NACEPT
Shaping the Nation's Environmental Policy
National Advisory Council for Environmental Policy and Technology
July 30, 2007
Administrator Stephen L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Re: Sustainable Water Infrastructure Recommendations
Dear Administrator Johnson:
On behalf of the National Advisory Council for Environmental Policy and Technology, I am
pleased to forward our initial findings and recommendations on EPA's Sustainable Infrastructure
Watershed Pillar. NACEPT endorses the recommendations in this report, which our sustainable
water infrastructure workgroup developed.
EPA asked the Council to identify ways the Agency can better advance sustainable approaches to
water resource management and infrastructure to meet watershed goals. The nation faces a
critical challenge in sustaining and expanding our water supply and our water and wastewater
infrastructure to continue to enjoy the benefits of safe, clean, plentiful water. One element EPA
is using to address this problem is the watershed approach.
We have concluded that, in general, neither policymakers nor the public have a clear
understanding of: (1) the concept of a watershed approach to water management, (2) the
relationship between a watershed approach and the urgent need to address water supply, water
quality, and insufficient or deteriorating water infrastructure, or (3) the benefits of a watershed
approach. Although a few excellent examples demonstrate application of these principles and
concepts, those examples are isolated, are not comprehensive solutions even within that
watershed, and are not part of a nationwide movement or state-of-practice.
NACEPT offers a set of recommendations for how EPA can advance wider and more effective
use of the watershed approach to sustainable water infrastructure. These recommendations fall
into four categories of specific steps EPA should take: (I1) lead by example, including organizing
within EPA and naming an Agency-wide sustainable watershed coordinator with responsibilities
for aligning all pertinent EPA activities and interactions with other federal agencies to help
advance watershed principles; (2) educate, communicate, and provide information, including
illustrating the urgency of the need to adopt a watershed approach for sustainable water
infrastructure; (3) encourage, facilitate, and fund collaboration, including leveraging and
participating in other agencies' planning activities; and (4) develop, use, and fund specific tools
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employing, for example, EPA's stormwater phase II authority, NPDES permits, state revolving
funds, trading, total maximum daily loads, and more.
In addition to the recommendations, this report also describes the background of our processes
and work, provides our findings based on our experience and research, and includes various
appendices with helpful materials. And in the second phase of our work, to be submitted in
2008, we will endeavor to identify what benefits are already known, ways EPA could further
develop this information, and ways EPA can communicate this information to stakeholders.
We appreciate the opportunity to provide these recommendations and hope this report will be
helpful to you and the Agency in achieving EPA's mission. Of course, we would be happy to
meet with you and others about the recommendations in this report at any time.
Sincerely,
John L. Howard, Jr.
NACEPT Chair
cc: Dan Watts, Chair, NACEPT Sustainable Water Infrastructure Workgroup
Marcus Peacock, Deputy Administrator
Charles Ingebretson, Chief of Staff
Ray Spears, Deputy Chief of Staff
Benjamin Grumbles, Assistant Administrator, Office of Water
Sheila Frace, Director, Municipal Support Division, Office of Wastewater
Management, Office of Water
Benita Best Wong, Director, Assessment and Watershed Protection Division,
Office of Wetlands, Oceans and Watersheds
Rafael DeLeon, Director, Office of Cooperative Environmental Management
Sonia Altieri, NACEPT Designated Federal Officer
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NACEPT's Initial Findings and
Recommendations on EPA's Sustainable
Infrastructure Watershed Pillar
My 2007
The National Advisory Council for Environmental Policy and Technology (NACEPT) is an independent federal
advisory committee that provides recommendations to the Administrator of the U S. Environmental Protection
Agency (EPA) on a broad range of environmental issues. The findings and recommendations of the Council do not
necessarily represent the views of EPA.
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Table of Contents
I. Executive Summary I
II. Background 3
III. NACEPT Findings for Phase I
General Comments 4
Specific Findings and Responses by NACEPT to Questions in the Charge 6
IV. Recommendations 20
Lead By Example 20
Educate, Communicate, and Provide Information 21
Encourage, Facilitate, and Fund Collaboration 25
Develop, Use, and Fund Specific Tools 28
V. Appendices
Appendix 1: Charge for Developing Recommendations on U.S. EPA's Sustainable
Infrastructure Watershed Pillar 32
Appendix 2: NACEPT Sustainable Water Infrastructure Work Group Members 39
Appendix 3: Schuylkill Action Network Fact Sheet 40
Appendix 4: Portion of Federal Highway Administration Request for Applications for
"Integrating Transportation and Resource Planning to Develop Ecosystem Based
Infrastructure Projects" 42
Appendix 5: EPA Region I Charles River Project Press Release 48
Appendix 6: Nitrogen Trading by Connecticut POTWs 51
Appendix?: California Regional Blueprint Planning Program 55
Appendix 8: Envision Utah 56
Appendix 9: Jefferson Area Eastern Planning Initiative 58
Appendix 10: Greenseams Program - Milwaukee Metropolitan Sewerage District 62
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NACEPT's Initial Findings and Recommendations on EPA's Sustainable Infrastructure Watershed Pillar
July 2007
I. Executive Summary
EPA asked the National Advisory Council on Environmental Policy and Technology
(NACEPT) to identify ways the Agency can better advance sustainable approaches to water
resource management and infrastructure to meet watershed goals. The nation faces a critical
challenge in sustaining and expanding our water supply and our water and wastewater
infrastructure to continue to enjoy the benefits of clean and safe water. One element EPA is
using to address this problem is the watershed approach.
John Wesley Powell described a watershed as "that area of land, a bounded hydrologic
system, within which all living things are inextricably linked by their common water course and
where, as humans settled, simple logic demanded that they become part of a community." A
watershed approach thus is a process of including broad stakeholder involvement across the
community to coordinate management of all aspects of policy and action affecting the water
within hydrologic boundaries.
EPA is working diligently to help communities address this issue. In just the last year,
EPA has announced several watershed-based initiatives, resources, and tools, including
promotion of green infrastructure to reduce stormwater runoff and hosting a national conference
on how to pay for water in the future.
EPA broke our charge into two phases. In the first, EPA asked NACEPT to answer by
this summer five specific questions about collaboration, support, and overcoming barriers. In the
second phase, to be completed in 2008, NACEPT will consider the question of benefits.
Our initial report contains four main sections: (1) a background of our processes and
work, (2) our findings based on our experience and research, (3) our recommendations, and (4)
various appendices with helpful materials.
We have concluded that, in general, neither policymakers nor the public have a clear
understanding of: (1) the concept of a watershed approach to water management, (2) the
relationship between a watershed approach and the urgent need to address water supply, water
quality, and insufficient or deteriorating water infrastructure, or (3) the benefits of a watershed
approach. Although a few excellent examples demonstrate application of these principles and
concepts, those examples are isolated, are not comprehensive solutions even within that
watershed, and are not part of a nationwide movement or state-of-practice.
In response, NACEPT offers a host of recommendations for how EPA can advance wider
and more effective use of the watershed approach to sustainable water infrastructure. These
recommendations fall into four categories of specific steps EPA should take: (1) lead by
example, including organizing within EPA and naming an Agency-wide sustainable watershed
coordinator with responsibilities for aligning all pertinent EPA activities and interactions with
other federal agencies to help advance watershed principles; (2) educate, communicate, and
provide information, including illustrating the urgency of the need to adopt a watershed approach
for sustainable water infrastructure; (3) encourage, facilitate, and fund collaboration, including
leveraging and participating in other agencies' planning activities; and (4) develop, use, and fund
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specific tools using, for example, EPA's stormwater phase II authority, NPDES permits, state
revolving funds, trading, total maximum daily loads, and more.
As we learned in this first phase, the benefits of a watershed approach are neither well
defined nor well known. Community stakeholders will be attracted to a watershed approach only
if they see the direct benefit to their organization's mission. In our second phase, we will
endeavor to identify what benefits are already known, ways EPA could further develop this
information, and ways EPA can communicate this information to stakeholders.
In addition, we focused in this first phase primarily on water infrastructure: the pipes and
sewers and treatment plants of drinking water and wastewater. We did not adequately explore -
and so we will explore more fully in the second phase - the interrelationship of these issues with
the elemental issue of water supply.
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II. Background
EPA has asked the National Advisory Council on Environmental Policy and Technology
(NACEPT) to provide assistance to the Agency in advancing cost-effective and sustainable
approaches to water resource management and infrastructure to meet watershed goals. The
Agency belief is that the watershed approach is critical to protecting and restoring the nation's
waters. Furthermore, EPA advocates that full realization of the benefits of the watershed
approach will come from integration of the approach into the comprehensive planning processes
at the state, regional, and local levels.
One of the most critical challenges facing the Nation is the need to sustain our water and
wastewater infrastructure to ensure that the public can continue to enjoy the environmental,
health, social, and economic benefits that clean and safe water provide. Our nation's aging water
and wastewater systems together with growing and shifting populations will require significant
investment for new infrastructure along with maintenance and upgrade of existing facilities.
Current approaches and technologies, along with available investment sources, may not be
adequate to meet the needs. One component of the EPA approach to addressing this problem is
the watershed approach, which is generally understood to mean broad stakeholder involvement,
hydrologically defined boundaries (that may cut across political boundaries), and coordinated
management across all aspects of policy that affect water. The approach benefits from
participation and active involvement of stakeholders at all levels from federal to states and tribes
to local government and utilities.
Yet, questions remain about how best to facilitate the use of the watershed approach in
creating a sustainable water infrastructure. The Agency wants to focus its resources most
effectively in areas such as promoting collaboration among stakeholders, assisting local
government in building support for the watershed approach, encouraging grassroots support for
implementation of the approach, and identifying barriers that may slow implementation. In
addition, the Agency is interested in how best to use information and data from successful uses
of the approach that communicate the benefits that can be achieved.
The full charge, and additional background material, from EPA to NACEPT is contained
in Appendix I. In summary, NACEPT was asked to answer five specific questions that involve
the issues of collaboration, support, and overcoming barriers with the request that answers be
provided in 2007. A second phase of the request asks NACEPT to consider the question of
benefits and is to be completed in 2008.
NACEPT Approach'
NACEPT established a Work Group to respond to the charge from the Office of Water.
The Work Group held three meetings, in conjunction with NACEPT Council meetings. In
addition, several conference calls were held. The Work Group followed two paths to obtain an
initial understanding of the current approaches and activities within EPA in the area of use of a
watershed approach to sustainable water infrastructure as well as learning about activities and
'The intention of these discussions and recommendations is to include Tribal Governments. Any omission of Tribal
Governments when referencing State or Local governments is unintentional.
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needs of stakeholders who are responsible for addressing the sustainable water infrastructure
issues. The Work Group met with representatives of many programs within the Office of Water
and other EPA entities to learn about current initiatives and plans. In addition, interviews were
held with state, local, and private groups from around the nation who are working to include a
watershed approach to address their particular sustainable water infrastructure need. The Work
Group's thinking and recommendations were informed by these discussions and interviews.
Additional information from those interactions will be discussed in the findings and
recommendations from the second phase of the Work Group activity.
III. NACEPT Findings for Phase I
General Comments
During the course of interviews, examination and analysis of published materials, and
discussions with experts and practitioners, the NACEPT workgroup has concluded that there is
not a clear understanding broadly spread throughout the nation of the concept of a watershed
approach to water management, and there seems to be even less knowledge about the
relationship between a watershed approach and the impending need to address urgently the
issues of water supply, water quality, and insufficient or deteriorating water infrastructure.
While some excellent examples of application of the principles and concepts exist, they
often seem to emerge from independent actions at one place, not as part of a nationwide
movement or state-of-practice. Many times, even the best examples of implementation are not
able to accomplish a fully integrated program, but rather a part of such a program. This is not
meant to be a negative comment on the potential value of the approach. Rather, it is a realistic
evaluation of the progress the concept has made. In essence, it is a very young concept in terms
of implementation. That means that one of the key barriers holding back it implementation is
lack of knowledge about what a watershed approach includes and entails. Moreover, effort is
necessary to answer other important questions at the local level in a way that encourages even
consideration of the watershed concept. These questions include: what is the value of even
considering it by an often disparate collection of public and private entities within a watershed
area? Where can local groups go to get help to make it pay off for them? Local groups have
some immediate needs and issues and this seems to be a long-term approach. How can they
meet current needs with something so distant? How can they really estimate the benefit?
It is evident that EPA is working to help address these questions. For example, during
the time NACEPT has been working with EPA on this issue, several announcements of
initiatives, resources, and tools related to a watershed approach have emerged from the Agency.
Among these are:
• an agreement to promote the use of green infrastructure to reduce stormwater runoff and
sewer overflows
• a national conference on paying for water that provided opportunities to discuss
watershed approaches
• a release of a watershed planning tool
• a focused set of activities, parallel to this initiative with NACEPT, that attempts to
understand watershed issues from a utilities perspective
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EPA has identified an important role of empowering the process through education about
the mechanics and benefits of the watershed approach, encouraging consideration of the
approach and facilitating implementation through creative and supportive use of permitting and
existing financing options. At the same time the Agency works to minimize short comings and
penalties because their resulting negative publicity is likely to inhibit initiatives by others in the
future. NACEPT agrees with this approach and urges expansion of the approach as discussed
later in this document. These tools of education, encouragement, and creative use of permitting
and funding capabilities are important for EPA because much of the planning and work to
address the water sustainability problem from a watershed perspective is at the state, tribal, and
local level and not at the national level where EPA can take more direct action.
Some additional specific approaches and initiatives undertaken by EPA to facilitate and
promote a watershed approach to sustainable water infrastructure are included in the following
description of current EPA actions.
While EPA cannot require states, tribes, and localities to adopt the watershed approach, it
does use its tools to create incentives, educate constituencies, and remove barriers. Further,
when EPA becomes aware of a state's struggles with competing priorities and limited resources,
EPA tries to identify areas to give flexibility while maintaining progress in base programs and on
key priorities. Some examples of how the watershed approach is currently woven into EPA's
programs include:
• NPDES (National Pollutant Discharge Elimination System) Watershed-Based Permitting
o Permit writer training incorporating watershed approaches
o Watershed-based permitting implementation and technical guidance
o Trading policies, tools and training (point-point and point-nonpoint)
o Wet weather strategies such as green infrastructure
• Section 106 Priorities
o Strategic Plan & GPRA (Government Performance Results Act) priorities are
highlighted during EPA-state workplanning
• Clean Water SRF (State Revolving Fund) criteria providing incentives and flexibility for
targeting watersheds
• Nonpoint Source Program
• TMDLs (Total Maximum Daily Loads): EPA encourages states and tribes to develop
TMDLs on a watershed basis (see EPA 1991 Guidance for Water Quality-based
Decisions: The TMDL process).
• Cross-Program Coordination
o Watershed sub-objective strategic targets include watershed outcomes, to which
all surface water programs must contribute
o Outreach and capacity building efforts, such as the targeted watershed grants,
access to many tools via the web including a watershed portal, etc.
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o Sustainable Infrastructure Initiative and Green Infrastructure
- While this is a new initiative, the Office of Water is working to develop an
action plan that integrates Clean Water Act and Safe Drinking Water Act
programs on a watershed-basis, to the extent statutory authorities enable
such integration. This workgroup includes the active participation of the
Office of Enforcement and Compliance Assurance (OECA).
EPA Administrator Johnson considers SI (Sustainable Infrastructure) and
GI (Green Infrastructure) as part of his top priorities.
• Drinking Water Program
o Source Water Collaborative
o Long Term 2 Enhance Surface Water Treatment Rule incorporating a watershed
approach and toolbox
Aspects of these issues and resulting recommendations are discussed in the NACEPT
responses to the individual questions in the charge, which appear below.
NACEPT believes that although there are examples that show positive aspects of each of
these questions, EPA can and should go further in each case. Some examples of successes that
could serve as models for expanded activities include:
• EPA Region I issued enforcement orders simultaneously to all communities in the lower
Charles River basin in order to address stormwater pollution, identified as the primary
source of impairment (see Appendix 5).
• Connecticut POTWs have watershed based NPDES permits that allow nitrogen trading to
reduce nutrient loading to Long Island Sound (see Appendix 6).
• EPA has issued a Watershed Plan Builder Tool and a related web site
http://iaspub.epa.eov/watershedplan/planBuilder.do?pageId=5I&navld39&sessionActive
=true. In addition, there is a communication plan. The current plan for outreach is
generally limited to promoting a "train the trainer" approach, for example ten training
workshops per year for 40-80 people per workshop. The trainees would include NPDES
program managers, TMDL staff, state, tribal and local staff and watershed groups. About
4,000 watershed planning handbooks were distributed and there are 1500 requests for
additional copies. No provision was made to document the number of hits on the web or
track the impacts of disseminating these resources, although this information may be
available. NACEPT suggests that EPA develop a method to track the dissemination and
use of these tools in order to quantify the success of this communication and training
approach.
Specific Findings and Responses by NACEPT to Questions in the Charge
In the following section, questions in the charge are discussed and specific
recommendations are provided.
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Charge Question "A". How can the Agency more effectively promote increased collaboration
among drinking water, wastewater and storm water utilities, local governments, planning boards
and other stakeholders that result in collective water infrastructure priority setting under a
watershed management context through education and other means?
NACEPT Response:
Experience has demonstrated that attention and action by collaborating groups can be
generated most effectively by use of regulatory actions or by providing funding to promote
desired types of actions. In the case of promoting a watershed management approach to water
infrastructure priority setting, the use of neither of these classic strategies is contemplated. Use
of educational and related approaches can be useful, and perhaps essential. However, these types
of approaches will be most effective if they can communicate a sense of urgency, a likelihood of
success, a set of practical examples that have worked, some resources for assistance, and frankly
some assurance that regulatory complications can be avoided and that cost savings will be
realized if the watershed strategies are implemented.
To be most effective in such an initiative, the Agency will need to consider and respond
to several parameters that are discussed below.
1. Promotion of increased collaboration among these stakeholders will first require
communication of a critical need and of the advantage of collaboration.
The group of stakeholders discussed (drinking water, wastewater and storm water
utilities, local governments, planning boards and others), are not necessarily natural
allies, nor in many cases do they usually work together collaboratively. A movement
toward collaboration will occur most rapidly if a clear understanding of the need and
advantage of such collaboration can be generated. This means among other things
general educational activities for all stakeholders, and probably means as well focused
communication and education within the professional organizations for each of these
individual groups of stakeholders until key opinion leaders are convinced of the
advantages of action and effectively communicate that belief to others in the category.
For the Agency to be effective in this strategy will take careful planning, honing of the
message for each group, and a very clear statement of the regulatory complications to be
avoided and the eventual cost savings to be realized.
A possible model for this multi-faceted educational approach is currently being
implemented by the EPA Office of Water for source protection, which has developed
approaches involving professional organizations, states and local governments, and the
general population.
NACEPT will work with EPA in Phase II of this Workgroup effort to develop some
specific examples that illustrate what regulatory issues could be avoided and what cost
savings could occur. The illustrations will serve to make the point.
2. An important question is whether EPA can be effective in direct communication with this
group of stakeholders in an effort to move toward collaborative action. Would indirect
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communication through the states be more effective? Who are these groups most used to
listening to? What would be the response of states to what might be perceived as an "end
run"?
The reality of this situation seems to be that because the audiences are different, the
means of outreach should be different as well. The Agency can be most effective
working on the national level with the national professional organizations and with the
national press in order to communicate the needs and possible responses and encourage
actions. To be clear, NACEPT realizes this is already happening. At the regional level,
EPA can facilitate joint communication to and between states in the individual regions
which share watersheds and share common challenges in watershed management. EPA
Headquarters indicates that they are actively working with its regional offices to facilitate
interactions with the states. In addition, EPA is communicating with EGOS
(Environmental Council of the States) to encourage outreach to local entities in the states.
Communication and education with municipalities and local planning boards may be
most effective if done by the individual states. There are several reasons for this,
including the fact that these organizations are creations of the states and the networks of
relationships and interactions may vary widely from state to state. Educational and
communication programs tailored at the state level are likely to be more effective than a
single national program. The development of an individualized program may benefit
from a two-fold approach. Material from EPA could emphasize the national perspective
and provide information about cases where success has been achieved. Each state could
contribute local perspective that particularly emphasizes how a sustainable infrastructure
watershed approach can be developed and implemented in that particular state. The
material could provide information about state policy encouraging these types of
innovative practices. Guidelines could be provided about which state agencies need to be
contacted to obtain necessary approvals, permits, funding, inspections, or other oversight
mechanisms. Ultimately the state portion of the training will be most effective if it
conveys to the local officials that these actions are favored by the state, that procedures
are in place to facilitate their forward movement at the state level and there will be no
harm done to localities if they take this approach. EPA can help the states by providing
guidance and background about how these messages can be conveyed most effectively.
This means clearly, however, that EPA will need an effective strategy to provide
information, ideas, and resources to the individual states to facilitate the provision of the
ultimate result—educational outreach to the municipal and local stakeholders. While the
messages will need to be individualized at the state level, they should be consistent with
national goals and expectations.
3. Is the Agency prepared or can it be prepared to transmit or develop specific area and
regional information about need and existing water infrastructure capabilities to local
governments and the other local stakeholders? If not, how can these stakeholders get the
information that will support any efforts for collaboration in competition of other public
concerns? A real issue may be getting the necessary level of concern and attention in the
arena of public debate and priority setting.
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If the expectation is that local authorities and utilities will modify their planning and
operational approaches based on responses to real current and future needs and
challenges, there must be a way to provide them with locally relevant information, data,
and options in order to allow them to consider various scenarios and to make informed
choices. The Agency needs to be able to point the stakeholders to locations where this
information exists or to provide easy to understand guidance about how it can be
developed locally. Local development of data or even assembling it for convenient use
will involve costs that may impede the level of progress that is desired.
Much of the necessary information is available, although it is in different places, such as
USGS, databases connected to well protection programs, storm water assessment
program resources, and information from individual state databases. It is recognized that
data on wastewater volumes may be more difficult to assemble, but will still be useful for
this initiative. A useful approach to address this concern would be for EPA to develop
guidelines about what information and data is important to gather in order to move
forward with a watershed approach to sustainable infrastructure with specific suggestions
about where and how to gather the information for specific locations. The more detailed
this information can be, the more useful it will seem to local utilities and authorities. The
level of detail may include what specific websites could be accessed and what specific
offices can be contacted.
A larger issue related to these types of initiatives is that no group or entity is charged with
bringing together people at the local level to initiate this type of watershed approach to
sustainable infrastructure. EPA should encourage each state to identify ways to assemble
and energize local groups to begin the work to achieve the collaboration and outcomes
desired.
4. Because an effort such as this is voluntary and not regulatorilv driven, a successful
communication campaign would benefit from partnerships so that it is not seen as an
EPA-only initiative. What organizations could be lined up as interested partners? Could
they include the national associations of planners, mayors and municipal councils, water
utilities, and watershed associations?
An educational initiative such as this has multiple audiences and therefore requires
different approaches in order to be effective. Ultimately, the necessary audience is the
assemblage of rate payers and taxpayers. Informing that group of citizens can probably
best be done by a coalition of the organizations mentioned, with a key leading role by
EPA. Many ways to reinforce the message can be used by each of the stakeholders
involved. However, achieving this degree of collaboration means that preparatory
communication and education needs to be done first by EPA Headquarters and Regions
and the individual states. This will not be an easy or quick task. Careful planning and
allocation of appropriate levels of personnel will be required in order to achieve the
results needed.
There is an additional facet to the concept that this program will have multiple audiences.
That is, the audiences will vary over time as well. Specifically, although an immediate
educational program may well be successful in establishing a mindset favoring
watershed-based sustainable infrastructure initiatives, in practice actual implementation
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will come when there is a locally recognized need for expansion, upgrade, or replacement
of existing infrastructure. In essence, this means a first wave of educational programs
should establish a baseline of expectation that a watershed approach to sustainable
infrastructure is valid, preferred and advantageous. A second wave must be ready and
accessible whenever planning finally starts for changes in existing infrastructure. In
some locations, that may be immediately, while in others it may be years away. EPA
must see this effort as long-term—a set of actions that will need to be sustained.
There is an additional timescale issue that should be incorporated into the educational
program as well, and in ways that reflect the multiple audiences. That is, people need to
know and understand the long periods of time that will be incorporated into the use of
this type of infrastructure approach. For example, they need to understand the time scale
required to protect and rehabilitate natural water sources. They need to understand the
expected lifespan of any infrastructure to be installed. This type of information can be
expected to assist in decisions about investment and predictions of cost savings.
5. Is there a firm idea about who really needs to be educated and convinced? Is it the
decision makers, the professionals and agencies, and the utilities, or is it the private
citizens in the community who can urge the decision makers to act?
As discussed previously, in order to achieve an effective educational program as
measured by actual implementation of watershed approaches to address water
infrastructure issues, all of these stakeholders will need to be educated and convinced.
The challenge will come in selecting the methods and order of educational activities.
The Agency has already decided that direct communication with the general public about
this issue would not be the best use of their limited resources for education. Rather, they
are developing relationships with WEF (Water Environment Federation) and similar
professional organizations to promote knowledge about watershed-based sustainable
water infrastructure to private citizens. The Agency resources can perhaps be most
effectively used in providing educational opportunities for people in state agencies,
professional organizations, and utilities. Examined more carefully, this means that EPA
expectations in this area can perhaps be best met by recognizing and in turn encouraging
recognition by states, utilities, and professional organizations that the advancement of the
goals will require employees at all of these locations with specialized knowledge about
the initiative and the steps required to make it work, including educational outreach.
One strategy to assist in meeting the goal of specially trained staff who could aid in
communicating with all audiences would be for EPA to develop a "communications
toolbox". The toolbox could contain documents, videos, PowerPoint presentations and
similar material including topics such as "Watersheds 101", as well as information about
how water infrastructure is planned, built, operated, paid for, as well as the services it
provides.
6. How best can the economic case for a watershed management approach be made?
A particularly effective driver to encourage adoption of a watershed approach by local
authorities will be a strong case that money will be saved. A part of an effective
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educational program will be the provision of easy to use tools that can help local
authorities and utilities predict advantageous economic factors if something other than
the usual strategies are implemented. EPA could be particularly effective in providing
these tools and approaches. Assistance in providing the data to use with the tool would
be very helpful as well.
There appears to be a lack of well-documented case studies that illustrate the
opportunities and strategies for cost savings from a watershed approach to sustainable
infrastructure. This difficulty in identifying case studies that demonstrate cost savings is
likely to be a disincentive for some local groups to investigate the approach. Even
though EPA advances the watershed approach as one of the pillars of sustainable water
infrastructure, good examples of successes are essential for making the case. There may
be some examples that could be gleaned from work in the area of water quality trading.
In general, it appears that the educational agenda would benefit from additional case
studies, as well as from action to make any existing case studies readily available in the
communications toolbox as well as in other accessible locations. NACEPT expects to
work closely with EPA in the second phase of this student to identify appropriate case
studies that illustrate cost savings.
7. Is there a clear and effective model that can be used to demonstrate how this type of
collective decision-making can work? In reality, many decision makers likely will be
concerned about loss of current decision-making ability and control over expenditures.
Finding ways to answer these types of concerns could facilitate movement to
collaborative decision-making.
Organizational issues and sociological issues need to be considered and addressed if the
collaborative watershed approach is to be successfully implemented on a broad scale.
Even when a strong technical and economic case is made, individual decision makers will
ask related questions that must be resolved before progress can be made. For example,
permit applicants and governmental bodies may have an adversarial relationship. Less
publicly stated, but equally real, may be issues of turf, prestige, and level of funding to be
managed by each collaborating entity. In order to overcome these types of issues, clear
models of how such collaboration can work, or has worked effectively, will need to be
provided. This may be based on case studies of working projects or they may be based
on careful consideration and guidelines of how to build collaborations. This is a real
issue that must be overcome in order for the approach to be implemented successfully.
While all of these constraints may exist, it is also true that all of the groups that need to
be participating in this type of collaborative activity are interested in achieving efficiency
and economic benefit in all of their activities. The taxpayers and ratepayers both expect
and demand that. One strategy to overcome the natural reluctance toward collaboration
would be to emphasize the organizational and operational benefits that can derive from
what is in reality a systems approach toward sustainable infrastructure. Information and
strategies to convey the information should be part of the communications toolbox that is
provided to the people who have been designated to bring together the local groups to
initiate planning for the watershed approach.
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8. Promotion of this type of collaboration will require clear demonstration in the local
context of advantage. Without that, natural resistance to the uncertainties of change will
interfere with movement toward collaboration.
Clearly, if the goal is change at the local level, including in some cases giving up some
local decision-making opportunities to a collaborative regional group, a local advantage
must be demonstrable. Therefore, all of the educational and communication activities
must point to empowering local people to understand and predict the local impact on
these drinking water, wastewater and storm water utilities, local governments, planning
boards and other stakeholders. The overall program clearly has national benefit and
perspective, but individual local people make local decisions based on advantages near
them.
To facilitate this level of local understanding and local decision-makin'g, professionals
will need to be able to communicate more effectively with the public about these issues.
This will involve knowledge of how people obtain information, how they process it, how
they check it for accuracy, and how they utilize it in decision-making.
Charge Question "B". How can municipalities and other local government/regional planning
entities build support for promoting a watershed approach to water infrastructure planning?
NACEPT Response:
The first step in taking a watershed approach to water infrastructure planning is to
generate public and inter-agency awareness of the watershed, which generally crosses
jurisdictional boundaries (and does not align with most political boundaries). These awareness
or educational approaches can take many forms:
0 One or more localities working together, either because they share a utility district, a
reservoir (and source watershed) or a river.
n The effort tends to be more successful or comprehensive when it includes the entire
watershed or bio-region (including across state, tribal, locality, or utility boundaries).
0 The larger scale of watershed planning means that regional organizations or alliances
are better poised to initiate watershed planning, education and awareness efforts, even
if actual project funding and oversight is at the locality or utility level.
0 Successful watershed planning approaches can be initiated by regional organizations
or non-profit groups, but are more successful if they take an 'all-hands-on-board'
approach, including localities, utilities, large landowners, agriculture and business
interests, environmental groups, and regulators.
0 Related factors such as threats or apparent crises help promote watershed awareness -
drought, impacts of growth and sprawl, flooding and other natural disasters, location
of other treasured natural resources, and other local, regional, or state environmental
initiatives (sustainability/smart growth, green design/green infrastructure).
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Once there is awareness of the watershed, the planning approach can vary widely,
depending on a combination of factors that influence who might want to be involved and what
there primary drivers and interests are:
• Regional climate (dry or wet) and hydrogeology of the aquifer and drainage areas.
• Water source and method of use - reservoirs, wells, direct from river.
• Ownership, management, and size of drinking water and stormwater utilities.
• Regional economies - agriculture, industry, tourism, military.
• Areas where watershed boundaries cross multiple jurisdictions - tribes, multiple
states, international boundaries.
• Abundance/scarcity issues - is there enough water, but not enough storage? Is it
always dry, with occasional major storm events? Is quantity enough, but quality the
issue due to growth and run-off?
Due to the complexity (and localization) of the above issues, the regional approach of
awareness, education, participatory planning, and cross-jurisdictional cooperation may lead to
longer-term solutions across the entire watershed.
• By incorporating watershed education into other public planning exercises
(transportation and land use, rural development, agricultural, hazard mitigation,
community plans, schools, parks, airports, etc.) overall awareness of a watershed
approach can be raised.
• Following the 'golden rule' of regional planning - 'regional awareness and
coordination, local decision-making' - localities, tribes, landowners, and utilities will
be more likely to stay in the game and show all their cards.
• Raising awareness of the cost and quality of life implications of the 'business-as
usual' approach, along with the potential savings and benefits over time of a greener
watershed-based approach (green roofs, low-impact high-performance design like
green streets, more compact development) can get the attention of the decision-
makers in both the public and private sector.
• Express the 'sense of urgency' within the watershed about infrastructure issues that
will help coalesce a broad watershed action alliance and bring decision-makers to the
table. This can be quantified by conducting a regional build-out analysis, using a
computer model that identifies and quantifies the future regional impacts (on water
quality and quantity, air quality, land cover, traffic, infrastructure costs for
transportation, water, sewer, and schools, etc.).
Charge Question "C". Using relevant examples from the recent Cooperation Conservation
Conference, what are the ways in which "cooperative conservation " or "coordinated resource
management" has been or can be used to overcome barriers to promoting a watershed approach
to water infrastructure planning?
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NACEPT Response:
Interior Secretary Dirk Kempthorne joining with the Secretaries of Commerce and
Agriculture, the Administrator of the Environmental Protection Agency, and the Chairman of the
White House Council on Environmental Quality hosted listening sessions on cooperative
conservation and environmental partnerships.
The recent Cooperative Conservation Conference discussed ways that "cooperative
conservation or coordinated resource management" has been or can be used to overcome barriers
to promoting a watershed approach to water infrastructure planning. Though these challenges
are listed as individual elements, they are best accomplished and approached simultaneously.
• enhance wildlife habitat, species protection, and other conservation outcomes through
regulatory and voluntary conservation programs.
• enhance cooperation among federal agencies and with states, tribes, and local
communities in the application of environmental protection and conservation laws.
• work with states, tribes, and other public- and private-sector partners to improve
science used in environmental protection and conservation.
• work cooperatively with businesses and landowners to protect the environment and
promote conservation.
• respect the interests of people with ownership in land, water, and other natural
resources.
The conservation model exemplifies the use of conservation principles, policies and
practices to provide for the protection, storage and distribution of natural resources within an
urban and regional pattern that assures smart growth and integrates the before mentioned
elements.
Therefore viewing the above list as connected rather than segmented elements within a
plan, all resolved simultaneously, creates the opportunity to connect funding sources with
multiple issues, stimulating groups and agencies to work together to create a plan.
While there a several success stories where most of the components of cooperative
conservation have been melded with a watershed approach toward sustainable infrastructure, two
examples include: the outcome of Cache Valley, Utah activity within the Sustainable Design
Assessment Team (SDAT) program of the American Institute of Architects, and the Diablo Trust
in Arizona, a collaborative land management program.
Charge Question "D". How can EPA, States, or others influence various community
stakeholders to adopt and promote such an approach?
NACEPT Response:
Experience working with several water resource-related programs where groups have
come together to agree on an action plan reveals that:
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1. Stakeholders want to do the right thing but they define their "right thing" very narrowly.
They are generally looking at the problem from their own vantage point. In this context,
everyone is doing the right thing but the end result does not result in synergy. Very
often, their approaches contradict rather than complement. The first step to overcoming
this barrier is providing a forum where stakeholders can periodically meet and share their
experiences - conference, meeting, sessions. Some states are providing guidance to
communities about how to approach planning for water resources and infrastructure
planning from a watershed perspective. For example, Massachusetts has recently issued
a document titled "Water Resource Management Planning, a Guide for Towns and
Communities" (http://www.mass.gov/dep/water/laws/policies.htm').
2. Scientific reports and data are powerful identity builders. Scientific reports cannot be the
end of the process, but they offer excellent starting points. EPA can assist in ensuring
that scientific reports are available on watersheds.
3. Grants, even though small, can provide big incentives for stakeholders to come together
and create a synergistic working environment. Several EPA programs that were popular
with local citizen groups have been eliminated or substantially cut back. The Regional
Geographic Initiative gave the EPA Regions substantial latitude in the past to fund
regional priorities but their funding has been cut back to the point that the likelihood of
funding for local groups is very small and they, therefore, do not even apply for that
reason. The previous funding program had few strings attached and required only a 5%
match which made it easier for local watershed-based groups to apply and carry out the
grant program objectives. It was used generally for studies or on-the-ground
implementation projects. Groups were able to apply for $50,000 for good projects
determined by the Region. Presently they may be able to receive $10,000 and have to
compete with dozens more organizations for much less money. This is very
disappointing to the local groups and doesn't help EPA's agenda of involving local
watershed groups.
In the past, these local groups accomplished a great deal in advancing watershed-based
approaches with Section 319 funds. Now with the elimination or substantial reduction of
other sources of funding (federal, state and private combined), however, the Section 319
funds are just about the only option available to support activities of local groups. This
makes competition extreme while the need continues to grow. Because Congress is
asking why more streams aren't coming off the 303d list, states are prioritizing impaired
segments at the expense of many other good projects. Many local groups in the past
hesitated trying to have their stream segments listed because of their perception of the
stringent requirements of the TMDL process. Now it appears to many of those groups
that the only viable approach is to have them listed, making the list longer and
perpetuating the appearance that little is getting done. It is still not required to be on the
303d list to work on non-point source pollution problems. With the increase in
competition, though, many states are moving towards prioritizing mostly the impaired
waters in order to document success. There need to be additional ways to document
success and that respond to these concerns. Much good work is being done locally and
much more can be done to show improvements using other criteria. Either Section 319
eligibility should be expanded or other sources of funding should be reinstated or
developed.
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4. EPA watershed programs and initiatives must respond to the fact that all communities are
unique. No uniform formula will work with all of them. For example, two separate
initiatives were undertaken with two Florida communities barely 50 miles apart but the
two took very different approaches and reached the same end point. The success of the
facilitation resulted from allowing them to embark on different paths. Similarly
differences exist among large regional watershed initiatives such as those in the
Chesapeake Bay, Great Lakes, Long Island Sound, Everglades, Pacific Northwest that are
funded by regional to the level of up to $20 million/year. These differences provide
useful illustrations of how standard watershed approaches can be successfully applied to
geographically and ecologically unique situations. However, some unique
geographic/ecological niches do not yet have such an initiative. A case in point is the
Rocky Mountain Region although the area supplies water to 100 million people in 19
states and two countries.
5. There is no substitute for local monitoring leading to increased public awareness.
6. There is a set of barriers that inhibits adoption of watershed efforts by local groups.
These barriers include:
• No financial ability or financial support to establish a watershed planning effort.
Local groups often do not have the ability to pay for joint watershed planning
efforts.
• Lack of leadership to bring the parties together. Leadership is imperative to
formulating watershed planning groups.
• Lack of interest or lack of knowledge about unifying issues or problems and the
benefits of watershed level planning.
• Multi-jurisdictional issues cause conflict and lack of trust. This stifles the ability
of key players to make a commitment to joint planning.
o State/Tribal
o International
• Water rights conflicts (lack of finality in water rights) cause lack of
communication, trust and interest in joint watershed planning, especially in inter-
state, tribal/state, watershed settings.
• International conflicts limit the ability to do complete watershed planning when
international borders bisect watershed boundaries.
Charge Question "E" What are the specific barriers (and recommendations for addressing
them) embodied in existing EPA or slate policies or practices that need to be addressed to help
EPA and states further encourage and assist entities to consider and implement alternative
and/or integrated approaches for water infrastructure planning and management?
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NACEPT Response:
Over the past several years, watershed-based infrastructure planning has been bandied
about in a number of forums: conferences, reports, studies, and, in some limited instances, actual
application. It makes perfect sense to plan, design, and construct water infrastructure (drinking
water, stormwater and wastewater) using the watershed as the basic hydrologic planning unit.
Since the purpose of these projects is to improve or restore water resources, it is only logical that
watershed-based planning is essential for projects to be successful.
As early as the late 1970's and early 1980's the so-called "208 plans" for water quality
improvement under the Clean Water Act called for watershed-based, decentralized, infrastructure
planning. The watershed approach resurfaced in the early to mid-1990's as states began
conducting water quality monitoring, assessment, and permitting by watershed to bring to bear
watershed science in regulatory decision-making. North Carolina was probably the first to go to
a five-year rotating watershed cycle for integration of its water quality programs. Massachusetts
and others developed similar programs, and by the mid-1990s most states had embraced this as a
best management practice for efficient and effective administration of its programs, if for no
other reason.
This system empowered watershed associations and increased stakeholder involvement in
decision-making, which was the intent of the watershed approach.
So, here we are in 2007, and we ask the question: "Why isn't watershed-based
infrastructure planning the standard practice? What are the barriers that must be addressed for
watershed based infrastructure planning to become a reality not just in a few cases, but more
broadly across the country?"
A significant answer to this question is very simple but solving the problem is politically
challenging. One simple answer to the question is this: "Projects follow money. Projects follow
regulations." If neither funding requirements (ranking criteria) nor regulatory requirements steer
projects very strongly in this direction, watershed based infrastructure projects won't happen
unless they are driven by local forces. While local forces are very powerful, they are
circumstantial and unpredictable. If the USEPA wants to drive projects in a watershed direction,
simply supporting local decision makers, writing up their successes in journals and newsletters
and giving them awards won't get the job done, by a long shot. We can continue to talk about it
in theory, and we can point to a case study or two, but we will be talking about the rare
exception, not the mainstream reality.
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While EPA's Office of Water (OW) has been developing its thinking and adapting its
practices around a watershed approach for a number of years, OW actually began to restructure
its program to address "protecting water quality on a watershed basis" beginning with the 2003-
2008 Strategic Plan and continuing with the 2006-2011 Strategic Plan.2 Over time, programs
such as TMDL, Water Quality Standards, NPDES, CWA (Clean Water Act) Section 106 Grants,
Source Water Program, and the Clean Water and Drinking Water SRFs have been working to
incorporate watershed principles in guidance, policies, initiatives and priorities, keeping in
perspective the fact that EPA cannot tell states and tribes how to spend their own funds.
Despite this and the many watershed focused efforts of EPA's OW, until very recently
there has been little explicit incentive for integrated watershed-based (or other alternative)
infrastructure planning embodied in EPA policies or regulations, as viewed from the perspective
of many states. EPA has incorporated watershed planning in its Long Term 2 Enhanced Surface
Water Treatment Rule, and it has engaged a Source Water Collaborative with thirteen national
organizations to build drinking water protection into land-use planning and stewardship. We
recognize that OW has recently initiated its Sustainable Infrastructure Initiative, representing a
significant new undertaking to promote this kind of integrated planning. NACEPT urges EPA to
follow through on this effort and ensure all EPA offices (including the Office of Enforcement
and Compliance Assurance and the Office of General Counsel) embrace it.
Regarding specific aspects of the Water program, NACEPT finds that certain barriers
need to be addressed. For example, approximately 20-25% of wastewater treatment
infrastructure is financed through the SRF program, and water and wastewater utilities are facing
a large financing gap. As a result, state and local programs are consumed with finding adequate
amounts of funding and long-term management of infrastructure rather than integrated planning
approaches. Success has traditionally been measured primarily by things like dollars spent,
projects built, millions of gallons of wastewater treated, population served by sewers, and rarely
if ever, water quality improvements or watersheds restored. EPA should improve its internal
coordination - even though OW programs promote watershed approaches, the Clean Water SRF
program and the Section 106 grant program need to do a better job incentivizing utilities to
operate programs on an integrated watershed basis. One tool might be increasing emphasis on
linking SRF expenditures with water quality and watershed improvement. EPA has been
successful in working with states for voluntarily reporting data on loans in order to demonstrate
use of SRF to restore and protect water quality for various uses. This information should be
explicitly used in planning.
Similarly, the NPDES program needs to help states streamline their programs to
maximize efficiency in permitting, in order to preserve resources for watershed-based planning
and implementation. For example, states struggling with resource limitations have urged EPA to
support administrative renewals of some permits to allow more focused attention in priority
watersheds. In addition to EPA's recent shift in emphasis to 'priority permits' and priority
watersheds in its measurement systems, EPA needs to assist states with finding ways to extend
permits that don't need revision in order to avoid unnecessary re-permitting. In doing so, EPA
should keep in mind that there may be complications to be addressed that result from legal
review of these approaches.
! See httpV/www.epa gov/ow/waterplan/
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Water withdrawals, wastewater discharge and stormwater systems must all the integrated
into watershed-based infrastructure planning but there does not appear to be a centralized
coordinating mechanism to push this at EPA, and often in the states. There is also very little in
the way of policy or guidance to encourage states and communities to do such planning (though
in Massachusetts, integrated water resource management planning guidance is nearly complete
and will go a long way towards addressing this). The following recommendations are offered to
help EPA identify ways to assist states with such integrated, watershed-based, resource planning.
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IV. Recommendations
In addition to the findings we offer in response to EPA's five questions to us, NACEPT
also provides the recommendations below for EPA action to promote the watershed approach to
sustainable water infrastructure. We found that our recommendations fit into four categories
(that overlapped, diverged, and generally did not fit neatly within the five questions): leading by
example; educating, communicating, and providing communication; encouraging, facilitating,
and funding collaboration; and developing, using, and funding specific tools. We view each of
the four categories as equally important and critical to EPA's successful implementation of a
watershed approach. Within each category, we have sought to generally prioritize our
recommendations, with the highest priorities appearing first. The highest priority
recommendations are as follows:
Highest Priority: Recommendations 1, 3, and 4
Very High Priority: Recommendations 5, 19, and 20
High Priority: Recommendations 2, 4, 21, 22, 23, 24, 25, and 26
Lead by Example
1. Organize internally and name a coordinator. Neither policymakers nor the public have
much understanding of a watershed approach or its benefits in providing sustainable
water infrastructure. As the first step in raising awareness and building the support
necessary for success, NACEPT recommends that EPA start at home by making this a
visible priority.
EPA should assure that all components of EPA's organizational structure, including the
Office of Enforcement and Compliance Assurance (OECA), effectively support
watershed-based program implementation by promoting common integrated themes and
messages. In part, this can be accomplished by aligning the goals and objectives of each
office, division, and region sufficiently to promote a harmonious unified watershed
approach, so that all stakeholders throughout the country can implement watershed-based
infrastructure decisions. This is asking a lot of EPA, and any particular office or division
is likely not to be able to have the resources or institutional support to undertake this role.
Instead, to best integrate such an effort across the Agency, the Administrator should
name a coordinator and coordinating team and identify them and the watershed approach
as a priority. By being better organized internally to promote the watershed approach,
EPA then will be better able to help tribal, state, and local officials with a truly integrated
approach and strategy.
2. Initiate at least two innovative watershed infrastructure projects in each EPA region.
NACEPT recommends that EPA designate a national high level action group (such as the
Innovation Action Council or a similar group) to work with stakeholders (tribes, states,
local officials, watershed associations, businesses, etc.) to undertake and provide seed
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funding for at least two innovative watershed infrastructure projects per region. The
objectives of each pilot are to: (1) define needs and watershed boundaries, (2) integrate
drinking water, clean water, and stormwater infrastructure issues, (3) discover any
obstacles inherent in EPA's practices and structure, and find solutions, and (4) ultimately,
improve EPA's ability to use the watershed approach more effectively and embed it into
standard practices. The group should include a top level decision maker from each EPA
Region (a Deputy Regional Administrator or Water Management Division Director) and
from Headquarters offices (Office of Water and OECA). These personnel should have
the authority to take risks and should expect to be evaluated on the program's success.
NACEPT further encourages at least one of the projects in each EPA region to include a
tribal authority, and the tribes should participate in defining the watershed boundaries, the
problem, and any solutions. For example, given the recent national attention due to
wildfires, rapid development, habitat protection, water quality, and water supply, the
watershed including Lake Tahoe in Region 9 might be a candidate project under this
initiative. We also hope that at least one of the projects involves a watershed that is
transected by an international boundary.
3. Reward collaboration. As part of the promotion of a watershed approach, EPA's
personnel and training policies should recognize and reward the important role of
collaboration. EPA staff should be able to be fully engaged as partners in local and
regional watershed initiatives. Even something as basic as regional staff attending and
participating in local public meetings will demonstrate EPA's commitment to making the
watershed approach work and will pay benefits in terms of receptivity by all stakeholders.
Educate. Communicate, and Provide Information
The next two sections and their recommendations are integrally related regarding what
needs to be communicated, to whom the information needs to be communicated, and with whom
the parties providing and receiving the information should be collaborating. EPA has the
opportunity to play several important roles in promoting the watershed approach. One involves
being a national leader, provider of general information, author of national policies, and funder.
Another is to work at the watershed level by providing staff resources, watershed-specific
information, flexible application of national policies to local situations, and localized funding.
4. Illustrate the urgency of the need to adopt a watershed approach for sustainable water
infrastructure. Because very few people know about the watershed approach or its
benefits, NACEPT recommends that EPA illustrate and emphasize through its
stakeholder partnerships the urgency of meeting current and looming water problems and
meeting them with sustainable, locally designed water infrastructure solutions. EPA is
making concerted efforts to communicate with the water professional communities about
the infrastructure shortfalls and huge costs (of addressing them in the traditional ways),
but EPA also should make strong efforts to reach local stakeholders and decisionmakers
more directly. Given EPA's limited resources and personnel, EPA should start by
utilizing its already existing communication partnerships with national associations of
local governments and local watershed groups.
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5. Help incorporate watershed principles in college curricula and research programs.
Realizing that achieving a sustainable water infrastructure will require a combination of
near- and long-term actions, NACEPT recommends that EPA begin now to initiate the
design of watershed-based curricula for colleges and universities, including tribal-
supported colleges and continuing professional education programs. By building
knowledge, support, and capacity for using the watershed approach to sustainable water
infrastructure, schools can help make this a well-integrated component of academic
study, increase its recognition as a viable and valued approach in the water field, and give
the approach dignity and credibility as a career choice and professional field. EPA could
assist this effort in several ways, by: (a) developing a forum for academics to determine
what priorities should be taught and how to encourage cross disciplinary approaches with
such fields as architecture, land-use planning, and infrastructure planning; (b) informing
the academic community about the potential job market for graduates with this type of
training (through surveys of water utilities, for example); (c) collaborating with the
National Science Foundation to provide research support for focused watershed approach
research and innovative curricular development projects that incorporate watershed
approaches; and (d) discussing with accrediting agencies, such as ABET, Inc (formerly
known as the Accreditation Board for Engineering and Technology) how to best to
communicate with individual academic programs about the value of including sustainable
water infrastructure approaches in the course of instruction.
6. Identify key stakeholders, survey their needs, and together develop an
educational/communication program. To be successful, EPA will need to create a
comprehensive education and communication program. Key players include EPA
Headquarters (at least OW, OECA, and the Administrator's Office), regions, tribes,
states, local governments, and national professional water organizations. Other potential
groups include historical societies, cultural institutions, recreational associations, schools,
friends of parks organizations, and farmers.
Because it will be unwieldy to start, EPA also should develop milestones and timetables
to develop such a unified theme. Critical to this effort's success are strong partnerships
between the EPA regions, tribes, and states, which generally are responsible for adapting
and implementing the national priorities on specific issues. As a first step, NACEPT
recommends that EPA survey these partners and key stakeholders to identify what they
see as their particular needs, the expected benefits, and the likely hurdles and solutions.
For example, EPA could survey all the regional councils of governments (generally
voluntary groups of local governments that focus on identifying and addressing regional
issues). The survey also could explain the watershed approach to sustainable water
infrastructure, provide information about available tools and funding opportunities, and
offer to assist in implementing the approach.
Armed with EPA's current knowledge and this new outside information, EPA would be
in a better position to facilitate the preparation and provision of effective guidance, tools,
and information to stakeholders. EPA also should beef up its current watershed website
(www.epa.gov/watershed) to offer information (as more fully discussed below) about
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how the watershed approach can benefit sustainable water infrastructure, as well as data,
case studies, and links to other related programs and information.
When any part of EPA announces a national or local watershed initiative, partnership,
database, or report, EPA should seize that opportunity to connect the announcement to
EPA's overall watershed communications program. Through such strategic, concerted
efforts, the public and key decisionmakers are more likely to begin to understand the
watershed approach.
7. Identify the needs of local stakeholders. In addition to surveying national groups about
their needs, EPA also can play an important role for specific watersheds. At the
watershed level, EPA can do many things to empower the local community, such as
providing scientific data, a common forum, grants to develop a working relationship, and
recognition of their unique conditions. Where EPA may want to assist with a particular
watershed, it should first assess the local stakeholders' needs in order to determine how
EPA can best assist that unique watershed. This may mean identifying individuals within
the regions that can provide localized responses to questions or requests for information,
as well as ideas for strategies helpful for that specific watershed. It may mean
establishment of locally available facilitators (perhaps at universities based on the model
of EPA's Technical Outreach Services for Communities program) to help establish and
facilitate the establishment of the local groups. This may, in part, be achieved through a
communication effort since EPA is currently doing many of these activities.
8. Help provide watershed specific data to local decision makers. EPA could promote faster
and broader adoption of a watershed approach at the local level by providing local
stakeholders with easy access to databases about their watershed's water quality and
quantity. EPA regional personnel frequently are the most knowledgeable about a local
watershed's conditions, so EPA should encourage regional personnel to share their
information and collaborate with watershed stakeholders. Where the data is in the hands
of other federal agencies, such as the United States Geological Survey or the Army Corps
of Engineers, EPA should facilitate the sharing of this information and promote easy
links where possible. Where necessary, EPA should consider entering into a
memorandum of understanding with appropriate agencies to best facilitate this sharing
and coordinating of information.
EPA's STORET website (STOrage and RETrieval, www.epa.gov/storet/) is a repository
for lots of water quality, biological, and physical data. STORET can be a valuable
starting point, but EPA will need to work with other agencies to enhance its website
(either STORET specifically or the general EPA watersheds site) with more information
on the connections between its watershed and water infrastructure, including green
infrastructure, approaches. If STORET is not the appropriate vehicle, perhaps EPA could
establish a Watershed Technology Center that provides stakeholders access to watershed-
based data, expertise, and communication.
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9. Communicate cooperative conservation watershed success stories to local communities.
In communicating with local stakeholders about watershed approaches, EPA should
include not just general benefits information but also the story of how local cooperative
conservation successes took place. EPA should highlight the critical connections
between community, economic and environmental groups and discuss how the activity
was funded, what innovative approaches were taken, and what lessons were learned. The
presentation of lessons learned should include the effective push-pull factors, together
with suggestions for avoiding the pitfalls and empowering successful processes. This
information source should have an internet component. The website should not,
however, simply list old projects, but it should be integrated into EPA's main watershed
website, include an analysis of the overall approach and reference the individual projects,
allow project participants to add comments and communicate with others about their
projects, and be up-to-date.
10. Establish follow-up approaches to validate the watershed and cooperative conservation
approaches. EPA should establish follow-up processes to validate the continued success
of its efforts, particularly as the watershed and cooperative conservation approaches
discussed here are new and should have a strong feedback and continual improvement
loop. Specifically, EPA should want to assure that information about and enforcement of
its regulations realistically support and actually yield implementation of watershed-based
actions, such as watershed-based TMDLs, watershed-based permitting, watershed
pollution trading, and watershed-based compliance and enforcement activities. Critical
follow-up questions to ask would include: what practices were used to form a local
group to maintain the project's stewardship, how was the group structured and funded,
was the project successful in the long-term, and what changes would the participants have
made?
11. Develop and use training materials to integrate the watershed approach into others'
planning. NACEPT recommends that EPA develop short educational and training
materials on how to integrate a watershed approach into other agencies' planning
projects. These materials should help raise awareness and stimulate opportunities with
federal, tribal, state, and local agencies and with the other groups involved in planning
projects. Many of the how-to materials related to effective processes are already
available, so the new materials should be technically-focused.
12. Directly facilitate communication among jurisdictions about a watershed approach. EPA
should directly facilitate communications between jurisdictions to actively develop the
watershed planning approach. Given its credibility, data, resources, and personnel, EPA
could help bridge the gap between jurisdictions, engage in regional and even international
discussions, provide leadership (and financial support when necessary) where watershed
planning is needed and leadership is lacking, and offer guidance to groups in defining
unifying issues and benefits of watershed planning. NACEPT suggests that EPA initially
implement this as a pilot program as part of the demonstration projects proposed in
Recommendation 2, in order to identify approaches that are effective and strategies that
can be transferable.
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13. Expand communications with local government through EPA's Local Government
Advisory Committee. NACEPT recommends that EPA work to nurture and expand these
developing initiatives through the EPA Local Government Advisory Committee. This
could help provide two-way communication with local government officials throughout
the country about a watershed approach to sustainable water infrastructure and its issues,
problems, perspectives, and potential solutions.
Encourage. Facilitate, and Fund Collaboration
One of EPA's critical roles regarding a watershed approach is to find the best ways to
help bring people together to achieve their water goals. EPA is not likely to be the lead for many
of these projects, but it nevertheless can have a significant role in helping bring people together.
14. Participate in and leverage other agencies' activities, particularly planning. In addition to
working with its sister agencies to communicate information, EPA also should partner
with federal agencies to coordinate their work on watershed projects and reduce
unnecessary overlap, hurdles, and mixed signals. Obvious agencies to partner with are
other water-focused agencies, such as the United States Geological Survey (USGS) and
the Army Corps of Engineers. In addition, some sister federal agencies such as the
Department of Agriculture and the Bureau of Land Management have direct
responsibility for large areas of public land that are integral parts of watersheds. EPA
should work closely with them to promote the watershed approach in their activities. In
this case, the federal agencies should take the lead in collaborative approaches with
states, tribes, local governments, and local utilities in carrying out actions that provide
overall benefit to the entire watershed. These approaches should also illustrate the
important value of both rural and urban portions of watersheds to the overall
sustainability of the nation's water infrastructure.
Many other agencies conduct extensive regional and local planning for various projects
that impact watersheds. Because many of the impacts on watershed infrastructure are
generated by growth and housing development, runoff, industry, agriculture, and other
land uses, watershed planning is best conducted as part of a broader effort that helps
defines how and where communities will grow. The same approach can apply to
planning for schools, parks, airports, and other facilities with major potential watershed
impacts and the potential to bring a variety of interests together. NACEPT recommends
that EPA leverage and participate in as much of this planning as possible.
This cross-program, multi-jurisdictional approach stretches funding, saves time for the
public, decision-makers, and agency staff, and helps communities develop better plans
and projects. In order to facilitate the EPA role in these processes and to provide
maximum watershed benefits, EPA should carefully determine the connections between
water infrastructure and watershed issues and the particular project being planned.
Although each location likely will have its unique factors, common themes will exist.
Communication of effective responses to these themes will help EPA advance solutions
that integrate sustainable water infrastructure into the other agencies' planning objectives.
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We recommend that EPA:
a. Identify what kinds of land use planning other federal agencies are funding and
convening. For example, the Federal Highway Administration has initiated a program
titled, "Integrating Transportation and Resource Planning to Develop Ecosystem Based
Infrastructure Projects" (see Appendix 4). Other agencies that fund or lead land use
planning exercises include the Federal Transit Administration (most likely through state
departments of transportation), metropolitan planning organizations, the Department of
Agriculture's rural development program, the Department of Housing and Urban
Development's Community Development Block Grants and Home Investment
Partnership Program, the Army Corps of Engineers, the Bureau of Land Management,
and the Bureau of Reclamation.
b. Direct the regions, as part of the pilot projects proposed in Recommendation 2, to
identify specific planning opportunities to test this strategy at the tribal, state, regional,
and local level. Because many watershed efforts are conducted at a regional level, the
regions could convene an information-sharing session with regional planning councils
and metropolitan planning organizations to learn about upcoming regional planning
efforts and to share information about funding for watershed initiatives.
c. Strongly encourage states, tribes, utilities, and non-profit grantees to identify such
broader planning efforts and include watershed infrastructure planning in them. For
example, competitive grant funding for watershed initiatives could offer bonus points for
coordination with other regional planning efforts.
d. Participate in an extensive participatory process (i.e., charettes) in which the broader
community or region has established their values and goals. These shared values
(typically including but not limited to watershed issues) then should serve as the basis for
what the scenario analysis measured in its modeling (as was done in Envision Utah and
the Eastern Planning Initiative's Sustainability Accords; see Appendices 8 and 9).
e. Use existing planning models (such as INDEX, CorPlan, and CommuityViz) to
incorporate limited analysis of watershed impacts into transportation and land use
alternatives. EPA also should work on integrating (or at least connecting) EPA water
models with such scenario planning and analysis models.
f. Participate in regional scenario planning initiatives, with the Federal Highway
Administration and the Federal Transit Administration, which develop and test
alternative futures for economic development, transportation investment. This would be
a good opportunity to demonstrate the pre-NEPA (National Environmental Policy Act)
potential outlined in SAFETEA-LU (Safe, Accountable, Flexible, Efficient
Transportation Equity Act: A Legacy for Users). This may be especially useful in fully
integrating into a watershed-based environmental approach the analysis of transportation
and land use alternatives; historic, cultural, and tribal assets; and green infrastructure
principles. Scenario planning examples include California Blueprint (see Appendix 7),
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Envision Utah (see Appendix 8), and the Thomas Jefferson Planning District
Commission's Eastern Planning Initiative (see Appendix 9).
g. Expand community awareness of watershed issues during planning to groups and
agencies that are focused on other issues, such as transportation, housing, land use,
agriculture, tourism, economic development. This can be done efficiently by targeting
the conferences and publications of relevant national associations, such as the
Association of Metropolitan Planning Organizations, the National Association of
Regional Councils, the American Planning Association, and the National Association of
Development Organizations.
h. Offer watershed planning and funding as an opportunity for other planning efforts (the
reverse of leveraging EPA watershed funding by attaching it to other agencies' planning).
Where a community is planning a watershed-level infrastructure project, that investment
(and public attention) can be leveraged to address transportation, housing, or community
development issues - and broaden the support for watershed-level issues. One example
is the Columbus (Georgia) Water Works watershed initiative that used a broad
partnership to leverage a water infrastructure project into a downtown and riverfront
revitalization project, coupled with an environmental education center.
15. Increase collaboration among the full range of water-related utilities. Another
opportunity is for EPA to build upon and leverage its existing partnerships and alliances
to promote collaboration among water supply, wastewater, and storm water utilities, and
industries in a given watershed area. This would give them a more effective voice with
local decisionmakers and stakeholders. EPA, tribes, states, and utilities should elucidate
the benefits of working together to the many different types of organizations that might
participate in the watershed approach.
EPA could use the partnerships being formed for the source water assessment processes
and vulnerability assessments. In Region 3, for example, EPA offered initial guidance in
the creation of the Schuylkill Action Network, which is working successfully to improve
its watershed resources in Pennsylvania by partnering with federal and state agencies,
local watershed organizations, water suppliers, and local governments (see Appendix 3).
The EPA Office of Water should identify other existing Clean Water Act and Safe
Drinking Water Act programs for melding them to facilitate a watershed-based approach
to locally relevant infrastructure issues.
16. Develop effective approaches to bring together groups of stakeholders within a
watershed. EPA should give more attention, and perhaps detailed research, to the
question of effective models or approaches that can be used to bring together
stakeholders in a watershed to achieve a common good, even if it brings certain costs.
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17. Encourage state and tribal environmental agencies and utilities to join integrated
watershed planning efforts. EPA should identify strategies to encourage state and tribal
environmental agency and local utility staff to join in integrated planning efforts and to
coordinate them with their own agency plans and investment strategies. EPA should
communicate with the tribal and state agencies that set utility rates about the potential
cost reductions that could be achieved by using this type of coordinated planning
approach. EPA also should help states and tribal authorities understand that if they use
the watershed approach to pick the most important water quality/quantity problems, then
their stakeholders will be more likely embrace the watershed approach as the best way to
solve them.
18. Extend partnerships with water professional organizations for effective
communication with rate pavers. As the ultimate decisionmakers for many watershed
issues, water ratepayers have a significant role and need additional education on the
watershed approach. NACEPT recommends using its existing partnerships with
professional water and water utility organizations (both public and private) to help
communicate to ratepayers that the watershed approach uses money more wisely to
achieve the necessary infrastructure results. Because the watershed approach is relatively
new and the period of each interaction with the public is short, this must be seen as a
long-term program that must be regularly refreshed and updated. EPA could develop a
series of "factoids" of successful projects and partnerships as the basis for the educational
content, which utilities could use in such materials as customer bill inserts.
Develop. Use, and Fund Specific Tools
EPA's role does not end with aiding communication and collaboration. EPA's
regulatory, enforcement, and funding initiatives also can play significant roles in actually
achieving successful local watershed projects using a host of existing and possible tools.
19. Use Stormwater Phase II authority to ensure that transportation projects incorporate
green infrastructure principles. NACEPT recommends that EPA actively pursue its
Stormwater Phase II authority to ensure that transportation projects incorporate green
infrastructure principles (see below), that transportation projects and watershed plans are
coordinated, and that eligible transportation funding be made available to support these
efforts. Where appropriate, related authorities under phase I or other funding programs
also should be used. These coordinated efforts would help ensure that transportation
projects have minimal negative impacts on the watershed, that Stormwater systems are
properly sized, constructed and maintained for watershed protection, and that water
infrastructure needs are appropriately addressed.
20. Apply a "hold harmless" approach to promote multi-program scenario analyses.
NACEPT recommends that EPA determine whether a 'hold-harmless' approach can be
applied in certain situations. For example, where localities and utilities agree to
participate in a more complicated multi-program scenario analysis, EPA could give them
more time for certain regulatory reviews, including permitting and enforcement, or
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streamline or conduct simultaneous reviews. The most typical example is where
transportation, land use, and natural resource planning (by a metropolitan planning
organization or regional planning agency using transportation funds) is conducted
independent of water, sewer, and stormwater infrastructure planning (by a water agency)
because different laws and rules impose different timetables - even when the studies
address the same watershed, at the same time, with competing public workshops and for
the same elected decision-makers. A more efficient and effective approach would allow
the water agencies the time needed to conduct their planning in parallel with the related
land use effort.
21. Use NPDES permits to provide watershed-wide monitoring. EPA, with tribes and
states, should use the NPDES process's available flexibility to encourage permittees to
transition some of their current end-of-pipe outfall monitoring to a more meaningful
watershed-wide data approach. EPA could do this by modifying the frequency and
details of a permittee's NPDES end-of-pipe monitoring conditions.
22. Fund local watershed groups and unique multi-iurisdictional watershed improvement
projects. NACEPT recommends that EPA reexamine its funding opportunities for local
watershed groups and pilot projects to encourage smaller, more locally do-able watershed
initiatives linked to infrastructure needs. Such local involvement can build upon the
typical energetic participation of local people committed to the watershed, build broader
understanding of the connection with water quality/water quantity issues, and provide
significant leverage for EPA's funds. Providing seed money for such multi-jurisdictional
watershed efforts is one of the surest ways for EPA to demonstrate to the broader
population the benefit and contribution of linking a watershed approach with sustainable
water infrastructure. Such funding should be given with the expectation that it will
encourage new project development and that it will help leverage others' funding. Such
initiatives can be facilitated if each region has the means and the charge to meet with
each state and tribe to help them promote a watershed approach.
More specifically, NACEPT recommends three changes in current funding priorities:
a. Supplement 319 grants. EPA should allow the Section 319 grant program to provide
additional funding initiatives for local watershed groups. Such new or reinstated
initiatives could take advantage of matching by existing state funds for water quality and
watershed enhancement projects. One approach might be to fund at higher levels the
Regional Geographic Initiative (RG1), which allows the regional offices to leverage
funding innovative solutions to local environmental issues through partnerships. For
instance, the RGI could be very helpful in leveraging funds from Colorado's Watershed
Protection Fund (a voluntary state income tax check-off program that raises about
$100,000 each year for local watershed groups) and would encourage project buy-in by
local citizens.
b. Enhance EPA's targeted watershed grants. EPA should enhance its targeted watershed
grants program, which assists watershed organizations in building their capacity to be
better positioned to undertake large projects. Many local watershed groups view the
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goals of the grants as laudatory, but also believe that the funding (targeted at larger
projects) was achieved by eliminating funding for smaller projects. NACEPT urges EPA
to consider creating a "best of both worlds" opportunity by funding statewide groups that
would integrate, through subcontracting, smaller local projects that in composite have
watershed-wide effects commensurate with a large-scale project. Such an approach
would provide project management efficiency at the state or tribal level while promoting
broader participation by local groups.
c. Use supplemental environmental projects. Supplemental environmental projects
(SEPs) are enforcement resolution tools that EPA can use to provide funding and
resources (from the enforcement target) for environmental projects in communities.
SEPs generally offer flexibility and funding and thus can be very helpful in providing
seed money for watershed demonstration projects, such as watershed-wide water quality
monitoring.
d. New regional watershed initiatives. EPA has already created several regional
watershed initiatives, such as the Chesapeake Bay, Gulf of Mexico, and Great Lakes.
EPA should explore creation of additional regional watershed initiatives to cover portions
of the country that are currently not involved in such projects but possess unique
geographic and ecological features that would benefit from such a concerted, integrated
approach. One such possibility would be the Rocky Mountain Headwaters.
e. Smart growth grants. EPA's smart growth initiative in the Office of Policy,
Economics, and Innovation works well with the Office of Water, states, tribes, local
governments, and the real estate and development industry. As water supply decisions
become more important to community development decisions, EPA should consider
providing additional technical assistance and funding for the smart growth program.
23. Provide wastewater and drinking water state revolving funds to promote green
infrastructure. EPA should work with its regional offices, tribes, and states to explore
ways the Agency can use the SRF program to promote green infrastructure that offers
watershed sustainability. We recommend that EPA consider a comprehensive natural
systems or ecosystem approach to water-related green infrastructure because an
ecosystem approach, involving both rural and urban components, can provide the most
beneficial foundation for the future needs of the area. (See Appendix 10 for an example
of this type of approach.) While states and tribes largely set environmental ranking
criteria for SRF projects, EPA should develop explicit incentives in its SRF guidance for
communities to use a watershed approach. EPA also might consider approaches to set
aside a small amount of SRF dollars nationwide for competitive watershed-based green
infrastructure planning (not construction) and should seek Congressional authorization
for such set-asides where needed. The set-aside could target funds for integrated
watershed management, including wastewater, stormwater, and combined sewer
overflows, and require that all projects receiving SRF dollars be consistent with green
infrastructure principles. To discourage sewer-expansion-driven sprawl, the SRF
program could consider adopting a "fix it first" policy, whereby states would have to
show preference for fixing existing water quality problems and failing infrastructure
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before expanding sewers to accommodate new development in outlying areas. This
concept, however, should not stand in the way of projects to provide necessary sewer
services to existing areas that have been underserved or have not been served at all in the
past. Some tribes and states already have developed policies in this area, and EPA should
identify some successful examples and options as guidance for others. In addition, EPA
should coordinate state activities with tribal programs that are supported by the SRF
tribal set-aside.
24. Synchronize NPDES permit renewal dates across watersheds. EPA should continue
working with states and tribes to synchronize all NPDES permit renewals within each
watershed. This practical approach will allow a comprehensive, watershed-wide review
of total NPDES loading, thereby promoting watershed-based pollutant trading and
consistent application of effluent criteria. EPA should give states and tribes the option of
conducting "administrative renewals" every five years and substantive renewals every ten
years in order to focus more resources on priority watersheds. In addition, often
overlooked and infrequently renewed "minor" NPDES permits should be included in the
synchronized, watershed-based renewal schedule. Finally, other federal permits, such as
Stormwater Phase II permits and underground injection control permits, should be
included within such coordinated NPDES watershed renewal cycles. Where EPA has
primacy in permitting, EPA should implement this timing approach.
25. Facilitate watershed trading. EPA should continue its work to make watershed
trading easier. As one example, EPA could require that wastewater treatment plants meet
end-of-pipe effluent limits within the typical timeframe for compliance, but allow more
time to develop a watershed trading scheme that would result in equivalent (or greater)
watershed benefits at lower cost. EPA should examine such trading incentives as:
regional offices granting differential oversight to adequately performing tribal or state
programs that wish to experiment with watershed trading; faster turnaround time for
review/approval of state or tribal submissions (e.g., TMDLs, regulations, plans); and
technical support from EPA regional offices.
26. Promote more innovative watershed-based TMDLs. Total maximum daily loads
(TMDLs) are one of the clearest watershed-based tools EPA, tribes, and the states already
have. NACEPT recommends that EPA take additional steps to promote innovative
watershed-based TMDLs. NACEPT suggests, for example, that EPA adopt a shorter
turn-around time for its regions to review TMDLs so that they would have more time to
encourage and facilitate innovative TMDL approaches by states and tribes. NACEPT
also applauds the Office of Policy, Economics and Innovation's pilot impervious cover
method grants. To best use this powerful tool to facilitate watershed approaches to
sustainable water infrastructure, EPA's TMDL program (and EPA's Office of General
Counsel and the Office of Enforcement and Compliance Assurance) must take a broader
view of its mission and embrace true watershed-based TMDLs. Given the opportunity to
embrace greater overall environmental water gains, TMDLs could address all
contributions (e.g., stormwater), not always be defined by water body segments, and not
always be restricted to individual pollutant loads.
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar
National Advisory Council for Environmental Policy and Technology
Charge for Developing Recommendations on U.S. EPA's Sustainable Infrastructure
Watershed Pillar
Background
The EPA Administrator has identified Sustainable Water Infrastructure (hereafter referred to as
Sustainable Infrastructure (SI)) as one of the Agency's highest priority initiatives. In January
2003, the Administrator convened a Forum - Closing the Gap: Innovative Responses for
Sustainable Water. At this Forum, the Assistant Administrator for Water highlighted the "Four
Pillars of Sustainable Infrastructure"— Better Management, Full-Cost Pricing, Water Efficiency,
and Watershed Approaches to Protection (hereafter referred as the Watershed Pillar). The SI
initiative aims to decrease the gap between growing infrastructure (drinking water plants, piping,
etc.) needs and spending, by promoting sustainable infrastructure through the four Pillars.
This charge is being developed to address the challenges specific to the Sustainable
Infrastructure (SI) Watershed Pillar. The goal of the Watershed Pillar is to enable utilities (i.e.,
drinking water and wastewater) and other stakeholders (e.g., local and State agencies, local
planning and ordinance organizations, environmental advocacy groups, watershed decision
makers) to take advantage of opportunities offered by watershed approaches to minimize
infrastructure cost and/or operating and maintenance expenses to achieve water quality and
quantity and human health protection goals.
One of the most critical challenges facing the Nation is how to sustain our water and wastewater
infrastructure to ensure that the public can continue to enjoy the environmental, health, social,
and economic benefits that clean and safe water provide.
Our wastewater and drinking water systems are aging, with some system components older than
100 years. Our growing and shifting population requires investment for new infrastructure and
maintenance of existing infrastructure. Current treatment strategies and technologies may not be
adequate to address emerging issues, investment in research and development has declined, and
the prospects for continued large federal investment are limited.
EPA's Clean Water and Drinking Water Infrastructure Gap Analysis (2002) estimated that if
capital investment and operations and maintenance remained at current levels, the potential gap
in funding between 2000 and 2019 would be approximately $270 billion for wastewater
infrastructure and $263 billion for drinking water infrastructure.
Meeting these challenges requires a multi-faceted approach to managing and sustaining our
infrastructure assets. The Nation must change the way we manage, view, value, and invest in our
water infrastructure. This can only come about if all parties embrace a collaborative approach
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar (continued)
that encourages new and innovative solutions to the challenges we all face. All levels of
government and the private sector have a shared responsibility for seeking effective, efficient,
and fair solutions for sustaining our precious water infrastructure.
Through collaboration with all key stakeholders, the use of effective and innovative approaches
and technologies, and a commitment to long-term stewardship of our water infrastructure, we
can make better use of our resources, potentially reduce the funding gap and move the Nation's
water infrastructure down a pathway toward sustainability over the next fifteen years. For
example, more than 4,000 local watershed organizations are at work in the United States. They
are advocating watershed restoration, source water protection, improved site design, erosion
control, land conservation, and storm water management — to name just a few activities.
The watershed approach is generally invoked to mean broad stakeholder involvement,
hydrologically defined boundaries, and coordinated management across all aspects of policy that
affect water. "Source water protection" is the watershed approach's analog under the Safe
Drinking Water Act. The watershed approach and source water protection are grounded in
science and allow for prioritization and cost-effective interventions, as appropriate.
The EPA Office of Water's 2003 guidance on watershed-based permitting and water quality
trading allow for strategic, cost-effective actions to meet water quality standards. Watershed
goals and the impact of multiple pollutant sources and stressors, including nonpoint sources, are
considered when National Pollutant Discharge Elimination System (NPDES) permits are written
for multiple sources in a watershed. The goal of this approach is to issue permits that take into
account the conditions of the entire watershed and address diverse pollution sources, not just
individual point sources. Often, such permits carry a trading component. A current example of a
successful watershed-based permit with trading can be found along Long Island Sound, where
nitrogen trading among dozens of publicly owned treatment works in Connecticut is expected to
save more than $200 million in control costs.
Source water protection, targeted to protect current and future sources of drinking water, also
holds the promise of substantial benefits. EPA has determined that preventing contamination can
be up to 40 times more cost effective than remediation of a drinking water source or finding a
new one.
Development decisions are another important approach to the watershed paradigm. Development
decisions are generally made at the local level. While local governments have direct authority
over land use and development decisions, many states play important roles in setting statewide
approaches to planning for growth. The EPA cannot and should not be a national or regional
development board, but the federal government can help states and municipalities better
understand the impacts of development patterns. The Source Water Collaborative's3 recent
3 The Source Water Collaborative consists of a broad set of constituencies that include the U S. EPA and 13 national premier
organizations (representing state agencies, water utilities and environmental groups) that have agreed to combine their efforts to
protect drinking water sources
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar (continued)
Vision Statement notes that drinking water protection should be integrated into land-use planning
and stewardship; road, sewer and water projects; farming, industry and development practices;
waste disposal methods; watershed planning, protection and clean-up; and the routine decisions
Americans make every day. EPA is working to help states and communities realize the
economic, community, and environmental benefits of smart growth by: 1) providing information,
model programs, and analytical tools to inform communities about growth and development; 2)
working to remove federal barriers that may hinder smarter community growth; and 3) creating
new resources and incentives for states and communities pursuing smart growth.
A key objective the Agency wishes to advance under the sustainable infrastructure effort is the
merger of watershed management principles into utility management, so that key decision
makers consider the watershed approach alongside the traditional treatment technology
investments. As part of this effort, the Agency needs information regarding whether: 1) a bias
exists in favor of technological investments due to existing governmental policies, institutional
structures, scientific uncertainties, or problems in valuing the benefits of using a watershed
approach; and 2) if such a bias exists, how can this bias be eliminated?
The SI now seeks to develop more robust information, data, case studies, and lessons-learned
with respect to the use of watershed approaches to avoid or reduce current or future
infrastructure costs and/or operating and maintenance expenses. EPA is specifically interested in
gathering data on the cost savings and ecological and public health benefits that the use of such
an approach may accrue while still achieving compliance with the requirements of the Clean
Water Act and Safe Drinking Water Act.
Charge to the NACEPT Water Infrastructure Workgroup
The Water Infrastructure Workgroup of the National Advisory Council for Environmental Policy
and Technology (NACEPT) is asked to assist the Agency in advancing cost-effective and
sustainable approaches to water resource management and infrastructure to meet watershed
goals. It is the Agency's position that the watershed approach is critical to protecting and
restoring the nation's waters. The Agency furthermore suspects that in order for the benefits of
the watershed approach to be fully realized it must be integrated into the comprehensive planning
processes at the state, regional and local levels.
There are several areas where NACEPT can assist the Agency in determining how to best use its
expertise and resources to promote the watershed approach, as it specifically applies to
Sustainable Infrastructure, and its integration into state, regional and local comprehensive
planning processes.
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar (continued)
Overall Goals:
A. Promote the development of sustainable infrastructure by elevating water resource and
infrastructure protection and management as a state, regional and local government
priority in the comprehensive planning process on a par with transportation planning,
public safety and schools.
B. Encourage widespread adoption of an integrated planning approach focused on water
resource and infrastructure protection and management.
C. Provide information, data, tools and tools necessary for state and local governments and
their communities to adopt these approaches.
Research and Recommendations
The Charge encompasses two distinct focus areas. Consequently, the Office of Water is
proposing that NACEPT adopt a phased approach for addressing the charge over a two-year
period.
A. Phase 1: Comprehensive Planning and Decision-Making
No later than May, 2007 NACEPT would identify incentives, drivers, barriers, and other
factors that encourage or inhibit the prioritization of water resource infrastructure and
management into the comprehensive state, regional and municipal planning frameworks
and decision-making processes.
Also no later than May, 2007 NACEPT would provide recommendations to the Agency
on:
1. Actions the Agency can take to help states and local governments overcome the
barriers and impediments that prevent the full integration of water resource management
as a priority in their respective planning and decision-making processes. For example:
b. How can the Agency more effectively promote increased collaboration among
drinking water, wastewater and storm water utilities, local governments, planning
boards and other stakeholders that result in collective water infrastructure priority
setting under a watershed management context through education and other
means?
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar (continued)
c. How can municipalities and other local government/regional planning entities
build support for promoting a watershed approach to water infrastructure
planning?
d. Using relevant examples from the recent Cooperation Conservation Conference,
what are the ways in which "cooperative conservation" or "coordinated resource
management" has been or can be used to overcome barriers to promoting a
watershed approach to water infrastructure planning?
e. How can EPA, States, or others influence various community stakeholders to
adopt and promote such an approach?
f. What are the specific barriers embodied in existing EPA and state policies or
practices that need to be remedied to help EPA and states further encourage and
assist entities to consider and implement alternative and integrated approaches for
water infrastructure planning and management?
B. Phase 2: Benefits of Traditional versus Alternative Approaches to Water Resource
Infrastructure and Management
No later than May, 2008 NACEPT would identify, analyze and report on the actual or
potential benefits that accrue to local governments and utilities that use alternative and
integrated approaches to manage wastewater, drinking water, and storm water, and the
factors that affect whether alternative or traditional approaches are more cost-effective.
Examples of these alternative approaches include centralized management of
decentralized technologies and systems, soft path technologies, conservation designs,
smart growth strategies, water conservation and reuse policies and low impact
development approaches.
In doing so, NACEPT would examine specific examples and associated factors from
communities where centralized approaches are predominant and those where alternative
approaches have been used, along with the key factors that caused these communities to
adopt these approaches.
In addition, NACEPT would identify, analyze and report on the actual or potential
incentives for local governments and utilities to use alternative and integrated approaches
to manage wastewater, drinking water, and storm water.
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar (continued)
Also no later than May, 2008 NACEPT would provide recommendations to the Agency on:
1. Specific actions (e.g., policy, guidance, technical and programmatic tools, research)
that the Agency can take to encourage and promote the investigation of alternative
approaches that could meet water quality and service objectives at lower life-cycle
cost than traditional approaches. For example, assist EPA in identifying mechanisms
for promoting consideration of centralized management and oversight of
decentralized systems as a cost-effective alternative to physical consolidation of
infrastructure.
Potential Future Work
EPA would be open to identifying additional research areas, upon completion of the current
charge, to further improve the understanding of sustainable infrastructure issues. The additional
research topics may include new areas or may build upon the results of the current research
charge.
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APPENDIX 1: Charge for Developing Recommendations on U.S. EPA's
Sustainable Infrastructure Watershed Pillar (continued)
ATTACHMENT A
Watershed Approach (Long Version)
What does EPA mean by "a watershed approach"?
To achieve environmental goals EPA encourages adoption of a watershed approach as a broad
coordinating process for focusing on priority water resource problems. Using a watershed
approach, multiple stakeholders integrate regional and locally-led activities with local, State,
Tribal, and Federal environmental management programs. These environmental goals should
ultimately protect and restore the health of the nation's aquatic resources, which includes but
goes beyond meeting water quality standards; we must also address (a) pollutants for which there
are currently not numeric standards (including nutrients and clean sediments); (b) healthy aquatic
habitats (including wetlands); (c) coastal and marine waters; and (d) invasive species and other
stressors. Relevant activities in watersheds include use of Clean Water Act and Safe Drinking
Water Act authorities, funding and guidance, as well as many other tools that are available
through other Federal, State, Tribal and local programs and non-governmental resources.
Major elements of successful watershed approaches involve:
• focusing on hvdrologicallv-deflned areas—watersheds and aquifers have hydrologic
features that converge to a common point of flow; watersheds range in size from the very
large, such as the Mississippi River Basin, to a drainage basin for a small creek;
• using an integrated set of tools and programs (regulatory and voluntary,
Federal/State/Tribal/local and non-governmental sectors; innovation; communication and
technical assistance; and sound science and information) to address the myriad problems
facing our Nation's water resources, including: nonpoint source and point source
pollution, habitat degradation, invasive species, and air deposition of pollutants, like
mercury and nutrients;
• involving all parties having a stake, or interest, in developing collaborative solutions to
a watershed's water resource problems;
using an iterative planning or adaptive management process of assessment, setting
environmental and water quality and habitat goals such as water quality standards,
planning, implementation, and monitoring and ensuring that plans and implementation
actions are revised to reflect new data.
• breaking down barriers between plan development and implementation to enhance
prospects for success
EPA continues to work with Federal agencies, States, Tribes, local communities, and non-
governmental sectors to make a watershed approach the key coordinating framework of our
planning, restoration, and protection efforts to achieve "clean and safe" water and healthy
aquatic habitat.
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APPENDIX 2: List of NACEPT Sustainable Water Infrastructure Work Group Members
NACEPT Chair:
John Howard
Vinson & Elkins, LLP
Workgroup Chairs;
Dan Watts (2007)
New Jersey Institute of Technology
Richard Sustich (2006)
University of Illinois at
Urbana/Champaign
Members:
Arthur "Butch" Blazer
New Mexico State Forestry Division
Rob Buirgy
Big Thompson Watershed Forum
Jeff Crane
Colorado Watershed Assembly
Renu Khator
University of South Florida
Clayton Matt
Confederated Salish and Kootenai
Tribes
Bill Mull lean
Texas Water Development Board
Howard Neukrug
Philadelphia Water
Arleen O' Donnell
Massachusetts Department of
Environmental Protection
Harrison Rue
Thomas Jefferson Planning District
Commission & Charlottesville-
Albemarle Metropolitan Planning
Organization
Dan Williams
Architect
EPA Liaisons:
Andy Grassland
Sheila Frace
Robert Goo
Kevin McCormack
Benita Best Wong
Designated Federal Officer;
Sonia Altieri
U.S. Environmental Protection
Agency
Office of Cooperative Environmental
Management
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APPENDIX 3: Schuylkill Action Network Fact Sheet
Schuylkill Action Network (SAN)
rack. 5ri««t
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Sctv/U Action Network fret Sheet - Miy 2OO4
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NACEPT's Initial Findings and Recommendations on EPA's Sustainable Infrastructure Watershed Pillar
July 2007
APPENDIX 4: Portion of Federal Highway Administration Request for Applications for
''Integrating Transportation and Resource Planning to Develop Ecosystem Based Infrastructure
Projects"
Federal Cooperative Agreement Opportunity
Request for Applications (RFA)
Executive Summary
Federal Agency Name: U.S. Department of Transportation
Federal Highway Administration
Office of Acquisition Management
1200 New Jersey Avenue, SE, Room (TBD)
Mail Drop: W36-481
Washington, DC 20590
Attn: Sarah Berman, HAAM-40F
Funding Opportunity Title: "Integrating Transportation and Resource Planning to
Develop Ecosystem Based Infrastructure Projects"
Announcement Type: This is the formal announcement of this funding
opportunity. It has previously been described on FHWA's
STEP website at http //www fhwa dot aov/hep/step/fv07rp.htm
Funding Opportunity Number: RFA Number DTFH61-07-RA-00117
SECTION I - FUNDING OPPORTUNITY DESCRIPTION
A. STATEMENT OF PURPOSE
The Federal Highway Administration (FHWA) hereby requests applications to result in the
award of up to ten (10) cooperative agreements for "Integrating Transportation and Resource
Planning to Develop Ecosystem Based Infrastructure Projects."
B. LEGISLATIVE AUTHORITY
Section 5207 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A
Legacy for Users (SAFETEA-LU), Public Law 109-59, authorizes "... a Surface Transportation
Environment and Planning Cooperative Research Program (STEP). The program carried out
under this section may include research (1) to develop more accurate models for evaluating
transportation control measures and system designs that are appropriate for use by State and local
governments (including metropolitan planning organizations) in designing implementation plans
to meet Federal, State, and local environmental requirements; (2) to improve understanding of
the factors that contribute to the demand for transportation; (3) to develop indicators of
economic, social, and environmental performance of transportation systems to facilitate analysis
of potential alternatives; (4) to meet additional priorities determined by the Secretary in the
strategic planning process under section 508; and (5) to refine, through the conduct of
workshops, symposia, and panels, and in consultation with stakeholders (including the
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APPENDIX 4: Portion of Federal Highway Administration Request for Applications for
"Integrating Transportation and Resource Planning to Develop Ecosystem Based Infrastructure
Projects" (continued)
Department of Energy, the Environmental Protection Agency, and other appropriate Federal and
State agencies and associations) the scope and research emphases of the program."
The authority to award a cooperative agreement for this effort is found in SAFETEA-LU Section
5201, paragraph (c)(3) Cooperation, Grants, And Contract, which states, "The Secretary may
carry out research, development, and technology transfer activities related to transportation... by
making grants to, or entering into contracts and cooperative agreements with one or more of the
following: the National Academy of Sciences, the American Association of State Highway and
Transportation Officials, any Federal laboratory, Federal agency, State agency, authority,
association, institution, for profit or nonprofit corporation, organization, foreign country, or any
other person."
C. BACKGROUND
The concept of integrating both infrastructure and ecological planning efforts has been
incorporated into the last three transportation bills. Most recently, Section 6001 of the Safe,
Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-
LU), Public Law 109-59, specifically incorporates environmental planning factors into the
statewide and metropolitan planning processes, and requires that transportation planning
agencies consult, as appropriate, with natural resource planning and protection agencies to
coordinate and compare their planning efforts and products. These efforts lead to more informed
transportation planning decision-making, including the integration of natural resource
considerations with transportation needs, prioritized mitigation areas, and the identification of
mitigation opportunities having the greatest potential to restore the environmental functions that
may be affected by a proposed transportation project. Section 6002 of SAFETEA-LU
strengthens and carries these planning objectives forward into project development by requiring
transportation agencies to coordinate with resource agencies and public stakeholders as early as
possible in the Environmental Review Process.
In 2002, Executive Order 13274 Environmental Stewardship and Transportation Infrastructure
Project Reviews was signed. The order was issued to promote environmental stewardship in the
nation's transportation system and to streamline the environmental review and development of
transportation infrastructure projects. An interagency task force was established to oversee the
implementation of the Executive Order and monitor the environmental review of certain high
priority projects. A workgroup was established by the task force to focus on creating and
documenting better ways to more effectively link transportation system planning performed by
State and local governments with natural and cultural resource concerns. While planning efforts
are required at transportation agencies as well as resource conservation agencies, historically
these efforts have occurred with little or no coordination between the agencies until the plans are
implemented and specific projects initiated. In addition, the workgroup formed the core group
that led to the creation of the publication Eco-Logical: an Ecosystem Approach to Developing
Infrastructure Projects, (Eco-Logical) in early 2006. A PDF version of Eco-Logical is available
at: httD://www.environment.fhwa.dot.gov/ecological/eco index.asp.
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APPENDIX 4: Portion of Federal Highway Administration Request for Applications for
"Integrating Transportation and Resource Planning to Develop Ecosystem Based Infrastructure
Projects" (continued)
The multi-agency publication Eco-Logical encourages Federal, State, tribal, and local partners to
integrate environmental solutions and goals into planning for infrastructure development. Eco-
Logical puts forth the conceptual groundwork for integrating environmental and infrastructure
plans across agency and geographical boundaries, and endorses ecosystem-based mitigation
approaches to compensate for unavoidable impacts caused by infrastructure projects.
The ecosystem approach to infrastructure development as outlined in Eco-Logical consists of
restoring, creating, enhancing, and preserving habitat and other ecosystem features in
conjunction with or in advance of projects in areas where environmental needs and the potential
environmental contributions have been determined to be greatest. Ecosystem-based mitigation
extends existing compensatory mitigation options by offering a way to evaluate alternatives for
off-site mitigation and/or out-of-kind mitigation in the ecologically most important areas as
defined by interagency partners and the public. The approach shifts the Federal government's
traditional focus from individual jurisdictions and actions to a larger focus of multiple agencies
within the larger natural ecosystem. The overall goals of the ecosystem approach to mitigation
and Eco-Logical are: conserve larger, scarce, multi-resource ecosystems; increase habitat
connectivity; improve predictability in environmental review and regulatory processes; provide
better public involvement to improve transparency and establish greater credibility; and
streamline infrastructure planning and development.
Various habitat or watershed programs are cited in Eco-Logical as examples of components of an
ecosystem approach to mitigation. Some of the examples focus on conservation of habitat for a
single species, such as the Indiana Habitat Conservation Plan for the Indiana Bat and the
Alabama Gopher tortoise conservation bank. Other initiatives, such as the Colorado Short grass
Prairie Initiative and North Carolina's Ecosystem Enhancement Program, are more
comprehensive in their conservation strategies.
D. OBJECTIVES
The objective of the "Integrating Transportation and Resource Planning to Develop Ecosystem
Based Infrastructure Projects" is to conduct an integrated planning effort and develop ecosystem-
based approaches for transportation related efforts as outlined in Eco-Logical, which may be
used as case studies and best practices to be promoted nationwide.
E. STATEMENT OF WORK
FHWA asks prospective applicants to focus on the Eco-Logical document as the primary
construct in developing their proposal. The applicant's application shall address one or more
elements suggested in the eight-step integrated planning process described in Eco-Logical.
Eco-Logical articulates a vision of how infrastructure development and ecosystem conservation
can be integrated to harmonize economic, environmental, and social needs and objectives. The
development of an ecosystem based approach will provide planning agencies, as well as
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APPENDIX 4: Portion of Federal Highway Administration Request for Applications for
"Integrating Transportation and Resource Planning to Develop Ecosystem Based Infrastructure
Projects" (continued)
communities and resource agencies, the ability to utilize the best available science and achieve
greater efficiencies in the transportation decision-making process.
The ecosystem approach should be viewed as a tool for partners to develop acceptable solutions
that complement agency missions. Agencies and private and public partners are encouraged to
build collaborative partnerships to establish an integrated planning method that would ultimately
yield a Regional Ecosystem Framework (REF) that designates environmental priority areas,
mitigation options, and performance measures for the mitigation effort. Some expected benefits
from this approach can be: safer and improved infrastructure that balances social and ecological
concerns, watershed and ecosystem health, and minimized habitat fragmentation as a result of
planning focused on increased habitat connectivity and conservation.
Recipients shall perform tasks within the following work areas, which are based on the eight-step
integrated planning process described in Eco-Logical:
1. Partnering and Data;
2. Integration of Conservation and Transportation Planning; and
3. Performance Monitoring
Note; Applicants may propose to perform activities under one, two or three of the above
work areas. Additional weight will be given to proposals that incorporate elements of
multiple work areas.
Note; In addition to the three work areas noted above, applicants are encouraged to
propose other activities that support the integration of natural resource planning and
preservation with the development of transportation based plans and projects within the
funding limitation on page 8 of this RFA.
Area 1. Partnering and Data
This work area is based on the initial steps of the integrated planning process as described in
Eco-Logical. Applicants applying under this work area may be at the early stages of developing
an Eco-Logical framework for their transportation infrastructure program or individual projects.
Partnerships are being developed and planning documents are being collected.
Note; Applicants shall identify what their agency will accomplish with this project, identify
where their agency is in institutionalizing the Eco-Logical framework, and indicate the next
steps to be taken in the project.
The Recipient shall engage in any or all of the following:
o Partnership building: convening multiple agencies and stakeholders
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APPENDIX 4: Portion of Federal Highway Administration Request for Applications for
"Integrating Transportation and Resource Planning to Develop Ecosystem Based Infrastructure
Projects'" (continued)
• For example, facilitated meetings/training; establishment of formal
agreements such as memorandums of understanding/agreement
o Data sharing: collecting and sharing existing plans and data among multiple
agencies
o Data gathering: collecting data and/or researching existing resources
• For example, to be used in the development of a regional ecosystem
framework (REF); CIS based maps of ecological areas and cultural
resources
Area 2. Integration of Conservation and Transportation Planning
This work area is based on the middle steps of the integrated planning process as described in
Eco-Logical. Applicants applying under this work area have already formed partnerships with
multiple agencies, have collected planning documents from these agencies and are beginning to
integrate these plans.
Note; Applicants shall identify what their agency will accomplish with this project, identify
where their agency is in institutionalizing the Eco-Logical framework, and indicate the next
steps to be taken in the project.
The Recipient shall engage in any or all of the following:
o Resource assessment: identifying the most critical conservation areas from an
ecosystem perspective
o Conservation planning: determining strategies to conserve critical resources
• For example, development of a conservation strategy for important habitat
and/or resources that identifies actual opportunities for adaptive
management and ecosystem enhancements
o Integrated planning: applying conservation data and assessments, goals and
strategies into transportation planning
• For example, the incorporation of environmental resource management
plans and other data to be considered as part of the environmental analysis
for transportation planning (multimodal, corridor), project planning,
environmental analysis, design, maintenance, and operations
o Ecosystem mitigation: connecting ecosystem strategies to transportation projects
and programs
Area 3. Performance Monilorine
This work area is based on the final steps of the integrated planning process as described in Eco-
Logical. Applicants applying under this work area have already identified and prioritized
mitigation areas based on proposed transportation infrastructure projects. This work area
evaluates how well the Eco-Logical framework is implemented, the environmental health of the
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APPENDIX 4: Portion of Federal Highway Administration Request for Applications for
"Integrating Transportation and Resource Planning to Develop Ecosystem Based Infrastructure
Projects" (continued)
ecosystem, environmental documentation and review timeliness, and the deliverability of
transportation infrastructure projects.
Note; Applicants shall identify what their agency will accomplish with this project, identify
where their agency is in institutionalizing the Eco-Logical framework, and indicate the next
steps to be taken in the project.
The Recipient shall develop at least one of the following:
o Performance measures: defining metrics to be used to assess ecosystem health and
stewardship
o Monitoring systems: developing programs for monitoring ecosystem health and
stewardship
• For example, the development of an adaptive measurement process to
monitor the impacts of infrastructure plans and projects on the ecosystem
o Agency performance measures: development of guidelines to assist State/local
transportation agencies and other groups to effectively and efficiently integrate
planning efforts by implementing and attaining compliance with related
rules/regulations, policies, and standards
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APPENDIX 5: EPA Region I Charles River Project Press Release
Charles River 'Report Card' Grade Drops to a "B-" - Clean Up Efforts Continue;
Outlying Communities Challenged to Match Boston and Cambridge's Efforts
Contact: Peyton Fleming, EPA Press Office (617-918-1008)
For Immediate Release: April 21, 2004 Release # 04-04-39
BOSTON - The U.S. Environmental Protection Agency today announced a report card grade of
"B-", down from a "B" last year, for the Charles River. The grade, based on water quality data
collected last year, shows that water quality improvements in the river have leveled off in recent
years and that additional stormwater controls and planned sewer system upgrades will be
essential for water quality to improve over the next few years.
While environmental officials acknowledged the reduced grade indicates the huge challenge
involved in restoring the Charles, they also pointed out that the goal of making the river safe for
swimming and fishing is within reach. Future improvements will depend to a large extent on
towns and cities along the Charles incorporating the kind of all-out effort already underway in
both Boston and Cambridge. Those two cities are spending hundreds of millions of dollars
tackling illicit sewer connections, stormwater overflows and other pollution problems that
continue to beset the Charles River, especially after rain events.
"If every community along the Charles puts in the kind of effort to reduce sewer waste we have
seen in Cambridge and Boston, we can indeed cross the finish line," said Robert W. Varney,
regional administrator for EPA's New England Office, at a news conference today on the Weeks
Footbridge overlooking the river. "The dramatic water quality improvements we achieved in the
early stages of this project are still with us, and the Charles continues to be much cleaner and
safer than it was in the mid-1990s. However, with each increment of progress, the task ahead
becomes more challenging. We grabbed the low-hanging fruit in the late 1990s. Now we are
reaching for the upper branches."
Over the last five years, communities have successfully closed illegal discharge pipes and
separated sewer lines responsible for much of the river's pollution. More than one million
gallons a day of sewerage was removed from the river through those efforts. But stormwater
overflows and illegal sewer-line hookups continue to discharge more sewage than is acceptable.
"Today's grade clearly underscores the complexities of resolving issues in the urban
environment," said Robert Zimmerman, executive director of the Charles River Watershed
Association, which collects the water quality samples used for grading the river. "Nevertheless,
with attention and diligence, and some creativity, the Charles can be fully restored. I'm looking
forward to redoubling our efforts over the coming years."
Last year, the river was clean enough for boating 85 percent of the time, down from 91 percent
of the time in 2002 and met swimming standards 46 percent of the time, compared to 51 percent
the previous year.
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APPENDIX 5: EPA Region I Charles River Project Press Release (continued)
Although the 2003 data shows that challenges that lie ahead, dramatic gains have been made
since the Clean Charles 2005 initiative began in 199S. At that time, EPA gave the Charles a
grade of "D," since it was meeting bacteria boating standards only 39 percent of the time and
swimming standards only 19 percent.
During that time, significant efforts by state and local agencies, businesses and individuals have
successfully reduced stormwater discharges, illicit sewer connections and other pollution
sources.
Various actions were outlined today for achieving additional water quality improvements in the
river, among those:
• Boston Projects: Boston, with support from the MWRA, is spending millions of dollars to
reduce combined sewer overflows into the river from the Stony Brook drainage basin,
which includes Jamaica Plain, Hyde Park, Roslindale and West Roxbury. When this
project is done in 2006, Boston will have removed the largest remaining source of
bacterial pollution to the Lower Basin. Boston has also undertaken a $1.5 million project
to identify illicit sewer connections in this drainage basin. Illicit connections are also
being removed in Fanueil Brook, another significant source of bacteria into the river.
This project is part of a new City-Wide Illicit Connection Investigation Program that
Boston is undertaking. The three-year program will address an estimated 6,000 acres
throughout the city served by separate storm drains. The investigation will focus on
approximately 95 outfalls, 2,500 manholes and 6,000 building connections. Collectively,
Boston's programs removed nearly three-dozen illicit connections last year that were
discharging 12,000 gallons of sewage a day into the river.
• Cambridge Projects: Since the mid-1990s, Cambridge has spent more than $100 million
on sewer separation and stormwater management activities. Over the next several years,
Cambridge has earmarked more than $70 million for additional sewer reconstruction
projects. Among the biggest projects is separating storm drains from sewer pipes in the
city's Agassiz neighborhood, a project that will result in far fewer discharges from the
Cottage Farm Combined Sewer facility, the largest discharge source on the Cambridge
side of the river. Another significant project is a $30 million effort to eliminate 90 million
gallons of combined sewerage that presently flows into the Charles from the
Cambridgeport neighborhood during heavy rains.
• Watershed-Wide Stormwater Management Subcommittee: Boston and Cambridge have
agreed to lead an EPA-sponsored subcommittee, created as part of the Clean Charles
2005 Task Force, to make sure that all municipalities in the watershed are doing all that
they can to reduce stormwater pollution into the river. Based on the significant
knowledge and technical expertise of these two cities, their experience will be a
tremendous asset to other municipalities to identify and correct inappropriate discharges
into the river. Among the top priorities is the development of a comprehensive,
systematic illicit connection identification and elimination protocol similar to the
program being used by Boston. EPA intends to make comprehensive illicit removal
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APPENDIX 5: EPA Region I Charles River Project Press Release (continued)
o programs a requirement of each municipality=s stormwater management permits. EPA
will monitor through annual reports the progress these communities are making toward
eliminating all connections.
o Hot spot monitoring: Citizen watchdog Roger Frymire of Cambridge has helped identify
bacterial loads to the river, which have allowed EPA to direct municipalities, including
Waltham, Boston, Watertown and Brookline, to give immediate attention to these
discharges. In the year ahead, EPA will continue to look for such hot spots with
Frymire's help.
For more information about EPA's Clean Charles 2005 project, visit EPA's web site at
http://www.epa.gov/region01/charles/index.html.
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APPENDIX 6: Nitrogen Trading by Connecticut POTWs
Connecticut Pre-proposal to the United States Environmental Protection
Agency
Innovations Grant Program
August 19, 2002
Submitted by
Connecticut Department of Environmental Protection
Bureau of Water Management
79 Elm Street
Hartford, CT 06106-5127
Monitoring of Municipal Sewage Treatment Plants For Pollutant Credit Exchange and
Compliance
Summary
The Connecticut Department of Environmental Protection (DEP) is implementing legislation
authorizing the issuance of a watershed general permit to regulate the discharge of nitrogen from
municipal point sources and the institution of a nitrogen credit-trading program pursuant to the
approved Total Maximum Daily Load (TMDL) for Long Island Sound. The General Permit (GP)
issued by DEP regulates 79 publicly-owned wastewater treatment works (POTW) located
throughout the state of Connecticut and establishes the most expansive program of water
pollutant trading in the U.S. This program is projected to save the state $200 million in capital
construction costs and will accelerate the schedule for meeting the TMDL wasteload allocation
(WLA) for point sources by providing economic incentives for those POTWs that move quickly
to remove nitrogen and comply with the limits in the GP. There is potential to expand this
approach within Connecticut to other sources, including nonpoint sources. It can also serve as a
model for other states that are facing similar TMDL implementation challenges not only as a
cost-effective approach to reducing a pollutant from numerous sources, but also as an innovative
approach to integrating the allocation of State Revolving Fund funding with permitting and
enforcement programs.
Despite the anticipated value and cost savings from implementing the Nitrogen Credit Exchange
(NCE) in Connecticut, there are concerns over the reliability and accuracy of standard
monitoring protocols. The GP sets monitoring frequency based on plant size. Facilities with
design flows greater than or equal to 10 MGD are required to monitor the final effluent at a
minimum frequency of twice per week while smaller plants are required to monitor at a
minimum of once per week. Each sample must be a 24-h composite sample and be analyzed
according to methods approved by EPA. While it is believed that this frequency will be adequate
to characterize an individual plant's nitrogen load and that analytical protocols are proven
suitable for wastewater analysis, local plant variability and weather effects may produce enough
statistical error to require additional analyses. There have been no detailed studies of effluent
nitrogen variability on daily to weekly time scales at Connecticut facilities. Given the economic
impact of the nitrogen trading program at municipal and state levels, DEP needs to provide
assurance that monitoring to generate credits is reasonably accurate and conducted at the most
cost-effective frequency possible. Further, this evaluation will assist scheduling of compliance
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APPENDIX 6: Nitrogen Trading by Connecticut POTWs (continued)
checks and reduce the possibility that nitrogen loads to Long Island Sound are erroneously under
reported.
Background
Over the past decade, DEP has worked with the EPA Long Island Sound Study (LISS) and the
Water Environment Research Foundation (WERP) to develop a framework for a Nitrogen Credit
Trading Program. Connecticut and New York jointly drafted the TMDL to address seasonal low
oxygen problems in Long Island Sound and with its approval in early 2001, Connecticut is faced
with reducing nitrogen loads from 79 POTWs scattered throughout the state. Nitrogen is the
primary pollutant linked to an extensive low-oxygen (hypoxia) problem that affects up to half of
Long Island Sound's 1300 square miles of bottom during periods of summer stratification when
bottom waters are prevented from mixing with surface waters. The nitrogen fuels the growth of
algae, which eventually decays after it settles to the bottom of the Sound. The Sound is so
heavily enriched that the microbial decay drives oxygen to levels low enough to create unhealthy
or even lethal conditions for aquatic life.
The TMDL1 to correct this problem, which was approved by the EPA in April 2001, requires a
58.5% reduction in baseline anthropogenic nitrogen loads from sources in Connecticut and New
York by the year 2014. Using the trading framework developed by the LISS and WERF2 as a
starting point, DEP proposed legislation3 to establish a nitrogen general permit and a nitrogen
credit-trading program for municipal point sources throughout Connecticut. Public Act 01-180
was passed in June 2001 and established a Nitrogen Credit Exchange (NCE) to be guided by a
Nitrogen Credit Advisory Board (NCAB) under the authority of the Commissioner of the DEP.
The Nitrogen General Permit is key to the success of Connecticut's trading program. It
collectively regulates 79 POTWs located throughout the state and establishes the basis for the
most expansive program of water pollutant trading in the U.S. The GP sets annual nitrogen limits
for each POTW that are increasingly stringent until the final WLA is attained in 2014. POTWs
can comply by either treating or by purchasing credits from the Nitrogen Credit Exchange
annually. The nitrogen credit-trading program is both innovative and essential to resolve the
complex water quality problems in Long Island Sound in a cost-effective manner. The proposed
program links together Connecticut's existing general permitting authorities, the State Revolving
Loan Program (SRF) and other salient features of state and federal laws to form a comprehensive
regulatory program to assure compliance with Connecticut's nitrogen reduction requirements
under the TMDL. However, the success or failure of this program, and the improvement to the
health of LIS, rely heavily on our ability to accurately monitor nitrogen loads from the 79
facilities incorporated in the GP.
TASK1
The first task under this proposal would be to conduct high-intensity monitoring at four to six
municipal POTWs representing a range of sizes, nitrogen removal capability, and susceptibility
to weather changes (e.g., infiltration from wet conditions). Samples would be collected at the
facilities by automatic sampler for later analysis. One larger facility would be selected to utilize
online real-time nitrogen analysis systems. The real-time analysis system will be installed and
operated for a period of one year. The facility utilizing the online real real-time system would
also conduct the same high-intensity monitoring. Laboratory analyses would be conducted using
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APPENDIX 6: Nitrogen Trading by Connecticut POTWs (continued)
EPA standard protocols under an approved EPA Quality Assurance Project Plan (QAPP).
Frequency would be at least four times per day over a two-week period once during each of four
seasons. This sampling strategy would experience a full range of wet/dry and warm/cool
conditions that might affect nitrogen removal capability, and would also fully examine day to
day fluctuations in effluent nitrogen strength.
Data would be analyzed statistically to identify and develop a sampling scheme that would
maximize precision in monthly nitrogen load calculations. It is possible that certain conditions
might need to be targeted for more frequent sampling, such as higher spring flows that might
vary with rainfall, or certain days of the week that might reflect maximum or minimum
concentrations related to business days vs. weekend conditions. The data could also help guide
compliance monitoring programs to ensure reliable, yet cost-effective checks on self-monitoring
programs. In both cases, it is the desire of DEP to gain the most reliable nitrogen load
estimations with the minimum resources, saving money for the municipalities and DEP while not
compromising the credibility of the NCE.
TASK 2
In addition to the first year's assessment of monitoring, DEP proposes to evaluate the program's
effectiveness in regulating point source discharges as related to the accuracy of nitrogen load
estimates. Because the first year of operation of the NCE (2002) will be based on the
requirements of the GP noted above, this monitoring study will allow estimates of error under
GP protocols compared to proposed revisions in the monitoring program that the study might
support. Since one possibility is that the GP monitoring requirements are excessive, it will also
be possible to demonstrate what significance there might be to an increase in sampling error
under a reduced sampling schedule. Any number of "what if scenarios can be constructed using
the database generated in this study, allowing an optimal monitoring program to be selected from
a range of potential error conditions.
TASK 3
The third task would seek to maximize efficiency of quality assurance for individual facility
monitoring programs (e.g., duplicates, blanks) and frequency of independent (e.g., DEP) split
sampling or compliance sampling. This analysis of the data would focus on error in split and
duplicate samples, perhaps using two labs for some of the analyses, to ascertain level of
reliability at the facility level and increase value of compliance sampling at the state level. An
attempt will also be made to identify attributes associated with unreliable data or operational
problems leading to development of a "risk-based" compliance/technical assistance program.
Broader Application
Connecticut has embarked on a complex, but highly innovative, general permitting and trading
program that has not been implemented to this degree anywhere else in the U.S. Of prime
consideration in evaluating the success of the point source program being implemented in 2002
and the potential for change in sampling frequency and timing, including compliance sampling
without compromising nitrogen load estimation accuracy. In addition is the learning value it may
hold for other states implementing complex TMDLs that require accurate reporting of pollutant
loads. Estuaries like the Chesapeake Bay and Gulf of Mexico are addressing hypoxia problems
similar to those observed in Long Island Sound and are planning and implementing nutrient
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APPENDIX 6: Nitrogen Trading by Connecticut POTWs (continued)
control programs in multi-state areas. The successes and failures of Connecticut's program will
yield valuable lessons for these and other areas where closed system trading under a general
permit makes economic and environmental sense and the credibility of the program relies on
accurate monitoring of effluent parameters.
Deliverables
Final products of this project will include:
1. A technical assessment of the intensive monitoring effort along with a comparative
analysis of utilization of online real-time nitrogen analysis. (Task 1)
2. An evaluation of the change in error related to a range of monitoring schedules (Task 2)
3. An evaluation of quality assurance sampling and compliance sampling (Task 3)
Budget (estimatedfor a two-year study effort) [REDACTED BY US EPA]
References
• New York State Department of Environmental Conservation and Connecticut
Department of Environmental Protection. 2000. A total maximum daily load analysis to
achieve water quality standards for dissolved oxygen in Long Island Sound. NYSDEC
and CTDEP, 57 p.
• Water Environment Research Foundation. 1999. Nitrogen credit trading for Long Island
Sound watershed. R.E. Moore, M.S. Overton, R.J. Norwood and D. DeRose, Pis. WERF
Final Report RFP 97-IRM-5.
• Substitute Senate Bill No. 1012. 2001. An act concerning nitrogen reduction in Long
Island Sound, Public Act No. 01-180. Connecticut General Assembly.
• General Permit for Nitrogen Discharges
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APPENDIX 7: California Regional Blueprint Planning Program (http://calblueprint.dot.ca.gov)
California Regional Blueprint Planning Program
The Regional Blueprint Planning Program is intended to better inform regional and local
decision-making, through pro-active engagement of all segments of the population as well as
critical stakeholders in the community, business interests, academia, builders, environmental
advocates, and to foster consensus on a vision and preferred land use pattern. It is anticipated that
the regional blueprint planning grants will build capacity for regional collaboration and
integrated planning that will in turn enable regions to plan to accommodate all their future
growth, thereby reducing need for sprawl.
The grants for regional collaborative decision-making will lead to adoption of blueprint plans
that will:
1. Foster a more efficient land use pattern that (a) supports improved mobility and reduced
dependency on single-occupant vehicle trips, (b) accommodates an adequate supply of housing
for all incomes, (c) reduces impacts on valuable habitat, productive farmland, and air quality, (d)
increases resource use efficiency, and (e) results in safe and vibrant neighborhoods.
2. Provide consumers more housing and transportation choices.
3. Improve California's economic competitiveness and quality of life.
4. Reduce costs and time needed to deliver transportation projects through informed early public
and resource agency involvement.
5. Secure local government and community support, including that of under-represented groups,
to achieve the resulting comprehensive vision through including innovative computer models
and public involvement activities.
6. Establish a process for public and stakeholder engagement that can be replicated to build
awareness of and support for critical infrastructure and housing needs.
The regional blueprint efforts will include development of regional performance measures that
can measure progress toward the region's own vision for future land use and transportation. Each
region will also select several statewide performance measures to measure progress toward
statewide transportation system and housing goals.
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APPENDIX 8: Envision Utah (http://www.envisionutah.org)
Introduction to Envision Utah
By the year 2020, the Greater Wasatch Area of Utah will add a million more residents, two-
thirds of whom will be our own children and grandchildren. From Brigham City to Nephi and
Kamas to Grantsville, Utah, residents breathe the same air, share common water sources and use
the same roads as we drive to work, shopping and recreation. Just as Utah's founders planned for
the future of our valley, we must work together today to preserve the quality of life in our
growing communities.
In January 1997, the Envision Utah Public/Private Partnership was formed to guide the
development of a broadly and publicly supported Quality Growth Strategy - a vision to protect
Utah's environment, economic strength, and quality of life for generations to come. Five years of
scenarios analysis, research and public involvement have helped Envision Utah bring the topic of
planning and preparing for growth to the forefront of the public mind. With the help of thousands
of Utah residents, Envision Utah has developed a Quality Growth Strategy that will help
preserve critical lands, promote water conservation and clean air, improve our region-wide
transportation systems, and provide housing options for all residents.
Envision Utah's goal throughout the process has been to involve key decision-makers and the
community to gain support at the ground level. Building grass roots support for the project will
ensure successful implementation. The Envision Utah effort has included research concerning
core values of Utah residents, workshops with key stakeholders to address where and how to
grow, and extensive public awareness and education efforts asking Utah residents to express
their preferences for their communities' future. The Governor's Office of Planning and Budget
coordinates a technical committee, Quality Growth Efficiency Tools (QGET), which provided
critical technical information to help analyze the impacts of growth on transportation, air quality,
land use, water supply/demand, and infrastructure costs. Through the exhaustive involvement of
the public, local and state elected officials, the business, civic, and religious communities, and
other key stakeholders, Envision Utah has gathered information about what Greater Wasatch
Area residents value and how they think growth should be accommodated. Based on this
information, Envision Utah identified six primary goals that need to be addressed in the Greater
Wasatch Area if we are to protect our environment and maintain our economic vitality and
quality of life as we accommodate anticipated growth:
• enhance air quality;
• increase mobility and transportation choices;
• preserve critical lands, including agricultural, sensitive and strategic open lands;
• conserve and maintain availability of water resources;
• provide housing opportunities for a range of family and income types; and
• maximize efficiency in public and infrastructure investments to promote other goals.
These goals can be realized over time by the careful and deliberate pursuit of the thirty-two
individual strategies identified by Envision Utah in the Quality Growth Strategy. These strategies
rely on citizen involvement with local officials, local land-use decision making and more
awareness of free market needs in housing choices. Cooperation at the regional level, state
incentives to local governments and local government incentives to developers will also be
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necessary to address issues such as air quality, water conservation, housing opportunities,
transportation, and critical lands.
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APPENDIX 9: Jefferson Area Eastern Planning Initiative
(http://www.tjpdc.org/community/epi.asp)
Jefferson Area Eastern Planning Initiative
Building Livable Communities
The small city and rural areas that make up the Charlottesville, Virginia region are growing
rapidly. While growth stimulates new economic and cultural resources, many are concerned that
the natural beauty of the Blue Ridge Mountains and the historical ambience of Monticello are
being encroached upon by strip commercial development and dispersed subdivisions. These
concerns prompted the Sustainability Council of the Thomas Jefferson Planning District
Commission (TJPDC) to develop the broadly supported 1998 "Sustainabilitv Accords".
In January 2000 the TJPDC launched the Jefferson Area Eastern Planning Initiative (EPI) with a
grant from the Federal Highways Administration (FHWA^ Transportation & Community &
System Preservation (TCSP) Program. The EPI Advisory Committee, made up of elected
officials, residents, and leaders from business, development, environmental and community
groups, met eleven times and hosted four public workshops during the two-year study, focusing
on three key questions:
• How will we live? - In what types of communities do we want to live and work by the
year 2050?
• Where will we live? - What areas in the region are suitable for urban development and
what areas are off limits?
• How will we get there? - What steps are needed to move the region from where it is now
to the desired types of communities and growth patterns?
How will we live?
Community Elements
How can community design improve everyday quality of life? The project team developed
drawings and spreadsheets describing the physical characteristics of 17 existing community
types or "elements" throughout the region, from Charlottesville neighborhoods to small towns
like Stanardsville and Palmyra. Each element was scaled to a 12 mile circle, about a S-minute
walk from edge to center, which made it easy for participants to visualize and compare them.
Residents evaluated the community elements based on personal perspectives and the regional
Sustainability Accords. The team then developed enhanced urban and suburban community
elements, showing how more compact growth could occur over time.
Designing Desirable Communities
These design principles were developed by observing our region's historic communities, and can
be applied to downtown neighborhoods, growing suburbs, or rural small towns.
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APPENDIX 9: Jefferson Area Eastern Planning
Initiative (continued)
• Create a focal point that establishes community
identify
• Provide a variety of activities to encourage
interactions and improve convenience
• Design buildings and distances at a pedestrian
scale
• Provide options to walk, bike, drive, and use
transit
• Make open spaces accessible and available
The Urban Mixed Use design combines a healthy
mix of housing, workplaces, shopping, culture and
recreation within a 5-minute walk.
NOTE: The EPI is called "The Eastern Planning
Initiative" because our funding required us to study the faster-growing, or Eastern, portions of
the five-county region. Although not part of the original study, Nelson County has recently
adopted a new Comprehensive Plan based on the EPI principles.
Where will we live?
Regional Growth Scenarios
Through games developed by the project team,
residents created maps of possible future
development patterns by clustering community
elements. Using the CorPlan model, the team
converted the maps into three scenarios that
compared impacts on transportation, land
consumption, and other factors from the
Sustainability Accords. The reaction from the
public at the workshops was clear: residents
rejected a dispersed, low-density pattern, and
preferred clustered enhanced communities along
major corridors and key crossroads.
The Dispersed Scenario shows what can happen by the year 2050 if recent development trends
continue. Suburban communities will continue to spread north along US 29 and east along US
250. A large network of wider roads and bypasses costing about $1 billion will be needed, and
transit will not be feasible outside the core city. The Town Centers and Urban Core scenarios, by
contrast, feature urban and enhanced suburban community elements as the building blocks for
development. Growth would be concentrated in and around Charlottesville, with varying options
for growth at major crossroads (Town Centers) or around existing villages and towns (Urban
CoreL and CoreM).
How the Scenarios Compai
Percent Farms & Forests
Percent Developed
Percent Living in
Clustered Communities
Percent Non-Auto Trips
Annual Gallons Gas
Consumed (billions)
Percent Travel Congested
Water Quality & Quantity
•e
Dispersed
55%
45
13
4
155
44
Poor
Town
Centers
64%
36
61
15
121
27
Good
Urban
Core
65%
35
68
18
110
20
Good
APPENDIX 9: Jefferson Area Eastern Planning Initiative {continued)
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The transportation system for the alternative scenarios is based upon a pedestrian-friendly street
network in the development areas and allows for extensive expansion of the transit system,
including rail or bus rapid transit if the community wishes. Large freeways around the city would
not be necessary. The street system would cost about $500 million, half as much as the network
required by the Dispersed Scenario. The table below shows some real differences in the
scenarios. While all would accommodate the same anticipated growth of people and jobs, the
alternative scenarios would consume much less land and reduce overall roadway congestion
significantly.
How will we get there?
Building Success
The Advisory Committee and the public agree that business as usual is not a preferred course.
They also agree that changing course could be quite a challenge. They asked questions such as:
Is it possible to build walkable communities in our auto-oriented society? Is it possible to cluster
communities in areas where growth makes sense? Is it possible to change the way roads are
planned and built? Is it possible for all localities to agree on a coordinated approach? What
happens if not everyone buys into this new approach?
To address these challenges, the Advisory Committee recommends that the localities in the
region work together to achieve the keys to success listed to the right. Some have already been
initiated or are under consideration. Albemarle County has defined designated development areas
in its comprehensive plan and recently incorporated the Neighborhood Model, a blueprint for
livable communities, into its plan. Fluvanna County is updating its zoning ordinance; Nelson
County is incorporating community elements into its comprehensive plan and zoning ordinance.
Charlottesville recently completed a Commercial Corridor Study to promote livable communities
and is rewriting its zoning code, and Greene County is now embarking upon a comprehensive
plan update. TJPDC just completed a Regional Economic Development Plan and is developing
the UnJAM 2025 transportation plan that meshes the MPO's goals for the urban area with new
visions for the rural areas.
The Advisory Committee lauds the region's localities for all their efforts to work toward a
sustainable future and presents this study as an important resource in taking another important
step forward.
Dispelling the Myths
Myth 1 - We Can Build Our Way Out Of Congestion
Building new freeways and widening roads encourages development to spread, making trips
longer and causing growth in overall vehicle miles traveled. The net result is more congestion.
The EPI found that the number of congested miles driven under the Dispersed Scenario is nearly
twice that of the Town Centers and Urban Core Scenarios despite adding twice the number of
roadway lane miles.
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APPENDIX 9: Jefferson Area Eastern Planning Initiative (continued)
Myth 2 - Density Causes Congestion
It is logical to think that more density leads to more congestion. But combining local trips into
well designed compact development areas actually reduces congestion for two reasons: 1) typical
trips are shorter, resulting in fewer vehicle miles driven, and 2) people can choose to walk,
bicycle or take transit at least some of the time. The EPI analysis confirms this. The more
compact Town Centers and Urban Core Scenarios result in half the congestion of the Dispersed
Scenario with far fewer road investments.
Myth 3 - Density Is Unattractive And Not Marketable
The EPI scenarios, in response to strong preferences expressed by local residents, don't call for
any new or existing communities to exceed the density of downtown Charlottesville (buildings
up to four stories high and five or fewer single family homes per acre). The urban and enhanced
suburban communities are able to accommodate more people and jobs by organizing streets,
parking, public spaces and buildings more efficiently so suburban places can gradually fill in
with attractive, livable amenities. It is primarily the proximity and improved connectivity of the
enhanced elements that allows more people to live and work in them, not always bigger
buildings or smaller yards. Nationally, these types of community designs are faring quite well in
the marketplace.
Myth 4 - Controlling Growth Causes Housing Prices To Increase
Limiting the amount of developable land would raise housing prices if demand exceeded supply.
But all of the EPI regional scenarios allow enough land for the anticipated growth. The amount
of land needed for new development under the Dispersed scenario is twice what is needed for the
other scenarios because virtually all new development would spread into suburbs and rural areas.
The alternative scenarios assume that new development would be focused in urban centers,
enhanced suburban communities, small towns and villages. These mixed-used community
clusters naturally feature a variety of housing types and prices, just as they do today in
downtown Charlottesville and the village of Palmyra. Localities can further boost a variety of
housing in targeted areas through incentives such as location efficient mortgage programs and
regulations such as inclusive zoning.
Myth 5 - Everywhere Will Look Like Downtown Charlottesville
Participants at EPI workshops and the Advisory Committee agreed that a wide variety of
community types and land uses were desirable. The key to improving future development is to
make enhancements to several community types, especially in suburban areas, such as giving
them focal points and making them walkable. The alternative scenarios feature a variety of
community types including urban, enhanced suburban, and traditional suburban areas as well as
small towns and villages. Many people will also choose to live in rural areas, but the
convenience and attractiveness of the targeted development centers will help localities target
most new growth to community centers and preserve open spaces rather than having no choice
but to spread out into farm and forestland.
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APPENDIX 10: Greenseams Program Milwaukee Metropolitan Sewerage District
(http://www.mmsd.com/floodmanagement/greenseams.cfm)
Greenseams
Land is the one thing we cannot make more of and MMSD is working hard to preserve what is
needed to help prevent future flooding in the region. Greenseams is an innovative flood
management program that permanently protects key lands containing water absorbing soils. The
program also aims to preserve land along stream corridors that connects the region's supply of
public properties.
By storing and draining water into the ground
naturally, Greenseams provides added support
and protection for MMSD's structural flood
management projects - infrastructure
investments worth hundreds of millions of
dollars.
Greenseams identifies and purchases
undeveloped, privately owned properties in areas
that are expected to have major growth in the
next 20 years and parcels of open space along
streams, shorelines and wetlands. Sales are
completely voluntary.
Figure 1: Forest
MMSD hired The Conservation Fund (TCP) to
run Greenseams. TCP is a national non-profit conservation organization that forges partnerships
to protect America's legacy of land and water resources. TCP performs high volume real estate
transactions for local land trusts and government agencies throughout the country.
All land acquired will remain as open space,
protecting water and providing the ability to
naturally store rain and melting snow in critical
areas. Wetlands maintenance and restoration at
these sites will provide further water storage.
In addition, preserving the properties also saves
wildlife habitat and creates recreational
opportunities for people living in the region.
Where applicable, the properties can be used by
the public for hiking trails, bird watching, and
other passive recreation.
Black-eyed Susans on Hanson property
Partnerships
One of the great benefits of Greenseams is the formation of key partnerships throughout the
Milwaukee region. Each property acquired will be owned and managed by a local community or
land trust and subject to a conservation easement held by MMSD. Conservation
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APPENDIX 10: Greenseams Program - Milwaukee Metropolitan Sewerage District (continued)
easements ensure that the land remains open space forever.
A number of grant programs are used to leverage MMSD funds for Greenseams. In 2004, the
United States Fish and Wildlife Service's Partners for Wildlife program contributed $7,900 and
in-kind services towards restoration of three Greenseams properties. Also, MMSD and 5 other
partners secured a North American Wetlands Conservation Act (NAWCA) grant, which
provided Greenseams $130,000 to use for land purchases in 2005. In addition, the Wisconsin
Department of Natural Resources Stewardship Program and the Wisconsin Coastal Management
Program have recently contributed $575,417 and $147,400 respectively to help fund the purchase
of Greenseams properties.
Spreading the word about the program
The Greenseams program is a unique approach to flood management and is touted as model land
use technique at various forums, conferences and in other municipalities.
Recent publicity has included:
Wisconsin Chapter of American Planning
Association Annual Conference
University of Wisconsin- Milwaukee
Land Trust Alliance
City of Ann Arbor
Civil Engineering News
Izaak Walton League
National Association of Counties
Wisconsin Association of Floodplain Managers
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 24
THE ADMINISTRATOR
Mr. John L. Howard, Jr.
Chair
National Advisory Council for
Environmental Policy and Technology
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Dear
: the National Advisory Council for Environmental Policy and Technology and its
Sustainable Water Infrastructure workgroup for the recommendations provided for Phase I of
their charge. The findings and recommendations give a truly comprehensive view of the issues
before the group, and EPA has been striving to incorporate them into its efforts.
The Office of Water has carefully reviewed the report's 26 recommendations and
continues to incorporate them into its policies and programs. For example, one of the main
points emphasized throughout the report is the need for EPA to redouble its efforts at outreach
and marketing of watershed approaches to infrastructure. We believe that your comments hold
true for the entire Sustainable Infrastructure Initiative, and we are working with our partners to
expand outreach and the mechanisms through which we get feedback on its effectiveness. For
instance, the Office of Water is:
• Expanding its collaboration with the Local Government Advisory Committee to develop
strategies and tools to reach local officials;
• Engaging the participants in the National Estuary Program to enlist their help in
promoting watershed approaches to infrastructure using their extensive capacity for
outreach and fostering collaboration;
• Pilot testing customer satisfaction surveys in review of select products we complete; and
• Securing consultant services to develop a formal marketing plan for the SI Initiative.
Several of the recommendations also pointed to ways EPA could work better with the
U.S. Department of Transportation on watershed issues. To that end, the Office of Wetlands,
Oceans, and Watersheds is establishing a liaison who can serve as a focal point in our
interactions with DOT. This liaison will be tasked with expanding and improving the
effectiveness of our collaborations with Transportation.
Internet Address (URL) • http://V/ww epa gov
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In addition, the recommendations pointed to the need for improving and centralizing
leadership on the Watershed Pillar, which was previously shared among several people. The
Office of Water has now assigned a single person to the task to improve its internal organization
of efforts under the Pillar.
While these are just a few examples, know that EPA will continue to incorporate the
workgroup's ideas and thinking into its efforts to promote watershed approaches to
infrastructure. I greatly appreciate the effort and thought that went into NACEPT's report and
look forward to the workgroup's report on Part II of the charge.
Si
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