FOR  WATER  QUALITY

               The report examines the impact of the unified HUD/EPA Water Quality
             Management Planning Guidelines on the planning efforts of several States
             with particular  regard to institutional and intergovernmental arrangements
             in State, river basin and regional planning.  The report identifies the sta-
             tus and current problems of the  water  quality management State planning
             programs and presents recommendations  for the alleviation of the problems.
                           Washington,  D. C.   20460

                                SEPTEMBER  1971



                              FOR WATER QUALITY


     The report examines the impact of the unified HUD/EPA Water Quality
Management Planning Guidelines on the planning efforts of several States
with particular regard to institutional and intergovernmental arrangements
in State, river basin and regional planning.  The report identifies the
status and current problems of the water quality management State planning
programs and presents recommendations for the alleviation of the problems.
                                 PREPARED BY

                      Harold F. Wise & Associates, Inc.
                      1771 N. Street, N.W.
                      Washington, D. C.  20036

                                   FOR THE

                      Office of Water Programs
                      Environmental Protection Agency
                      Contract No. WA-71-90
                               SEPTEMBER 1971

An effective planning process is an integral part of, and provides
the basis for developing and efficiently implementing the total water
quality management program.

There are some strong reasons for an appropriate combination of
Federal, State and local planning effort.  (1) Broad Federal
guidance and technical support assures the perspective and priority
considerations necessary to achieve national water quality goals.
(2) State establishment or designation of responsible planning
agencies coupled with State participation and coordination with
these agencies will assure stronger State water quality programs
and consistent plans for implementation of the water quality standards.
(3) Development of plans by local governments as the responsible
planning agencies will provide the grassroots involvement essential
to plan implementation.

This report is intended as an aid to the States in defining and
assessing their institutional interfaces in the planning process.
Water quality management planning requires extensive cooperation
and coordination between a variety of governmental entities.  Lines
of communication, both inter- and intra-governmental, which are not
based upon dollar flow are often weak or non-existent.  Effective
planning can result only if such weak communication links are
strengthened.  By presenting the relevant Federal, State and local
authorities, tasks, requirements and intergovernmental relationships,
this report indicates the basic planning framework and the necessary
lines of communications.  It is designed to enable State and local
governments to evaluate their current planning structures and interfaces
in terms of management needs and to implement the necessary institutional
arrangements to improve their planning efforts.
                                    Deputy Assistant Administrator
                                          for Water Programs

                        TABLE OF CONTENTS

   CONSIDERATIONS                                      2

       Background                                        2
       The Guidelines                                     2
       Conclusion                                        9

   PLANNING                                           12

       Intergovernmental Lines of Communication
           Defined                                      12

       1.  Federal Level                                12
           CHART: Lines of Communication For
                 Water Quality Management
                 Planning                                13
           A.  Department of Housing and Urban
                 Development                            14
                 (1)  Funding and Control  Re-
                     lationships                         14
                 (2)  Planning Requirements               16
                 (3)  Comments  and Observations          20
           B.  Environmental Protection Agency —
                 Water Programs Office                   21
                 (1)  Section 8,  Construction Grants       22
                 (2)  Section 7,  Program Grants            23
                 (3)  Section 3c, Planning Grants          24
           C. Office of Management and Budget           26
                 (1)  Circular No. A-85                   26
                 (2)  Circular No. A-95                   26
           Conclusions —"Federal Level                  29

       2.   State Level                                  29
           A.  State Water Quality Management
                Office                                29
           B.  State Comprehensive Planning
                Office                                31
           Conclusions — State Level                   32

       3.   Areawide Planning Organizations               32

     DATIONS FOR EPA ACTION                           35

       Findings                                        35
       Recommendations                                41

IV. A GUIDE FOR STATE ACTION                          43

The contract calling for this report required the contractor to conduct a re-
connaissance of three selected states, and their respective EPA regional
offices, in order to determine:

  "a.  The nature and extent of the States' institutional and inter-
       governmental arrangements;

   b.  Their interpretations of and actions taken with regard to the
       implementation of the "Guidelines — Water Quality Manage-
       ment Planning" published January 1971;  and

   c.  An assessment of possible future actions the Office of Water
       Programs can undertake to strengthen the planning process
       contemplated by the guidelines in light of the findings made
       under a. and b.  above."

The States selected for study were Massachusetts, Arkansas, and Florida.
EPA regional offices responsible for these States are located in Boston,
Dallas, and Atlanta.

The conclusions drawn and recommendations  set forth in this report are
based on the field visits referred to above, interviews with Washington
based EPA, HUD, and Department of Agriculture officials, and observa-
tions made by the authors in connection with other planning assignments
with various State and areawide planning organizations.

It is the purpose of this report to set forth a series  of observations and
recommendations  to assist EPA and the States in developing the  institu-
tutions necessary to proper planning end programming of Water Quality
Management actions.


The primary mission of the Environmental Protection Agency's Office of
Water Programs is "the prevention, control,  and abatement of water pollu-
tion" so as to  "enhance the quality and value of ... water resources. "!/

The major tool available to the agency is its construction grant program.
Section 8(a) of the Act authorizes the making of grants  "for the construction
of necessary treatment works to prevent the  discharge of untreated or in-
adequately treated sewage or other waste into  any waters and for the pur-
pose of reports, plans,  and specifications in connection therewith."

The  Congress has authorized  $2,000,000,000  for FY 1972 for these
purposes.  Legislation pending before Congress would  raise authorizations
to incur obligations to make construction grants to five billion dollars for
F.Y. 1975. Appropriations to meet grant contract obligations are author-
ized  to aggregate as much as fourteen billion dollars through fiscal year

The  Congress has provided that these construction grants will be made in
an orderly manner,  based on comprehensive  planning and programming
coordinated through  the State  Governments.  The Federal Water Pollution
Control Act, as amended, provides that "no grant shall be made  for any
project ...  unless such project shall have been approved by the appro-
priate State water pollution control agency .. .  and unless  such project
is included  in a comprehensive program . . „" and "... is in conformity
with the State water  pollution  control plan .. . " .
I/ Section 1 (a), Federal Water Pollution Control Act, as amended (33 U.S.C.
   466 et. seq.).

The Guidelines

During January 1971,  the Environmental Protection Agency issued its
"Guidelines — Water Quality Management Planning. "

These Guidelines initiate the unification of planning  requirements for
the EPA Waste Water  Treatment  Works Construction Grant Program and
the HUD Water and Sewer Facilities Grant Program.

The  "Preliminary Planning Guidelines" provide the basic considerations
to be addressed in meeting the requirements of both organizations.  Re-
visions, based on experience, are contemplated.

The Guidelines were issued to implement EPA's current regulations
(18CFR 601.32 and 33) published on July 2, 1970.  The regulations
state "no grant shall  be made unless the project  is included in an
effective  current basin-wide plan for pollution abatement."  The reg-
ulations further provide that "a  grant for a project shall not be made
unless  ... such project is included in an effective metropolitan or
regional plan ... and certified by the Governor or his designee as
being the official pollution abatement plan  ... for the metropolitan
area or region .. . " .

In the evaluation of plans,  the regulations  indicate that determinations
must be made whether the plans "adequately take into account:  antici-
pated growth of population and  anticipated economic activity with ref-
erence to time and location;  present and future  use of the waters
within the planning area for water supplies, propagation of fish and
wildlife,  recreational purposes, agricultural, industrial and other legi-
timate uses;  adequacy of the waste collection systems in the planning
area with reference to operation, maintenance, and expansion of such
 systems;  combination or integration of waste treatment facilities into
a waste treatment system so as to achieve efficiency and economy of
 such treatment;  practicality and feasibility of treating domestic and
 industrial waste in a combined  waste treatment facility or integrated
 waste treatment system;  need  for and  capacity to deal  with waste from
 sewers which carry storm water or both storm water and sewage or
 other wastes; waste discharges presently in or  anticipated for the
 planning  area;  effect of the  proposed waste treatment facility upon  the
 quality of water within the  planning area with reference to other waste
 discharges and to applicable water quality standards."

 Water quality management  plans,  both at the basin and at the metro-
 politan/regional (areawide)  level, are to be in place and completed
 by July 1, 1973.  Interim plan  procedures may be used  to back up

 construction grant applications prior to this date to reconcile "lead time for
 planning with the existing implementation schedules and flow of construc-
 tion projects."!/ Procedures are provided for updating and maintaining com-
 pleted plans.

 Samuel C. Jackson, Assistant Secretary for Community Planning and Man-
 agement, Department of Housing and Urban Development, and William D.
 Kuckelshaus, Administrator of the Environmental Protection Agency,  signed
 a "Joint Agreement  for Inter-Agency Coordination in Planning and Develop-
 ment", dated June 7, 1971, and providing for "coordinated administration
 of comprehensive and functional planning and construction grant require-
 ments applicable to:

   a.   Policy and coordinative planning;

   b.   Integrated functional planning for water quality; and

   c.   Development of fully integrated wastewater collection and
        treatment systems."

 The agreement indicates that grants awarded by HUD and EPA "must meet the
 same administrative and regulatory requirements with respect to comprehen-
 sive and functional planning, and programming of wastewater collection and
 treatment systems."

 Programs covered by the agreement are:

              Department of Housing and Urban Development

   1.   Basic Water and Sewer Facilities Grant  Program Section 702 of
        the Housing and Urban Development Act of 1965, as amended —
        42 USC 3102 (C).

   2.   Comprehensive  Planning Assistance  (701) Grant Program —
        Section 701 of the Housing Act  of 1954,  as amended — 40 USC  461.

                    Environmental Protection Agency

   1.   Construction Grants for Wastewater Treatment Works — Section
        8 of the Water Pollution Control Act, as  amended — 33 USC  1158.

   2.   State and  Interstate Program Grants  — Section 7 of the Water
        Pollution Control Act," as amended — 33 USC 1157.

   3.  Comprehensive River Basin Planning Grants  — Section 3(c) of the
       Water Pollution Control Act, as amended — 33 USC 1153(c).
!/ The Guidelines ~ page 1-9.

These guidelines and the agreement follow a long-term history of cooper-
ation between administrators of HUD's comprehensive planning program
and community facilities (including water and sewer facilities grants)
grant programs, on the one hand, and EPA's predecessor agency's pro-
grams for wastewater treatment works.

The current joint EPA-HUD Guidelines for Water Quality Management Plan-
ning rely heavily on the perfection of intergovernmental machinery for
planning and action,  to accomplish the objectives of the EPA and HUD
programs .

Properly, the regulations and guidelines provide that:

   1 .   Federal grants for the construction of Waste Treatment works
        will only be made if the project in question is included in
        "an effective  current basinwide plan for pollution abatement"
        as well as included in "an  effective  metropolitan or regional
        plan developed or in the process of development and certified
        by the Governor ... as being the  official  pollution  abatement
        plan ...  for the metropolitan or regional area within which
        the project is proposed to be constructed."

   2.   The Governors, or their designees, of the respective states have
        the final sign-off on all Basin and Metropolitan/Regional Plans.
        They also sign off on the State's Annual State Program Plan.
        They certify the internal consistency of each.

   3.   "Planning is required in two distinct but related geographical

            a.    The Basin hydrological system; and

            b.    The Metropolitan/Regional plan.

   4.   The guidelines differentiate between the Basin Plan and the
        Metropolitan/Regional Plan, as follows:

        "1 .   The basin plan should provide the main input on
              hydrology,  location, and characterization of waste
              sources (including storm water,  combined sewers,
              non-point sources) ,  treatment levels (present and
              future), water quality effects (present  and future) ,
              land use, basin-wide alternative's  (such as trans-
              basin diversions, flow augmentation),  and ba s i n-
              wide priorities for construction.

        2.    The metropolitan/regional plan should provide  the
             main input on land use, growth,  estimated waste
             production, process design,  service areas, collec-
             tion systems , sewer drainage areas,  investigation
             of local and regional alternatives,  cost estimates,
             financing, and institutional arrangements.  If no
             metropolitan/regional plan is  to be prepared,  the
             basin plan should then include the  expected envir-
             onmental impacts of any projects proposed for  the

 The Guidelines envision an integrated and interacting system of intergov-
 ernmental relations.
 Water Quality Office, EPA,
     together with
 Community Planning and
 Management, HUD
Establish regulations and issue guidelines;

Define desirable planning and action roles
as between the States,  River Basin Organ-
izations and Metropolitan/Regional agencies;

Make planning and construction grants con-
sistent with the above.
Governors of the States
Cooperate with EPA and HUD Area and Re-
gional Offices in recognizing area wide
Planning Organizations to accomplish
Metropolitan/Regional Water Quality Man-
agement Plans;
                                  Designate appropriate basin planning or-
                                  ganizations. Establish processes for co-
                                  ordination between Are a wide and Basin
                                  planning organizations;

                                  Certify that plans  are consistent with State
                                  programs and that  Metropolitan/Regional
                                  plans are consistent with Basin Plans and
                                  vice versa;

                                  Sign off on the Annual State Program Plan
                                  containing  statewide priorities (which are
                                  based upon Basin and Metropolitan/Regional

                                                                        — 7 —
 River Basin Planning
A State  level responsibility.

Basin Plans emphasize  Basinwide water
quality  management solutions, hydrol-
ogy, and waste-carrying capacity of
receiving waters;  are concerned with
with developing most cost-effective
solutions and the establishment of wa-
ter quality standards.  The  basin plan
should assess those factors which, for
any reason, cannot be effectively eval-
uated separately by the various metro-
politan/regional areas within the basin;

Metropolitan/regional plans are consi-
dered in basin planning in the determin-
ation of potential waste sources.

State Water Quality Agency coordinates
with State  and metropolitan/regional
planning agencies for consistency in im-
plementation of policies and planning.
Planning Agencies
Prepare Metropolitan/Regional Water Qual-
ity Management plans defining "the stra-
tegy which results in the most cost-effec-
tive solution for the waste water disposal
problems within the  planning area."

As the Guidelines indicate:

"The basin plan . . .  should define the al-
lowable total waste  discharge to the re-
ceiving water from each Metropolitan/Re-
gional (M/R) area.   Therefore, within  each
M/R area,  the objective is  to allocate this
allowable discharge  among  the individual
wa s te  s ource s .  Whe re a s the  ba sin pka n _

                                 may lump the total waste discharge from
                                 the M/R area into a  single point discharge,
                                 the M/R plan must consider each waste
                                 discharge individually.  The task becomes
                                 one of coordinating these individual waste
                                 sources into a  regional system.  This ...
                                 implies a coordinated and unified planning
                                 effort within a  M/R  area to assure the most
                                 cost effective  water quality management
                                 program for the area as a whole, consistent
                                 with the overall strategy for the basin, as
                                 defined in the  basin plan."

                            •    Concentrate on the insitutional arrangements
                                 necessary to the rn pie mentation of the
                                 Metropolitan/Regional Plan and the Basin

                            •    Provide the clearinghouse function under
                                 OMB Circular No. A-95,  reviewing appli-
                                 cations for Federal planning and construc-
                                 tion monies for consistency with regional
                                 comprehensive  planning and water quality
                                 management plans.

The Water Quality Management Planning Guidelines indicate that:

     "Some technically  feasible alternatives may,  in certain cases,
     be constrained because of the absence of a legislative base for
     implementation.  Additionally, jurisdictional  problems can exist
     because of the vested interests  of many institutional entities
     which may exist  in a basin or M/R area.  Where conflicts of in-
     terest affect any of the abatement alternatives, they must not
     only be recognized as constraints in the analysis, but organiz-
     ational or other institutional remedies should be proposed."!/
The implications of these provisions are clear. What is being said is that
the local metropolitan/regional planning organization (whose policy body
is predominantly composed of elected officials of the units of local gen-
 l/ The Guidelines — page 3-3.

eral government in the area) has the responsibility to hammer out the inter-
governmental relations in developing the institutional and governmental
arrangements to accomplish the most cost effective solutions to local
water quality management.
1.  EPA and HUD regulations and guidelines, for the first time, begin to
    spell out the relative responsibilities of State, basin, and metropol-
    itan/regional levels of government for water quality management

2.  The guidelines recognize that oftentimes new "institutional remedies"
    are needed and should be proposed.

         •   The fact remains, however,  that the guidelines are
             new  (January 29,  1971), and are imposed on existing
             planning and decision-making machinery that is not
             necessarily new, even though arrangements necessary
             between elements of this planning and decision-making
             machinery will be new.

         •   Techniques and methods beyond the issuance of guide-
             lines may have to be developed to achieve the levels
             of institutional innovation and  smooth-working inter-
             governmental relations necessary to the accomplishment
             of the basic waste treatment works construction and
             water quality management mission of the Office of
             Water Programs, EPA.

The basic and very real problem that emerges is the knitting together  of the
planning  and decision-making institutions and the perfecting of the intergov-
ernmental relations:

    1 .   at the Federal level (EPA and HUD);

    2.   at the State level (the State Water Quality Office and  the
         State's Comprehensive  Planning Organization);

    3.   basin planning arrangements;  and

    4.   local intergovernmental areawide Metropolitan/Regional
         planning organizations .

Institutions at each of the four levels enumerated above exist and are in
business. They have not, however, in the normal course of events,  been
clearly tied together in common cause to meet planning requirements  in a
timely fashion (in this case by July 1, 1973). Each State has its own div-
ision of labor between State agencies of water pollution control, health,
natural resources,  and state planning.  And each has its own pattern of
regional planning agencies that were initially sponsored and have grown up
under a variety of special purpose federal and State programs -- the Econ-
omic Development Agency, the Farmer's Home Administration, the  Soil Con-
servation Service,  and HUD,  to mention only a few  sources of planning assis-
tance.  Areawide planning machinery has become increasingly more compe-
tent and more responsive to elected officials, but its piecemeal growth has
left a set of institutions highly uneven  in strength with irregular patterns of
coordination between functional planning and comprehensive planning.

The law is clear. The Federal Guidelines are understandable.  It  is the  per-
fecting of communication and mutual support at the State and areawide levels
that poses the greatest challenge.

One other problem complicates the perfection of  institutional arrangements
necessary to accomplish the planning needs  of the  program.  Since EPA's
Water Pollution Control Program is essentially a  "hardware"  grant program,
many key administrators at all levels of government are more used to the
business of building and "getting  the money out" to facilitate building, on
the one hand, and are unfamiliar with planning and programming, on the
other hand.  People have a propensity to deal with the familiar and to shun
the unfamiliar.  Action agencies and administrators want action. It is that

One conclusion is inescapable at  this point, given the great differences be-
tween States and their areawide  planning and programming agencies.   There
must evolve a total commitment to orderly planning and programming in or-
der that the  construction program can meet Congressional targets.

The programming inputs, thought through, resulting  from basin and areawide
planning, are the best possible insurance that the multibillion dollar con-
struction program currently being debated by the  Congress will mean more
effective administration of the program,  and  more rational and economic ap-
plication of the construction dollars available — in  short, genuine assis-
tance to orderly program administration.

As  stated, planning deadlines are July 1, 1973.   The 14 billion dollar pro-
gram envisioned by new legislation is authorized in  FYs 1972,  1973,  1974,
and 1975.  Hence,  even though there has been a  great deal of

activity in the construction program over the past several years, the great
thrust, and by all odds,  the greatest dollar expenditures, are yet to come.
Planning and programming processes must be in place to meet these con-
struction and expenditure demands.

While the planning  machinery is being cranked up, the construction grant
program will, of course, continue, based on interim plans.

There is  no possible way that planning and programming  can hold up or de-
lay the construction grant program.  It can, in the long run, only aid and
assist in meeting serious National commitments to clean up the Nation's
waters .


 Intergovernmental Lines of Communication Defined

 Before setting forth a series of action recommendations, it is essential that
 the institutional framework  within which water quality management planning
 takes place is clearly understood.

 First, the institutional framework is intergovernmental, involving all levels
 of government and requiring a high level of intergovernmental cooperation.

 Secondly, the primary and most closely knit intergovernmental channels of
 communication are based on the  flow of dollars.  The power to grant or
 withhold dollars includes the clear authority to establish performance
 standards and time tables for actions.

 Thirdly,  the weakest part of the  intergovernmental chain are those links
 that  require cooperation with no  apparent money relationships.

 The chart on the following page indicates the primary lines of communica-
 tion  between the levels of government and the agencies involved in water
 quality management planning.  Solid lines indicate direct relationships
 backed up by dollar flow.  The dotted  lines indicate necessary cooperative
 and coordinative relationships not backed up by dollar flow.  It is these
 latter relationships that the most careful attention must be given to by
 those with overall  water quality  management planning responsibilities,
 particularly at the  state level.

 Within this frame,  the institutions dealing with water quality management
 planning  will be examined.
1.  Federal Level

In matters of water quality management, the principal actors at the Federal
level are the Environment Protection Agency, the Department of Housing and
Urban Development, the Farmers Home Administration (Department of Agri-
culture) , the Economic Development Administration, and the Office of Man-
agement and Budget of the Executive Office of the President.

The Executive Departments and agencies have operational, related to
grant-in-aid, functions.  OMB is charged with significant management and
coordination responsibilities within the Federal establishment.

Neither the  Farmers Home Administration or the Economic Development Admin-
istration is  currently a part of the agreement to the issuance of the Water Qual-
ity Management Guidelines.  They  should be.  The massive challenges of


            EPA-WPO —	— HUD
          STATE WATER                  STATE COMPREHENSIVE
BASINS          ~ ^.^
                                             Direct - based on dollar
                                             •Cooperative  and Coordin-
                                                     ative - minor or
                                                     no dollars involved

dealing with water pollution problems where the people are has probably
contributed  to HUD and EPA getting together, while FHA and EDA continue
to play their roles. FHA, of course, is restricted by law to providing
assistance to  locations with less than 5,500 population.  Ultimately,
FHA and EDA must become parties to the Federal coordinated approach.

Steps have been initiated in this direction with the formation of an "in-
teragency committee to provide continuing coordination of sewer and
water programs", as of September of 1971.  FHA, EDA, EPA, and HUD
are all represented on the committee.

This section of the report will deal with HUD, EPA, and OMB, their roles
at the Federal level and their relationships with States, localities, and
areawide planning agencies -- focused on water quality management
   A.  The Department of Housing and Urban Development

        (1)  Funding and  Control Relationships

 The Department of Housing and Urban Development has had a long standing
 mission in the area of financial assistance  to comprehensive planning under
 Section 701 of the Housing Act of 1954,  as  amended.  Since its initial en-
 actment in 1954, the 701 legislation  has been amended regularly to expand
 its coverage.  Today, units of general government ranging from States,
 counties, cities and regional  organizations, metropolitan and non-metro-
 politan, are the principal recipients of funds under the planning assistance

 The  flow of dollars from  HUD does not follow a consistent pattern,  largely
 due  to legislative  inconsistencies that came about as, from time to time,
 the basic enabling act was amended.

 HUD funds, for planning  and programming purposes, the following levels
of government directly:

            States for State planning
            Cities with populations of 50,000 and over
            Metropolitan Region Councils .

HUD dollars for planning assistance flow through State agencies to fund
the planning activities of the following:

           Cities, or groups  of adjacent communities, with
                 populations  of under 50,000
           Regional Councils or Development Districts in
                 non-metropolitan areas.

Thus, HUD, based on direct dollar flow, has a program overview of State
planning, large cities (over 50,000) and metropolitan planning agencies.

Conversely, the States do not necessarily have a program overview of
large  cities or metropolitan  planning agencies, since they do not admin-
ister the basic grant money  involved.

States do have a program overview (i.e., they do administer the dollars
involved) in planning for small cities,  counties, and non-metropolitan
planning areas.

In the administration of the  Water Quality Management Planning Guidelines,
therefore,  States are usually entering into new relationships with Metropol-
itan Planning agencies in arranging for  a unified planning response to meet
Metropolitan/Regional (areawide)  planning requirements  (which must in-
volve both metropolitan and non-metropolitan areawide planning agencies).

In Massachusetts, for example, the Governor has established, by Execu-
tive Order, eleven areawide planning districts. Of the eleven, nine are
Metropolitan-area based, and as  such  have in the  past had little  or no
direct program or funding relationships  with the State.  In Arkansas, of
fourteen regional planning agencies, five are metropolitan (three of these
are interstate — to  compound the  confusion further — one each including
areas in Oklahoma and Texas,  and the  other including counties in Tenne-
see and Mississippi).

The areawide planning district systems of Massachusetts and Arkansas
cover the entire State (i.e., no county or any geographical area is left
out).  In Florida,  on the other hand, there are sixty-seven  counties.
The only areawide planning agencies are metropolitan, nine in all, whose
combined jurisdictions cover only seventeen counties.  Four of these
agencies have only  a one-county  jurisdiction.

The point here is that the mission of accomplishing areawide water quality
management planning is made much more difficult from a State point of
view by the direct HUD - Metro Area funding-program overview relation-
ship. States should have been in the act sooner.  But the fact is that
they  have not, since the program  initiation came from HUD by Congress-
ional action.  Few States have seen the need to buy in.

EPA dollars for waste treatment construction flow through the State, and
must relate to a State  (Governor) certified "Annual State Program ...  Water
Pollution Control Plan".  EPA has established planning guidelines that must
rely on areawide planning organizations over which the State has,  in the
past, had very little,  if any, program control.  All of these facts set up
a situation where one  of the real challenges is  that of building new re-
lationships between old organizations, namely  the State and its  metro-
politan planning agencies, in order that EPA construction grant money
can flow in an orderly and timely fashion.

HUD, of course, has also signed off and agreed to the Guidelines, but
their historic funding and program control relationship with Metropolitan plan-
ning agencies does not help to weld together a  clear Federal-State-local
(areawide) hierarchy of planning and political decision making that is at
the heart of the  Water Quality Management Guideline philosophy in action.
HUD's willingness to cooperate is one thing — but their channels  of com-
munciation  (established by Congress) for planning assistance builds  or-
ganizational relationships contrary to the spirit of the Guidelines and the
structure of EPA's Waste Treatment Facilities Construction Grant program.
        (2)  Planning Requirements

It is important to recognize the differences between comprehensive plan-
ning and functional planning.

The planning for a wastewater treatment system on an areawide basis is
the planning for a single function.  Highway planning is another function,
as is housing or recreation.

All functional planning must have a common base in relation to the loca-
tion of population and economic activity, projected growth patterns,  and
the social needs  of the  population.

Construction activities  resulting from functional planning must be har-
monious with the total growth patterns of the area.

The linking  of functional planning to  a common base and the insurance
of balanced, harmonious development is accomplished through the com-
prehensive planning process.

HUD, in their Comprehensive Planning Assistance Handbook (MD 6041.1),
defines the  purpose of its planning assistance program as one "to assist
state and local elected  officials  (e.g., governors, mayors, city council-
men,  and county  commissioners)" to

  "a. Establish the comprehensive planning process as a con-
      tinuing function of government, including the establishment
      and improvement of professional staffs to assist elected
      officials to make policy affecting urban and rural development;

  b.  Make comprehensive planning relevant to critical social
      concerns  such as poverty, inadequate housing and edu-
      cational opportunity, and social injustice;

  c.  Prepare and adopt plans, programs and budgets which af-
      fect development on a comprehensive continuing basis and
      which influence the allocation of scarce public and private
      resources, including the preparation of guides to channel
      Federal assistance  to state and local governments;

  d.  Improve the quality and efficiency of land development and
      associated physical facilities;

  e.  Improve the quality of methods and analytic techniques
      used  in the  comprehensive planning  process; and

  f.  Secure the participation of business firms and voluntary
      groups in the planning and development process."!./
In HUD Circular MPD 6415.1A, the Department defines the Com-
prehensive Planning Process as follows (an APO is an Areawide Planning
Organization;  an APJ is an areawide Planning Jurisdiction):

   carrying out comprehensive planning for an areawide planning
   jurisdiction, an APO should undertake  the activities set forth

       a.  The Comprehensive Planning Process.  It is essen-
           tial that a  continuing comprehensive planning pro-
           cess  be developed and maintained.  Such a process
           involves human and natural resources,  as  well as
           economic,  governmental and physical concerns re-
           lated to the development and  well being of the APJ.
           Planning should  be comprehensive in the sense that
           it encompasses elements for housing, employment,
           and other aspects necessary to address  current and
           future problems of land use and development.  Pro-
l/ MD 6041.1 — page 1.

cedural matters should be so structured as to allow
minority and low-income groups  to significantly im-
pact the decision-making process.  Further, through
comprehensive planning, programs should be effec-
tuated to create areawide choices to house minority
and low-income families.  Additional programs should
be structured as necessary to address  problems of and
interrelationships between educational facilities,
employment centers, transportation, taxation, inter-
governmental relations, etc., as they  relate to housing
and development.  Basic components to be considered
in the planning process are set forth below.

(1)   Development of goals and objectives to provide
      a framework for planning and policy decisions,
      to relate functional elements to  one another, arid
      to relate the technical phases of the planning
      process to overall policy making. Goals are
      long term in nature, requiring periodic updating
      and modification as realistic alternatives for
      meeting such aspirations emerge. Objectives
      should be  set forth in measurable terms and
      time periods whenever possible  to enable eval-
      uation of progress toward the stated goals.

(2)   Identification of problems and opportunities as
      a basis  for preparing a program to study and re-
      solve problems and to meet jurisdictional goals.

(3)   Systematic collection and analysis of data re-
      lating to population, economic factors, health,
      education,  welfare services, land uses, trans-
      portation, community facilities, government or-
      ganization and other factors relating to problems
      and opportunities.

(4)   Development, evaluation, and testing of alter-
      native courses of action to resolve the prob-
      lems and to meet jurisdictional goals for con-
      sideration by the policy makers, affected in-
      terests, and  the public.

(5)   Development of a  long-range comprehensive plan
      for  the future development of the APJ.  This may
      be basically a policies plan  setting forth  the
      agreed upon courses of action from item (4).  The
      goals and objectives (item (1)) should be refined
      and adopted as a component  of the plan.  The
      plan should provide a  coordinative framework for

                 functional planning with future needs and objec-
                 tives expressed for the various  functional areas
                 based on such indices as peculation and em-
                 ployment characteristics, distribution and fu-
                 ture estimates. When the functional plan ele-
                 ment is undertaken by agencies other than the APO,
                 such planning should be consistent with the
                 goals, objectives, policies,  future estimates,
                 and other plan elements as set  forth in the
                 comprehensive plan.

           (6)    Development of legislative, regulatory and
                 administrative measures to implement the com-
                 prehensive plan,  including short-term action
                 programs, fiscal  plans and programming of
                 capital investments and services together
                 with budgetary measures.

           (7)    Updating and refining in response to new agree-
                 ments on goals and policies, current data and
                 conditions,  new  methods and techniques and
                 generally new concepts and ideas about the
                 future .

           (8)    Development and maintenance of systems to
                 enable a continuing evaluation of the planning
                 process and the measurement of the results of
                 policy, objectives, program recommendations
                 and implementation efforts."!/
HUD also requires that the policy making body of areawide (M/R) planning
agencies be composed of elected public officials of units of local general
government within the planning area of jurisdiction:

   "Insofar as feasible voting representation from units of local govern-
   ment should be composed of elected officials or appointed  chief ex-
   ecutives responsible to elected officials. "±/

All of the foregoing is implied in the "Guidelines Water Quality Management
Planning" when they state:

           "Areawide Planning Organizations.
           The EPA Regional Office, jointly with the HUD Area
           Office and with the  Governor or his designee will
           recognize Areawide  Planning Organizations (APO's)
           guided by the HUD Areawide Planning Requirements."^./
I/ MPD 6415.1A, pages 12 - 14.
2/ MD 6041 .1 ,  page 41 — guideline
3/ The Guidelines -- page 1-5.

        (3)  Comment and Observations

There must be a joint three-way agreement in the designation of
agencies to accomplish areawide water quality management plan-
ning, and further, such agencies must be:

   •    the areawide comprehensive  planning agency,

   •    with a policy board composed primarily of elected officials
        of the units of general local  government within the APO's jur-

The importance and wisdom of utilizing this intergovernmental planning and
political decision making machinery, where it exists,  lies in two directions:

   •    It ensures that water quality management planning (functional)
        becomes a part of and is related  to the broader comprehensive
        and coordinative planning ongoing in the region, and

   •    That those who are politically responsible in the region
        (local elected officials)  make the policy for  the "institu-
        tional arrangements" necessary to carry out  and to im-
        plement the region's water quality management plan.

The latter point is most significant when it is realized that more  and more
systems for the management of water quality are going to have  to be dev-
eloped and operated on an intergovernmental, areawide basis.  As the
Guidelines state:

        "The Metropolitan/Regional plan defines the strategy
        which results in the most cost effective solution for
        the waste water disposal problems within the planning
        area. "I/

        The Guidelines go on to state:

        "This does not necessarily imply a single treatment facility
        for the M/R area;  rather it implies a coordinated  and uni-
        fied planning effort within a  M/R area to assure the most
        cost effective water quality management program for  the
        area . .. " . I/

Who should, indeed, wrestle with the problems of new,  innovative, institu-
tional arrangements than those who have to defend these  decisions among
their constituents while running for re-election  to office.
!_/ The Guidelines, page  3-1 .
2/ Ibid.

This language also properly positions special purpose districts — such as
sewer districts or river basin authorities.  Over the  past fifty years,  State
and local governments have sought to solve special  purpose  problems by
the creation of special purpose districts.  Too often these districts develop
a political  independence from the local jurisdictions they serve.

The procedures set forth in Office  of Management and  Budget Circular No.
A-95, which establishes regional planning agencies as clearinghouses  to
review applications for Federal assistance (including applications for con-
struction grants under Section 8, of the Federal  Water Pollution Control
Act, as amended),  states:

        "Comments and recommendations made by or through
        clearinghouses with respect to any project are for the
        purpose of assuring maximum  consistency of such pro-
        ject with State, regional, and local comprehensive plans."!/

A-95 also provides that comments may include information about:

        ". . .The extent to which the project is consistent with
        or contributes to the fulfillment of  comprehensive plan-
        ning for the State,  region,  metropolitan  area,  or locality."!/

These procedures,  coupled with the fact that the same regional planning
agencies will accomplish metropolitan/regional (areawide) water quality man-
agement planning under the terms  of the Guidelines,  assures the fact that spe-
cial districts will be  properly positioned to where they become instruments that
can be used to carry out and implement functional and comprehensive plan-
ning and development policy established by,  in fact,  a consortium of units
of local general government acting through their areawide regional council.
   B.  Environmental Protection Agency - Water Programs Office

The Water Program Office administers  the Federal Water Pollution Control
Act, as amended.  Its lines of communication, based on dollar flow, are
relatively simple. As a  matter of law  and policy, EPA-WPO deals directly
with the Governor of each State.  Usually,  the Governor designates a State
officer, usually his director of the  State's Water Quality Office,  as his
representative in dealing with EPA-WPO, although the Governor personally
must sign off  on the  State's annual Program  Plan.

There are three primary sources of money available to EPA-WPO to deal with
water quality  management matters:  Construction Grants for Waste water'
I/ OMB Circular No. A-95, page III-A-8.

Treatment Works (Section 8), Comprehensive Basin Planning Grants (Sec-
tion 3c), and State and Interstate Program Grants (Section 7).

EPA-WQO has other programs dealing with research and demonstrations,
monitoring, manpower training, information and technical assistance, for
example.  The basic programs outlined above, however,  are the key to the
Nation's water quality management commitment.

        (1)  Section 8,  Construction Grants,  are to assist in the con-
    struction of waste treatment works by State,  municipal, intermunici-
    pal, or interstate agencies.

    Grants are allocated to States on a formula basis related to pop-
    ulation, and  relative per capita income in the State.

    Local matching requirements vary, depending on State participa-
    tion as follows:

        30 to 33 percent grant, no State matching program;
        40 to 44 percent grant, 30 percent State  matching
        50 to 55 percent grant, 25 percent State  matching
            program together with provisions that effluent
            discharge is to meet  enforceable approved
            State water quality standards .

    One important consideration with regard to Section 8 funds relates
    to the phasing of payments of  grant funds. Essentially,  this is a
    reimbursement program.  Grants payments are usually based on
    25, 50, 75, and 100 percent of construction completed, or equip-
    ment delivered to the site. The States and localities, in other
    words,  must  provide "front end money" to finance construction
    prior to receiving grant money.

    Obligations during F.Y. 70 amounted to $425,600,000;  during
    F.Y. 71, $1,200,000,000.  F.Y. 72 obligations are currently
    estimated to run on  the order of $1,900,000,000.

The channels of communication for these funds are simple and
direct.  The Federal Government (EPA-WPO) deals only with
States.  The States deal with the localities.
     (2)  Section 7, Program Grants, are for basic support to
State water quality and pollution control offices to assist them
in establishing and maintaining adequate measures for preven-
tion and  control of water pollution.

Grants are allocated to States on a formula basis related to pop-
ulation,  the extent of the water pollution problem, and financial
need.  Grants range  from 33-1/3 to 66-2/3 percent, depending
on per capita income in the State .  Obligations incurred during
F.Y.s 70 and 71 were $10,000,000 each year.  It is estimated
that F.Y. 72 obligations  will amount to $15,000,000.

This is a direct Federal - State grant and the  lines of communication
are clear and uncomplicated.

Each State agency receiving a  program grant under Section 7 pre-
pares an annual State Program  Plan which constitutes an applica-
tion for Section 7  funds.  The program plan covers the broad
range of water pollution  control activities that the State engages
in. It sets forth the State's goals,  planned activities,  author-
ization to act and  budget, among other things.

Included in the submittal are one and five year schedules, which
detail  "municipal  waste  treatment needs".  These  schedules,
geared to actual and anticipated allotment of Section 8 Construc-
tion funds list, by jurisdiction, river basin,  receiving stream,
and population served, the cost, capacity, and State contribution
to a particular water pollution  control facility.  During the fis-
cal year following submittal of the one  year list,  no local pro-
ject can be funded that is not listed.  The schedule also indi-
cates the status of the project with regard to  its conformity with
a regional plan.

The Guidelines indicate, with  regard to  State Program Plans,  that:

     "Plans prepared by local  planning organizations (i.e., Basin and
    Metropolitan/Regional - author) are to provide the basis
    for the State program  plan submitted annually  to EPA
    under Section 7 of P .L. 660, i.e.,  the State  program

       plan should describe the State Planning Program and the stra-
       tegy of accomplishing  that program."—/
   This is a very important tie-back to the basin and areawide  planning
   process and the planning system that the State will set up under the
   provisions of the "Guidelines — Water Quality Management Planning".

   The State  must utilize its problem-stating and problem-solving tools —
   its monitoring, measuring,  basin and areawide planning process — to
   set action and spending priorities, and to display proposed projects
   and priorities on its annual listing of "Municipal Waste Treatment Needs"
   submitted with its annual State Program Plan.

   EPA's instructions for preparing  the annual State Program Plan and Grant
   Application, state :

        "The Act, as amended, emphasizes the need for preventing
       pollution and, thus, the  necessity of a continuing  planning
       activity as an essential  part of the process of establishing
       and implementing water quality standards.  Planning  is a
       continuous process which develops and keeps current the
       State's "water quality plan" to meet present,  near  future,
       and long-range needs for water of suitable quality  to serve
       projected use. In general,  the various basin and metropol-
       itan/regional plans provide  the basis for preparation  of the
       State's water quality plan.  The Program Plan sets  forth
       the State's strategy for developing and implementing  the
       basin/metro/regional plans  proposed."^/
       (3)  Section 3c, Water Quality Management Planning Grants, are to
   assist in the development of comprehensive water quality control and
   abatement plans  in river basins or portions thereof,  such as Metropol-
   itan/Regional (areawide) plans.

   Grants made have a statutory limitation of three years, although,  ad-
   ministratively, applicants are urged to complete projects within two
   years so that the plan will more rapidly impact overall water pollution
   control programs.  Fifty percent of the costs of planning must be pro-
   vided locally under this program.
I/ The Guidelines, page  1-17.
2/ See Instructions contained in EPA Form 5750-1 (3-71) .

This program has been notoriously underfunded, considering the
planning requirements that the Congress has written into the statutes.

Over the past five years,  Congressional appropriations have been:

              F.Y. 68         $500,000
              F.Y. 69        1,250,000
              F.Y. 70        1,780,000
              F.Y. 71        2,070,000
              F.Y. 72        5,370,000.

The authors estimate, conservatively,  that upwards of $100,000,000
a year over the next four years, as a bare minimum, will be required to
meet the planning mission very properly spelled out in the  "Guidelines --
Water Quality Management" — which mission is, in fact, based on
Congressional mandate for planning.

The annual dollar build-up would, of course, have to relate to State,
basin, and areawide demonstrated capacity to constructively produce
necessary  plans and programs in a timely fashion.

The aggregate four year spending  rate suggested above is less than 3
percent of  the construction grant obligation authority contained in leg-
islation now before Congress, which would anticipate construction ex-
penditures  on the order of $14,000,000,000 between F.Y. 72 end F.Y.
75.  In fact, the  minimum annual  planning expenditures suggested above
are but 2%  of $20,000,000,000 in construction money which has been
suggested by the Congress.

The lines of communication of the 3(c)  program based on dollar flow are
clean and direct, provided it were adequately funded.  Applications are
made by the Governor and he designates  the recipient agencies.

The river basin and areawide planning Guidelines provide for the desig-
nation of planning agencies to accomplish metropolitan/regional area-
wide water quality management planning by the Governor.  His designa-
tions are concurred in by HUD and EPA regional offices as being consis-
tent with the Guidelines.

   C.  The Office of Management and Budget - Executive Office of the

The management side of OMB in The Executive Office  of the President is
charged with the responsibility for the coordination of  Federal program ad-
ministration.  Important policies of the Executive Office of the  President
are promulgated through the issuance of OMB Circulars which are addressed
to the Heads of Federal Executive Departments and Establishments.

A brief review of two key OMB Circulars  is included here because of
their effect on the manner in which planning for water quality management
is conducted.
        (1) Circular No. A-85 provides that prior to the issuance of Fed-
eral rules, regulations, standards, procedures, and guidelines, comments
will be  sought from chief executives of state and local governments.  The
Advisory Commission on Intergovernmental relations manages the comment
process.  Comments from chief executive officers are sought through their
national,  State, and local government associations: National Governors'
Conference, Council of State Governments, International City Managers'
Association,  National Association of Counties, National League of Cities,
and United States Conference of Mayors.

OMB also circulates proposed Guidelines to other affected or interested
Federal agencies.

Circular No.  A-85 is mentioned because  the "Guidelines — Water Quality
Management Planning" did  go through this comment process prior to its
issuance.  Extensive discussions were held, not only  on an interagency
basis at the Federal level, but with the State and  local government asso-
ciations enumerated above.  In short, the best thinking of  many people
and groups went into and is represented  in the Guidelines .
        (2) Circular No. A-95

This Circular has its legislative basis in Section 401 (a) of the Intergov-
ernmental Cooperation Act of 1968, which provides, in part, that

        "The President shall ... establish rules and regulations
        governing the formulation, evaluation, and  review of Fed-
        eral programs and projects having a  significant impact on
        area and community development. . .".

The President's Memorandum of November 8, 1968, to the Director of
the Bureau of the Budget ("Federal Register, " Vol. 33, No.  221,  Nov-
ember 13,  1968) provides:

        "By virtue of the authority vested in me by Section 301
        of Title 3 of the United States Code and Section 401 (a)
        of the Intergovernmental Cooperation Act of 1968 (Pub-
        lic Law 90-577) , I hereby delegate to you the authority
        vested in the President to establish the rules and regu-
        lations  provided for in that section governing the formu-
        lation,  evaluation, and review of Federal programs and
        projects having a significant impact on area and commun-
        ity development, including programs providing Federal
        assistance to the States and localities, to the end that
        they shall most effectively serve these basic objectives..

        "In addition, I expect the Bureau of the Budget to gener-
        ally coordinate the actions of the departments and  agen-
        cies in exercising the new authorizations provided by
        the Intergovernmental Cooperation Act, with the objec-
        tive of  consistent and uniform action by the  Federal Gov-
        ernment. "I/

Part I of Circular No.  A-95  encourages  "the establishment of a network of
State,  regional, and metropolitan planning and development clearinghouses
which will aid  in the coordination of Federal or federally assisted  projects
and programs with State, regional, and local planning for orderly growth
and development. "I/

Clearinghouses are to evaluate "the significance of proposed Federal or
federally assisted projects  to State, areawide,  or local plans and  programs,
as appropriate. "I/

The proposals are forwarded to the Federal agency administering the program
involved, with local clearinghouse comments regarding the "extent to which
the project is consistent with or contributes to the fulfillment of comprehen-
sive planning for the State, region, Metropolitan area, or locality", and
"the extent to which the project contributes to the achievement of  State,
regional, metropolitan, and local objectives ... as follows:

   (1)   Appropriate  land uses for housing,  commercial, industrial,
        governmental,  institutional, and other purposes;

   (2)   Wise development and conservation of natural resources, in-
        cluding land, water, minerals,  wildlife, and others;
I/ OMB Circular No. A-95,  page III-A-3.
2/ OMB Circular No. A-95,  pate III-A-5.
3/ Ibid . , page III-A-6.

   (3)  Balanced transportation systems, including highway, air,
       water, pedestrian, mass transit, and other modes for the
       movement of people and goods;

   (4)  Adequate outdoor recreation and open space;

   (5)  Protection of areas of unique natural beauty,  historical and
       scientific interest;

   (6)  Properly planned community facilities, including utilities
       for the supply of power,  water, and communications, for
       the safe disposal of wastes, and for other purposes; and

   (7)  Concern for high standards of design. "I/

The three key EPA-WPO programs referred to above — construction, program,
and planning grants — are all covered by the clearinghouse review process.
This requirement is reflected  in the Guidelines.

The clearinghouse process  is relatively new, the first A-95 Circular being
issued July 24, 1969 (it  was  subsequently revised  and extended  effective
April 1, 1971). Prior to A-95, review and comment processes were  es-
tablished for metropolitan areas during 1967 „

In this short period, there have been organized some 208 metropolitan
areawide clearinghouses and  some 172 non-metropolitan areawide clear-
inghouses,  380 in all.  These clearinghouses cover 1680 counties in the
United States,  or about half of the total counties.  OMB officials esti-
mate that 85% of the country's population resides in  these covered counties.

HUD has of course worked closely, over a  number of years, in the dev-
elopment of planning programs and planning capacities of the metropol-
itan planning agencies.

The significance of A-95 to the Water Quality Management Planning process
extends beyond the review and comment procedure it encourages, as im-
portant as that is.  The clearinghouses are metropolitan/regional compre-
hensive planning agencies, the same agencies that are envisioned  by the
Guidelines as being the  agencies to accomplish Water Quality Manage-
ment Planning. These facts encourage a high level of local government
participation in the areawide water quality planning  proceedings and in
the development of the  "institutional arrangements"  that are so key to
the implementation of that planning.
 I/ OMB Circular No. A-95,  pages III-A-8 and 9.

   Conclusions -- Federal Level

Although administratively independent of each other, the Environment Pro-
tection Agency, Water Programs Office, and the Department of Housing and
Urban Development have bridged the potential communications gap.  The
joint issuance of  the Guidelines for Water Quality Management Planning
and the  June 7, 1971 "Joint Agreement for Inter-Agency Coordination in
Planning and Development" are the key evidence to this communication.

Procedures and the  influence of the President's Office of Management and
Budget have materially assisted in developing this common approach to
water quality management planning.

The Federal establishment is a vast thing.  Each Department and Agency
has many separate offices within it.  HUD  and EPA also have regional
offices.  In accordance with a Presidential directive of two years ago,
EPA and HUD together with ten other Departments and Independent Agen-
cies adopted or were committed to a uniform system of regional boundar-
ies with regional  headquarters located or to be located in the same cities.
Ten uniform regions (with the same groups  of states relating  to each
regional office) have been established.  In addition, HUD has estab-
lished a series of area offices responsible  to each of the  regional offices.

The accomplishment of the planning mission outlined in the Guidelines
requires the development of very  close coordinative relationships between
EPA and HUD at the regional and  area office level. They are, as well,
integral  links in  the planning chain between the States, their basin and
areawide planning organizations, and the localities where actual sewage
treatment plants are to be constructed.
    State Level
Two and sometimes three State agencies have prime roles to play in water qual-
ity management planning.  These are the State's water quality management
agency (pollution control agency) , its  State Planning  Agency or Office, and,
on occasion, a Department of Local or Community Affairs.

   A.   State Water Quality Management Office

This is the key agency that schedules  and programs the expenditure of
Section 8, Construction Grant money.  It prepares the Annual State Program
Plan, which allocates priorities and identifies locations  of proposed con-
struction of waste treatment works.  The Guidelines indicate that the An-
nual State Program Plan, which provides the  basis for an EPA Program Grant
to fund the State Water Quality Management  Office under title 7 of P.L. 660,
"should describe the State Planning Program  and the strategy for accom-
plishing that program."1
I/ The Guidelines  — page 1-17.

To put this Guideline language another way:   the Program Plan should in-
dicate the names of the areawide planning organizations who have been
formally designated by the Governor to do areawide Water Quality Manage-
ment Planning and the status of their planning and the  funding therefore.
EPA,  by specific directive, should emphasize the fact that the Pro-
gram  Plan should indicate the arrangements that have been made
and the time  table for accomplishing the required basin planning and its
relationship to areawide planning.

State  funding and assistance for local construction of waste water treat-
ment works and for basin and areawide planning are, in addition, key
parts  of the Annual State Program Plan.

Part III of OMB Circular No. A-95 provides for the Governor, through the
State  clearinghouse,  to review and comment on State plans prepared by
State  agencies as a requirement or condition of assistance under various
Federal programs. Section 7 and proposed allocations of Section 8 assis-
tance as set  forth in the Annual State Program  Plan is one such plan that
falls under Section III.

As the Circular states,  the Governor will "be  given the opportunity to
comment on the relationship of such State plan to comprehensive and
other State plans and programs."!/

Of course, EPA itself requires that the Governor sign off on the  State Pro-
gram  Plan, but the type of review afforded by  these provisions of A-95
gives one more chance  for coordinative interface between the  State's Plan-
ning Agency and the Water Quality Management Agency and the  perfection
of the State's Water Quality Management structure and process.
Each State Water Quality Management Office should have a planning
division who would work with the State' Comprehensive Planning Office
and the State's areawide planning agencies to develop the Water Quality
Management Planning structure for the State.  The planning division would
develop the necessary arrangements for the accomplishment of river ba-
sin planning and relating the technical aspects of basin planning to area-
wide planning.  In most States, the State Water Quality Management  Office
accomplishes basin planning on its own account.  Consultants can be
I/ OMB Circular No. A-95, page III-A-15.

used or there could be a system of one or more river basin authorities,
who could be assigned the work, which would be coordinated by the State
Water Quality Office.
   B.  State Comprehensive Planning Office

Almost all of the States have a State Planning Office.  The principal func-
tion of such an office is to advise the Governor on planning matters.  The
Office should be the central location for the development of basic infor-
mation necessary to everybody's  planning, such as population studies
and forecasts,  and  studies of economic trends  and employment.

More  and more, Federally funded programs require a State plan as a con-
dition to the  grant of funds.  The State Planning Office would  act as a
coordinator of such plans,  which normally would be  prepared in  the Agency
where actual operations are located.

Increasingly, Governors have, by Executive Order, established  a  set of
sub-State regions for local intergovernmental planning purposes.  The in-
itial studies  establishing such a  system of regions have regularly been
done  by State Planning Offices, who in turn work with these regions in
the development of  their planning programs.

It is usually the State  Planning Office  which administers HUD "701"  plan-
ning assistance funds  for communities under 50,000 in population and for
non-metropolitan areawide  planning agencies.  In some States,  this func-
tion is accomplished by a Department of Community Affairs.

State Planning  Offices accomplish studies and plans in particular areas
of concern to assist the Governor in the development of new policies and
new programs.  State concern with its statewide  land use pattern, the
development of urban growth policy and new community development as pro-
vided for under the  new Urban Growth and New Community Development Act
of 1970 , is one such example .

State  Planning  Offices engage in comprehensive State planning,  tying to-
gether policies of State government concern.

In this connection,  State Planning Offices are usually designated  by  the
Governor as the State clearinghouse under the provisions of OMB Circu-
lar No. A-95, discussed earlier.

State  Planning  Offices can provide invaluable assistance to State  Water
Quality Management Offices in the development of the Water Quality Man-
agement Planning machinery for the State.  Where Departments of  Commun-

ity Affairs play a role in servicing areawide planning agencies, they
should be involved as well.  The Water Quality Management planning
structure for any state must be developed as a joint venture between the
state's  Water Quality Office and its State Planning Office.
   Conclusion — State Level

The basic responsibility, under Federal Water Pollution Control legis-
lation, for the administration of these funds in the States, rests in the
State Water Quality Management Office, wherever it is located on the
State's organizational chart.  EPA-WPO under Federal legislation re-
quires planning and the development of a planning system as a condition
to its  construction grant program.  Plans for river basins and on an area-
wide basis are to be complete by July 1 , 1973.

In those States where there is no State Planning Office or local areawide
planning agency structure,  the State Water Quality Management Office
must  "go it alone" and accomplish the total planning job.  In  States
where  the other planning institutions do exist, their help and  assis-
tance  should be actively sought, for these  planning resources are  essen-
tial to meeting the charge set forth in the Guidelines.
3. Areawide Planning Organizations

For the purposes of this paper,  there does not need to be any differ-
entiation made between metropolitan and non-metropolitan areawide
planning organizations.  Although, as has been reported above, there
are differences in their planning funding from HUD, the basic water
quality management planning job is the  same. The only real differences
are differences of degree brought on by  population size  and distribu-

Over recent years, areawide planning organizations have become more
experienced as the Congress writes more areawide planning requirements into
functional grant in aid  programs.  Areawide planning on an intergovern-
mental basis is now required as a condition to receipt of certain grant funds
for programs dealing with:

             Water and Sewer (HUD - FHA(Ag) -'EPA)
             Economic Development (EDA)
             Air Pollution Control (EPA)
             Health Facilities and Hospital Construction (HEW)
             Juvenile Delinquency (HEW)
             Housing (HUD)
             Historic Preservation (HUD)
             Open Space Land Acquisition (HUD)

            Law Enforcement Assistance  (JUSTICE)
            Manpower (LABOR)
            Highways  (TRANSPORTATION)
            Urban Mass Transit (TRANSPORTATION)
            Community Action Operations (OEO) .

Where there is an areawide planning agency, and where it has been desig-
nated as the clearinghouse under OMB Circular No. A-95, the areawide
agency is in effect the coordinator of all regional and areawide planning
and Federal construction grant applications to carry out such plans. The
review and comment procedures set up under A-95  and required by HUD
regulations ask the clearinghouse to set  forth  the relationships between
functional planning and applications for grants with overall  areawide com-
prehensive planning and the goals and objectives of the communities in
the region.  Grant applications have to be consistent with the areawide
functional planning and programming which in turn must be consistent
with the areawide comprehensive plan.

Areawide planning agencies have had a variety of antecedents.  Almost
all of them have come  into existence,  however,  in order to  permit the
communities in the area to become eligible and to continue  eligibility
to receive Federal financial assistance.

The policy boards of areawide agencies are representative.-  of the units
of local general government (cities and counties) in the region.   It is at
this level that intergovernmental policy matters are settled  and established.
In effect, the  Congress has asked local  cities and counties to get to-
gether through their areawide planning organizations and to determine
among themselves those  matters  where intergovernmental cooperation
at the local level is essential.

Cities and counties by themselves and individually just simply cannot
cope  with the  transportation or water pollution problems,  for example,
of an entire region.

State and Federal governments  can set standards and offer incentives for
action, but the localities acting  together must make the local institu-
tional arrangements to meet these standards on the ground and in the region,

It must be admitted that the capabilities and capacities of local regional
councils to do a technical planning job and  to arrive at policy consensus
vary widely as between the almost 400 areawide agencies in the  country
that have been recognized as regional clearinghouses for OMB Circular
No. A-95 purposes.  Nevertheless,  the fact remains that these areawide

organizations are taking their place as an integral and essential part of
the governmental structure of the country.  State Water Quality Manage-
ment and State Planning Offices should consciously engage in the build-
ing and strengthening of these agencies.  Too much depends on them to
do otherwise.






As a result of the interviews held in the States and EPA Regional Offices
visited and extensive contacts  with planning organizations in many other
states,  a series of problems have been identified.  These problems cur-
rently pose serious impediments to  the development of the plans called
for by the "Guidelines".  Action recommendations are  made in light
of these defined problem areas.

As has been pointed out in this paper, the development of plans having
the sophistication and thoroughness called for by the "Guidelines" re-
quires closely coordinated action by several sets of governmental units.
Basin planning alone will require coordination of the activities of the
State Water Quality Management agency,  the State Water Conservation
and Development agency, Basin Planning Organizations, if any  are
designated, and interstate basin organizations.

A second  set of agencies  focuses on areawide, comprehensive planning.
This set includes the Office of State Planning,  the  Community Affairs
agency, if such exists, the sub-state areawide  planning organizations,
and other  areawide organizations with responsibilities related to water
quality.   These agencies  have highly varied capabilities, authorities,
resources, and sources of support.

Formal and clearly  recognized intergovernmental arrangements are needed
for planning both within and between these sets of agencies.  The exis-
ting relationships in the three States surveyed varied greatly in strength
and extent.  Few existing and established relationships were  built on  the
"Guidelines".  There is a need to even out the arrangements,  bringing
in units not currently included,  and strengthening uncertain or little
used channels  of coordination.  There is also a  need to set up intergovern-
mental processes specifically geared to water quality management plan-
ning within the institutional framework described in Section II of this report.

Intergovernmental arrangements need to be based on formal agreements
on the division of labor, the exchange  of resources and information,  the
timing of activities, and the coordination of decisions. Such arrangements
also depend on personal contacts and commitments to daily, informal co-
operation.  Both formal  and informal relationships need to be strengthened
for water quality management planning. At the State  level, the State
Water Quality Management Office has to be  the lead  agency in  making
these arrangements with strong involvement  and  cooperation from the State
Comprehensive Planning Office.

It is clear that neither the state agencies nor the areawide planning or-
ganizations had the funds, manpower, data,  and equipment needed for
developing water quality management plans.  There is danger that the
deadlines will not be met or that the planning organizations will be
forced to neglect their other on-going activities in order to complete
the plans in time.  The provision of additional funds by state legisla-
tures and local governments without substantial federal assistance is
not now  happening  on a wide scale.  The  shortage of State funds due
to the recession and past lack of supportive attitudes toward compre-
hensive  planning in terms of State  priorities make local resources  diff-
icult to tap.  Responsible agencies will clearly  be turning to the appli-
cable sources of Federal planning assistance with the result that they
will also be insufficient to meet the demand.

EPA has  a clear responsibility to redress this widespread lack of re-
sources. Legislation now pending before Congress does provide a
broader funding base for planning.

The extent to which responsible State officials have begun to convert the
"Guidelines" into work programs vary greatly. Those States with some
thinking underway tend to focus on the basin  planning activities of the
water pollution control agency, rather than on the work accomplished
and programmed through areawide planning organizations.

There is little recognition of the tasks involved in integrated compre-
hensive, areawide planning with functional planning in water quality man-
agement;.  A complete and detailed work plan that encompasses both basin
and areawide planning is essential  to the development of task oriented
intergovernmental arrangements and to the assessment of resources
needed for planning.  Although the areawide planning organization is re-
quired to adopt the  EPA required metropolitan/regional planning as part of
their comprehensive planning process, the state role becomes important
in coordinating the  planning activities at the state  am? areawide  levels
to avoid duplication.

It is recognized that all areawide planning agencies receiving HUD  701
funds are  required to develop work  plans  and programs.  What is being
said here  is that State Water Quality Management and State Planning
Offices do not have copies  and generally are not cognizant of these
work plans.  They should be.

In order for the State Water Quality Office to adequately complete the
statements required by Section 7  of the Water Pollution Control Law,
the annual State  program plan, and to enunciate completely the State's
"strategy  for accomplishing that program", a clear understanding of
where  each areawide planning agency stands in its own water quality
management planning is essential.

Integration of State level basin planning work programs with each area-
wide planning agency work  programs will be necessary to the develop-
ment of such a programmed  strategy at the State level.

In a new joint letter to regional offices issued in late September, HUD
and EPA have  issued instructions that will begin to work toward this
end.  The instructions state:

        "  ...  it is requested that for each State, the EPA and
       HUD Regional  Offices meet, and develop, with the  State
       water quality and  comprehensive planning organizations,
       procedures  for coordinating how the planning requirements
       are to be accomplished through existing APO's (areawide
       planning  organizations) and State agencies . . . The agree-
       ments developed should be  completed by December 31, 1971 . "


Disagreements and uncertainties have arisen concerning

       •    the content of the various plans and  their interrela-
            tionships, especially the Basin and Areawide Plans
            as they relate to State Program Plans under Section
            7, State Implementation Plans under  Section 10, and
            Engineering Design Plans for projects receiving con-
            struction grants under Section 8 of the FWPCA as amended.

       •    the relationships between the time frames  for interim
            plans, fully developed plans, and the scheduling of
            construction projects .

       •    the relationsips between the boundaries of Basin
            and Areawide  Planning Jurisdictions and Organiza-
            tions .

Confusion on the  relationships between the  various plans has arisen be-
cause of piecemeal development of planning requirements.  The Guide-
lines definition of the differences between basin and areawide plans ap-
pears to State officials  to call for some duplication.  There is  a need to review
the content  of the  various plans with the objective of clarifying and sim-
plifying the  States' paper work.  Although the Guidelines  seem quite clear
to the authors of this report, when related to past practices  difficulties
in interpretation seem to arise. These difficulites should  be worked out
as the Guidelines  are in fact applied and the intergovernmental structure
for Water Quality Management planning is perfected and work is actually

Problems arise in fitting presently scheduled construction  schedules,  in-
terim plans, fully developed plans,  and  the Annual Lists together in a
unified time frame.  The scheduling  of "interim planning to lead in a log-
ical sequence toward fully developed plans  within the  least possible

amount of time" is specified by the Guidelines.  The Guidelines also
state that interim plans may be used "prior to July 1,  1973" and that
"facilities construction grant awards" will not be made in the absence
of water quality management plans after July  1, 1973.  Presumably,
grant awards made during fiscal year 1973 will be based  on interim
plans even though some of the actual construction activities will occur
after the July 1973 deadline.   The States need additional guidance on
the time frame to be  covered by each plan submitted between now and
the deadline.

It is quite  clear to the authors of this report that most of the so-called con-
fusion that is arising is  in reality based on the fact that the Guidelines are
new and that it is easier to excuse  lack of action on the  basis of "confu-
sion and conflict" than it is to, in fact,  study, seek understanding, and
apply the  planning system that the Guidelines spell out.  Most of this
kind of "confusion"  will work itself out as state agencies find that EPA
and HUD mean  business and that the Guidelines are firm requirements.

This problem stems in large part from past emphasis of pollution control
activities on construction of waste treatment facilities, with or without
planning.  Sanitary engineers  have usually been in the position of design-
ing plants to correct for known and obvious deficiencies in water quality
due to untreated waste loads.  The  "Guidelines",  with their emphasis on
basin, areawide, and comprehensive planning are  a big step from  the "fix
it" or "catch up" orientation of past efforts.  Because of this historic
emphasis and due to basic unfamiliarity with planning and the planning
process, there are many water pollution control personnel who  fear that
planning will mean red tape,  paper exercises, and delay, rather than
a means  of saving limited resources.  There is little appreciation  for the
savings that can result from considering basin and regional alternatives
or from controlling land use, both of which are essential parts  of the plan-
ning process.


Generally speaking, the plans that have been prepared have been  inade-
quate.  Interim plans that have been prepared tend toward individual pro-
ject justifications rather than elements of broad water quality management
plans.  Alternatives and most cost-effective solutions have not been care-
fully examined.

As time goes on, a very much higher level of performance is going to
have to be demanded.

Metropolitan/regional  plans are going to have to be prepared in suffi-
cient detail that engineering design contracts can be let based on the
plans.  Engineering design firms so retained would not then have to go
back and recalculate population, land use, catchment areas, waste
loads, and other factors.

Metropolitan/regional  plans have erred on two sides.  One, they may be
too general and not in  enough  detail to establish priorities and provide
the basis  for letting construction design contracts.  Or, two,  they have
simply been "plumbing plans", lacking in consideration of future land
use, population trends or trends in economic activity.

As experience is gained,  and  as planning capability is established,  both
basin and areawide plans will have to consider the adequacy of and need
for clear and reasonable land  use controls as  an  integral and essential
part of water quality management planning . This is particularly true of
basin plans developed at  the State  level.  Control of future location of
economic activity on a basin-wide  basis will  become more of a  concern
of State governments.  This is one  point where close working relation-
ships between the State Water Quality and Comprehensive Planning
Offices is absolutely essential.

Basin plans have-in the past relied too heavily on monitoring and meas-
uring at the expense of looking to patterns of future development. A
good deal of this emphasis has been the result of the need to correct
past deficiencies and  a reluctance  to seek an understanding of, much
less to direct,  patterns of future settlement and development.

All planning agencies, State,  areawide, and local, that receive HUD
planning assistance money (701) are required  by  law to include  a hous-
ing element in their comprehensive planning program.  While these
housing elements have not generally been completed around the coun-
try, this is one  more area for  planning integration.  There should be
complete integration of water  quality  management plans with housing
and land use planning  and programming at the  State and areawide levels.
Land use controls at the State and areawide levels must play an increas-
ingly critical role in maintaining the validity of water quality manage-
ment plans.

By the July 1, 1973 deadline,  these matters of planning integration
should be assured and the quality of plans prepared should be vastly

Re commend at ions

In addition to some suggestions contained in  the foregoing problem state-
ments, it is strongly urged that EPA-WPO formally organize a national
series  of workshops  that would involve all EPA and  HUD Regions, and
HUD Area  Office people.  State Water Quality Management Office and
State Comprehensive Planning Office personnel would be invited.

Perhaps five such workshops could cover the  entire  country.  On the other
hand, it may be desirable to have one such workshop series for each of
the Federal regions.

The subject matter to be covered in lectures, panel discussions ,_and
question and answer periods would include:

        1 .   Interpretations of the Guidelines
        2.   Clarification of the respective HUD and EPA
        3.   Water Quality Management Planning Work
            Program development for
                  a.  Basin Planning
                  b.  Areawide Planning
        4.   Suggestions for perfecting intergovernmental
            institutional arrangements to accomplish the
            planning  mission contemplated  by the Guidelines
        5.   Relation of Interim Plans  to completed functional
            Water Quality Management Plans
        6.   Plan and  project application processing  pro-
        7.   Perhaps, some show and  tell success stories
            based on case histories.

Properly developed written materials and visual aids should be prepared to
maximize the teaching benefits of the workshops.

Related to  the above suggestions is a recommendation that a joint HUD-
EPA letter be sent to all Regional and Area Offices to the effect that by
a  certain deadline, each State would  be requested to file an organiza-
tional plan for the accomplishment  of their Water Quality Management
Planning.  Such a plan would clearly  indicate the organizational  arrange-
ments made to accomplish basin planning and areawide planning. The
designated APOs and APJs would be set forth.   The State's organizational
report should be signed off by both the Water  Quality Management Office
and the State Comprehensive Planning Office.  If separate Departments

of Community Affairs are in existence, they should be a part of the
development of the organizational plan.

Once such an organizational plan is developed and filed,  the Annual
State Program Plan submitted under  Section 7 would reflect updating
of the organizational plan and the strategy for accomplishing the State's
planning program.

Instructions for the preparation of the annual submittal under Section 7
should be examined annually so that State Program Plans will reflect
the dynamics of the Nation's Water Quality Management Program as
it develops and approaches the clean water goal set by the legislation.

The September  1971 joint HUD-EPA  memordandum starts in this direction,
This recommendation is made here to emphasize the  necessity of com-
pleting  the necessary organizational steps so that State Water Quality
and  State Comprehensive Planning Offices can monitor the areawide
planning efforts and be knowledgable as to  the progress that is  being
made toward the meeting of the July 1973 planning deadline.

                           IV .  A GUIDE FOR STATE ACTION
        Although some of the problems met in implementing the Guidelines
        arise from the patterns of Federal-State relationships,  many arise from
        the existing relationships  among agencies at the State  and sub-State
        level.  Since the Guidelines effectively require certain types of plan-
        ning activities and plans as prerequisites for federal grants,  most of
        the actions to overcome existing problems and implement the  Guidelines
        must be initiated at the State level.

        This section outlines the major areas of activity that State agencies
        should undertake in implementing the Guidelines.  The focus  is on the
        development of the intergovernmental relationships needed for the plan-
        ning process. The approximate flow of activities is shown on the chart
        which follows.
Does It
                Define Planning Tasks, Products,
            Work Schedules,  Participating Institutions
Survey Available
Resources and
Establish Division of
Labor and Responsibilities
         Identify Re-
         source  De-
                        Develop Coordinating
                        Mechanisms and Pro-
                      Locate and
                      Tap Addi-
                      tional Re-
                                             Strengthen Planning
                     Conduct Water Quality
                     Management Planning

Work planning is a key element in initiating  State activities for water
quality management planning.  A work plan identifies the specific plan-
ning tasks to be performed, the products to be prepared,  the overall
work schedules and the agencies that will participate  in the work.
This information is essential for developing agreements for intergovern-
mental arrangements and for the development of planning  assistance
grant applications.

The  work  plan should usually be developed by the key State agencies
in water quality management planning — the Office of State Planning
and  the State Water Quality Office.   It  can be the primary activity for
developing stronger working relationships between the two. The first
step toward the work  plan is to restate  the "Guidelines" in task form.
Each of the major tasks thus identified  can then be divided into a se-
quence of sub-tasks.  As the analysis is  done, relationships between
tasks are developed and agencies to perform tasks are identified.  The
work plan should also be reviewed with the regional planning agencies
to provide their view of the areawide planning tasks,  keeping in mind
that the Guidelines provide that:

     1 .   The basin plan should provide the main input on
          hydrology, location,  and characterization of waste
          sources  (including storm water, combined sewers,
          non-point sources),  treatment levels (present and
          future),  water quality effects  (present and future),
          land use, basin-wide alternatives  (such as trans -
          basin diversions, flow augmentation), and basin-
          wide priorities for construction.

     2.   The metropolitan/regional  plan should provide the
          main input on land use,  growth, estimated waste
          production, process design, service areas, collec-
          tion systems,  sewer  drainage areas, investigation
          of local and regional alternatives,  cost estimates,
          financing, and institutional arrangements.  If no
          metropolitan/regional plan is to be prepared, the
          basin plan should then include the expected envir-
          onmental impacts of any projects proposed for the

As indicated in early parts of this report,  HUD requires all areawide plan-
ning agencies to prepare work plans that program the  tasks to be performed,
including water quality management planning.  The State should assemble,
evaluate, and integrate these work  plans in order to program the necessary
statewide planning effort that will be necessary.

The check list set forth below is intended to be general and to be used as
a guide to the preparation of basin and areawide water quality management
plans.  In addition, the Guidelines  contain very effective outlines of con-
tent for both Metropolitan/Regional and Basin plans that should  be referred
to in the development of work plans.

 Some of the items to be considered in work planning are listed below:

    Planning Tasks

            Choose objectives
            Identify planning  premises and problems
            Set standards;  allowable waste loads
            Identify alternatives for waste  management and
            Collect Data
                  -  hydrological
                  -  economic
                  -  demographic
                  -  land use
                  -  waste loads
                  -  existing system — location and capacity
            Estimate Costs and Resource Requirements
            Evaluate Effectiveness of Alternatives
            Evaluate Environmental Impacts
            Identify Legislative and Institutional Changes
            Assign Priorities and Develop Management Strategy
            Develop  Financing Methods

            State Implementation Plan
            State Program Plan
            Basin Plans
            Areawide Plans
            Interim Plans

            Deadlines for Completion of Products
            Schedules for Completion of Individual Tasks

    Updating Procedures and Relating Areawide and Basin Plans
Resource and Financial Planning is a second important activity in implemen-
ting the Guidelines.  This involves the estimation of the resources needed to
complete the planning tasks, the surveying of available resources and
capabilities, the identification of deficiencies, and the tapping of add-
itional resources. The resources considered should include funds,
trained  manpower, equipment, data, and existing working relationships
between institutions controling the resources.

Additional resources can be sought on the basis of well defined work
plans from many sources.  Existing State appropriations and bond issues
can often be  used for planning.  Equipment can be borrowed,  manpower
detailed, and data transferred.  In most cases, however, even the best
efforts within the limitations of the State will need  to be supplemented
by Federal assistance.

There are many sources of Federal funds for planning assistance.  Al-
though none are currently adequate for water  quality management  planning,
sufficient resources  can  often be had by combining  sources and increases
are possible  if demand is well articulated. There are also  possibilities
that new or expanded sources of funds will be made available  from var-
ious Federal programs in  response to demonstrated need.

The following Federal programs provide assistance  for water quality man-
agement planning .

       Basin Planning Grants under Section 3 (c) of the Water
       Pollution Control Act

       EDA Planning Grants

       Farmers Home Administration,  Department of Agriculture

       Water and Sewer Functional Planning under  Section 701 ,
       Department of Housing and Urban Development

       Training Grants from the Environmental Protection Agency

       Economic Development Administration Planning Grants to
       Eligible Agencies
 A new mechanism is coming into being that will facilitate the appli-
 cation for funds from several Federal programs.  Under the Integrated
 Grant Administration (IGA) Program to be set up by a new Office of
 Management and Budget Circular, it will be possible for public agen-
 cies  to apply for a number of Federal assistance grants  through a
 single application.  Integrated Grant Applications will be processed
 under the auspices of the Federal Regional Councils and administered
 through a lead Federal, agency.  A key objective of the IGA program is
 "to encourage the 'nesting concept' of work program development,
 whereby State and local planning agencies jointly undertake common
 or coordinated activities and share staff. "

 The IGA will make it possible to tap planning assistance funds from var-
 ious  sources  to finance  the development of water quality management
 plans for a  State.  For example, Arkansas  is planning to submit an in-
 tegrated grant application for Section 3(c)  funds from EPA,  planning
 funds from Farmers Home Administration and from HUD.  Also included
 in the application will be requests for Solid Waste Management Plan-
 ning  funds from EPA.

 The IGA also  provides strong leverage for  unifying and coordinating
 planning activities.  Because it provides a funnel through which funds
 from  several sources flow,  it also provides a focal point for manage-
 ment of the grant  by the State.  A State can unify the administrative
 activities associated  with planning assistance and in the process
 unify and coordinate the activities of other State and regional planning
 agencies  involved in water quality management planning.  Once again,
 an active role at the State level is called for.

In addition, planning may be declared an allowable expense  under the
Waste Water Treatment Works Construction Grant Program, Section 8
of the Water Pollution Control Act.  While  this represents a sizeable
source of funds, disbursement is made on a reimbursable basis.  Since
the work must be "in place" before  payment is made, a revolving fund for
forward financing of planning is needed.

The use of Section  8  construction funds for planning would be facilitated if
the States established revolving  funds capable of financing planning as well
as construction.  Basin and areawide planning costs could be established
on a pro rata basis for each project undertaken.  The revolving fund would
be repaid for planning advances as  well as for construction advances as
Section 8 funds were paid to the  managing  agency on completion of the

A third type of implementing activity, perhaps the most important in the
long run, can be called institution building.  Water quality management
planning will be a continuing enterprise and may well  increase in impor-
tance as population and economic growth press ever harder on existing
water resources. Eventually, a close relationship  will be  essential be-
tween waste water  management and treatment  plans and  the comprehensive
areawide  plans for  land use, water supply, and the provision of public fa-
cilities and services. This will require close working relationships be-
tween the governmental institutions charged with the related planning
and management activities.  Implementation of the  Guidelines provides
a prime opportunity for strengthening  these institutions and their inter-
relationships .

State officials should take a more active role  in building the new insti-
tutional arrangements needed for water quality management planning.
These arrangements need to reflect the pecularities of the  existing in-
stitutional structures and the emerging planning system. But they
should also recognize that a task of the magnitude  of water quality
management planning can be a  powerful stimulus for growth and change.
Care  should be taken to guide this growth  so that it strengthens the State
and regional agencies responsible for comprehensive planning as well as
those with narrower functional  responsibilities.  This  strengthening can
occur through increased competency and through increased political

State governments have several means of building new institutions.
The "Guidelines" call for the Governor to designate planning agencies.
This enables State  officials to establish a  consistent and coordinated
team  of planning agencies.  The  States also have a coordinating role in

compiling  and certifying  plans and in reviewing construction grant
applications.  These levers give an additional means for guiding the dev-
elopment of intergovernmental arrangements.  Needless to say, these
policy levers must be used actively in pursuit of planning and  institu-
tional development.

There are  several types of institutional arrangements that States should
establish to implement the "Guidelines".  Relationships  are needed

   •   To coordinate activities of basin planning organizations;

   •   To coordinate comprehensive and water quality  manage-
       ment planning activities at the regional  level;

   •   To coordinate basin  planning and areawide  planning activ-
       ities with each other;  and

   •   To integrate the basin and areawide plans into the State
       Program Plan.

To establish these institutional arrangements, the  Office of State Planning
should play an active role in developing agreements between the various
agencies,  specifying

                 the division of labor;

                 mechanisms for the exchange of resources
                 and information;

                 the timing of activities;

                 the coordination of key decisions.

The best starting point for such agreements is usually the identification of
personnel in the various agencies with the authority, competency, and
willingness to participate actively in the planning  process.

To this end, State Planning and Water Quality Offices  should establish
working teams of competent professionals and specialists to provide direct
technical assistance to sub-State areawide planning agencies.  A sense
of teamwork and partnership should  be established between State and sub-
State agencies.  Such mutual assistance  is essential to  the accomplishment
of clearly stated and understood common water quality  management goals.

 * U. S. GOVERNMENT PRINTING OFFICE :1972—484-484/149