national guidance are unpredictable and
uncoordinated at the headquarters level; however. Regional Pesticides and Water programs must integrate the grant guidance
and coordinate awards on the same time frame. It Is important that HQ coordinate and produce guidance to regional program;
on the same time schedule. This would greatly facilitate coordination between pesticide and water programs within the Agency
and, at the same time, promote coordination among state agencies (Region 9).
State Pesticide Management Plans: Although the Pesticide program has invited staff from the surface water program to
participate in state program reviews, the focus of pesticides/water program coordination has been on groundwater concerns. I
is vital to focus on both surface and groundwater protection activities (Region 9).
HQ Leadership in Coordination: One barrier to coordination that seems to exist is a lack of expectation on the pan) of
Headquarters that Regional Division directors will coordinate water and pesticides program activities. However, that expectation
should be based on examples of Headquarters leadership on coordination issues. As an example of both an opportunity for
leadership and a barrier to coordination. Headquarters should ensure that all grant guidance related to water and pesticide
programs is issued earlier in the grant year and that all the guidance is issued at the same time (Region 10).
Lack of Resources: Coordination of these muttlfaceted programs takes significant time and effort on the part of both mangers
and staff. Currently there is a lack of sufficient resources to cover the time and effort required for effective coordination (Region
10).
October 1992 Page 155
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Appendix C
6. Add any other region-specific information you feel is relevant to describing current program
coordination efforts within the Region. We are particularly Interested in identifying what has
worked and what hasn't in this area, and any recommendations you may have to improve
coordination and communication.
What Hat Worked
Coordinated Development of Regional Guidance for State Management Plans: The developmental process encouraged
interaction which may not have occurred otherwise. Presentation of this guidance as a coordinated unit to the states increasec
the credibility of the Agency and is helping to initiate coordination at that level. The message to the states was that the Agency
program personnel were working cooperatively across program lines and that we expected the states to do the same (Region •
Regional Ground Water Policy Committee: This committee, chaired by the Deputy Regional Administrator, has also provided
opportunities for cooperation and coordination (Region 1).
Pesticides In Ground Water Pilot Projects: These projects are being carried out In Lancaster County. PA and Jefferson County.
WV. The projects are a result of joint proposals from the Ground Water and Pesticides programs for Region III MERITS funding
Through these project, critical areas are being identified within these Counties where pesticides are most likely to leach to
ground water and affect drinking water wells. Results are being used by the Departments of Agriculture and local USDA offices
to target monitoring efforts and assistance to farmers, as well as to support development of a State Management Plan.
Interagency workgroups have been established between agriculture, health and environmental agencies at the State, local and
federal level of carry out these projects (Region 3).
Ground Water Vulnerability to Pesticide Contamination: In May, Region 3 and USGS Mid Atlantic Region signed an interagency
agreement for the purpose of developing monitoring strategies and evaluating methods to assess ground water vulnerability to
pesticides contamination. Results, which are expected by May 1993. will support development of State Pesticide ir/Ground
Water Management Plans (Region 3).
MOU with Programs within the Region: The Hazardous Waste Division and Water Management Division established a
Memorandum of Understanding (MOU) which included specifics on how the Water and Pesticides programs were to coordinate
in the Region. Since the reorganization of the Pesticides program into the Air, Radiation and Toxics Division in October 1989, a
new MOU was drafted but never instituted. The MOU needs to be finalized to reflect all organization and programmatic change
and then instituted (Region 3).
USGS National Water Quality Assessment: The Ground Water Protection Section is an active participant of the USGS National
Water Quality Assessment Liaison Committees which have been established for three large basins in the Region. All three
projects currently are either or will be addressing pesticides impacts to water quality (Region 3).
State Coordination: Judging from the FY92 workplans received to date, this year's grant guidance seems to have spurred
several of the States to push for coordination between agriculture and environmental agencies (Region 3).
FY92 Guidance Procedure for 8319 Grant Proposals: The guidance wfll call for state program coordination to ensure a balance
program that meets states' needs and emphasize the watershed demonstration approach. The expected result is closer progra
coordination by EPA to more fully utBize the multi-media concept, Including water and pesticide/toxic program implementation
(Region 4).
Joint Guidance of Pesticides and Ground Water Programs: The development of this guidance has been extremely beneficial in-
showing a coordinated and united front to the states and in negotiating a joint position between the two programs within the
Region (Region 5).
Coordinated Approach to Monitoring Use of Aquatic Biocides: The Pesticide Section has been working closely with the Water
Division to monitor compliance with FIFRA and CWA in the use of aquatic biocides. Enforcement actions have focused on
marketing of unregistered aquatic biocides, and the use of biocides in accordance with NPDES Permits (Region 5).
Page 156 October 1992
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Appendix C
Onpn Line of Communication: The most effective method of maintaining coordination between the water and pesticides and
toxics programs has been through maintaining an open line of communication between all levels of program staff. Staff level
personnel are able to identify coordination and communication issues between the programs and elevate the issues to the
appropriate level of management for resolution if the staff members are not able to resolve the issues themselves (Region 6)
Water Quality Coordinating Committee and Atr^ina Workgroup: These groups have been very beneficial in the exchange of
information within the region and allows for existing programs to be built upon and improved (Region 7).
State Directors Meeting: The four State Directors' Meeting has enhanced the state inter-agency working relationships. The
development of inter-agency agreements at the state level wDI hopefully resolve these conflicts of states not sharing information
or working together on shared issues (Region 7).
Personal Working Relationship: We feel we have the best program coordination where the staff have a dose personal working
relationship (Region 10).
Recommendations to Improve Coordination
Coordinated Responses to Information Requests: By having all responses coordinated between relevant programs prior to
sending responses to HQs. all the pertinent programs must work closely quickly together (especially given the short time frame
in many information requests). The result has been enhancing coordination and understanding of each others programs (Regie
i).
institutionalize Coordination: Coordination between the Water and Pesticides programs and between the various Water
programs needs to be institutionalized through the following mechanisms:
• Require integrated grant guidance should be instituted at the HQs level. Regions may wish to address Regional grant
guidance issues;
• Formalize review and comment process by the Ground Water and Pesticides programs on State grant applications.
workplans and progress reports: and/or
* Establish regional workgroups to address common issues (non-point source, ground water, permits, pesticides etc.)
(Region 3)
Strategy integration- EPA HO needs to integrate the various Strategies which are all being developed, such as Pesticides in
Ground Water. Nitrates. Sediment. Coastal Zone Management. Non-Point Source etc. Without integration, there is too much
chance for conflict, confusion and duplication (Region 3).
Pesticides Spills: A future opportunity to enhance coordination between water and pesticides programs is past pesticide spill
areas, such as agricultural mixing and loading sites. These areas have a high potential for serious water pollution. The State
Pesticide Management Plan development process may be the appropriate mechanism to provide guidance and promote
coordination among programs within the Agency and at the State level to address these areas of concern (Region 9).
Adequate Resources Needed: To assure continued and productive coordination efforts, adequate resource allocations at the H
and Regional level must be maintained (Region 9).
Present United Front to States: EPA should be presenting a united position on pesticides and water and water issues to the
States. We should not portray these issues from only one program's perspective. Although it sometimes does not meet this
goal, the State/EPA Agreement (SEA) process has considerable potential for presenting such a unified message (Region 10).
October 1992 Page 157
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Appendix D
Appendix D
Agriculture and Water Integration
Work Group Members
October 1992 Page 159
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Appendix D
Agriculture and Water Integration
Work Group Members
OPTS/OPP:
Cathy Kronopolus - Field Operations Division (Pesticide SMPs)
Jackie Harwood - Field Operations Division (Pesticide SMPs)
Jim Roelofs - Policy & Special Projects Staff (Pesticide SMPs)
Arden Calvert - Policy & Special Projects Staff (Pesticide SMPs)
OW/OGWDW:
Bob Barles - Ground Water Protection Division (CSGWPP)
Steve Ainsworth - Ground Water Protection Division (CSGWPP)
George Hoessel - Ground Water Protection Division (Class V UIC)
Janette Hansen - Ground Water Protection Division (WHP Program)
John Reeder - Immediate Office (PWS Program)
OW/OWEC:
Sheila Frace - Permits Division (NPDES - feedlots)
Tim Icke - Immediate Office (CWA 106 - surface water)
Ruby Cooper - Permits Division (NPDES - feedlots)
OW/OWOW:
Anne Weinberg - Assessment & Watershed Protection Division (NFS Program, Coastal
NFS Program, Clean Lakes Program)
Ed Richards - Assessment & Watershed Protection Division (NFS Program)
Mark Curran - Oceans & Coastal Protection Division (National Estuary Program,
Near Coastal Waters, Chesapeake Bay)
Sherri Fields - Wetlands Division (Wetlands Program)
OPTS/OCM:
Linda Flick - Policy & Grants Division (Pesticide enforcement)
Lori McKay - Policy & Grants Division (Pesticide enforcement)
October 1992 Page 161
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Appendix D
OPPEVOPA:
Clay Ogg - Water & Agriculture Policy Division (Agricultural Pollution Prevention)
Roberta Parry - Water & Agriculture Policy Division (Nitrogen Action Plan)
REGIONS:
Bruce Wilkenson - Region V Pesticides & Toxic Substances Branch
Doris Betuel - Region IX Groundwater Protection Section
Page 162 October 1992
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Appendix E
Appendix E
EPA Regional Program Contacts
October 1992 Page 163
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Appendix E
EPA Regional Program Contacts
For additional information on any of the 16 programs, please contact one of the
following offices:
Regional Pesticide Division Directors
(Generally responsible for: Pesticide SMP Program)
Region I
Air, Pesticides, & Toxics Management
Division
1 Congress Street
John F. Kennedy Federal Building
Boston, MA 02203
Tel: (617)565-3800
Fax: (617)565-4939
Region IV
Air, Pesticides, & Toxic Substances
Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Tel: (404)347-3222
Fax: (404)347-1681
Region II
Environmental Services Division
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
Tel: (908)321-6754
Fax: (908)321-4381
Region V
Environmental Sciences Division
77 W. Jackson Boulevard
Chicago, IL 60604
Tel: (312)353-3808
Fax: (312)353-4342
Region III
Air, Radiation, & Toxics Management
Division
841 Chestnut Building
Philadelphia, PA 19107
Tel: (215)597-9390
Fax: (215)580-2011
Region VI
Air, Pesticides, & Toxics Division
1445 Ross Avenue
Dallas, TX 75202-2733
Tel: (214)655-7200
Fax: (214)655-2164
October 1992
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Appendix E
Region VII
Air & Toxics Division
726 Minnesota Avenue
Kansas City, KS 66101
Tel: (913)551-7020
Fax: (913)551-7065
Region IX
Air & Toxics Management Division
75 Hawthorne Street
San Francisco, CA 94105
Tel: (415)744-1219
Fax: (415)744-1077
Region VIII
Air, Toxics, & Radiation Division
One Denver Place, Suite 500
999 18th Street
Denver, CO 80202-2405
Tel: (303)293-0946
Fax: (303)293-1229
Region X
Air & Toxics Division
1200 Sixth Avenue
Seattle, WA 98101
Tel: (206)553-4152
Fax: (206)553-0110
Page 166
October 1992
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Appendix E
Regional Water Division Directors
(Generally responsible for: Comprehensive State Ground Water Protection Program,
Wellhead Protection Program, Class V UIC Program, Nonpoint Source Program,
Coastal Nonpoint Source Program, Public Water Supply Program,
Near Coastal Waters Program, National Estuary Program, Chesapeake Bay Program,
State Wetlands Protection Program, Clean Lakes Program, NPDES — Feedlot Program,
and Clean Water Act Section 106 Program)
Region I
Water Management Division
John F. Kennedy Federal Building
1 Congress Street
Boston, MA 02203-2211
Tel: (617)565-3478
Fax: (617)565-4940
Region V
Water Management Division
77 West Jackson Boulevard
Chicago, IL 60604-3507
Tel: (312)353-2147
Fax: (312) 886-0957
Region II
Water Management Division
26 Federal Plaza
New York, NY 10278
Tel: (212)264-2513
Fax: (212)264-2194
Region VI
Water Management Division
1445 Ross Avenue
Dallas, TX 75202-2733
Tel: (214)655-7100
Fax: (214) 655-6490
Region HI
Water Management Division
841 Chestnut Street
Philadelphia, PA 19107
Tel: (215)597-9410
Fax: (215)597-3359
Region VII
Water Management Division
726 Minnesota Avenue
Kansas City, KS 66101
Tel: (913) 551-7030
Fax: (913) 551-7765
Region IV
Water Management Division
345 Courtland Street, NE
Atlanta, GA 30365
Tel: (404) 347-4450
Fax: (404) 347-5204
Region VIII
Water Management Division
999 Eighteenth Street
Suite 500
Denver, CO 80202-2405
Tel: (303)293-1542
Fax: (303) 294-1386
October 1992
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Appendix E
Region IX Region X
Water Management Division Water Management Division
75 Hawthorne Street 1200 Sixth Avenue
San Francisco, CA 94105 Seattle, WA 98101
Tel: (415)744-2125 Tel: (206)553-1793
Fax: (415) 744-1235 Fax: (206) 553-0165
For information on the Nitrogen Action Plan and the Agricultural Pollution
Prevention Strategy, please contact:
Agriculture Policy Branch, PM 221
Water and Agricultural Policy Division
Office of Policy Analysis
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
Tel: (202) 260-2753
Fax: (202) 260-2300
Page 168 October 1992
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