xvEPA
United States
Environmental Protection
Agency
Office of
Water Program Operations
Washington. D.C. 20460
Water
Proceedings
from National
Conferences on
Shopping for
Sewage Treatment:
How to Get the
Best Bargain for
Your Community
or Home
Draft
Dates: April 28, 29, and 30, 1978
Location: Washington, D.C.
June 4,5, and 6,
Denver, Colorado
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TABLE OF CONTENTS
DRAFT OF CONFERENCE PROCEEDINGS
SHOPPING FOR SEWAGE TREATMENT: HOW TO GET THE BEST BARGAIN FOR YOUR COMMUNITY OR HOME
INTRODUCTION
CONFERENCE CONVENING: Introductory Remarks
Washington, D.C. Conference (April 28-30, 1978) 1
Denver Conference (June 2-4, 1978) 2
I. SEWAGE: POLLUTANT OR RESOURCE? 3
Michael Gravits
II. THE TECHNOLOGIES 6
A lay person's description of the systems, effectiveness of pollutant removal,
reUability, renovation mechanisms, climatic and seasonal effect, sizing and
oost, environmental impacta, and common problems with evaluations of the
technologies.
INTRODUCTION 6
Michael Gravits
CONVENTIONAL AND ADVANCED WASTEWATER TREATMENT SYSTEMS 7
Dr. David Stensel j
Dr. Joseph Harrington -j
SEWAGE RECYCLING: TURNING POLLUTANTS INTO RESOURCES 21
Dr. John Sheaffer 21
John Marsh 24
J. Frank Gray 21
SMALL-SCALE ON-SITE SYSTEMS 27
Small Scale Systems: An Alternative to the Urban Model 27
Jack Abney
Aquaculture and Other Small-Scale Systems 30
David Del Porto
Water-Based On-Site Systems: The Septic Tank Revisited 31
Patricia Hesbitt
Central Collection vs. Separated Treatment 37
Carl Lindstrom
Separated Treatment: Waterless Toilets and Greywater 38
Abby Rockefeller
HEALTH EFFECTS OF THE TECHNOLOGIES 4V
Dr. Sam Fogel
FINANCING SEWAGE TREATMENT: WHAT TO LOOK FOR - WHAT TO AVOID 47
Stuart Fuchs ^g
Alan Parkas «g
Larry Cahill
WESTERN WATER RIGHTS AND LAND APPLICATION 61
John Musick
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Page
LIBERATING TECHNOLOGY: SAVING OUR WATERS AND DOLLARS 63
Ralph Nader
PROMOTING ALTERNATIVE WASTEWATER TREATMENT 68
Rep. Tim Wirth
III. THE MUNICIPAL CONSTRUCTION GRANTS PROGRAM AND CITIZEN INVOLVEMENT 70
A discussion of the legal and administrative requirements, the grant(s)
application process, public participation regulations currently being
drafted, same of the obstacles to effective citizen involvement, and some
of the remedies.
SETTING NEW DIRECTIONS AT THE ENVIRONMENTAL PROTECTION AGENCY 70
Thomas C. Jorling
A CHANGE OF COURSE FOR CONSTRUCTION GRANTS: WHAT THIS MEANS AT THE 74
REGIONAL LEVEL
Alan Merson
A SHORT TALK ON THE FEDERAL LAW OF SEWAGE TREATMENT 77
Gordon Wood 77
Larry Silverman 77
POLITICAL AND INSTITUTIONAL OBSTACLES TO CITIZEN PARTICIPATION 81
David Zaisk
CASE STUDIES:
Spokane, Washington 81
David Zwick
Pennypack Watershed Association, Pennsylvania 83
Donn Mitchell and Helga Wagner
Northglenn, Colorado 86
Richard P. Lundahl
Falmouth, Massachusetts 89
Dr. William Kerfoot and Glenn MacNary
PUBLIC PARTICIPATION: HOW PEOPLE CAN HAVE AN IMPACT ON POLICY 93
John Harmond
SEWAGE TREATMENT FACILITIES PLANNING: THE STEPS IN THE PROCESS 96
Myron Tiemens
CHOOSING, USING AND ABUSING POPULATION PROJECTIONS: PREDICTING GROWTH 100
Dr. Judith Kunofsky
BUILDING COALITIONS FOR BETTER SEWAGE TREATMENT 105
Skip Ptoberts
IV. SPEAKERS LIST 107
PARTICIPANTS LIST 1Q9
V. APPENDIX m
CHECKLIST FOR REVIEW OF FACILITY PLANS by Michael Gravitz
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CONFERENCE CONVENING: WASHINGTON, D.C.
(April 28-30, 1978)
SOPHIE ANN AOKI: Clean Water Fund,, Washington, D. C. Has coordinated citizen campaigns for
stronger water laws over the past several years.
DAVID ZWICK: Director, Clean Water Action Project, Washington, D.C. An attorney who ao-
authored Water Wasteland, a landmark 1971 oritique of federal cleanup pro-
grams, he has played a leading part in several national citizen campaigns
for environmental law reform.
SOPHIE ANN AOKI
Good evening, and welcome to the first of two conferences on "Shopping for Sewage Treatment:
How to Get the Best Bargain for Your Community or Home." On behalf of the Environmental Policy
Institute and the Clean Water Fund, it's a pleasure to welcome you to our three-day shopping
trip, sponsored by the National Science Foundation's Science for Citizens Program.
This first conference is being videotaped by the Environmental Protection Agency, so that this
unique gathering of technical experts, citizens, and the many others here may be packaged in
short form and then be available for use by citizens around the country that were not able to
attend these conferences.
Conference proceedings will be produced after both conferences are over, and will be sent to
all participants.
DAVID ZWICK
Welcome. The subject, as you know, is sewage treatment, at $5 billion a year. That is the
annual federal price tag alone--with billions more each year in state and local spending—for the
sewage treatment construction program that will have such an enormous impact on the future of our
country's communities and waters.
You participants are an extremely diverse and unique group. This ought to be described as the
first sewage summit, the first time that the top national experts in the technologies have come
together with the regulators, local officials, taxpayers, and the citizens who have to face
paying the bills and living with the results.
The costs of mistakes are high. The decisions that our communities will have to make on the kinds
of technologies to adopt, ways to pay for it, the ways to control them and operate them--these
decisions will affect the future of our fishing waters, the safety of our drinking water, the
size of our sewer bills and tax bills, our community budgets, the well-being of our neighborhoods
and of our farms. They will shape the face of this country in the years to come. It's important
to do the best we can.
We need facts, but especially at the local level, facts can be very hard to get. Arguments
bolstered by contending technical claims are among the weapons in struggles over competing notions
of what the problem is and how it should be solved. Local officials often feel in the dark in
dealing with these complicated questions. Citizens feel more in the dark, and even the so-called
experts, the trained technicians, sometimes don't know as much about the available solutions as
they think they know or claim to know.
The purpose of this conference is to begin to narrow that knowledge gap. In doing so, it's not
possible to avoid controversy. To do that would fail to expose you to what you are going to run
into, as you and others begin to raise these questions in your own communities. Our purpose will
be to enlighten that controversy, so that better choices can be made.
CONFERENCE CONVENING: DENVER COLORADO
(June 2-4, 1978)
SKIP ROBERTS: Trade union activist. Former American Federation of State, County, and Municipal
Employees (AFSCME) Union area director (Rocky Mtn. region). Special assistant to
President, Colorado AFL-CIO. Denver, Colorado.
TERRY STUART: President, Colorado Open Space Council, and an environmental consultant
with Stuart-Nichols, Denver, Colorado.
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SKIP ROBERTS
My name is Skip Roberts and I am the local coordinator of this conference for the Colorado Open
Space Council, which is one of the co-sponsors of this conference. This is the second of two
national conferences—one was held about a month ago On the East Coast. The main sponsors of
both conferences are the Environmental Policy Institute and the Clean Water Fund, two national
organizations that are working with a grant from the National Science Foundation's Science for
Citizens Program. Then, in addition, the Environmental Protection Agency has helped in funding
this second conference in Denver.
On behalf of the Colorado Open Space Council and Coloradoans interested in water issues, we'd
like to welcome you to the Western session of the sewer summit. As they say, about eight weeks
ago, I couldn't really spell "sewage expert" and today I are one. It's amazing to see the number
of people, geographic spread, occupational background, and interest of all of you who are turning
out and giving up a weekend to get into this subject. With the Open Space Council, I've tried
to promote sewage treatment as a coming issue of the 1980's and we've been telling people that
they really should get in on the ground floor.
But have you ever noticed how people look at you real funny when you talk about sewage? It's
very interesting how our culture is set up to avoid even the discussion; even some of our water
people said, "Well, I'm really just into drinking water." So while I think it's great that there
is this kind of turn out on what is still a very unsexy issue, it is also amazing to me that more
people aren't interested. People will get upset about $10 missing in food stamps or something
along that line but when you talk about this incredible program of $25 million dollars in federal
funding alone, just for construction, it's amazing that the decision-making has been left to a
small group by themselves with no one else participating, with the exception of some environmental
groups and the League of Women Voters, depending on how advanced the state of the art is in each
state. Very few people are on top of this issue and following it.
We have altogether at this conference, this weekend, approximately 160 people. Half of them are
from Colorado and the other half are from 30 other states. Every single state west of the Missis-
sippi I think, except Alaska, is represented. There are also a few stray Easterners who missed
the D.C. conference.
TERRY STUART
On behalf of all of us at the Colorado Open Space Council, we are pleased to be your local host
for this conference. We hope that by the time it's over, you'll find out that the issue of sew-
age can be fun. Colorado Open Space Council was formed in 1964, as a coalition of 23 citizen
groups who are interested in promoting a better environment in Colorado. We have to name a
few—the Sierra Club, the Audubon Society, the Colorado Mountain Club, Trout Unlimited and
various other environmental groups, as well as some fanners groups. We are particularly pleased
today to see some new interests here—engineers,labor, agriculture, as well as the general public
that's generally associated with clean water. We believe that working with diverse groups of
people to achieve common goals is very important and we very much welcome the diverse group that's
here today.
The effort to become better shoppers for sewage treatment is clearly worth it. We can't afford
to waste water, valuable resources, money, or to lose our agricultural land. The aim of this
conference is to give us the information we need to better protect our communities, our water,
and our pocketbooks. To give us that information, we have assembled a stable of stars, the top
experts from around the nation on several topics. We're especially proud that so many of those
experts are from right here in Colorado. Our aim, however, is not to make all of us experts.
We don't plan to graduate Ph.D.'s in one week.
Our aim is to better enable us to control the expert: to give us the background we need to be
able to know when important decisions are being made, to be able to stop problems and find the
appropriate answers, to know when we need more information, to know where we can go to get that
information, and most important, to know some of the action steps we can begin to take to
achieve the sensible results that we want.
The first speaker today is Michael Gravitz. Mike is from the Environmental Policy Institute and
is its director and the organizer for these Shopping for Sewage Treatment conferences. As the
director of research for the Clean Water Action Project, he studied obstacles to innovation in
wastewater treatment technology. He prepared the recommendations which shaped the changes in the
latest amendments to the Clean Water Act. He's now at the Kennedy School of Government at Harvard
University in Cambridge, Massachusetts.
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SEWAGE: POLLUTANT OR RESOURCE? .
MICHAEL GMVITZ: The Environmental Pol-Lay Institute's director for the tao conferences on
sewage treatment. As Clean Water Action Project's Research Director, Gravitz
studied obstacles to innovation in waste treatment technology, preparing re-
commendations which shaped changes in the Clean Water Ast. Currently at the
Kennedy School of Government, Harvard University, Cambridge, Massaahusetts.
Sewage is about 99.94% water—that's pure, clean water. I'd like to talk to you about the
other .06% of sewage, which is just a little more than 1/20 of 12. We're dealing with a sub-
stance that is very dilute; it's mostly just water. There is organic material in sewage. Any
compound with at least carbon, hydrogen and oxygen in it is organic. Many bodily waste pro-
ducts are organic materials decomposed.
Why are we concerned about organic materials in sewage? Why bother? When this organic stuff
is dumped in streams or lakes, bacteria decompose the organic material — they eat it for food,
just like we do. When they do this, the bacteria consume oxygen. They breathe oxygen, not
quite like we do, but I can use the word breathe very freely I hope. If there's too much
organic material in the sewage, or in the stream, then too much oxygen is taken out of the
water, and fish or shellfish, which also need oxygen to live, can't get enough and therefore
they either can't live in those areas of the streams and they avoid them, or they grow much
more slowly. Water without oxygen in it also tends to smell very bad. There are bacteria
that live in water without oxygen called anaerobic bacteria. They don't use oxygen to breathe
and they give off commonly a hydrogen sulfide--or rotten egg--kind of smell.
Let me deal very quickly with some of the technical terms that engineers use all the time to
quantify the amount of organic material in sewage. I think it'll be very useful to you, and
I'm going to try to explain it very simply, so let me emphasize they're used all the time.
I think that's why they're valuable to understand.
Engineers call the amount of organic material in sewage BOD, which stands for biochemical
oxygen demand. They calculate the amount of organic material in sewage, the BOD, by following
several steps. First, they measure how much oxygen is dissolved in sewage or water initially.
Then they put this sewage into a bottle or closed container for about 5 days, at a certain
temperature. They let the bacteria eat the organic material. They then measure the oxygen
content of the water or sewage again and the amount of oxygen used up during this 5-day period,
or whatever period it is, is an indication of the amount of organic material in sewage. If
the period had been 5 days, the scientific way they would say it goes like this: "the 5-day
BOD is such-and-such " It's an indirect measure, not a direct measure, of this organic
material.
Engineers also use the terms parts per million, or ppm, or milligrams per liter, as units to
measure the amount of pollutants in water or sewage. One part per million equals one milligram
per liter—they're equivalent. So that shouldn't confuse you, if people switch back and forth
between them, or use one and not the other. For example, there are about 250 parts per million
oi" irri 11 igrams per liter of organic material in sewage when it comes into a sewage treatment
plant. To give you an idea about how little this really is, although the number 250 sounds
relatively high, one part per million is equivalent to one inch in 16 miles, or one minute in
1.9 years. But even these very small quantities of materials strongly affect a stream's
health or the things that live in the stream.
What else is in sewage? There are a lot of nutrients, or fertilizers, in sewage. Sewage
contains a lot of nitrogen and phosphorus. For example, each person puts about 12 pounds of
nitrogen per year into a sewage treatment system, and about 3 pounds of phosphorus. It may
not sound like a lot but when you multiply it by 10,000 or 50,000 people, you have an enormous
amount of fertilizer going into a stream. Just like the farmer who applies nitrogen and phos-
phorus to a cornfield and expects it to help the corn yield go up because of the fertilizer,
applying nitrogen and phosphorus to rivers and lakes increases the amount of plants and algae
that grow in those rivers and lakes. Algae are just microscopic green plants.
Why are nutrients a problem? Well, it's not really a problem until there's too much of those
fertilizers going into those streams. Like a lot of pollutants, there are low levels at which
we don't have problems, but there are higher levels at which we begin to have problems.
If there are too many nutrients in the water, we have too many algae. Those algae die.
They get eaten by the bacteria, because they are organic materials also. And these bacteria,
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again, suck oxygen out of the water depriving the fish and the shellfish of the oxygen they
need to live. This is the process called eutrophication. In addition, swimming in water that
has a lot of algae growing on it, is a very unpleasant experience. It could be dangerous too
because you can't see what's in front of you, in the water. And decaying algae smell a lot.
They often smell like rotten eggs.
Second point. When the nitrogen in sewage gets changed by bacteria, and they use a lot of
oxygen in that process, the oxygen demand is called NBOD, or nitrogenous biochemical oxygen
demand. That's another technical term. This NBOD often is greater than the amount of BOD in
sewage. So you have to be careful when someone tells you that there's a certain amount of BOD
in the sewage and you think, well, that's all the oxygen that it's going to take out of the
water. You should be careful and aware that there's also NBOD, which isn't measured in this BOD.
There are a lot of living organisms in sewage. Sewage has a lot of bacteria in it, for example.
They mostly come out of our intestinal tract; that's very normal. Most of these organisms are
absolutely harmless. These organisms can also include pathogens. That's why there's this wide-
spread impression that sewage is such a dangerous substance--that most of the organisms in
sewage are somehow dangerous and can make you sick. That is definitely not the case. The pre-
ponderdance of the organisms are fairly harmless. So big numbers should not really scare you,
because most of those things, for example, 10 million bacteria per quart, are basically harmless.
But some of them can make people sick, give people different kinds of illnesses. Tomorrow,
Dr. Sam Fogel will be talking more about these organisms and which kind are harmful and which
aren't.
One of the reasons we care about the amount of bacteria in the water is because we might want
to swim in it. If some of these harmful bacteria are around, they can enter cuts or bruises
or get swallowed by people, and people can get sick. Shellfish commonly accumulate bacteria
that are in water, and that's not good.
The next major grouping of things that I want to go into in sewage are called toxic materials.
These are materials that, even with small concentrations, can cause harm to humans or fish.
Commonly there are small amounts of pesticides, heavy metals, oils, and organic materials
that take a long time to degrade, or decompose, in nature. An example of this is something
we've heard a lot about lately, called PCBs —poly-chlorinated biphenols. PCBs are very diffi-
cult to degrade and very toxic.
Another toxic that is in sewage effluent is chlorine. Chlorine isn't usually in the sewage
when it comes into the sewage treatment plant. The treatment plant puts the chlorine in. Most
treatment plants use chlorine because they want to kill lots of the bacteria that are in the
sewage. Until a couple of years ago, people thought, "oh well, big deal, chlorine. You know,
it's important to kill these bacteria." But what we're finding out now is that chlorine and
its byproducts in sewage are very toxic, in incredibly low concentrations, to shellfish, fish
and fish larvae. It's just amazing. We're talking about a very low parts per billion range
at which they become toxic. In addition, ammonia is in sewage effluent. Nitrogen initially
leaves the sewage treatment plant in the form of ammonia, and can be toxic to fish and shellfish
in very low concentrations.
Finally, in rural areas of this country, people take their drinking water out of streams into
which sewage treatment effluents and industrial effluents have been dumped. A lot of these
toxic materials that we're talking about have serious human health effects. They can lead to
cancer and a whole host of other human ailments.
Now, there are drinking water treatment plants where we try to take out some of these toxics
before piping the water into our homes. But, typically, these plants weren't designed to take
out many of the toxics. We're drinking them. We're just beginning to discover what an enormous
health problem we have in this country with contaminated drinking water.
Let me go over the four things that are in sewage: 1) sewage is mostly water; 2) there are lots
of nutrients in sewage; nitrogen and phosphorus which, when farmers use them for fertilizers,
grow plants, and that's what they do in water—they grow lots of plants and algae; 3) there are
lots of bacteria and viruses in sewage; 4) there are normally small concentrations of various
toxic materials in sewage, some of which—like chlorine—we have put into the sewage to clean
it up in certain ways.
I'd like to answer some questions, if people have them.
QUESTION: I have one. The alternative to using chlorine—what other alternatives do you have
for a disinfectant?
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GRAVITZ: There are a couple. One is actually not a disinfectant at all. We heard something
about lagoons. Well, commonly, if you detain sewage for a long enough period of time, you get
a large natural dieoff of the bacteria and viruses in sewage. So for example, in some lagoon
systems, you don't need to chlorinate because the water is held so long that the populations
are so low.
Another alternative that people are talking about more and more is ozonation. In other words,
using ozone to disinfect sewage. Ozone is really 03. The oxygen we breathe is 02- It turns
out that 03 is very toxic for most bacteria and viruses. It's a fairly simple process to
create it. For anybody who lives in big, metropolitan cities where they have subway systems,
ozone is that acrid smell that comes from the electricity going through the air. If you've
ever been around an electric storm, you smell ozone. But when you put that into water, that
kills lots of bacteria and viruses. Ozone dissipates much more rapidly than chlorine and
doesn't stick around and combine with other substances that are toxic to shellfish and fish
and larvae.
There are a couple other possibilities people have talked about: using ultraviolet radiation
and other types of radiation to disinfect sewage. Those are less commonly talked about, but
some people have used ultraviolet light before. And all of those options are things that do
not, as far as we know now, contribute toxic materials to sewage effluent. It is true, you
can also boil, in effect, sterilize, effluent. But this is such an incredibly energy-intensive
process, if you do it under normal circumstances, that it's not a practical disinfection method.
QUESTION: I'm Jim Stone, a consulting engineer. I'd like to have your comments on the signifi-
cance of BOD in relationship to land application and also the significance of our Colorado
standards which require a coliform count of 200 on our Class A streams and several thousand
Class B streams, but less than two on your lawn. During our recent Memorial Day celebration
on the Platt River, we had boat races and kids playing in the water. That stretch of stream
was running about 10,000 coliforms per millimeter. It seems to me, as an engineer, that this
doesn't make sense. Shouldn't these inconsistent regulations be changed?
GRAVITZ: Mr. Stone, you're asking a couple of questions: 1) what's the importance of BOD in
land application; and 2) why should standards for bacteria in receiving waters or effluent be
inconsistent. In other words, why do some standards require very low amounts of bacteria in
water while other standards aren't so stringent. Let me answer the first one very quickly;
I think the second is a little more complicated.
BOD, or biochemical oxygen demand which is that indirect measure of the amount of organic
material in sewage, for most land treatment systems, isn't that significant. One of the
beauties of land treatment systems—one of the beauties of what happens in the earth—is that
it has a great ability to deal with large amounts of organic material. In fact, if you don't
put anything else onto the soil and if there aren't plants growing on it and decaying, bacteria
crunch up—they eat perhaps one to two tons of organic material per acre per year. So it's
actually a good thing to put organic material back into the earth. Sewage recycling systems
have been shown to handle incredible loadings or amounts of organic material put onto the land.
The second question is a little harder. Let me explain a little bit of the technical lingo
that we just heard. I explained that very few of the bacteria in sewage are harmful. Very
few of them are what scientists call pathogens, i.e., harmful bacteria. Well, since there are
very few of them, it's very hard to measure sewage for harmful bacteria. The tests are very
expensive and difficult. So we tend to use "indicator organisms." We tend to use organisms
that occur much more frequently in sewage and use those as an indicator of how many pathogenic
bacteria might be there. But again, it's kind of an indirect measure and it's real imperfect.
In fact, it's not a very good measure at all. So, fecal coliforms—the amount of fecal coli-
forms in a liter of water is an indication of the amount of bacteria in water, but fecal coli-
forms in themselves are not harmful to human beings. They're understood to be an indication of
the amount of pathogenic organisms that could be there. I agree with Mr. Stone that often
standards for bacteria are really Inconsistent. One of the main reasons for it is because the
fecal coliforms test is a very imperfect indication of the potential harm of the water that
you're swimming in, in terms of bacteria. I think that most states don't do a very good job of
setting fecal coliforms standards or bacterial standards, and it's basically because the infor-
mation that's available is not very good. People have not done very good research to date, or
at least those research results are not known yet. We just don't have good epidemiological
studies, or studies of increasing amounts of bacteria in the stream and how much disease people
get. So I agree with him, the standards are inconsistent. And we'd like to see those standards
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made consistent.
QUESTION: At what level does chlorine become harmful?
GRAVITZ: As I said in the talk, amazingly low concentrations. If I remember my facts right,
we are talking about concentrations of 5 to 10 parts per billion, which are levels that have
only recently been able to be measured, in fact. Much of my experience has been in the East.
I lived in Washington, D.C., and there used to be lots of clams and oysters in the Potomac
River; there aren't anymore, and people wonder why. It turns out that one of the reasons that
probably there aren't as many clams or oysters is because of chlorine. It comes out of the
sewage treatment plants and some of the electricity generating plants, where they chlorinate
the cooling water. It is killing off the larvae and making the reproduction levels much lower.
It's a shame and we ought to do something about it.
COMMENT: I'm Keith Johnson, of the Public Health Department for Mercer and Alburn counties
in North Dakota. One more comment on the subject of chlorine; one that wasn't emphasized
enough was the treatment of fairly heavily organic laden water with chlorine. It's been proven
just lately that chlorine links up with orgam'cs to form so-called "chlorinated hydrocarbons,"
like chloroform. They can be carcinogens. People are drinking, subsequently, the water out of
the same receiving water. It's starting to be implicated as a cause of cancer.
II. THE TECHNOLOGIES
A lay person's description of the systems, effectiveness of pollutant removal^
reliability., renovation mechanisms, climatic and seasonal effects, sizing and
cost, environmental impacts, and common problems with evaluations of the tech-
nologies.
INTRODUCTION
MICHAEL GRAVITZ
This part of the program is devoted to the kinds of sewage treatment technologies available,
where they can be used, how they work and what they cost. More than 99" of the federal funding
for sewaoe treatment has been spent on what are called conventional treatment technologies.
With that record of domination, it is easy to see why they are called conventional. They
evolved from a bygone day when an accepted solution to pollution was transportation—get it
away. Wastes were flushed into sewers, transported to the nearest rivers and lakes, dumped in,
then transported downstream.
There have been some improvements since then. First, so-called primary treatment can be added
on, a first stage of treatment which separates out part of the waste by gravity then dumps the
partially treated effluent into the water body, which still serves as the final stage of the
treatment process. The separated-out material, called sludge, must be then disposed of in
some other way.
When primary treatment is not enough to stop pollution from being intolerably bad, further
stages of treatment can be added on. They are called secondary and tertiary. But the basic
scheme remains the same: conventional treatment pipes the waste to a central treatment plant
in sewers, separates out some of the pollutants, and then dumps the treated effluent into the
stream.
One alternative is so-called sewage recycling plants, typically designed to use many of the
wastes in sewage in the process of separating them out, as opposed to simply throwing them away.
Examples of this kind of technology are land treatment or spray irrigation, or aquaculture,
where fish or plants are grown in wastewater.
The third technology we'll hear about is called sewerless systems. These systems either avoid
mixing the water and human wastes together to begin with or when they are mixed, they're
treated locally, either on the land that the house is on or in the neighborhood. These are
small decentralized systems.
The first presentation will be on conventional technologies.
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CONVENTIONAL AND ADVANCED WASTEWATER TREATMENT SYSTEMS
DR. JOSEPH HARRINGTON: Gordon McKay Professor in Environmental Engineering in the Department
of Applied Science, Harvard University, Cambridge., Massachusetts. A
member of the National Research Council's Subcommittee on waste treat-
ment, he holds a joint appointment with Harvard University 's School of
Public Health, where he has served for 15 years.
[The transcript of Dr. Harrington's presentation was not available in time for this
draft, and will be included in the final version of the proceedings. In the interm,
copies are available at the Clean Water Fund,]
DR. DAVID STENSEL: Manager of Biological Systems, Envirotech, Inc. Does research, develop-
ment and design of wastewater treatment systems which allow water to be
recycled for industrial uses, and which reduced energy consumption by 50%.
DR. DAVID STENSEL
The purpose of this paper is to provide a summary of the basis of selection for wastewater treat-
ment facilities and a brief description of the type of wastewater treatment designs available.
This brief description of conventional and advanced wastewater treatment systems will show that
the technology is continually changing in an effort to provide more economical and lower energy
wastewater treatment systems.
Need for Wastewater Treatment
The conventional concept of wastewater treatment has evolved into one in which the wastewater is
collected via sewer lines and delivered to a treatment facility for processing. The processing
plant can be designed using a variety of methods to remove certain pollutants. The discharge from
this plant is normally sent into a receiving stream or body of water.
The need for wastewater treatment began as a result of health hazards related to waterborn
diseases. Table I shows the various types of diseases that can be related to wastewater. As can
be seen, water can be used as a carrier for such diseases as typhoid, salmonellosis, dysentary,
and hepatitis. These diseases can be contracted by drinking the water or by eating food that has
been contaminated with the wastewater. It was these types of problems that originally initiated
the construction of wastewater treatment facilities. With a more industralized society other
types of water hazards have resulted. Table II summarizes some of these other possible water
hazards. These are essentially non-biological water hazards and are just as dangerous as the bio-
logical hazards. Table III summarizes the main problems associated with municipal wastewaters.
The most common problems, of course, are the bacterial virus danger and the heavy metal or toxic
dangers from industrial wastewaters. However, BOD and nutrients have also been considered a pro-
blem due to the higher standard of living experienced in this country. These pollutants degrade
the stream water quality making it undesirable for fishing or other forms of recreation.
The degree of treatment that will be used to remove these possible pollutants depends on the
ultimate use or reuse of the water. As Table IV shows water is used for human consumption or
for industrial processing. The actual pollutant(s) in the water depends on the original use.
The reason that the water is termed polluted is due to the fact that the water is unfit for further
use. The magnitude of the bar graph in Table IV indicates the degree of treatment required for
each water use. If the water is to be reused for drinking water, then the degree of treatment
must be quite extensive and sophisticated to provide a continuously safe drinking water supply.
The same is true for goundwater recharge since this same water can show up in drinking water.
Treatment for irrigation or agriculture use need not be as sophisticated since certain materials
can be left in the water and could be beneficial for agricultural use. These materials include
nitrogen or phosphorus which provide good fertilizers for plant growth but which would be undesir-
able for certain industrial uses or for recreational waters. Thus, the type and degree of treat-
ment will depend on the ultimate water use.
Factors in Selecting Wastewater Treatment Systems
Table V shows the type of mechanisms available for removal of pollutants in wastewaters. These
mechanisms are either phsyical, chemical, or biological. A chemical method involves the addition
of a material which will react with the material to be removed. Common examples of this are
phosphorus removal and chemical (i.e. ozone, chloride, etc.) oxidation of the wastewater for
either disinfection or odor control. A biological system is the most common type of wastewater
treatment process for removal of pollutants. In biological systems, bacteria are used to
-------
TABLE I
WASTEWATER RELATED DISEASES
SOURCE
DRINKING WATER
SHELLFISH IN POLLUTED
WATERS
VEGETABLES & FRUITS
CONTAMINATED BY SEWAGE
SOIL EXPOSED TO SEWAGE
FOOD CONTAMINATED BY FLIES
& VERMIN FEEDING ON SEWAGE
BATHING IN POLLUTED
WATERS
SEWAGE IN FOOD CHAINS
DISEASES
CHOLERA, TYPHOID, SALMONELLOSIS, BACILLARY DYSENTARY, WEILS
DISEASE, AMEBIC DYSENTARY, SCHISTOSOMES, INFECTIOUS HEPATITIS,
GASTROENTERITIS
TYPHOID, SALMONELLOSIS, BACILLARY DYSENTARY, INFECTIOUS
HEPATITIS
TYPHOID, SALMONELLOSIS, DYSENTARY, PARASITIC WORMS,
INFECTIOUS HEPATITIS
HOOKWORM
TYPHOID, SALMONELLOSIS, DYSENTARY, INFECTIOUS HEPATITIS
WEILS DISEASE, SCHISTOSOMES
TUBERCULOSIS IN COWS MILK, INTESTINAL WORMS FROM COWS
FEEDING ON IRRIGATED GRASSLANDS
TABLE II
OTHER POSSIBLE WATER HAZARDS
TOXIC SUBSTANCES FROM MINERALS
TOXIC SUBSTANCES MANUF. BY ALGAE
HEAVY METALS
INDUSTRIAL TOXINS
RADIOACTIVE SUBSTANCES
PESTICIDES REACHING WATER SOURCE
NITRATE FROM FERTILIZERS OF
SEWAGE TREATMENT
TABLE III
MAIN PROBLEMS IN
MUNICIPAL WASTEWATER TREATMENT
PATHOGENIC BACTERIA, VIRUSES
BOD
NUTRIENTS - NITROGEN
PHOSPHORUS
POSSIBLY HEAVY METALS
POSSIBLY TOXIC MATERIALS
-------
TABLE IV
REUSE DETERMINES
DEGREE OF TREATMENT
DRINKING WATER
GROUNDWATER RECHARGE
INDUSTRIAL USE
RECREATION
QTPFAM
REPLENISHMENT
I
I
AGRICULTURE
TREATMENT TECHNOLOGY DEPENDS ON
POLLUTANTS AND MATER REUSE
-------
TABLE V
WASTEWATER TREATMENT MECHANISMS
TABLE VI
FACTORS IN SELECTION OF
TREATMENT METHODS
TABLE VII
COMMON WASTEWATER TREATMENT
ALTERNATIVES
TYPE FUNCTION EXAMPLES
PHYSICAL SCREEN BAR SCREENS
SETTLE PRIMARY
SEDIMENTATION
FILTER POLISHING
FILTERS
ADSORPTION CARBON
TREATMENT
FLOTATION SLUDGE
THICKENING
CHEMICAL PRECIPITA- PHOSPHORUS
TION REMOVAL
OXIDATION ODOR
CONTROL
DISINFECTION
BIOLO- METABOLIZE TRICKLING
GICAL ORGANICS FILTERS
AND OTHER ACTIVATED
POLLUTANTS SLUDGE
NITRIFICA-
TION
PURE
OXYGEN
OXIDATION
PONDS
CARROUSEL
BARDENPHO
REQUIRED QUALITY OF TREATED
WASTEWATER
HEALTH AND SAFETY
TREATMENT RELIABILITY
CAPITAL COST
OPERATING COST
ENERGY
TECHNICAL KNOW-HOW
LAND REQUIREMENTS
EPA ACCEPTANCE
RESOURCE RECOVERY
SECONDARY PROBLEMS
ALTERNATE SYSTEMS TREATMENT LEVEL
CONVENTIONAL REMOVAL:
ACTIVATED SLUDGE BOD5 - 80-90%
SS - 80-90%
TRICKLING FILTERS
PLASTIC TOWERS
BIODISC
PURE OXYGEN
OXIDATION PONDS & FILTRATION
AERATED LAGOONS & FILTRATION
PLASTIC TOWER & ACTIVATED SLUDGE
CARROUSEL
-------
metabolize organics or pollutants that are not desirable for the environment. Basically, a
biological system is designed to enhance the biological metabolism so that the pollutants can be
broken down at a much faster rate and in a much smaller area than if the pollutants were dis-
charged into receiving waters. Table V lists the types of systems commonly used for biological
treatment.
With many advances being made in the wastewater treatment field over the past few years, there
are now a number of alternatives that the design engineer has for solving a particular wastewater
problem. The design engineer makes a selection of the wastewater treatment process based on a
number of very important factors. These factors are listed in Table VI. The table shows that
capital cost, operation cost, and energy are not the only factors that must be considered in
selecting a given process. With rapidly changing technology one of the key aspects in the selec-
tion is the determination of the treatment reliability of many of the new processes available.
Of course, the required quality of treated water is also a factor in selecting one system over
another. A big factor is the technical know-how and experience of the consultant engineer.
The EPA plays a role in the types of processes that they accept for wastewater treatment. Without
EPA acceptance the engineer cannot get his project funded. As the engineer will not want to
risk putting in a poorly performing plant, he must eigher see plants in operation or demonstrated
data of operation to provide him with the know-how necessary to design a new system.
Conventional Wastewater Treatment Systems
Wastewater treatment began with primary settling tanks. In the primaries the raw sewage was
directed to a large settling tank and the solid material that could settle would be removed from
the bottom of the tank. This is a rather crude form of treatment and only accounts for about 30%
removal of biodegradable organic material. The solid material from the settling tank would then
be removed for digestion or for disposal.
Wastewater treatment processes seem to have evolved by the addition of another treatment step to
accomplish each successively higher degree of treatment. Only recently has technology come up
with a single unit process that can eliminate successive steps of treatment. Following the pri-
many settling tank, it has been common to add one of many types of biological treatment units for
further degradation of the organic material. In addition to organic degradation, some of these
biological units could also oxidize ammonia to nitrate. The purpose of this ammonia oxidation
is to reduce the nitrogenous oxygen demand on the receiving stream.
The common requirements for any of the biological treatment steps are twofold: oxygen must be
supplied in the system to oxidize the organic material; and, the biological solids must be main-
tained in suspension to be available to continuously metabolize the organic material. The
methods of keeping the biological solids in suspension and of supplying oxygen distinguish one
system from another. Some of these methods are quite different and involve different levels of
energy due to the efficiency of providing the oxygen for the bacteria.
Table VII shows the common types of wastewater treatment systems used. The activated sludge
process is a tank where the biological solids are mixed. The tank effluent is directed to a
clarifier where the solids are settled and recycled back into the activated sludge tank for
reaction with the organic material.
Trickling filter (TF) systems involve rock or plastic media on which the biological solids can
grow, thus eliminating the clarifier for sludge recycle to the reactor. In TF systems, the
oxygen is provided by air passing up through the medium. Some problems with TF systems are the
ability to obtain a high degree of treatment and in many cases the capital cost is quite high
for trickling filter treatment. These systems also require a large amount of land area.
To decrease the land area problem, manufacturers have developed plastic media towers and biodisc
systems which are more efficient and use less land area. Figure I shows a sketch of the biodisc
system. The discs are rotated in the incoming wastewater and the biological slime growing on
the discs removes the organic pollutants from the wastewater. When a disc is exposed to the
atmosphere, oxygen is picked up by the liquid flowing in a thin film over the disc to provide
the necessary oxygen for metabolism.
In an attempt to decrease the size of the activated sludge unit, Union Carbide developed a system
called the Pure Oxygen System (see Figure II). In most activated sludge plants the atmospheric
air around the plant is used to provide oxygen into the tank contents. In the Pure Oxygen System
special generators are used to provide a gas with a high percentage of oxygen. The claim for
11
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FIGURE I
Rotating Disc Package Plant Details
Teed Mechanism —
/— 1st Staae
Disc Drive Motor
Effluent
Effluent
6'-2
Scoop Drive —'
Secondary Clarifier
Sludge
Discharge
-------
FIGURE II
PURE OXYGEN SYSTEM
CONTROL
VALVE PRESSURE SIGNAL
WASTEWATER
FEED
WASTE
ACTIVATED SLUDGE
c oiayom. ihrpe-staye Unox system.
-------
this system is that the oxygen can be generated at a lower energy than the energy required for
dissolution of the oxygen into the mixed liquor. This claim has been true for very very large
plants but for small wastewager plants (treating a population equivalent of 100,000 or less) the
energy requirements for the conventional system are much more favorable. In some cases, Pure
Oxygen Systems can be quite complicated for operation relative to the operator skill in a given
area.
Oxidation ponds are very shallow ponds (about four feet deep) where the wastewater enters one
end and after many days' detention time, the treated effluent exists from the other end. Aera-
tion is accomplished by the waving action of the water. The long detention time for the waste-
water in the system does result in organic pollutant removal.
Aerated lagoons are another form of the oxidation pond where mechanical equipment is used to
provide oxygen to the system. The aerated lagoons are much deeper and have better mixing for
the biological solids. Both of these systems require a fair amount of land area and can be
unreliable with seasonal changes and upsets in the lagoons.
Figure III shows a Dual Biological System (DBS) where a trickling filter is followed by an acti-
vated sludge tank. This combination can result in a more stable biological solids production and
more stable operation. In addition, the energy requirements are quite low for the very high
strength wastewaters.
All of these conventional systems require a number of pretreatment steps. The sludge from these
conventional systems is also sent to separate tanks for digestion.
A new process developed in Holland in the last 10 years—the CARROUSEL wastewater system—can
accomplish all of these treatment functions in one tank at minimal construction cost and energy
requirements. The CARROUSEL system is a unique method of using standard surface aerators and
standard concrete tanks.
The problems with the previously described conventional systems are the high level of complexity
due to all of the separate treatment steps and various pieces of equipment. This also results in
more difficult operation for the plant operator and higher maintenance requirements. When the
operation is more difficult for the plant operator and maintenance requirements are higher, the
effluent quality can be lower than desired due to the problems that the plant operator can
experience.
Due to the simplicity of the CARROUSEL system as shown in Figure IV, the equipment is minimal and
the operator requirements are also quite minimal. Host of these plants only have one operator for
plant sizes of sufficient capacity to treat the wastewater from 100,000 people or less.
Table VIII evaluates the various alternative systems on a qualitative basis for various aspects
evaluated for wastewater treatment. All of these factors must be considered in selecting a
given process to meet the effluent requirement established by the EPA.
Advanced Wastewater Treatment
Advanced wastewater treatment systems develop their name because when further treatment was
required such as removing nitrogen or phosphorus instead of just organic material, additional
unit operations were added. These operations were called advanced because of the newness of the
technology. Figure V is a good example of a conventional wastewater treatment system for nitro-
gen and phosphorus removal. A number of tanks and pieces of equipment are added in a long row
to achieve the higher level of treatment.
In addition, these systems many times require chemicals for either nitrogen or phosphorus removal.
In the case of phosphorus removal, the chemicals required can be very expensive. Their use
results in a sludge that is very difficult to handle and to dispose. Such systems become very
expensive due to the cost of the chemicals and also are very complex for operation.
This type of treatment has also been called a "physical-chemical" treatment system. In this
system, chemicals are added for sludge removal and for phosphorus precipitation. The effluent
is then passed through ammonia stripping towers for nitrogen removal. These towers have been
plagued by scaling problems and cold weather problems and are not commonly used anymore. After
this carbon adsorption is used for removal of organics. It has been found that biological
organic systems are more cost effective than activated carbon removal of organics with subsequent
carbon regeneration by thermal means.
14
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PRIMARY
EFFLUENT
DBS
FIGURE III
rrm
ROUGHING
TRICKLING
FILTER
TOWER
AERATION TANK
(2-6 hrs.)
FINAL
EFFLUENT
RETURN SLUDGE
SECONDARY
CLARIF1ER
INFLUENT
WASTEWATE.R
CARROUSEL FLOWSHEET
FIGURE IV
CARROUSEL AERATION
SCREENING
SLUDGE
DISPOSAL
SLUDGE
THICKENER
FINAL
CLARIFICATION
FINAL
EFFLUENT
15
-------
TABLE VIII
EVALUATION OF TREATMENT ALTERNATIVES
ALTERNATE
SYSTEM
CONV. ACT. SLUDGE
TRICKLING FILTER
PLASTIC TOWER
BIO DISC
PURE OXYGEN
OX. POND & FILTR.
AER. LAGOON & FILTR.
PLASTIC & A.S.
CARROUSEL
MAX. RANKING
TREATMENT
RELIABILITY
H
L
M
M
M
L
L
H
H
H
««,._
CAPITAL
COST
M
M
M
H
H
L
L
H
L
L
j : 80-90%
LAND
REQ'D
M
H
L
L
L
H
H
M
M
L
REMOVAL
OPERATOR
SIMPLICITY
M
H
H
H
L
M
M
H
H
H
HANDLE
SHOCK LOAD
M
M
M
L
L
H
H
H
H
H
EFFECT OF
TOXIC MAT'L
M
H
H
H
H
M
M
M
M
L
CLIMATE
IMPACT
M
M
M
M
M
H
H
M
M
L
RELATIVE RANKING: HIGH-H, MEDIUM-M, LOW-L
-------
TABLE X
ESTIMATED TOTAL COST FOR TREATMENT ALTERNATIVES
SYSTEMS
Convent ional
BODc Removal
EFFLUENT
QUALITY
BOD5 <30
1 MGD
61
TOTAL COST C/1000 gal.
5 MGD 10 MGD
32
26
Conventional
Nitri fi cation
BOD <20
NH3-N
75
40
30
Carrousel
BOD
43
25
20
Conventional
Phosphorus Removal
BOD
92
49
37
Carrousel/P
Removal
BOD
NH-N
46
28
24
Conventional
AWT-Nutrient
Removal
BOD5 <5
N<3
110
63
53
Physical Chemical
AWT
120
75
59
Bardenpho
Carrousel
60
35
30
Cost inc1udes:
Capital amortized at 5 5/8% for 20 years, power, chemicals, maintenance,
labor & sludge thickening and conditioning prior to dewatering or disposal,
-------
TABLE IX
EVALUATION OF ADVANCED WASTEWATER
TREATMENT ALTERNATIVES
ALTERNATE TREATMENT CAPITAL OPERATING OPERATOR HANDLE EFFECT OF
SYSTEM RELIABILITY COST COST SIMPLICITY SHOCK LOAD TOXIC MAT ' L
CONV. NITRIF. H M MM M M
CARROUSEL
CONV. NITRIF +
P REMOVAL
M
M
CARROUSEL - P
REMOVAL
M
CONV. AWT
PHYSICAL - CHEM
BARDENPHO +
CARROUSEL
MAX. RATING:
RELATIVE RANKING: HIGH-H, MEDIUM-M, LOW-L
-------
FIGURE V
-------
Another process termed the Bardenpho process Is a biological system that can remove the nitrogen
and phosphorus without the addition of chemicals. Special designs of activated sludge tankage
and sludge recycle results in the bacteria being able to carry out this type of removal.
Table IX summarizes the comparison of these various treatment methods for advanced wastewater
treatment.
Table X summarizes a cost analysis for these various wastewater treatment methods. The interesting
aspect of Table X is the fact that the CARROUSEL system can cost less than a conventional system
for BOD removal even though the CARROUSEL system gets a higher quality effluent. In addition to
this, the Bardenpho-CARROUSEL system which is an advanced wastewater treatment system for com-
plete nitrogen and phosphorus removal cost about the same as the conventional organic removal
system.
Summary and Conculsions
The concept of collecting, processing, and disposing wastewaters has evolved over the last 70
years into some very sophisticated types of wastewater treatment processes. The selection of
these processes recognizes the various constraints of a designer and recognizes the use or need
for the discharged water.
With more stringent requirements placed on the effluents, the type of systems that have been
designed have become very complicated and very expensive. New technology has been introduced
for removal of these materials at a much lower cost. With the EPA's emphasis on innovative
technology funding and new technology growth, it is possible that systems such as CARROUSEL and
Bardenpho will advance in the wastewater field for acceptance by engineers and EPA officials.
20
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SEWAGE RECYCLING: TURNING POLLUTANTS INTO RESOURCES
DR. JOHN SHEAFFER: President, Sheaffer and Roland. Former Advisor to the Undersecretary of the
Army; planned numerous innovative wasteuater treatment systems, including
Muskegon, Michigan.
JOHN MARSH: President, Engineering Enterprises. Specialist in total water resource management.
A civil and sanitary^ engineer who works with farmers to convert the nutrients in
urban sewage to agricultural use through recycling treatment systems.
J. FRANK GRAY: A Texas farmer, Gray has 40 years of experience farming with sewage from the City
of Lubbook. He negotiated his first contract with Lubboak in 1957, and has shared
his know-how with farmers across the country.
{The transcript of Frank Gray 's presentation of the land treatment system in Lubboak, Texas
was not available in time for this draft. It will be included in the final copy. In the
interim, copies are available at the Clean Water Fund.~\
DR. JOHN SHEAFFER
Let's look at what we as Americans expect when we're shopping for sewage treatment. There are
six situations I think we've been conditioned to expect. I'll go over them quickly. Perhaps
you have encountered these in your experiences.
We expect polluted water. Very few of us know what clean water is. We expect the waters around
major cities to be murky and turbid. Some of the most creative hurdles we have faced, in our
efforts to clean water, are raised by our officials who are allegedly controlling water pol-
lution. Their viewpoint seems to be that rivers have been made as convenient places to dump
wastes.
The next situation we've learned to expect is confrontation politics. We say that there is con-
flict between economic and environmental goals. You can either have clean water or a job or
clean air or a job. It is made to appear that to have clean air and clean water would be
economic disaster.
A third situation I have learned to expect relates to what I call technical distortion, and I'll
give you a few illustrations. Phosphate discharges into the Great Lakes were evaluated. The
lowest discharge came from Muskegon, .07 parts per million. The next lowest was seven times
higher than that. But the recommendations in the report did not suggest if we want to reduce the
discharge of phosphate into the Great Lakes, we should do what Muskegon did. It instead sug-
gested other courses of action.
Or I could point out a city where they compared alternatives of [conventional] advance waste
treatment and land treatment. The four-mile pipeline in a land treatment system was listed as
having average operation and maintenance costs of $770,000 a year. A reasonable price would
have been more like $50,000. With that magnitude of distortion, the two alternatives were
approximately equal. Or too close to call.
At a state water quality control commission, the alternatives being evaluated were biodisc and a
land treatment system that had an aerated lagoon. The evaluation concluded that the land treat-
ment system was far more costly. One member of the Commission asked, "How could that be? How
many people did you assume were going to operate the biodisc plant?" The designer said, "One."
The Commissioner then asked, "How many people are going to operate this aerated lagoon?" The
designer replied, "Fourteen." And there was the answer.
Enough for these kinds of distortions. I am not suggesting that everyone is deliberate. I am
simply suggesting that many factors are put into the equation by people who didn't fully under-
stand them, and therefore, you get the wrong answer.
A fourth situation to which we have all become conditioned is inflation. We expect public
services to cost more. And there are a lot of reasons why this is so. We have pursued energy
and chemically intensive solutions, and we have attempted to get rid of our waste streams. A
good illustration of this is that to replace the nitrogen that's contained in the annual flow of
wastewater in the United States, through chemical fertilizers that are petroleum-derived, which
requires the importation of 2.25 billion gallons of crude oil. Or another example is the phos-
phate industry that's a major power user in Florida. This expensive energy use and chemical
fertilizer production is much larger than it would be if we were not throwing away the natural
fertilizers in our wastes. And the cost of food is directly related to how we manage wastewater.
21
-------
Another situation which we have grown to expect, the fifth one, is frustration. I've heard it
said, that if you want clean water, get a swimming pool. Give up all the broad social causes
and get all you can for yourself. Unfortunately, many people on the campuses are taking that
attitude.
A final point is that we have learned to think negatively of waste. One can always get an
audience response, really roll them in the aisles, with the jokes about the four-letter word.
And this is frequently done. Thus wastes are not perceived in terms of chemistry, in terms of
biology. Rather they are looked at in terms of odor, disease, toxic substances, and low property
value. This neqative view is carefully taught. It's in our literature. It's in our slang
language. When we are depressed, we are "down in the dumps" and undesirable people are labelled
"trash." That's been put in us from the time we entered kindergarten. Because we are so program-
med, our generation may be a lost cause.
I'm here to suggest that hope is on the way. There is evidence that the next generation is
thinking differently. This is what motivates me to a large degree. If any of you have visited
Chicago, you've seen the beautiful, lakefront park system, and you may have wondered, why doesn't
every city do this? Well, let me tell you, when that was first proposed, it was not acceptable.
People said, "You can't do that. It's going to cost too much money. The railroad is along the
lakefront, there's industry. How in the world are you going to have a lakefront park?" Dan
Burnham, the planner who proposed the system took a year to visit every high school in Cook
County and explain to them what could be. Within a few years, the lakefront park system was
underway.
I have been spending a lot of my time in schools talking to students, teachers, and superinten-
dents. And in fact, our firm, as a public service, is working with the Chicago Board of Educa-
tion, the second largest school system in the United States, on energy and the environment. We
want to put the philosophy of recycling and reuse throughout the curriculum so that even kinder-
garten children can learn that everything is going to be someplace, and will inquire where that
someplace is. So that's my first basis for being encouraged.
Second, there is an emerging environmental philosophy which provides a framework for analyzing
environmental issues. Almost all, if not all of us in this room and many people in this metro-
politan area, know that the environment is a single system. Air, land, and water are constantly
interacting, and they affect, and are affected, by human activity. It can be said that every-
thing is related to everything else. This single interacting system cannot discharge. Everything
is someplace. It is possible to go through the most comprehensive technical report and inquire
where the pollutants are and in what form? We don't want the pollutants to emerge in another
form or location to further haunt us. So when you see some technical report, you can ask, what
happens to that pollutant? And where does this other one go?
The next element in the philosophy is that pollutants are resources out of place. One million
gallons of sewage would bring $130 in the fertilizer market today. For a community of 10,000,
that amounts to $47,000 a year. For a city with 100,000,000 gallons, that's $4,745,000 a year.
What community wouldn't give its right arm for an annual grant of that amount?
The environmental philosophy is helping to disseminate an understanding of sewage treatment. It
is being perceived as a separation process. There are a whole array of alternatives that can be
used to separate. One approach is conventional technology. It contains three steps. The first
one is called primary treatment, which is, by and large, mechanical. Skimming, screening and
settling are used to remove material from the wastewater. The primary step generally doesn't
malfunction, since it's physical. The second step provides biological treatment, or secondary.
A colony of bacteria feeds on the organic matter. Because it depends on living cells, it is
subject to periodic biological upsets. The third stage--"tertiary" or advanced waste treatment-
seeks to remove nutrients through a range of physical, chemical and ecological processes. In any
extent, anything removed must be taken someplace. The more effective the treatment, the more
material that has to be taken someplace else.
The conventional approach is what an economist would call non-productive. It's not producing
goods and services that can be marketed. Therefore, we need tax money to construct, operate
and maintain such systems. And as construction costs go up, we need more money. Federal and
state participation is a subsidy helping local units of government to construct these systems.
A land treatment system—some people refer to it as nature's advanced waste treatment plan—is
a productive multi-purpose system. It involves agriculture; it involves open space; you can't
do it on asphalt. You have to have land and you have to have growing crops or trees. Therefore,
it has the good air quality implications. It has implications with respect to urban sprawl.
22
-------
There are a number of processes that are contained in land treatment. The first one is pre-
treatment. You do not irrigate with raw sewage. How you pre-treat is going to be determined by
local conditions. I prefer a pre-treatment system that minimizes sludge production, because it's
difficult to handle and get rid of. The pre-treatment avoids nuisance conditions.
To beneficially use the pre-treated wastewater, storage must be provided. Crops don't need to
be irrigated during the non-growing season and you don't want to be irrigating when you're trying
to plant or harvest the crop. So you need a means of storing.
Incidentally, that's a U.S. contribution to the technology. Many people say, "Well, there were
sewage farms in Germany, Australia, Paris." But the one thing they didn't have was storage.
When it was raining eight inches during the day, they had still to irrigate. When the ground
was covered with snow and a mess, they still had to irrigate. Those of us in America, and I
think it's an American contribution, we said, "Hey, we can store it, and irrigate it when the
crops need it." Very simple. A contribution which made land treatment work, one which made
Muskegon quite different from any other land treatment system in the world. We select the
storage to fit the area we are in. The amount of storage is obviously dictated by the climate.
After storage, we irrigate. The irrigation of the pre-treated, nutrient-rich stored water takes
place at an appropriate site on selected crops. Wastewater with a high concentration of cadmium
should not be used to irrigate leafy crops, like lettuce. Cadmium will be accumulated in the
leaves. There is a wide range of crops to consider. There is a wide range of wastewater char-
acteristics.
What happens when wastewater is put on the land? Some of the nutrients are recycled by the
plants. The organic matter is added to the soil to enrich it and improve its tilth. Pollutants
not recycled generally are confined and contained. Some are not. Salts which are dissolved in
the wastewater may flow through the soil. Therefore, any properly designed land treatment
system is going to have an under-drainage system that is going to collect this material so that
we can avoid two problems: salt build-up [in underground water] and water-logging [of the soil].
Heavy metals are primarily confined. A few of them will migrate or be taken up by the plants.
That's why I used cadmium as an example. That's the most difficult one to deal with. Therefore,
we have to plant crops, if we have a cadmium-rich wastewater, that aren't going to be affected
adversely by the cadmium.
With the under-drainage system we come out with reclaimed, purified water and crops. We have a
productive system, one which has the potential to increase our production of food and fiber.
The federal and state participation can be viewed as an investment in the production of future
food and fiber. That's one reason why the 1977 Amendments to the Clean Water Act provide 10%
bonus [for land treatment]. The justification is that federal money in innovative and alternative
systems such as land treatment is an investment in the production of future food and fiber. There
are working examples of large-scale land treatment systems. The Muskegon County Wastewater
Management System is the best known. Muskegon has had problems. It was a first. Irrespective
of the problems, it's gone through its second year with essentially a million-dollar crop return
on the County's wastewater. I don't think there's any other system that can claim that. There's
a report about to be released on the social/economic effects of the system. Muskegon was a very
poor agricultural area prior to it. It is now one of the leading agricultural counties in Michi-
gan. Sales of fishing licenses, particularly 3-day out of state licenses, increased drastically
in Muskegon. New plants were located there. Existing plants were expanded. All the so-called
good things to a Chamber of Commerce took place in Muskegon. Yet, the staff at the National
Chamber of Commerce has not been encouraging efforts to allow communities to recycle their
wastewaters. I believe the economic issue is resolved. There are enough examples of land
treatment systems to show that large systems are viable, both in the humid and the arid parts of
our nation.
Legislation is changing. I refer to the 1977 Amendments. Dave Zwick [of the Clean Water Action
Project] would agree with me, when the 1972 law was passed, we thought we had solved the problem.
When Senator Muskie went on the floor of the Senate and said the Federal Water Pollution Control
Act Amendments of 1972 mean one simple thing: "streams are no longer a part of the sewage treat-
ment process," it appeared that we were on the road to clean water. Little time elapsed, how-
ever, before pollution administrators were trying to figure out the assimilative capacity of
streams. They were working out waste load allocations, sophisticated models to see how much
pollution we can put in the stream before we break its back. That showed me that legislation
probably would never solve the problem. The Clean Water Act of 1977 has the 10% bonus and they
set aside money Twhich only can be used for innovative or alternative sewage projects]. Hopefully,
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efforts to work up some administrative criteria for that law so that we can simply continue to go
the way we've been doing will be thwarted.
There is encouraging action. On October 3, 1977, the Administrator of the EPA put out a strong
directive on recycling. If land treatment is not recommended, the community Is to explan why it
could not do it. State water pollution control commissions are approving recycling systems,
sometimes against the recommendations of their technical staff. The Northglenn, Colorado system
is proceedinq. Northqlenn said there are better ways for cities than to condemn farmers' water
and to put farmers out of business. A better way is to borrow the water. Northglenn uses the
water in the city, then returns it to the fanners with a 10% bonus or interest payment. The
10% water bonus is secured in part by trapping storm water, treating it like sewage, and taking
it out to the farmers. This approach, incidentally mitigates flood problems downstream.
There are many private actions taking place in the U.S. right now. Lubbock Christian College has
signed a contract with the city of Lubbock, Texas. For 20 years they're going to take the
effluent from Lubbock and they're going to irrigate farm land which was donated to the College.
They'll have the potential to realize as much as a million dollars a year, the equivalent of a
$20 million endowment fund at a 5% return. El Reno, Oklahoma will be selling its effluent to a
private farmer. A large real estate firm is planning to take all the wastewater from a large
development including a 500-room luxury hotel and 6 million square feet of rentable commercial
and office space, and recycle it on their site—irrigate the greenery around the buildings. Why?
Because it is the most economical way.
Arguments that it costs too much to go to land treatment certainly are paling in the light of
such evidence. The private sector selects the most efficient systems, because they have to pay
for them without federal or state grants. Self-contained wastewater urban systems are being
more and more frequently articulated as the goals of new urban development.
What does this all mean? We're going to clean up our water. Not because we want clean water—
and that hurts me, as an idealist—but because we want the material that causes the pollution.
We can't afford to pollute our streams. We need the nitrogen, we need the phosphorus, we need
the organic matter. Pollutants, or displaced resources, will be used rather than discharged in
the water.
The only conjecture is, when? Properly informed citizens are getting the upper hand. There are
examples of success in Northglenn and Lubbock and El Reno, in Salisbury, Massachusetts, and Nan-
tucket Island, and in the Chicago area.
The management of wastewater as a resource in a comprehensive program is an idea whose time has
come. Now is the time to get involved. I'm striving to break the shackles of polluted water,
confrontation politics, technical distortions, inflation, frustration, and negative attitudes
about waste. I'm looking forward to clean water!
JOHN MARSH
I'm going to talk about the three types of land applications systems that are in the literature,
and that are being utilized today. I'm not too fond of a couple of them, although they have
their applications. I'll discuss the three methods in order of their increasing ability in pol-
lution control performance, which is also the order of the degree to which they accomplish
recycling. I really do believe, as Jack Sheaffer mentioned, that everything's got to be some-
where. And I think it's got to be recycled or spread back out, not accumulated.
The first type of land application system which is the least effective at removal of pollutants
and the least effective at accomplishing recycling, is known as infiltration-percolation. With
this technique, a wastewater that has had primary or secondary treatment, is simply percolated
into the ground and groundwater. It doesn't take much land, as hydraulic loading rates are high.
A typical system would use from 10 to 25 acres of ground per million gallons a day of wastewater
or roughly 10 to 25 acres per 10,000 population. Obviously, this accomplishes high recharge to
the groundwater table. It may not discharge the best of water, but it does have that benefit of
high rate of recharge to the groundwater. It does not recycle contained nutrients. So it's low
on my list of technologies that are applicable today.
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The second type of land application technology is a little higher on the scale in accomplishing
recycling and renovation. This system is called overland flow. With this technique, primary or
secondary treated wastewater is spread on the ground through sprinklers or other distributing
devices. The ground receiving the wastewater slopes very gently, at maybe two or four feet per
hundred feet. This system will treat a relatively raw wastewater. For example, a wastewater
that has been settled in a tank for maybe 10 or 30 minutes.
Now, strangely enough, various grasses can be grown on those slopes. And strangely enough, this
is most applicable where the soil is very tight, like clay, which will not accept much water.
The water runs overland and through the grasses and the treatment takes place partly on the
grass—the grass uses some of the nutrients. But by and large, most of the renovation takes
place in the upper 1/8 or one-quarter inch of the soil. As the water tumbles down the slope in
this upper 1/8 or one quarter-inch of the soil, ammonia is oxidized in the surface of the soil.
A little further down, a reduction of nitrates is accomplished (nitrogen goes off into the air
as a gas). Overland flow does not contribute to groundwater recharge, but it does discharge an
effluent better than many of the older conventional secondary treatment process and it is con-
siderably cheaper. There are several of these systems around the country which are quite suc-
cessful . These systems have to some extent been made famous by the Campbell Soup Company who
had good results with this type of system.
The third and best type of land application system is irrigation with pre-treated wastewater.
Roswell, New Mexico, for example, uses this technique. At Roswell, the wastewater undergoes
conventional secondary treatment before it is sold to farmers for use in the irrigation and
fertilization of forage crops. It's actually rather a shame to spend the money to treat the
wastewater in a conventional secondary treatment plant prior to irrigating forage crops, because
the secondary treatment is expensive and removes some of the goodies which would be a benefit on
the field. While there may be some application where that would make sense, usually it would not
be warranted. The degree of pre-treatment depends on the soil and type of crop to be irrigated.
Too much pre-treatment increases cost and reduces benefits. For an extreme example, one would
not design tertiary treatment in a system to irrigate hay.
The irrigation technique accomplishes very high removals of suspended solids, BOD, phosphorus,
nitrogen and the heavy metals. Further, research produced at Muskegon by EPA shows good removals
of most of the feared toxic organics. Research performed at Roswell, New Mexico, shows 100% re-
moval of viruses with slow-rate irrigation techniques. The irrigation technique is best, over-
land flow is next best, and direct infiltration is the lowest on the ladder of land application
techniques.
QUESTION: What's your largest city?
MARSH: One large city that's using these systems is Muskegon, Michigan. That is designed for
44 million gallons a day.It's in operation now at something like 25 to 30 million gallons a day.
Melbourne, Australia is the largest. There, an irrigation system has been in operation since the
turn of the century. There is a two-and-a-quarter million population whose wastes are treated by
irrigation of a 20,000 acre beef ranch. Part of the area is irrigated with raw wastewater and
part with secondary effluent. There is a guest house in the middle of the farm. The recycling
program is really considered a use of the resource for the benefit of the public, and they grow
beef there and have for years and years.
A significant wastewater irrigation project is under construction at El Reno, Oklahoma. The
system is designed for a 25,000 population. It will be completed in December 1978. The plan-
ning was begun in 1973, so accomplishing this recycling project has been a lengthy process.
El Reno is on the North Canadian River, in a three or four mile wide river alluvial valley.
This alluvial valley is filled with sand, gravel, silt and clay to a depth of around 50 feet.
Two reservoirs are located on the river, about twenty miles downstream. The reservoirs supply
water for Oklahoma City. Water wells adjacent to the river supply water to Yukon, Oklahoma,
about ten miles downstream.
This river, like so many rivers, has been receiving the wastewater, treated or untreated,
depending on the situation, from various towns for years and years. The permeable alluvial
valley is saturated with groundwater. Much of the land in the flat valley is irrigated. There
is a very strong, competing demand for the limited amount of water in the Canadian River valley.
The irrigators need and use it. But likewise, the municipalities need water.
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Consider what's been happening historicany--the fanners produce water from wells for irrigation.
The cities also use groundwater, and then discharge the wastewater into the stream to fertilize,
and therefore pollute, the river and downstream reservoirs. This competition and pollution con-
dition set the stage for an exciting project. Now the city will get the groundwater from the
farmers and the farmers will use the nutrient-rich wastewater to irrigate and fertilize the crops
instead of fertilizing the river.
The system consists of simplified lagoon pre-treatment and conventional center-pivot irrigation.
The simple lagoons function as storage reservoirs also, allowing the water to be used only when
it's beneficial to do so--that is, the crops will be irrigated only when they can utilize the
nutrients. They will not be irrigated during freezing or wet weather.
A significant thing is that in the development of the project, an objective was to get the
farmers involved in the project, and to establish an air of competition for the wastewater. For
sure, that wastewater is very valuable. It contains the water and the nutrients. So early in
the project, we met with seven different groups of farmers, some near the proposed lagoons, some
across the river, some upstream and some out of the valley, and talked with them about this con-
cept. They seemed to like it. We held those meetings a couple of times during the planning and
design process. It's hard for a civil and sanitary engineer to talk with farmers because engi-
neers are not noted for their knowledge about agriculture. So at first it was difficult to gain
their respect, although I could tell they thought this system would work. So we called in
Mr. Frank Gray from Texas. He is a farmer who has used wastewater for years. He helped to gain
the confidence of the farm community. And after competitive proposals from the farmers were
reviewed, we signed a contract with one of the farmers to use the wastewater on his land.
We did not have to buy the land. The farmer is paying the city a significant sum of money for
the wastewater, nutrients, and use of the equipment. In addition, the farmer operates the irri-
gation activities. And, most importantly, the farmer has transferred to the city his ground-
water rights in an acreage equal to the acreage that is irrigated. So, in return for the waste-
water, the city will realize from $200,000 to $300,000 in actual value—in payments, services
and water rights.
Further, we have really doubled the water resource—because every gallon of wastewater used for
irrigation will free up one gallon of groundwater for use by the municipality that would other-
wise have been used for irrigation only. The cost for this system handling 2.25 million gallons
a day was $1.3 million or about $600,000 per million gallons a day capacity. The cost per
1,000 gallons processed is about 19
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SMALL-SCALE ON-SITE SYSTEMS
JACK ABNEY: Senior environmental planner, Parrot, Ely, and Hurt, Lexington, Kentucky.
Abney works with local agencies in dealing with prohibitive health regula-
tions for implementation of on-site disposal systems. Planned the Fountain
Run (Kentucky) facility plan, one of the first in the nation to consider on-
site and cluster disposal systems. Emphasis on favorable ecomomia and
environrrtental impacts for users.
DAVID DEL PORTO: President, ECOS, Inc. Specializes in appropriate technologies. Citizen
Chair of Massachusetts ' Appropriate Technology Program.
PATRICIA NESBITT: Co-author of Goodbye to the Flush Toilet. Consultant and specialist in
water and sewer issues, Strasburg, Virginia.
CARL LINDSTROM: Technical advisor, Clivus Multrum, U.S.A., Cambridge, Massachusetts.
An engineer who has specialised in composting, Lindstrom was responsible
for research on waste treatment technologies at Sweden's Environmental Protec-
tion Agency, before becoming the Environmental Attache to the Swedish Embassy.
ABBY ROCKEFELLER: President, Clivus Multrum, U.S.A., Cambridge, Massachusetts. Clivus Multrum
manufactures the oldest Swedish waste composting system.
SMALL SCALE SYSTEMS: AN ALTERNATIVE TO THE URBAN MODEL
JACK ABNEY
EPA's Thomas Jorling was quoted in the Journal Water Pollution Control Federation, August 1977,
as making a statement like this: "There shouldn't be such a thing as a sewer system from the
individual household. It is just nonsense that we do it that way." He's expressed an opinion
which is held by a growing number of people in this country. Some of us have seen that our
traditional centralized urban approach to the wastewater planning problem has not solved the
problems in all communities in the manner in which we had hoped.
This basic urban approach could be stated in two basic concepts: the primary concept is that the
ultimate goal of wastewater planning should be regionalization of all wastewater collection and
treatment. And this has resulted in extension of sewers through undeveloped land, construction
of treatment plants which replace other treatment plants, and regionalization of these systems.
And increasing costs for wastewater management.
Part of this concept included the oft-repeated statement that septic tanks and other on-site
systems should be judged as only temporary, until sewers could be provided. In addition, it was
felt very strongly that all good systems were scale versions of centralized urban systems, even
in very small towns. Economic and environmental costs of centralized systems were considered
inevitable, if considered at all. In fact, before the 1972 Clean Water Act and the resulting
facilities planning guidelines were published, the consultant often merely wrote a feasibility
study and presented one alternative with no consideration of an environmental impact at all.
This was a very common practice and was part of the reason that consultants resisted the facil-
ities planning guidelines.
Since local funds were often inadequate for construction of centralized systems, federal funds
were demanded, and that was part of the pressure for a revised Clean Water Act in 1972 and
increased funding, which was increased to 75%.
There are some disadvantages to this urban approach, as we are now beginning to realize. First,
the economic cost was found to be a disadvantage in many areas. Economic costs became dispro-
portionate where certain key social and environmental conditions departed from the typical urban
model by more than certain amounts, and we have begun to recognize some rough rules of thumb.
One guideline says that where the cost per family for a community's sewage system exceeds 1% of
average family expendable income, the system should not be considered a proper alternative.
Well, we find that the costs of a centralized system are high where population density is less
than 10 persons per acre. Where the topography is flat or rolling, costs are increased. Where
the depth of bedrock is less than six feet, and where unstable soil conditions exist, the costs
of centralized systems are greatly increased.
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The environmental costs can include property damage done by blasting, which sometimes results in
rocks going through roofs, or foundations being cracked or windows broken. But there are also
negative primary impacts—direct impacts of the plant itself—from sewage plant operation. These
often stem from the plant's failure to meet the design effluent criteria or perhaps failure of
operation, such as through neglect. Other negative primary impacts may, in some areas, include:
exfiltration, which is seldom considered by consultants; overflows due to storm water or other
overloads; and pump failures. Secondary impacts would include unplanned growth resulting from a
sewer construction project, which perhaps would have an impact on air quality in some areas.
Now, there are changes occurring in wastewater planning. We are beginning to realize that on-
site systems may in many places have a proper role in community wastewater planning. Advantages
of on-site treatment and disposal systems may include: lower monetary cost to users; reduced
primary and secondary environmental impacts (as compared to sewers, of course); the possible
development of marginal land with on-site systems, where sewers would be too costly to install.
Sewers, of course, are most economical in prime farm land—with deep soil, moderate slopes and
so forth.
On-site systems may permit the development of residential lots of a large size, such as one
acre or more, where this is desired by the community or the people. Remember, the persons
utilizing on-site disposal are taxpayers, and they may not have been getting an equitable return
on their tax dollars under previous policies. Bosly, in Indiana, analyzed the assessed evalua-
tion of sewered versus unsewered properties in that state. He found that there were approximately
6.6 billion dollars worth of property in assessed evaluation served by sewers. On the other hand,
there was 5.3 billion assessed evaluation of property not served by sewers. According to the
1976 wastewater needs survey, those properties had no wastewater needs, at least not officially.
Populations using on-site wastewater disposal were virtually ignored in the needs survey.
But some recent policy decisions have begun to change the traditional concepts about wastewater
planning. Primary among these would be U.S. EPA program guidance memorandum 77-8 which was
issued June 21, 1977. It established requirements for considering on-site disposal in a commun-
ity's wastewater plans. It stated that future collection systems must show that there's an
adequate capacity for treatment, that there's an adequate population density for sewering, that
there's documentation of any claimed health or groundwater problems caused by existing on-site
systems. It stated that if it is claimed that there are site restrictions against the use of on-
site disposal, these must be carefully documented. The planner wishing to install collection
must also identify the nature, number and location of malfunctioning on-site systems. And fin-
ally, it's required that any sewers proposed be shown to be clearly more cost-effective than on-
site systems. Particularly where population density is low.
Alternatives which were required to be considered by this memorandum include: improved operation
and maintenance of on-site systems; new septic tanks; holding tanks; truck transport; mounds or
other designs for overcoming site limitations; clustered systems; water conservation systems; and
partial sewering, as of a simple small business district in a small town. The Clean Water Act of
1977 also contains provisions which should enhance the consideration of on-site disposal, as
you'll learn later in this conference.
Some states have taken positive actions, independently of the federal EPA, to encourage the con-
sideration of on-site wastewater treatment and disposal. Chief among these would be the Illinois
EPA. Guidelines used there parallel the new federal guidelines, and they also provide screening
criteria for planners and engineers.
There's increasing activity related to the development of technical manuals. Design manuals are
considering on-site wastewater alternatives. These have been funded byttie EPA. A new manual
for on-site wastewater system design should be available in about a year.
What are some examples of on-site wastewater planning? There are some on-site services provided
by local governments, mostly in California. These would include county health departments, which
may design and provide some maintenance, or at least maintenance inspections, to all on-site
systems, and perhaps order the pumping of septic tanks, or the repair of leaking absorption
fields after this annual inspection. In some counties, there may be established specific sub-
divisions which have public maintenance of on-site wastewater systems. Some special districts
have been established. These include the Santa Cruz Countywide District in California and the
Georgetown Divine Utility District in California, which was established to provide on-site
systems design, construction inspection, and operating assistance to a large sub-division develop-
ment. One community, Bolinas, California formed a utility district to manage on-site systems to
avoid the extention of sewers, which they felt would change the nature of their community.
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There are a few community wastewater plans which have, as of this date, to my knowledge, con-
sidered on-site disposal. These would include: Fountain Run, Kentucky, by Parrott, Ely, and
Hurt Consulting Engineers--! was involved in developing that plan; and East Ryegate, Vermont
by Dufresne-Henry Engineering Corporation. There's one other—I don't know where it stands now--
in Boones Mill, Virginia, which had some consideration of on-site disposal systems. Other plans
are probably being developed under the impetus of the new criteria published by EPA.
The community of Fountain Run, Kentucky, was one where we considered four basic alternatives.
These included gravity sewers and central treatment—the conventional urban approach; effluent
sewers and central treatment, an almost conventional approach; community clustered subservice
disposal; and total on-site disposal. Fountain Run is at present an unsewered community. There
are no sewers, except for house to septic tank sewers, in the entire small town. There are about
350 people living there. They have a water district which provides public water services. But
they have no wastewater services, other than those provided by private contractors and perhaps
the county health department in a regulatory sense.
We found that the aravity sewer alternative had a very high cost in Fountain Run and would, in
fact, cost about $17.30 per month per user in 1976. That was assuming that the collecting
system would be eligible for federal funding at this 75% level. Since then, we've found that
EPA would be unlikely to fund all of the collection system, and therefore, the community would
have a higher monthly cost than $17.30.
The second alternative was for the installing of septic tanks, or upgrading septic tanks in each
home and carrying the septic tank effluent to a central system. That alternative would cost
about $12.80 a month, some savings but still beyond the means for many of the older retired per-
sons living in that community.
The third alternative, clustered subservice disposal systems, had a projected monthly cost of
$7.30 per user. This was a $10 a month saving over the conventional system, and the people felt
that perhaps this was within their means.
The final alternative, complete on-site disposal at each individual business and residence, was
rejected by the local people because they felt that it would not be that much different from
what they already had; they did not recognize the advantages of properly designed and maintained
on-site wastewater systems.
So the partial sewering—that is, sewering by collecting septic tank effluent and gathering the
effluent in small diameter plastic pipes for disposal at a few locations—was the alternative
which was selected by the local community. This decision was the result of a public hearing
and much discussion. It consists basically of 22 subservice disposal areas in the community
which would serve the majority of the 144 potential customers. There would be an additional 20
or so individual on-site systems which would also be publically managed, if the residents desired
that type of management system.
It can be seen that the subservice disposal alternative, although very unconventional and not
providing the growth potential that a conventional sewer may have provided, was clearly the most
desirable alternative in this small community. Not only would the economic costs be lowered,
saving the local people approximately $10 a month on the average sewer charge, but also the
environmental costs, or environmental impacts, would be lower with this alternative than with
the conventional centralized system.
Application of this concept is hindered by several factors. They include the growth psychology
which is prevalent in some areas, prejudice against septic tanks and against four-inch sewers
which would not have any manholes, and a lack of profit incentive for change agents such as con-
sultants and developers.
Some persons have expressed strong concern about the possible groundwater contamination resulting
from on-site disposal by subservice application. There have been several studies of groundwater
which did not show significant impact from subservice disposal of septic tank effluents. These
include a University of Michigan study at Travis City, Michigan, where sandy soils and high
groundwater combined to provide conditions which would normally be thought of as conducive to
groundwater contamination. But the researchers in that study could find no correlation between
any parameters related to septic tank effluent except nitrate. They predicted that by 1998, if
growth continued in the Travis City area, that nitrate as nitrogen might rise to about 2.7 milli-
grams per liter. This is approximately one-fourth the drinking water standard. Therefore, no
serious result or affect on groundwater could be predicted in that area. There's another study
by the U.S. Geological Survey in Dade County, Florida, where 170,000 septic tanks existed. The
U.S. Geological Survey could not find a correlation between groundwater quality and subservice
disposal or septic tank effluents.
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The longevity of septic tank systems, absorption systems in particular, has been questioned by
many persons. I've often heard it said that the average septic tank system only lasts about
seven years. Some studies have found this to be untrue. The Connecticut Agricultural Experiment
Station in 1974 published a report which summarized their findings in one Connecticut town. They
found that in dense glacial till, the least permeable of the soils studied, that the half life
of septic tanks equals 38 years. That is, in 38 years, one half of the systems could be expected
to fail.
In a study for Marin County, California, by Brown & Caldwell, the consultants concluded that two
1500 square foot areas used for absorption alternatively, that is, on alternate years, would pro-
vide use for the life of the dwelling without fear of significant percentages of failures.
So we can summarize by saying that traditional sewers and centralized treatment of wastewater has
not been a very successful means of wastewater management in many places. Also recent federal,
state and local actions have enhanced the viability of on-site wastewater management alternatives,
including septic tanks and subservice absorption. And finally, the use of on-site alternatives,
may result in lowered monetary and environmental and land use impacts.
AQUACULTURE AND OTHER SMALL-SCALE SYSTEMS
DAVID DEL PORTO
We can't really dispose of anything on this earth unless we take it to outer space; all things
do return. Our wastes have been returning with a vengeance. We have to connect our plumbing
with the natural cycles for the greatest benefit and the lowest cost to us all. We have to
treat nature as an ally and not as an adversary. Thomas Elliot said: "The end of all exploring
is to return where you started and know the place for the first time." This is especially true
when we're talking about discovering that our adversaries can be allies.
One adversary that can be an ally is the hyacinth. The National Aeronautic & Space Administra-
tion has actually been trying for a long time with federal monies to figure out how to eradicate
this pest, and unsuccessfully. Millions and millions of dollars have been spent trying to poison
it in Florida because it literally takes over the waterways. One day they discovered it might be
a benefit. They fed some of this plant, literally, some raw sewage. It started to grow at a
very, very fast rate. So fast, in fact, that it was completely taking over the very small
lagoon that the raw sewage was going into. The uptake of nutrients produces roughly anywhere
from 8 to 16 tons per acre of green material per day feeding on raw sewage. A single acre of
sewage growing hyacinths can produce enough biomass to generate 3,000 to 7,000 cubic feet of
methane gas daily, which, in a sense, is cogeneration. The by-products, of course, can be used
for feed stock because it is very high in protein. 25% is crude fiber.
Greenhouses can be added to the pond treatment system, increasing the temperature and boosting
the process. This is an aquaculture system. Here's a system where all of the wastes that we've
been talking about all become resources—from energy to industrial use of water.
The city of Hercules, California is currently planning a waste treatment plant utilizing water
hyacinths and other aquatic polycultures.
Another aquaculture plan has a series of ponds—aquacells—filled with the water hyacinths,
accomplishing secondary and advanced treatment. This is followed by sun filtration and then
disinfection. (I know of places where ozone is used rather than chlorine, because ozone doesn't
have the propensity to form substances with carcinogenic properties that may be attributed to
chlorine.) The treated wastewater could then be sent into a reservoir where it is reclaimed for
agricultural and industrial uses. The treatment ponds vary from six to eight feet in depth,
which seems to be the ideal depth for the polyculture. Fish can be used along with plants to
eat the sewage. The fish are harvested. The plants are also harvested daily and put into a
methane generator and the methane provides the fuel to heat the'solar ponds.
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WATER-BASED ON-SITE SYSTEMS: THE SEPTIC TANK REVISITED
PATRICIA NESBITT
This is a brief overview of the actual technology involved in on-site treatment. My talk
will deal primarily with water-based systems—that is, systems that still use the flush toilet.
There are on-site systems that get away from the flush toilet entirely, which I'll leave to
other speakers.
Generally on-site treatment refers to privately owned and operated septic systems comprised of
a septic tank and leach field. There are variations to the standard septic system, which I will
describe later. The Clean Water Act of 1977 gave all these on-site systems a boost by making
them eligible for federal funding under certain circumstances, even when they are privately owned.
The purpose of on-site wastewater treatment is no different than any other kind of wastewater
management. The intention is to provide for safe disposal of all wastes in a way that prevents
the contamination of surface water, groundwater, land, and air. What distinguishes on-site
systems from other sewerage systems is the wastes are treated at the same location
where they were produced. This singular aspect of on-site treatment has both advantages and dis-
advantages. The advantages include less monetary and energy costs for conveyance of wastes to
the treatment site, direct recycling of wastewater to replenish the groundwater or to be reused
in ponds or irrigation, and simpler treatment technology due to the lack of toxic materials in
wastes.
The disadvantages of on-site systems stem primarily from poor design, poor construction, and
poor maintenance, all of which result in inadequate treatment with possible public health con-
sequences and groundwater contamination. The fact that so many septic systems have failed due
to one of these factors points to the need for some sort of better management—either public or
private—of on-site systems, and it also underscores a critical need for better public education
about the limitations and maintenance requirements of the septic systems. Additionally, many
planning agencies view septic systems as a threat to good land use planning because on-site
treatment allows decentralized development apart from the restrictions set by the central water
and sewer services.
A bias against septic systems is seen everywhere, starting on the first page of the Public
Health Service's Manual for Septic Tank Practice, and filtering into most branches of the govern-
ment, into engineering schools, throughout public health departments, and most particularly
among consulting engineers. Septic systems generally are viewed as health hazards, leading to
water pollution and shallow well contamination. It's no wonder: most of these systems were
designed according to the outdated Manual of Septic Tank Practices which is largely responsible
for the "creeping progressive failure," seen in many failing systems. But the bias is not only
one argued on technical grounds—it is one perpetrated by a general ignorance of maintenance
needs and improved systems and sanitarians who get very emotional when you challenge their author-
ity. But most importantly, there just isn't much profit in these systems, because any competent
backhoe operator can put one in, they work uery well, and they use very little energy to operate.
For all these reasons, the general tendency has been to discontinue use of septic systems, even
if they are operating well. Between 1950 and 1970, 10 million homes with on-site treatment were
connected with sewers. No one knows how many of these were done needlessly.
Today this trend has reversed somewhat, as the shift to the rural countryside increases. We can
only hope that what we are doing now will help reverse the poor record of on-site treatment.
Good engineering is available today to make these systems work even better at lower costs and
more environmental protection.
Nearly one-third of the U.S. population uses on-site systems today, relying on over 20 million
septic systems already in the ground. These systems are good reliable equipment which have
already been paid for, and short of the improper maintenance given to most, they are one of the
cheapest, most reliable, and stable wastewater management systems there are. Many people do not
realize that on-site systems actually have been utilized for many decades and that they can per-
form reliably often for the life of the home they serve.
31
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INSPECTION (OR CLEAN-OUT) PORTS
FIGURE 1
SEPTIC TANK DESIGN
X (
Q t
1
___
-1
J
-S*«
I'-': •::..::••:•::••.•. -.\
~
"" FLOATINGSCUM
LIQUID £
p**
-------
The size of the leach field is dependent on the amount of wastewater and the treatment capacity
of the soil. Some soils are more porous and biologically active than others. Poor soils may
not be suitable at all. Generally, the poorer the soil, the more it will cost.
Septic tanks themselves cost somewhere in the order of $250 to $350 with the mainentance cost
of about $30 to $40 every two years to pump them out. A lot of people are getting sewer bills
like that every month these days to pay for advanced waste treatment plants.
A leach field can cost considerably more, again depending on the amount of wastewater and the
local soil conditions. In good soil for a three-bedroom house, the cost may run about $900 to
$1,000 but they could cost up to $6,000 to $7,000 easily if you have to go to a specially engin-
eered system for poor soils.
Even so it is the least costly of all systems. It requires little maintenance and it may not use
any energy. I am reluctant to stress this aspect of low maintenance because people say, "Well
a little maintenance: that means every five, six or seven years I need to get the honey dipper
in here and in between I can just forget about it." This happens all too often and it convinces
me that most failures are these cases where there is no maintenance at all.
A septic system gives very effective treatment. One of the nice things about it is that it
doesn't act up if you go away for a weekend, a month, or even a year. In fact, it's really good
for it if you go away for awhile, to let the soil dry out and rejuvenate its good filtering
capacities. It is reliable for surge flows; if you have 20 people in for the weekend, it can
handle that too. It's very dependable in highly variable situations. And no power and moving
parts means there's no energy cost, unless of course a pump is needed to pump the waters uphill
to the leach field. It also has a self-stabilizing mechanism, characteristic of biological
systems.
There are also some disadvantages. Obviously, adequate space is needed and good soils are nec-
essary. This simple design for the leach field cannot be used in shallow bedrock because drain-
age is poor. Similarly, a high water table will interfere with good treatment because treatment
is dependent on the stability of the biological community in the soil. If the water table fluc-
tuates rapidly or is generally high, then the biological integrity of the field is going to be
impaired somewhat. Such conditions require changes in the leach field design, which I'll get
into later.
The soils in the leach field are the most sensitive component of the whole system. It is
critically important to protect them, both in the construction process and throughout its life.
Oftentimes the system gets dug in wet seasons when it's easier to dig. That is fine, but they
never should be completed then. Wet soil compacts very easily. What happens is that the sides
and the bottom of the leach field are smeared, effectively limiting the amount of porous openings
in the soil. The water does not pass as easily against compacted surfaces and the biological
degradation of the wastes is impaired. This kind of smearing or clogging often begins in the
construction phase, producing a system that is prone to progressive failure. What is actually
happening is that a good bit of your treatment capacity is eliminated from the outset.
The soil in the leach field can also be compacted by machinery, cars, or motorbikes over it.
My recommendation is that you should never take anything over a leach field heavier than a hand-
pushed lawn mower or maybe a roto tiller, at the maximum. Even this will compact it some, but
the effect is marginal. All homes should be accompanied with a map of the leach field, so that
this rule can be respected.
Figure 3 shows a diagram of how the water enters the pipes in the leach field. In normal gravity
feed, a whole stream of water enters in a surge. Obviously it's going to take the course of
least resistance so most of it will percolate downward at the beginning of the line with less
and less as it moves down the line. This slowly builds up a condition of clogging at the begin-
ning of the line and as the system is used longer, you'd have what is called "creeping progres-
sive failure." The last diagram on the figure shows the water being distributed evenly over
the whole pipe and throughout the whole drain field, which maximizes even distribution and there-
fore also better treatment. This can be achieved with pressure distribution using a simple one-
third horse power pump. An additional benefit of this system is that all the water is distri-
buted at once rather than being allowed to trickle out. This gives the soil a chance to dry out,
allowing the aerobic bacteria to breathe. The aerobes take over when the soil is not engulfed
with water and the anaerobes thrive when the field is inundated.This teamwork between the two
kinds of microbes gives excellent treatment. Pressure distribution, dosing the absorption
trenches, or alternating leach fields will maximize this teamwork arrangement between the aerobes
and the anaerobes. These methods have been developed well in Wisconsin by the Small Scale Waste
Management Project in Madison. They have found these methods result in much longer life of the
absorption fields. 33
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FIGURE 3
PROGRESSIVE CLOGGING OF THE INFILTRATIVE SURFACES
OF SUBSURFACE ABSORPTION SYSTEMS
Gravity flow.
continuous trickle of effluent
_J
J
Equilibrium
. i
t T
TRADITIONAL SUBSURFACE SEEPAGE BED
~.ef. EPA Technology Transfer Seminar Publication. Alternatives for Small Hastewater
Treatment Systems; Part I: On-Site Disposal/Septage Treatment and Disposal. October 1977.
In systems where conventional leach fields do not work well because of poor drainage or poor
top soil, there are other ways of dealing with wastewater on-site. In a mound, water is pumped
uphill to a leach field constructed a few feet above the normal grade (see Figure 4). Additional
soil and sand are brought to the site and mounded over the area to be used for the leach field.
The sand is laid down on the grade, followed by the gravel, the drain pipes, more gravel, and
finally covered over with good soil. These can be expensive because of the site-specific design,
the transportation costs, and the fill itself. They also have regular operating costs for the
electricity to pump the septic tank effluent to the leach lines, but these expenses are worth it
to many who could not build on their site with some special design as this.
-
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FIGURE 4
PLAN VIEW AND CROSS SECTION OF MOUND SYSTEM FOR PROBLEM SOILS
Topsoil
Subsoil \ Perforated PVC pipe ciay fill or topsoil
Water - \ \ Sand fi
Topsoil
SEPTIC TANK
1V4- to 2-inch PVC pipe
^/ from pumping chamber
jl 1-inch perforated
PVC pipe
Seepage trench
5/8 to 1 inch stone
PLAN VIEW
Ref. EPA Technology Transfer Seminar Publication. Alternatives for Small Wastewater Treatment
Systems; Part I: On-Site Disposal/Septage Treatment and Disposal. October 1977.
Evapotranspiration beds (see Figure 5) are similar to mounds except that they rely on evapora-
tion and transpiration for water disposal. However, unlike mounds, an impermeable liner is
placed underneath the mound. This is particularly valuable where the groundwater is very high
because it should prevent contamination. The surface vegetation utilize the nutrients and
evaporate the water through its leaves in a process called transpiration. These ET beds are
more likely to work in Southern climates that are not quite as harsh or in summer homes in
Northern climates.
35
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FIGURE 5
TYPICAL EVAPOTRANSPI RATION BED
J_
T
Impermeable
plastic liner
Ref. EPA Technology Transfer Seminar Publication. Alternatives for Small Wastewater Treatment
Systems; Part I: On-Site Disposal/Septage Treatment and Disposal. October 1977. p. 8B
An aeration tank is another modification of the septic system which consists of little more than
an aerator stuck into the septic tank. It bubbles air into the tank in order to maintain an
aerated effluent. These aerated units cost a good bit more than regular septic tanks and they
have high energy costs for operation. Maintenance has caused many owners to discontinue using
them. The manufacturers often recommend them in cases where the leach field is ponding, with
stinky septic soup flooding lawns. They do help for a year or so to clear up the symptoms, but
since the problems began in the leach field, the ponding will return. When a leach field is
misdesigned, misconstructed, and mismanaged, a remedial solution for the septic tank will not
do the job. It is much better to let the field dry out by itself and put in a new one to use
alternately.
Sand filters are now being suggested by the Wisconsin people as a follow-up treatment for the
septic tank, before the water flows into the leach field. They are useful in cases where the
leach field is quite close to a stream. Sand is a fairly effective medium to filter out bac-
teria and there is also some nutrient removal. Before I conclude my remarks on on-site treat-
ment, I want to acquaint you with some innovative work being done by Dr. Homer Buck of the
Illinois Natural History Survey in downstate Illinois. He is feeding sanitary wastes from pigs
directly to fish ponds. A grouping of eight different species of fish, primarily some Chinese
carp, perform the treatment and most of them can be used for a harvestable cash crop. The resul-
tant water quality is good, the crop is of high quality, and the environmental impact appears
to be negligible. These systems are operating throughout the Midwest now, with one of the most
interesting applications being a state hospital in Arkansas.
Aquaculture appears to offer much promise for small communities, and it suggests that the
thousands of lagoons we have all over the country might offer a means of recycling the nutrient
value of our wastes directly into harvestable crops (used for feed) instead of needing to further
treat them on the land.
Concluding Remarks
The work of people like Tim Winneberger in California, Dick Otis and Bill Boyle in Wisconsin,
Jack Abney in Kentucky, Rein Laak in Connecticut and others, coupled with renewed interest in
on-site systems at the federal level, has shown that today the future of on-site is brighter
than ever. New engineering developments, along with a tested model of on-site management have
significantly advanced the field of on-site treatment and disposal. For the public to benefit
from this technology, its use must be permitted and encouraged. The advantages of on-site
systems are too numerous to overlook. Today, these systems can be engineered to reduce ground-
water pollution, provide greater service life and lower annual energy costs, and recycling of
nutrients and water.
36
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CENTRAL COLLECTION VS. SEPARATED TREATMENT
CARL LINDSTROM
If we want to accomplish the reuse of the resources—the water as well as the nutrients and
useful materials in our wastes—we also want to see what it is we have to avoid.
The problem of toxics in the environment can be dealt with in different ways. One choice is
trying to stop the proliferation of petrol chemicals, that in general, show up as statistics.
We can't see the harm. It's coming out at us as increases in cancer, allergies, and things
like that.
The other thing we can do is to at least stop their spreading into the environment. That's why
we have to be considering the idea of segregating waste treatment in such a way that we at least
don't invite the mixing of things that belong in our food cycle with those that do not belong
there. Once they are mixed, we'll eventually need energy or work, one way or another, to
achieve this separation again. So we might as well try to keep them segregated from the start.
It will be immensely easier. I will try to give at least some idea why.
Sweden had a very rapid development of advanced sewage treatment in the early 1970's. Right
now, about 85% of Sweden's urban population is attached to tertiary treatment, advanced waste
treatment. The main experience from that is that we have, all of a sudden, a new product that
we don't know how to deal with, which is sludge. This sludge cannot be burnt successfully
because of the air pollution that comes—that just simply spreads it another way. You can't
very well dump it in landfills as a permanent solution—it will eventually leak out and cause
other problems. You can't dump it in the water, which should be self-evident. And the farmers
are often not very happy about taking it, because the better you do with the wastewater purifi-
cation, the worse the sludge.
From the farmer's point of view, receiving sludge as a fertilizer is a very risky proposition.
If you get sludge from a big collection system, from a big city, you can be pretty sure that you
have almost a chart of everything that you want to avoid—like cadmium, lead, mercury, PCBs, DDT,
you name it, it's there. As soon as it's on the market, it's going to be in the sludge. If
you have a small municipality and a smaller collection system, you run into different problems,
because now you probably will not have a consistent type or a consistent level of these elements.
But you run into the lack of predictability of when it's there and when it's not there. You may
run into something that you don't know about. Then you look back and your soil has a concentra-
tion of something that is not easy to rectify.
This has been happening repeatedly in Sweden. It is the nature of having a collection system
that invites you to dump down whatever you want to get rid of—whether it's chemicals or pesti-
cides The ideal is segregated, separated, waste treatment. You need to keep these toxic
organics, as much as possible, out of the whole chain, so that you can retrieve the valuable
nutrients.
Greywater has several differences from sewage that I want to talk about. Greywater can be land
treated on-site successfully because, first, it's less volume to deal with than sewage. About
40% of the water use is from the toilets; the 60% remaining is greywater. There is less nitrogen
in it, which is an important thing. Nitrogen, when it is being transformed into mtrates, is
very easily leaked through all soils and could show up rapidly in the groundwater. But there is
another interesting difference as It relates to land treatment and that is that its biological
characteristic is different. It is a much more rapidly stabilizing liquid from the biological
point of view. It consumes oxygen more quickly. Compared to sewage, you have a very quick
decomposition process in the beginning with greywater and then it pretty much levels out So you
let the water percolate through the soil; it stabilizes relatively fast and you have a better
buffer, so that when the water eventually hits the groundwater table, there is a very good chance
that it is in a stable biological form.
37
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SEPARATED TREATMENT: WATERLESS TOILETS AND GREYWATER
ABBY ROCKEFELLER
I will discuss the reasons why separated on-site treatment is the way to make on-site treatment
work. We'll first review what separated treatment is, the principles at work in separated on-
site treatment and what happens with one particular process, and the barriers to widespread use
of on-site treatment.
First, why bother making two problems out of one by treating the "black" (kitchen and toilet)
wastes one way, and the "grey" wastes (washwater) another? In answer to the first half of the
question, separated treatment involves the use of water as a solvent only—a washing medium—not
as a transportation medium for toilet and organic kitchen wastes which are treated separately,
ideally by decomposition on-site. The answer to the second half of the question has three parts:
1) conventional on-site subsurface systems receiving the combined load of organic wastes and
washwater are only capable, by anyone's standards, of treating those materials in a certain per-
centage of the soils in this country; a significant percentage of the land in the U.S. is
classified as not suitable for conventional on-site disposal for reasons of low percolation, high
water table, shallow soil or rough terraine. Some of this is nevertheless already built on; much
of what remains—the marginal areas (excluding swamps)--could be used for dwellings, if the antici-
pated load were significantly reduced. 2) The old criterion for what constituted successful
on-site treatment was making the wastewater go away. The new criteria include protection of the
groundwater; making the effluent percolate into the ground at a certain rate is no longer con-
sidered good enough. 3) Clean water is in increasingly short supply, both absolutely, and more
so in relation to the growing number of users. Separated treatment would save 40% of our total
domestic use by eliminating flush toilets, and more by eliminating the use of garbage grinders.
What then does separated on-site treatment of domestic wastes involve to effectively work? The
basic principle involved is the keeping of nutrients in a relatively short organic cycle by
ensuring plant uptake, rather than in the long and destructive cycles associated with putting them
in the water—ground or surface. This, in turn, means keeping them near or at the surface of the
soil. The principle is incorporated in the Clivus Multrum 1} by stabilizing the compostable
wastes from toilet and kitchen which can then be directly applied to the soil surface, and 2) by
changing the character of the remaining wastewater by what it keeps out of it, so that the
nutrient (i.e., pollution) content is, for several reasons, more recoverable by plants.
This second point needs elaboration. About two-thirds of the total organic pollution (based on
the ultimate biological oxygen demand) in domestic sewage is from the toilet wastes. Where
garbage grinders are used, the combined oxygen demand of toilet and kitchen wastes is increased
to over 90% of the total pollution in the wastewater. 90% of the nitrogen in combined sewage is
from the toilet wastes (urine is the major source), about 50% of the phosphates (depending on
laundry detergents), and usually over 50% of the chlorides.
This is not to show that greywater can be directly discharged into bodies of water. On the con-
trary, the pollution concentration (based on 8005) is about the same as in combined sewage. There
is no question but that it must receive treatment in the soil, the best medium known for puri-
fying organically polluted water. But, the character of the organic content in greywater is
different from that of combined sewage in an important way: its constituents are more readily
available to oxidation by bacteria than are toilet wastes (Olsson, 1968). This means that, if
greywater is discharged untreated into water, the effects of the pollution (e.g., algae bloom)
show up very quickly. On the other hand, if it is discharged into soil, as it should be, the
consequence of this characteristic is that purification takes place sooner (that is, higher up)
in the soil profile. Also, because greywater is on the average 15° warmer than sewage that
contains toilet water, the leach lines can be laid nearer the soil surface.
Thus, the effects of the absolute reduction in pollution in greywater unburdened by kitchen and
toilet wastes, the rapid stabilization of its remaining organic content and its higher tempera-
ture, altogether benefit the groundwater below by keeping the nutrients out and the plants above
by making them accessible.
38
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One process that separates wastes on-site is the Clivus Multrum. It's the oldest Swedish com-
posting toilet. The Multrum consists of a treatment unit—a large fiberglass tank with an
inclining bottom—located beneath the toilet and the kitchen'waste depository. It is designed
to treat all food, as well as toilet, wastes without the aid of water, chemicals or externally
supplied energy, since these wastes are transported (in most cases) by gravity, and converted by
the metabolic energy of microorganisms to a stable, highly mineralized compost. It therefore
immediately saves 40% of the water and obviates the need for a garbage grinder. Nor does one
have to put food wastes in the trash (the other conventional recipient) where a Multrum is
installed This is as important to the management of solid wastes as keeping toilet wastes out
of the water is to the management of wastewater. The remaining solid wastes (cans, bottles,
paper, plastics, etc.) are rendered aesthetically and sanitarily inoffensive when not contamin-
ated by putrescibles, and can be stored for long periods of time, thus cutting down on the need
for such frequent, and energy intensive, trash collection. (We should also remember that, in
ten years, half of the cities will run out of landfill space.)
The Multrum process is an effectively aerobic one because of its ventilation system which
affords a continuous airflow through and over the decomposing wastes. This means that, although
there may be pockets of anaerobic activity, the end product cannot, because of the baffle and
airduct design, be removed before it has been subjected to aeration. The draft, supported by a
14 watt fan, carries the waste gases (C(>2 and water vapor) above the roof. Odors are prevented
from entering the house by the same air flow serving the decomposition process: the negative
pressure in the tank causes air to be drawn into it, through either the toilet or kitchen waste
depository, whenever either of these lids is opened.
The system relies on time and microbial competition and predation, rather than on high tempera-
tures, to achieve safety of the end product. Incrementally introduced, the metabolically
generated heat is incrementally released, and therefore never reaches the thermophilic levels
characteristic of forced composting.
Now, we would like here to emphasize the importance of size of the composting chamber. Many
attempts have been made to "do the same thing" with a little box, in order to avoid the incon-
venience of installing the large system. However, we're convinced that such small units cannot
accomplish the same thing; that is, they cannot, without a lot of attention, achieve a regularly
safe end product relying on decomposition alone. Nor can they withstand peak loads, since their
tolerance with respect to urine build-up is very limited. These dehydration toilets have in
common the problem of trying to compensate for their small size by striking an all-but-impossible
balance between adding enough heat (electrically supplied) to drive off the liquid, and, at the
same time, not so much that the excrement is baked, making it difficult to remove. These units
have their place where use is low and without sudden peak loads (chiefly in vacation homes).
But it should be noted that the trade-off at issue is their small size plus high maintenance and
an unpredictably stable end product, versus the large, compost-heap sized decomposition chamber
plus low maintenance and assurance of an immediately usable end product, such as the Multram has.
Given the benefits of separated on-site treatment, and the availability of a range of technologi-
cal devices, what are the barriers to widespread implementation of such treatment? The first is
the fact of greywater. In the first place, it must be established what can be done with it
immediately, before the qualities which distinguish it from total sewage are fully understood.
Certainly its ultimate treatment should take place in the soil, but it is not clear that the
septic tank is the appropriate form of pretreatment. It was, after all, in response to the flush
toilet that the septic tank came into being; before it, small drywells had handled the greywater.
It was the introduction of the slow degrading feces and toilet paper into the wastewater stream
that made necessary some means of protecting the drainage bed from plugging up. The septic, or
settling, tank was well-suited to this purpose, but greywater—even modern greywater--does not
contain the large objects that make the settling tank useful to it.
We have for three years been working with a stone-filled roughing filter which seems in several
respects to be a more suitable method of pretreatment for greywater: 1) it is likely that it
will do a better job in the long run of protecting the leach lines, since it does not allow the
periodic outflows of unoxidized organic matter which occur in theanaerobic settling tank where
the sludge index fluctuates; 2) the effluent doesn't become septic, since it flows directly
through the filter into the purification bed, which is more favorable to the oxidation pro-
cesses in the soil and to plants; 3) any problems with plugging up will occur in the filter,
which is readily accessible.
39
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Next, we need to establish the criteria for the appropriate combinations of pre- and final
treatment of greywater. This means that we need extensive research and demonstration projects
based on real-life situations, not on simulated effluent and flow rates. We need to know what
is both appropriate and cost effective in various marginal situations. For example, where there
are existing but failing septic systems, one can install a compost toilet to reduce the hydrolic
and pollution load, and expect to make it function again; where the soil is shallow, or the
groundwater high, a raised bed preceded by a roughing filter might work best. Where there are
cesspools without septic tanks, installing a Multrum will have the effect of immediately con-
verting the cesspool into a drywell suitable for treating greywater.
Our most interesting experiment has been with using a greenhouse to treat greywater which, after
being pre-filtered in the roughing filter referred to above, is pumped into leach lines three
inches under the surface of deep soil boxes. In operation for two years, it has been an excel-
lent example of the rewardingly positive synergistic effects of separated treatment: by keeping
the toilet and kitchen wastes out of the wastewater stream, the resultant greywater is raised in
quality to the level of both a good irrigation and good nutrient source for growing plants,
while at the same time the growing medium is the ideal leaching/purification bed. There are very
satisfying tangential benefits to this system: for example, there is the heat-exchange function
performed by the soil, which recovers valuable heat (already paid for in the electric bill) to
be used a second time; there is the ecological stability of the micro-environment created by
the deep soil which, in duplicating more nearly the earth outdoors, allows a diverse range of
soil organisms to thrive, thus preventing to a very great extent the common outbreaks of green-
house pests; also, because it is self-watering, and because the deep soil can hold a great deal
of moisture, this greenhouse is practically maintenance free. No surface watering is necessary
once plants are past the seedling stage; it can be left for two weeks without fear of dehydra-
tion, even when no one is using the washing facilities in the house.
The same approach should be used in outdoor leach beds: thinking of the greywater in terms of
its irrigation and nutrient potential, lay the leach lines close to the surface (one foot or
less), and grow something on top (such as a lawn) that will be "harvested" regularly. A deeper
drywell or leaching trench can be included in cold climates for periods when the shallow bed
freezes (which, because of the warm effluent will be seldom). Or, where the leach lines are
under a garden, coldframes can be put on top in the winter to prevent them from freezing.
The second barrier presently stifling the use of greywater systems in conjunction with compost
toilets, is various aspects of the regulatory structure pertaining to wastewater treatment. The
following changes must be made before separated treatment can become an actual solution: first,
semantic impediments must be removed from environmental, health and plumbing codes. For example,
the statements to the effect that every house must have a "water closet," and that every toilet
must be connected to plumbing, should be eliminated, or appropriately altered. This also means
modifying the definition of "toilet" so that it doesn't imply water carriage. Second, per-
mission should immediately be granted, at minimum, to allow a 40% reduction of leachfield size
consistent with the 40% flow reduction. Third, further modifications in requirements for grey-
water treatment (e.g., further reductions in leachfield size) should be made in accordance with
research demonstrating the lesser pollution load and other characteristics favorable to its
treatment in the soil. Fourth, shallow leaching beds, and other innovative types of raised
disposal beds (e.g., greenhouses), should be tested extensively in order to establish a range
of alternatives suitable for different site conditions.
In conclusion, the criteria for sound wastewater management must include these basic laws: 1)
don't transport for central treatment what can be successfully converted on-site; 2) don't use
water as a transportation medium for organic wastes, that is, don't mix into water wastes well-
suited to conversion and volume reduction by composting; 3) design for plant uptake of nutrients
first, percolation second. It must be remembered that treatment of organically polluted waste-
water is a function of biological, not mechanical, processes. Stabilization of nutrients in the
soil is only the first step: ultimately, it is plant uptake that matters. Since the soil's
physical and biological capacity to hold nutrients is finite, loss to the life cycles, or pollu-
tion of the groundwater, is the inevitable consequence where growing plants do not retreive the
nutrients.
40
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HEALTH EFFECTS OF THE TECHNOLOGIES
DR. SAM FOGEL: Mievobiologist, J.B.F. Scientific Corporation. Ten years
experience in wastewater and sludge management.
My presentation is roughly in two parts. I want to cover basic information first and then apply
it to the different recycling technologies and the conventional technologies. So first, I will
talk about the constituents, their levels and the ways of removing them from sewage, and then
look at the routes by which humans are exposed. Then we'll look at the specific technologies.
I'll first talk about the micro-organisms. One can, without even identifying the organisms,
stand back and say some very basic things. One is, if you consume untreated sewage, you'll un-
doubtedly come down with some infection. Most of the waterborne diseases in this country,
historically and in the present day, result from contamination of the drinking water supply by
untreated sewage. One takes that as a fairly strong factual piece of information.
The second piece of information—again without knowing anything about the specific intestinal
disease incidence in your community and other details--is that you can expect to find, in the
sewage from centralized systems, representative organisms. So that if someone comes back from
a trip abroad and there is an outbreak of cholera or a hospital case of cholera and that hospital
is connected into a sewage treatment system, more than likely you can find the cholera organisms
in the sewage treatment plant. This was particularly illustrated in the early days of the polio
vaccination program when they were giving out lots of polio vaccine. In one particular community
they stopped the program after less than 1% of the community had been given the vaccine. Two
days later it was observed that in the sewage treatment plant you could find polio virus that
had not been there prior to that time. As a general statement, in centralized systems, at some
point in time, you will find all the disease-causing organisms present in that sewage that are
in the community.
Let me quickly go through some of the pathogenic organisms. We're talking primarily about four
classes of micro-organisms: the bacteria, the virus, the intestinal worms or helminths, and
the protozoans. There is a formidable list of organisms. The more common ones among the bac-
teria in this country are Salmonella and Shigella. These cause intestinal diseases or episodes.
Cholera organisms are very significant in India and some other countries. There are two types
of waterborne diseases commonly associated with viruses. Sixty-seven types of so-called Enter-
oviruses can cause gastroenteritus, the general name for intestinal disorders. The hepatitis
virus, of course, causes infectious hepatitis. Helminths include hookworms, which could turn
up, for example, if you walked barefoot in soil irrigated with raw sewage. Another helminth
is the tapeworm.
The point is that if you go through and clinically analyze what you have in sewage, you're going
to find a large number of organisms.
Now the question is what is the relationship of those large number of organisms to disease in
this country. Surprisingly, the number of recorded waterborne episodes—from drinking water
or water contact like swimming—are quite low in this country. Figure 1 shows the number of
recorded waterborne disease outbreaks from 1971 through 1974. It gives the number of outbreaks
and then the actual number of people who were infected. You can see that we're talking about a
total of 99 outbreaks reported nationwide and something on the order of 17,000 people infected.
Most public health officials tend to believe that the reported cases may be only 10% of the real
totals. But even with that, you can see the numbers are low in relation to our population of
over 200 million.
Now, there are a couple of reasons why the numbers of disease episodes are low. First of all,
in order to contract a disease, one would like to look at the characteristic of the organism
itself called its virulence, its capability to cause infection. It's not a well understood
concept. We know that historically, during the Middle Ages, the bacteria that caused plague
swept through Europe and decimated the population. Obviously a large number of people were
susceptible to it. Huge populations were killed. We can say the organisms were unusually
virulent. We saw something like that during the first World War when influenza epidemic came
along. I would say that since that influenza epidemic we have not seen—whether you're talking
about viruses or bacteria—the type of virulence that had been shown earlier on during the last
thousand years where there have been recorded episodes. However, there is constant concern with
influenza virus that a virulent strain will develop. We live in a period where there is not a
great deal of virulence right now, and then this has a lot of implications for recycling
41
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Figure 1
Figure 2
ETIOLOGY OF WATERBORNE OUTBREAKS
AND CASES, 1971-1974
(USA)
DISEASE
GASTROENTERITIS
GIARDIASIS
SHIGELLOSIS
CHEMICAL POISONING
HEPATITIS-A
TYPHOID FEVER
SALMONELLOSIS
TOTAL
OUTBREAKS
46
12
13
9
13
4
2
99
CASES
7,992
5,127
2,747
474
351
222
37
16,950
EFFECTS OF SEWAGE TREATMENT PROCESSES
ON SURVIVAL OF PATHOGENIC ORGANISMS
PATHOGEN
SALMANELLA (BACTERIA)
MYCOBACTERIUM (BACTERIA)
E. HISTOLYTICA (PROTOZOAN)
HELMINTH OVA (WORM)
VIRUS
NUMBER OF
UNTREATED
WASTEWATER
20,000
200
15
250
40,000
ORGANISMS PER GALLON
PRIMARY SECONDARY
EFFLUENT EFFLUENT
10,000
100
13
25
20,000
500
15
12
5
2000
DISINFECTION1
0.5
.015
.012
.005
2.0
ORGANISMS
APPLIED PER
ACRE PER DAY
PER MILLION
GALLONS^
3,900
120
93
39
16,000
1. CONDITIONS SUFFICIENT TO YIELD A 99.9% KILL
2. APPLIED AT A RATE OF 2 INCHES PER WEEK
42
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technology. Because if the levels of disease are low, and the virulence is low, then that
suggests one operating mode. One would be less concerned with plant operation upsets that
temporarily resulted in very little chlorination, for example.
Another factor related to virulence is the number of organisms that you need to ingest to cause
a disease episode. With certain strains of Salmonella bacteria, you have to ingest a million
cells. Now note the drinking water standard for bacteria is less than one organism per 100 milli-
meters, which is a couple of good glasses of water. So that to get a million cells the water
would be obviously turbid. With certain other types of micro-organisms—more virulent ones—
a number as low as 10 organisms could lead to infectious disease.
In addition to a lack of virulence, part of the reason we don't see the same numbers of
diseases now that have been seen in the past, is that sewage treatment is more prevalent and
reduces the organisms. Figure 2 shows the effectiveness of centralized conventional sewage
in killing of pathogenic organisms. After primary treatment you get a modest reduction in
Salmonella bacteria, for example, of 50%, down to 10,000. After secondary treatment, it's down
to 500. If you chlorinate, you can get it down to less than one cell per 100 gallons. Note how
resistant the protozoan is to conventional sewage treatment. You start with 15 and you wind up
with 12 before you disinfect. Note also how at every step in the process, viruses are reduced
less than most of the other organisms. Note, finally how important disinfection is. Still, if
you were chlorinating to the extent that you wound up with only two viruses per gallon, if its a
million gallons a day or a hundred million gallons a day, you're discharging a considerable number
of viruses.
Now, once the organisms are discharged into the environment—whether it's discharged into a
receiving water as most centralized systems do, or whether its discharged on the land in spray
irrigation—there's a natural die-off of all organisms over time, which further reduces their
impact. Organisms do die, just by being in the environment over time. Even if you spray organ-
isms into the air, as in spray irrigation, a die-off occurs due to ultraviolet rays.
There are numerous studies which show how long it takes each organism-type to die. Me know
that the bacteria generally die off much more quickly than some of the protozoans. The notion of
die-off has public health significance.
If the sewage is being discharged into a receiving water, for example, and you have shellfish in
the area, then shellfish will frequently pick up the viruses that survive the chlorination. And
many of them do survive the chlorination. Due to the fact that shellfish have a natural process
of filtering the water, you'll wind up having a concentration of viruses in the shellfish.
As far as heavy metals go, there are five metals that are of special concern. They are cadmium,
copper, lead, nickel, and zinc. In trace amounts, humans need many of these metals to satisfy
the body's nutritional requirements, particulary copper, zinc and nickel. One needs to have
several milligrams per day of copper in one's diet. A little of something can sometimes be good
for you. A whole lot of it, the adage goes, can be poisonous.
The metals introduce two concepts. One is acute toxicity—poisoning—and the other notion is
chronic toxicity, harm caused by gradual accumulation over a long period of time.
What does the long term ingestion of small levels of metals do to you? This is the issue of
the age As acute episodes die out, or are not being seen in this country, people become con-
cerned about what happens in small quantities. It's a very hard issue to deal Wlth-Jhe^.^nrp
evidence that if you ingest cadmium over your life time you can get kidney damage. The evidence
of that, primarily results from industrial exposure. But people conjecture what will happen if
you eat cadmium-laden lettuce for 20 years. You'll find out that the evidence is not very clear.
There is very little documentation.
If your community has industry in it, metal plating operations in particular, you're likely to
find high ™ve s of metals in the centralized sewer system. Oust as one has to take into account
what k Sd of d seases are present in a community and ask whether theyare going to show up in the
sewage treatment plant, you ask what kind of industries are in the conmunity as a guide to which
metals will be showing up in the sewage.
When the wastewater is treated conventionally, the metals get concentrated in the sludge And
so those metal levels will go up a thousand fold once you start concentrating sludge out That s
why the metals areWh more of a concern with sludge than with effluent. In general, with spray
"rrigation of wSteHSter, you'll not see as much concern about metals as there is when sludge is
put on the soil.
43
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The category of pollutants which has provoked the most recent concern is organic chemicals.
Our consciousness towards this class of chemicals has grown primarily through the use and misuse
of pesticides. The original damage from organics in the environment was fish kills due to pesti-
cides. Later on people began to notice discoloration of fish flesh due to organic chemicals
like phenol. Over the last 15 years, people's awareness has been raised and analytical techniques
have improved to the point that now very sophisticated equipment is used to test for minute levels
of organic chemicals.
Remember the difference between chronic verses acute toxicity. Occasionally people do die from
ingesting pesticides due to accidents. Pesticide workers have died from overdoses of pesticides.
Many of them are chlorinated hydrocarbons. That's the acute toxicity effect.
It's the chronic damage that is the bigger and more recent concern. Five years ago, EPA started
to examine drinking water and found large numbers of chlorinated hydrocarbons. There are now
some correlations between cancer incidence in population and the amount of these chlorinated
hydrocarbons in drinking water. They are correlations, they are not cause and effect. But again,
it does point out the concern of public health people and, in particular EPA, about the chronic
types of diseases, diseases caused by the long-term exposure where a latency period of 20 or 30
years goes by before you see the harm.
Through what routes are humans exposed to the dangerous contaminants in sewage? In conventional
centralized sewage treatment plants, you get a chlorinated effluent. The effluent is an absolute
disaster for fish, there's no question about it. That is not necessarily a human hazard, but
certainly from an environmental standpoint, the fish are decimated in the vicinity of outfalls.
Conventional treatment effluent can also become an acute microbiological hazard, particularly with
regard to shellfish taking up viruses. When we chlorinate sewage we generate a lot of these
chemicals, chlorinated hydrocarbons, that we are now associating with cancer, a problem of
chronic toxicity. The sludge from the conventional treatment plant does concentrate the metals.
Land filling is one method of disposal of sludge. That can cause groundwater contamination by
the many pollutants present in sludge.
Aerosols—contaminants transmitted from the sewage treatment process through the air--have been
extensively looked at. Researchers have not found any evidence to suggest that aerosols from
conventional wastewater treatment plants are dangerous to surrounding human populations. Herb
Pahren at EPA in Cincinnati, has more information on the ongoing aerosol effect studies.
A variation on this conventional treatment scheme is the one in Chicago. Chicago carries out a
conventional discharge of its effluent. However, it applies its sludge to the land in a number
of ways. They compost part of their sludge and apply it to land which is farmed. My own view
of it is that there's not much hazard if you grow corn for animal feed. But one should not put
sludge on soil and then grow lettuce for human consumption. It's becoming kind of a basic
approach to this area to grow animal crops, and not allow animals to graze on untreated sludge.
The sludge is stabilized, either through anaerobic digestion or lime stabilization. Now,
Chicago happens to be relatively high in metals, and there's some concern in terms of a 20-year
or 30-year buildup in the soil. Measures to combat that include enforcement of sewage pre-
treatment standards for industrial waste.
Another treatment alternative is the spray irrigation recycling model, as in Muskegon, Michigan.
You do not have short-term sludge problems in Muskegon. The lagoons provide for a long-term
stabilization and breakdown of sludge. I presume that after a number of years they'll have to
clean out those lagoons. But you don't have a separate sludge disposal problem. And, as I said
earlier, in most cases metal concentrations are not high enough in effluent to cause a problem
when it is spray irrigated. What is most likely to happen is that the metals would stay on the
bottom of the lagoons, presuming that you did have metals. The question that has roost frequently
been raised is aerosols—the pathogens possibly being thrown into the air during irrigation and
carried away to cause harm. Mitigating measures for this are things like buffer zones of several
hundred feet and/or trees. There is no evidence to date that there have been problems with
aerosols in this country. In the case of the city of Chicago, who is spraying sludge, the nega-
tive public reaction to their program was very vigorous. But it was primarily because there was
this big, rather obvious black stream of material being shot up into the sky using the rain guns.
Chicago got so much protest from the people in Pullman County that they switched to using sub-
service injection systems.
The conventional on-site treatment in this country is septic systems. Without a doubt, the
disposal of the sludge material left over is a giant problem. To a great extent, septage becomes
landfill. It's very nasty material. It can give rise to lots of groundwater contamination
44
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Figure 3
HEALTH IMPACT COMPARISON
RATING SCALE: 0 TO 5
GW = GROUND WATER
SW = SURFACE WATER
CONVENTIONAL
CENTRALIZED
OVERALL IMPACTS ON
WATER QUALITY
NORMAL OPERATION 4
UPSET CONDITION 5 (SW)
INFECTIOUS DISEASE
POTENTIAL
NORMAL OPERATION 2
UPSET CONDITION 5
METALS
NORMAL OPERATION 1
UPSET CONDITION 3
PERSISTENT ORGAN I CS
& CARCINOGENS
NORMAL OPERATION 2
UPSET CONDITION 5
TOTALS
NORMAL OPERATION 9
UPSET CONDITIONS 18
ALTERNATIVE
CENTRALIZED
I
(CHICAGO)
3
5 (SW)
2
5
1
3
2
5
8
18
ALTERNATIVE
CENTRALIZED
II
(MUSKEGON)
1
2
(SW & GW)
1
4
1
2
1
1
4
9
0 = HARMLESS
5 = MOST HARMFUL
SEPARATED
ON SITE ON SITE INDUSTRIAL
0 TO 5
2 0
5 (GW) 1 (GW)
2 1 0
520
0 0 0 TO 5
0 0 0 TO 5
0 0 0 TO 5
1 1 0 TO 5
4 1 0 TO 5
11 4 0 TO 5
45
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problems. There are some recent studies by EPA which attest to this. Fully half of the water-
born diseases in this country come from contamination of drinking water supplies, either private
wells or adjacent public supplies, by leachates from septic systems.
On-site industrial waste systems can cause serious problems as well. Soil is unable to accommo-
date high level discharges of metals and other industrial wastes.
The last technology is separated on-site treatment. Composting waterless toilets are an example.
Potentially, this form of treatment leads to the least environmental hazard if the technologies
function properly. The pathogenic organisms are mostly contained. If the waterless toilet has
a long detention time, as some of them do, of two to three years, one can argue that it's not
likely that you're going to find any organisms after that period of time. However, public health
officials frequently ask for the data to support this notion, and most manufacturers of these
devices simply do not have the data. To get that data, one has to innoculate a composting toilet
with many different organisms and then follow it over a period of years. So the data is not
available. But one can say from available information on the survival of organisms in the envi-
ronment, that very few organisms survive longer than a couple of years. The leach field for the
greywater would not contain anywhere near the load of pathogenic organisms produced by the
standard septic systems nor would it contain the load of organic material of the conventional BOD
type. Even if that leachate distribution system failed, the level of contamination presumably
would not be nearly as serious just by virtue of the fact that most of the pathogenic organisms
have remained in the composting end of the system. The major question, of course, is how well
these technologies function. The technologies do appear to be quite well-designed in the sense
of containment of pathogenic organisms.
Figure 3 presents a rough comparisonal ranking of these standard forms of technologies in terms
of their ability to guard against health and environmental harm. What it's intended to do is
give an idea how they stack up relative to one another. The rating scale here is 0 (Harmless) to
5 (Most Harmful). The chart distinguishes between "normal operation" and "upset operation." In
the conventional sewage treatment plant, an example of an upset operation would be where they run
out of chlorine, and are discharging raw waste. Or in the land application technology, for exam-
ple, you could leave the sprinkler system on too long and get a hydraulic overload and wind up
getting surface runoff. That's another example of an upset condition.
The first category on the chart in Figure 3 ranks overall impacts on water quality. The chart
reflects the fact that, environmentally, the conventional cnetralized system, even in "normal"
operation, has a serious damaging impact on aquatic life. The disposal of sludge typically by
landfill, can pollute the groundwater. The Chicago type is the same as far as the effluent goes,
but its sludge disposal has less impact. The failing septic tank is the common upset for conven-
tional on-site treatment.
The conclusion is clearly that the separated on-site system has the least overall adverse envi-
ronmental and health impact under both normal and upset conditions of the systems relying on
central sewage collection. The Muskegon model has far fewer health problems than those which
discharge into receiving waters that are then used for drinking water supplies. Under upset con-
ditions, roughly the same order is maintained.
When you are talking about recycling technology, an important point to remember is that there has
to be good communications between the public health people who know something about the communi-
cable diseases in that area and the people who operate the recycling system. In a similar sense,
insofar as toxic chemical pollutants like metals and synthetic organic chemicals are concerned,
you simply have to know what industrial practices are going on in your community. An industrial
survey has to be done and there has to be good pretreatment. Without the close scrutiny, you
always run the risk of an upset condition. Upsets are the most serious problem, whether it's
conventional technology or alternative technology.
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FINANCING SEWAGE TREATMENT: WHAT TO LOOK FOR—WHAT TO AVOID
STUART FJ'CHS: An attorney and municipal finance specialist, Fuahs has brought numerous
bond issues to market over the past several years. He is responsible for
structuring well over $250 million of water and sewer revenue bond financings
for the cities of Louisville, Kentucky and Northglenn, Colorado, among others.
LARRY CAHILL: Project Manager, Booz-Allen & Hamilton. Specialist in institutional aspects
of regional water quality planning. A former environmental commissioner
of Camden, New Jersey.
ALAN PARKAS: Director of Policy & Program Development Unit, Energy & Environment Division,
Booz-Allen & Hamilton; Bethesda, Maryland. Former Deputy Director for Policy
Development, Ohio Environmental Protection Agency.
STUART FUCHS
My name is Stuart Fuchs. I'm a municipal finance specialist with Goldman, Sachs & Company, an
investment banking firm headquartered in New York. As investment bankers, we share your concern
that water treatment projects should not be built at all costs, but rather in the most efficient
possible way. We want to make sure that the community has the wherewithal to sustain whatever
sewage system it decides it wants to have. We're particularly interested in the bondholders who
invest their money in the project. For example, say they put $1,000 into your sewage treatment
facility. Investors who buy your bonds, share your concern that the facility operates properly
because then there is a good chance that the principle and interest on their bonds are going to
be paid when due.
One of the projects around the country that we're very supportive of is Northglenn's wastewater
management project involving land treatment. Our primary reason for support was the favorable
breakdown between capital costs and operating and maintenance (O&M) costs. We're very concerned
that over the long haul, especially in an inflationary economy, with the cost of chemicals and
other operating and maintenance charges going up for conventional systems, you have less money
left to pay the bondholders.
Let me briefly sketch out a rough outline of what you have to do with your bond issue. First,
you have to deal with the problem of selecting consulting engineers and getting your 201 facility
plan in shape. These problems were addressed yesterday so I won't elaborate, except to stress
that we as investment bankers have to take a very critical look at your 201 plan and satisfy
ourselves that the resolution of your sewage problems is being accomplished in a reasonable way.
After your 201 plan is completed and you know what kind of facility you're going to build, you
go through a process of selecting investment bankers. The investment banker performs more than
just the function of a consultant. He is not an employee or agent of the municipality that's
building the sewer project. He makes an offer for the purchase of your bonds for public reoffer-
ing to investors who have confidence in his underwriting judgement. He's really got to put his
money where your consulting engineers' mouth is and say that "based on the population and cost
projections, we feel that you have a viable project and that there is an adequate source of pay-
ments for these bonds."
Securing Bonds
Let me explain briefly the source of payment for the bonds. There are a number of ways that you
can secure bonds. Broadly, I'll talk about two categories. The first and most traditional kind
of municipal bond is a general obligation bond which is backed up by the pledge of the community
to raise what are known as ad valorem taxes: that's a Latin phrase which refers to the value of
property. Rising property values are usually accompanied by increased property taxes. A com-
munity pledge to its bondholders is that it will back up its bonds with its full faith and cre-
dit: that in effect is its promise to raise taxes sufficiently to pay its general obligation
bonds.
There is a saying that when California sneezes, the rest of the nation catches cold.
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Mr. Jarvis and Mr. Gann in California have really spead a germ around that will create complica-
tions with general obligation bonds. I think it's a very exciting notion in one sense, that you
don't want to get tied into the ever-increasing rachet effect of higher property values causing
higher property taxes and people just going beyond their ability to pay for it. Basically, the
Jarvis-Gann initiative[Proposition 13] rolls back property taxes to 1975 levels and provides
that you can't raise taxes without a two-thirds majority of all qualified electors agreeing to
the tax increase. So we have a problem; the previously unqualified promise may no longer be an
unqualified promise if Jarvis-Gann goes through in California and if this idea catches on and is
spread nationwide.
So what I want you to focus on also when you're talking about financing your project is a second
source of revenues for the project—user charges—and viewing them as the primary source of pay-
ment. You have to look at what each household is going to have to pay for its share of not only
operating and maintenance expenses, but also what is called "debt service." This refers to the
amount of principle and interest that the community has to repay each year in order to finance
the project.
Credit rating services are very important inthe process because they assign a rating, whether
it's A, BBB, or AA, depending on your community's track record and their assessment of the pro-
ject. They look at all kinds of economic factors: the project itself, and the feasibility study
described in the 201 plan. Keep in mind the rating will have a large impact on how much interest
you're going to have to pay over the life of the bond. If you have a 30-year bond issue at say,
6-1/2 percent, you're paying far more than one dollar in interest for each dollar in principle
you raise.
I don't think it's a bleak picture; I think it's a very exciting picture. We were concerned
with the burgeoning cost of the technology and the fact that communities couldn't possibly repay
these bonds. I think now with land treatment and a number of other technologies being discussed
at conferences such as this, we have a chance to construct systems which meet local problems at
feasible costs. I'll be happy to go into any questions that are raised here and any others you
may have at the workshop.
QUESTION: How does one get out of the trap of getting advice from investment bankers contrib-
uting to the overdesign of plants because they look for million dollar plant price tags?
FUCHS: Obviously, most investment bankers are interested in the biggest possible deal that they
can get. I'd recommend talking with other investment bankers and that you keep looking until
you find one that you like and that you can trust. Go for a second opinion.
QUESTION: But how do you respond to the trap of some million dollar limit marker or some set
figure of high financing costs?
FUCHS: There are ways of doing so-called private placements, which you might talk about with
your investment banker which may save some issuance costs of a public offering although interest
rates may be higher. Bank loans are another alternative. You might talk to your local banker
about his financing of small projects. But don't let the investment banker or your consulting
engineer drag you, kicking and screaming, into issuing more bonds than you're comfortable with.
We're very concerned about the number of bonds issued, because of our interest in the commun-
ity's ability to pay them back. Dick Lundahl who is here from the City of Northglenn will bear
this out. In structuring Northglenn's bond issue, we both want to make sure that we're not
issuing a penny more in bonds than absolutely necessary.
QUESTION: I've heard no one discuss anything about the non-production costs that are built
into the ultimate cost of the project, such as the cost for the bond attorney, which would be
one or two percent; and additional costs that go into the project such as the astronomic figures
for consultants in the very process of preparing the necessary documentation for a hearing on
the Environmental Impact Statement, etc.?
FUCHS: I'd rather not be placed in the position of justifying bond attorney fees for you.
But I will say that their job is making sure that the bonds are legally authorized and valid
when issued. They also doublecheck us and our attorneys on whether each statement that is made
in the disclosure document is accurate and not materially misleading.
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ALAN FARKAS
Larry Cahill and I are going to talk about the economics of sewage treatment and we're going to
be concerned, really, with the economics associated with conventional centralized treatment
rather than alternative on-site systems. Larry and I and others on the environmental staff at
Booz-Allen have been interested and, in fact, paid observers of the facility planning process in
roughly 10 different states over the last several years. We've helped EPA regional offices pre-
pare environmental impact statements on especially controversial projects. We've worked for
areawide 208 agencies in helping them review ongoing facility planning, and we're currently
under contract to the New York State Department of Environmental Conservation to analyze various
aspects of sewage treatment economics.
Larry and I will address three questions: 1) what are the costs of centralized conventional
treatment? 2) when are the costs too high for the residential user? 3) what does necessary finan-
cing mean to local government?
We'll conclude our presentation by suggesting ways that you, as citizens and as public officials,
may be sure that any facility your community goes with is characterized by sound economics. And
now, I'd like to introduce Larry Cahill, who will speak to these first two questions, and then
I'll speak to the third.
LARRY CAHILL
Thank you, Alan. My talk will address the costs of sewage treatment, their distribution, and
their impacts on individual households. First, let's look at the different costs of sewage
treatment facilities (Exhibit 1). They're broken down into construction, and operation and
maintenance, the second category something we often forget. The construction costs are related
to first, the planning and design, commonly referred to as the Step 1 and Step 2 phases of a
construction grants program. There are also construction costs associated with the actual
facility construction in Step 3 of the construction grants program. These facilities consist of
treatment plants, major sewer lines such as interceptors, collector sewers, and any correction
of existing sewer problems. Along with these typical construction costs are the capital costs
of land acquisition, should you require land for new treatment plant facilities, and the finan-
cing of the capital costs, which often matches the annual construction costs. As I said before,
we often forget that not only are there capital costs associated with treatment plants and facil-
ities, but there are operation and maintenance (O&M) costs as well. These are related to the
personnel you need at the plant (for maintenance and operation); the chemicals you need for
treatment; energy, which is becoming quite a critical issue recently; and any equipment
replacement.
To recover the costs of sewage treatment plant construction and operation, a typical community
uses four major financing methods: taxes; special assessments; user charges; and an add-on to
a water supply charge (Exhibit 2). The most commonly used technique is a user charge, both for
repayment of capital costs and also for repayment of operation and maintenance costs. The add-
on tax for recovering operation and maintenance costs was more or less outlawed by the 1972
Amendments to the Clean Water Act. This provision has been relaxed in the 1977 Amendments, but
it remains unclear as to how many communities might still have to switch over from an ad valorem
taxation system (i.e., property tax) to a user charge system to assure proportional charging of
individual residences, commerce, and industry.
Who really pays for the cost of system construction and operation? We've already heard about
the construction grants program where EPA funds 75% of the construction of treatment facilities
and sewer systems. Well, let's see what that really means for a local community. Along the
left-hand column of Exhibit 3, you'll see that I've depicted capital costs, O&M costs, and
total annual costs. I've given a percentage breakdown for two different federal funding
scenarios The first assumes federal grants are available for all components of the wastewater
treatment system except storm water collection. That is, federal grants are available for the
construction of the treatment plant, the major interceptors, and collector sewers. You can see,
in this case, EPA will pick up 75% of the capital costs and the states will pick up, on the
average 11 of the capital costs, with some states picking up none and some states, such as New
Hampshire, picking up as much as 20%. That leaves 18% to be picked up by the local government.
O&M costs, as I mentioned before, are something we often forget. There is no subsTdy made by
federal or state governments for O&M costs recovery except for the state of New York which
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What Are the Different Costs
of Sewage Treatment?
Construction
— Planning and Design
— Treatment Plant
— Major Sewer Lines
— Collection Sewers
— Correction of Existing Sewer Problems
— Land
— Financing
Operations and Maintenance
— Personnel
— Chemicals
— Energy
— Equipment
-------
BOQZ
ALIEN
How Are Local Costs
Typically Recovered?
Major
Financing Methods
Ad Valorem Taxes
Special Assessment
User Charges
Water Supply Charge
Percent of Communities Using Method
Repayment of
Capital Costs
25
8
54
15
Operating and
Maintenance Costs
20
1
72-81
12
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01
!\3
BOOZ
ALLEN
Who Pays for the Cost of System
Construction and Operation?
Capital Costs
O&M Costs
Total Annual Costs
Federal Grants for Ail
Components Except
Stormwater
Federal
75%
0%
58%
State
7%
0%
5%
Local
18%
100%
36%
Federal Grants for Only
Plants El- Interceptors
Federal
58%
0%
37%
State
5%
0%
4%
Local
37%
100%
59%
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provides a 25% reimbursement. Other than this case, the O&M costs are supported totally by local
governments. Adding capital and O&M costs together, results in local communities paying 36% of
the total annual costs of the sewage treatment system.
Under the second scenario, federal grants are available only for plants and interceptors, which
has been typically the case in the last few years. The numbers change dramatically under this
assumption. Local communities pay 37% of capital costs and, of course, are again paying 100% of
the O&M costs. That results in their paying almost 60% of the total system costs on an annual
basis. This Exhibit, by the way, comes from the National Commission on Water Quality, and the
first time I saw it I was overwhelmed by the fact that local communities were paying up to 60%
of the sewer system costs. I had thought previously that the 75% funding program was a great
thing for local communities, but I now reserve judgement.
How much does an average household have to pay? Well, EPA conducted a survey in 1976 to find
out how much the average household might have to pay should some of these more sophisticated
treatment plants be built (Exhibit 4). For all systems, which includes about 250 facilities
plans, of both totally new and upgraded systems, 60% of the communities have households paying
less than $100 a year on the average sewage treatment plant services. 30% would be paying
between $100 and $200, and only 10% would be paying more than $200 a year.
If one looks at just new systems, which includes construction of collector sewers, the results
are much more dramatic. In this case, 20% of the communities would be paying greater than $200
a year. That amounts to a lot of households paying a lot of money.
This EPA study has been substantiated in some of the 208 areas we've worked. In Florida, for
example, we found one treatment facility that was built, with several communities beyond the
prime community first promising then refusing to tie-in, which resulted in user charges upwards
of $60 to $80 a month for sewer service. That amounts to almost $1,000 a year for sewage ser-
vice. There are a lot of fixed income people in this planning area, indicating if there are
people making $5,000 a year on Social Security and their sewage bill is $1,000, you can have
extraordinary economic impacts.
In other areas we've run up against the same kind of problem. We find, in some instances, the
cost of sewage treatment for a whole package can be up to 10% of income. Now, I look at my
income, take 10% of it, and I find it difficult to justify paying this amount for sewer service.
We've got electricity, water, gas and other utilities to cover; paying 10% alone for sewer
service is ridiculous. Yet, we've found that to be the case in many instances.
So how much should somebody pay? What are the guidelines? Is it 10% of your income? 5%? 1%?
Some agencies have been dealing with this issue (Exhibit 5). Among them are the Farmers' Home
Administration (FHA) and EPA, along with several states which have to deal with this problem on
a day-to-day Basis. You can see that the FHA has used as a criterion in their program, that if
sewer service is greater than 1% of median family income (for debt service alone) they will
provide either low interest loans or grants to this community to help reduce the cost, to below 1
of median family income.
EPA has taken this approach one step further. They've taken the 1% of median family income for
debt service as a base criterion, and have also stated that if greater than 2% of median family
income is being paid out for total sewer service (i.e., for capital costs plus operation and
maintenance costs) then these communities or these households will be suffering hardship. In
other words, it's greater than 1% for debt service alone, and greater than 2% for debt service
plus operation and maintenance.
Several states have also looked at the hardship issue. You can see the first two sets of cri-
teria set by the federal agencies are more or less absolute—a flat 1% cutoff. Virginia, in
trying to distribute funds equitably on a statewide basis, has looked at the state average of
total utility costs relative to average income. They've actually obtained the data to calculate
the state average of total utility costs and divided this byttie state median income. Then for
the individual facility plan, they perform the same calculations. They calculate, for the
average household being served by the proposed sewage facility, the expected utility costs.
And by utility, I mean water, electricity, and phone, plus sewer service. They then take the
typical utility costs and divide by the median family income in that given area, and compare
this against the state average. If people are paying more than the state average, when Virginia
has had the funds, the state provides additional grants for these communities to reduce the
averages down to or below the state average.
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BOOZ
ALLEN
How Much Does an Average
Household Have to Pay?
All Systems:
Less Than $100/Year
60%
Between $100/Year and
$200/Year
30%
Greater Than $200/Year
10%
New Systems:
Less Than $100/Year
25%
Between $100/Year and
$200/Year
55%
Greater Than $200/Year
20%
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BOOZ
AUJEN
How Much Is Too Much?
in
in
Farmer's Home Administration
— Greater Than 1% of Income for Debt Service
U.S. EPA
— Greater Than 1% of Income for Debt Service
— Greater Than 2% of Income for Total Service
State of Virginia
— Greater Than State Average of Total
Utility Costs Over Household Income
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How Do General Obligation and
Revenue Bonds Compare?
(ALLEN
Characteristics
G.O. Bonds
Revenue Bonds
Backing
General Revenue
'Enterprise" Revenue
Debt Ceilings
Usually Applicable
Usually Not Applicable
Prevalence
Most Common
Common
Interest Rate
Determinants
Credit Worthiness
of Jurisdiction:
Debt to Value of
Property
Debt to Per Capita
Income
Potential for Default:
» Net Revenue to
Principal & Interest
> Household Charges
to Past Rates and
Per Capita Income
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I have been concerned with measuring and assessing ecomonic hardship—the impact on the
individual household. There's also another problem with the funding of these sewage treat-
ment facilities, and that is the impact on the local government—the impact on the community's
fiscal integrity. Alan will address that to finish up.
ALAN FARKAS
Local governments will use general obligation bonds, they will use revenue bonds, some will also
use bank loans to finance. Now because bank loans are only issued by very small communities,
and even then it's not a preferred alternative, we've only to focus on general obligation (GO)
and revenue bonds. In Exhibit 6, we compare these two types of instruments in terms of four
characteristics: with regard to backing, general obligations are backed by general revenue;
that is, all the revenue the jurisdiction collects through exercising its taxing authority.
Revenue bonds, on the other hand, are backed by revenue generated from the enterprise being
financed. In terms of legal debt ceilings or limitations, these legal limits usually apply to
general obligation bonds. Typically, debt limits are imposed on a locality either by virtue of
the state constitution or statute. The laws rarely apply those limits to revenue bonds. And
for this reason, some communities prefer to issue revenue bonds when they have the legal author-
ity to do so. We do find that general obligation bonds are most common. In a study that was
done for the National Commission on Water Quality, we find that twice as many communities use
general obligation bonds as use revenue bonds for their treatment plant financing. This is
probably due to the fact that, in many states, localities do not have the legal authority to
issue revenue bonds.
Interest rates are, of course, a critical concern. The determinants of interest rate are varied
between these two types of instruments. For GO bonds, the primary determinant is the credit-
worthiness of the jurisdiction. Credit-worthiness is a function of such things as the total
community debt, the value of taxed property, and the ratio of total debt of capital income. It's
to these kinds of indicators that the rating agencies look in trying to give a credit rating to
a locality. Moodys and Standard and Poors will rate the financial health of communities. If
your community has a credit rating of BAA or less, and is going to use GO bonds to finance a
facility, you will know there is a potential for some problem. If your community is unrated, and
if your community hasn't been to the bond market recently it probably will be unrated, then you'll
know that the condition in and of itself may cause problems. Certainly your community can expect
to pay a premium interest rate when it goes to finance.
With revenue bonds, the interest rates depend primarily on the potential for default. Potential
for default relates to the net revenue generated by the enterprise compared to the bond principal
plus interest payments. In reviewing a proposed treatment facility bond issue, investors may
also look at the projected household charges and how those compare to past rates of per capita
income. For the revenue bond therefore, there is a direct relationship between the reasonable-
ness of the projected charges and the feasibility of financing.
What are some of the main concerns of the local government ? Can the bonds be sold? At what
interest rates? And at what consequences for future borrowing? In 1975-76 when New York City
first broke through its acute financial crisis, the public became aware that the answers to
these questions are not always pleasant ones. The answers to the first two questions depend not
only on the soundness of the municipality's finances or the soundness of the project to be con-
structed, but also on the conditions in the bond market. During the New York City crisis,
there were many localities that were unable to go to the bond market to raise capital. Even
today, there are some communities that would be precluded.
Regarding the consequences for future borrowing, there is some concern with respect to GO bond
issues If a community is going to finance a treatment facility with GO bonds, it is going to
be incurring debt against its limitation-thus, it may be precluded from financing any other
needs down the road. In addition, the added debt that a treatment facility represents may
cause the credit rating of a community to drop. When this happens, not only does the interest
ra?e thai the community has to pay for that issue increase, but the interest rate for subsequent
borrowing also increases.
Booz-Allen looked at these three questions for some 350 New York State communities that have
identified a need for treatment facilities. Our report is rather confidential and I can t,
Iherefore, share with you the specific findings, but I can tell you that we found « significant
fraction of the communities will be precluded from going to the borrowing market. And an addi-
tional significant fraction of the communities can only raise revenue by either paying an interest
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13OOZ
ALLEN
How Important Are Interest
Rates?
Interest Rates Determine Debt Service
Requirements and Impact User Charges.
Case of City X:
— $5.2 Million Needed for Local Share
— Credit Rating of Baa-1; Use of G.O. Bond
If City X Had the Highest Rating of Aaa, How
Would the Financial Picture Compare to the
Current Situation:
Credit Rating
Baa-1
Aaa
Interest Rate
6.34%
5.18%
Interest Payment
$5.2 Million
$4.1 Million
Total Local
Share (Interest &
$5.2 Million
Principal)
$10.4 Million
$ 9.3 Million
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What Can You Do to Ensure a
Proposed Facility Is Economically
and Financially Sound?
' fp, ri r? *f^r' i« f)
, ALIEN
en
vo
Request That User Charges Be Estimated in a
Facility Plan and That They Cover All Appropriate
Costs, Including "Ineligible" Capital Costs, O&M
Costs, & Debt Service Costs Employing Realistic
Estimates for Interest Rates.
Compare Projected Charges, to Per Capita Income
to Assess Reasonableness Against Different
Guidelines.
Be Sure That All Possible Federal Funding Sources
Are Investigated.
Suggest That Your Local Government Retain
Qualified Financial Counsel to Determine and Make
Public:
— Whether a Needed Bond Issue Can Be Sold
— Likely Interest Rate
— Effect on Credit Rating and Debt Ceiling Limitations
-------
rate premium or by incurring adverse consequences for future borrowing.
Now that I've concluded the discussion of the financial aspects of sewage treatment, let's take
a closer look at the issue of interest rates. I'll try to give you a quantitative feeling of
how important they are (Exhibit 7). Interest rates determine debt service requirements with a
resultant impact on user charges. Let's take the case of city X. City X is a community in
central New York. Here are the facts: $5.2 million is needed for the local share of capital
treatment plant costs; city X has a credit rating of BAA-1 (this is the lowest investment grade
rating) and city X will have to use GO bonds (the opportunities for communities in New York to
issue revenue bonds are very few).
Now we pose this question. If city X had the highest rating of AAA, how would the financial
picture compare to its current situation? We're assuming that we look at the credit rating,
the corresponding interest rate, and calculate the interest payment that would accumulate over
the next 25-year life of the bond, and then display the total cost of principal and interest.
At the BAA-1 rating, the community has interest payments totalling $5.2 million. Incidentally,
this happens to be the same as the cost of principal. In a AAA rating, the community would pay
$4.1 million. In other words, the community, because of its low bond rating, will be paying
about 25% more in interest rate payments over the life of the bond. When we add the interest
payments to the principal, we find that that community will be paying about 12% more with the
lower bond rating.
Finally, we would like to pose the question of what you, as citizens and public officials, can
do to insure that a proposed facility is economically and financially sound (Exhibit 8). First,
it is important to request that all user charges be estimated during the facility planning stage.
These estimates should cover not only the eligible capital costs but also the ineligible capital
costs, O&M costs, and debt service, employing some realistic estimates for interest rates.
EPA has been very diligent in trying to encourage communities and their consultants to show
these costs up front in a way that is meaningful to the public. Larry and I and others from
Booz-Allen have reviewed facility plans in six or seven states over the last year, and I can
tell you that this is a requirement that is honored in the breach. Usually the costs are not
presented in a way that is understandable to the public and not presented on a per household
basis and often they don't include the total costs.
Once you can get the total costs realistically stated, you can compare these projected changes
to per capita income to assess the reasonableness against selected guidelines. Larry has told
you about some of the guidelines that are used by federal and state agencies, and you can develop
your own criteria as well.
If user charges are high, you want to be sure that all possible federal funding sources are
investigated. In addition to EPA and FHA, HUD and EDA have provided various loans to communities
that meet certain eligibility requirements.
Also when you have high costs, you want to be sure that alternative treatment systems have been
fully investigated to see whether the costs can be reduced by using one of the more unconven-
tional systems. Note that not only might the actual costs be less—particularly since unconven-
tional alternative systems often have low O&M costs (which is the portion of the cost that gets
no federal subsidy) but unconventional systems may also qualify for the extra 10% bonus in
federal funding (i.e., 85% rather than 75%) that the 1977 law gives to "innovative and alterna-
tive" systems.)
Finally, request that your local government retain qualified financial counsel to determine
and make public, at the facility planning stage, whether a needed bond issue can be sold, the
interest rate and what effect that will have on credit rating and on debt ceiling limitations.
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WESTERN WATER RIGHTS AND LAND APPLICATION
JOHN MUSICK: Partner in a Moulder, Colorado, law firm. As a specialist in water- law,
Musick has aided aonmrunities in developing innovative solutions to water
supply and wastewater treatment problems.
I listened to what Alan Merson [EPA Regional Administrator] said yesterday about lawyers, and
I thought long and hard about his comments. I view a lawyer's contribution, or the contribution
of law kind of like the English monarchs. It's not so much what it does with its powers as the
powers that it denies of others. So that's a fairly important concern when you're dealing with
water rights. We, those of us who—fortunately or unfortunately—practice the subject of water
rights law, find ourselves dealing also with the subject of sewer law. So that gives a play on
words for the kind of lawyers we are. Actually, the subjects of water rights and sewage law,
or the law of the right to use sewage, are interrelated.
I can say across the board, based on my knowledge and my experience on Western states' water
rights laws, that laws will accommodate the kind of use you want to put to it. Remember, this
is not a circumstance where you have to make a choice of evils. You don't have to make a choice
between water rights law or water quality law. Stick with the law that we have, stick with the
Western states' water law. I, for one, support it. I think that it's a very, very good system.
You have to think back on what we've been successful in doing with the appropriation doctrine.
We use that as the commonly accepted method for apportioning water in the West. With the appro-
priation doctrine, we have irrigated the great American desert, built power plants, and we've
caused cities to grow and supplied the water to them.
Now, we have some other problems with it. We have to make the law adapt to our changing needs
in this society. And I believe—strongly so—that in states like Colorado, where we have the
appropriation doctrine, these laws can be adapted to the changing needs of the society. An
example of this is the city of Northglenn. It is not, however, the only example. Yesterday
John Marsh talked about El Reno, Oklahoma. Now, the law of groundwater of Oklahoma is different
from the law of groundwater of Colorado. But he was describing a system in El Reno, Oklahoma
quite similar to what we're doing in Colorado with Northglenn. That is, basically borrowing
the farmer's water and returning the utmost to the farmer. It was accommodated in the Oklahoma
legal system, even though that system is different than Colorado's. So my general proposition
is that the laws cf the Western states will accommodate the types of uses you want to make.
I think that proposition will stand.
The importance of this is that it's up to you, it's up to the individuals in the communities
and their leaders to determine the kind of system they really want, after some very, very
difficult soul-searching. The law should not be thrown up to you as being a hindrance. Now,
we get involved in a lot of battles with EPA, with our own state water administration officials.
Everybody says well, what about water rights? And I tell them, "Well, we'll solve that
problem." And it's not a problem. In our state, fortunately, we have some cases that say that
there is a "non-injury" doctrine. What that means is you can basically do anything you desire,
so long as you do not injure someone else.
That has direct or indirect applicability throughout the West. In any state in the West that
principally has used the appropriation doctrine, whether it has used it with modifications like
the riparian system in California or the permit system in Wyoming, basically the assumption is
that you can do as you need for your community so long as you don't injure anyone else.
Remember, we're talking about the law. You may like to say to yourself, "Well, I don't really
want to go to land treatment." Some sanitary engineers say, "First of all, there's a water
rights problem, and second of all, you'd rather have some type of sanitary treatment facility
rather than a land treatment facility." Remember it is the ]aw--the federal law, PL 92-500, the
Clean Water Act—that the engineers "shall investigate all reasonable cost-effective alterna-
tives." And it has been supported by direct statements by the EPA Administrator, Douglas Costle
of the EPA and his right-hand man Mr. Tom Jorling and you heard yesterday Mr. Alan Merson, our
Regional Administrator. They have been supportive of the requirement that land treatment shall
be considered. If land treatment poses problems with water rights, I submit to you that it is
incumbent upon you to find a way to solve the problem. I believe after having investigated the
laws of other states, worked extensively in Colorado and to a limited degree in other states,
that the problem can be solved.
I'll use one kind of general example. In every state there are—as I see it—if you want to go
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to land treatment or some type of cooperative system other than a mechanical plant, there are
four necessary elements. You have to have a water source, or else the citizens can't drink
water and the farmers can't supply the water. Usually both groups, cities and farms, are com-
peting for that water source. You also have to have a storage facility or a method of con-
ducting the water to the farmers and the city. You have a city that needs the water. It also
does something else. It generates waste. Waste which should not be thrown away, but which is
an asset. And, finally, you have the farmers.
With those four elements, in any combination, you can work out a land treatment system or an
alternative system of water supply and land disposal. It doesn't necessarily have to have the
water supply—which, in the case of Northglenn—is Clear Creek flowing to Stanley Lake Reservoir
flowing into the city of Northglenn and then to the farmer's ground. You can reverse those
processes. Like pieces on a chess board.you can move them around any way you wish. Our law
accommodates it. In almost every state in the West, directly or indirectly, the water laws
accommodate it too. And in the Eastern states too. [Persons interested in the legal details
and other details of accommodating water rights laws to sewage recycling plans, should consult:
"Colorado Water Law and Clean Water by Irrigation with Sewage Effluenf'by Musick et al, available
at the Clean Water Fund.]
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LIBERATING TECHNOLOGY: SAVING OUR WATERS AND DOLLARS
RALPH NADER: Consumer advoaate. A longtime observer of the conditions under which new tech-
nologies are either stifled or encouraged, his many accomplishments include
playing a lead vole in bringing about federal laus safeguarding water supplies.
Powerful Vested Interests
The particular problem we're addressing here today has numerous characteristics that are preva-
lent in many other areas of publically-purchased technology. These characteristics present a
series of obstacles to innovation and to broader value systems than the value systems of the
firms and the government agencies, the professional organizations that work in a particular
technological area. We know, of course, that there is a sub-economy that's developed in this
country that has pushed expenditures in sewage treatment to considerably high levels, and it's
one of the few areas in the environmental sector that has a very powerful vested interest.
You really don't have to worry about Congress sunsetting this part of the programmer saying
that this part of the program is a fundamentally inflationary factor in our economy. Notice
that when Mr. Robert Strauss indicated that he was going to go after environmental regulations,
there was no mention of this area whatsoever.
The problem is something that has not been given very wide publicity. For some reason it has
been suffused with technical jargon and technical societies and technical firms who are not
really interested in publicizing this in a broad sense to reach the millions of people who are
paying the bills, from both an economic and a health standpoint. Furthermore, it has an image
that it's now on track, and it's a construction program—you just keep on building and building.
It has an image of having momentum.
No Organized Citizen Constituency
Well, as we might well have suspected, this problem, in its breakdowns, is beginning to per-
meate other areas of the environmental health and it's coming full cycle to plague us. In
particular, note the weak efforts to implement the Safe Drinking Water Act of 1974 by the EPA.
A recent slight revival of the recognition of that law by the EPA is suffering grossly from
the lack of a citizen constituency—not even an organized citizen constituency, just a plain
unorganized citizen constituency. And in the hearings EPA has held around the country in
recent months, the water works people have been there in full force, equating our constitutional
rights with the freedom to drink risky water until the evidence of health damage is fully sub-
stantiated—which means a statistically representative sample of victims geographically around
the country who fall on their knees, about to expire, and utter the words, "It was cadmium in
our drinking water."
Facets of the Problem
Now, the various facets of the problem in the sewage treatment area can be summarized quite
quickly.
o One is the usual corruption that attends government procurement programs. I say usual now
because the clearly recent events have shifted the burden of proof on those who have a Polly-
anna view of life in the procurement area, and now even the Government Service Administration
has been stunned with exposure of kickbacks in the management of relatively simple technologies
known as government office buildings. We do have a corruption problem, and that translates of
course often to substandard technology.
o A second aspect, of course, is contamination of our drinking water both by the pollutants
and the chemicals used to treat them. We all have heard of the chlorine problem and its pro-
pensity to combine with other industrial chemicals to produce chloroform and carbon tetra-
chloride.
o Another is the depletion and waste of water resources. The scarce fresh water effluent
is being piped into the ocean in many places while ground water supplies are drained dry.
Florida has a really serious problem—it's going to become even more serious—of the depletion
of the underground water reserves. Not only that, but the carcinogens in Miami's drinking
water are very numerous, which indicates that the process of contamination is we!1-advanced.
o Then there's the nonreliabil ity of the technology itself. It's been estimated that about
50% of the federally funded treatment plants will fail to meet design specifications or even
comply with federal pollution control standards. So we may have some real white elephants—
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bills come due and these systems are found not only to degrade rapidly but not even to have
worked properly at the outset. This, of course, will also be associated with the rising taxes
to pay sewer bills, and pretty soon that rise may be another stimulant to make the utility
perform, along with the public outcry against higher electricity prices and gas prices.
o In some localities, of course, there is neighborhood disruption. You don't see major cen-
tral sewage treatment plants in Scarsdale or Grosse Point, and the situation I've described is
going to tend to develop more and more neighborhood concern for the immediate presence of these
kinds of installations. New York has shown us what the legacy of sludge can be like, with the
expiration of much of the oceanic life around the New Jersey coast and the south New York State
area. In fact, they call it "Dead Sea," and they have other descriptions for it, and it's kind
of a mode of economic growth, is it not? I mean, you finish off one part of the environment;
this creates new economic demands to deal with the wreckage in the first place, and in a kind
of spiral of technological insanity, you increase the gross national product.
o And then there are the worker hazards, which I think would do more to dramatize the subject
than perhaps anything else. I'm sure some of you, who have spoken to workers who descended the
depths, know that it isn't just a kind of disagreeable type of work—they face deficient oxygen,
digging and crawling around in the sewers, the toxic gases—sometimes fatal—explosions, etc.
o There is also the stifling of available technologies. The country periodically gets into a
serious grip of technological stagnation because the new technologies challenge the traditional
investment in the old technologies and they also challenge the traditional vested interest,
vested ideas. There are people who have worked all their careers on a certain technology.
They've got their egos and their reputations committed to it and they feel threatened by some
other technology, particularly one that isn't highly capitalized, or maybe a little more decen-
tralized, a little more practical, a little more old-fashioned, a little more quaint, a little
more rural, and smaller. It's like the image of one going backwards into the future. There
isn't just an economic vested interest. It's very much an intellectual or professional vested
interest that John Kenneth Galbraith has called "the most entrenched of all vested interests."
We see this in the nuclear area, the automobile area; we see it in the cosmetic area. You have
to displace certain habits, certain career roles, and that means coming up against solid stone
walls.
Now, the question of liberating the technology, of course, raises the various alternatives that
you've discussed and will discuss later on in this conference, alternatives such as sewage
recycling and the sewerless technologies that have been suggested and have been working in some
parts of the country and the world.
Obstacles to Technology Alternatives
But the question is not so much that we're going to come up with some new ideas or apply some
old ideas that have been blocked, but what are the obstacles? Are they purely technical? No,
they are not purely technical. They're not even purely economic. They basically are obstacles
that deal with a very tightly organized sub-economy that surrounds this multi-billion dollar
industry, without the susceptibility to displacement or challenge from the outside. It is a
very secure type of sub-economy. It does not, for example, have the insecurity of competition.
Competition is an insecurity. If you don't do a certain thing in a right way and people who
buy the service or product know that there's a better way, you're going to be insecure in
terms of being displaced by someone else. In sewage treatment you have a public procurement of
materials and services. You don't have the kind of competition you have in a more ideal
setting, in the market place. You also have the kind of specifications and standards that can
tend to lock out innovators or competitors or make it incredibly difficult for them to, in fact,
submit their collective bids.
Now, the non-technical obstacles to innovation extend beyond the absence of competition. For
example, you have the internal resistance to change in the government. The water works people
have even defined the lowest of expectations about their ability to change. In fact, this
really surprised me, and I don't surprise very easily when I see this kind of intransigence.
But when Robert Harris went on a national survey for me a few years ago on drinking water con-
tamination in various cities, he went down to New Orleans and was treated like a kind of Sher-
man heading for the sea, only he didn't have any troops. And he received a nasty kind of "What
are you doing, asking questions? We've got everything under control." And when he put out his
report on New Orleans drinking water, the response of the officials in Louisiana was aston-
ishing. The head of the public health unit in New Orleans went on television and said there
were a lot more dangerous things you could do in New Orleans than drink the water. And then,
of course, the governor did what was expected of the governor. He said he just loves New
Orleans drinking water; 1t makes great iced tea and he drinks 1t every time he's in New Orleans.
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Why has Change Been Stifled?
We can go through a number of issues. They sort of interlock among themselves. One is that
the utilities, of course, are monopolies--! mean the people, the institutions in place.
There's also a kind of technological monopoly which you've talked about; the fact that you
cannot find firms easily available who want to do alternative treatment work. The conventional
treatment dominates the operating economy in this area.
There is also a scientific monopoly. Teaching, research, training of young people to go into
this area, have been dominated by people who have the conventional-style treatment know-how
and approach, so it tends to become an inheritance process.
And then there's a professional lack of competition. The sewage treatment industry is domin-
ated professionally by the sanitary and civil engineers and their professional codes of conduct
can sometimes stifle not only criticism but needed competition.
Of course, all this could be so—this closed network, this closed sub-economy, this closed
enterprise system, if you want to call it that—and still be susceptible to creative disruption
by superior forces, on the merits, if there wasn't such a breakdown of representation. It s
hard enough for an individual consumer in the market place to protect oneself, but in this
situation, we are several layers removed in responsibility. You have the third party payment,
you have the seeds for enormous waste and lack of accountability. Here we have, in effect, the
city, or the state or EPA, functioning as a representative of the ordinary citizen, as the
public buyer, so by definition it's not coming out of their pockets. This creates opportun-
ities for conflict of interest that do not arise when buyers represent themselves. All the
commercial forces—labor, business, real estate operators, large land owners, chemical compan-
ies, construction—all have a stake in the outcome of the sewage treatment decisions. With so
much money involved, they have a reason to constantly lobby and communicate with government at
every level. The saga of the revolving door is known here as well. They communicate in a way
that ordinary citizens, the consuming public, cannot do, unless it's organized—organized in
ways which I will try to suggest in just a very few minutes.
With this indirect representation of the taxpayer, the consumer is removed a step further,
because the city then delegates some of its responsibilities to technical consultants to give
it advice. If you map it out on a piece of paper—the sewage treatment industry and the
government role it's in—it's a classic case of government run amuck.
It is not just one-step delegation, which is what a legislature is for people; or a two-step
delegation, which is what a government department is; but it's a three-, a four:, a five-, and
a six-steo delegation, often times, right back to the private sector. It s as if the public
sector serves as a sheen, a sheen of public presence, but it's merely, in fact, a transfer
agent for the decisions to be made back in the private sector where the conflicts of interest
between public trust and private profit are apparent. Certainly we should not burden the pri-
vate sector in the sewage treatment industry with public trust; they have enough problems just
doing the job for the contracted amount in a reliable confident manner.
Now the government, of course, bears the burden here. It takes two to tango, and they seem to
promote the lack of competition. When a dominant industry or techno ogy or profession converts
its power to political power, the activities of government, if it tolerates this kind of power,
cements the absence of competition and makes it even harder for new ideas to come forward.
This happens in a number of ways. The standards, of course, tend to be based on the dominant
solutions at the time rather than on the best available solutions, and things just sink to that
level It's a national requirement, for example, that every city install secondary treatment.
This requirement has led EPA, in response to overwhelming momentum and pressure from estab-
lished sewage treatment forces to disallow anyone to spend any extra money to do better than
secondary uStil everyone has arrived at the secondary level-which of course forces them
down the conventional treatment road in many cases. Another example is the water quality
standards, which in many places are similarly based on what conventional treatment can accom-
plish rather than what clean water is needed. If citizens want better technology they have to
work to raise those standards so a better result is achieved.
There are alsc the professional standards which I have alluded to, and these often screen out
people with skills to design some alternative systems. There's nothing more heartrending in
Ehe innovation area than to see someone with a fairly good idea not gettmg a chance to have it
evaluated—after knocking on doors a hundred times and having them slammed shut. It's a poli-
tical game, it's an access game of who has the best know-who rather than know-how.
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Then there's the problem of professional standards intruding in the agencies themselves. You
get people belonging to the same professional societies; some work in government; some work in
industry. They meet each other regularly, and there's a kind of homogenization process. One
suggestion would be that all government officials always refer to all private sector contrac-
tors as Mr. or Ms. The minute you start by first names, you're on your way down, and pretty
soon you say, "How about some golf?" The formality is really broken down between government
and the people and the firms, who hover around government for recurrent contracts. There's
also a tendency to promote uniformity in the approval process when being able to rubber stamp
standard solutions is easiest.
The problem with subsidies, of course, when you have 75% federal money or more from the govern-
ment is that it can dilute the demand for more efficient solutions. Since 1972, more than 99%
of the federal grants money went for conventional treatment. The federal grants program has
had a multi-billion dollar smothering impact on alternative technologies, and a lot of people
have said that. But more people have to say that, until there's a response to that rather
easily substantiated charge.
The civil service is also a part of it. It means it takes more time for old directions and
cozy relationships to change.
All these factors operating together, of course, develop this network of obstacles to finding
the best solutions, experimenting with different solutions, and the like.
So, how do we find our way back? How do we free these available solutions or develop the cli-
mate for the refinement or expansion of present ideas that have some sort of installation
record but are not diffused widely? This requires citizen action, of course. A good question
is, given all the demands on citizens to get interested in this and that, such as neighborhood
revitalization, housing, consumer protection, air pollution control, tax reform, mass transit,
health care, hospitals, nursing homes, police protection, other municipal services—how can
you put this in the ring? Particularly since people don't like to say—in answer to the ques-
tion, "What are your citizens' concerns these days?"—the answer, "Sewage." So we know it
always produces the kind of snickers that reduce that kind of civic enterprise to relatively
low status on the totem pole of other civic enterprises.
Here are a few Suggestions
First, one can say, citizens must get organized, and if citizens do net get organized, the pro-
cess will continue to deteriorate. Truism, number one. It's at that recognition that we have
to step back and ask: how do we develop the instruments which will facilitate the attraction
of the small number of citizens in a community who could become most interested in doing some-
thing about this? In order to do this, you have to have an inexpensive instrument, an inex-
pensive mechanism that will regularly screen as close to 100% of the citizen universe in order
to extract the support of perhaps a fraction of 1%, which can be quite decisive, as we all know.
Now, when you're dealing with utilities, you are dealing with legal monopolies which really
can't lose money. I was just reading the other day where people in Maryland conserved watery
more than that, they conserved water so adequately that now their rates have to go up. There s
nothing more destructive to civic cooperation than that, whether it's in California or Maryland.
Because, however it may be explained, the explanation, if there's any, is not going to be com-
municated. The utilities, as legal monopolies, should be required to state law, to permit a
piggyback-free communication system to consumers, so that for all utilities, any time there is
a letter or bill to the customer, there is a slip of paper in the envelope which says: Con-
sumer action is critical to the proper functioning of your utilities. All those who are
interested in making a voluntary contribution of, say, $5 per year to join and become a part in
the democratically accessible consumer or action group dealing with utilities, can send their
contributions to " And then this group would have full-time organizers, publicists, some
experts, technicians, etc., that would deal with these problems at all levels of citizen
action—hearings, legislative deliberations, court case?, mobilizing neighborhoods, changing
patterns of accountability, or ownership, and the like. This proposal is now being considered
by five state legislatures geared toward conventional utilities.
Once this consumer checkoff, so to speak, gets established, you will have this inexpensive
interface with the universe of citizens in order to attract the smaller number who can become
a political and technical force to do something about it. Short of that, we already have HEW-
funded organizations of citizen energy councils, residential energy consumers, in power ser-
vices areas, joining together to become more effective,
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Then I note that EPA is supposed to be conducting education of the public on water conservation
and water recycling. Having local citizens plan and organize their own local public education
programs would be one of the most effective ways. Apparently, this already allocated money
should be spent. EPA has about $200,000 or so looking for demand.
Then, of course, the alliance factor—forming alliances with other groups with an interest in
alternative technologies could strengthen a kind of common philosophy, even though it may be
applied in different areas of our economy. This kind of network can be extended tc the nation-
al level. For example, I was reading an article the other day where the author claimed that
billions of dollars have been spent by fishermen looking for a bass that exceeds the all-time
record of 23 pounds; a bass which was caught in Georgia back in 1933 or '34. And there are
just hundreds of thousands of fishermen looking for the bass; you know they all know about it;
it's a great thing if they could ever get a bigger bass. Well, see, some of those people have
to step back and save the waters so the bass can thrive, so they can beat the record. We need
generic fishermen who go to the source of the problem that's perhaps depriving them of winning
the record. If the fishermen would ever get fully mobilized and support the small groups that
are already organized, nothing could stand in their way. You know that. Nothing could stand
in the way of determined fishermen. For two reasons: one, there are huge numbers of them,
and they're very well-connected; and, second, they can't be accused of being crusaders, because
they're sportspeople. So, they're not doing it to save people's lives; they're doing it for
their recreation, and politicians know that really means business.
Then perhaps we can find a way to set up expert action teams of engineers, scientists, organi-
zers, people who can motivate citizens,to begin developing manuals that are simple to under-
stand, that citizens around the country can grab hold of. Then there's the need for clinics,
that is, quick 3- to 5-hour training clinics. These roving teams of specialists can go all
over the country and train people, leave the manuals, and develop a network, because these
networks are self-motivating, of course.
There's also a need to institutionalize a way to exchange this information regularly. This
isn't just "here's what's happened folks;" this is a lot more dynamic, a change-oriented news-
letter or communication process. And not just in the printed word, but. we also have to hit
the television and radio on this; there are cable systems now that have a lot of time space;
there are programming opportunities for EPA and others to get into this type of thing.
I know you're going to hear in just a few seconds Tom Jorling and if I can predict what he may
do, he's going to tell you what EPA is doing as of January 1977, by way of a new look. But
you know, the more I watch well-intentioned skilled people in government agencies operate, the
more I have to realize they really can't do very much without a citizen backbone out there,
because they are surrounded by extremely inquisitive and knowledgeable special interest groups
who have their offices here in place and their networks throughout the country and there's no
way you are even going to be able to stand up to these people.
Even in the area of public hearings for pure drinking water, to get the contaminants out of
drinking water, the EPA hearing officers are being berated all over the country by water works
people who tell them that the standards are unrealistic, they're not. needed for health, etc.
Meanwhile, back at the faucet, in a hundred million homes, people are quiet. So above all, we
have to find the communication means to alarm people.
This concept that government must not unduly alarm people is absolutely nonsense. Government
has to alarm people, and, given the seriousness of the problem, they have to go a long way to
qualify for the adjective "unduly." It's their function to alarm people. It's the function of
Doug Costle to go on "Meet the Press" and tell people there is a major contamination problem in
many of our mass drinking water systems, and that this is in part due to the sewage mistreat-
ment process, and this is an emergency and it is a crisis—even though it involves silent vio-
lence and impersonal violence, and difficult epidemiological connections. It clearly is sub-
stantiated in statistical studies that more people are going to get sick and more people are
going to die as a result if this is not stopped. And he must make a final appeal by saying:
"My friends, it's not going to cost you anywhere near what it's going to cost you if you don't
spend the money in a wise fashion." So somehow we have to find a way to communicate the urgen-
cy of this in a far superior manner than we have. One can think of some very basic and clever
metaphors to stimulate people into action on sewage treatment, even if it involves a substan-
tial application of humor.
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PROMOTING ALTERNATIVE WASTEWATER TREATMENT
REP. TIM WIRTH: Serves on the House Interstate and Foreign Commerce Committee, and on Science
and Technology Committee. Wirth holds a PhD. from Stanford, and was a White
House Fellow and Special Assistant to former HEW Secretary, John Gardner. He is
finishing his second term from Colorado 's 2nd Congressional District.
While I am not an expert in the area of alternative treatment processes or all of the things
that you are discussing at this conference, I am increasingly becoming an expert in the political
world and about how to try to get things done.
I thought it would be useful to talk about our experience here and what we tried to get done on
sewage recycling, how we tried to get momentum going. Maybe some of that will be useful for some
of you to take home and apply in your own community.
Right after I was elected at the end of 1974 it seemed to me that an important thing to do was
to look at the vast public works projects that the federal government was funding. We started
right away to take a shot at the B-l bomber, which we all know is one of the great public works
projects of our time.
The wastewater treatment programs deserved a very significant look. After all, we're spending
close to $5 billion of federal money on it. Where is all that going? One can become necessarily
skeptical about the kinds of bureaucracies and organizations that are going to administer all of
that money. I felt there was some conventional wisdom going on there that we should try to break
into. Happily, the kind of success that I had was reinforced by Ray Wells, who has been the
city manager of Muskegon, Michigan, and was the internal force getting together the Muskegon
program, which I'm sure many of you have heard about this morning, or will hear more about later
on today. The key person in that project was Jack Sheaffer, who is right up here. Ray Wells
suggested that we consider looking at alternatives to conventional sewage treatment programs.
Clearly, this would be particularly important in Colorado where water is scarce.
After sending invitations to a seminar out to a broad cross-section of people--we asked all the
members of the City Councils from all over Denver and Denver metropolitan areas, the county com-
missioners, the state representatives, the regional council of governments, the water lawyers
and many others. We met in my office one afternoon with about 150 people. In about a two-hour
session, Sheaffer talked about the Muskegon experience and water attorneys made some comments.
It was very clear that there were a number of people in the room on various city councils, and
commissions or boards in various local government agencies who had thought or heard about land
treatment. We watched for individuals who looked like they were responsive. By the time everyone
had been talked out , Ray Wells, Jack Sheaffer, and I had identified about 15-20 possible
willing people. As people began to leave, we went zipping around and pulled all those people.
over into the corner. We asked who in that group might like to carry things on to the next step.
Well, it turned out that out of that group came a hard core of eight or ten individuals who
devoted themselves for the next nine months to putting together a very clear explanation of what
alternatives to wastewater treatment programs meant, and why we should be looking at them. They
prepared an excellent slideshow and presentation, and we called them the Land Treatment Task
Force. They then took that presentation around and met with every one of the City Councils of
all the towns in the Denver metropolitan area. They went to talk with the Denver Regional
Council of Governments, the Governor's Office and really began to create some momentum. In about
half the communities in which they met, they would find a sympathetic member of a board of com-
mission or City Council and they would get that individual to offer a resolution to the City
Council or the city or county commissioner suggesting that they endorse looking at alternative
treatment programs.
After about a year and a half of this we had about 12 endorsements from communities around the
metropolitan area. We also had a very sympathetic Governor and people in the Governor's Office.
Harris Sherman was there as head of the Department of Natural Resources. Ken and Ruth Wright
were also working with the Governor. The upshot of all of this is that in the Denver metropolitan
area we now have two communities that are well on their way towards developing good alternative
programs. The northwestern suburban area of Denver in Westminster and the City of Northglenn
(in addition to the City and County of Denver). We ran into a lot of skepticism, particularly
in all of the agencies that you have to do business with. We said that they ought to be thinking
a little bit differently about sewage treatment. In any case, we now have a kind of momentum
going in Denver with a lot of people thinking and talking about it. This has happened in the
space of three and a half years. It obviously took an awful lot of work by individuals prior to
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our effort but I think this was the first time we were able to pull a lot of these concerned
people together for action.
If this process can be some kind of a model, most of you who are not from Colorado would pro-
bably find that the person representing you in the Congress doesn't know much about sewage
treatment alternatives. A good thing to think about doing would be to get your member of Con-
gress to use his or her office to help you advance the cause and help get the word out.
First of all, you want to meet with your Representative and Senator when both members of Congress
are in their district. Call and make an appointment and make sure that that individual under-
stands what it is you're talking about: why alternative treatment programs are important, what
the $5 billion funding program is all about, and the fact that there may be a better way of
doing the job. I think that you'll find people who are sympathetic, for the most part, to
looking at different ways of doing things.
The next step is to convince that member of Congress to use his or her offices, to use their
mailing list, and to set up the kind of meetings we did, in one community after another. There
are lots of other things that that individual can do.
And, there are probably some resources at EPA that can be used, if you're interested in trying
to get this kind of momentum going and need help. With new leadership and a new set of priori-
ties at EPA, one should be able to find some help there.
I hope that in these brief remarks I have been able to share with you some understanding into
the way each one of you can help out in promoting alternative wastewater treatment. Simply
understanding various alternatives is not sufficient. Communicating your knowledge and concerns
to the key decision-makers must be the focal point of your efforts and a careful strategy
must be developed. I'm very impressed by the quality of this conference and I hope that the
information obtained here in the past few days will help us all in the years to come.
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III. THE MUNICIPAL CONSTRUCTION GRANTS PROGRAM
A discussion of the legal and administrative requirements, tfce grants appli-
cation process, public participation regulations currently being drafted,^ some
of the obstacles to effective citizen involvement, and some of the remedies,
SETTING NEW DIRECTIONS AT THE ENVIRONMENTAL PROTECTION AGENCY
THOMAS C. JORLING: Assistant Administrator for Water and Hazardous Materials, U.S.
Environmental Protection Agency. The principle drafter of the
original 1972 Clean Water Act as a Senate staffer in 1971, Jorling
is now in overall charge of the nation 's water cleanup program.
The overall fabric of the Clean Water Act gives everyone an area in which to work—the notion
of protecting the integrity of water. I think it is a very sound notion and one that we real-
ize, as time passes, is an important step in the history of the nation. I think the concept
will extend beyond water to include all the elements of the life support system and become a
frame of reference within which the government will operate. The success of the 1977 amend-
ments is an indication that the 1972 Act is a solid political document, and one from which we
can derive some reassurance. It is not soft. I think one of the messages that came out of 1977
with both the Clean Air Act and the Clean Water Act was that environmental programs are here to
stay.
Let's talk about some of the elements of the program that EPA is charged with implementing. The
1972 amendments set in motion a policy of innovation, of encouraging alternatives to convention-
al sewage systems. That policy, however, was not very well implemented for a number of reasons-
agency inertia, state opposition, local opposition, health department opposition—a whole series
of oppositions. The 1977 amendments did not change that orientation towards alternatives;
rather they improved on it. They gave the policy some muscle. The muscle takes the form of the
increased federal share [communities adopting alternative systems get an extra 10%--85% rather
than 75%—federal funding], and the cost-effectiveness requirement with a 15% kicker, which give
us the ability to fund an alternative project, even if the cost is [up to 15%] greater than that
of the conventional system.
Now there are many difficult aspects to that policy when you begin to translate it into actual
language to govern these 1800 projects that we have underway at any one time.
And there is also the other concern that we do have the possibility of abuse. People are going
to be calling something green that is, in fact, red, just for the purpose of picking up an addi-
tional 10% federal money. We know we have some difficult management and administrative tasks
ahead of us. So in addition to being concerned about the environment, we're also very concerned
about the taxpayer; and hopefully the two interests coincide.
One of the other themes that emerges is the need for the agency to shift its manpower resources
toward a much heavier emphasis on that part of the process in which critical decisions which
seriously affect the environment are made-namely the Step 1 facilities planning process [This
is the phase in which a community reviews all the available options and chooses what kind of
system it will adopt, and where it will put It-the pipes, the plant, etc.-and how large it
will make it ] To enable us to do this and continue to maintain quality control in the btep J
process [the construction phase], we have undertaken with the Corps of Engineers a joint enter-
prise in which the Corps of Engineers will take over the management-the EPA role--in Step 3 ot
the process. They will contribute some 600 man-years of effort at the beginning of fiscal iy/y.
This is a program that has already commenced. The importance of that move is that it takes
EPA's environmental mission-type people and moves them into the overview of Step 1 so that we
can do a better job of assuring that bonafide consideration is given to environmental and social
impacts of those treatment plants.
Another theme that the statutes speak to in the 1977 amendments is eventually turning over the
managlLntTf SS SSgSl" most respects to the states. While.I support the general thrust
of the statute, I recognize that it may create problems for bringing about consideration of
alternative treatment systems. I know that there are personnel in my agency-both in the head-
quarters and scattered through the regions-who are either constitutionally or otherwise °PP°sed
to the notion of alternatives and innovation. I think, as a generalization, it is sate to say
that the states are even more hostile to those notions than are the federal bureaucrats. The
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states have an inherent need to get more federal dollars. Federal money is usually devoted to
support of bigger, more exotic technology. There is a genuine, very inherent institutional con-
flict of interest. They would like more federal dollars in their state; but more federal
dollars are not necessarily needed to fund alternatives and innovation. What can we do? Well,
we're going to try to execute the Section 205 program in a manner that prevents, to the extent
possible, that conflict from occurring.
But the prospects for state management aren't all bleak. The model for this program is Califor-
nia. California has been managing a construction grant program now for roughly two years with
only a very generalized supervisory role from EPA. When California picked up the program, they
hired 140 new people in less than six months. In one fell swoop they brought in 140 fresh new
bodies, new talent, to state government. Those 140 people have had more influence on the qua-
lity of the California program than any amount of regulations, any amount of guidance, any
amount of all the other bureaucratic techniques that are used to try and control a program.
When we hire 140 new people we have a possibility of changing these programs in very important
ways. We're looking forward, at least in the major states, to bringing a whole influx of new
talent, new skills, new perceptions, into government service. And that can be a very positive
benefit from the transfer of these programs to the states; it can't be achieved any other way.
So there's a very important plus that can be achieved.
We're also trying to improve public participation in the Step 1 process. Traditionally, there
has been little or no interaction between the community and the architecture and engineering
professions during the period of development of a facilities plan. That's an unacceptable way of
operating. So, in the regulations we're attempting to establish a public participation mechan-
ism during the facilities planning process, to provide the local community with a mechanism of
interacting with the planners. Through this practice we can be sure, at leas* to the extent
possible, that the alternatives are being considered,that the ft-mpaets are being evaluated pro-
perly, and that all of the features that are attached to one of these projects are analyzed and
reviewed, including the projection of operation and maintenance costs over the life of the
project.
There is another series of things which we must address concerned with public health and toxic
pollutants. Rather than throw our hands up, as many would tend to do when you talk about the
reuse of water, it's necessary to have an aggressive program that takes on those concerns
directly. We have to have an aggressive pre-treatment program, and we hope within the next few
weeks to have proposed pre-treatment regulations in the Federal Register. We already have eight
pre-treatment standards for particular sets of industrial categories in effect. Through the BAT
(Best Available Technology) toxic control program, we will have another roughly 400 such cate-
gories within the next three years, so we are beginning to address, in a very aggressive way,
the problem of the discharge of toxic materials into public wastewater treatment systems.
Sludge management is another area that cannot be overlooked. We have problems in many metro-
politan areas where the sludge contains high levels of toxic materials. We are now developing
a set of regulations which may provide a threshold test of whether municipal sludge can be
safely put on the land or whether the sludge is hazardous and must instead be transported to a
permitted hazardous wastes receiving site.
Another thing, in the same context, has to be the protection of groundwater. It is very easy,
without facts, to say that your proposed land treatment system—either irrigation, rapid infil-
tration, whatever your technique—will contaminate groundwater. It's easy to get on that band-
wagon, because nobody likes to contaminate groundwater. Once it's contaminated, we all know
that the flushing times are so slow that it is, in effect, contaminated for all time. We have
to make sure that that criticism, that objection, when made, is addressed properly and effec-
tively, so that we do have a series of requirements coming out which will address groundwater.
I'm sure that everyone agrees that the planning process hasn't been carried out the way the
1972 Act envisioned. Implementation of the 208 planning program was delayed for two years.
The 208 program was to be the catalyst, the process through which all these activities were
initiated. Well, since it started two years late and everything else continued on, planning has
never caught up. And it may be that we're going to be unsuccessful in catching up. But we do
hope that we can, and we will be issuing a whole new series of guidance and regulations on 208.
We also know that the 201-208 linkage has been inadequate. We're trying to address that problem,
and we'll be issuing another set of requirements that all 201 plans be integrated with the 208
plans beginning at the end of fiscal year 1979, and in many instances in advance of the end of
fiscal year 1979.
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QUESTION: I'm Lewis Emmerich, Envirotech Corporation. I wonder, in the planning process, do
we call upon the consulting engineer to do too much? Basically, he's trained to do the plans
and the specifications. Hopefully, that's what he's trained for, as a technical expert. But
do we ask him to do too much in the demographics area? Do we ask him to do too much in the
economic analysis area? In that planning process, would you not consider that perhaps in the
future we should bring in experts on a broader spectrum to work in that planning process as well
as the architects and engineers?
JORLING: I think that your statement has a good deal of merit. The fact is that the program
called and continues to call for, an obligation outlay rate that's very high. Last year we
obligated 6.4 billion dollars in this program, and that kind of performance taxes everyone.
The standard engineering practice was overburdened. Much more was demanded of it than it could
perform. But it is true that if we're going to have a facilities planning process that calls
for all of this analysis, we're going to have to have the types of methodologies and skills out
there to do that, and we don't have that yet.
QUESTION: I'm Dave Del Porto, from Boston. I'm wondering what role will flow reduction
and water conservation play in the sewage treatment facilities planning process?
JORLING: I could give a long answer and explain that the Administration had recommended a pro-
vision [to Congress] that would have reduced the amount of reserve capacity in a treatment
plant, that could be funded, but we lost that. What are we doing with respect to flow? There
are two things in the cost-effectiveness analysis. One [The Clean Water Act says that the
federal government can only fund the most cost-effective systems.] is that the guidance now
speaks to a specific gallon per capita number that is used. We had seen a wide range in the
past, all the way up to 200 gallons per day being used to support these kinds of projects. And
yet we know that the average per capita flow is around 70; in some areas it's a little more, in
some areas a little less. So that's one provision. The other is the flow reduction. Techni-
ques must be included in the cost-effectiveness analysis for the project to determine whether
it's more cost effective to reduce flow than to build a plant, or a portion of the plant. So
that's included in the cost-effectiveness analysis. Those are the two most important.
QUESTION: I'm Suzanne Pogell, a citizen from St. Louis. I'm concerned about the Step 3 con-
struction facilities under the Corps of Engineers, and I wonder if you would expand upon what
their responsibility would be management-wise and building-wise. Would they only build or would
they have responsibility for other decisions?
JORLING: The first role in Step 3 is going to be equivalent to what EPA's role is, or has been,
in Step 3~supervision of construction. We're not specialists at it; the Corps generally is.
What they will do, for every project over $40 million, is have an on-site inspector. We do not
have any on-site inspectors, even in Chicago, New York, San Francisco or St. Louis, where we are
putting upwards of $500 million 1n a single project. We don't even have a federal presence
there; the Corps will have federal presence. So they're going to be doing some things we're
supposed to be doing but, because of our resource shortage, have not been doing.
POGELL: Strictly according to the plans that have been designed in Steps 1 and 2?
JORLING: Once you're in Step 3, nothing changes.
POGELL: If there is a full-fledged citizen program in the Step 1 and perhaps Step 2 process,
will that then continue in Step 3 with the Corps?
JORLING: Yes, but I think that the citizens' involvement in the construction process is best
served by professionals, and hopefully, that's what the Corps is going to bring. The flow of
money, the determination of whether the quality of the concrete that's being used is meeting the
specifications—all those are very technical factors. The citizens' involvement there should be
protected by the government. That's not the case in Step 1, where the quality of the planning
process is amenable to a larger number of factors than just whether or not the project is being
built according to specification.
QUESTION: I'm John Marsh, Engineering Enterprises, Inc. I'm a consulting engineer. I hope to say
however, that I am an enthusiastic person about what resource recycling can do in this country.
My concern is that under Public Law 92-500, several billion have been spent already. Certainly,
there are many projects in Step 2 that this group would probably say, "Hey, there's a natural,
that should be going toward resource recycling," when in fact it's going towards conventional
treatment. My question is, what provisions will be made, if any, to alter the planning projects
that are in Step 2, where it would be logical for them to turn around and go back to resource
reuse, considering the new guidelines?
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JORLING: Anytime an amendment causes change in the groundrules, phasing in the new requirements
is one of the more difficult management problems. What we're saying to the regional administra-
tors is: use some discretion; try to figure out a common sense way of achieving a best result
when you're intersecting this in either Step 1, Step 2, or even in some cases, Step 3, before a
major construction. But it's basically an effort to give some discretion to make adjustments in
on-going projects, to reflect the new policies and guidelines.
QUESTION: I'm Audrey Moore, Board of Supervisors, Fairfax County, Va. I was very apprehensive
about the changes to the clean water law in that I was afraid the changes might have given the
states the right to spend federal clean water money without strings. I wonder what protections,
for instance, are written into your regulations that specifically might keep my state from
shoving funds meant for projects to clean up our rivers and instead putting the money into trunk
sewers or other development schemes?
JORLING: In the determinations to make the transfer of management of authority from EPA to the
states, we have to go through a process of the review of the quality of that state program.
The quality includes application of resources, the whole range of—there are about 23 points
that they have to satisfy. Included in those is an assurance that they will carry out the
policies of the federal statute; the policies and the requirements of the federal statute.
That's an easy thing to say, and a state official can come in and say, "Yes, we're really going
to push land treatment," and then get the program and never do that.
MOORE: Well, who"makes the decision on what the priority system is in Virginia? I guess that's
the bottom line.
JORLING: By and large, it's primarily the responsibility of the state.
MOORE: We've had it. It's not your fault—it's Congress—but we've had it.
JORLING: Well, I think it might go better than that, but it's going to take some pressure.
MOORE: Thank you, and my deep sympathy and appreciation for you in being willing to stay No. 1
in this very difficult world—I know just a little bit about it.
QUESTION: I'm Ron Frank, Merrimack, New Hampshire. I represent a citizen's effort, a frustrat-
ing effort in Merrimack, N.H. I don't want to get into the specifics of that, but I have two
questions which will allude to the situation. One, what specific steps does EPA plan to take to
enforce its regulations with regard to industries when they are clearly breaking regulations?
JORLING: The pre-treatment regulations?
FRANK- Any kind, sir—it's pre-treatment, it's overloading of treatment plants, it's violation
of NPDES permits, it's the inability of the sewage and sludge incinerator to comply with air
emission standards—it's a whole long laundry list which can all be traced back to one industry
which uses over 97% of the capacity of a municipal wastewater treatment plant. The industry has
never been cited in this since 1970 in any way by EPA. In fact, I can even state that your Bos-
ton office has taken steps that have been totally in sympathy with the industry and totally out
of keeping with the public interest.
JORLING- You're asking questions about enforcement factors and those are very difficult to
answer. If your last comment is that you've already been to the regional office and not reached
satisfaction there, draw it to the attention of the headquarters enforcement office. But hope-
fully, our enforcement program is better than that which you've described, and if you raise this
with Lesley Cretters in Region One and she doesn't give you a response, would you ask her to
tell me why' It's very hard for me to be as specific with this specific enforcement kind of
question I hope it's our intention of enforcement to enforce the laws as thoroughly as we can.
If we're not, I'd like people that are supposedly making that decision to explain why they have
not.
FRANK: If I might ask another question, what steps does EPA plan to take to enforce the citi-
zens' efforts in the type of situation I'm describing?
JORLING- Public participation efforts are different in each of our programs. In the Step 1
area for instance the new regulations will make it a condition of funding, at making payment.
Iftte reglSSSS'on JartlcljJtlon have not been complied with by the applicant, then payments
are not Se It is a condition of the grant. That, for instance, is one techmque that will
be used In'the 208, the same thing is true: part of the 208 monies go to pubHc partinpation
efforts. If they are not appropriate, then that becomes a consideration in the approval process.
It's different in each of our programs.
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A CHANGE OF COURSE FOR CONSTRUCTION GRANTS: WHAT THIS MEANS AT THE REGIONAL LEVEL
ALAN MERSON: Administrator, Region VIII of the U.S. Environmental Protection Ageney.
Former Chair of the Colorado Land Use Commission; was Deputy Director of
the Alaska Community Aation Program; Director of Urban Legal Studies,
Denver University.
I see the aim of this conference concurring really with a much larger need in our society,
and that is, essentially to look for the soft path. Most of us here recognize that this
society is heading down the road to disaster. A disaster that, to some extent, has been
created by our own technological ingenuity. I guess there's a feeling, or there has been a
feeling in our society, and maybe it characterizes the West more than any other part of our
country, that "By golly, if we can do it, let's do it!" "If it's possible, if it's humanly
possible to devise something, let's do it anyway, regardless of the cost, regardless of the
risks to society." And in the final analysis, I think regardless of the many human costs
that may well be involved, as well as the economic costs attached to it.
In a very real sense, it's the fault of all of us. We've turned over the dam building, the
water plant building, the sewage treatment plant building, the highway building, the building
building—we've turned this over essentially to people who say "We know how to build." The
fact is that now many of us are trying to reclaim some of this decision-making from those who
said nothing more than "We know how to build," and to start asking questions about "Why build?
What do we build? For what purpose? And what will be the long range consequences of what we
are building?"
What we're doing here today is what I think is happening within my own agency. I must say
I'm very proud to be a member of the management team of the EPA these days. You've heard
from Tom Jorling, some of you, in the past. I think you're all familiar with Tom's philosophy
with respect to sewage treatment and how this program ought to be used, not how it's been used.
I sat in Tom's office last year, discussing with him and some members of my staff, some issues
relating to Colorado. At one point, we were going through some traditional arguments for
either going ahead or not going ahead with a given project and Tom just sat up in his chair,
slammed down his fist, and he said, "Don't you realize we've been doing it all wrong? Our
people never read the Act. They never really understood what was written in 1972." And he
said, "I hope that this is the year most people get the message." Because Congress, in
revising the Clean Water Act last year, gave some special attention to the basic objectives
of the original 1972 Federal Water Pollution Control Act.
It's a very, very difficult task. I can tell you, as one on the firing line, that once people
are going down the road, trying to get them to divert, trying to get them to change that
course, can be an agonizing experience. I find myself, not daily, but certainly very frequ-
ently, having to sit down with local government officials who say, "Why aren't you funding
this?" That's the bottom line. That's the bottom line for those of us here on the regional
level. Why aren't you funding this? And I really have to give a much more extensive speech
than I'm going to give you right now, to tell them why we're not funding it and why in fact
this is not a public works program. We have a public works component at the very end, but it's
not a public works program. It's an environmental program. It's a human survival program.
In the final analysis, what we do in the waste treatment area, as well as what we do in the
energy area, is going to determine how this society survives.
Now, I don't like to be dramatic or to make big deals out of little things, but it is a big
deal—I think survival's a big deal—and the fact is that we can't continue to go down the road
we've pursued for most of this century. There is no technological fix in this area. Techno-
logical fixes lead to further technological problems.
Wy point today is simply that there are some of us in this agency, I'd like to think many of
us, who are in positions of responsibility who are determined to change the course of the
Section 201 construction grant program, who are determined to askthehard questions and hope-
fully take some risks as we do it.
I'd like to ask you now to ask me some questions, if you have some. Yes sir?
QUESTION: I'm Larry Silverman of the Clean Water Action Project. In the Clean Water Act of
1977, there's a provision called Section 214, called Public Education. It says that- by the
end of this year EPA must have a "continuing program of public education" on the subject of land
treatment, water conservation, and wastewater recycling programs generally. Now, what I'd like
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to know—I frequently ask the people in EPA's Washington office, particularly in the Municipal
Grants Section, the ones who deal with sewage treatment plants, what they intend to do about
that. I ask how they intend to fulfill that responsibility, and I never get a clear answer on
what they're going to do. I want to ask you, since you're down here on the regional level closer
to the public, what do you intend to do in terms of public education of these subjects, how
much money you intend to spend, how many people you can put on it, and what sort of programs you
have in mind.
MERSON: I can't give you a clear answer to all those questions, but let me at least suggest an
answer. One is, when I came into this job last September, the first thing I did was to re-
organize the office, the Regional Administrator's office. One of those things was to combine
the public affairs/inter-governmental relations offices into an office of public awareness. We
have doubled the size of that office of public awareness in the last few months. We not only
doubled the size, but we made a commitment to that office, in terms of the role they're going to
play in energizing the 300 or so people who work for this regional office as catalysts in the
public participation process.
Now we've had, in the past, some public participation, as a required component, of the 208 pro-
gram. I think you're familiar with that. If there's been public participation in EPA it's
mostly been as an adjunct of 208. What I propose to do—and all it can be now is a promise,
because we have a long way to go—is to put together an aggressive constituency building program
for the agency.
A major component of that has to be related to the construction grants program. For a couple
of reasons. First, you can't get people interested unless there's money. In the final analysis,
I think we have to accept certain facts of human nature. You and I may be interested even
though there's not a lot of money involved, but if you look at Water for Colorado, the developer's
lobby, for example, I think you'll understand why they're very interested. When you're talking
about a couple of billion dollars in construction contracts, people get very interested. When
you talk about a $4-1/2 billion annual program, you're talking about a lot of money.
It seems to me that if some effort on the part of the agency to train the people who work for EPA
results in each one teach one," we shall have found the only way to get leverage within this
agency, which is still a relatively small agency. I believe we have talented people within the
agency. In some cases, its been talented people who've been kept back, who've been stifled,
who ve been muzzled, and who haven't been able to function to the best of their capabilities
There are people in many of our programs, including Air, Solid Waste, Pesticides, Radiation,"who
have had nothing to do with construction grnats. What I'm trying to do right now is to conduct
a talent search within our agency and find those people who are the most effective communicators,
people who can go out and do a job of community organization. The important thing is the commit-
ment on the part of the agency to getting people involved in the decision-makinq process.
What you're doing here today is saying, "If people are going to be involved, they'd better be
educated; they'd better understand the process. Once they understand the program, they can begin
to drive that process." If people are ignorant, only the experts prevail. When people are edu-
cated, they understand that the expert has some competence though it may be a narrow competence,
but it's not a competence to determine the future of the world. In essence, I'm telling you
that there is a commitment in this regional office, as well as in EPA generally, to involve the
public in the decision-making process.
QUESTION: Do EPA officials attach a greater importance to public input than they have in the past?
MERSON: I think that our agency, as the case with many other federal agencies, has exhibited an
arrogance in dealing with people. The typical arrogance of people who have a certain background
and training and tend to feel that they're dealing with people out there, who are not competent
to participate in the processes.
I happen to have a high regard for many of the people whom we've labeled as bureaucrats within
EPA because I believe that they are talented people. But a typical bureaucratic reaction, very
often, is not to be bothered with the public because it slows down the process. It messes it up.
Thus the only time you invite the public in is at the public hearing at the end of the line
where they can't do anything about it anyway.
We have now, in the agency, people like Joan Martin Nicholson in Washington, who have a genuine
commitment to bringing people in at an earlier stage. We have people like Tom Jorling who have
a very clear commitment to bringing people in, on the takeoff as well as at the crash landing.
And so I think the agency is in a position to do better. You'll just have to wait, to some
extent, and measure our performance.
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QUESTION: What can be done to assure that publically elected officials really represent the
public?
MERSON: Who does represent the people? When we held a public hearing on Foothills, for
example, we got a very strong indication of how most of the people in Denver felt. On the
other hand, if you look at the lineup of elected officials, with respect to this subject, you
get a very different picture. Well, who represents the people? My feeling is that in the final
analysis, the best contribution the federal government can make to solving problems, is to try
and help improve the process at the local level, so that ultimately, local officials do represent,
in a far better fashion than they do now, the will of the people. I believe in local government.
I've spent a professional career dealing with it, but it can also be the most oppressive, arbi-
trary and totalitarian government we have in this country. Thus it's really a question of how
well the process is working at the local level. I think we have an obligation to work with
local governments. We can't do otherwise. We also have an obligation in our citizen participa-
tion effort, to arm citizens to participate in that process, and hopefully, when you arm people,
after a period of time, they begin to acquire the accouterments of power themselves. They begin,
in essence, to determine that process, and they themselves then become local government repre-
sentatives. I think President Carter's urban policy is a good indication of how the White
House views this. It's going to work with local governments but it's also going to work with
neighborhoods. Both are necessary.
QUESTION: Since EPA certifies many of the states to actually administer, or to be the primary
administrator of the program, what kinds of review provisions or what kind of program do you
have for reviewing state public participation programs of the certified state agency that s in
many cases doing the primary work on such construction works?
MERSON- I don't know the answer to that question in terms of what our authority is to ensure
that the participatory process is working properly at the state level. My reaction is that if
there is any way for us to possess the power to somehow ensure that the process is working well
by involving a broad cross-section of the community, then we do have an obligation to inquire
into the effectiveness of that participation. I haven't specifically looked at that issue.
It's one that I shall look at because I think you've raised a legitimate concern. Not only
local governments, but states, are prone to develop an exclusionary process. Now, hopefully,
EPA does have the authority to demand of the states that they do in fact have that kind of
open process.
QUESTION: Isn't EPA a political technology that tells people what they ought to be doing?
MERSON: I don't know what a political technology is.
QUESTION: Well, like engineering, it's a political group, similar to engineering. You have
pointed the finger at engineers as technologists who are seemingly guiding the people under these
areas. And that is not right—it's a whole group of people, the people themselves.
MERSON: You're right to scold me. There are engineers and engineers. There are lawyers and
lawyers I'm a lawyer and as some of you know, I'm extremely critical of the legal profession--
more so than any other group of people I know. What I'm saying is that sometimes one s pro-
fessional training creates a mindset, and I think this is true with engineering. I think it is
also true with lawyers, doctors, architects, school teachers, or any other profession you might
choose There comes to be a conventional wisdom that's associated with a profession. Sanitary
engineers tend to come from a similar educational background. They tend to approach problems
in a similar way. That doesn't apply to all sanitary engineers-since we've seen some very
creative sanitary engineers suggesting alternative approaches. Just as lawyers forget their
common sense as a result of law school training, having taught law school for 10 years, I ye
found lawyers saying dumb things that they would never have said before going to law school.
They've let their professional training overcome their common sense. They check their intelli-
gence at the door and blindly adopt the rules they've been taught. It can happen to any pro-
fession. It has certainly happened to the design of wastewater treatment facilities, where we
haven't applied the more creative intelligence of sanitary engineers, but have often settled for
the lowest common denominator.
I am asking for a partnership between people who have no technical expertise—but do have concerns
and legitimate interests with respect to how wastewater treatment facilities are designed and
operated—and the professional engineers. I don't think it's an either/or proposition. I do
think though, that in this field, as in others, there has been an unfortunate tendency to abdicate
decision-making "professionals" who haven't applied their best intelligence. Thank you very
much. I'm going to stick around and listen for awhile.
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A SHORT TALK ON THE FEDERAL LAW OF SEWAGE TREATMENT
LASRJ SILVERMAN: Clean Water Fund, Washington, D.C. As an attorney and Washington Representa-
tive of Clean Water Action Project, Silverman participated in the drafting of
the Clausen Amendment to the Clean Water Act, boosting recycling technologies,
and coordinated the citizens campaign for its enactment. Specializes in water
conservation, water pricing, and municipal waste treatment policies.
This is going to be a very short talk on the law of sewage treatment. Forgive me if I gloss
over some very important things.
What is the federal law of sewage treatment? Here is a copy of part of the Federal Law of
Sewage Treatment: The Clean Water Act of 1977. Copies of this are obtainable from various
trade associations, and also from the Environmental Protection Agency, from your local library,
your Congressman. It's worth having. The Clean Water Act deals with all the things that cause
and all the ways to cure water pollution. Sewage treatment is only one aspect of it. But it is
a very important aspect of the law, one which will have a significant impact on the quality of
our waterways and the character of our communities.
So this, the Clean Water A:., of 1977, is the basic document.
But the law itself is only the beginning of the process. Other elements of the law are regula-
tions. Congress passes the laws and then bureaucracies try to implement them through regulation.
So, for example, in the Federal Register of April 25, 1978, copies of which are available, con-
tains some of EPA's new proposed regulations interpreting this law. Now, regulations are not
always consistent with the laws passed by Congress and signed by the President—they tend to be
the law in effect—until someone challenges them or questions them. This is what people live by.
This April 25th document contains only proposed regulations. Theyare not final yet. The U.S.
EPA wishes us to comment on these regulations and they want our comments by June 30, not very
much time. All of you can participate in making the law by commenting on these regulations.
These are not the only regulations. This is a December 17, 1975 set [holding up a reprint from
the Federal Register] which these 1978 regulations modify. If I had to hold up all the other
bureaucratic documents that comprise the law, or the rules of the game, I would not have room on
this podium. There are guidelines for interpreting regulations, and studies to illuminate the
guidelines, and so forth. So, we're dealing here not just with a statute, but with a bureaucracy.
I'll touch on this subject again. [Note: The final construction grant regulations were pub-
lished in the September 27, 1978 Federal Register, beginning on page 44022.]
Let me make some general remarks about the Clean Water Act and what it's about. The purpose of
the Clean Water Act is to restore and maintain the physical, biological and chemical integrity of
the nation's waterways—this is a very ambitious purpose. The law is aimed at making all the
waterways in the country fishable and swimmable by 1983; it's aimed at eliminating the discharge
of pullutants. Let's say that again. One of its objectives and goals—it's right here in black
and white—is to eliminate the discharge of pollutants. That is not always the popular goal, it
is not always, in fact, the goal of the bureaucracy. It is rarely reflected in the regulations;
but that is in the law, that is the goal.
Other goals are that the federal government should subsidize construction of sewage treatment
facilities, and general sewage treatment facilities, and that in fact water pollution control
programs should, through a complex process, be regulated by state and local governments. This is
a federal law with a great deal of federal control; but there is a constant concern to get the
responsibility back to the local governments and state governments.
Another goal of the law we should keep in mind is the goal of regional planning and "areawide
wastewater treatment management planning"—that's the phrase. Regional planning for managing
wastewater. "Planning" and "managing" are very important words that recur over and over again
in the law. The mechanisms for good planning and management are described in Section 208 of the
law. Section 208 has given its name to many regional and statewide water planning organizations.
I know some of you belong to 208 agencies. In any case, regional planning and management is also
a goal of the law.
The 1977 Clean Water Act is an amendment to a 1972 law called the Federal Water Pollution Control
Act, sometimes referred to as PL 92-500. Feel free, for the next six months or so, to use that
phrase. PL 92-500 has now been amended; this PL 95-217 is the new law. But PL 92-500 lives on,
as many of the things in PL 95-217 are the same. The amendments have been characterized by the
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Congress and everyone else as "mid-course corrections." In 1972, we set out on a voyage to
clean water which was to reach its destination by 1985 or thereabouts; by that time we were to
have clean water, and eliminate the discharge of pollutants. Midway in our journey to clean
water, we decided to have a mid-course correction. We're going to see what mistakes we'd made,
and correct them. Now, in the area of sewage treatment there were many corrections, because
we made many mistakes. We ran off course quite a bit. So, there are a lot of corrections. This
is what lawyers call a remedial law; a law that remedies a prior situation. Sometimes to under-
stand such a law, you have to understand a little bit about its history, to know what evil it
was intended to remedy. So when you read the new law and you hear people discussing it, that's
a question you should ask yourself: what evil was it intended to remedy?
One other general observation, the law of sewage treatment is an attempt to regulate the conduct
of municipal governments. Those of you who are in municipal government are in a way the subject
of the law because sewage in this country—rightly or wrongly—is handled by municipal govern-
ments. And there are two ways, two general techniques, ancient techniques used in this law for
regulating municipal governments. One is the carrot: some gift, some inducement, some incen-
tives to local government to do something. And the other is the stick, which is to say stricter
enforcement: "We'll take you to court if you don't do what the law says, and we'll pound you
into submission in other ways."
Let me talk to you first about the sticks in the law. There are many. In the first place,
stick number one, are standards. There are two kinds of standards in the law. One is effluent
standards, that is to say, how much pollution can you discharge from a given facility. A typi-
cal effluent standard in the law is secondary treatment by 1977. Every community sewage treat-
ment plant must meet a standard of secondary treatment or the equivalent. What does that mean?
It's a technical term and it's interpreted in these regulations. So you see how much power EPA
has The law says secondary treatment, but what that means in terms of what you can do and
what you can discharge is in the regulations. By 1983 you're going to have "best practicable
waste treatment technology." The best you can do practically and, again, that is an effluent
standard of a sort, subject to EPA interpretation. Debates about the interpretation of that
phrase could fill many volumes. It is an important battleground. Controversies about the
meaning of best practicable technology will go on as long as we're dealing with the problem ot
waste treatment. What is the best technology? Or rather, how much can we reduce the discharge
of pollutants by using the best technology? Other kinds of standards are water quality stan-
dards When we look at the stream we say we want this stream to be fishable and swimmable. We
say in order to achieve that we have to reduce the level of pollutants in the stream to a certain
level, eliminate or reduce them to a certain point and that is a water quality standard. That
is hard to enforce against anybody because you're not saying "you do this or you do that —
you're saying "stream be clean!" And that means you have to figure out who is polluting it.
You look at everybody who is polluting it and try to figure out an implementation plan for
obtaining the water quality standards. These standards are enforceable through court action by
EPA, through criminal and civil penalties, and also through citizen suits. So, all you citizens,
if you're dissatisfied with what your municipality is doing, you have a right to take them to
court, a very important right. If you win, you may get attorney's fees and expert fees. So much
for the sticks. On to the carrots.
The carrot is very big, about $5,000,000,000 per year. For the next five years, the federal
government will spend almost $25,000,000,000 on subsidies for sewage treatment. This « still
a lot of money. The sewage treatment construction grants program could become one of history s
great domestic capital spending programs. It could end up costing more than the Interstate mgn-
way System. Those are the dimensions of it. This is a huge program.
How is the money distributed? Well, in general it's intended to help communities cover the
capital costs of sewage treatment facilities. In general, the federal government pays 75% of
the capital cost for sewage treatment facilities. Capital costs: the costs of Planning the
costs of design, the costs of building, construction, and start-up. Not all capital costs are
covered; some are not grant-eligible. In the past, land for lagoons for storage of water for
land treatment systems was not grant-eligible. That greatly discouraged the building of land
treatment systems. John Marsh, who you've heard from, was one of the people who informed Con-
gress of this mistake and Congress corrected it in the 1977 law. The Marsh Amendment,
allowed people to get federal funding for lagoons. That's one small example of a grant-eligible
capital expense. Coming to a conference like this or holding your own conference is.grant-
eligible; it is part of the planning process. Learning a^f-^1 this.;?J> grant 9
expense. The federal government will, or should, pay 75% of it at a minimum.
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Operation and maintenance expenses are not covered by the federal government. You pay for them.
A lot of communities come in and say, "Oh, we're going to get all that federal money and we're
going to do real well." They build a plant with federal money, and then they get the operation
and maintenance expenses and they find themselves on the edge of ruin, as a result of a federal
gift. So that's a big expense—operation and maintenance—and it's yours.
Now, how do you get this money? First, you've got to get on a priority list. The state
develops a list, a pecking order, of who gets what, when. In the past, big cities got that
money because priorities tended to be based on population and severity of population. The cities
had the biggest problems and the biggest population; they got most of the money. That's been
modified. Now, rural areas, communities or municipalities with 3,500 people or less, are
guaranteed a certain portion of the money, if they use it for systems and technologies suitable
to their needs. A certain amount of money has been set aside for them. 4% of every rural state's
allotment is set aside for alternative technologies in small communities. A rural state is
most of the states in the country, any state with a rural population of 25% or more. That's a
very big change in priorities. Sewers are given—the actual pipes and ditches—a special place on
the priority list. This reflects, as much as anything else, the political influence of the sewer
contracting industry.
Now, what are you supposed to do with the money that you get? Well, you're supposed to build
sewage treatment systems that meet certain standards. That's the first thing. You've got to meet
the secondary treatment standards. You've got to get the best practicable treatment technology.
You eventually have to eliminate pollution. But the law goes a bit further. In 1972, as a result
of the work of Jack Sheaffer and Congressman Guy Vander Jagt of Michigan, a description of the
types of facilities we want was put into the law. These are types of facilities that need to be
encouraged: would produce revenues, confine and contain the pollutants that they could not recycle,
and would be integrated with other facilities. Maybe different kinds of waste treatment facilities
would work together in such a way as to produce revenues from all of them. As a result of that
being put into the law, nothing happened. In fact, EPA's level of funding for those kinds of
systems—the systems that met that description—actually was lower after the 1972 law than before.
That's again an indication of what sometimes happens when a law travels from Congress through the
bureaucracy to the public. It got lost. As a result, a remedy was needed.
Don Clausen (R-Cal.) introduced a bill to remedy the problem. A number of provisions, including
the Clausen amendment, are described in some detail in the 1978 Clean Water Yearbook, put out by
Clean Water Action Project. Here are some of the changes. In planning wastewater treatment
systems, you now have to study possible innovative and alternative systems. These are the kinds
of systems we've been talking about at this conference. They reclaim and reuse water, eliminate
discharges, and specifically, include land treatment. They involve new and improved management
techniques, and more efficient use of energy and resources.
Further changes include the following:
•Open space opportunities. Open space and sewage treatment have a very close relationship,
and that's something to be looked at.
•Financial incentive. If you have an innovative or alternative system as defined by the laws,
by the regulations, you don't get a 75% grant, you get an 85% grant. That is a 40% cut in
your local expense. I think that's right. A very substantial incentive. That s part of the
carrot, you know, to get the municipalities going. And a certain amount of money is set
aside—2% and then 3%-to pay for the 10% increase.
•Insurance policy. If an innovative system fails, it's nobody's fault; the federal govern-
ment will build you a new one—100%. . , ™. • ., 4.
•National clearinghouse for technical information. The law said that EPA is supposed to set
up a clearinghouse so that municipal officials, engineers, other people who would like to
learn more about the subject can always get that information from the government. It s not
available now. They're supposed to set it up, but they haven't done it yet.
•Changes in the cost effectiveness analysis. It's an extremely important subject. I can t
qet into it now, there's not enough time, but there are some changes.
•Planning and management. As I said before, the building of sewage treatment systems is
really part of building a community. Just as a highway will dramatically affect a community,
a sewage treatment system will do the same. Who plans them? The law says, when you get
right down to it, that 208 agencies, areawide wastewater management and planning agencies,
are supposed to plan waste treatment facilities. They do not do that for the most part.
But they have the power to do it, and the responsibility to do it.
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•Public education—which is what we're involved in here. We're supposed to educate people
about water conservation, land treatment, and recycling of resources.
I will take questions now.
QUESTION: If you have a conference, basically, on innovative and alternatives, can you get
85% funding?
SILVERMAN: That's a good question. There are three steps to the grants process—Steps 1, 2, and
3. Step 1 is the most important as far as the citizen is concerned because that's when you're
supposed to evaluate all the alternatives. There's only 75% funding available for Step 1. On the
other hand, it's the most important and least expensive step. Step 2 is design, actual formal
specifications, blueprints, charts, and so forth. If the system is innovative or alternative,
you get 85%. Step 3, construction, allows 85% for innovative and alternative technology. So, for
the first step, you do not get the 85%.
QUESTION: I think the gentleman asked whether it would be possible to get money from EPA to hold
conferences or meetings like this on a state-wide or local basis.
SILVERMAN: I think that's a legitimate part of the Step 1 process. The law says there should be
public participation. The municipal grants section of EPA is terrible in the public participation
and education areas. They're beginning to change, but it's hard, hard sledding. Myron Tiemens
is here; he's one of the fellows in EPA who is going to try to push that ahead, I think. I think.
that's one area of the Step 1 grants process where you can get money for a conference like this
and educate yourself and your citizens. I think EPA has a positive obligation to set up a public
education program and to fund that kind of effort, maybe at 90% to 100%. I think that's something
we ought to be pressing too.
COMMENT FROM EPA STAFF: On the subject of training, I think you might get some money for
training under Section 105. Secondly, if innovative and alternative technology fails, EPA would
just fund what has failed and is classified as innovative. EPA wouldn't replace the whole thing.
SILVERMAN: This is a great help to the engineering profession, because you only get that insur-
ance policy if nobody's at fault. In the past, if the system was built and failed, the community
would come in and say, "It's the engineer's fault, let's sue him." Now, with this federal insur-
ance policy, the community's going to come in and say it's nobody's fault. It just happened and
so EPA should pay it.
QUESTION: Who is entitled to get 75% funding or to get 10% more? Do you have to be a government
of some kind?
SILVERMAN: The law says that municipalities are eligible. The word municipality covers a wide
range of different types of local government.
QUESTION: Local government, though?
SILVERMAN: Yes, we're dealing with local government. The 208 agencies are supposed to designate
the types of local government and the specific local governments which actually can get this
money. So that's a great power of the 208 agencies that has not been exercised to my knowledge.
Yes, local government, that's what this is all about.
QUESTION: ON the local government issue, for example, in Arizona, there is a volunteer organiza-
tion of regional councils. Theoretically, that's supposed to be illegal for a local organization,
but there's no binding power involved and yet they're saying "no" to local governments.
SILVERMAN: A municipality is defined as an agency established by state law having some authority
over waste disposal. That's it. It could be a special sanitary district. All you need is a
state law to authorize authority over waste disposal. It could be a city, county, regional
council, or some other entity. The shape of your local institutions is one of the most difficult
tasks that people who want clean water are going to have to deal with.
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POLITICAL AND INSTITUTIONAL OBSTACLES TO CITIZEN PARTICIPATION
DAVE ZWICK: Director, Clean Voter Action Project, Washington, D.C. An attorney who
so-authored Water Wasteland, a landmark 1971 critique of federal cleanup
programs, he has played a leading part in several national citizen cam-
paigns for environmental Icao reform.
What are the obstacles to clean water? One thing we've learned so far at this conference is that
there are few serious technological obstacles. There are a number of affordable technologies.
Yet those who propose them—those who propose alternative solutions to old conventional methods--
run into obstacles at every turn. Those are the real obstacles to clean water—those institu-
tional and political barriers that stand in the way of using the best technologies, the latest
knowledge.
We all can easily predict that it will take more than decrees in the federal law to overcome
these obstacles. An $8 billion a year industry has grown up around largely a single set of
solutions. When that kind of big money gets rolling, its momentum is difficult to overcome.
It's force is felt in every sector of society. Government agencies are staffed with people who
are used to conventional solutions. The schools teach only conventional solutions to prepare
students for jobs in the consulting and construction firms, that recommend and build only conven-
tional solutions. And it's no wonder. It's not just a matter of their having had the wrong
training and experience. It costs them money to change. Just as General Motors resists
scrapping the internal combustion engine, it is difficult for a firm that used to do simple stan-
dard conventional technologies everywhere to get the new staff in to do the specific environmen-
tal design work tailored to each local area that it takes to put in, say, a land treatment system.
That internal shift means higher overhead and lower profits for the firm. So we're combating
conventional experience, ignorance, cozy relationships between the old firms and the old offi-
cials, and an industry that is dominated by those who favor the conventional technologies.
How do we overcome that? Well, it could sound pretty gloomy, but there are encouraging messages
coming up. The purpose of the case studies is to explore the lessons that citizens in communities
around the country have learned in the process of attempting to overcome those obstacles. These
are stories of citizens and local officials who have actually tried to shop for sewage treatment-
tried to get the best bargain. They are the real experts, the people who know what makes the
difference between success or failure. In each case, they ran into obstacles. They all had to
deal with complicated technical questions. They had to deal with attempts to confuse them and
the public. They had to overcome opposition and cut through red tape. They all learned valuable
lessons.
There is one lesson that is most important. It is, to remember that the obstacles are political.
Because that is the key to what the solution is. The solution is a political solution. You
really have to remember that. Turning to the old technical experts in and out of government,
and trying to convince them, to persuade them, is certainly worth attempting. But they have to
be listening When the technicians and bureaucrats seem to have their minds made up, you 11 have
to find a way to make them listen. You'll find, by and large, that the solution will come when
the push comes from the outside. In the sewage treatment area, it's fresh faces and new ideas
that are needed. It's the push from the public that is needed. That point is a central theme
you'll see emerging from all these examples, both the successes and the failures.
SPOKANE, WASHINGTON: CASE STUDY
The first case study is a failure. That's the experience of Spokane, Washington. Spokane is dry.
Irrigation water is in great demand, so great that the Bureau of Reclamation has a number of
active federally subsidized irrigation projects. Back in the early 970's, Spokane was ordered
to clean up its pollution. Original cleanup orders had beenissued in the 960 s.but there was
foot dragging on the city's part. The state finally got serious in the early 1970;s. Well, this
set in motion a search for solutions. A very tenacious local engineer, more tenacious than most
we've seen designed a very attractive land treatment spray irrigation system. He went out and
found farmers who wanted the nutrient-rich water. He found an ideal spot, a natural depression
in the land-they wouldn't even have to dig a lagoon, there was one right there. And he worked
oSt the other arrangements. The cost was very favorable. It was $10 million less than the
cSnven?iSnaf alSat1ve-wh1ch would cost $30 million. It would have avoided the sludge problem
of the conventional plant. It would also have led to a solution of the storm runoff problem.
It would have completely eliminated pollution discharges into the Spokane River.
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Yet when the decision was made, the conventional alternative was adopted, an alternative which
had none of these advantages. Since the new conventional plant in Spokane has gone into opera-
tion, it has demonstrated a number of other disadvantages. Like cost overruns, for example.
The city's solution to the sludge problem is especially interesting. A study has been done
there about what should be done with the sludge the plant is producing. The landfill into which
the sludge has been dumped is on top of an aquifer which is the sole source of drinking water
for the area. The same firm is studying the sludge problem that designed the plant. They are
coming up, a little belatedly, with the answer that the farmers would like the nutrients in the
sludge. And so a proposal that they've made is that the solution at this point would be to
truck the sludge out to surrounding farm areas. However, the farmers apparently, don't want the
sludge without water, so the proposal envisions piping water out there too, and putting the
water back together with the sludge and nutrients that they separated out in the first place,
obviously at an astronomical cost. Of course, another problem is that the sludge contains alum, a
chemical which they use in the phosphorus removal process in the sewage treatment plant. The alum
will ruin the farmland after a certain period of time. So suffice it to say that Spokane bought
itself a very expensive lemon.
Why did this happen? Well, the first answer is obvious. It turns out that the engineer who
designed the land treatment system, Jim Latenser, was unfortunate enough to jump into the case
after another engineer had been hired by the town—an engineer who had apparently already been
directed by state and local officials to do a conventional system. The momentum was impossible
to stop. It illustrates one simple point. The selection of the engineer is usually the single
most critical stage in the evolution of exactly what your treatment plant is going to be. It
certainly was here.
Secondly, it's very easy to prove that it's impossible to do what you don't want to do. An
expert can always prove that. That is a corollary to the first point on the importance of the
selection of the expert. In this case, the experts who did the official studies checking out
land treatment—the studies the town relied on to fulfill its legal obligation to "consider" all
alternatives—showed that it was much more expensive than conventional technologies. The reason
for this finding is that they overlooked all the land treatment sites close to town and claimed
the sewage would have to be piped several miles further out from town. Their land treatment
plan would have required digging a large canal and had other expensive features. It's always
easy to escalate the costs of the system you don't want to build. There are a number of other
tricks that can be played.
And the final point is that the people are very important. The most serious mistake in Spokane,
probably, is that the people—ordinary citizens groups—never really got involved in the dispute
in large numbers. Somehow the connection never was made. The engineer favoring land treatment
tried appealing to EPA and nothing happened—no help. He tried publicity but it must have been
a little confusing to the public because the papers typically don't explain these complicated
questions very well. He tried a lawsuit which was thrown out of court. The law gives local and
state pollution control officials a great deal of discretion in this area, so lawsuits are not
a promising avenue for relief. This is not to say you should give up on lawsuits altogether.
There may be cases where it's necessary to sue. But even if you win one, remember there are
probably 30 or 40 more decision points still to come in the whole process. You may face resis-
tance at every single turn. If you've avoided taking the difficult but necessary step of
building a political base, going to the people—which sometimes is easy to avoid if you simply
file a lawsuit—then you won't have anything more operating in your favor when you go on to the
next stage and run into the next obstacle. You'll have no more support for a sensible solution
than when you started.
So the message is that the problem is political, and this is the key to the solution. Ultimately,
you can't count on simply having friends in the right places, on the experts. You will have to
use them, of course, and get their assistance. But, in the end, there's a message that we'll
hear again and again in the case experiences that follow and that I think you'll find will hold
true in your own experiences. The message is that to turn around a wrong decision, it's going
to take resigning yourself to the task of building an organized base of popular support for the
right kinds of solutions. You might as well get started on that as early as you can.
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PENNYPACK WATERSHED ASSOCIATION, PENNSYLVANIA: CASE STUDY
DOM MITCHELL: Consultant, suburban Philadelphia. A former newspaper reporter, Mitchell is
a writer and active in community organising projects and is working with the
Pennypaak Watershed Association.
HELGA WAGNER: A Director and active member of Pennypaok Watershed Association, Wagner is
also a Commissioner of Abington Township. She has been appointed by the
Governor of Pennsylvania to the Southeast Regional Planning Council of the
Governor 's Justice Commission.
When I hear the Pennypack case described as a success, I wince a little bit. Because even when
you get a decision out of your state agency that says, "Yes, you're going to get a land treatment
system in your community," there is still a lot of work to be done. I'd like to give you some
background on what has happened, and tell you about the obstacles we encountered and the strate-
gies we used to, if not overcome the obstacles, at least wiggle around them.
The controversy concerned three municipalities in suburban Phi lade!phia—Abington, Lower More-
land, and Bryn Athyn. All three of them are upper-middle and high income communities. They are
adjacent to the city limits of Philadelphia. Philadelphia is the fourth largest metropolitan
area in the country. It has five million people in the Standard Metropolitan Statistical Area
(SMSA). Two other SMSA's are right next door, Trenton and Wilmington, which are part of the
greater Delaware valley. So it's a very large interconnected metropolitan area, a sprawling
octopus.
In the Abington, Lower Moreland, Bryn Athyn area there is a green belt that is adjacent to the
city limits which is the only green belt left that is adjacent to Philadelphia. Therefore, there
was a strong incentive on the part of environmentalists to preserve that green area. Pennypack
Creek is the creek with which we're concerned. It is a tributary of the Delaware River.
Abington Township has a population of 66,000 people, concentrated in 2/3 of the Township. The
eastern 1/3 of the Township is mostly open space. Lower Moreland has 11,000 people. Bryn Athyn
has 1,000 people. . .
Bryn Athyn is a very unique sociological phenomenon, in that it is a religious community that has
been in existence for about 100 years. It has its own school system and its own cultural iden-
tity which is very distinct from the other communities. The Sweden Borgian religion has a very
strong conservation ethic, consequently Bryn Athyn has been thinking in terms of water recycling
for a long time. Thinking about doing things to clean up Pennypack Creek.
About five or six years ago, Bryn Athyn applied for a grant to build a spray irrigation system
to service that community. At the same time, Abington and Lower Moreland applied for funding to
extend an existing sewer interceptor line that came up Pennypack Creek inside the city to the
city line. This interceptor would have taken the wastewater from the central watershed and
exported it to Philadelphia's northeast treatment plant.
The regulatory agency indicated that they would not fund two separate systems in the same service
area and that the communities had to work it out. Abington and Lower Moreland said to Bryn
Athyn, "Why not run the pipe up a little further and connect Bryn Athyn in too?
At about that time, my conservation group came along and said, "Wait a minute, why not put Bryn
Athyn Abington and all of Lower Moreland into the same spray system?" It took a long time to
get that considered seriously. We had to threaten to go into court at just about very turn.
The reason we were able to do it was because they knew we had enough money behind us to go to
court if we really had to. We got the state to make a study of the alternatives and, ultimately,
the state decided in favor of our system. But the fight to get to that point was a long and
hard one.
The interceptor plan was a bad plan for three basic reasons. First, it involved exportation of
water f%m the central watershed. Second, it meant that on-site systems and small package plants
Safwerl recSarginSpennypack Creek would be phased out. Third, it would have left the Upper
MoreUnS trStmeSt plant/which is the primary source of pollution as the sole source of flow
into the creek We felt it was patently illegal to take federal clean water funds and use them
to Lke Pennypack Creek worse. Another factor was that Philadelphia to whose plant we would be
piping our sewage, is the worst water pollution problem in the five-state region.
What our group proposed as an alternative was not a single spray irrigation system, but a de-
centralized approach of seven small systems that could be built in stages, so we could supply
services to areas that needed it most.
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We had a number of assets going for us. For one, the other plan—the interceptor sewer—was
so bad. Also, the Pennypack Watershed Association already existed. It was an organization "
dedicated to cleaning up Pennypack Creek and guiding the growth of the surrounding environment.
It was well funded and well staffed and was professionally respected. But we had to go beyond
that, as we found out when we went to the state.
They were willing to begin the study we demanded, to consider spray irrigation as an alternative,
and the study as it developed, eventually began to vindicate our viewpoint. But we were told by
the state that even though our concept made sense and the other plan didn't—and even if the
study should confirm this—there was still a problem. The state told us that as long as some
local governments opposed our plan, we would have to do something to convince the state that they
should overrule the opposing municipalities.
In other words, we would have to demonstrate a lot of grassroots support.
So, we started at a really basic level. We formed another organization called "Citizens' Committee
for Responsive Sewage Planning." We tried to get the issues down on paper to about one page. We
went out into the shopping center, started handing out the leaflets and explaining to the shoppers
what we were advocating, and we got them to sign petitions.
When you go to the local commissioners with petitions, they always say that this isn't so, that
it doesn't mean anything. The signatures probably don't mean much to the commissioners, but
they meant a lot to us. Once we got 1,000 signatures on a petition, we made a mailing list.
From that mailing list, we started doing direct mailings to all these people to educate them
about the process and inform them about the developments in the state study.
The way the state did the study was interesting. The state hired consulting engineers and had them
directed by a Multi-Agency Task Force. It was a very open process. They had public meetings
at every stage to critique the study as it progressed. Initially, the engineers started to con-
clude spray irrigation would not be cost effective. They couldn't find land, and so on. That's
when we knew we'd have to get serious. We got our own engineers, and we went out and found land
that would work. We got the state study to evaluate our specific proposals. And we had large
numbers of our supporters attend the Task Force meetings, monitoring their every move. That's
when things began to turn in our favor.
We used the mailing list from the petitions to keep the momentum going. We compared that
mailing list with the membership of the Pennypack Watershed Association, which at that time was
about 500, and has since grown to more than 1,000. We were delighted to find that most of the
people who signed the petition were not members of the Pennypack Watershed Association, which
indicated we had tripled our outreach at that time.
We then went through cross directories and street lists to get the names of all the people in
all the neighborhoods that would be affected positively by the spray plant or negatively by the
sewer plan. Then we examined our own mailing lists to see who supported us in those neighbor-
hoods and contacted those people and asked if they would host a neighborhood meeting. We went
into those neighborhoods with maps, charts, and films, and said, "This is what we want to do
right here in your neighborhood."
To this day, the neighborhoods that we got to first still support us, and the ones the opposi-
tion got to first are still against us. In a lot of ways, it's a matter of being poised to act
rather quickly. You must be ready to reach people.
Well, things were going really well at that point. We got endorsements, not only from neighbor-
hoods, but civic associations and all kinds of groups. There was no organized citizen opposition
to the land treatment proposal, until after we had what was, by our standards, a stellar success.
That's what scared the political structure in the community, and that's when they started doing
their own organizing.
Lower Moreland's conmissioners had always been unanimous in their opposition to our spray plan.
Abington, on the other hand, had been split for about two years. Democrats had been one vote
short of a majority on the Board, so there were two parties sitting there. It was easier to
divide that township on the issue. Eventually, the Democrats won the majority and we got our
key citizen organizer, Helga Wagner, elected to the Board.
Having a local unit of government, Bryn Athyn, officially for us from the start helped a lot.
It gave us official entre, a credibility that we would not have had otherwise. The way we got
the state study initially was that Bryn Athyn challenged the state's priority list for federal
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funding. And a portion of the legal and engineering fees for developing our specific proposal
to present to the state study was paid for by Bryn Athyn.
When we first started running into opposition, what we did was to keep up regular mailings. And
we continued to participate in the state study as it was happening, to keep people informed about
it. I'm not even sure why we wanted to do it, but we wanted to have a public hearing when the
draft of the state's report—the study of the alternative—was finished. That study recommended
the spray alternative. We did two direct mailings to get people out. And we made 400 telephone
calls right off our petitions to get people out to this meeting. Almost as an afterthought, we
decided to get "Hurray for Spray" buttons. We were really glad we did because we had 800 people,
and about 600 of them were wearing our "Hurray for Spray" buttons. We knew that because we
counted how many we had before we handed them out, and then counted how many we had left after-
wards. We were kind of amazed ourselves, because to get people to sign a petition is one thing
but to get them to actually take part and support something—especially something as esoteric as
a specific sewage treatment technology—is an accomplishment. The biggest success that any of
our local citizen organizers had under the belt before that was to get 400 people out in opposi-
tion to something. Which is a lot easier. So we thought we were doing pretty well.
The Republican party in Lower Moreland Township thought we were doing pretty well too, and that's
when they started doing their own organizing. To date they have produced 600 signatures on a
petition, so we're still ahead in terms of petitions. They turned the petitions into the state
agency and sent us a copy of the cover letter. They did that to scare us. That wasn't a
smart idea, because then we knew who to go to for a copy of the petition. Since they were turned
into a state agency, they were public information and they had to give it to us. We then made a
mailing list from those petitions and now we have their mailing list as well. We've really done
a lot with direct mail, not just to reinforce our own constituency but also to embarrass the
opponents.
We have been very strict about being open and upfront about who is behind us, and what our
motives and our goals are. The other side has really used the fact that we have some wealthy
supporters against us.
One of their problems is that they don't understand technologies too well and also don't under-
stand the legal ramifications of the two issues. As a result, they make a lot of mistakes. And
whenever they do, we nail them on it. One of the ways we do it is by direct mail to their
neighborhood. If one of our opponents makes a statement that is not really true, we'll write to
all their neighbors and say, "Gee, did you realize that so-and-so is saying this about your
neighborhood, or about this issue or about the way all of you feel?"
It's a very effective strategy. What it boils down to is being ready for that kind of thing.
You can't sit around and expect people to rise up spontaneously and to recognize the difference
between the right and the wrong arguments. You've got to really get the information out to them.
I think that what the politicians are looking for before they'll move—they want to see iiow many
people ultimately you really can influence. That's the thing to organize—how many votes you
can deliver, or how many newsletters you can get out before they get their newsletters out.
One of the things we learned was that we can identify certain specific issues that we think any-
one dealing with land treatment is going to have to deal with. They involve health impact and
property values, odor, insects and mosquitoes, tax impact, and in our part of the country the
question of what happens when the system freezes and later melts? Those are the questions we
get asked about most often.
The questions we get reveal a real lack of environmental understanding. We found repeatedly that
we had to take people back to page one and explain to them what happens when they flush their
toilets. We have to explain to them basic things about viruses. We have to make distinctions
for them between viruses and carcinogens, the kinds of things that we environmentalists have
already been sensitized to.
We constantly found that we had to be very careful that we don't get into the habit of using the
technical jargon that we encounter—that we have to continually be sensitive to our own language.
We have to aet our supporters to ask questions, encourage them to make us repeat ourselves, and
suDDort them when they think that we're not making ourselves clear. If we can do that, if we
can get it into those simple grassroots terms, I think we've got a chance of building a consti-
tuency.
The jury is still out on the final decision. The opponents have appealed the state's decision
on the grant, through an internal process at the state level. It has not gone to court.
Whether or not it will is unclear. But at this point, the state's decision for spray irrigation
is still standing. We think we will be effective in getting a land treatment system for a
developing suburban community. 85
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NORTHGLENN, COLORADO: CASE STUDY
RICHARD P. LUNDAHL: Public Works Director, Northglenn, Colorado. Implementing a unique
sewage recycling plan for Northglenn.
The city of Northglenn's comprehensive land and water resources management program, has stirred
up controversy at every level of government, from the counties to the EPA. Northglenn's program
combines water supply, urban stormwater runoff treatment, and sewage treatment objectives into a
comprehensive plan to conserve valuable water resources and meet the 1985 zero-discharge goals
of Public Law 92-500.
Northglenn is a suburb of Denver, Colorado, with a population of 33,000 people. Incorporated
in 1968, it has the vigor and vitality of youth and the vision to translate dreams into reality.
Within an enclave of only seven square miles, its City Council and staff have been concentrating
recent efforts on providing its citizens with a safe, adequate and reliable water supply, and on
a sewage facility which is environmentally sound and will meet the strict water quality goals
of PL 92-500.
Northglenn was previously dependent on a neighboring city for water and sewer service. This
city undertook to condemn agricultural water rights to meet its municipal needs. If successful,
these condemnations, which are still pending, would take 40,000 acres of prime agricultural land
out of production. Northglenn found this solution untenable and proceeded to work out a unique
water-sharing agreement with surrounding farmers.
Developed through months of hard negotiation with the Board of Directors of the Farmers Reservoir
and Irrigation County (FRICO), the agreement is the cornerstone of the Northglenn Water Manage-
ment Program. The biggest obstacle which had to be overcome in working with the farmers was
their justified mistrust of cities, resulting primarily from the pending condemnation action,
which would turn their 40,000 acres of irrigated farmland into a dust bowl.
The agreement was consummated because both the City of Northglenn and FRICO shareholders will
benefit from the proposed concept of sharing water. Very simply, FRICO agreed to let the city
borrow their high quality mountain water, use it in the city for municipal purposes, capture the
sewage, treat it and store it for up to nine months, and return the treated effluent to the
farmers as needed for irrigation. Rather than charge Northglenn in dollars for the borrowed
water, the fanners agreed to be paid back 10% more water than was loaned to Northglenn. North-
glenn agreed to this condition and will make up all consumed water by collecting urban runoff,
developing groundwater supplies and purchasing other water as needed.
Thus, the City of Northglenn will benefit by obtaining a high quality, dependable water supply.
The farmers will benefit by getting back more water than they had to begin with. They will also
get a valuable bonus, since the returned water will contain fertilizing nutrients such as potas-
sium, nitrogen and phosphorus, and the additional storage will increase the amount of water
available to them each year.
As a further plus, the public at large benefits because thousands of acres of prime agricultural
land will remain in production. Water supplies for the area will be increased by using high-
quality water in the city first and recycling treated wastewater to the land. Waters of the
region will improve because sewage and urban storm runoff will be more thoroughly and consistently
treated by the land application process before returning to state waters.
That's what we're trying to do in Northglenn. Except for one final hurdle—EPA's determination
of the level of federal funding—the project is ready to go forward to final design and construc-
tion. But we think we have learned a few things on the way which could help you succeed in
getting clean water for your own community.
The hardest step of all in your community may be one that was relatively easy for us compared to
what happened later — winning local approval of an alternative waste management plan.As a public
works director, I can tell you that it's especially important to have the local public works
director on your side. If the public works people are not wholeheartedly working for a recycling
plan, you may have to find a way to get them replaced because they can undercut your efforts at
every turn.
Remember your biggest enemy is delay—delay in getting things approved and started. That's
because with inflation in construction costs plus the cost of paying for people waiting around
to get started or making false starts, delay means increased costs you face. The pressures
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get greater and greater for you to just give up and take the easier route, adopt the more
familiar conventional technologies. It's easy enough for your opponents to throw up little
obstacles that add up to lots of delay—that's the bureaucrat's main weeipon^without being
undercut right in your own camp. So your own public works people are very important to have
on your side.
One thing we did very early that helped solidify the support of our local government for the
kind of plan we later developed, was first have our Council adopt a statement of policies,
objectives for our wastewater management plan.
The objectives involved finding a plan that would deal with runoff, with water supply, with
wastes—with all our water needs—and not just look at one piece of the problem. Another
objective in our policy statement was having a harmonious relationship with the farmers in the
surrounding area. Another was trying to find a way to use the resources in our wastewaters.
We adopted these, we defined the problem, before we ever got down to any specific debates over
which engineers to hire to help solve it or over specific proposals or locations. When these
later questions come up, all the various interests that people and groups have start having an
impact on the process. So having some guiding principles before that gives you criteria by
which you can judge everything that's proposed.
After that, of course, we had to choose our technical consultants, our engineers, to investi-
gate the options and cost them out—to present specific possible proposals with specific land
and so on. This is probably the most important choice you'll have to make. The key is to
look for someone that has a track record and a staff set up especially to do this kind of
total waste management concept. You want a firm that really understands it. Now, you'll find
lots of engineers talking a good game, since this kind of system is becoming more widely known
and is more in demand. You want to make sure your engineers really are qualified to make the
kinds of judgments they'll have to make. One good test is looking at what they have actually
designed and built in the past.
After the specific proposal was worked out, the Council decided to adopt it officially. In the
debate over whether this was the best way to go, the Council decided that it would help to move
the project along later if Northglenn was prepared to fund not just the non-federal share, but
the whole thing, if necessary—if for some reason the plan ran into resistance or delay. That's
how committed we were to do it. We thought this project would be a benefit to our community.
That commitment has helped out since then.
The City Council then decided to go to a vote of the people to get a feeling of support. To
ask: "Are we going in the right direction?" The Council had authority to issue revenue bonds.
They didn't have to go to a vote of the people. But our Council and Mayor felt very strongly
about the need to get a vote of the people, to find out if we're going in the right direction.
Prior to the bond election, we went to sixty or seventy discussion-type public meetings in
homes, at service clubs, at real estate offices, with all the local organizations, police groups,
teachers, everyone. We carried this project to the people, took their input, answered their
questions. We had this fantastic vote last July, a two-to-one margin to go ahead with the pro-
ject. Now we have very strong local support. That's a very important thing.
Remember that there are two levels of local support—the government and the people, the groups
in the community. If you don't have the officials' support to start with, community groups may
have to organize to push for that. But even when you do, we thought support from the people
was important.
The next step for us was getting the approval of the 208 Regional Planning Agency.[Under Sec-
tion 208 of the Clean Water Act, proposed treatment plants can be federally funded only if they
are consistent with these agencies' regional plans.] That experience shows why local public
support and involvement is so important. Because getting a project like this—one that makes
so much sense—approved at the local level is, as I said, sometimes the easiest step. After
that is where you can really run into resistance. There are hundreds of hoops to jump through
and the hoops are moving. There's constantly shifting EPA regulations and policy, approval by
regional agencies, health departments, state government, EPA, and then getting state and federal
funding approved at the right level and actually granted, which means being high enough up on
the state-set "priority list." It's a long and very political process. Maybe the best way to
summarize it is that "there's a turkey behind every tree" out there.
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That's kind of a way of saying that there's that mindset out there. There is a definite bias
in the health departments of the country, not just Colorado and in EPA and in regional planning
bodies, people that are trained in conventional treatment. Alan Merson [Region B Administrator
for EPA] mentioned it yesterday. That's one of the biggest problems that he even has to over-
come, reorienting the thinking of his own staff as well as health regulation authorities and
others. So you've got to be aware that, even though the people may be well-meaning, they
are wrong. And you have to find a way to convince them that they are wrong.
That's where people's support, popular support, makes a difference. For one thing, your people
must be prepared to perservere through periods of resistance to your plan and not jump ship and
settle for something inferior when the going gets tough. And the support and understanding of
the people—in our case, it included the neighboring farmers too and that was a real advantage
of building them in at the beginning—will be needed to help overcome all those political
obstacles you can expect. Being able to demonstrate that support—pointing to our two-to-one
vote—and even having local people really to go to bat for the plan themselves is the key.
That's what it takes to win it.
We first had to win over the 208 Planning Agency, in our case it was the Denver Regional Council
of Governments. We had an extraordinary amount of difficulty trying to get what is called
"management agency designation." Without that designation, you cannot get federal funds directly
to build a sewage treatment plant. We talked and discussed and went into great detail with the
staff of the Denver COG. They thought it was "great"—they were all for us—until we actually
got on the state priority list for federal funding, and then all of a sudden, "Well, it's pre-
mature, let's slow down and look atthis thing, make sure you look at all the different problems
and so on." After that, it's delay and delay and delay. In a project of any magniture, delay
is inflation and increased cost. That's not to say that you shouldn't have a comprehensive plan.
But, there comes a point when you've got to build the project, and we did a fair job of study
beforehand. So I think that a lot of those staffs have premature conclusions, mindsets or biases
towards conventional treatment. The Denver COG fought us all the way. There were three advis-
ory committees to COG and two out of three advisory committees also succumbed to the persuasion
of the COG staff. Without their own staff accountable to them and without enough time to do their
own research, these advisory committees can be very vulnerable to being manipulated by the COG
staff. We lost at the advisory committee level and at the staff level. So we took it to the
political level.
The officials that are responsible to the people, the officials that are most likely to hear the
people—elected officials—are the ones that have been most responsive to our plan. We went to
the governing board of the Denver Regional Council of Governments and we overcame the staff bias
and recommendations against our project. We got approval of the Management Agency by a vote
of 28 to 2. That kind of a phenomenal political success really spurs thing on! Once you get
that, then you work with the state officials and the EPA officials.
That's where we're at right now. We're trying to redirect the thinking of EPA. Because we're
kind of on the forefront—we have a complicated project that is a combination of water supply,
wastewater treatment and urban runoff treatment--we're ahead of EPA regulations. The regulations
don't quite handle our particular kind of project. So how much federal money are we entitled to?
We're trying to reach an understanding so that EPA is giving funding at what we think is an
appropriate level for this project.
To summarize, if you're in an area that doesn't have, say, a city council and staff that are
open to nonconventional treatment, then the first thing you have to do is get strong support
from the people. The next step, once you do get a broad political base, is to start getting
city councils developing policies, so they know where they're going on a particular issue, in
this case, sewage treatment and water supply. Then you go to the selection of staff and expert
consultants. If you have a public works director, for instance, who is not open to this kind of
thing, then you better get a new one, because that person can really slow you down and stop you.
The consultants are very important also. There are firms that have a narrow bias, and they want
to build conventional treatment plants. It's their thing. So you better get the right consul-
tant. Otherwise, you're never going to get to the point where you can get a good project. The
next thing is to get regional/state/federal staff to convert to your way of thinking. If you
don't, then you better go the political route, because the political people are much more respon-
sive. So remember, you're in a fight to change things. You're fighting the status quo, and
that's always an uphill battle. Thank you.
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FALMOUTH, MASSACHUSETTS: CASE STUDY
DR. WILLIAM KEPFOOT: Chief Scientist., Environmental Devices Corporation, Merion, Mass.
Formerly Assistant Scientist at Woods Hole Oeeanographia Institution.
and Director of Environmental Management Institute, a water quality
consulting group.
GLENN MACNARY: President, Association for the Preservation of Vineyard Sound,
Falmouth, Mass. Retired as President of Continental Baking Company.
Falmouth is located on the Southwest corner of Cape Cod. It is a town of 20,000 and growing.
It is bordered on one side by Buzzards' Bay seawater, and on the other side by Vineyard Sound.
The sole source of water for this entire area comes from rainwater. Thirty million gallons a
day is the effective recharge rate of the Falmouth area. It's located on a sandy aquifer--a
sandy base covered with a sandy loam—and it is bordered on both sides by salt water. When you
consider sewage treatment or water supply plants, you cannot separate the area from the hydro-
logy. It continually receives rainwater and this water continually flushes out at both sides.
The rate of recharge maintains the water table. That is important for the 152 great ponds and
double that number of small ponds on Cape Cod. Within Falmouth alone there are 23 ponds, which
are major tourist attractions and revenue producing areas of the Falmouth region.
The story of Falmouth, you could call it a horror story or a success story. We've been at it
for close to seven years. Our educational efforts have produced results. The vote in the last
election for selectmen was two to one for our candidate, who in his advertising had stated that
he was for inland spray irrigation. We got two out of the three selectmen, and that has happened
in the last year. Rarely do you now hear anybody say, "Well, I'm for outfall." Also in the
Department of Public Works for the first time in the vote this spring we elected our man who for
years has been saying "I'm for spray irrigation."
So we're making progress in education. Those people would not have been elected unless the
majority of those voting believed in our position as the best way for Falmouth to solve its sewer
problem.
The story started with a crisis—the sewer problem. The state had told us that we had to improve
our outfall at Woods Hole which at this point only includes primary treatment. At a town
meeting, we had voted the funds for a large activated sludge plant with the outfall into Nobska
Point.
Now many of us thought polluting Vineyard Sound with sewage effluent would be terrible. What to
do? We then formed the Association for Preservation of Vineyard Sound. We had a crisis.
When you are setting up a new organization, you can get a large group (we have about 300 members
in the town of Falmouth for the Association for the Preservation of Vineyard Sound)—you can get
an organization of that size together and get them to join—if there is a crisis, a need for
action If you try to do it at'a time when there isn't a crisis, it is probably too theoretical.
Theyare not properly motivated, and therefore not anywhere near as many join. Even though you
have a large organization, of course you will find that you can only rely on a much smaller num-
ber of people to carry out the nitty-gritty day by day.
After we formed the Association, we immediately went to work with the town to get the 10% signa-
tures needed in the town of Falmouth to get a referendum on the act passed at the town meeting,
to get it reversed. We had to start educating people right away.
What were our arguments? Well, we first thought our best argument would be to avoid any pollu-
tion of the ocean surrounding the Cape. But as we went further in talking and getting signa-
tures, we found that our best issue was the conservation of water, the need for maintenance of
our water table, for avoidance of a drop in our pond levels Which had happened fortunately,
in a way, in the mid-601 s, at which time there was a drop of four feet and the edges of those
lakes became vegetable swamps. So there had been a demonstration of what could happen on the
Cape if tSe was a draining! of the water rather than a recycling, which is now going on through
rp^nonls seotic tanks and so on. So we had two good reasons why we should have an inland
trea£ent'sy!tem rather than an outfall. But at that point we still didn't know what system.
Well, we had the referendum, and we won it by a two to one vote The selectmen then set up a
sewage committee. They very hurriedly selected four people that were for outfall and four that
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were for inland. You can just guess what went on. Meeting after meeting, bickering.
So we decided as an Association, to set up an ad hoc study committee, to come up with a recom-
mendation of what would be the best solution. I chaired that committee. We studied Lake Tahoe.
We came down [to D.C.] to Blue Plains. We did some additional looking at physical-chemical
plant experience. We also had a study of Muskegon, Michigan, which was just then getting started.
We decided that spray irrigation, with some modification of the Muskegon County Program, would be
the ideal for Falmouth if we could find the right land.
We recommended that to the regular committee. They had the usual argument and could not resolve
it. Finally, in a compromise, the regular sewer committee decided to recommend sort of a "tin
can" system, a small package plant as a temporary solution, to upgrade the Woods Hole waste to
secondary treatment but keep dumping it right off Woods Hole into Great Harbor. This recommenda-
tion did not include sewering the center of Falmouth and connecting all that in--the center of
town had been polluting the groundwater and the ponds with septic systems. So the amount of sewer
effluent wouldn't be increased. At a town meeting they voted $100,000 to work out the plans for
this small conventional plant with a new engineering firm, Anderson and Nichols. The first firm
was Whitman and Howard.
So what were we to do? We were still looking for what we would consider a benefit not only to
Falmouth but an example to the 15 other towns on the Cape, 13 of which had no sewer plant but
will need one in the future. It would be an example, as well as protect the groundwater and the
level of the ponds in our own vicinity. The problem was, if we want to go spray irrigation,
where are we going to put it?
Otis Air Force Base had very limited personnel at this time. They had a plant that was designed
for three million gallons a day. There is ample capacity to take care of Falmouth and then add
a lagoon and spray irrigation. So I asked the city's Department of Public Works if that might
not be a reasonable alternative to that tin can plant. If we were going to treat the wastes at
Otis, I suggested, then we could go ahead and sewer and treat the center town, which has polluted
feet
d
ponds within its borders. The odor in the summertime is very discernable. Their reply was,
"Well, the Army made a study of Otis and said that it wouldn't be feasible to pump the 100 fee
elevation to Otis." We said, "Can we see the Army plan?" Well, they didn't have it but they'
get it.
We waited and called. Didn't show. Then I got hold of a representative in Congress and he said
he'd try to get it. Again, delay—no results. So we took the bull by the horns and flew down
to Washington to the Pentagon and had a session with MacLucas, Air Force Under Secretary. He
called in Lew Turner, who's Deputy Administrator for all Air Force bases in the world. I said,
"I'm looking for a plan for this study that was made by the Corps [of Engineers] for the Air
Force showing that it would not be feasible for Falmouth to tie in with the Otis facility.1 Lew
Turner went back to his office and came back with a wad of paper. He said, "The only study we
have is by your own engineering firm." So obviously that was slanted.
While I was there, I talked about the possibility of Falmouth taking over their plant and having
350 acres of Otis land for spray. I was a little surprised they thought it might be a good thing
to do. When I got back, we set up a special town meeting of precinct representatives. They
called the citizen representatives to meet with the Air Force to talk this out. Well, our Depart-
ment of Public Works, again, fouling up the deal, brought down all the Whitman and Howard [the
engineering firm] that had recommended the large activated sludge plant. They proceeded, while
the Air Force was sitting on the platform, (one of whom had flown in from Denver for the session)
to take up all the time talking about the benefits of the outfall. The townspeople that were
there, who were by this time ardent land treatment advocates, were very upset.
When the meeting was over, the Air Force said, "What goes?" And we said, "Well, look. This is
not the majority of the town. The majority of the town voted two to one against the outfall.
This engineering group is in the saddle at the moment, but we expect to swing things around. We
would like letters that would give us the use of the land and the treatment plant." We got those
letters. They are in the town's files. Then we thought, we can't sell this proposition without
a feasibility study. Also, we need more stimulation as far as the people are concerned, further
education. I went down to Washington and invited Jack Sheaffer, who was then the Science Advisor
to the Army Corps of Engineers to come up and speak. We put out a town-wide invitation, and it
was a good turn out. Jack, as usual, did a terrific job, which was a great stimulus to our pro-
gram and the value of spray irrigation. We asked Jack: "We need a feasibility study. Would
Bauer Engineers [from Chicago], who are doing the Muskegon County Program, be interested in doing
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that kind of a study? He said, "Let me talk to them."
Now Bauer thought we should have a local firm involved in the study so we decided to ask the
new firm, Anderson and Nichols [which already had the contract to design the small plant], to
work together with Bauer checking out the possibility of spray irrigation at Otis AFB. I got
the President of another organization, the Association for Preservation of Cape Cod, to work
with me on this. He and I went to see Anderson and Nichols and Bauer flew in from Chicago for
the meeting.
I had thought the study was going to cost around $20,000. Well, when we got to talking it out
with the engineers, it got to be $30,000. The President of the Cape Cod Association said, "We
don't have money of this sort." I said, "Well, we'll get the money." So we went to work—
$10 here, $50 there, $1,000 somewhere else and we finally ended up with $31,000. With that, we
got the study. It should be in gilt.
We were ready for a real educational drive with our feasibility study. It was quite elaborate
and it was keyed to the entire Cape, with Falmouth as the example. We went to the Rotary, the
Garden Club, the Lions, all the schools, not only with the feasibility study but with the
Pennsylvania State film—they have a good one on spray irrigation and its results. We showed
them that and left the feasibility study with them. We also went to the Woods Hole Oceano-
graphic Institution brown bag Friday afternoon luncheon. I spoke before their scientists,
showed the film and left the feasibility study. They got interested in it. Bill Kerfoot [of the
Oceanographic Institution] made a trip to the Penn State, I believe, on his own,and came back
and reported to Woods Hole Institution. He gave them a factual scientific analysis of what
went on there and its results. This was our educational effort. We, then were ready to go to
the town meeting.
Let me remind you that the town had already voted $100,000 for the plans for the small plant.
We went to the meeting for $65,000 to get Bauer and Anderson and Nichols followup on their
feasibility study by doing an official preliminary comprehensive plan for spray irrigation at
Otis. At the town meeting, the town Department of Public Works fought bitterly against our
proposal. But we had mailed one of these feasibility studies to all 250 of the precinct repre-
sentatives in advance. We had sent a series of letters to the town representatives pointing out
the need to conserve the water, the danger to the seafood chain if there was a shift in the
salinity at the shoreline, the need to hold the ponds at their present level, the avoidance of
pollution and the fact that secondary treatment plants do not run automatically day by day but
there will be days when the secondary effluent going into the ocean will be far from high
quality. So we had support at the meeting and won the vote to fund preparation of the spray
plan, which was completed by Bauer.
So now we had an official local proposal for the spray idea and were ready to try to get the
State to approve it. That's when we started getting whipsawed between two old line State agen-
cies, the Department of Water Pollution Control and the Health Department. The water pollution
people were wary about spray irrigation but were willing to let us take the wastes to Otis. They
said Falmouth should first try filter beds [a system which rapidly percolates the wastewater
through sandy soil] at Otis, and if that doesn't work, then maybe spray irrigation would be
approved. But, they said, you also have to get the State Health Department's approval. The
State Health Department had many fears, viruses floating around the world and so on, and said
no. So we were stymied.
We decided we needed to prove that spray irrigation would work and also keep our momentum going,
Se we got local and state funding for a small spray irrigation experiment to be conducted at
Otis using the wastewater from the Air Force Base. As that began to work out, we figured, it
would be easier to win approval for putting Falmouth's waste out there. Woods Hole Oceanographic
Institution did the experiment. It went on for three years--1974, 1975, and 1976. The final
EPA report on the experiment is close to being completed.
In the meantime, we were trying to overcome the logjam in the State bureaucracy. When the admin-
istration changed—the Republicans went out and the Democrats came in—we had a new ballgame.
We had to go back and start over with new administrative officials. But at the agency operating
levels, those civil service bureaucrats keep surviving one governor after another. The Health
Department still would not budge. So we were still stalled.
At that point, the State Water Pollution Control agency out of the blue, gave the town another
order to start construction of the small plant before 1976. These people had been with the
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Department for a long while. They felt that the timing was right to push ahead doing what
they wanted.
There was such a flood of protect letters from people in our town to Water Pollution Control
and to EPA that they got their heads together to figure out what to do. They decided to get
another engineer. Counting Bauer, who we brought in, that made the fourth firm put on the
case. Camp, Dresser, and McKee was hired to study all the proposals that had been made up to
that time for Falmouth and recommend which one should be picked.
We knew we had to get support for our plan within the new administration. One lesson we've
learned is that at the state level, you are much better off going to the top than starting at
the bottom of the bureaucratic ladder. We called and could not reach the new Governor right
away. So we wrote him. And got a nice letter back, suggesting we get in touch with the Secre-
tary of Environmental Affairs. So we had an invitation to do that. It worked.
There are really two reasons why that is a better technique than starting at the bottom. One,
the higher you go (and I [McNary] learned this in business) the higher up you go to talk to
somebody about a problem, the more perception and the more they listen. At the lower rungs of
the business ladder, you are inclined to get shut off, or they would much rather talk rather
than listen. People with more responsibility are more ready to listen. That's reason number
one for going to the top.
The second reason is that when your opponents are the local Department of Public Works, which
is often the case, your opponents generally have a relationship with the entrenched lower rungs
of the state hierarchy, with the old people in the agencies. So you're running up against
relationships that have already been established.
We got the meeting with the new Secretary of Environmental Affairs, Evelyn Murphy. The man in
charge of grants for Water Pollution Control was there too. We made our pitch to Evelyn
Murphy. Finally she turned to the Head of Water Pollution Control and asked, "Will this be cost
effective?" He said, "I don't think so." She said, "Don't you think we ought to find out?"
He said, "Yes." But he wasn't going to do a darn thing about it.
So on our own we had to get the competing plans—the outfall plan and the spray plan—updated
to account for inflation, to show the spray plan made better economic sense. After we made
the cost presentation to Environmental Secretary Evelyn Murphy, she set up a meeting for us with
her new Commissioner on Environmental Engineering, Dave Standly. The Department of Water
Pollution Control, who has been giving us trouble, works for him. Standly had the new engin-
eering firm—Camp, Dresser, and McKee—at the meeting. After our presentation, he said, "Frankly,
I'm in favor of land treatment." So we had an ally in state government.
We made sure we gave the new firm our cost effectiveness study before they got started. They
said they were going to meet with different groups in town, but they never did. We learned
later that they had been given orders by our Department of Public Works not to contact anybody
in town. The Department claims they were not influencing Camp, Dresser and McKee themselves.
However, we got a copy of a scenario that they had written for the 208 program, with a copy to
Camp, Dresser and McKee. This scenario was "Build the small plant and they study whether the
center of town needs sewering." The strategy was obvious. If you already have a small plant,
you wouldn't build two plants. You would just build on to the small plant.
This is a very important point too. It is very important to determine the client-customer
relationship when it involves an engineering firm, to determine who the engineering firm views
as their client. Whether they view the town, whether they view the Department of Public Works
(DPW), whether they view the Selectmen as the client.
That's where we stand. We've got solid local support from the people and allies now in the
State administration. [There's been another change in State administrations since this presen-
tation was made, however.] The Health Department is still an obstacle to the spray plan and the
Department of Water Pollution Control keeps threatening to ask the Attorney General to sue the
town, to order immediate installation of a conventional system. We've got a report coming out
soon from EPA on the successful experiment at Otis AFB. We've got a new man elected to the
town's Department of Public Works. And it looks like new state laws will prohibit new sewage
outfalls into Vineyard Sound. We don't have our spray irrigation system yet, but we're
getting there.
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PUBLIC PARTICIPATION: HOW PEOPLE CAN HAVE AN IMPACT ON POLICY
JOHN HAMMOND: Public participation consultant, Facility Requirements Branch, Municipal
Construction Division, U.S. Environmental Protection Agency.
Public participation is an important thrust of this Administration—the President? EPA Adminis-
trator Douglas Costle, Deputy Administrator Barbara Blum, and Assistant Administrator Tom Jorling,
who is in charge of the water program. Tom Jorling really wants to see something done. One of
the things he did in his first year in office was set up a working group to review the existing
public participation regulations for all the water programs under the Clean Water Act and par-
ticularly for the municipal grants program. That review is leading to new regulations, which
are being drafted. One of the things I want to do here is discuss some of the concepts which are
emerging as likely to become part of the new regulations.
How can you as a citizen, influence public policy? How can you have an impact on the federal
sewage treatment construction program? EPA's upcoming regulations on public participation will
give you some important handles. We expect there will be two separate sets of proposals. First,
there will be an overall policy statement covering general public participation procedures for
all the programs under Tom Jorling's jurisdiction. This includes solid wastes, drinking water
supplies, areawide wastewater treatment planning (Section 208 of the Clean Water Act), and
Section 201--the municipal construction grants program. This first set of requirements is
expected to be called Part 105 of the regulations. The second set of requirements, referred to
as Part 35, gives specific rules for participation in the construction grants program.
Let me give you three reasons why I say the public participation requirements need to be strength-
ened. One is, "those who pays, plays," Citizens are paying for it. You may be removed from
the product, but you are paying for it. EPA needs to have an effective outreach program to
involve citizens in the grants decisions, even if they don't move at the beginning to be effec-
tive or even if they don't know that these decisions will affect them.
A second major reason is that it is a source of new ideas. Innovative and alternative approaches
will die unless the public supports them and pushes them. The public will raise these ideas,
probably more than the engineering community initially.
The third reason is that the agency lacks resources, sufficient manpower to fully monitor and
implement the Act. This is a serious problem. One of the functions of public participation will
be in effect to monitor the whole process.
What changes can be expected in the new public participation regulations when they are proposed?
I can point to some changes that have been considered. [All these changes later showed up in
the proposed EPA regulations. As of this printing, final regulations have not been published.]
Public notice of hearings and meetings is required to come further in advance to give citizens
groups more time to prepare. There are requirements for earlier consultation of the public in
any planning or grant process. There are a number of new initiatives. One is advisory groups.
Any recipient of a construction grant, for example, would have to appoint, give special training
to, and consult with, a citizen advisory group. A dominant proportion of the people on the
advisory groups will have to be people who do not have a personal economic interest in the grants
process, but who represent themselves or others as ordinary citizens.
Another initiative will be a requirement for a grant recipient to prepare a work plan on public
participation at the beginning of every federal grant. The plan should identify the budget for
public participation, the staff assigned to do it, who is to be contacted, and what will be done
during the planning process. This work plan should then be distributed and be available. Every-
one will know at the very beginning what is going to take place, and when, and at what points
they can have input.
Another initiative will be the requirement that the grantee respond to comments made by the pub-
lic The response is not to be a mere description of the public comment but an explanation of
what the grantee is going to do about it, an explanation of why the comments are being accepted
or rejected.
Another initiative will require training of the advisory groups developed by EPA, probably imple-
mented by EPA or its designee.
Now for the Construction Grants Regulations. The existing requirements for public participation
in construction grants -the provisions relating to that in Part 105-are very general. They
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call for one mandatory public hearing, normally held at the point at which an alternative has
been selected and is being recommended to the grantee and the public. Other meetings can be
held and it is encouraged that they be held early. But they usually are not. In some cases
where an Environmental Impact Statement is prepared, there are many public meetings. But where
there is no EIS, in most cases, the only requirement is the one hearing. What's being prepared
to replace that is a two-tiered program, recognizing that some projects are more complex, more
controversial, more costly, than others. All programs would fall under a basic public partici-
pation program, a minimum of activities that must take place. Some, maybe 10-30%—we have to=have
some criteria for identifying the more complicated projects—will have to meet additional public
participation procedures. Figure 1 sets forth the participation requirements that we are con-
sidering putting into Part 35 of the regulations in the Facilities Planning process. The "Basic
Program" procedures would apply to all grantees. The "Full Scale Program" is the one we're
considering making applicable to the more complicated projects.
I won't elaborate on every step displayed. I hope you will comment on the regulations when they
are proposed and then become familiar with them and use them as handles, when they are finally
promulgated, which we expect will come sometime after the Fall of this year.
I would like to make three points about these requirements. First, any project set forth in the
"public participation work plan," which will be a part of the Step 1 Facility Planning process,
is eligible for federal funding—namely 75%, or 85% in the case of innovative or alternative
projects. [Suppose you can persuadeyour locality to, say, have citizens hold an educational
conference or meetings or, say, to provide participating citizens groups with a certain amount
of expert staff, perhaps with the experts the citizens choose themselves, or the cost of, say,
some informational mailings. These are possibilities that citizens have asked us about. The
answer is, they could be eligible for federal funding help if they are included in the grantee's
work plan.]
Second, whatever the public participation requirements turn out to be, they will be minimum
requirements. There is nothing stopping you from organizing to demand additional input steps
or safeguards. [So, for example, even if the requirements don't say that public meetings have to
be held in the evening, or, say, out in the neighborhood affected, local citizens could get
the grantee to agree to that. Or if the federal requirements don't say that the public needs
to be involved in the selection of the engineer, local citizens groups could still spell out
a proposed procedure for their having a voice in this and work to have the local government agree].
Finally, and most important, the procedures will be no better than the use that's made of them.
That's obvious but always worth saying. If there is a public meeting, people have to be there
to participate or the meeting doesn't make any difference. We at EPA need you there. Your com-
munity also needs you to be involved,and—in your own defense—you need it too. Vigorous
participation by an informed public will, we think, be the best guarantee that our efforts will
succeed.
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FIGURE 1
PROPOSED PUBLIC PARTICIPATION FOR FACILITIES PLANNING
Basic Program
Outline of public parti-
cipation work plan,
public notification and
consultation
Distribute work plan,
project fact sheet, and
notice of engineer
selection
Consultation, responsive-
ness summary
Public Meeting,
responsiveness
summary
Public hearing
Summary of public parti-
cipation (including
responsiveness summary)
as part of the completed
facilities plan
Step 1 Activity
• Plan of study
• Grant Award
• Preparation of
detailed pub!ic
participation work
plan
t Assessment of
existing and future
situations (before
selection of
alternatives to be
considered in the
Cost Effectiveness
analysis)
• Cost effective
analysis (before
an alternative
has been selected)
• Consultant
recommendations
• Facility plan
submitted to
State
Full-Scale Program
Outline of public parti-
cipation work plan, public
notification and
consultation
Designate or hire public
participation coordinator;
establish advisory
committee
Consultation with the
public and advisory
committee, distribute
work plan, project fact
sheet, and notice of
engineer selection
Training for advisory
committee and agency staff
Public meeting (with
advisory committee);
responsiveness summary
Public meeting (with
advi sory commi ttee),
responsiveness summary
Public Hearing
Summary of public parti-
cipation (including
responsiveness summary)
as part of the completed
facilities plan
FOR ADDITIONAL INFORMATION CONTACT,
John Harmcnd, WH-547, EPA, 401 M St., SW, Washington, D.C. 20460
202/426-9404
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SEWAGE TREATMENT FACILITIES PLANNING: THE STEPS IN THE PROCESS
MYRON TIEMENS: Chief, Policy and Guidance Section, Facility Requirements Branch,
U.S. Environmental Protection Agency.
What I hope to cover quite briefly is the framework of the construction grant process, how
facility planning fits into that process, and briefly go over by step the planning elements
involved in facility planning. Later, in the workshop, I will discuss the mechanism of proce-
dures involved in actual cost effectiveness evaluation. [The workshop presentation on cost-
effectiveness evaluation is not included in this draft conference reader.]
What's facility planning for? It's to make sure that the treatment works built into the grant
program are cost effective and environmentally sound. But what does that mean? Well, another
way of putting that, from both a programmatic basis and a project-by-project basis, is that we
want to maximize the environmental enhancement per dollar of expenditure, whether public, pri-
vate or both.
Fatility planning is the keystone of the construction grant process. That's the point at which
most of the decisions are made that affect waste treatment projects. There are some notable
exceptions to that, and I'm going to mention them in my discussion. But facility planning
determines what is to be built and operated, how it is to be built, its design and size, where
and when, and, as a matter of fact, facility planning does not necessarily need to lead you to a
decision that something needs to be constructed at all. It may identify a non-structural option
or a minimal-action option, which I'll discuss later, that can be accomplished without massive
construction.
But why do facility planning? We'll be obligating funds now at the rate of $4.5 to $5 billion a
year. We have some 10,000 active projects. We have about 5,000 facility plans throughout the
country that are active at this time. So I think the planning's important to try to reduce the
costs of this enormous program. And perhaps even more important, to ensure that when the treat-
ment works and the waste management measures are built, that we simply don't pass an environmen-
tal problem from one medium or place to another.
Just briefly, how does facility planning, 201 planning, [required under Section 201 of the Clean
Water Act] relate to the water quality management planning process, including the 208 designated
area planning and the state's water quality management planning? We look for the water quality
management planning, through a waste load allocation process [under Section 304] to set the
effluent limitations—that is, the discharge controls that the treatment facility must meet.
We're to identify the service area—the total area that is to be served by the treatment plant.
There may be many subservice areas within a typical 208 designated area. All 208 planning
agencies are to establish the population forecasts and wastewater flow forecasts, and I'll men-
tion the importance of these later on. Finally, they are to determine the priority for future
facility planning and for construction of treatment works within the area. This priority deter-
mination for an individual 208 planning area would then feed into the state priority system [the
state-set list determining which needs get federal funding first].
Unfortunately, 208 planning got started behind 201. Most of the reasons for the delay had to do
with the fact that 208 is a formal process requiring new institutional and planning
mechanisms and would inevitably require some time. It was delayed through impoundment of funds,
also. At the same time, 201 facility planning had to get off the ground right away, because
there was no hiatus provided in the Public Law 92-500, no waiting period before construction
grant funds would be obligated. There was $18 billion in contract authority as provided by the
1972 law, and funds had to be obligated immediately. So 201 planning had to get out in front.
201 planning is basically structured administratively; there is no formal 201 planning process
in the law, although there are a numberof individual statutory requirements in Section 201 and
Title II of the law, which have been factored into the facility planning process.
Now, how does facility planning fit in with the construction grant process? As most of you
know, the construction grant process is a three-step process: facility planning, Step 1; pre-
paration of detailed design plans and specifications, Step 2; and actual construction, Step 3.
Facility planning, as I mentioned, is essentially the decision-making first step.
Going into the construction grant process, I hope that most of you have had an opportunity to look
at the blue book, How to Obtain Federal Grants. I highly recommend it. It lays out pretty well
the steps in the construction grant process, including the Step 1 phase.
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Basically, we begin with the recognition of a problem, a pollution problem, in a community which
will lead to the state putting the community on the state project priority list for funding. The
community submits, after notification from the state, an application for a Step 1 grant, and that
application is reviewed by the clearinghouse and ultimately by the state. If there's a 208 desig-
nated planning agency in existence, the 208 agency would also review the Step 1 grant application.
The application first is assigned a priority through the priority system; it is first ranked high
enough for funding through consideration of several criteria. One is the need for preservation
of high quality waters; the severity of the pollution problem, and existing population affected.
The state may set some of its own criteria. The readiness to proceed with an innovative or alter-
native technology project as provided by the 1977 Clean Water Act Amendments could also elevate
an applicant on the priority list.
The Step 1 grant application consists of a plan of study, the clearinghouse and 208 agency com-
ments, and the proposed engineering contracts for doing the work. The need for engineering ser-
vices, if it is over $25,000, has to be advertised. The selection of the engineer is very impor-
tant, for a number of reasons already mentioned. The process is complex and requires considera-
tion of a number of alternatives and it will require more than one discipline to develop the plan.
The plan of study is expected to include a delineation of the planning area, which has been
established by the state under the water quality management planning process. The planning area
may include more than one political jurisdiction, and these need to be identified. The lead
jurisdiction, the one that will do the planning, should also be identified. A description of the
problem must be presented too. What is the problem? Is it septic tank failures, or treatment
plant overload, or whatever. The effluent limitations that the new facility should meet which
will be set forth in its pollution discharge permit [under Section 402 of the Clean Water Act]
should also be included in the plan of study. Finally, the plan of study should include an outline
of planning tasks, the schedule, and the cost estimates, broken down by the costs for each of the
principal tasks.
The Step 1 application then goes for state approval. It must be certified by the state. The
project must be certified by the state as entitled to funding priority. Finally, it's approved
by EPA and the Step 1 grant offer is made. That begins the process of facility plan preparation.
After the plan is completed, it undergoes state review and review by the 208 planning agency, and
finally, EPA receives the plan for review. EPA will conduct a review, including an environmental
review [an appraisal of the proposed project's likely environmental impacts], of the facility plan.
It will issue a so-called negative declaration—and there is a 15-day period allowed for public
review of the negative declaration—of an Environmental Impact Statement, an EIS, is not be
prepared.[The National Environmental Policy Act (NEPA) requires that any major federal action
significantly affecting the environment be accompanied by a statement of its environmental
impact, which must be considered. A "negative declaration" is a statement that the adverse impact
is not significant enough to warrant an EIS.] If the environmental review indicates an EIS is to
be prepared, EPA usually will either prepare the EIS itself or have it prepared under contract.
If an EIS is prepared, there is an opportunity for a public review of the draft EIS, and there is
a public hearing on it. After the final EIS is prepared, there is a waiting period, I believe of
30 days, and then EPA can make the Step 2 grant offer for the engineering design phase.
Now, to go into the facility planning process in greater detail. As I noted, the first step
in facility planning is to identify the effluent limitations that must be met by the treatment
facility Effluent limitations are usually already included in the NPDES (National Pollutants
Discharge Elimination System) permit. They set a treatment goal that the facility must be
designed to meet The second step—basically the-beginning of facility planning~is assess-
ment of the current situation. There's got to be an opportunity here for public involvement.
This is where it should begin, right at the beginning of the planning process. I would point out
that although the present grant regulations and facility planning guidance encourage public
involvement at that step, at this point there is no absolute requirement for it. But there will
bp if reoulations we are preparing go into effect. John Hammond will be talking about that.
Tte grantle will havl JJhave submitted a work plan showing what public involvement in the planning
process will be.
The other elements are, of course, the identification of the planning area, and the environmental
Inventory of Se existing environmental conditions, including existing land useThe existing
wastewater system and the performance of the system should be described in addition to that. The
optSm performance of the system, if it were operated at its best, should be described in the
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facility plan. The importance of this is to establish a base level for evaluation of alterna-
tives. The infiltration/inflow analysis must be done—that's simply an analysis of the extra
water that comes into the system when it rains because the pipes leak. A determination must be
made of what these extra flows are.
A "cost effectiveness analysis" is done at this point, comparing the cost of transport and treat-
ment of these extraneous flows with the cost of rehabilitating the sewer system to remove the
flows. The idea is to pick the cheaper way to solve that problem. Of course, that decision can
affect the design of the wastewater treatment works and cost later on. So it's more easily made
earlier in the process.
The third step is to assess the future situation. For example, land use plans for the area should
be looked at if there are any, because that will be a very important factor in determining where
the interceptor sewer should be provided and where the treatment plant should be located. If the
land use is planned, it could be possible to plan the facility so as to minimize the so-called
"secondary" adverse environmental impacts. That means the non-water-quality impacts of having a
treatment system—mostly those caused by the residential and industrial development, and changes
in land use that the new system can be expected to spur.
You have to locate the facilities where you want growth to occur. Population forecasts have
heretofore been done by the grantee and included in the facility plan. The new cost effectiveness
guidelines, that will be in effect in 60 days, have established new procedures for population
forecasting. The new procedures will reduce the amount of excess capacity, reserve capacity, in
treatment works from the amount that has typically been provided to date. So in the past, when
communities wanted to encourage lots of new growth and development, they could make their popu-
lation forecasts very high and then argue for the necessity of building in a great deal of
reserve treatment capacity. This was a way of getting more federal funding for their community.
What we're calling for now is basically a top down procedure for population projections. We're
asking that projections prepared for the individual planning area be reasonably consistent with
state and national total projections based on U.S. Census Bureau projections. [Dr. Judith
Kunofsky explains this method in her talk on projections.] The wastewater flow forecast which,
in part, is based on the population projections, is also important. It is important in deter-
mining the size of the wastewater treatment works.
The most important step of the facility planning process is to develop and evaluate alternative
treatment plans. Everything else leads up to this. To do this, you first try to identify all
the feasible alternatives. Then you go through a process of preliminary screening with respect
to approximate cost, ability to meet the effluent limitations, comply with the environmental
constraints. And then finally you reduce that number of alternatives down to a manageable number
for more detailed evaluation. Under the new guidelines and regulations, land treatment or waste-
water recycling options are to be considered in detail in each case.
Alternatives that call for minimal action should not be overlooked. As I indicated before, a
facility plan does not have to lead to massive construction. In some cases, the problem may be
such that it involves only minor changes—improvements in the operation and maintenance of
existing septic tanks for example, of operational improvements in the treatment plant. Or per-
haps construction of flow equalization facilities to relieve hydraulic overloading might solve
the problem.
Where the facility planning problem includes more than one political jurisdiction or community,
we expect regional options to be looked at. The term regional planning is often misunderstood.
It's often understood to mean that what you're calling for is interconnection of communities and
provision of waste treatment by a single wastewater treatment plant. That's not the case. We
encourage areawide or regional planning on a broad enough basis to intelligently make decisions
and environmental evaluations. But it doesn't follow that this should lead to an interconnected
large facility. Other options might be: regional sludge management, or a regional operation and
maintenance and management program for the treatment plant, or perhaps joint use of the labora-
tory facilities.
Most of the water conservation options need to be considered as well. I'll talk about those a
little more later on. But most of the treatment alternatives can be fit into these four cate-
gories: treatment and discharge; treatment and reuse; land application; and small nonconventional
systems, including on-site options.
On-site options for the treatment plant need to be looked at. There will be size options as well.
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Should the treatment plant be designed to handle a flow over a ten year period or a twenty year
period, for example? That's one key question that needs to be looked at, and the answer can be
partially obtained through a cost effectiveness analysis. Also in small plants, in particular,
a storage facility at the head of the plant can serve to reduce fluctuation in the hydraulic flows
in the plant and accomplish two purposes. First, it can improve the operation of the plant and,
second, reduce the size of some of the components of the plant as well.
After analyzing each of the most attractive treatment options, the final step of the facility
planning process is to select the plan that makes the most sense. There's an opportunity for
public involvement. We expect the alternatives and tradeoffs to be displayed. We require a dis-
play of the local financial cost for the community and for each household, at least for the
preferred alternative. Sometimes that requirement isn't followed too well. The reasons for
rejection of the alternatives need to be presented at a public meeting, along with an explanation
of the alternatives that were considered.
Now the construction grant regulations require that a public hearing be held at this point-r-tne^
point at which the alternatives have been developed and evaluated but before a final decision has
been reached. In practice, however, the public hearing is often held later, after the alterna-
tives have been selected and the design has been developed, and it tends to be a mostly pro forma
arrangement. As John Hammond[of EPA] will explain, the new process will envision even earlier
public involvement so people can have a say about the alternatives to be considered and how they
are to be evaluated.
In displaying the preferred alternative, the facility plan must include a financial program, as
I noted, and there must be an agreement among the political jurisdictions for implementation of
the plan, as well as provision for adequate staffing and training.
QUESTION- Is it true that a developer who wishes to put in a sub-division, and half the town is
supporting him in the idea of building a sewage treatment plant, can get funding through the
town, that the town can get funding for a sub-division or development?
TIEMENS: No, that's not true. The town cannot get funding for a new collection system for a
new development. The community must be in existence as of October 18, 1972. The habitation must
be there as of that date before the town could receive funding for a collection system for it.
QUESTION: Is the 15% bonus for innovative and alternative systems on the cost of just the inno-
vative part, or on the total cost of the project?
TIEMENS- The ^5% cost effectiveness preference should be applied in most cases to the total cost
of the project The only exception to this rule would be the case where one or more innovative
Processes are included within an otherwise conventional treatment and discharge facility In
this case the calculation base for the 15% preference would be the present worth cost of the con-
IentiSnI?'treatment processes replaced. [The above answer was supplied after EPA's final regula-
tions came out in September 1978 and is based on them.]
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CHOOSING, USING AND ABUSING POPULATION PROJECTIONS: PREDICTING GROWTH
Off. JUDITH KUNOFSKY: The growth policy specialist on the staff of the national Sierra Club,
and the national President of Zero Population Growth. She recently pub-
lished a citizens' manual on how to avoid being fooled by growth projections.
A population projection—compared to, say, a population estimate—is a statement of what the
future population of an area, a given geographic region,would be at some date in the future.
A population estimate generally refers to how many people there are today or in the past.
A census is an exact enumeration—a count of how many people there are. A projection, or a
forecast, says that the Denver region, for example, will in the year 2000, if some current
trends continue, have a certain number of people in it—and you specify what trends you are
assuming.
Now many people think that a population projection is something very mechanical, very straight-
forward—you hire a consultant to produce a model and assumptions, and you get a single popula-
tion projection that, if it's done right, accurately predicts the population. Well, that's
total nonsense. Projections, within a wide range, are fairly arbitrary. They're not arbitrary
in the sense that anyone could sort of guess what the population will be in a few years. But
considering the techniques that many local planners use, you could do almost as good as they
do—and even considering the very elaborate computer modelings that are sometimes done. There
is an enormous range of what a skilled professional using demographically acceptable techniques
could get for the population for the same community for the same year in the future.
For example, there are 3 basic projections of future U.S. population—called Series I, II and
III—produced by the Census Bureau. The difference between Series I, the high one, and
Series III, the low one, is a difference of an average of one child more per family. Series
III assumes 1.7 children per woman, and Series I assumes 2.7 children per woman. They all
assume the same level of immigration to the U.S.. By the year 2050, the difference between
Series I and III is the difference of between231 million and488mill ion. That's a difference
larger than the current population of the U.S., just from the difference in the average family
size of one child per family.
Now most communities are not planning for sewage needs that far in advance. You're only
looking, maybe, 20 years in advance.
The Population Research Unit of the California Department of Finance prepares four projections
for the State of California. For the year 2000, about 20 years from now, they range from
about 24 million up to 32 million. The Bureau of Economic Analysis of the U.S. Department of
Commerce projects about 24 million for the year 2000. The projection the State of California
uses in most of its planning is about 4 million higher than that. So there's an enormous
variation at the state level.
When the regional 208 agency, the Council of Governments (COG), wanted to choose a projection
for Monterey County, California, to use in its water quality program, they had a large number
of available projections—some done by state agencies and others by local agencies, using a
variety of assumptions and methods—to choose from. When they finally picked one, they said,
"Well, looking at all factors, we decided that this one had been done the best way using the
most local involvement and the most up-to-date information, etc." It's important to note that
the one they chose was the one in the middle of all the others. There's a rule—if you want
something adopted, have a few higher and a few lower. If you're looking at water conservation,
for example, and you say, "Here's the current trend in water use—this is 10% more conserva-
tion, this is 50% conservation," and so on. If you want to get to 50% conservation, don't
make that the top estimate on the chart. Have another one that has 75% conservation, another
one with 90% conservation. It's human nature to reject what seems to be the extremes, and it
can be quite effective.
If the only use of projections was to be prepared for what will happen anyway, they would be
still important, of course. But projections do not simply predict the future—they also help
create it. The way projections are used is a key leverage point in affecting the amount and
distribution of growth within a region.
The federal Clean Water Act was primarily designed to solve current water pollution problems,^
problems of inadequate sewage treatment, for example. But you don't just build to meet today's
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problems, because then a facility will be out of date in a few years. There's always a certain
amount of reserve capacity built in. The amount of reserve capacity is determined by a number
of things, including projections of per capita load, industrial use, and maybe some agricultur-
al water. It is also heavily dependent on population projection. If you live in an area whose
population has been increasing very rapidly,this may be the most significant component. The
Denver Regional Council of Governments said in its handbook on projections that, while they do
the projections, the ultimate size of the plant is not determined based on the projections—it
is determined by the cost-effectiveness analysis. Now there's a little sleight of hand,
because the population projection is an integral part of that analysis. Projections are also
used in figuring out what the operation and maintenance costs will be per family, or per house-
hold. You're supposed to say, "Well, in 20 years, the operation and maintenance cost will be a
certain number of dollars per year per household." The higher the population projection for a
given sized plant, the lower the per family cost will seem to be.
The main reason that the projections are important is that treatment plants, as opposed to on-
site systems, induce growth. The problem is not simply that, if you build a plant that's much
too large, you'll have all this wasted excess capacity and high costs. In some cases, of
course, that can be a serious problem. You may have the excess capacity, and the community
could have a terrible time paying back the bond. But it is also true that when you have excess
capacity, it induces or attracts growth. It does that for two reasons. One, the capacity is
available, so that compared with a community down the road or in some other part of the country,
an industry may be more likely to locate in your community. Another reason is that once the
community has obligated itself to pay for the construction of a large plant, it wants to induce
growth to help pay back the cost.
Someone today gave me an article from the Republic, Missouri newspaper. The title is "Sewage
System is Vital to Republic's Growth." The first two paragraphs are: "Whether the fastest
growing town in Green County continues at its present rate depends on an adequate sewage col-
lection and treatment system, city officials said. 'It's vital," Larry Cox, Republic Mayor
said." Well, in a sense, he's right. One of the main things that determines whether your
region will be able to accommodate increased population and industrial growth or whether a
particular community within a larger region will be able to attract growth in housing or indus-
try from another part of the region, is whether you have the capacity for sewage treatment and
possible sewer hookups.
Let me give you a few examples. The nine counties in the San Francisco Bay area had a 1975
population of 4.8 million. Each county has a high or low projection of its own, which when
you add them up for the year 1990, range from a regional total of from 6.4 million to a low of
5 8 million. The regional projections preparedby the Association of Bay Area Governments,
range from a high of 5.6 million to a low of 5.3 million. That is, the high projection for
the region made by the regional association was lower than the sum total of all the low pro-
jections for the counties. This happens all the time. The reason for it is that when you do
a regional projection, you may be tying it in to projection of jobs. While that is just as
arbitrary as projecting populations, it has some relationship to reality. When you re pro-
jecting a community's population within a larger region, essentially, what you're projecting
is how your local housing market will be relative to the community five miles down the road.
And that is hard to know—you can work ten miles away and live here, or you can live ten miles
on the other side of your job. It's really very hard to know what sort of factors to take into
account except the past rates of construction. And so every little community assumes its past
rate of construction will continue. And in order to make sure it continues, it tries to get
sewage treatment money to build a big plant.
There's a real question, and I'll get to it in a moment. What is the responsibility of the
federal government? Should we pay for whatever every little community says it wants? Or
Should the federal government exercise some control over how much federal taxpayers money goes
to the community?
In Denver, the regional projection for the year 2000 is 2.35 million compared to 1.5 million
today There seems to have been a little hanky-panky in preparing that. I was reading one of
the loca publications last night on the plane. The original projection was about 175,000
lower Then there was something about the southwest corner of the city growing faster than
they thought So instead of shifting the projection around from another part of the region to
thlre, they justupped the whole region's projection a little bit. Then the planners went back
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and tried to figure out a combination of family size and migration that would lead to that num-
ber that they got. So that seems a little arbitrary.
The region is zoned, or was zoned a few years ago, for 6.5 million, so that zoning, at least in
the Denver region, appears to have very little influence on where the growth occurs. One of
the things that will determine where growth occurs is where you decide to put in the sewage
treatment facilities.
Another blatant example is in Atlanta. The state of Georgia has projected that if current
trends continue, the Atlanta region will have 2.4 million people by the year 2000. The Atlanta
Regional Commission projects it will have 3.5 million people by the year 2000. That's 46%
greater. And the Atlanta Regional Commission has been quite vocal throughout the country in
opposing the EPA-proposed changes in the way it will use population projections. The reason is
that it wants to plan on the basis of 3.5 million people, not 2.4 million.
Another example is the Forest Service. The Forest Service has been develop-
ing a management plan for the Huston Park Unit of the Medicine Bow National Forest in Wyoming.
The Cheyenne Water Board wanted to reserve part of that land for further development of its
municipal water facilities. The Cheyenne Water Board used a projection of 113,000 for the city
of Cheyenne for the year 2000, compared with 44,000 in 1973. But the Economic Research Unit of
the state had projected the year 2000 population to be 69,000 for the City of Cheyenne compared
to the 113,000 projection of the Water Board—just about half. The issue of population projec-
tion was the key factor in causing the Forest Service to change the land management plan it was
proposing. The debate was over whether the land needed to be developed for water or whether it
should be put in the wilderness study category. As a result of the challenge to Cheyenne's
population projection, instead of the Forest Service allocating 30,000 acres for wilderness
study, they're allocating 37,000 acres for wilderness study. This is a very clear example of
where projections have made a difference. Cheyenne has appealed that decision and we're not
sure which way it will go.
There are a number of examples around the country where projection is used in ways to get
around the debate about what regional or local growth goals are. In cases where environmental-
ists and others have questioned projections, they've gotten a lot of gobbledygook for answers.
You have to be prepared to get that. I'd like to read you a quote from the Texas Water Board,
which has been proposing an enormous boondoggle of a water project that will cost 40 billion
dollars, which makes federal water projects pale in comparison. They used a much higher pro-
jection for the state of Texas than the U.S. Water Resources Council does. In their written
description of the projection process, they wrote the following (and I will read it fast
because you wouldn't understand it even if I read it slowly): "It is emphasized that profes-
sionals with experience in economic and demographic forecasting weighted the alternative pro-
jections produced by several different procedures, in light of detailed time series analyses
of demographic and economic factors, and data, that provided a framework within which subjec-
tive judgments could be combined and utilized as a tool in the projections process. Each
projection was subjected to close scrutiny to ensure that it was in line with the observable
trends and future prospects for an area."
That essentially means they like their projection better. There is nothing more or less to
it. But what has been happening is that many local planners don't know much about projections
themselves and a really vocal citizens group that says, "We don't want to grow this fast;
or "The growth should occur in the central city instead of out in the farmland, or instead of
suburban sprawl," can have an impact. You may be able to get an enormous amount of mileage
without becoming a demographer yourself. In fact, if you become a demographer, it may really
hinder you.
I'd like to tell you what EPA is proposing. It is very significant. It is very controversial.
It is being opposed by a number of county governments, city governments, and states that want
to continue the old process of over-projecting, over-building, and getting as much of that
good federal 75% or 85% money as they can. EPA is proposing to start with the Census Bureau
Series II, the middle level projection, which has some problems with it but at least it s a
national uniform projection. The Bureau of Economic Analysis of the Department of Commerce has
divided that projection into projections for each of the states. Each of the states will then
have responsibility to divide up its projection to the 208 agencies, the regional water quality
102
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planning agencies, to SMSAs in other parts of the state and to counties in other parts of the
state. It could do it any way it likes. It could do it, of course, according to current
trends. It could do it according to its own growth goals to put more population into growth
regions of the state, or to put more population in urban areas if it wanted to develop an urban
focus. Then each 208 agency will divide up its projection for the cities and counties that are
within its jurisdiction and also divide it up to the facility planning areas. It could do it,
again, according to current trends. It could do it consistent with the Clean Air requirements
to focus growth on urban areas to minimize air quality or water quality problems and to protect
agricultural land. Then these final numbers would be the numbers—the only numbers—that EPA
would allow to be used for the federal funding. There is some flexibility, up to 10%, but that
is the basic plan.
The main advantage of this is that it promotes national consistency. Right now if you added up
the projections all over the country, you would get something that was wildly greater than any
projection, any reasonable projection of U.S. population growth, even if you included a 3 child
family and whatever estimate of illegal immigration you wanted. Because communities are over-
projecting and over-building to get that federal money.
It would also mean that states have a role, communities have a role, and they could be encour-
aged to do goal-oriented regional projections that fit in with other environmental and commun-
ity goals, not simply current trends. It's an enormous step ahead, if EPA goes ahead with it.
QUESTION: I'm David Hanke from Missouri. You mentioned the town of Republic, Missouri, in
talking about its vast growth. Just 100 miles from there, we had this catastrophic breakthrough
of the sewage lagoon which poisoned the groundwater. In my analysis, the root problem—in West
Plains where this catastrophic break occurred—is that the city is growing much too fast for
the topography to handle the amount of waste it has. I think that it's important to see that a
sewage system is a factor controlling growth and the question to ask of those who plan sewers
is, do they want growth or don't they? I would like to ask you, do you think that growth
should be accelerated by sewage systems or should we use those sewage systems in planning
things to implement a steady state?
I think it's very important for planners, again, to use the idea of sewage to implement another
philosophy because this growth and consumption kind of orientation is just what's causing
inflation and degradation of our environment. I just wonder where you're coming from on the
issue of sewage funding and growth.
ANSWER: It's difficult to answer that, as you can tell from the Census Bureau's Series II
population projection for the U.S. Even if future population matches the Series III projec-
tion, which is the lowest of the three, our numbers would still continue to increase substan-
tially over the next few decades. So I don't think politically it would be acceptable—it
would never get through—in the Southwest, in Colorado, to plan for no increase in sewage capa-
city, unless you were simultaneously planning to reduce the per capita production of sewage.
I think what we need to do is to look at the political situation, each community one at a time.
The ideal situation is to try to get the most out of what you already have, and to try to
reduce the production of sewage and the consumption of water. Reduce the use of water as much
as possible. But in the interim, before you achieve that, if the only thing you do is stop
increasing the capacity of sewage treatment plants, everything else may continue to grow. If
your land use and population and housing production, industry and agriculture, and everything
else continue to grow, and if the sewage treatment facilities appear to be the only bottleneck
in the system, eventually the pressures will build up so that you'll have to produce a bigger
sewage system. You can't simply use one tool, such as sewage treatment or land use or housing
and expect that alone to control growth. Because it will essentially be the weak link in the
chain.
Now that doesn't mean that you shouldn't try to limit sewage treatment capacity just because
you haven't solved all the other problems first. It may be the best place to start. But it s
important to remember that you have to tackle these other problems too.
So there has to be a more comprehensive approach. I think we're getting more and more suc-
cessful One of the tools, I think, is to point out that it's not a question of accommodating
growth that would have occurred anyway. To a large extent, you are accelerating local growth
and attracting people out of already developed parts of the country. That sort of focus, I
think, works a lot better now with the national debate about revitalizing cities than locally
talking about how we want to stop population growth.
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QUESTION: I'm Paul Robinson from Albuquerque, New Mexico. One of the problems that we face
in Albuquerque is that when you get a population projection accepted, then you get this pre-
planned facilities construction program and seem to be locked into a growth projection for
the next 30 years, which is, of course, not the way things work. It would seem that one way
that could be developed to deal with this problem would be to have facilities which were not
locked into a given growth schedule but could be flexible depending on whether growth trends
actually continued.
KUNOFSKY: I think the shorter you stage your initial construction, the more what you're sug-
gesting, in fact, is true. We attempted to get an amendment to the Clean Water Act that
would require that the facilities be staged for, was it 10 years? And interceptors for 20
years—but that was defeated. So clearly, the thing you want to do is to plan a short enough
time ahead, so that you're not inducing growth. But politically that's very difficult. Be-
cause communities may think that if you plan for 20 years but then condense that growth so it
occurs in 10 years, you'll be ahead.
In the debate on the amendments to the Clean Water Act, Congressman Cleveland of New Hampshire
said, "I don't want this EPA using sewers to control growth. I want EPA to provide sewage
treatment to accommodate normal growth." But "normal growth" is whatever you think it should
be. Ultimately, you have to make some assumption about growth, whether based on current
trends or goals or whatever, to figure out what reserve capacity should be.
The more we can get communities to plan just a little bit ahead, instead of a long way ahead,
the better we are. Unfortunately, the cost-effectiveness analysis may turn out, in some cases,
to indicate that you want to plan for a big system. But the assumptions that go into the popu-
lation projections are the things that determine, to a large extent, how the cost effectiveness
analysis will turn out.
QUESTION: I'm Doug Shakel from Tucson, Arizona. I like what you're saying. I want to make a
suggestion. Population projections have not been around too long. They only started in the
late 1950's and 1960's. They generally were for a 20 or 30 year period. Well, now we're at
the end of the 1970's and 1980's. We had an issue in the Tucson area that had nothing to do
with sewers. One of the more effective arguments that we had against this proposed development
was to go back and find local projections from the 1950's. Tucson today is around 450,000
people; projecting one million to one and a half million people within 30 years. It turns out
that even by 1965, projections were that we're already supposed to have 1.2 million people in
Tucson. If you can find these things—they're difficult just to research and find, but if you
can pull these out of old newspapers and point out that your town is already 60% low or 30% low
from a 20-year projection made by the biggest bank in the state, with many of the same people
making the same projections—it can be a very telling argument. I wonder if you've researched
how often past projections are overshot.
KUNOFSKY: That's an excellent idea. One of the things that we're covering in the workshops
and I'm covering in a handbook that I'm writing for citizens on projections, is what questions
to ask. And the most effective tool is to find other projections for your area that were pro-
duced by a business, a university school of research, other governmental agencies. You don't
have to know anything about the projection. You just say, "Well, why is this one different
from the other one? Why is yours any better?" Even if theirs is better, they often can't
explain why it's better.
Projections were started for the U.S., as a whole in the 1920's or 1930's and they were dis-
mally wrong. They were started in the depression years and they projected the U.S. population
would never reach 200 million and would start decreasing in the 1950's. The baby boom proved
them wrong.
For the local level, projections have been wrong too. You may have to dig for the information.
One of the most effective tools is to say, "This projection is different from this other one;"
or "That one was made two years ago and trends have changed;" or, obviously, "Why do you want
us to increase our percentage of the nation's population?"
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BUILDING COALITIONS FOR BETTER SEWAGE TREATMENT
SKIP ROBERTS: Trade union activist. Former Amer-iaan Federation of State, County, and
Municipal Employees (AFSCME). Union area director of the Rocky Mountain
Region. Special assistant to the President, Colorado AFL-CIO. Specialist
in environmental, trade union and public policy issues. Denver, Colorado.
Let's briefly look at institutional obstacles to change on the sewage treatment issue from the
vantage point of organized labor. When we look at institutional obstacles to change, all too
frequently, the organized labor of that particular field or that industry, becomes a captive of
that industry and gets locked into: positions that sometimes they shouldn't be in. And it is not
helped by the fact that generally, I would say, most people in this room, could probably not even
come up with the name of the president of the central labor body in their area, much less their
home phone number. On the other hand, if they were already friends with that person and have
dealt with them on a regular basis, when a problem comes up they can go to that person.
I come out of the American Federation of State, County, and Municipal Employees. We probably
have the largest single collection of conventional wastewater treatment plant employees across
the country.
There are several things I want to tell you about working in a conventional wastewater treatment
plant. First, it's an absolutely terrible job. It is one of the more hazardous jobs possible
from both the job safety and worker health perspective. Consider a few examples of workplace
hazards: methane gas explosions, totally inadequate plant design in terms of safety; most plants
seem to have been built with a complete lack of concern about worker safety—they don't even have
guardrails on tank walks and such. There are long-term occupational hazards. People in the
community get upset when maybe 1% of the odors escape from a treatment plant. But think of
What happens when you're breathing all sorts of who-knows-what kinds of carcinogenic materials
on the job, day-in and day-out, over a long term period.
Then you have the fact that these jobs aren't held in esteem; the kids don't tell the other kids,
"My day works for a sewer company." On the issue of wages, if you look at least right now in the
West, an operator of an advanced wastewater treatment plant with credentials can really get any
salary one wants. Skilled people are really in short demand; no one is rushing into this field,
even though they really can because it is basically a sellers' market.
Yesterday, there was a lot of discussion on building coalitions, alliances, and spreading the
word. This is especially applicable if you look at alternative treatment systems. There are a
number of things that can be used to sell labor on the issue, all of which may result in labor not
really going out to push the issue, but they also may not oppose it. And that is very important
because they are, in effect, pulling away from what we could call the public works-consulting
engineeer-industrial complex. So you can peel off or neutralize a portion of their political
support.
While there is no such thing as a unified labor movement, there are all sorts of different
individual labor parts. In fact, organized labor is a contradition in terms. I speak for the
public sector trade unions; that is where my background is.
While no one has ever done a study comparing the different technologies' impact on job safety,
and the number of jobs involved, there are several things to keep in mind about alternative treat-
ment systems Let's assume that some of the building trades are going to be upset because they re
not going to'use as much concrete as they might in conventional systems Yet as you saw in some
of the pictures used by speakers describing the various technologies, a lot of drainage pipes
are used under land application, which means jobs for the laborers union and the pipefitters
union-so there are going to be jobs there. Instead of going vertically on the job scale, its
more of a horizontal slant because it seems that there are more operation and maintenance jobs in
™nd applicat on systems. These are lower level jobs which for the unions and their institutional
llf-iSerests, means more members. Then you're going to probably have just as many Professional
jobs with alternative treatment systems, including soil professionals and the like work ng for
the county or the sewage district. In terms of the public employees union's interest, it's always
nice when you're going to the bargaining table to have a revenue-producing sewage system for the
city on your side! instead of a conventional system that requires a permanent part of the mumc -
pality's budget to be locked in to pay for the ongoing costs of the plant. It gives you a little
105
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more to play with when you're at the bargaining table.
When you're building coalitions, remember that none of us in this room can do it by ourselves.
You've got to sit down and analyze every possible self-interest involved. And there is usually
plenty to go around, and that should be included in the effort, even if a group is not going to
actively campaign. Create a broad-based letterhead because that is going to give you more credi-
bility and more political legitimacy. It starts attracting politicians, who go where they think
there's a crowd. So you want to always appear broader than you are. Take a look at every angle:
jobs, the environment, the farms, citizens groups, taxpayers, Common Cause, the League of Women
Voters, other watchdog groups, and the Chamber of Commerce. It's a great way to sell it to the
Chamber of Commerce by saying, "We want something for the environment and it's going to save us
money."
I encourage you to come to the citizen action and organizing workshop this morning. We're going
to have two of them because the idea of this conference as we said, is not to give you Ph.D.'s in
sewage but rather for you to know the kinds of questions to ask when you get back home, the types
of excellent resource people that are out there, and finally, how to spread the knowledge you've
got and put it to effective use. Thank you.
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SPEAKERS (at the Washington, D.C. and Denver conferences)
JACK ABNEY
Parrot, Ely, & Hunt
620 Euclid Avenue
Lexington, Kentucky 40502
(606)266-2144
LARRY CAHILL
Booz-Allen & Hamilton
4330 East-West Highway
Bethesda, Maryland 20014
(202)951-2573
KEITH DEARTH
Chief, Assistance and Review
Facility Requirements (WH595)
Office of Water Programs Operations
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D.C. 20460
(202)426-9404
DAVID DEL PORTO
ECOS, Inc.
21 Emrie Road
Boston, Massachusetts 02134
(617)782-0002
ALAN L. FARKAS
Booz-Allen & Hamilton
4330 East-West Highway
Bethesda, Maryland 20014
(202)951-2573
DR. SAM F06EL
J.B.F. Scientific Corporation
2 Jewel Drive
Wilmington, Massachusetts 01887
(617)657-4170
RON FRANK
C.W. Communications
797 Washington Street
Newton, Massachusetts 02160
(617)965-5800 or 1-800-225-3080
STUART FUCHS
Goldman, Sachs & Co.
55 Broad Street
New York, New York 10004
(212)676-2126
MICHAEL 6RAVITZ
239 Commonwealth Avenue #63
Boston, Massachusetts 02116
(617)236-4745
Kennedy School of Government
Harvard University
FRANK J. GRAY
P.O. box 711
Lubbock, Texas
(806)744-8056
79408
DR. JOSEPH HARRINGTON
Department of Applied Science
Pierce Hall, Room 113
Harvard University
Cambridge, Massachusetts 02138
(617)495-2024
JOHN HAMMOND
Facility Requirements
Municipal Construction Division
U.S. Environmental Protection Agency
401 M SZreet, S.W.
Washington, D.C. 20460
(202)755-8054
THOMAS C. JORLING
Assistant Administrator
Office of Water and Hazardous
Materials (WH-556)
U.S. Environmental Protection Agency
401 M STreet S.W.
Washington, D.C. 20460
(202)755-2800
WILLIAM KERFOOT
K-V Associates
49 Ranson Road
Falmouth, Massachusetts 02540
(617)540-0561
DR. JUDITH KUNOFSKY
The Sierra Club
530 Bush Street
San Francisco, California 94108
(415)981-8634
CARL LINDSTROM
Clivus Multrum
14 A Eliot Street
Cambridge, Massachusetts 02138
(617)491-5820
RICHARD P. LUNDAHL
Cith of Northglenn
10701 Melody Drive, Suite 313
Northglenn, Colorado 80234
(303)451-8326
GLENN MACNARY
Ridge Road
Box 815
Falmouth, Massachusetts 02556
(617)563-3330
JOHN MARSH
Engineering Enterprises,
Inc.
1225 West Main, Suite 215
Norman, Oklahoma 73069
(405)329-8300
ALAN MERSON
Regional Administrator
U.S. Environmental
Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
(303)837-3895
DONN MITCHELL
Consultant
Pennypack Watershed
Association
2208 Lombard Street
Philadelphia, Pennsylvania
19146
(215)732-8498
JOHN MUSICK
Musick, Williamson,
Schwartz, Leavenworth &
Cope
P.O. Box 4579
Boulder, Colorado 80306
(303)499-3990
(303)925-6617
RALPH NADER
Center for Study of
Responsive Law
P.O. Box 19367
Washington, D.C. 20036
(202)833-3400
PATRICIA NESBITT
Environmental Consultant
Route 2, Box 374
Strasburg, Virginia 22657
703-465-8742
SKIP ROBERTS
Colorado AFL-CIO
3303 West 29th Avenue
Denver, Colorado 80211
(303)433-9966
ABBY ROCKEFELLER
Clivus Multrum
14 A Eliot Street
Cambridge, Massachusetts
02138
(617)491-5820
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DR. JOHN SHEAFFER
Sheaffer & Roland, Inc.
20 N. Wacker Drive
Chicago, Illinois 60606
(312)236-9106
LARRY SILVERMAN
Clean Water Fund
1341 G Street, N.W. Suite 200A
Washington, D.C. 20005
(202)638-3013
DR. DAVID STENSEL
Envirotech, Inc.
EIMCO-PMD
P.O. Box 300
Salt Lake City, Utah 84110
(801)521-2000
TERRY STUART
Stuart-Nichols
1726 Tampa
Denver, Colorado 80202
(303)825-0586
Colorado Open Space Council
MYRON TIEMENS
Facility Requirements
Municipal Construction Division
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
(202)426-9404
HELGA WAGNER
512 Moreland Road
Huntingdon Valley, Pennsylvania
U.S. REPRESENTATIVE TIM WIRTH
District Office
9485 West Col fax Avenuie
Lakewook, Colorado 80218
(303)2340-5200
GORDON WOOD
01 in Corporation
1730 K Street N.W.
Washington, D.C. 20006
(202)331-7400
DAVID R. ZWICK
Clean Water Action Project
1341 G Street, N.W.
Washington, D.C. 20005
(202)638-1196
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PARTICIPANTS (at the Washington, D.C. and Denver conferences)
CLARK AGUILERA
U.S. EPA
1860 Lincoln
Denver, CO 80203
(303) 837-2879
Water Division
RUTH ALLEN
2398 Cloud Croft Sq.
Reston, VA 22091
(703) 860-3942
No. Va. Conserva-
tion Council
SCOTT ALLEN
10401 Grosvenor PI. #806
Rockville, MD 20852
(301) 493-9338
Sierra Club
MARK ALPERT
Research Cottrell
1800 K St. NW #720
Washington, D.C. 20006
(202) 466-5207
Engineer
DR. DOUG ALVORD
300 N. Willson
Bozeman, MT 59715
(406) 587-2455
Montana Trout Unlimited
MIKE ANDREWS
Indiana Public Interest
Research Group (INPIRG)
406 N. Fess
Bloomington, IN 47401
(812) 339-3447
Community Action Program
ALAN APT
1912 Corriedale Court
Ft. Collins, CO 80521
(303) 221-3316
Sierra Club Water
Quality Commission
CANDACE ASHMUN
Box 157
Mendham, NJ 07945
(201) 539-7547
Ran tan Watershed Assn.
TOM BARLOW
Natural Resources Defense
Council
917 - 15th St, N.W.
Washington, D.C. 20005
(202) 737-5000
MICKI BARNES
Colorado Dept. of Health
4210 E. llth Ave.
Denver, CO 80220
(303) 320-8333
Office of the Secretary
DOROTHY BARNOUW
3148 0 St. N.W.
Washington, D.C. 20007
(202) 333-0942
Delaware River Basin Tri-
State; LWV of Metrop. NYC
EILEEN BARTHELMY
American League of Anglers
810 - 18th St. N.W. #308
(202) 347-7475
DOROTHY BATCHELDER
R.D. 1
New Hope, PA 18938
(215) 794-8010
Inter-League Council, LWV
BRUCE BAUMGARTNER
308 - 3rd
Crested Butte, CO 81224
(303) 349-5374
Town Manager
STANLEY BENDER
City of Northglenn
10701 Melody Dr. Suite 309
Northglenn, CO 80234
CHARLES BENJAMIN
Hadden Industries
RD 1, Chestnut Tree Road
Honey Brook, PA 19344
(215) 942-3194
Industrial Hygienist
HARLIN BENKER
Julesburg Chamber of Commerce
Route 1, Box 97
Julesburg, CO 80737
(303) 474-3344
208 Planning Council
SAM BERMAN
U.S. EPA
1860 Lincoln St.
Denver, CO 80203
(303) 837-3961
Grants Officer
109
SCOTT BERNSTEIN
Center for Neighborhood
Technology
570 West Randolph
Chicago, IL 60606
(312) 454-0126
GENE BJERKE
Box 1832
Williamsburg, VA 23185
(804) 229-1000 ex. 2288
Chesapeake Bay Foundation,
York Chapter
THOMAS E. BOND
TLB Corporation
160 Willard Ave.
Newington, CT 06111
(203) 233-5109
KEITH BROOKS
4500 Chestnut St.
Bethesda, MD 20014
(301) 223-6800 ex. 387
Interstate Commission on
the Potomac River Basin;
working withmetro COG
GREG BROWN
Research & Development Office
U.S. EPA
Cincinnati, OH
(513) 684-7931
MICHAEL BROWN
Box 88
Idledale, CO 80453
(303) 697-4375
KENT BUSHNELL
Slippery Rock State College
Dept. of Geology
Slippery Rock, PA 16057
(412) 794-7303
Slippery Rock Sewer Comm.
JAY W. BUTTS
316 W. 22nd Ave.
Olympia, WA 98501
(206) 352-8059
Nisqually Delta Assn.
ANN CARDINAL
Southwestern Pa. Regional
Planning Commission
564 Forbes Ave.
Pittsburgh, PA 15219
(412) 655-9559
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FRED CARUSO
1111 S. Colorado Blvd. #401
Denver, CO 80222
(303) 759-9805
Colorado Water Congress
JIM CASSELS
125 Northway
Greenbelt, MD 20770
(301) 474-4046
Rep. Greenbelt on Land Use
Citizen Advis. for Metro.
COG
JAMES W. CLARKE
402 Burgundy Dr.
Rockville, MD 20850
(301) 840-4615
Potomac Chap. Chairman,
Sierra Club
JAMES COFFMAN
ELSTON COOK
Lubbock Christian Congress
5601 - 19th St.
Lubbock, TX 79407
(806) 792-3221
JOHN CORBETT
Northcoast Environmental Ctr.
640 Tenth St.
Arcata, CA 95521
(707) 445-3275
Calif. Water Quality
Control Bd.
SARAH L. CORSON
2527 N. Vermont St.
Arlington, VA 22207
(703) 243-2818
Working with Maine community
on proposed sewer hookups
AL COVIELLO
Thetford Corporation
P.O. Box 1285
Ann Arbor, MI 48106
(313) 769-6000
JIM COX
West Plains Daily Quill Newspaper
West Plains, MO
(417) 256-4111
JOSEPH D. DVORAK
Center for Rural Affairs
P.O. Box 405
Wai thill, NE 68067
(402) 846-5428
LEWIS EMMERICH
Environtech, Inc.
P.O. Box 300
Salt Lake City, UT 84110
(801) 521-2000
JERRY ENOERS
2720 Urbandale Lane
Wayzata, MN 55391
(612) 473-4171
League of Women Voters
HELEN ENGLE
4011 Alameda Ave.
Tacoma, WA 98466
(206) 564-3112
Pres., Wash. Envir. Council;
League of Women Voters
TOM EVANS
1402 Pump House Dr.
Richmond, VA 23221
(804) 231-9011 ex. 403
Bass Anglers Sportsman Soc-
iety; Va. Bass Anglers Sports-
man Society State Federation
CAJ 0. FALCKE
c/o David M. Dornbusch & Co.
1736 Stockton St.
San Francisco, CA 94133
(415) 981-3545
ILIA J. FEHRER
110 W. Federal St.
Snow Hill, MD 21863
(301) 632-2640
Worcester Env. Trust;
Eastern Shore Alliance Poto-
mac Chap. Sirra Club
ROBERTA FELDERMAN
Route 1, Box 44
Bruce, SD
(605) 693-4180
South Dakota Resources Coali-
tion
ANN FENN
Office of Technology Assessment
Oceans Program
Congress of the United States
Washington, D.C. 20510
(202) 224-7038 or 224-5694
RICHARD L. FETTER
4800 Wadsworth, #204
Wheat Ridge, CO 80033
(303) 421-8630
Colorado Municipal League
110
MARGARET FINDLAY
Clivus Multrum, Inc.
14A Eliot St.
Cambridge, MA 02138
(617) 491-5820
JOHN FLOWERS
Wash. Surburban Sanitary
Commission
4017 Hamilton St.
Hyattsville, MD 20781
(301) 277-4367
WILLIE FONTENOT
Louisiana Oept. of Justice
The Capitol
Baton Rouge, LA 70804
(504) 389-6776
JIM FOWLER
2555 W. 37th
Denver, CO 80211
(303) 477-6291
Sierra Club; Advis. Comm.
of the Denver Metro
Sewage Dist. #1
JOHN H. GARGANUS, JR.
P.O. Box 97
Jackson, NC 27845
(919) 534-5161
Exec. Director, North-
ampton County Economic
Dev. Commission
CAROL GATES
6405 Kirby Rd.
Bethesda, MD 22034
(301) 229-3537
C.M. GILMOUR
1335 - 2nd Ave.
Salt Lake City, UT 84103
(801) 359-8036
Water Rights Attorney
CHRIS GODDARD
Dept. of Interior
Legis. Program Coordinator
Heritage Conservation Re-
creation Service
1951 Constitution Ave. NW
Room 238
Washington, DC 20240
(202) 343-5776
NEAL GOLDBERG
Clean Water Action Project
1341 G St., NW #200
Washington, DC 20005
(202) 638-3013
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JEROME GOLDSTEIN
Compost Science/Land
Utilization
Box 351 - 18 S. 7th St.
Emmaus, PA 18049
(215) 967-4010
Editor & Publisher
JIM GRACIE
3652 Clifmar Road
Baltimore, MD 21207
(301) 355-0770
Trout Unlimited
HARRY GRANT
3038 So. Nooksack Valley Hwy.
Clipper, WA 98244
(206) 671-1882
Farmer
DAVID HAENKE
Edge City Farm
Box 67-2
Caul field, MO 65626
Co-founder of Ozark Area
Community Congress
CHRISTY HAKIM
Sierra Club
530 Bush St.
San Francisco, CA 94108
(415) 981-8634
RONALD HALLEY JR.
Hydro-Triad Ltd.
7500 W. Mississippi Ave.
Lakewood, CO 80226
(303) 934-2477
RICHARD HAMILTON
Park County Planner
Box 517
Fairplay, CO 80440
(303) 836-2451
Gov. Committee on 208
WALTER HANG
N.Y. Public Interest Research
Group (NYPIRG)
5 Beekman St.
New York, NY 10038
(212) 349-6460 or 799-9113
ANN HANSEN
3473 N. 39th St.
Boise, ID 83703
(208) 344-1478
League of Women Voters:
Nat'l Resources Chmn.
PATRICK HANSON
Box 968
Santa Fe, W 87503
(505) 827-5271 ext. 327
N.M. Water & Wastewater
Utility Operator Training
Program
S. HANSON
American Worm Growers Assn.
PETE HARTLEY
Colorado School of Mines
American Studies Assoc.
Golden, CO
(303) 279-0300
TED HILLMER
Rt. 2, Box 269-P
Conifer, CO 80433
(303) 839-3961
U.S. EPA Reg. VIII
(Grants 201)
HAROLD HODGES
City of Northglenn
10701 Melody Dr. Suite 309
Northglenn, CO 80234
RACHELLE HOLLANDER
Science for Citizens Program
National Science Foundation
1800 GjSt., NW
Washington, D.C. 20550
(202) 655-4000
MARY HOOPER
1730 M St., N.W.
Washington, DC 20036
(202) 659-2685
League of Women Voters
Education Fund
JOHN HORST
Henningson, Durham & Richardson
310 Capitol Life Center
Denver, CO 80203
(303) 861-1300
ELIZABETH HORVATH
7025 Benjamin St.
McLean, VA 22101
(202) 224-9044
No. Va. Conservation Council
TREVOR C. HUGHES
Utah State University, UMC 82
Logan, UT 84321
(801) 752-4100 ex. 7961
Hot Water Research Lab.
Ill
HAROLD HUMPHREY
5 Mudnock Rd.
Salisbury, MA 01950
(617) 462-8141
Salisbury Sewer Commission
HENRY JAKED
401 M St., SW
Washington, D.C. 20460
(202) 426-8973
Municipal Construction
Div. Office of Water Progs.
U.S. EPA
JOEL JACKNOW
8110 Timber Valley Court
Dunn Loring, VA 22027
(703) 698-8702
Consultant to Sludge Furnace
Technology Sub-Comm. on
Water; Wastewater Equipment
Manufac. Assn.
KEITH JOHNSON
Merser County Courthouse
Stanton, NO 58571
(701) 745-3695
KIT JOHNSON
3520 Connecticut Ave., NW
Washington, DC
BILL JOHNSTON
R.R. 1, Box 488
Huntingtown, MD 20639
(301) 872-0123
ELMER E. JONES, JR.
U.S. Dept. of Agriculture
(USDA-SEA-FR) Building 228 .
Beltsville Agric. Research
Center-East
Belts ville, MD 20705
(301) 344-2012
PAT JORGENSON
Longmont Daily Times Call
Box 299
Longmont, CO 80501
(303) 444-3636
SELMA KALLIS
3502 Legation St., NW
Washington, DC 20015
(202) 363-0079
League of Women Voters of
Wash. D.C.; Potomac Basin
Inter-League Comm.
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BETTY J. KAMPSCHROER
3963 Brookridge Dr.
Mechanicsburg, PA 17Q55
(717) 732-2157
Public Participation Coord.
of 208 Prog, for State of PA
SALLY KANCHUGER
10908 Picasso Lane
Potomac, MD 20034
(301) 299-8030
ROSE KAPOLCZYNSKI
Wilderness Workshop
Colorado Open Space Council
1325 Delaware Ave.
Denver, CO 80204
(303) 573-7870
DAVID KEATING
325 Pennsylvania Ave., SE
Washington, DC 20003
(202) 546-2050
National Taxpayers Union
CHARLES KNELL
Midwest Electric Consumers Assn.
9338 W. Iowa Ave.
Lakewood, CO 80226
(303) 234-0541
JOHN KOFFMAN
P.O. Box 237
Chester, MT 59552
(406) 759-5635
Public Works Director
AL KRAUSE
U.S. EPA
1221 Crystal Lake Rd.
Lake in the Hills, IL 60102
(312) 353-2159
DAVID KRAUSER
116 Brent Ave.
Arnold, MD 21012
(301) 224-1471
Arundel Cty. Planning &
Zoning Division
MARGARET LADNER
727 Massachusetts Ave., NE
Washington, DC 20002
(202) 547-2955
DR. ANTHONY LASKA
814 B Royal St.
New Orleans, LA 70116
(504) 586-4751
Environmental Director
New Orleans Planning Goran.
STUART LEIDERMAN
New Life Farm
Drury, MO 65638
(417) 261-2553
STEVE LENCHNER
724 Dupont Circle Bldg.
Washington, D.C. 20036
(202) 223-9138
Environmental Action
Foundation
DOROTHY LETTS
Life of the Land
404 Piikoi St. #209
Honolulu, HI 96814
(808) 521-1300
PHILLIP LOAR
6826 Old Chesterbrook Rd.
McLean, VA 22101
ARTHUR LONG
1609 Northcliff Ave.
Norman, OK 73071
(405) 321-0224
City Engineering Dept.
KATHY LOUGH
1312 S. Taylor St., Apt. 22
Arlington, VA 22204
(703) 920-6991
LINDA MANDEL
Box 1031
Telluride, CO 81435
(303) 728-3559
on Planning Board
PETER MANIKAS
Better Government Assn.
230 N. Michigan Ave., #1710
Chicago, IL 60601
(312) 641-1181
ROBERT 0. MANKES
Purecycle Corp.
P.O. Box 671
Boulder, CO 80301
(303) 449-6530
RASHID MARKDOON
Water Resources Specialist
Native American Natural
Resources Dev. Federation
910 - 15th St., Suite 840
Denver, CO 80202
(303) 534-4484
112
HANUMANTHAIYA MARUR
7244 North Genesee Rd.
Genesee, MI 48437
(313) 640-2000
Engineer, Township of Genesee
YOLANDA MAYNE
113 Marshall
Yellow Spring, OH 45387
(513) 767-7858
League of Women Voters of OH;
Ohio Inst. for Appropriate
Technology; Yellow Springs
Envir. Control Commission;
Miami Valley Reg. Plan. Comm.
LARRY MCBENNETT
U.S. EPA
Facility Requirements Branch
401 M St., SW
Washington, DC 20460
(202) 426-9404
R. MIKE MCCLAIN
Highland Hall Annex
Court House
Hollidaysburg, PA 16648
(814) 695-5541 ext. 61
Blair Cty. Planning Comm.
ROGER MCCLURE
3847 Beecher St., N.W.
Washington, DC 20007
(202) 785-0614
Citizens Advisory Committee
for Water Resources Planning
Board, D.C. COG
TIM MCCLURE
Box 73
Frisco, CO 80443
(303) 453-1129
Summit Recycling Project
BETHLYNN MCCLOSKEY
4113 Bissonet Dr.
Metairie, LA 70003
(504) 887-2554
Board of LA Nature Center;
Louisiana Coastal Comm.
ROBERT MCGREGOR
Sheaffer and Roland
1660 S. Albion
Denver, CO 80220
(303) 758-7653
JACK MCKEE
2029 K St., NW
Washington, DC 20006
(202) 331-7020
Nat'1 Society of Prof. Engin.;
Adv. Comm. for Sewage Treat-
ment Conferences
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JIM MCNELLY
P.O. Box 418
Boulder, CO 80306
(303) 666-8395
Planet Earthworms
BOB MCPHEE
1240 Sherman
Denver, CO
(303) 839-3451
Colo. Land Use Commission
BUD MEKELBURG
Route 1
Yuma, CO
(303) 848-5605 or 774-7475
National Association of Soil
and Conservation Districts
JIM MILES
Lower Arkansas Valley Council of
Governments (COG)
Bent County Courthouse
Las Animas, CO 81054
(303) 456-0692
MICHAEL MILGROM
Minnesota Public Interest
Research Group (MNPIRG)
3036 University Ave.
Minneapolis, MN 55414
(612) 376-7554
CHARLES MILLER
Environtech, Inc.
P.O. Box 300
Salt Lake City, UT 84110
(801) 521-20-0
MARTHA MOHLER
5609 Grove St.
Chevy Chase, MD 20015
(301) 656-4986
Montgomery Cty. Civic Fed.
JOHN H. MONROE
104 - 8th St., NE
Washington, DC
(202) 547-4365
AUDREY MOORE
7670 Little River Turnpike
Annandale, VA 22003
(703) 256-4983
Fairfax Cty. Board of Suprvs.
Annandale Dist.; Advis. Comm.
for Sewage Treatment Confs.
WILLIAM MOORE
1819 H St., NW
Washington, D.C. 20006
(202) 293-1455
Int'l Community Dev. Associates
ALAN MORRIS
325 N. Washington
P.O. Box 830
Liberal, KS 67901
(316) 624-0101
City Manager
GARY MUNDT
Office of Cong. Pat Schroeder
1767 High St., Denver CO 80218
(303) 837-2354
1507 Longworth
House Office Bldg.
Washington, DC 20515
(202) 225-4431
KEVIN MURPHY
Kentucky Rivers Coalition
P.O. Box 1306
Lexington, KY 40501
(606) 233-7227
TERRY MURPHY
2018 S. Emerson
Denver, CO 80210
(303) 733-3425
MARY MUSHINSKY
Conn. Citizen Action
Group (CCAG)
P.O. Box G
Hartford, CT 06106
(203) 527-7191
WILLIAM B. NAGEL
7172 S. Grant St.
Littleton, CO 80122
(303) 794-6292
BERNARD NAGELVOORT
Merchant Marine & Fisheries Comm.
1337 Longworth Bldg.
Washington, DC 20515
PATRICIA B. PELKOFER
252 So. Winebiddle St.
Pittsburgh, PA 15224
(412) 441-0171
Group Against Smog &
Pollution (GASP); Rep. on
208 Water Quality Manage-
ment Planning
PATSY PEPPER
P.O. Box 68
Tallahassee, FL 32301
(904) 878-4152
Clean Water, Inc.
KIM PERUSIK
Western Colorado Rural
Communities Institute
Western State College
Gunnison, CO 81230
(303) 943-0120
GREG PHILLIPS
2018 S. Emerson
Denver, CO 80210
(303) 733-3425
KAY PILCHER
724 Dupont Circle Bldg.
Washington, DC 20036
(202) 223-9138
Environ. Action Foundation
SUZANNE POGELL
6318 Washington
St. Louis, MO 63130
(314) 534-9350
Water Quality Director;
Committee for Environmental
Into.; League of Women Vot.
RICK POWELL
Office of the Peoples' Counsel
917 - 15th St.
Envir. Coali.wa!hingJ*n,JC 20005
Adv. Comm. for Sewage Treatment*
Conferences
JANET
1943 Rosemary Hills Dr.,
Silver Spring, MD 20910
CONNIE WEISS O'MARA
1730 M St., N.W.
Washington, DC 20003
(202) 659-2685
DON PATTERSON
220 C St., S.E. #309
Washington, DC 20003
(202) 544-5750
American Agri. Movement
113
FRANK PRATKA
2200 - 19th St., NW Apt. 408
Washington, DC 20009
(202) 234-2775
W. WILLIAN PUUSTINEN
3560 Hayden Bridge Rd.
Springfield, OR 97477
(503) 947-2220
Columbia River Fishermen's
Protective Union
RAY QUADA
301 East Main St.
Lowell, MI 49331
(616) 897-8457
City Manager
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ROBERT E. RASCHKE
National Assn. of Soil & Conser-
vation Districts; Western Off.
9150 West Jewel
Lakewood, CO 80226
(303) 988-1810 or 795-0915
GAIL RAYWID
Environmental Policy Institute
317 Pennsylvania Ave., S.E.
Washington, DC 20003
(202) 544-8200
MARY REARDON
National Association of Counties
1735 New York Ave., N.W.
Washington, DC 20003
(202) 785-9577
Director, Clean Water Project
JIM RESICK
214 S. 4th St.
Douglas, WY 82633
(307) 358-5558
Powder River Basin Resource
Council
PAUL ROBINSON
S.W. Research & Info Center
P.O. Box 4524
Albuquerque, NM 87106
(505) 242-4766
MARISSA ROCHE
Conservation Foundation
1717 Massachusetts Ave., NW
Washington, DC 20036
(202) 797-4368
RUBEN RODRIGUEZ
Clear Creek Valley Water &
Sanitation District
5420 Harlan St.
Arvada, CO 80003
(303) 424-4194
SID ROSENTHAL
Fund for Animals
P.O. Box 10676
Jefferson, LA 70181
(504) 834-8779
TERRI SALTIEL
7769 Deep Wood Trail
Tallahassee, FL 32301
(904) 878-4466
Clean Water, Inc.
JOE SALVO
NYPIRG
1004 East Adams St.
Syracuse, NY 13210
(315) 476-8381
RICHARD SANDERSON
714 Birch
Grafton, ND
(701) 352-0400
Graf ton Planning Council
Susan Sarason
1341 6 St., N.W. #200
Washington, DC 20005
(202) 638-1196
Clean Water Action Project
BILL SCHROER
Colorado Open Space Council
1325 Delaware Ave.
Denver, CO
BOB SCHULZ
New Life Farm
Drury, MO 65638
(417) 261-2553
DOUG SHAKEL
Sierra Club
P.O. Box 41166
Tucson, AZ 85717
(602) 623-7132
JAMES W. SHEARARD, JR.
Technological Resources, Inc.
P.O. Box 391
Camden, NJ 08101
(609) 964-5603
ELEANOR SHIMEALL
7028 Leesburg PI.
Stockton, CA 95207
(415) 986-1532
Water Director, League of
Women Voters, Calif.
ARLENE SHULMAN
National Assoc. of Counties
1735 New York Ave., N.W.
Washington, DC 20006
Assoc. Director, Clean Water
Project; Advis. Comm. for Sew-
age Treatment Conferences
TED SHULTZ
Box 595
Livingston Manor, NY 12758
(914) 439-5339
Theodore Gordon Flyfishers
JERRY SILVER
2817 Northampton St., N.W.
Washington, DC 20015
(202) 244-9194
114
DUANE SILVERSTEIN
National Indian Health Bd.
Brooks Towers, Room 4-E
1020 - 15th St.
Denver, CO 80202
(303) 534-5482
DON SLAVIN
4450 Salzbury
Wheatridge, CO 80033
(202) 423-1737
RALPH SMALLEY
Office of Technology Assess.
Oceans Program
Congress of the United States
Washington, DC 20510
(202) 224-7038 or 224-5694
PAT SMITH
1082 Evanston
Aurora, CO
(303) 364-5102
Farmer
ROD SMITH
Patton House Engineering
P.O. Box 46 - 100 S. Main
Bridgewater, VA 22812
(703) 828-2616
JIM SMULLEN
Denver Reg. Council of Gov.
2480 W. 26th Ave., I200B
Denver, CO 80211
(303) 455-1000
DENNIS SOHOCKI
Water Division
U.S. EPA
1860 Lincoln St.
Denver, CO 80295
(303) 837-4831
JAN SOKOL
Oregon PIRG
918 S.W. Yamhill
Pythian Building
Portland, OR 97205
(503) 222-9641
ROBERT SOLOMON
Environtech Corp.
9051 Baltimore Nat'l Pike
Building 4, Office E
Elliott City, MD 21043
(301) 465-7020
MARTIN SORENSON
10703 Moore Way
Westminster, CO 80020
(303) 279-6565
Colo. Sierra Club
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MICHELE SPAIN
110 W. Federal St.
Snow Hill, MD 21863
(301) 632-2640
FREDERICK E. STEARNS
P.O. Box 247
Poolesville, MD 20837
(301) 972-8481
Exec. Director, Western
Upper Montgomery County
Citizens Assocation
GARY STEINBERG
54 Elm Ave., #1
Takoma Park, MD 20012
(301) 270-0676
MARILYN STOKES
879 S. Gaylord
Denver, CO 80209
(303) 744-7455
Colo. Open Space Council
JAMES S. STONE
7131 W. 84th Way No. 1604
Arvada, CO 80003
(303) 424-0121
Stone Envir. Engineering
Services, Inc.
MICHAEL STRIEBY
P.O. Box 1112
Evergreen, CO 80439
(303) 674-4024
JAMES SULLIVAN
7513 MacArthur Blvd.
Cabin Oohn, MD 20731
(301) 224-6889
National Science Founda-
tion Conference Staff
BILL TAFFEL
Energy Resources Inc.
185 Alweiss Brook Parkway
Cambridge, MA 02138
(617) 661-3111
FRED TAPIA
11502 Gilpin St.
Northglenn, CO 80233
(303) 447-6059
Member, City Council
ANTHONY TAQUEY
1681 - 31st St., NW
Washington, DC 20007
(202) 254-8237
MEGAN TAYLOR
California State Water
Resources Board, Div.
of Planning & Research
19th & V Sts.
Sacramento, CA 95814
(916) 445-9248
MIKE TAYLOR
City Hall
P.O. Box 313
Craig, CO 81625
(303) 824-3938
Director, Public Works
& City Engineer with
201 Study
Mayor Alvin B. Thomas
City of Northglenn
10701 Melody Dr., Sute 309
Northglenn, CO 80234
Howard Tingley
12433 Highway 82
Carbondale, CO 81623
(303) 963-2832
MICHELE A. TINGLING
Urban Environmental Conf.
1302 - 18th St., NW, #301
Washington, DC 20036
(202) 466-6040
HOWARD TRAXLER
Indiana Public Interest Res
Group (INPIRG)
406 N. Fess
Bloomington, IN 47401
(812) 337-7575
MINDY TROSSMAN
Better Government Assn.
230 N. Michigan Ave. #1710
Chicago, IL 60601
(312) 641-1181
RICHARD TROY
Office of the Attorney Genl.
234 Loyola, Sutie 700
New Orleans, LA 70112
(504) 568-5575
St. of LA Dept. of Justice
WAYNE TURNACLIFF
Bio-Gas of Colorado
3525 - 23rd St.
Boulder, CO 80302
(303) 422-4354
BRAD VANDERMARK
417 W. Linda Lane
Chandler, AZ 85224
(602) 963-2625
Citizens Concerned about the
Project
ROSS VINCENT
Ecology Center of Louisiana
P.O. Box 19344
New Orleans, LA 70179
(504) 488-7856
PETER VREM
2331 W. 31st St.
Denver, CO 80211
(303) 839-2835
State Agriculture Dept.,
Feed & Fertilizer Division
SHARON WALKINGTON
Utah League of Women Voters
999 S. 15th E.
Salt Lake City, UT 84105
(801) 583-2284
BOB WARD
Agriculture & Chemical Engin.
Colorado State University
Ft. Collins, CO 80523
(303) 491-5252
KURT WEHBRING
David M. Dornbusch & Co.
71 S.W. Oak St.
Portland, OR 97204
(503) 221-0333
Consulting Engineer
RUTH WEIR
321 Kittanning Pike
Pittsburgh, PA 15215
(412) 963-8131
Squaw Run Watershed Assn.
MARTHA WEISER
4020 N. 75th St.
Boulder, CO 80302
FRANK WELCH
1445 E. Meadowbrook
Phoenix, AZ 85104
(602) 277-5080
Pres., Az. Society of Profes-
sional Engineers
NEAL WELSH
3706 Parkwood St.
Cottage City, MD 20722
(301) 779-3209
115
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BRAD WELTON
Friends of the River
1742 Curtis St.
Berkeley, CA 94702
(415) 527-0851
MARCHANT WENTWORTH
1411 Kennedy St., N.W.
Washington, DC 20011
(202) 726-0971
MARTIN F. WHITCOMB
635 St. Johns Rd..
Baltimore, MD 21210
(301) 323-4130
SHIRLEY WHITTEN
City of Northglenn
10701 Melody Dr., Suite 309
Northglenn, CO 80234
BETTY WOODRUFF
910 Wayne Road
Columbia, MO 65201
(314) 449-7797
League of Women Voters
JOHN YURICH
Box 94
Oak Creek, CO 80467
(303) 736-2698
Farmer on Rauth County
Plannin- Council; Rauth
Reg. Planning Commission
KATHLEEN ZACHER
Booz-Allen & Hamilton
4330 East West Highway
Bethesda, MD 20014
(202) 951-2573
GIL ZEMANSKY
Friends of the Earth
N.W. Regional Office
4512 University Way N.E.
Seattle, WA 98105
(206) 633-1661
PETER ZWICK
3229 S. 166th St.
Seattle, WA 98188
(206) 246-8916
116
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CHECKLIST FOR REVIEW OF FACILITY PLANS*
MICHAEL GRAVITZ
I. Plans involving small unsewered communities or areas of "malfunctioning septic systems"
If consulting engineer has recommended sewering an area with onsite systems because of health
or environmental problems, he should:
1. Do a community survey to find what number and percentages of systems are failing, their lo-
old
cation, how old they are, type of failure and frequency of cleaning them. Failure of
systems should be documented with dye tests, specific instances of failure such as backups,
complaints to local health department, contaminated well water (maybe the well ought to be
moved, not a new septic system built), specific cases of disease.
2. Document nature and extent of the water pollution problem, if any. Can be shown with water
samples or other kinds of tests. There should be stream data and/or discharge data if the
systems are discharging directly to a stream.
3. If high groundwater and/or poor soils are claimed to be a problem, consultant should do soil
borings and/or percolation tests to really establish the truth of this claim. Reference to
soil maps is often not a good enough indication of whether a system has a chance of working
in a particular location because often soil maps are of too large a scale or just do not
reflect accurately the ability of someone's backyard soil to absorb wastes.
4. The consultant should examine some reasonable means of correcting the problems, if they
really exist, other than by sewering the whole community. These include:
a. possibility of reconstruction/rehabilitation of individual systems
b. construction of clustered systems on better soils
c. waterless toilets and separate greywater disposal
d. better operation and maintenance on existing or newly constructed systems, possibly
by a municipal operation
e. if a small dense area like a central business district of the town is the cause of most
of the problems, perhaps only this limited area needs to be sewered
f. examination of "innovative" collection systems: small diameter, vacuum, and pressure
Engineering firm should have expertise in surveying and identifying problems with onsite
systems. They also should have expertise with designing new onsite systems. They ought to
have expertise in soils, groundwater, water quality sampling, and waterless toilets.
When the engineering firm presents its facility plan it should include a statement about what
the monthly user charge or expense will be for a typical household in the town for each of the
alternatives examined. This should include all costs of each alternative, even private costs
such as: pumping septic tanks more frequently or connecting the house to a new sewage system
and filling in the old septic tank (which can be very expensive—several hundred dollars).
II. Plans involving land treatment systems and the examination of land treatment as an alternative
in the facility plan. Factors deserving special attention are:
1 Waste Flow Rate - the population projections and per capita water usage that go into this
are important because the higher the flow rate, the more land will be required for the land
treatment system. Often larger parcels of land are harder to find and assemble than smaller
parcels and political opposition is lessened. In addition, land treatment systems have
smaller economies of scale than conventional systems. As the necessary size of the system
grows, conventional alternatives sometimes become more competitive.
2 Irrigation Rate - this is a crucial factor. The lower the allowable rate, the larger the
' amount of land that needs to be used (bought, leased, contracted for) for the treatment of
the same amount of effluent. A seemingly small change in the irrigation rate can lead to
large changes in the amount of land needed. For example, a decrease in .5 inches/week in the
rate could increase land requirements by one third.
*Some of the materials incorporated in this work were developed with financial support of the
National Science Foundation Grant OSS77-21229. However any opinions, findings, conclusions, or
recommendations expressed herein are those of the author and do not necessarily reflect the
views of the Foundation. Copyright 1978. Clean Water Fund.
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Usually there is a single factor limiting the amount of effluent that can be applied in a
given period. These are:
•organic loading (rarely important)
•hydraulic loading
•nitrogen or phosphorus loading (usually the factor for good soils)
In order to determine a reasonable loading rate the consultant should not just pick one out of
the air. He needs to have a good idea of soil types on the site. Investigate: percolation
tests and soil borings.
If the application rate is not limited by the amount of water that can infiltrate and percolate
through the soil, it is probably limited by the amount of nitrogen that can be applied in the
effluent without putting too much nitrogen in the groundwater. Is the consultant assuming the
correct amount of nitrogen removal by the crop that will be grown at the site? Is there an
allowance for denitrification—nitrogen loss to the air by bacteria—in the soil that lowers
the amount of nitrogen available to move into the groundwater? Is the consultant using the
crops that maximize nitrogen removal or perhaps more valuable crops that do not remove as much
nitrogen? There is a tradeoff here between revenues from the crop and increased amount of land
needed if a lower nitrogen removing crop is used. Systems can by designed to maximize crop
production and revenues or maximize application rates.
If the consultant claims that groundwater will be polluted and violate EPA groundwater criteria,
does he show how? Does he know how deep groundwater is and where it flows?
3. Pretreatment - Is the level of pretreatment for the effluent before it is used in the land
treatment system just right, or too high? Sometimes consultants assume that sewage must be
treated in a conventional secondary plant before land treatment. Of course, then land treat-
ment cannot compete with secondary conventional treatment. Often an aerated lagoon or
nonaerated lagoon will do for pretreatment.
4. Buffer Strips - Are the size of the buffer strips surrounding the site of the land treatment
system reasonable? Or are they ridiculously large? This can increase the cost of a system
tremendously.
5. Storage Requirements - land for any storage lagoon to store effluents during non-irrigation
seasons is now eligible for EPA grants, but it still adds to the cost of a system. Is the
size of the storage lagoon reasonable? This is based on assumptions about the length of the
growing season and climate. Are the factors used reasonable? Remember, some crops can be
irrigated much longer than others. Length of growing season also influences amount of land
required.
6. Land Acquisition - Did the consultant assume that land would have to be purchased? This is
often the most expensive way of getting an irrigation site. Other ways are: lease, pur-
chase and lease back, contracts/arrangements with farmers for them to use the effluent. If
the price of the land is reasonable and substantiated, this is one option for acquisition.
Remember, large pieces of land often cost less per acre than smaller pieces. Consultant
should examine alternatives besides purchase. Often a consultant will say that land treat-
ment is not viable in the situation because it would take too long to implement, e.g., either
purchase land or make other arrangements. Yet most conventional treatment plants take years
to build. Rushing a system to completion ought not to be used as an excuse to reject land
treatment. Did the consultant look at actual land treatment sites and cost out a system?
If not, why not? Land may increase in value faster than the rate of inflation. If this is
so, then the appreciated value of land should be used as the salvage value in the cost-
effectiveness analysis instead of just the original price of the land.
7. Sewage Recycling Technologies - Did the consultant look at the different types of land
treatment systems, not just spray irrigation? Some other system might be better suited to
your area like: overland flow, infiltration/percolation, spray irrigation of forest land,
or aquaculture. Combination systems employing one technology in one area, but a different
one on different soils can be built. This combination can take advantage of sites with
very different soils on them. Land need not be "wasted" just because a consultant does not
want to use more than one technology at a site.
8. Return Flows, Erosion. Underdrains - Has the consultant dismissed land treatment because he
says there would be problems with erosion or need for a return flow system? Are these
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problems real or imagined? Would good farming practices simply take care of this? Is the
need for underdrains increased? If they are included in the cost estimates, are they
really needed?
9. Revenues - Are reasonable revenues from sale of crops, or delivery of irrigation water,
if any, calculated?
10. Other Benefits •- Will there be benefits from a zero discharge land treatment system that
ought to be calculated into cost-effectiveness analysis? Examples: more than meeting water
quality standards in the stream to which a system would have discharged, recharge of ground-
water, open space preservation.
11. Overall Design - Is the proposed land treatment system, if any, well designed? or poorly
designed? Poorly designed systems can give sewage recycling systems a bad reputation when
they are built and operate badly.
12. Water Rights - Many consultants (especially in the West) often claim that land treatment is
not possible because of water rights problems. The problem is that people downstream of
the sewage treatment plant sometimes have a right to use its effluent or a major part of the
stream of which it is a part. Because this is not always the case even though consultants
will often claim it, this should be checked out. Even where this is a real problem, it can
often be solved by agreements between downstream users and the town. One solution is for
the town to use the water and send its treated sewage directly to those downstream farmers
who have water rights.
13. Public Acceptability - Consultants often claim that you cannot do a land treatment system
because the public will not accept it. This claim is usually unsubstantiated and should be
checked out. In any Ease, plans which are drawn up without public participation and an
adequate program of public education will often face opposition from citizens. Consultants
should be prepared to involve citizens who are interested or who are likely to be affected
in plan preparation and be able to responsibly discuss all aspects of land treatment
systems, especially health aspects.
III.Conventional Systems/Any System
1 Capacity of the System - Are the flow per capita assumptions reasonable? Are the population
projections reasonable, and how were they arrived at? Is there too much reserve capacity in
the system. Was phasing of the treatment plant or pipes investigated? Was the inflow and
infiltration study to determine if there is too much leakage of water into the system done
correctly and wholeheartedly?
2 No Construction or Minimal Construction Alternatives - Were these kinds of alternatives to
a full fledged construction program examined by the consultant? Examples: better operation
and maintenance of the existing plant, flow equalization, waste and flow reduction through
residential and commercial/industrial conservation.
3 Planning Area - Is the planning area too small? Will it include all the areas that will
' be affected by the new system, including those that will be impacted by growth effects?
Is the planning area too big? Does it include large areas of undeveloped land that lies
between two centers of population which might be connected in a regional system? Or if the
planning area is regional in scope, has the consultant examined two or more separate
systems instead of the one regional plant?
4. NPDES Permit - Is the NPDES permit for the system high enough to allow water quality
standards to be met?
5 Sludge Disposal - Has long term sludge disposal been considered? This means sludge disposal
for the ife of the system. Have the costs of long term sludge disposal been realistically
costed out and added into the cost-effectiveness analysis? If the town now landfills its
s?u5ge, and ?he landfill will be used up during the life of the system, has the real cost
of future alternative methods of disposal really been thought out seriously?
6 Adaotabilitv for Later Use of Recycling Technologies - The law requires in Section 201(g)
6< (%t that if a system does not use recycling technology now it must be designated flexi-
bi 1 ty enough to allow for this possibility in the future. This has rarely been done or
even addressed in facility plans. The normal design process for a conventional system does
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not often preserve this kind of flexibility. Here are some problems and ways of retaining
flexibility:
•site treatment plant near good farmland or in areas that are likely to attract
industries that can use recycled water.
•many conventional plants are located at the low end of the system next to a river,
but this is not where you would normally want pretreatment for a land treatment
system because it could require lots of expensive pumping to a treatment site.
•if all local treatment plants are consolidated into one big regional plant, it may
be difficult to find a nearby site to treat all the effluent whereas there is a
greater possibility of finding small sites closer to the smaller local treatment
plants. Transmission costs back to these small local sites from the huge regional
plant would probably be prohibititive.
•it may be necessary to spend a bit more money on a system which preserves flexibility
for later addition of recycling than on the cheapest conventional alternative which
does not preserve the same flexibility.
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