Phase II Report
   Problem Identification
         September 1990


This report was approved by a straw vote of the organizations participating in
the Water Quality 2000 Member Congress, held September 12-14,1990, in An-
napolis, Maryland. It is now being circulated to all member organizations for

For more information, contact Water Quality 2000,601 Wythe Street, Alexandria,
VA 22314-1994, (703) 684-2418.

                          Table of Contents


    Sources of Impairment   	iv
    The Condition of the Nation's Waters and Aquatic Habitat   	vi
    Causes of Water Quality Problems   	viii
    Impediments to Solutions   	ix
    Looking Forward Toward Phase HI Solutions   	x

    Sources and Effects of Impaired Water Resources	3
    Measurements of Progress Toward Clean Water Goals    	6
         The condition of surface waters  	7
         The condition of groundwater	11
         The condition of aquatic resources	13
    Measurement of Commitment to Gean Water Programs	14
         Investments in water pollution control	14
         Services delivered  	15
         Numbers of trained water quality professionals	16
         Public awareness of water quality issues  	17
         Growth in the number of water quality institutions   	18
    Conclusion	18

    Societal Causes of Water Quality Impairment   	20
         How we live	21
         How we produce and consume  	22
         How we farm   	24
         How we transport people and goods	25
         How we plan   	27
         How we have acted in the past   	28
    Conclusion	29

    Narrowly Focused Water Policy  	30
         Watershed-based planning  	31
         Cross-media effects    	32
         The relationship between water quantity and water quality	33
         Pollutant prevention	33
         Environmental results   	35
    Institutional Conflicts	36
         Federal government    	36
         State government  	37
         Local government  	38

         The private sector   	39
         Citizens'organizations	40
    Legislative and Regulatory Overlaps, Conflicts, and Gaps	40
         Overlapping statutory or regulatory controls   	41
         Conflicting policies and programs	42
         Gaps in authority   	43
    Insufficient Funding and Incentives for Water Quality Improvement  	45
    Inadequate Attention to the Need for Trained Personnel	47
    Limitations on Research and Development	49
    Inadequate Public Commitment to Water Resource Quality   	51
    Conclusion	53

    Preventing Pollution   	54
    Controlling Runoff from Urban and Rural Lands	55
    Focusing on Toxic Constituents	56
    Protecting Aquatic Ecosystems	56
    Coping with Multi-media Pollution	57
    Protecting Groundwater	57
    Increasing Scientific Understanding of Water Quality Issues	58
    Promoting Wise Use of Resourcese   	58
    Setting Priorities   	59
    Providing Safe Drinking Water	60
    Managing Growth and Development  	61
    Financing Water Resource Improvements   	61



Organization, Goal, and Mission of Water Quality 2000	69

Member Organizations   	72

Steering Committee Members and Their Affiliations	74

Work Group Participants	75

Water Quality 2000 Vision Statement and Goal	82

Summaries of Work Group Reports	83

Major Milestones in Federal Water Quality Legislation	118


     This report is a starting point in that it identifies problems
without considering solutions. The phased approach of Hater Quality
2000—which proceeds from problem identification to discussion of
solutions to public outreach—allows for fully informed debate that
considers all interests and points  of view.  However, this approach
also poses  some risk. Phase  II is limited to  identifying water
quality  problems  without  considering  solutions.  This  does  not
imply, however, that solutions do not exist, or that we should fail
to give  credit to  the  substantial progress that  has been made.
Readers  should  rather consider  this  document as merely the first
half of a two-part report.  It has been developed  and adopted in the
recognition that a common understanding of these  problems among all
parties will facilitate a unified approach to formulating solutions
during Phase III.
     While all the problems discussed in this report are  important,
some  are more  severe  than others.  Despite the  risk of  leaving
readers  with the  impression that all  problems  are  equal, this
report  does not  attempt  to  assign priorities.  Phase  III will
include  additional  consideration of which problems  should  receive
priority for action.
     To  assist  in this  effort,  readers are encouraged to  provide
Water Quality 2000 with their views about the severity and relative
priority of the problems identified here. Comments  should  be sent
to Paul  Woodruff  (chairman of the  Water  Quality  2000 Steering
Committee), Water Quality  2000, 601  Wythe  Street, Alexandria, VA
22314-1994,  (703)  684-2418.
September 1990                                                   Page iii

                        EXECUTIVE SUMMARY

     Water  Quality  2000—a  consortium of  more than  80  public,
private, and nonprofit organizations—began a four-phase effort in
1988 to  develop and implement  an  integrated national  policy for
water quality. This  policy for  protection and enhancement of U.S.
waterbodies  ultimately  supports  Water  Quality  2000's  goal—a
society living in harmony with healthy natural systems. This report
completes Phase II, the identification of problems. Phase III will
focus on solutions, and  Phase IV will  begin the implementation
process by transmitting recommendations to the Congress  and all who
influence water  quality.  A complete description of the processes
by which Water Quality  2000 was organized  and now  conducts its
deliberations  is  presented in Appendix A.
     Based  on  the  reports  of  ten work  groups, which  brought
together hundreds of water quality experts,  Water  Quality 2000 has
concluded that today's water quality problems stem from a variety
of human activities  and that  the public  policies  and programs
currently  in place  are  not  sufficient to  deal with them.  While
significant progress has been made to improve the  condition of the
nation's  fresh and  marine waters,  the national  interim  goal of
"fishable  and swimmable"  waters has  not  been attained  in many
areas.  Moreover, much  work  is needed  to  achieve  the broader,
overall objectives of a wide range of  water legislation including
the broad objective of the Clean Water Act—to restore and maintain
the chemical,  physical,  and biological integrity of the nation's
surface waters.

     Degradation (pollution) of the nation's water resource results
from  direct  human  activity,   such  as  municipal  or  industrial
discharges of wastewaters, and from indirect actions, such as land
alteration  for   farming,  forestry,   mining,  transportation,  or
development. Sources of impairment vary  from location to  location
and among surface waters, ground waters, and aquatic resources. Yet
overall, the following sources  (listed alphabetically) contribute
significantly to impairment in  many  locations and ecosystems:

     o Agriculture
               Agricultural runoff is  the source of impairment of
               55 percent   of  surveyed  river miles  found  to be

September 1990                                                   Page iv

               impaired and  58 percent  of surveyed  lake acres.
               Runoff  includes  large volumes  of  sediment  and
               nutrients and smaller amounts of more acutely toxic
               pollutants,   such   as  pesticides.   Agricultural
               chemicals  are significant sources  of  groundwater
               contamination,  and  animal  production  is  a major
               source  of  phosphorus  and  pathogens  in  lakes.
               Agriculture also accounts  for  wetlands losses and
               damage to riparian and floodplain environments.

     o Community Wastewater
               While publicly owned treatment works (POTWs) remove
               many pollutants from community  wastewater, these
               facilities nonetheless are  the points  of entry of
               remaining pollutants  into  the  nation's waters. In
               addition to continuing on-going efforts to  improve
               the operation and maintenance of these facilities,
               communities face the following problems: the control
               of  pollution  from  combined   sewer   overflows,
               stormwater, and nonpoint  sources; the control of
               toxic pollutants from industrial, residential, and
               other  sources;  and  the  upgrading  of  existing
               facilities and  construction of new ones to  control
               nutrients, pathogens, and other pollutants.

     o Deposition of Atmospheric Contaminants
               Aerial transport of acidic compounds,  toxics such
               as  PCBs,  and  nitrates,  degrade fresh  and marine
               waters  and  impair  the  health  of ecosystems in
               several parts of the U.S. Sources  include utilities,
               industry,   motor   vehicles,   and   agricultural

     o Industry
               The manufacturing,  service,  power generating, and
               solid  and hazardous waste  management   sectors
               discharge  toxics  and other contaminants,  produce
               runoff, and contribute airborne  contaminants; and
               releases of waste heat.

     o Land Alteration
               A  wide variety of  land  uses—including  logging,
               mining, road building, and development (especially

September 1990                                                   Page v

                urban and suburban sprawl)—contribute to runoff of
                water, soil, and chemicals used in and on the land.
                These activities also degrade  or  destroy essential
                aquatic resources  such as wetlands  and riparian
                areas and the fauna and flora that depend on them.

     o Stocking and Harvest
                Intentional and accidental  introduction  of  exotics
                and overharvesting  of fish  and shellfish resources
                often result  in  irreversible  impacts on  aquatic

     o Transportation
                Major sources  of   impairment  from transportation
                activities  include shipping, surface transport,  and
                pipelines;  spills  and other discharges  of  oil  and
                other  substances;   runoff  from  transportation
                facilities; destruction of   wetlands  and  other
                aquatic  resources  from  dredging  and building
                transportation works; and air  emissions.

     o Urban Runoff
                Urban runoff is a major source of water pollutants.
                Municipal and industrial stormwater remains  largely
                unregulated. Residuals  of  chemicals applied  to
                suburban lawns may ultimately find  their  way to
                surface and ground  waters.

     o Water Projects
                By removing physical  habitat and  water required by
                aquatic  species,    channelization,   dams,    and
                consumptive use of  water  are implicated  in  the
                extinction   of many   species.     Dams  and  their
                resultant   reservoirs  have   been   particularly
                troublesome for anadromous  and riverine species,

     Neither the quality of the nation's waters  nor  the  health  of
ecosystems is measured regularly. Current ambient monitoring of the
chemistry and  biology of waters and aquatic resources is  far too

September 1990                                                   Page vj

limited  to be  of  use  in  assessing  the  performance of  water
programs. Moreover,  data on  the  release of contaminants to surface
and ground waters are incomplete, covering only a fraction of all
waters and, typically,  a  small  number  of pollutants.  The lack of
such fundamental measures of  progress  toward cleaner water leads
to  conflicting  reports  on  the condition  of  water  quality  and
aquatic ecosystems. Yet, we can see  the  results of water quality
programs  in the  return  of  game fish  to  rivers once  thought
incapable of supporting fisheries. Evidence indicates that progress
is being made. Although designated uses  allow for a wide variety
of  water quality,  some waters  now  enjoy  sufficient  quality to
support the uses specified by the states. At the same time, there
are  failures  of  programs:  when surface  and  ground  waters  are
reported as contaminated or  unfit for use as intended, when aquatic
habitat  is destroyed as  a  result of land  development and other
activities, or when contaminant advisories are necessary because
the harvestable fish are unsafe for human consumption.
     While contamination of surface waters from toxic  chemicals is
thought  to be  more localized  than  from  other sources  such as
siltation,  nutrients,  or organic matter, local impacts on public
health and aquatic life can  be severe where toxics have accumulated
or continue to be discharged.  In general, the nation has not fully
measured the prevalence of toxics in the environment, fully studied
routes of  exposure, or sufficiently understood levels  of concern.
The  high  cost  of  monitoring  for toxics  and conducting health
effects  studies partly explains this situation.
     Comprehensive  data  on the quality  of  groundwater  is not
collected  routinely.  Working  from anecdotal reports and one-time
surveys, however,  it is probably reasonable to conclude that the
shallowest aquifers are  at greatest risk of contamination  from
human  activities,  especially those  aquifers where the  overlying
soil  is thin  and  permeable.   Contamination  of shallow aquifers
results  from agricultural sources such as pesticides, animal waste,
or  nitrates  from   the  application  of  fertilizers,   and   from
industrial or  other sources such as synthetic organic chemicals,
leaky  underground storage tanks, and spills.  As yet,  most deeper
aquifers are  believed  to be  relatively free  from  contamination.
However, a survey conducted by  EPA shows that about 20 percent  of
all drinking water  aquifers (shallow and deep) are contaminated to
some degree by man-made chemicals.1
     Wetlands are not only  important breeding and  nursery  grounds
for aquatic life  but also have  an important function  in  improving
water  quality, recharging groundwater,  flood control,  recreation,

September 1990                                                  Page vii

fish and wildlife habitat, shoreline protection, and water storage.
These resources  are being rapidly destroyed by a variety of human

     The  fundamental  causes of  water  quality  problems  lie  in
seemingly  unrelated aspects  of  life:  the way we farm, produce,
consume, transport people and goods, and plan for the  future. Many
aspects of modern life  and  past  practices put pressure on water
quality. Until recently, these  activities proceeded  with little
recognition of the  degradation  they  caused  in surface waters,
groundwater,  or aquatic habitats.
     Typically,  individuals and society as  a whole make choices
that reflect  values specific to living, producing, consuming, or
working—but  not  necessarily to achieving clean water.  Sometimes
these  values conflict with  water  quality  goals.  Until  very
recently,  conflicts  remained largely unrecognized,  at least until
water quality problems became so apparent that the public demanded
action, as it did in the early 1970s in response to  the Cuyahoga
River catching fire, or in the 1980s to the declining  condition of
the  Chesapeake Bay.  Historically,  such  conflicts were resolved
through relatively narrow legislation to restore and protect water
quality  by altering  the  direct  sources  of  impairment but not
necessarily the forces underlying polluting behavior. Even today,
when we  are  beginning to recognize some  of the basic  conflicts
between   human   activities   and   environmental   quality,   few
contemporary  solutions address the basic economic and social forces
at the root of water problems. Governmental water quality programs
and policies  are part of the problem to  the degree that they do not
fully address these  societal causes of  impairment.
     Hence, while it  may take  time to reconcile societal values
regarding  the way we  live,  produce, consume, farm, or  work with
our preference for a healthy environment, drawing attention to the
effects  of our societal decisions on water quality  is  critical.
Whether  or not Water  Quality 2000's goal  for the nation can be
achieved  will be determined, in  large part, by  whether we can
reshape these societal functions in ways that are compatible with
protecting and enhancing water quality  and aquatic ecosystems.
September 1990                                                  Page viii


     Societal  factors  in  conflict  with  a healthy  environment
produce serious, long-term impediments to improved water quality.
In  the  near  term,  however,  opportunities  exist  to  address
impediments posed by current water policies and programs. The work
group  reports   consistently  raised  the   following   types  of

     o  Narrowly  focused  water  policies  impede  the  holistic
        solutions    that    address    watershed-based   planning,
        cross-media effects, the connection between water quantity
        and water quality, incentives for pollution prevention, and
        management for environmental results.

     o  Conflicts   among  water   quality   institutions   impede
        collaborative solutions in which all levels of government,
        the private  sector, and individuals participate according
        to their strengths and limitations.

     o  Legislative  and regulatory  overlaps,  conflicts, and gaps
        sometimes create  inefficient or ineffective solutions to
        water  problems or may  result in  the  underprotection of
        water quality or water-based natural resources.

     o  Inadequate funding and ineffective economic incentives for
        clean  water  programs and  construction, operation,  and
        maintenance  of facilities impedes progress toward national
        goals and is out of touch with general public opinion and
        actual  need.

     o  Inadequate attention to the need for trained personnel has
        created a serious gap between a  limited  supply  of new and
        retrained  professionals  and  a  growing  demand  for their

     o  Current research and development programs fail to meet the
        challenge  presented by  the complexity  of  today's water
        quality problems  and  the  need  to  improve  our  basic
        scientific understanding  of ecosystems.

     o  Inadequate communication  has resulted  in citizens who are
        largely unaware of  the linkages  between daily life and

September 1990                                                   Page ix

        water  resources,  what they can do to improve the quality
        of  water  and  aquatic  habitat,  or  why  they  should
        participate  in the  first place.

     The results  of  public  and  private  efforts to control sources
of water  pollutants and generally  improve  the  quality of waters
and aquatic habitats over the years have been mixed. Some problems
have  been  solved,  others   await  the  results  of  programs  only
recently put in place,  while still others remain challenges for the
future. One  of foremost challenges we face is to move the debate
over water quality toward the root  causes of  degradation in water
resources presented in this  paper. In practice, this means thinking
more  carefully about  how  to pursue societal goals  for living,
working,  farming, and  producing in ways that are consistent with
improving the  quality  of the nation's waters.
     Water  Quality 2000 identified  the following  12  issues that
merit consideration  in Phase III  of our work:

     o  Preventing pollution,

     o  Controlling  runoff  from urban and rural lands,

     o  Focusing  on  toxic constituents,

     o  Protecting aquatic  ecosystems,

     o  Coping with  multi-media pollution,

     o  Protecting groundwater,

     o  Increasing  scientific  understanding of   water  quality

     o  Promoting wise use  of resources,

     o  Setting priorities,

     o  Providing safe drinking water,
September 1990                                                    Page x

     o  Managing growth and development, and

     o  Financing water resource improvements.
     We  feel  confident that  this  report  presents  a balanced
description of today's  water quality problems, their causes,  and
the  impediments  to  solutions.   We  are  optimistic  that these
conclusions  will  stand as  a  sound  foundation  upon  which  to
formulate solutions in the next phase of our work.  We eagerly  look
forward to Phase III of  our project and extend an invitation to all
who wish to contribute  to the debate over  solutions  to  comment on
this report.
September 1990                                                    Page ri

               I.  WATER QUALITY CONDITIONS  IN  1990

     The effects  of  water pollution on human  health and natural
systems were first acknowledged in the U.S.  as a societal problem
in the 18th century. Major  urban centers  began to deal with this
problem by installing sewers shortly thereafter. The construction
of wastewater  treatment facilities  followed in the 19th century.
Water quality  legislation has  been  in place in many states since
early in this century.  By 1970, the  nation could point to over $70
billion  in  municipal wastewater treatment  assets  and almost $80
billion  in water  supply system assets. These facilities provided
three-quarters of the population with sewage  collection, two-thirds
of the population with  at least primary treatment, and about half
the population with  secondary  treatment.2 About 85 percent of the
U.S. population  was  served by  centralized  water  supply.  Also by
1970, state  regulation resulting in about  $10  billion a year in
private  investment in  pollution control facilities addressed the
problem  of industrial discharge, at least to some degree.3
     While the federal interest in water quality was established
as early as 1899 (See Appendix  G: Major Milestones in Federal Water
Quality  Legislation),  the basis for  today's  federal program was
established  in 1972. In that year,  Congress passed amendments to
the  Federal  Water Pollution Control  Act  (FWPCA), which together
with subsequent amendments  is  now commonly  called the Clean Water
Act. The Act had an  ambitious  objective—to restore and maintain
the  chemical,  physical, and biological integrity of the nation's
waters. As interim goals, the Act called for eliminating discharges
of  pollutants into  navigable  waters  and achieving fishable and
swimmable conditions.
September 1990                                                    Page 1

           (1972 Federal Water Pollution Control Act)

        The  Clean   Water Act  instituted  broad  federal
        authority over  all  public  waters and set as its

          o  To restore and maintain the chemical, physical, and
             biological  integrity of the nation's waters.

          o  Consistent  with  its other provisions,  the Clean
             Water Act established two interim goals:

             (1) eliminating  the  discharge  of
                 pollutants into  navigable waters
                 by  1985   (the  zero  discharge
                 goal),  and

             (2) achieving, wherever attainable,
                 a  water quality  that protects
                 fish,   shellfish,   and  wildlife
                 and provides  for  recreation in
                 and on the water  (the fishable
                 and swixnmable goal).

        In practice, the zero discharge goal is implemented
        with respect to point sources principally through
        a program of technology-based effluent guidelines,
        standards, and permits that require the elimination
        of discharges  of pollutants where technologically
        and economically achievable. Stricter controls have
        been  imposed where needed  to  meet water quality
        goals.  See  Appendix G for a more complete list  of
        major   federal  legislation that  affects   water
        quality and aquatic resources.
September 1990                                                   rage Z

     Since refocusing national clean  water  programs in 1972, the
U.S. has enjoyed nearly two decades of governmental, private, and
individual attention  to water quality protection.  Under federal
legislation,  public  and private responsibilities  for protecting
water quality have shifted over time,  as have statutory priorities
for action. An even longer history of state statutory action also
has  contributed  to  shifts in public and  private roles.   Many
factors have  influenced these shifts,  including the  advance of
scientific knowledge,  the  degree  of public  awareness  of water
quality problems,  resource limitations,  and the availability of
pollution control technologies. Much  progress  has been made, but
much more remains to be done.

     Five years after the 1985 "zero discharge" goal of the Clean
Water Act, and despite the Act's national policy of "no toxics in
toxic amounts," we continue to release large quantities of toxics
and other pollutants  into  the nation's surface and ground waters
from a variety of  sources. The 1983 goal of "fishable and swimmable
water" remains  equally elusive.  While many  waters have improved
since  1972,  some have deteriorated  and others have  barely kept
     The  failure to  meet  these  interim goals  means that  the
overriding  objective  of  the  Clean  Water  Act—to   restore  and
maintain the  chemical, physical,  and biological integrity of the
nation's waters—has  not been met for a  large percentage of our
surface waters. It also results from our overall failure to protect
rivers as rivers, lakes  as lakes,  and estuaries as estuaries. By
focusing only on chemical  water  quality, we  ignore  the overall
health of the biological system.  Consequently, we build right up
to  the  water's  edge,  remove essential coastal and  riparian
vegetation and other habitat, and channelize and alter the course
of   our   natural  waterways.   Natural   diversity  and  aquatic
productivity  is lost as  a result.
     The principal sources of impairment  include  (in alphabetical

     o Agriculture
          Agricultural   runoff is  the source of impairment of 55
          percent of  surveyed river miles found to be  impaired and
          58  percent  of   surveyed   lake  acres.4  Runoff  from

September 1990                                                   Page 3

          agricultural lands includes large volumes of sediment and
          nutrients  and smaller  amounts of  more acutely  toxic
          pollutants, such  as  pesticides.  Agricultural chemicals
          are significant sources of groundwater contamination, as
          well,  and  animal  production  is   a  major  source  of
          phosphorus  and pathogens in  lakes.  Agriculture  also
          accounts for wetlands losses and damage to riparian and
          floodplain environments.

     o Community Wastewater
          While community treatment plants remove many pollutants
          from domestic and industrial  sewage,  these facilities
          nonetheless are the  points  of entry of pollutants into
          the nation's waters.  In addition to continuing on-going
          efforts to improve the operation and maintenance of these
          facilities, communities face the following problems: the
          control  of pollution   from  combined  sewer  overflows,
          stormwater, and nonpoint  sources;  the control of toxic
          pollutants  from   industrial,  residential,  and  other
          sources;  and  the  upgrading  existing  facilities  and
          construction of new ones to control  nutrients, pathogens,
          and other pollutants.

     o Deposition of Atmospheric  Contaminants
          Aerial  transport   of acidic compounds  and  other toxic
          substances  has  been  identified  as   a major  problem
          affecting  lakes  and estuaries in  several  parts  of the
          U.S.  Acidification  of  lakes  and  streams  is directly
          lethal  to  aquatic  organisms.  Deposition of airborne
          nitrates  degrades estuary water quality,  causes algal
          blooms,  and  impairs  healthy  ecosystems.  Atmospheric
          sources of  PCBs and other toxics are of concern in the
          Great Lakes,  marine  waters,  and estuaries.

     o Industry
          Although  more  than  90  percent  of   major   industrial
          dischargers   are   in  compliance with  their discharge
          permits, according to EPA's 1987 Toxic Release Inventory
          (TRI), manufacturing sources alone continue to discharge
          an estimated  360  million  pounds of toxic pollutants per
          year into rivers,  lakes, and coastal waters,  and another
          570  million   pounds  into   sewage  treatment plants.5
          Non-manufacturing  sources,   such   as   power-generating

September 1990                                                   Page 4

         utilities  (nuclear,  fossil  fuel,  and hydro), solid and
         hazardous  waste  treaters,   mining,   and others,  also
         contribute  significant  additional  amounts  of toxic,
         radioactive, thermal, and other pollutants.

    o Land Alteration
         A wide variety  of  land uses—including logging, mining,
         grazing, road building, and development (especially urban
         and  suburban sprawl)—contribute  to runoff of water,
         soil,  and  chemicals used  in  and  on the  land.   These
         activities  also degrade  or destroy essential aquatic
         resources   such as  wetlands,   headwater streams, and
         riparian areas, and the fauna and flora that depend  on

    o Stocking and Harvest
         Intentional and accidental  introduction of  exotics and
         overharvesting  of  fish  and shellfish  resources  often
         result  in  irreversible  impacts on  aquatic ecosystems.

    o Transportation
         Major sources include spills and other discharges of oil
         and  other substances from ships, surface transportation,
         and  pipelines;  runoff  from transportation  facilities;
         destruction of  wetlands and other aquatic resources from
         dredging navigation channels and building transportation
         works;  and  emissions. More than 10,000 oil spills release
          15 to 20 million gallons of oil into the nation's waters
         each year.

     o Urban Runoff
          Contaminated runoff continues  as a major source of water
         pollutants. Municipal and  industrial stormwater  remain
          largely unregulated. Residuals of chemicals applied  to
          suburban lawns may ultimately find their way to surface
          and ground waters.

     o Water Projects
          By  removing physical  habitat  and  water   required  by
          aquatic species,  channelization,  dams,  and consumptive
          use of water  are  implicated in the extinction of many
          species.  Dams and their resultant reservoirs have been
September 1990                                                   Page 5

          particularly  troublesome  for anadromous  and riverine
          species,  respectively.

Water  quality is impaired not  only  by current activities but by
past actions that have altered the aquatic regime or  have resulted
in on-going releases after the  productive  activity has  ceased.
     Polluted water and lost habitat  can  pose real  problems for
human  health  and the environment.  The abundance, diversity, and
structure of natural fish and wildlife populations may be impaired,
while  commercial,  sport, and subsistence  fisheries  and shellfish
beds may show reduced productivity. Food and water supplies can be
contaminated  and waters rendered  unsafe  for  swimming or other
recreational  uses.  An important part of our national and natural
heritage in clean water has  already been lost,  and the  balance is
under  stress.

      Ideally,   to  measure  progress  of  clean  water  programs
nationally,  investigators would have access to regularly collected
data  on physical, chemical, and biological conditions in fresh and
marine waters, groundwater, and aquatic habitats. But since  only
limited  data  exist,  various proxy measurements must be  used as
       The reports that states make to EPA every two years on their
progress  toward meeting  the  Clean  Water Act's two  interim goals
are  the   major  direct  sources  of  information.   Despite their
shortcomings,   these  305(b) reports  (filed to  comply  with  that
section of the Act) represent the latest available accounts of the
extent to which  U.S. waters are meeting  the goals of the Clean
Water Act.  These  reports, however,  are  somewhat  limited.  For
example,  waterbodies  can be  reported as meeting uses under  very
different  criteria  across  states.   Reports  often  include an
unrepresentative sample of  all  U.S.  waterbodies  and generally
measure ambient concentrations  of conventional as opposed to toxic
constituents.  Data  are gathered only from the water column, not the
sediment  below,  or from aquatic life.  This practice limits our
understanding  of accumulation  of  pollutants in the  sediment,  in
fish, and in other organisms. In addition,  this approach limits our
understanding  of the complex ecological  impacts of  other  factors
 (habitat  degradation,  flow alteration,  species  interactions, and
others)   that   degrade  the  quality  of water  resources.  Lack  of

September 1990                                                   Page 6

carefully formulated  biological  monitoring programs  impairs our
ability to evaluate environmental results of management actions.
     Because of the shortcomings  of the 305(b) reports, this Phase
II  Report also  presents  a wide variety  of  proxy,  or  indirect
measures, such  as the amount  invested  in water  quality control
programs, population served by water quality protection facilities,
pounds of pollutants removed from effluents, the degree of public
concern over water quality issues, numbers of trained water quality
professionals,  or numbers of  water  quality  institutions.  These
proxies represent several different perspectives on progress toward
building national capacity to address future water quality goals.
     A summary  of current sources  of impairment to water quality
for  all  types  of waters is  presented in  Table 1.  Sources for
entries in this table include the reports of Water Quality 2000's
work groups.
The Condition of Surface Waters

     Despite significant progress,  the national interim fishable
and swimmable goal  has  not  been attained for all waters. Many of
the  nation's waterways and  aquatic  ecosystems  continue  to be
affected by contaminants from a variety of human sources, including
industry, municipalities, agriculture, and urban runoff.
     Without adequate data on trends in water quality, it remains
difficult to draw clear conclusions on our progress. In fact, two
conclusions  appear  equally valid.  Some observers  characterize
progress since  1970 primarily as a  holding  action.  They believe
that clean water programs have mainly prevented further degradation
of the  nation's surface waters in the face  of growing pressures
from economic  expansion and population growth.   But without the
national effort to improve water quality, others argue, waterbodies
would be much worse off today than 20 years ago because population
and  economic output  have  grown  by 25  percent and  50 percent,
respectively. Our gains are reduced discharges of pollutants  on a
per  capita basis  and  per  dollar  of  economic output.  But the
population and  GNP  of the nation has grown—by 25 percent and 50
percent, respectively, between 1970 and 1988—so because of growth,
we may  be  just keeping even on a total  loading  basis, with the
result that water quality improvement  is not universal.
September 1990                                                   Page 7

                              TABLE 1

Surface Water
(river, lakes,  streams
 marine and  estuarine
(shallow  and deep
o Silt, nutrients,  and pesticides
  from agricultural practices
o Pathogens, organic material,  nutrients,
  and toxics from community wastewater
o Toxic and heated discharges from
  industrial sources
o Pathogens and nutrients from livestock
o Pathogens, organic matter, and toxics
  from storm sewers and combined sewer
o Silt and other pollutants from land
  alteration, resource extraction, and
  stream channelization
o Spills and other discharges of oil and
  other substances from transportation

o Natural leaching of metals, solids,
  salts, and radon
o Toxic metals and organics from leaking
  underground storage tanks, waste
  disposal sites, and landfills
o Percolation of water containing
  pathogens, nitrogen, and pesticides from
  on-site septic systems and agricultural
o Underground injection of industrial and
  resource extraction waste
Aquatic Resources
(wetlands, riparian
 areas, and  aquatic
o Losses and degradation as a result
  of agricultural practices such as over-
o Losses and commercial and industrial
  development and transportation
o Siltation as a result of land clearing,
  resource extraction,  and construction
o Losses from damming,  channelization, and
  shoreline protection
o Species introductions and overharvest
September 1990
                                      Page 8

     Fresh Waters. On a streaxn-by-stream basis, efforts to measure
progress toward clean  water  have been limited.  The latest annual
EPA survey (1988)  suggests that many waterbodies have been cleaned
up, but  others have  degraded.6  Lake  Erie, apparently  doomed to
death  in the  1950s,  is alive  and improving today.  Yet despite
improved conditions  from  the control  of conventional pollutants,
the lake still has significant toxic  contamination problems. The
International  Joint  Commission has  identified  eight   Areas of
Concern  in  Lake  Erie and   its  tributaries,  fish  consumption
advisories  are   in  effect  because  of  contaminants,  and  the
biological community has been drastically altered from its historic
condition. The Potomac River, once  an unfishable disgrace, is now
populated  by  numerous species  of game  fish  and  is a  proud
attraction for tourists and residents of Washington, D.C. Yet there
are   also   numerous   fish  consumption   advisories,   based  on
contaminants,  in  effect for  the  Potomac River.
     There are two interpretations  of the  1988 state reports  that
addressed the  quality of water in 29 percent of the nation's river
miles. Viewed one way,  progress has  been commendable. Of  the waters
measured,  70  percent  fully supported  designated  uses,  such as
swimming, drinking, or boating.7 Another 20 percent supported some,
but not  all of their designated  uses. Only 10 percent of assessed
river  miles  did  not support any of their designated uses. Viewed
another  way,  there may be less  to be encouraged about. That is,
supporting uses  does not  mean that waterbodies are pristine, nor
are  the conclusions  drawn  from this  relatively  limited sample
necessarily  appropriate  for river water  quality nationwide.   A
designation  of "not meeting uses"  can  mean slightly polluted or
severely polluted.  Moreover,  states  are  inconsistent in  the
criteria they use to  determine if a river  section is  or is not
meeting  designated uses.   Causes of impairment—silt,  nutrients,
organics, toxics, pathogens,  and so on—are not and cannot always
be related to sources of impairment, such as agriculture, industry,
or urban runoff.  Typically, EPA and  state reports measure water
quality  in the water column and not in the bottom sediment or in
fish.  Again typically, many factors affecting  water  resources,
including most toxic contaminants,  are not measured at all. A more
statistically  robust  analysis  concluded that 49 percent of stream
segments studied  were  impaired by degradation in physical habitat
conditions.8 Physical  habitat  impairment  is the leading cause of
extinction in  North American fishes.9
     The principal cause  of identified pollution in  rivers and
streams  was  silt  and  nutrients —about  42  percent  and 26 percent,

September 1990                                                    Page 9

respectively, of the river miles assessed in 1988 were so impaired.
Pathogens were the cause in nearly 20 percent of impaired miles and
organic enrichment was the cause in another 15 percent. Runoff from
agricultural  lands was  the  source  of 55  percent of the total
impairment.  Municipal point  sources  accounted for impairment in
about 16 percent  of river miles assessed; resource extraction and
habitat modifications affected 14 percent  each.  As  noted above,
however,  these data  may be  seriously skewed by  the  absence of
comprehensive monitoring for  toxics  in water,  fish and shellfish,
and the sediment. The remaining sources—silviculture, industry,
construction,  land disposal,  and  combined sewers—affected less
than 10 percent each.
     Assessments  of  lake acres indicated a similar percentage of
impaired  waters.  Of  the 41  percent of lake  acres  assessed,  74
percent supported designated  uses, 16 percent  partially supported
uses,  and 10  percent failed to  support uses.  Again,  nutrients
accounted  for about  half the impaired lake  acres.  Other causes
included siltation  (25 percent), organic enrichment (25 percent),
salinity (14 percent), and habitat modification (11 percent) . Other
causes—pathogens,   organics,  suspended   solids,   metals,   and
pesticides—accounted for less than  10 percent each. Storm sewers
accounted for  roughly another 35 percent.
     By far,  the  most prevalent source of pollution in lakes was
agriculture,  accounting  for  nearly  60 percent of impaired lakes
acres. Other important sources included habitat modification (33
percent), storm sewers  (28 percent),  land disposal (24 percent),
and municipal point sources (15 percent).  Other sources, including
industrial   point sources,   resource extraction,  construction,
silviculture, and combined sewer overflows, each accounted for less
than 10 percent.

     Marine Waters. It is difficult to accurately assess the extent
of impairment of  estuarine and coastal waters because the  ultimate
indicator—the biological  community—has   not  been  adequately
monitored.   However,  numerous estuaries  have been identified as
critically threatened ecosystems and the majority of estuaries and
many coastal waters  are clearly deteriorating.
     Municipal point  sources—with  unspecified contributions of
pollutants  such as nutrients, pathogens, organic  enrichment, and
toxics—caused the   majority  (over  50  percent)  of  identified
impairment  in estuaries. In contrast, municipal sources accounted
for a smaller proportion of the impairment of rivers, streams, and
lakes. Resource extraction caused 34  percent  and  storm sewers 28

September 1990                                                   Page  10

percent  of  impaired  estuarine  square  miles.  Pollutants  from
agricultural  runoff affected  only about  20  percent  of estuary
square miles assessed. The contribution of pollutants from rivers
is  also important,  but difficult  to quantify.  Intentional and
accidental discharges of oil and other materials from shipping and
boating also contributed to marine pollution.
     Fish  consumption advisories are  in effect  in  many coastal
areas (such as for large bluefish taken off New Jersey because of
PCBs),  and several  fisheries have  been depleted  (for example,
California sardines, Georges Bank groundfish,  redfish in the Gulf
of Mexico).
The Condition of Groundwater

     While most groundwater  is not currently tapped for drinking
because of high salinity,  it is the source of drinking water for
half the U.S. community drinking water systems  (somewhat less than
half the population, however)  and  95 percent of rural households.
Until recently, groundwater was generally assumed to be pristine.
We now know  that  in many areas groundwater has been contaminated
by  many  human activities.  Potential  sources of  contamination
attributable to human  activity include hazardous and solid waste
landfills,  petroleum  and chemical  transportation  and  storage,
septic systems, and the application of pesticides and fertilizer
to crops and lawns.  In addition, vast quantities of groundwater are
naturally degraded from metals, solids, and other constituents that
leach from surrounding  geologic formations.
     Groundwater  is found  in saturated  rock,  sand,  and other
geologic  formations called  aquifers.  It is part  of the  earth's
hydrologic cycle, receiving inputs from rain percolating  (seeping)
downward  through  the soil  and exchanging  water  with rivers and
lakes.  Generally,  groundwater  moves very slowly,  but  it  can
sometimes flow swiftly  and unpredictably.
     Because of these characteristics, protecting groundwater poses
special  challenges.  Contamination  is difficult  to  detect  and
predict;  concentrations of contaminants can be high in one place
and  absent  a  few feet  away.  Contaminants can travel slowly  or
rapidly,  evenly  or erratically, and cleanup once groundwater  is
contaminated  is  difficult  if at  all possible,  expensive,  and
time-consuming.  Contaminated  groundwater  can pollute  streams,
wetlands, and estuaries.
September 1990                                                   Page 11

     There  are  no comprehensive national accounts of the current
condition  of groundwater.  Despite  these constraints,  the U.S.
Geological  Survey,  the EPA,  and  other agencies have conducted a
number of groundwater assessments, from which a partial profile of
groundwater  quality  emerges.  The  highlights  of  one   recent
assessment  follow.10

     o  High  concentrations of a  variety of  toxic metals, organic
        chemicals,  and petroleum products form plumes around point
        sources such as leaking underground storage  tanks, waste
        disposal sites,  and  landfills.  Although the  volume of
        contaminated water  in such plumes is relatively small, tens
        of  thousands of such sites exist. These types of problems
        are,  in many cases,  a result  of past practices and are
        concentrated in urban or industrialized areas, although
        they  are also found in rural areas.

     o  Some  contamination is the result of natural leaching of
        constituents from  soils.   Common  natural problems include
        concentrations  of  dissolved solids,  sulfate,  iron, and
        manganese that exceed drinking water standards. In some
        western locations,  natural concentrations of nitrate exceed
        primary drinking  water standards—levels of purity for
        drinking water determined  to  be  safe  under  the Safe
        Drinking Water Act.

     o  In  some regions,  contaminants derived  from runoff are
        frequently present in shallow  wells  scattered  throughout
        an  area.    Where  detected,  contaminant concentrations
        generally are at minimum detectable levels,  although in  a
        small percentage of water samples,  contaminants (such as
        nitrates and pesticides)   exceed  drinking water  standards
        or  health   advisories.  Such  runoff  is  associated with
        densely populated  urban  areas,  agricultural lands, and
        concentrations of septic  systems in suburban areas. Thus,
        shallow groundwater contamination is often related to land

     o  The  shallowest   aquifers  are   at  greatest  risk  of
        contamination,   especially  those   where  the   overlying
        unsaturated zone is  thin  and  permeable.  Contamination by
        nitrates  and  synthetic  organic  chemicals  of  shallow
        aquifers is widespread  in many  areas.  For example, 20

September 1990                                                   Page  12

        percent of 124,000 wells analyzed over 25 years had nitrate
        contamination  attributable  to  fertilizer  application,
        septic systems, or animal wastes.

        As yet, most deep aquifers  are  believed  to be relatively
        free from  contamination.  Yet a recent EPA survey showed
        that  about 20  percent of  all  drinking  water  aquifers
        (shallow  and  deep)   are  contaminated to  some degree  by
        man-made chemicals.11

        One or  more of 47 pesticides  that can be attributed  to
        normal agricultural use have been detected in groundwater
        in 26 states.
The Condition of Aquatic Resources

     Aquatic resources include wetlands, riparian (shore) habitat,
floodplains, aquatic habitat,  and the plant and animal communities
that inhabit these areas.12
     Aquatic resources have been degraded and destroyed by a broad
range of human activities.  To date, more than  half of the inland
and coastal wetlands  in  the contiguous  U.S.  have been destroyed,
with  10 states  losing  70 percent  or  more  of their  original
acreage.13  Agriculture is by  far the major cause of wetland loss.
Urbanization, tree harvesting,  and grazing have also altered the
integrity of aquatic  resources.  Damming,  channelization, mining,
thermal  effects  on  biota, and water  consumption have further
altered  and  eliminated  aquatic habitat  and  restricted  major
fisheries.  Fish and wildlife may be affected when aquatic habitats
are degraded. For example,  nearly one-third of North American fish
taxa are now at  risk of extinction.14 Dams on  the  Columbia River
blocked  access  to 50  percent  of the basin's  headwaters  for
anadromous   fish,  causing  an  estimated loss  equal to  75  to  80
percent of  the annual catch.15   Thirty-eight states,  in actions
attributable to contamination, have advised against the consumption
of certain  fishes  or  have restricted or closed  sport fishing in
some areas.16 In some areas, disposal of waste and other by-products
of human activities has led to contamination of the water column,
sediment, fish, and shellfish by bacteria,  viruses, and toxics.
     State  reporting on the status of wetlands in 1988 was sparse
and uneven;  only about one-fourth of  the states made  reports.17
Incomplete  reporting can be traced to the  complexity and expense

of wetland monitoring, the  lack of a complete database on wetland
acreage, the absence of state water quality  standards for wetlands
(on  which  measures  of  supporting  uses  could  be based) ,  and
inconsistent  national  guidance  on  the type  of  information  to
collect.  Further, no efforts are made to report on the status and
trends of other aquatic habitats,  many of which have experienced
widespread degradation, or to demonstrate successful environmental
results of management programs.

     The 305 (b) reports just discussed make up the most direct data
on water quality progress. However, several  indirect measures also
provide valuable perspectives. Most  of these indicators measure
our national commitment to water quality rather than conditions in
bodies of  water.  Nonetheless, they serve as useful indicators of
our current efforts  to control pollution and of national capacity
to address these  goals in the future.
Investments  in Water Pollution Control

     As  a nation, the  U.S.  spends more on pollution control per
capita  and  more per unit  of economic  output than  most other
industrialized nations including Great Britain, Japan, Canada, or
Germany.18 All  levels of government  (federal,  state,  local,  and
special  districts) and industry have reported to the Bureau of the
Census   that  they   have  spent $239  billion  to  build  capital
facilities for water pollution control and another $234 billion to
operate  facilities and administer water pollution control programs
since 1970 (1986 dollars).19
     Much more may have been spent on water pollution control, but
not  recorded in Census surveys. For example,  water quality is the
principal beneficiary of  much  of what is spent under the  Superfund
and  Resource Conservation and  Recovery Act  (RCRA)  programs. Many
industries,  such as mining or construction,  invest millions in
controlling  runoff from sites,  but these expenditures are probably
not  recorded   in  standard  surveys of  water  pollution  control
     The assessment  of need  for  additional  investment  in water
quality   is  somewhat variable,  as  it responds  to  changes  in
government regulation, improvements  in control technologies and

September 1990                                                 Page 14

strategies, and shifts in public attitudes about how much spending
is  acceptable and  how  clean  is  clean.  Yet  in certain  areas,
well-documented estimates exist  that  indicate a need  to  invest
substantial sums. EPA's 1988 Needs Survey, for example, concludes
that  another $84  billion will  have  to  be  spent on  municipal
wastewater treatment systems to serve the projected population in
the year 2008 to comply  with the  requirements of the Clean Water
Act.20   This figure could easily double if  communities choose to
invest  in the control  of urban runoff, combined sewer overflows,
and rehabilitation of current facilities.  Moreover, these figures
exclude  needed  upgrades  to   comply  with  the  toxic  discharge
requirements  of the  1987  amendments to  the  Clean Water  Act.
Implementation of remedial action  plans in  critical areas of the
Great Lakes  or  restoration plans  in  the  nation's estuaries will
increase estimates of need, as well.
     EPA's work to implement Section 304(m)  of the Clean Water Act
indicates that effluent  guidelines and standards must be revised
or  developed for  many  industries.  These  new  requirements are
expected to result in significant new private  investment in water
pollution controls.
     In 1987, local governments spent about $15 billion to build
and operate  drinking  water systems. By the year 2000,  they will
have  to spend  nearly $22 billion a  year  just to  maintain the
current levels  of  service and water purity.  Compliance with new
standards  of water purity under the  1986 amendments  to the Safe
Drinking Water Act will cost local governments another $500 million
a year  by the year 2000.21
     State water agencies have estimated  that, by the mid-1990s,
they  will  have  to spend  between  $300 million  a year  and $400
million a year more than  they now spend to  administer water quality
and drinking water programs.22
Services Delivered

     The total  population served by central sewers and secondary
treatment of wastewater or better has increased by 76 percent,  from
85 million  in 1972 to 150 million in 1988.a Federal construction
grants plus state  and local shares built  some 4,000 sewer systems
and 2,000 treatment plants between 1972 and 1988.2* By 1988,  less
than  1  percent  of the urban population  routinely generated  and
discharged  wastewater to  waterbodies without any  treatment.
September 1990                                                   Page IS

     In the  1980s,  EPA and the states had a considerable backlog
in issuing wastewater permits to major industrial dischargers. Now,
the backlogs appear to be shrinking. Today only about 13 percent
of major dischargers await renewed permits.25 The figures  for minor
dischargers  whose  effluents  individually  (but  not necessarily
collectively) have less effect on the environment are somewhat less
encouraging, however  (32 percent backlog). As of December 1988, 93
percent of major industrial  dischargers  and  87 percent of major
municipal  facilities  reported,  from  the  results  of  their  own
discharge monitoring, that they were  largely meeting their effluent
limits. Existing permits, however,  do  not  always cover the full
range of pollutants discharged nor do they always protect biotic
     Drinking  water  is provided  to  200 million  Americans  (80
percent  of  the  population)   by  60,000 community  water systems.
Another 140,000  small-scale  suppliers  deliver  drinking water to
nonresidential   locations  such  as  campgrounds,  schools,  and
factories.   Forty  million  Americans  are  served  by  individual
drinking water wells.
Numbers of Trained Water Quality Professionals

     Separate  statistics are not available on the number of water
quality  professionals,   as  distinct  from  all engineers,  life
scientists,  or social  scientists.26 Yet  intuition  would suggest
that their numbers have grown in tandem with increased budgets for
water programs and the  resultant increase in the number of state,
regional,  and  local water  quality  institutions.  Some  data do
support  such  intuition.  For example,  the  employment  rate for
scientists  and engineers, in  general,  has  increased faster than
total U.S.  employment,  accounting for 3.6  percent  of  the labor
force in 1986, compared to 2.4 percent a decade  earlier.27 Compared
to the Bureau of Labor Statistics*  projection of 15 percent average
growth in  employment in the 1990s, the outlook for professionals
that  typically manage  water quality  appears bright: 17 percent
growth for civil  engineers,  26 percent for biologists, 17 percent
for chemists, and 32 percent for managers in the  natural sciences.28
     The  number of certified operators  of  water  and wastewater
treatment plants increased rapidly in the 1970s and 1980s.  In 1961,
there were only  about  20,000  certified operators of  water and
wastewater   treatment  facilities.29   By  1970,  the  number  of
board-certified water and wastewater treatment plant operators had

September 1990                                                  Page 16

almost tripled to 57,000. The total almost tripled again by 1980,
with 141,700 that year.30  A new survey in  1990 is expected to show
that growth in the number of certified operators has leveled off.
Public Awareness of Water Quality Issues

     By many measures,  public awareness of the environment is at
an all-time high. In a major public opinion poll conducted for USA
Today's special Earth Day coverage, for example,  Americans were found
to be more concerned about the environment today than in the past.
Two-thirds of the 850  adults contacted nationwide believed that the
environment is getting worse, and one-third saw evidence  of local
environmental  deterioration.  While  public  opinion  is  heavily
influenced by current events, one important finding of this survey
was  that  nearly  three-quarters of  the  respondents were   more
concerned  about these trends than  they were  five years ago.  In
another  recent survey of 1,500  adults  nationwide, 22 percent  of
respondents said they thought most groundwater is contaminated with
chemicals  or  other pollutants.  Only  7  percent were  so convinced
when that  same  question was  asked in  1981. 3Z
      Topping the list of environmental concerns in the USA Today poll
were two prime water quality issues: storage of hazardous waste and
pollution   of  drinking  water,  sixty-seven   percent of   those
interviewed said they were "very worried" about hazardous waste;
57 percent were "very worried"  about  contaminated  drinking water.
These issues  were found to be of greater  public concern  than
increasing cancer rates,  running out  of landfill space,  damage to
the  ozone  layer,  the  loss of  tropical rain forests, or damage from
acid rain.
      Of  particular interest, the poll  generally corroborated the
results  of similar efforts  in the past — that  Americans  are more
concerned about environmental quality than they are about the cost
or  inconvenience  of  new   environmental  regulations.   As  one
 indication, nearly two-thirds of all those polled  said they would
pay  15 percent higher taxes  to clean up the environment. More than
half said they were willing  to  pay 15  percent more for groceries
 if all packaging was recyclable.
      At the same time,  respondents  were not convinced that drastic
 action was necessary. Two-thirds believed  that individuals alone
 could help the environment significantly. More than half  said that
 the  environment can be kept  clean without drastic changes in their
 September 1990

Growth in the Number of Water Quality  Institutions

     Increases  in  statutory authority and  public  and  private
investment in water  quality have been accompanied by growth in the
number of water quality institutions.  This  includes local, state,
and  federal  agencies;  university  research  centers;  corporate
environmental programs; and  other  public and private entities.
     One indicator of the  growth in  water quality institutions is
the growth  in special  districts established to deliver drinking
water and wastewater treatment services to the public.  In the 1950s
and 1960s, there were few such districts; by 1972, however, a total
of  6,742  had been  established.33  The  number of  water  and sewer
districts grew by 50 percent over  the next five years to a total
of 9,386 by 1977. Growth continued over the following five years,
but at a  slower pace;  by  1982,  10,866 water and sewer districts
had been established.

     While  progress  has been  made  over  the  past  20  years,  a
consensus has emerged that we still have a long way to go to solve
the nation's water quality problems. If efforts are not expanded
to meet these  challenges,  not only will we fail to meet national
water quality  goals, we risk a  reversal  of the progress made to
September 1990                                                   Page 18


     The  fundamental  causes  of  water quality  problems  lie in
seemingly unrelated aspects of life:  how we live, the way we farm,
produce and consume, transport people and goods, and plan for the
future. Many aspects of modern life and past practices put pressure
on water quality. Until recently, these activities proceeded with
little  recognition of  the effects  they  had  on  surface  water,
groundwater, and aquatic habitats.
     Typically, individuals and society make choices that reflect
values specific to farming, producing, consuming, or working—but
not necessarily  to achieving clean water  or healthy ecosystems.
Sometimes these values conflict with  clean  water goals, until very
recently, conflicts remained  largely unrecognized, at least until
water quality problems became so apparent that  the public demanded
action, as it  did  in  the  early 1970s in response to the Cuyahoga
River catching fire, or in the 1980s  to the declining condition of
the Chesapeake Bay.  Historically,  such conflicts  were resolved
through relatively narrow legislation to restore and protect water
quality  by altering  the  direct  sources  of impairment but  not
necessarily the root  causes  of declining water resource quality.
Even today, when we  are beginning to recognize some of the basic
conflicts between human activities and environmental quality, few
contemporary solutions address the basic economic and social forces
at the root of water problems.
     Our  tendency  as a society  is to underestimate the  cost of
pollution in currently less populated areas, such as wilderness or
aquifer  recharge  areas,   because there   are  fewer  immediately
measurable  impacts  on  human  health  and  because  we  tend  to
undervalue  the  impacts   on  biological  communities  and  their
habitats.  We  are beginning  to  recognize  the inadequacies in
currently available methods to assess the negative consequences and
benefits of our actions.
     The economic benefits of  pollution may be reaped by one group,
whereas the costs of pollution may be borne disproportionately by
another—those  least   financially  and  politically  capable  of
influencing the decisions.
     Hence, while  it  may take time  to reconcile societal values
regarding the way we live,  produce and consume, farm, or work with
our preference for a healthy environment, drawing attention to the
effects of our societal decisions on  water quality is critical.
Focusing  on  these societal causes  of water quality problems is
September 1990                                                  Page 19

essential  if we  are to articulate  long-term  solutions in which
societal goals  are compatible with clean water.

     People's day-to-day activities  and the choices they make for
lifestyles—suburban living,  green lawns, and throw-away consumer
goods—can  have  unanticipated  but  profound  effects  on  water
quality. Similarly, our business and government leaders have, at
times, made decisions with little regard for water quality impacts.
Intensive  agriculture  seeking   high yields   with  fertilizers,
pesticides, and  irrigation water is designed to feed the nation at
low cost. Until recently, the cost of water quality impairment from
chemicals  and soil washing  off  the nation's  farmland  has been
missing  from  agricultural   policy   debates.   Manufacturing  the
products most  Americans demand also generates  residual material,
which  is mostly  treated as wastes. While some  are recycled, many
of these wastes  directly or  indirectly find their way to surface
and groundwater. Even the most seemingly  innocuous of habits—for
example, fertilizing our lawns to make them green in summer—can
add potentially  harmful nutrients to nearby waterbodies as excess
nitrogen and phosphorus compounds wash off the  land or infiltrate
to groundwater when it rains.
     Every  day  the American public, including  individuals  and
leaders  of business and government,  makes choices in arenas that
appear unrelated  to  water  quality,  but do,  in fact,  affect it.
There  are six key areas of concern:

     o  How we live;
     o  How we produce and consume;
     o  How we farm;
     o  How we transport people  and  goods;
     o  How we plan;  and
     o  How we have acted in the past.

     Currently,  national water quality policies  and programs do not
address  these societal origins of impairment.
September 1990                                                  Page 20

How We Live

     The way Americans live  is  shaped by  a variety of social and
economic forces—the availability  of  inexpensive automobiles and
gasoline as well as a lack of alternative forms of transportation,
proximity  of  homes to  centers  of  commerce and culture,  and
government  incentives  for  home  ownership,  for  example.  The
resulting land use  pattern is a product of consumer preferences,
local  government  decisionmakers,  and  land  developers.    Until
recently, concern  for environmental quality has  not affected our
way of life to any significant  extent.  But as lifestyles evolved
toward decentralized urban and suburban centers after World War II,
conflicts began to emerge between lifestyles and the quality of the
environment.  Environmental   controls  in general  and  efforts  to
improve  water quality  in particular  increased in  the 1950s and
1960s, frequently in reaction to crises.  However,  efforts to target
and control urban  and suburban  growth and to plan for sound land
uses have not always been sufficient.  Sprawling growth continues
to claim our open space, agricultural, and natural lands.
     By 1970, the conflicts between American lifestyles and water
quality  captured national attention.  Twenty years later,  we can
point to much progress. However, we can also identify continuing
water quality problems associated with how we live,  such as runoff
from roads  and construction sites, contamination of groundwater
from poorly designed or malfunctioning  septic systems, discharge
of untreated  sewage from  combined sewers  when it rains,  loss of
open space  with the development of new suburbs  and  degraded or
destroyed aquatic  habitat from  overuse, unregulated recreational
activity, or housing construction. Our challenge is to anticipate
how lifestyle choices may affect water resources and then plan to
live compatibly with preserving and improving water quality.
     The way Americans use energy also has  significant implications
for water quality,  although  the linkages  are rarely spelled out.
Modern life entails higher energy use  than lifestyles of a century
ago. However, Americans use energy  half  as efficiently  per unit of
economic output  as do populations  in other developed economies.
More efficient  use of  energy in homes  and cars—shifts that are
well within  the  reach of  current technology with  net savings
compared to current use—could reduce  significantly the demand for
oil,  gas,  and  electricity. In  turn,   worldwide oil  and  gas
extraction,  processing,  and transport  could be  reduced,  with
accompanying  worldwide  reductions  in water pollution  from these
activities. Reducing worldwide oil and gas demand would also have

September 1990                                                  Page 21

other benefits, including reduced downstream water quality impacts
and  production of  acid rain,  which results primarily  from the
combustion of  fossil  fuels.
How We Produce and Consume

     Manufacturing processes that  transform  raw feedstocks into
fundamentally different products must of necessity generate some
residual   materials.   Until  recently,  industry  practices  and
government regulations  have thought  of these  materials almost
exclusively  as wastes,  so they  have  been disposed  of,  with or
without  prior treatment,  in the nation's rivers,  streams,  and
lakes. This  strategy  has been costly both to  society  directly and
indirectly,  through decreased environmental quality.
     The  U.S.  market-based  economy is  characterized by private
production and consumption decisions that are generally driven by
concern for short-term profits and convenience.  That is, producers
make decisions as  to whether and how to produce  goods  and  services
based on demand and their expectations regarding revenues  from the
sale of goods versus the cost of producing them.  Many environmental
problems  originate in  the difference between  the private costs
considered in production decisions and the external costs  of those
actions to society. Such societal costs include  reduced recreation
opportunities  or  increased  incidence  of disease  from  drinking
contaminated water.
     While producers do not  pollute out of  malice,  they may not
take into  account  the environmental ramifications and  or the costs
their  actions  impose  on  society unless  there  are government
regulations. Electroplaters, for example, would control the release
of spent plating baths  only to the extent that  it  is  economically
attractive to do   so.  Their calculation  of what  is or is not
economic must compare the cost of purchasing  new plating  solution
to  the cost  of  buying  and operating equipment  to  purify spent
solutions.  In the absence  of  regulations  preventing discharge,
whatever is not recycled would be discharged to sewers or to nearby
waterbodies,   possibly   without   adequate   treatment.   Because
electroplaters would  not have to pay directly for costs associated
with the effects of the  discharge, they would have no  incentive to
consider  these "external" costs  in  the management  decision of
whether to recycle or discharge  spent plating  bath.  Nonetheless,
those  uncontrolled  discharges   can   reduce  or  eliminate   fish
populations,  impair recreation,  and  impose  substantial  costs to

September 1990                                                  Page 22

nearby drinking  water supplies  for removing harmful  chemicals.
Other  environmental amenities,  such as  the overall  health  of
aquatic ecosystems  or the aesthetic  value  of clean water,  cannot
be fully measured in economic terms, but have value nevertheless.
     Without  government  regulations   mandating   such  actions,
industry  has little  incentive to  shoulder the  cost  burden  of
pollution control when the benefits  of  clean water accrue  not to
industry  specifically, but  to all  who  use  receiving  waters for
swimming, fishing, or boating. In a competitive market, producers
who raise their own production costs  by making greater investments
in controlling pollution  relative to other  producers are likely to
be driven out of the market. Well-designed government regulations
can reduce the effects of these perverse incentives.
     Consumption  patterns  also  are  responsible  for  much  of
production waste. American consumers typically demand, or have been
conditioned to expect,  well-packaged products. And while packaging
is often  associated with product safety,  hygiene,  or  longevity,
by-products of our  relatively  inefficient patterns of consumption
are  too  frequently  disposed  of  with little  thought  to the
consequences. Even  though consumers have always had opportunities
to exert  such  leverage through their buying power, only recently
have  they begun to influence production  decisions  by demanding
environmentally compatible products, less packaging, or packaging
materials with benign effects  on the environment.
     For  many  types of  products,   we  have grown  used to the
convenience  of disposal  rather than reuse.  It  is not  surprising
then that the United States produces more waste per person than any
other  industrialized nation.  In fact,  Americans often  throw away
what  amounts  to  valuable  recyclable  resources  in  some   other
economies—used plastic bags—for example.
     There are indications that the way we produce and consume is
beginning to change. In response to  incentives beyond regulations
—liability,  public  image,   expanded  markets  for  by-products,
shifting  consumer  demands,  widely available information,  and new
technologies, to name only a few—some industries are becoming more
environmentally  conscious,   recycling  materials   and  preventing
pollutants at  the  source. Overall,  however,  society has not done
an  adequate job  of sending  consumer  signals  and  developing,
encouraging, and regulating private industry to  make  profits in
ways that are consistent with  protecting the environment.
September 1990                                                   Page 23

How We Farm

     The production of food and  fiber of necessity involves the
disturbance of  soil and water.  Since  a great deal of the American
landscape  is  farmland,  activities  such as  tilling the  soil,
applying fertilizers and pesticides,  and irrigating fields make
agriculture the largest source  of polluted runoff in the country.
Agricultural sediments, nutrients, pesticides, and salts can impair
rivers,   lakes,   and  wetlands;   agricultural   pesticides  and
fertilizers   can   contaminate    groundwater;   and   agricultural
development can displace  natural  wetlands.
     Many farms are characterized by monoculture, or  the production
of  just one crop.  Monoculture requires  greater  use of chemical
fertilizers  and pesticides than  does diversified production. It
also may  cause more  soil erosion. With few positive  incentives,
but facing significant impediments to change, the farm sector has
been  slow to  adopt changes that can  be  equally productive and
minimize environmental impacts through crop rotation, integrated
pest management, soil  and water  conservation,  and  use of buffer
strips  to protect  aquatic ecosystems.
     Improper  irrigation  practices result in leaching  or drainage
of excessive amounts of salts, nutrients, and pesticides from soil
to  surface  waters,  and  infiltration  of these  constituents to
underlying aquifers.  Some government programs provide incentives
to farm in ways that directly influence water quality and use. For
example, federally subsidized irrigation water has been identified
as  a   disincentive  to  conservation  efforts.     In addition,
agricultural price and income supports encourage farming practices
that  lead  to water quality problems.   These practices may  result
in  agricultural production on environmentally  sensitive lands. In
the West, water rights based on the "use or lose" principle (actual
or  perceived)  also  encourage excessive application  of irrigation
     Policy  decisions that limit consumer choices are also  partly
responsible  for current farm practices that impair  water  quality.
Grading standards and marketing orders administered by government
and industry,   for  example,  place a  premium on unblemished fruit
and vegetable products,  which  leads  to greater use of pesticides
and waste of nutritionally acceptable food. Consumers have come to
expect  year-round availability  of such products. In addition, food
packaging  and value-added  processing  can contribute  to  water
quality problems  through the use  of paper and plastics and  the
production and disposal of chemicals.

September 1990                                                   Page 24

     Timber  harvesting,  grazing,   and  concentrated  livestock
operations also contribute to water resource impairment. Grazing,
timber, and mining subsidies often exacerbate impairment. Although
environmental impacts of livestock and use of pasture and rangeland
can be mitigated through proper management, degradation of adjacent
rivers, streams, and lakes has been and continues to be a problem
when  grazing  is  mismanaged.  The  most  prevalent  problem  is
overgrazing, which causes erosion and  loss of nutrients from the
soil into  waterbodies.  In addition, when  animals  are allowed to
graze riparian areas, they can seriously damage or destroy stream
banks  and vegetation  as well  as  produce wastes that  directly
contribute bacteria and nutrients to water. Finally, water projects
(ditching,  channelization,  dams)  alter  aquatic  habitats  and
decrease   biotic  integrity  (for   example,   extinctions   and
How We Transport People and Goods

     Transportation  is a  vital force  in the  nation's economy.
Although  water  quality implications  rarely  play  more  than a
peripheral role when transportation decisions are made, transport
facilities  (roads,  highways,  railways,   harbors)   and vehicles
clearly affect water quality  in five ways:

     o  Directly  through disturbance  or elimination  of  aquatic

     o  Directly   through    runoff   from   surfaces,   carrying
        contaminants such  as deicing salt,  oil drippings, brake
        lining dust, or fuel  spills.

     o  Directly  by  runoff to surface water and infiltration to
        groundwater  from  accidental  spills  of  oil   and other
        contaminants from trucks, ships, pipelines,  and trains;

     o  Directly  from  deposits  of airborne contaminants released
        through the routine use of facilities and vehicles; and

     o  Indirectly by helping to determine where we live and work;
        in particular by encouraging dispersed development patterns
        without adequate concern for water quality.
September 1990                                                   Page 25

     There is  little controversy about the need to control these
direct  impacts, especially  from land-based  transportation.  But
marine transportation also contributes to water quality degradation
in ways that are both anticipated and unanticipated. While national
programs seek  to minimize  adverse effects, dredging ship channels
to assure navigation eliminates habitat diversity and species and
can  resuspend  toxic  chemicals  and  other  pollutants  that  had
accumulated  in bottom  sediment. In addition, dredged material can
present  a problem  unless  disposed of  in  a  proper manner  and
     Improper  placement  of  this  material  can destroy  aquatic
habitat; but proper disposal of uncontaminated material can be used
for  beneficial  purposes,  including  beach  nourishment,  wave
attenuation,   wetlands  creation  or   restoration,  shallow-water
habitat development, or uplands construction. Contaminated dredged
material can cause numerous problems unless isolated from the water
column  by   management  techniques,  such  as  confined  disposal
facilities,  underwater  capped  mounds,   or  capped  underwater
depressions, that  are  suitably designed, sited, and operated.
     However,   while most  public  attention  focuses  on  direct
effects, the indirect  influence of transportation on land use and
lifestyles could have a more profound impact on water quality in
the long run.
     In  recent  decades,  the U.S.,  along  with other  advanced
economies, has increased its reliance on cars and trucks instead
of mass transit and rail. While cars offer convenience in moving
people and  trucks offer efficiency in moving goods, highways are
well-documented  sources   of  contaminated   runoff  and   their
construction has sometimes  destroyed  wetlands and other aquatic
habitat. Urban highways and other commuter roads have had the most
far-reaching  effect  on  water   quality   by  facilitating  and
encouraging  the nation's move to the suburbs, in 1980,  nearly 60
percent  of  our urban  population lived  in the  suburbs;  almost
three-fourths  of  the  growth  in  the 1980s  occurred  in suburban
areas.34 These  trends show no  sign of slowing, with 85 percent of
the growth  to  the year 2000 projected to occur in the 50 largest
metropolitan areas.  In the past, we have failed to recognize the
full   environmental   cost  of  development   in   land   use  and
transportation  policies.  Our  future  challenge  is  to  meet the
transportation needs of the nation in ways that are compatible with
good water quality.
September 1990                                                   Page 26

How We Plan

     Resource  and  land use  planning  is  essential  to  achieve
economic growth that is compatible with good water quality.
     Yet,  traditional  planning  efforts have  not  taken  a broad
enough  perspective to  anticipate  effects  on  water quality  or
aquatic  habitat over long  enough periods  of. time or  over wide
enough geographic areas. In some cases, when planners have failed
to communicate clearly with those responsible for implementation,
the  resulting  actions  have  been unrelated to even the  best of
plans. In other cases, despite adequate efforts to communicate, the
location  of  development or  transportation corridors has occurred
more as  function  of local political pressure  or the cost of land
than  of  overall  planning.  Even when planners  work  well with
politicians  and the private development  community,  attention to
water  quality  concerns may be  inadequate because  none  of the
participants are sufficiently trained in environmental disciplines.
     Traditionally, the need to provide a growing population with
water  and sewer  services  has driven  planning  related to water
resources and pollution control.  In the 1970s and 1980s,  government
increasingly regulated point  sources  and  much  water   quality
improvement  resulted. However, these regulations usually  followed
the  boundaries of  political jurisdictions  (states,  counties, or
municipalities) rather than ecological  areas,  such as river or lake
drainage basins. In addition, traditional planning efforts focused
on short-term delivery  of services; they placed  relatively little
emphasis on  long-range, strategic planning. Moreover,  rarely has
water planning incorporated interactions between water quantity and
quality.  Such needs are especially  critical for  planning  adequate
quantities   of  safe drinking  water from  all  sources including
surface  water  and groundwater as well as wastewater effluent and
other  nontraditional sources.
     The result of this legacy is that layers of federal,  state,
regional,  and  local government responsibility create a  fragmented
approach to planning.   An  emphasis  on  single-focus  compliance
ignores  the  importance  of management on a broader geographic scale
and  over  longer  periods  of  time.   The   current  paucity  of
consistently gathered data  on the quality of  the nation's waters,
discussed earlier,  is testimony  to this   relatively   narrow,
short-term planning perspective.
     Too often, point  source data  and chemical-specific  permits
dominate the process used  to make decisions that affect  entire
watersheds.  Data  on  runoff and ambient  conditions  (including
September 1990                                                   Page 27

integrative biological evaluations)  are not given equal status. For
example, the majority of controls in point source discharge permits
are based on  achieving a certain concentration in the water at a
specific site instead of by determining a total  pollutant loading
analysis  for the watershed  as a whole.  Moreover,  local ambient
water  quality  is generally  measured by  concentrations of  key
constituents in the water column, only—not in the bottom sediment,
in fish,  or in other aquatic  species.  Further,  little effort is
made  to  assess  the  structural   and  functional  integrity  of
biological systems within the  water resource. Finally, rarely are
the  effects  of upstream  land use  decisions or  the  cumulative
impacts  of many  small  human  actions translated  into basinwide
changes in the  quality of the  water resource.
     The  absence of a  comprehensive  planning  strategy  that is
accepted and  fostered by government and academic institutions has
hampered our  ability to properly use water resources and protect
water quality. There have been  some attempts to coordinate planning
efforts for entire watersheds,  such  as EPA's areawide water quality
planning  program in the  1970s  or, more recently,  its National
Estuary Program.  However, such efforts remain more the exception
than the  rule.  Even the most  comprehensive of planning exercises
often fail to account for cumulative effects.
     Local  land use controls that account for water quality have
also been the  exception,  although  this may  be  changing.  At the
local level,  most land  planning has  responded to growth, rather
than guiding development in ways  compatible  with protection of
recharge  areas, conservation of aquatic habitats, or improvement
in  the  quality  of surface  waters.  The  impact of   sprawling
development on  watersheds, and consequently on water quality, has
not always been recognized.  Even if recognized,  efforts  to target
and control growth  have often  been  insufficient.
     Much more  remains to be done to  improve  both the way we plan
for  general economic expansion and for  the  protection of water
resources.  We  must consistently monitor  changes in water quality
and  their effects  on aquatic life to  identify the most serious
causes of  impairment and, in turn,  use funding efficiently.
How We  Have Acted In the Past

      Changes in  how we  live  in the future  will  not prevent  or
remedy  all  damage to water quality. Water quality will continue to
September 1990                                                   Page 28

be degraded by past uses of the land that contribute to continuing
pollutant loadings and to physical damage to aquatic systems.
     Examples  of  these  past  activities with  continuing impacts
include drainage and leaching of pollutants from abandoned mines,
tailings piles, solid waste and hazardous  waste disposal areas,
spills, pollutants in the  bottom sediments,  and  pesticides and
other  materials currently  present in  the  soil  and groundwater
systems.  Past physical  alterations,  such as channelization, and
continuing  physical impacts of  past  activities,  such  as stream
scouring  and  erosion,   will  also  affect  future water quality
regardless  of  our  changes  in  current  practices.  Introduction of
exotic species have also occurred as a result of past activities.

     The  causes  of  water  quality  degradation  are  far  from
straightforward or  simple.  They are  intertwined with aspects of
life that  seem far removed from concerns  over water quality. In
addition, traditional  planning efforts have  been  too limited to
achieve economic  growth compatible with good water quality. The
section that  follows identifies the  many  impediments to solving
these problems.
September 1990                                                   Page 29


     What are  the major obstacles  to  improving water quality? The
reports of  the Water Quality  2000 work groups discussed a broad
range  of  impediments emanating from  a  great variety of sources.
Most  of  the  issues  raised  by the  work group  reports  can  be
summarized  in  terms of  seven crosscutting types of impediments to
improved water quality:

     o  Narrowly focused water policy;

     o  Institutional conflicts;

     o  Legislative and regulatory overlaps,  conflicts, and gaps;

     o  Insufficient  funding  and  incentives for water  quality

     o  Inadequate attention to the need for trained personnel;

     o  Limitations on  research and development; and

     o  Inadequate public commitment  to water resource quality.

     Effectively removing these seven  impediments will result in
near-term  improvement in  the  nation's  water quality.  Work group
members would agree that  these seven issues are not necessarily
equal  in  importance.  Establishing  priorities among them, however,
is  reserved for Phase  III of the project,  as explained earlier.
Despite gaps in  data,  limits to scientific knowledge,  and a need
for new technologies, many believe that water quality improvements
are attainable now.


     Water  quality programs  in the 1970s  and 1980s have  emerged
from relatively prescriptive, fragmented, and sometimes inflexible
federal and state mandates.  In part  because they were easier to
implement  and installation  was easier  to confirm,  water  quality
control strategies of  the 1970s  and  1980s relied on engineering
solutions;  little use was made of ecological knowledge and economic
tools  and  other strategies capable  of directing  resources  to

September 1990                                                   Page 30

protect water  resource quality.  The easy  targets--point  source
controls and conventional pollutants—were addressed first, largely
outside of  any  comprehensive  framework  for overall water quality
improvement.  Consequently,  too  little  attention was  paid  to
measuring  improvement in  waterbodies  as  a whole. Instead,  the
measures of improvement corresponded to the fragmented policies—
numbers of  treatment  facilities put  in  place or the reduction in
frequency of discharge violations from  individual point sources,
for example.
     The result is the distinct  lack  of a  holistic  approach to
water   resource  protection   programs   today.   In   particular,
traditional fragmented approaches typically fail to address:

     o  Watershed-based planning;

     o  Cross-media  effects  (pollutants  that  cross  traditional

     o  The relationship between water quantity and water quality;

     o  Pollution prevention; and

     o  Environmental  results.

Watershed-based Planning

     In Section 208 of the 1972 amendments to the  Clean Water Act,
Congress designed a framework to coordinate water quality programs.
Section 208 directed basinwide and areawide planning to account for
and  set priorities   over  controlling  municipal   point  sources,
industrial  point  sources,  and runoff from rural and urban  lands.
Over  time,  however,  the  208  program  produced many  planning
documents but largely  failed to coordinate government programs or
set priorities  for investments in water quality.  In part this  was
due  to unfortunate  timing—federal grants to build wastewater
treatment   plants  began   before  the  planning   could  help   set
priorities  for  funding.
     Much of the  problem  of policy fragmentation seems linked to
our  failure to recognize  or  reluctance  to adopt the appropriate
spatial  scale,  including   patterns   of   water  movement   and
biogeographic  considerations,  for water resource planning  and
management.  This  approach  provides  the  framework to evaluate  a

September 1990                                                   Page 31

natural  resource problem using a natural systems approach. It is
well  suited  to  track  holistic  cause-and-effect  water quality
relationships  since  it can  link upstream uses  with downstream
effects. Without understanding these relationships, it is difficult
to  assess  current  or  potential  conditions  or  to  remediate
cumulative  environmental degradation.
     Even   where  there  is  a  watershed  approach,  ecological
differences in the  landscape between upstream and  downstream areas
often are ignored.
Cross-Media  Effects

     Many  environmental   professionals  have  recently  come  to
recognize that many pollution  problems do not fit neatly into the
traditional  typology  of  single-medium environmental  laws  and
policies.  A single  disposal effort may potentially  affect both
water and air quality. Sludge  handling under the Clean Water Act,
for  example, can  have profound effects on groundwater quality.
Nitrogen oxides released into the air,  even in compliance with the
Clean  Air Act,  can be  deposited in waterbodies  downwind, with
significant degradation of water quality. Pollutants in surface and
ground waters increase the cost of delivering pure drinking water.
     Following traditional, single-medium approaches, residuals can
potentially  be transferred from one medium to another.  Under the
Clean  Water Act,  for example,  EPA established technology-based
effluent  limitation  guidelines  and standards  for  the  organic
chemicals industry that allow the use of air stripping. Under these
guidelines,  the   water  quality  problem  would  appear  to  be
eliminated, but air stripping can result in air pollution problems.
Air regulators are then left to regulate emissions from wastewater
treatment  plants  under  the  Clean Air  Act.  Alternatively,  if
industry uses  steam stripping, the sludges produced may become a
regulatory target under the Resource Conservation and Recovery Act.
     Shifting the  management burden from one medium to another is
inefficient  from both public and private perspectives.  In addition,
transfers leave open opportunities for pollution problems to  escape
regulation entirely.  In  a  striking example, Philadelphia recently
attempted  to control  emissions within its airshed by requiring
installation of precipitators on urban smokestacks.  The solids and
sludges that were removed,  however, found their way to  the Delaware
River,  either directly  through discharge  or  indirectly through
runoff  from land  disposal.  Once in the river,  metals  and other

September 1990                                                  Page 32

constituents that  had been removed from  smokestacks  through air
pollution  controls were pushed  upriver by natural tidal action
until they entered the  city's  drinking water intake.  Extra funds
had to be allocated to remove these pollutants from drinking water
The Relationship Between Water Quantity and Water Quality

     Water quantity is important to water quality in many areas of
the U.S., yet  the  quantity aspects of water resources are almost
always regulated and managed separately from the quality aspects.
Water  withdrawal  for all  types  of  consumptive  uses can  have
profound effects on aquatic habitat downstream. To the degree that
water is withdrawn from  streams and not returned,  less in-stream
flow is available for fish and wildlife habitat, inputs to wetlands
and other aquatic  resources,  and mixing in estuaries to preserve
critical  freshwater/saltwater  balances  and  prevent  saltwater
intrusion into coastal aquifers. Water used, degraded, and returned
to  waterbodies  can have  equally  significant  effects on water
quality. Irrigation return flows often have high concentrations of
salts and metals, for example. In addition, excess water use places
a burden on overloaded sewage treatment plants.
     Concerns  for  water quality also limit water use. Regulations
that prevent estuarine salinity from exceeding acceptable levels
for drinking water  supplies  can limit  power  plant withdrawals,
especially during  a drought. They also can affect the operation of
upstream reservoirs. In a few cases, strict application of effluent
discharge  rules at  wastewater  treatment plants can  alter water
supply and in-stream flow when treated effluent constitutes a large
part of the flow in  the receiving  stream.
     When  water  quality  is   impaired   by   point  sources  or
contaminated runoff, the effective water supply available for human
and environmental uses declines  or the cost of water treatment  (for
supply)  increases. Contamination of aquifers likewise eliminates
or increases the cost  of using  groundwater sources for many uses.
Pollutant Prevention

     Until very recently, the Congress and EPA have largely focused
their efforts on treating pollutants once they have been generated,
rather  than  preventing or reducing their generation in the  first

September 1990                                                   Page 33

place.  The  end-of-pipe treatment  focus  of  the  Act and  other
statutes fails to encourage or reward reduction at the source. The
very focus on effluents in the Clean Water Act is testimony to the
fact that  legislators have  not really begun to address  ways to
reduce waste at the  source.  Further,  it reflects the dominance of
a chemical perspective and  a  narrow concept of  pollution (chemicals
and other contaminants) that diverts attention from the biological
and physical impairment that results  from a wide variety of human
     Moreover, setting uniform national technology-based standards
may not require but tends to encourage installation of end-of-pipe
technologies used to set discharge limitations. Such standards act
as a disincentive for potentially more efficient local solutions
to  meeting  performance  targets,   some   of  which  could  involve
pollutant  prevention.
     Even  where  the language of the  law  may  authorize relatively
more  attention   to  preventing the   generation  of  pollutants,
legislative  and  regulatory policies  have  emphasized the granting
of permits to discharge a limited amount of pollutants or cleaning
up  existing problems  rather than  eliminating or  preventing new
ones. The  Clean Water Act, for example, established a  goal of zero
discharge. It  explicitly  calls  for a   standard permitting no
discharge  of pollutants, wherever  practicable, but this provision
of the  act has not been widely implemented. While the Clean Water
Act established this goal, it also  created a permitting system that
allows  discharge of pollutants up  to certain  limits.
     Most  states  have relied  on  best  professional  judgment in
setting these limits.  States have only  recently  begun to adopt
water quality standards based on specific  quantitative criteria for
metals  and  organic  compounds  or  to include  these  limits in
discharge  permits.  As  a  result,  dischargers  have had little
incentive  to reduce their discharges of  these constituents below
levels  required  by effluent limitations.
     Pollutant  prevention strategies  hold particular promise for
addressing water quality problems  caused by agricultural  or urban
runoff. While historical  efforts to address soil erosion  problems
are analogous to practices to prevent  the  generation of pollutants,
only recently have efforts been initiated to  address  agricultural
water quality problems resulting from application of nutrients and
pesticides.  Similarly,  controlling or preventing the  discharge of
pollutants from stormwater has only recently begun to be  addressed.
September 1990                                                  Page 34

Environmental Results

     Measuring the outcome of our water quality control strategies
has proven elusive, in part because of the limitations of the data
currently collected. At best, we have devised ways to count inputs
—the  number  of  permits  written,  the  number  of  enforcement
proceedings, or the dollars and staff devoted to a given problem.
But  in most cases,  we have not  chosen  to measure  progress by
measuring environmental results. Overall, monitoring programs have
not been used extensively to measure the status of water resources
or to  identify the causes  of declines  in quality when  they are
detected.  Further,  monitoring  has not been  used to  assess the
extent to which regulatory and other efforts have had the desired
effect in improving the quality of water resources.
     Clean water programs have been less effective than they could
be because  of  a failure to  collect  baseline  data and statistics
related  to environmental  results  over time.  This lack  of data
contributes  to a  lack of program  accountability,  inadequate or
uncontrolled  program  oversight   and  implementation,  uncertain
direction, and the inability to  focus limited resources on the most
environmentally effective  initiatives. While  the Clean Water Act
required collection and reporting of data  on the attainment of its
f ishable-swimmable goal, EPA has developed inappropriate or unclear
accountability  measures that are  more related to administrative
activities  than to clear-cut environmental results.  In its clean
water agreements with states, in effect, EPA often ends up holding
states  accountable for  collecting  statistics  on administrative
activities  rather  than  for achieving measurable  environmental
improvements.   Historically,  monitoring  has  focused  on  water
chemistry,  largely ignoring physical habitat, flow,  and biology.
This has resulted in substantial losses of aquatic ecosystems.  Both
the  extent  and  the  biological  integrity of  the  resource has
suffered,  despite general  improvement in water quality.
     Even  where environmental data are used to assess results of
programs,   sometimes  different   EPA  program  offices  collect
noncomparable  data  or use  incompatible  systems  or  formats.   A
similar  problem  exists  among the various  agencies  charged  with
protecting water  quality (the Environmental Protection Agency, the
National  Oceanic  and Atmospheric  Administration,  and  the  U.S.
Geological Survey, for example). In 1988, a U.S. General Accounting
Office report  recommended  that  EPA  do  more  to   "manage for
environmental  results.I|3S
September 1990                                                   Page 35

     Development  of  improved biological  methods over  the past
decade  has  provided  a  mechanism  for  assessing  environmental
results.  Ohio  and  Maine,  for example,  have  adopted biological
criteria to assess  resource status  and  trends.

     Under the American system of government,  federal, state, and
local  units  share responsibilities  for different aspects of the
same program or for different programs.  Implementing environmental
initiatives   under  this   system   inevitably  involves  private
participation and the commitment of individual citizens or their
representative groups.   Relationships  among these key players are
largely  constructive;   opposing  viewpoints  can  be  voiced  and
compromises reached.   Yet  conflicts  can arise  over  the allocation
of authority and responsibility among government units, the private
sector, and individual citizens.
     Two  types  of conflicts  can  cause serious  impediments  to
improvements  in  the nation's  water  resources.  First,  conflicts
can arise  out of the balance of authority among the key players.
Second,  conflicts can  arise among  different participants within
each  level of  authority.   The  following sections present  the
current role  of the key  institutional players in water quality and
note the critical conflicts that often arise.
Federal Government

     While  the federal  government  participated  in water quality
control  to some  degree  in the  1950s  and  1960s,  surface water
quality was predominantly a state and local concern until 1972. In
that year,  the federal  role  in setting standards and charting a
national  program  direction  for  surface  waters  began to grow.
Throughout the late 1970s and 1980s, states began to adopt the role
of implementing  agents of the federal program but retained their
authority  to  enact  stricter  or more  expansive  water  quality
controls so long as minimum federal requirements were met. While
local governments  continued their role  as  owners and operators of
drinking water and wastewater  treatment  facilities,  the  pace of
construction  of  wastewater facilities was greatly hastened under
an expanded federal grants program.  The 1974 Federal Safe Drinking
Water Act focused local attention on the quality of drinking water.

September 1990                                                  Page 36

     Federal programs in water resources development and protection
have undergone several major shifts since the late  1800sr when the
Corps of Engineers was first authorized to protect  the nation from
floods.  Today, more than a dozen federal agencies conduct programs
in such  diverse  areas as navigation,  flood control,  irrigation,
hydropower  production,  ecosystems preservation,  fisheries  and
shellfisheries restoration  and  maintenance,  coastal and marine
protection, and  basic water use and quality data  collection and
     With so many federal agencies  involved  in water resources and
water quality, it is not  surprising that they sometimes overlap or
conflict with each other.  For  example,  federal  land management
agencies may work at odds with water quality goals when they seek
to maximize timber production, mining output, or grazing acreage.
One federal agency with authority for delivering irrigation water
to off-stream farms may  have little regard for another agency's
goals for alternative in-stream water uses,  such as maintenance of
aquatic habitat.
     As already discussed, conflict is  fundamental  to the American
form of government.  Federal mandates that apply nationally may be
inefficient  when applied  in some  localized situations.  Yet,  a
strong federal role is often needed to ensure some minimum level
of  environmental  quality  nationwide,   despite  the conflicts or
inefficiencies that may arise.
State Government

     States play a key role administering national clean water and
drinking water programs. Historically, the federal government has
supported this role  with grants  for state program operation. But
the federal budget deficit, continued expectations for maintenance
of base programs,  plus new initiatives  enacted  by  Congress, are
expected  to  pose  serious  funding  problems  for  state  water
administrators within  the next several  years. By  the mid-1990s,
for example, states  could  face an aggregate deficit of some $400
million a year between the cost of clean water and drinking water
programs mandated by Congress  and combined federal and state funds
currently available to administer them.36 Moreover, the demand for
resources to  run  state  clean water  programs will  compete with
equally large demands for funds to administer solid waste and air
quality programs.
September 1990                                                  Page 37

     While the states are being asked to assume more leadership in
water quality programs,  clear accountability and responsibility for
those  programs has  not yet registered  at the  state  level.  The
responsibility  for  these  programs has  not  been matched  by  the
financial  resources  or  political  independence  necessary  to
accomplish the job. In some instances, while states work to improve
their  programs, current controls  are  inadequate  to ensure against
degradation of water quality.
     On the other hand,  in many respects states have not  fully met
their  obligations under Clean Water Act  programs.  For example,
state  water quality  standards have lagged behind  federal  guidance,
leaving  gaps  and other problems  in  state  water programs.  In
addition, state agencies may have  inadequately coordinated policies
and  procedures,   such   as  among  agriculture,   drinking  water,
transportation, health,  and  aquatic habitat protection. Where this
occurs, some  programs can lose effectiveness.
Local  Government

     Local  governments are responsible for delivering clean water
services,   such as  drinking  water,  wastewater  treatment,  and
stormwater  control.  They also assist in implementation of national
programs,   including  wellhead  protection,  the  preservation of
aquatic habitat, and industrial pretreatment.  Wellhead  protection
relies on local data  collection, land use ordinances,  and zoning
controls.  Pretreatment  of  industrial discharges requires local
implementation. Perhaps most important in terms  of  current water
quality programs is the key role that local  governments play in
integrating land use management with water quality protection. But
local  land use  decisions rarely are based on water quality factors,
and water quality gains achieved by  federal and state  regulatory
programs often are offset by development  at the local  level.
      In the  case of  drinking water,  the nation's most  serious
contamination problems are associated with the 13 million private
wells  and 180,000  small public  water suppliers  (serving fewer than
3,300  people  each).37 Yet,  even though a large number of  small
entities are recognized as the source  of the problem, the role for
local   governments,  which  are  closest to  the  problem,  remains
relatively  restrained. This situation  leads to  an underuse of local
land use controls  (a traditional province  of local government),
public education,  and technical assistance.
 September 1990                                                  Page 38

     In the  1970s and 1980s, a  doubling in the number  of local
water  and  sewer  districts  enabled  financing  of  these  services
without  restrictions  imposed  on  municipalities.  Yet  special
districts may not provide the best or most cost-effective services
due to lack of economies of scale.
     Local attainment of  Clean Water Act goals has been impeded,
to a  degree,  by other government programs that may be  based on
sound policy reasoning but  that  have an unintentionally perverse
impact on water  quality.  Over the past eight years, for example,
the U.S. Tax Code has been revised six times to reduce tax abuses
and promote tax equity. While changes have appropriately supported
these goals, each revision  has  further curtailed state and local
ability to meet water infrastructure needs through  the issuance of
tax-exempt bonds and reduced incentives  for the private sector to
finance  such  needs.  Limits  on  tax-exempt  bonds  to  finance
public-purpose,  government-owned water  and sewer  projects plus
other   restrictions  on  tax-exempt  financing  have  increased
significantly the cost of building these facilities.38
The Private Sector

     The private  sector has a pivotal role in (1) complying with
controls for  the  126 priority pollutants and other contaminants;
(2)  preventing  pollution;  (3)   implementing  nonpoint  source
controls;  (4) financing and/or operating assistance for water  and
wastewater infrastructure;  (5) creating new products  (and markets
for products)  in response  to consumer demand;  and (6) educating
consumers  on how  to  use products without impairing water quality.
     The private  role in controlling the release of heavy metals
and organic compounds is self-evident. Some drinking water sources
drawn  from both ground and surface waters have been contaminated
with industrial toxic wastes, representing significant economic,
aesthetic, and human health losses. Reproduction of aquatic species
has also suffered,  as a result—at least in part—of exposure to
industrial toxins, with the nation's  attention now turning to  the
environment, the private sector faces  increased pressure to do more
to reduce  or otherwise control toxic releases into air, water,  and
the land.
     Less  widely  recognized but probably equally  important is  the
private  role  in  controlling runoff.   The  essential  character  of
runoff problems is the  ubiquity of sources, many  of them private.
Agricultural pollution stems from uncountable day-to-day activities

September 1990                                                 Page 39

and management decisions taken by  farmers  as  they interact with
highly  site-specific  conditions  (soil  type,  field  slope)  and
natural  events (rainfall, temperature). The  millions  of private
entities  and  uncontrollable  natural  events  involved  greatly
complicate  the abatement of runoff. Another critical but largely
unassumed private role  is  to  provide the  farm sector with new,
environmentally conscious instructions on  the use of  fertilizers
and pesticides.
     A behind-the-scenes but nonetheless important activity  is the
private  sector's  participation  in financing  or  operating  the
environmental  infrastructure.  While estimates vary  on the exact
sums  involved, almost  all  analysts concur that  future needs to
build and operate water  and wastewater facilities  outstrip current
public   resources  devoted  to   these  purposes.  Historically,
government  fiscal, tax,  and environmental  policies and programs
have  tended   to  discourage  private  participation in facility
construction,  ownership, operation, or management and in assistance
in program  administration. Some view the private sector as a great
untapped resource in these  areas.
     Manufacturers have already  begun to take on  a role  as
proponents   of  "green"  products—products  that  require  less
environmentally  harmful  inputs   for  production,  produce  few
residuals,  and  are  believed  to  be  more  compatible  with  the
environment during  their  useful   lives and  after  disposal.  In
response to a growing  demand  for such products and  increasing
sensitivity to  liability  associated  with waste disposal, some
producers  are beginning to  promote "green" products  in place of
environmentally harmful ones,  at least in  a limited way.
Citizens•  Organizations

      Citizens,   both   as   individuals   and  through   citizens'
organizations,  have a central role  to  play in protecting water
resources. In decisions about facility siting, land use management
and zoning,  transportation,  permitting,  and protecting  natural
resources, the viewpoint of affected communities is critical.

      While  eliminating  these  concerns  entirely  would  be  an
unrealistic goal, a principal  impediment to  forming solutions  to

September 1990                                                  Page 40

today's  water  quality  problems   are  the  many  instances  of
legislative and regulatory overlaps, conflicts, and gaps.

     o  Overlapping statutory  or regulatory controls  as well as
        other policies and programs are inefficient unless they are
        carefully coordinated and work toward the same goal.

     o  Conflicting legislative authorities, policies, and programs
        are potentially counter-productive.

     o  Gaps  in authority,  policies,  and  programs underprotect
        water quality and water-based natural resources.

     The evolution  of water quality  laws from the  1960s to the
present reflects several trends: increasing federal responsibility,
enactment  of new authority  to fill gaps,  increasingly  explicit
requirements for treatment of  toxic levels of metals and organic
compounds,   increased  attention  to   biology,   and  longer  and
more-detailed statutes. As  information available to policymakers
improved,  laws and policies shifted from  abating acute hazards to
preventing chronic low-level hazards.  Instead of focusing on a few
pollutants,  regulators began to address hundreds of  substances of
potential  concern.  The earlier  focus  on single-medium  pollution
problems has begun to shift to  include  inter-media pollutants  that
cycle  from  air,  to land,  to  water.  Similarly,  single-chemical
criteria  are being  supplemented by  whole effluent and ambient
toxicity,  as well  as  ambient  biological  and  physical habitat
     It is not surprising that a patchwork of sometimes  overlapping
and  conflicting legislation has  resulted.  These  inconsistencies
have serious effects.  They often send mixed messages  about which
environmental values  are to be protected and how much protection
will be provided.  For example, similar processes may be required
to  meet  different and  inconsistent  standards  under  different
statutes with the common goal  of protecting groundwater.
Overlapping  Statutory  or Regulatory  Controls

     Overlapping  statutes  or  regulations  can impose  unnecessary
costs  on both the public  and  private sectors—sometimes with  no
net gain in environmental benefits. At least four federal statutes,
for example,  require some  monitoring and reporting on  groundwater

September 1990                                                   Page 41

quality. Fragmented and inconsistent reporting requirements reduce
the overall efficiency and effectiveness of groundwater protection
efforts and may  impose unnecessary  costs.
     Commercial  or industrial facilities are  sometimes required to
report  the same data to,  or  obtain overlapping  permits  from,
several different EPA offices as well as other federal, state, or
local agencies.  The state of Louisiana,  for example, requires that
all dischargers  to surface waters obtain a permit to do  so  from the
state.  But  the  state  does  not   operate  a  federally   approved
discharge permit (NPDES)  program, so all  dischargers have to obtain
an additional  NPDES permit from the EPA for the same discharges.
Currently,  Louisiana's  industries  and  municipalities  pay permit
fees under the state  program, and they could become subject to pay
federal  fees  as well, if EPA institutes an  NPDES fee program as
proposed  in the administration's  Fiscal Year  1991 Budget.  Some
states are also  proposing  fees  for  ambient monitoring programs.
     Too many  regulatory institutions may leave no single agency
really  in  charge.  Many  agencies representing different political
and  programmatic   jurisdictions  are  tasked  with agricultural
pollution   control,   which  creates   difficult   planning   and
communication problems.  Even when interagency planning  does occur,
as was the case  in Section 208 of the Clean Water Act or as is now
the case under Section 319, problems arise.  Because typically one
set  of  agencies does the planning  while  another set  does the
implementing,  program  efforts  often  diverge from the   planning
Conflicting Policies and Programs

      Today's patchwork of laws and rules create the  potential  for
water quality policies to conflict with policies in  other arenas.
By  providing  tax deductibility  for second  home mortgages,  for
example,  the federal tax code promotes the construction  of second
homes,  many of which are  located  in environmentally sensitive or
heavily stressed areas  along the coasts or  adjacent to  mountain
wilderness lands and headwaters.
      Farm policy still works  at odds with water quality  policies
despite the changes  in the  1985  Farm  Bill.  Federal  commodity
programs raise prices above market levels,  which encourages farmers
to  intensify  their use of  program cropland through additional
cultivation, added agrichemicals, and greater irrigation. All these
factors may increase the discharge of nonpoint source pollutants,

September 1990                                                  Page 42

habitat destruction,  and extirpation of  species.  The  design of
current commodity programs also  constrains  farmers from choosing
the  mix of  crops  and  type  of management that  would be  most
environmentally   sound.   Base   acreage   rules  limit   farmers'
flexibility to rotate crops  or to  plant non-program commodities,
even though  these activities might reduce  adverse water quality
     In addition, our national policy of  dredging  to drain lands
and maintain shipping channels along navigable rivers and building
dams for navigation, water supply,  and electric power are at odds
with  both  water  quality  and  aquatic  ecosystem  conservation
policies. Careful planning can mitigate but not eliminate these
adverse  effects.   Without  such  precautions,   resuspension  of
contaminated  sediments  can   pollute  surface  waters.  Improper
placement of such dredged materials in certain land locations can
also  contaminate underlying  groundwater.   Dams, reservoirs,  and
dredging, including inappropriate placement of  any  type  of dredged
material, can  eliminate sensitive  aquatic  habitats,  remove  fish
habitat,  destroy bottom-dwelling communities  in both  freshwater
and marine environments, and  prevent or hinder fish migration.
Gaps  in Authority

      With the vast array of federal, state, and local water quality
statutes  and  programs  described  in  this report,  it  may  seem
surprising  that gaps  still remain in  our regulatory structure.
However,  such gaps do exist.  For  example,  while the Clean Water
Act,  Superfund,  RCRA,  and FIFRA each address distinct aspects  of
groundwater protection,  none  is  designed  for  total   resource
protection.   A  comprehensive  legislative  mandate  to  protect
groundwater does  not  exist.  Instead,  laws  intended  to  protect
drinking water supplies, control specific contaminants and sources,
or clean up aquifers provide a patchwork of groundwater protection
activities.  Protection has been incomplete  in some areas,  such  as
individual  drinking water  wells   (which  are  exempt from  federal
legislation)  and inconsistent in others.  Also no statute provides
for nationally  consistent accounts  to  be  kept  on the  current
condition of groundwater or to relate ground and surface  (fresh and
marine) waters as  an integrated system.
      Current water quality criteria often do not afford adequate
protection  to human health and aquatic life.  Similarly, criteria
are not always developed  for both fresh and marine waters.  More

September 1990                                                   Page 43

effective application of available knowledge would result in better
protection.  However,  establishing  the  comprehensive  chemical,
physical,  and/or  biological  criteria  essential to  protecting
aquatic ecosystems  is  difficult.
     Gaps in treatment of some water problems are attributable to
both the  absence of legislative  attention and to unsatisfactory
implementation  of  existing authorities. For example, even though
they have  been authorized by the Clean Water Act,  the  following
criteria have yet to be published by EPA:

     o  Numeric water  quality criteria  for the full  range of
        pollutants  (not just priority pollutants)  for all uses and
        types of aquatic systems, including human health, aquatic
        life in rivers,  lakes, estuaries,  and marine waters;

     o  Criteria  for  whole  effluent   toxicity  and total  human

     o  Sediment criteria;

     o  Criteria for residues of  toxics in fish and shellfish  that
        address toxicity to these species and to humans who consume

     o  Criteria   for   wildlife   that   use aquatic  systems  and
        biocriteria  for  overall  health  of  aquatic  systems,
        including  wetlands,  estuaries,  freshwater  systems,  and
        marine  waters; and

     o  Groundwater criteria, apart  from public drinking water

     In addition,  effluent guidelines  and standards  authorized by
the Clean  Water Act are  not complete.  According to EPA, four out
of  five  direct industrial discharges  are not covered by current
guidelines  specific to  their industrial category.39 Substantive
stormwater   regulations   and  technology-based   regulations  for
combined sewer  overflows are also lacking. Regulatory programs for
sewage sludge quality  and runoff  controls are still  in development
or only under  consideration.
September 1990                                                   Page 44


     At the  same time  that public  opinion polls  and  political
rhetoric suggest  that  our national commitment to  clean water is
strengthening, appropriations to  administer clean  water programs
are reduced and capital facilities for water pollution control are
under-funded. But the cost of water programs continues to escalate.
According to the EPA, the cost of  simply maintaining today's level
of drinking  water and water quality programs  will increase from
$31.3 billion a year in  1987 to $42.3 billion  by the year 2000.40
Adding the new programs that are currently authorized but not yet
in place  will add  another  $4  billion  a  year by  2000. Devising
efficient solutions to reduce the cost of clean water and healthy
ecosystems, paying the remaining costs,  and allocating funds among
competing environmental investments are among today's most critical
water quality issues for government  and the private sector.  Who
pays and how much become even more critical in light of equal or
greater demands on  limited  budgets placed by other environmental
needs such  as management of air  quality  or hazardous  and solid
     The  federal  government  is   clearly  withdrawing  from  its
historically prominent position as financier of water programs. In
dollars of constant purchasing  power,  EPA's water quality budget
in 1990 is one-third lower than its 1980 budget. EPA's 1990 support
for building wastewater treatment facilities  is almost half the
1980 level.  This  support will be eliminated entirely after 1994.
     One  might   argue   that  federal   financial  devolution  is
appropriate  because the prominent federal  role  of the  1970s and
1980s is  giving way to state and  local dominance  as the federal
government increasingly delegates  programs to the states. But this
decline  in  purchasing power  has occurred simultaneously with
increased    national   water   quality   mandates   and   program
responsibilities.  Imbalances  between mandates and funding could
grow more serious as the federal deficit continues  and as emerging
areas of concern are addressed. These areas include  aquatic habitat
protection,  nonpoint  source  control,  groundwater  protection,
control of toxic pollutants, and stormwater/combined sewer overflow
     State water quality and drinking water budgets are  also under
strain, caused  in large  part by the  withdrawal of federal grants
and  the new requirements  for  administering  water  quality  and
drinking water programs authorized in the  late  1980s. Estimates of
the gap between program needs and  available funds by the mid-1990s

September 1990                                                  Page 45

range  between $250 million and  $500  million a year. EPA's State
Funding Study addressed this  concern  and concluded that  increased
funding at both the state and federal levels would be necessary to
raise water programs to levels contemplated under current  policies.
     Local  governments are expected  to feel the full effects of
federal withdrawal as the transition from construction  grants to
State  Revolving Loan  Funds to  build local wastewater  treatment
plants   is   completed  in   the  mid-1990s.  Even   under  full
appropriations, which  has not yet occurred since  authorized levels
were established  in 1987,  combined EPA assistance to build local
treatment plants  would fall at least $1 billion short in each of
17  states.41 To meet the discharge limitations established in the
Clean Water Act, localities in these states will face  unprecedented
increases in local user fees  and capital formation requirements.
     Limited financial  resources also may limit  protection  of
aquatic resources  by all levels  of government. Current methods to
assess  the  economic  value  of  water resource functions  that
emphasize production of commodities,  for example, do not allow an
aquatic ecosystem  in its natural state to  be favorably compared in
terms  of  dollars  to  a  project  that  would  alter the system for
direct human use.  As  a  result,  all  types  of programs to protect
aquatic ecosystems may be underfunded. Advances in  environmental
economics and ethics  are likely to alter societal views in these
     Resources  for runoff control programs  also are limited.  To
date,  spending on polluted  runoff  generally,  and  agricultural
pollution specifically,  has been dwarfed in comparison to spending
on  point  sources. There  may  have   been  a time  when  this  was
justified,   but   as   polluted  runoff   increases   in  relative
significance nationwide,  the  justification  is fading.  Stated
simply, the  lack of funding for runoff control  programs has become
a  fundamental  impediment  to accomplishing  real gains  in water
     The private  sector cost of clean water is  substantial--just
over $13  billion  a year in  1989 for water quality and drinking
water.  As new regulations are  phased in,  costs are expected to
increase substantially.  A common assumption is that the private
sector  simply passes  the  cost  of pollution  control on  to the
consumer as  increased  prices  for goods or services.   But  in a weak
domestic  economy  or   in the face  of  price competition  on the
international market,  such price increases may be possible only at
the expense  of slower  sales, reduced market share, cutbacks in the
labor force,  or some combination.  Moreover, raising the funds to

September 1990                                                  Page 46

invest in pollution control  facilities may  be difficult for some
small or marginal businesses.
     Many  economic incentives  that could  encourage public  and
private investment capital  for funding  improvements  in drinking
water supply  and  wastevater  treatment  are no  longer available.
This has  significantly increased the  cost  of  capital  for these
     Not only are pollution control funds limited, but so are funds
to  adequately  monitor  the  environmental  effects  of  control
programs. State and federal monitoring is inadequate for unbiased
estimates of waterbody quality,  from which to  better decide how to
allocate limited control funds.  Our ignorance  of status  and trends
also prevents us  from educating the public about related risks.

     Clean water is a public good whose protection requires public
control, which, in turn, requires adequate human resources assets
to be effective. Assuring progress toward achieving national water
quality  goals will  require a  continued influx  of  sufficiently
trained,  adequately paid  professionals. According  to  a recent
review  of the  demand  for  engineers,  for example,  the American
Society   of  Civil  Engineers  concluded  that  the   need  for
environmental engineers will grow more rapidly than for any other
engineering  discipline through the  turn of the  century.42 Since
1980, the number of Americans employed in science and engineering
has risen twice as fast as employment in general.43 Yet,  in a number
of  industrialized nations, the percentage  of total  labor force
trained  in  science and engineering  is growing faster than in the
     In  some water  disciplines,  the gap between supply of new
professionals and  demand for their  skills  is particularly wide.
Demand for  environmental  engineers,  for example,  is greater than
supply  by  a factor  of  two  or  three.44 Groundwater  pollution
specialists  are in even  shorter supply.  Nearly 40 percent of the
chemists and engineers constituting today's scientific work force
will be eligible for retirement within the next five years.45
     Professional education—both academic training and continuing
education—must provide more opportunities to build the skills and
experience   needed   for  national  clean water  programs.  After
examining demographic  data and historic trends,  for example, one
recent  study concluded  that a cumulative  shortfall  of several

September 1990                                                   Page 47

hundred  thousand scientists  and engineers at  the baccalaureate
level might develop by  2000.** That  shortfall could translate into
an  annual supply-demand  gap  of several  thousand  scientists and
engineers  at  the Ph.D.  level,  with the shortage persisting well
into the  21st  century.  Such a trend in science and engineering as
a  whole  suggests  that  we  examine  salaries  for  positions  in
government clean water programs with an eye to how they meet the
competition. At  today's rates, government may be unable to attract
and retain skilled employees. High  turnover rates may  result, as
public employees leave  government for better paying industry jobs.
     Strong  leadership is needed from our  academic  institutions,
the professional community, political institutions,  and the media
to  turn  around the recent  decline  in federally  supported student
stipends.  The  number  of  federally  funded  graduate stipends
 (fellowships,  traineeships, and research assistantships) declined
from  80,000  in   1969  to 49,000 in 1989.47   Declining levels of
support,  however, may be only part of the problem.  Scientists and
engineers apparently do not put much effort into communicating the
values  that  make science  attractive. With world-class research
 facilities on college campuses across America, why do few research
professors pay  attention to  teacher training  programs at their
universities or, indeed, why do so  few willingly sacrifice  even  a
 small percentage of their budget to improve  such training programs?
      Current academic programs have limited access to the growing
 knowledge base  that  constitutes  the  foundation  of clean water
 programs and do not integrate it well into the curriculum. Natural
 resource managers, lawyers,  economists,  and  civil  engineers need
 a skills base that goes beyond the traditional  training of these
 disciplines.  Natural resource management requires staff trained in
 biology,   natural   resources,  water  quality,   environmental
 engineering,  cost planning, recreation, urban development and land
 use,  geographic analysis,  sociology,  and public relations. It  is
 no longer sufficient to train one  group of  engineers to  produce
 products and another group to clean up after them. And, considering
 the high visibility that most environmental issues receive in the
 eyes  of  the  public,  environmental  leaders   also  must  posses
 effective written and verbal communications skills  and  have a keen
 understanding of the impact of problems and solutions on society.48
      But  academic training   by  itself  will  not  necessarily  be
 sufficient to address tomorrow's  water quality problems,   such as
 controlling contaminated runoff. Failure of past control programs
 stem, in part,  from lack of perspective on the real  long-term goal
 of water  resource protection and a failure to train professionals

 September 1990                                                  Pa8e **

to work with individual citizens. As the nation turns its attention
to controlling  contaminated runoff,  planners  will be  needed to
develop land use  regulations that  are sensitive to water quality
issues. Too few agricultural specialists and farm advisors are now
adequately trained in the effects of farming on water resources and
in  techniques  to  reduce  these  effects.   In addition,  these
personnel may have inadequate training or resources to communicate
water resource  concerns to  the  broader public.   Few programs are
in place  to  educate consumers  about safe use and  disposal of
agricultural  chemicals,  and there  are too few efforts to train
dealers,  distributors,   and farmers   in  the   safe handling  and
efficient use of  agricultural chemicals and fertilizers, manures,
and other nutrients.
     Public  policy  managers must be trained  to understand social
values  underlying societal  origins of water  quality problems and
risk assessments to establish priorities. They must also be trained
to evaluate the costs and  benefits of alternative approaches to
improve water  quality  and  to  assess regional aspects of water
resources.  Enforcement  of  regulatory programs requires standards
that  are  ecologically  sound and  that will  hold  up  under court
challenges.  Therefore,  managers  will need expertise to resolve
legal difficulties related to scientific uncertainty behind control

     Although  ecological knowledge  relevant to the  solution  of
water  resource problems  is often limited, careful application  of
existing  knowledge by water resource professionals would  improve
the  condition of  those  resources.  At  the same  time,   current
research  and development programs are not keeping pace with demands
for scientific information. All too frequently, decisionmakers rely
on best professional  judgment instead of  empirical  information. A
limited national  research and development (R&D) effort  is  part  of
the  problem. While in dollar terms  the  total U.S.  effort  is the
largest in the world, Japan and Germany each invest  more in R&D  as
a percentage of their gross national product (GNP) than we do, and
other  countries equal  our current rate.49
     EPA's Science Advisory Board reported that the Agency's 1991
budget request for its Office of Research and Development— barely
sufficient to keep up with inflation compared to 1990 and  lower  in
terms  of  constant  purchasing   power than  in  1980—• is   grossly

September 1990                                                   Page 49

inadequate. The Science Advisory Board predicts  the  Agency will
face difficulties  attracting the kind of talent needed to replace
an aging scientific work force.50
     Policy  decisions  concerning  dredging  for  navigation,  as
mentioned  earlier, often  suffer  from a  lack of  sound economic
evaluation methods and a limited  understanding of the nature and
magnitude of  contaminated  sediments.  Managers cannot  discern the
best alternatives  because there is  insufficient  research on the
concentration  and  toxicity of contaminants  in sediments and the
bioavailability of potential contaminants to marine organisms.
     similarly,  much  remains unknown  about  health  effects  of
treated waters or pesticide contamination  of  ground  and surface
waters. Insufficient data are available on long-term health effects
of some pesticides, the risks of pesticide breakdown products, and
the potential  health effects  of exposure to multiple pesticides,
before decisions are made to  register pesticides  for  use. Nor do
we know enough  about actual pesticide use patterns and the amounts
of pesticide residues getting into surface and ground waters under
these use  patterns.  We also lack detailed  information—notably a
reliable, comprehensive database on pesticide  use—to enable full
understanding  of the amount of specific pollutants attributable to
different  sources  in agricultural runoff. In addition,  a greater
understanding   of  soil-water-plant  relationships  is   needed  to
develop improved management practices.
     Although  some stream  and  lake restoration projects have been
successful,  current technological solutions simply are  incapable
of filling the gaps  produced by ecosystem degradation.  It remains
unclear whether creation or restoration of wetlands are technically
or scientifically feasible. Hence,  restoration of many types of
wetlands remains  in the experimental  stages.
     Technology development   is  needed  for  new cost-effective
procedures  and equipment to  detect and remove  contaminants in
drinking  water.   Problems  arise  because regulations  often are
written ahead of needed research and technological  development and,
at the same  time,  federal  R&D  funding is limited.  In addition, in
the water  supply  industry few market incentives exist for private
sector technology  development.
     The   nature  and  magnitude  of  atmospheric  transport  of
pollutants  is  an  area  lacking sufficient research. For  example,
even  as atmospheric deposition,   runoff,  and  leaching of  toxic
metals  into  surface water and organic compounds  into groundwater
are widely recognized as areas of concern,  most research programs
fail to address them.
September 1990                                                   Page 50

     As well,  complex water quality  issues such  as  cross-media
effects and the  cumulative impacts of human activities  on water
quality receive too little attention.
     Finally,   past  government  research and  development  policies
have focused almost exclusively  on end-of-pipe  or other types of
pollution  controls. In comparison, preventing  the generation of
pollutants  in  the first place  has earned too  little government
funding. The lack of scientific information is one of the principal
impediments to making the transition from end-of-pipe controls to
source  reduction. Many who might  otherwise  choose to reduce the
generation of waste or consumption of water simply lack information
on the means to do so. That is,  industries may be unfamiliar with
the notion  that  improved process design and operation could help
them  use inputs  more efficiently  and  generate  less  waste.  One
reason for this information lag is that  our traditional regulatory
programs  have not yet  elevated source  reduction on a  par with
treatment technologies.

     We  can point  to some success  in public commitment in the
growing  numbers of  environmentally literate citizens who  push the
professional  community,  public  agencies,   and   industry toward
policies and programs for cleaner waters. On the other hand, a vast
public  also exists that  is uneducated or  misinformed about the
relationship between  clean water and a healthy economy.  While  it
is  popular  to assume  that a healthy  economy cannot coexist with a
healthy  environment,   it  can and  must.  The  environment  and the
economy  are not necessarily at odds.
     The  public   generally   receives  effective  communication
concerning   water  quality  crises.   In   contrast,   when   water
professionals  deliver satisfactory services, they receive little
recognition.  As  infrastructure  to  the  economy and community
well-being, water and waste services remain in the background. The
public  should expect  adequate quantities  of safe drinking  water
and pollution-free streams.  At  the  same  time, water  quality
personnel   do  not  do  an  adequate  job   of communicating the
difficulties  in achieving those  goals.
     Partially  because   of   our   failure  to   communicate the
relationship  between  human activities and  degradation  of  water
resources,  the public  does not  feel responsible for  its actions
that affect water quality. Ordinary citizens remain largely unaware

September 1990                                                   Page 51

of what  they can do  to improve water quality or  to reduce use.
Communicating to citizens and private industry that they must take
greater responsibility for the wastes they produce directly and for
the  wastes  produced  as  a  result  of  their  consumption  of
manufactured products has not been given enough priority. Industry
and consumers have little understanding that wastes can be used as
a  resource  without  negatively  affecting  human  health or  the
environment. Since traditional market mechanisms do not include the
environmental   cost  of  producing  certain  goods,   alternative
mechanisms are needed to tell citizens how their choices affect the
     Not applying ecological knowledge, described earlier, hinders
effective  communication about  water  quality  issues   and best
management practices  to minimize adverse water quality impacts.
     Private  commercial  interests  also sometimes tend  to limit
communications  that would further environmental  gains. Industrial
and  commercial competition nay  preclude  companies  from sharing
information about manufacturing processes that are  environmentally
     Consumers  and producers  are generally unaware  of how their
choices  can affect water quality.  Few consumers understand that
their  preference  for  unblemished fruit  may lead  to   increased
pesticide runoff and  concentration in game fish and water  supplies.
     The American public is also generally  unaware of  the true
costs  of ensuring  a  safe  and  uninterrupted  supply  of water for
drinking. When systems are financed from general  taxes, the true
cost  of drinking  water is hidden  from  the consumers.  Even when
homes  and industries  are metered and charged according to use, many
drinking water  systems charge  less  than  full  cost of service,
making  up  the  difference with  general  revenues.  As  explained
earlier, the perception that safe tap water  is  a  cheap  commodity
may be on a collision course with budgetary and regulatory trends.
     Another reason  for deficiencies  in public understanding  of
aquatic  resources  is that  education  programs  from kindergarten
through  college have  failed to stress the value of these  resources
and  the dependency  of humans  on  a  self-sustaining, healthy
ecosystem.  As  a  result,  even educated  people  lack sufficient
understanding of the nature of the environment,  the  environment's
fragility,  society's impact  on  the  environment,  and  even more
directly, the consequences  of individual actions such as lawn care,
home car-care,  or disposal  of household chemicals.  One of the areas
least  understood by  the public is the functional value of  natural
aquatic ecosystems.  Few understand  that these  ecosystems  provide

September 1990                                                   Page 52

flood   control,   water    quality   enhancement,    recreational
opportunities,  fish  and wildlife  habitat,  groundwater recharge,
shoreline protection, water storage, and natural green belts with
aesthetic value.
     In  many  respects  today,   we  lack  a  clearly  articulated
environmental  ethic  that  would  enable  us  to  value  natural
ecosystems for their own sake.   This is an impediment to resolving
water resources problems because it makes it difficult to balance
the values of natural systems against other societal priorities.

     Water Quality 2000 has identified many impediments to solving
our water quality problems. Many of these center on defects  in the
programs  and policies  currently  in  place.  Others  result from
inadequate  resources  devoted  to  the  problems—low levels  of
funding, inadequate application of existing knowledge,  insufficient
research and development efforts, and the potential for a personnel
shortage. Nor does the public sufficiently understand  factors that
impair water quality or the growing threats to the availability of
clean, abundant water.
September 1990                                                   Page S3


     As this report explains, the root causes of many water quality
problems are the activities of our society.  As we begin to address
these root  causes,  it will be necessary to think carefully about
the dual pursuit of water quality and societal goals. Disagreements
will arise  concerning the  relative  importance of water resource
quality as compared with other social,  environmental, and economic
goals.  Yet initiating the debate over compatibility of  these goals
is critical to  improving the condition  of the nation's waters and
aquatic resources.
     Hater  Quality 2000 has concluded that the results of public
and private efforts to control sources of impairment and generally
improve the quality of waters and aquatic ecosystems over the years
have been mixed.  Some problems have  been solved,  others await the
results of programs only  recently put in place, while still others
remain challenges for the future.
     A major  challenge facing water  managers will be to convey to
the public a clear picture of what constitutes our water resources
and the real risks we face as a result of their degradation, their
interconnectedness with  other  parts  of the environment,  and how
natural and human activities may affect water quality.
     Recognizing a longer-term  goal  of moving the water quality
debate toward the root causes of  impairment, the pages  that follow
present Water Quality 2000's assessment of  the key  emerging near-
term issues concerning water quality.

      Where there has been a sufficient economic incentive to do so,
 industry generally  has improved the  efficiency  of  manufacturing
 processes and hence prevented pollution.  But only  recently  have
 government  and  industry  turned  their attention  to  preventing
 pollution in the name of environmental protection  as an alternative
 to disposing waste once it has been generated.
      Heightened attention to pollution prevention is due, in part,
 to the  increasing  costs  of pollution control  attributable  to
 traditional forms of regulation and, in part,  to a more fundamental
 rethinking   of   the  other   economic  advantages   of  pollution
 prevention.  As  a  rule,  those  who promote  pollution prevention
 advocate  a  hierarchy of  alternatives   whereby   reducing  the
 generation of waste would take precedence over recycling or reusing

 September 1990                                                  Page 54

waste once  generated. In  turn,  recycling  and reuse would  take
precedence  over waste treatment.  Only after  these options  are
exhausted would the remaining residuals be disposed of as wastes.
     The impediments to implementing these principles include:

     o  a lack of economic and/or regulatory incentives to change
        current waste management practices;

     o  inability  to  access  information  on  how  to  prevent

     o  a lack  of willingness  to overcome the inertia from years
        of  conducting  business  without  explicit  concern  for
        pollution prevention; and

     o  physical  inability  to  add  technology  or  make process
        changes that would result in less pollution.

     Our challenge is to better understand the impediments standing
in the way  of pollution prevention and to promote adoption of the
hierarchy stated above in ways  that are technologically acceptable
and economically feasible.
     The pages that follow present Water Quality  2000's assessment
of the key  emerging issues concerning water quality.

     Largely because many of our past efforts have addressed point
sources,  controlling runoff from farms and  urban  centers in  the
future is likely to be far more important to improved water quality
than, say, removing  the final  5 to 10 percent of pollutants  from
domestic  sewage.  EPA studies have found  that,  since  most of  the
conventional  pollutants  have  been  removed  from  domestic   and
industrial wastewaters,  runoff  from urban and rural lands is  the
predominant cause of water quality impairment in more than half the
nation's  rivers and  streams. Controlling  runoff poses significant
challenges to conventional pollution control strategies,  given the
diversity of  human  activities  on  the land  and  the direct
relationship  between  land  use  and the  contamination of runoff.
Agricultural  runoff,  which contains  priority  constituents  and
excess  nutrients, is widely dispersed  over  the  landscape.  The
practice  of applying fertilizers and pesticides in amounts greater

September 1990                                                   Page 55

than the ecosystem can assimilate is a basic impediment to control.
Developing  and  implementing land  use management  measures  that
prevent  or reduce  impairment rather  than mitigate it  after it
occurs is a major challenge.

     We  face  major  technological  and  economic  challenges  in
preventing  the  generation  of  toxic  constituents  in  the first
instance—both toxic wastes and products that may be toxic in their
own  right.  In addition,  we  face challenges in improving  current
end-of-pipe control technologies. Tomorrow's water quality problems
are  more likely  to center  on  toxics,  including metals,  organic
compounds,   and   radioactive   constituents  than  they  are  on
conventional  pollutants.  While  guidelines limiting  concentrations
of toxics in point sources were put in place between 1977 and 1989,
control  of toxic pollutants in discharges is  only now  gaining
momentum.  Many  more  toxic  compounds  found  in  waterbodies  are
released  with no  control at all.  Water quality professionals  are
only just beginning to seriously consider how to deal with locally
contaminated  sediments and  the  buildup of  toxic  metals  and other
compounds  from unchecked discharges and runoff of past decades.
Moreover,  a significant  source  of toxics  in water  is atmospheric
deposition.  Controlling  these  sources implies strengthened  air
toxics regulations.  Compared  to  toxic releases  to  water, toxic
discharges to air have been underregulated at the federal level and
inconsistently regulated by individual states under federal  and
state  authorities.
     Given recent advances  in  our ability to  detect toxic metals
and  organic compounds in minute amounts, the policy challenge for
future control of toxics is  a better understanding of the risks to
health and ecosystems of toxics in trace amounts.

      Many aquatic ecosystems have been degraded or destroyed by a
 broad  range  of  human  activities,  including  construction  of
 residential   subdivisions,   new   transportation  systems,   and
 recreational developments.  These  physical  losses result in fewer
 benefits  from aquatic  resources,  such  as flood  control,  water
 quality enhancement, timber  and forage production, recreation, fish

 September 1990                                                  Page 56

and wildlife habitat, groundwater recharge, shoreline protection,
water  storage,  and  natural  greenbelts.  Although  considerable
knowledge  of  the  local  impacts of  human  activities  exists,
documentation  is  not available on cumulative  degradation across
regions.  Locally,  urbanization,  agriculture,   silviculture,  and
grazing have greatly reduced the integrity of the landscape. These
activities have altered the transport of water,  soil, and chemicals
to receiving waters and degraded essential aquatic and terrestrial
habitat.   Nationwide,  habitat loss and  declining  fisheries also
result from municipal,  industrial, and agricultural activities, and
various water development projects. Ambient biological monitoring
has been  underused to assess the extent to  which  regulatory and
other efforts have had the desired effect in improving the quality
of  water resources.  Our future  policy  challenge  is  to prevent
further degradation of aquatic habitat  and  find ways to restore
losses of past decades.

     Study  after study  demonstrates that  air, water,  and  land
resources are  interconnected. Yet cross-media controls constitute
one of the greatest remaining challenges of pollution control.  Ten
to  15  percent  of the nitrogen  entering Long  Island Sound,  for
example, and as much as half the PCBs entering the  Great  Lakes may
come from airborne  emissions.51' 5Z Concentrating contaminants  from
wastewaters  in treatment  sludges and disposing them on  or  in the
land may simply transfer  pollution  from surface to ground waters.
     Hater quality planning in the past often has been ineffective
when based on political boundaries rather than watersheds or other
appropriate  geographic scales.  A policy challenge is to find the
broad  perspective   necessary  to  achieve  effective   ecosystem
protection on  a rational  geographic basis.

     Significant gaps exist in comprehensive resource  protection
 for  groundwater. Yet groundwater is the repository of  most  human
 activities in and on the land  such  as  farming, manufacturing,  and
 transporting goods  and people.  Failed septic  systems,  leaking
 underground  storage  tanks,  improper  well  construction,   and
 infiltration from surface spills and  runoff also are  sources of

 September 1990                                                  Page 57

concern. According to surveys conducted by  EPA,  for example,  47
pesticides have been  detected  in groundwater in one or more wells
in 26 states  as  a consequence of normal agricultural practices.
It   is   questionable  whether  current  groundwater  protection
authorities and  programs will be sufficient to ensure the future
safety of drinking water drawn from the ground.  The challenge is
to pursue a nationally consistent level of groundwater protection
that  respects  ongoing  local  protection  activities and  allows
locally efficient solutions  to operate.

      In  contrast to the hundreds of billions of dollars spent on
facilities to remove pollutants before they  enter the nation's
waterways,   relatively  little  has  been  spent  to improve  our
understanding of the effects of pollution on humans and ecosystems
at all levels of concentration. Credible measures of environmental
results  are largely  unavailable. The  effectiveness of many types
of control measures has not been evaluated. A  basic understanding
of  the  values  of  aquatic ecosystems  is  lacking, as is  a  full
understanding of the cumulative effects  of  human activities on
these systems.
      Advanced methods to measure metals and organic contaminants
in minute concentrations makes them easy  to find  in most  surface
and  ground waters.  But views  conflict on the significance of
on-going,  low-level  toxic contamination  on human health or the
environment  and on  the cost-effectiveness of controlling  such
contamination at the outer  limits  of  detection. The challenge we
face is to  improve  our understanding  of the significance of
contamination and  the effectiveness of cleanup programs  through
improved sampling, testing for pollutants, and monitoring  for the
effects  of point sources and runoff.  This is  impeded by the  lack
of effective ecological monitoring  programs for aquatic resources.

      Until recently,  the by-products of industry,  commerce,  and
 everyday life have been treated largely as waste. Disposal of these
 by-products has put  pressure on the quality  of the nation's surface
 and ground waters. But as society has begun to increase the value
 it places on  clean  water resources,  institutions  and individuals

 September 1990                                                  Page 58

alike are  finding  new ways to use residuals productively,  rather
than dispose of them  on the land or  in the water.
     Similarly, because  supplies generally  have been  plentiful,
Americans  have grown used  to  low  prices  for  water  with  the
predictable  effect of excessive  rates of use.  In Europe,  where
water generally  is scarcer than  it is in the U.S., the  average
household  pays roughly twice  the average U.S.. price  for drinking
water and  uses roughly half as much  as we do in  this country.54
     A reduction in  the  quantity of clean water results directly
from unwise use of  resources. At some point, the higher prices that
must be  paid to  cleanse water of  residuals  disposed in it could
have a negative effect on lifestyles and dampen economic activity.
The challenge for  the future is to  find ways of  keeping materials
cycling through the economy rather than allowing them to escape as

     Disagreements over the most important water quality problems
hinder setting national priorities.  Moreover,  disagreements as to
the  relative importance  of  water quality problems versus other
environmental  issues also exist.  At the  heart  of many  of these
differences  are  different perspectives on the criteria  one might
use  to  set  environmental  standards,  agree  on priorities,  and
allocate  resources.
     EPA's Unfinished Business: A Comparative Assessment of Environmental Problems found,
among other  things,  that  one  alternative way to set priorities is
on the  basis of relative risk.  Using risk to set  priorities may
require a deeper understanding of both risk assessment and risk management--
two  distinct   concepts.   Risk  assessment   is   the   science  of
determining  what level of risk is posed by a given activity, such
as the  risk  of cancer from exposure to  a  toxic  pollutant in food
or water. While the validity of various risk assessment methods is
hotly debated, this is largely limited to scientific dispute.  Risk
management,  on the  other hand,  involves  extremely controversial
policy  issues such  as what  level  of  risk  is  "acceptable"  for
various  activities  as well as the feasibility  of  success within
specified time frames or  resource limitations. Opinions vary from
those  that  argue   that  no   risk  from  chemical  pollution  is
acceptable,  to those who  point to the necessity of balancing risk
to  human  and ecosystem  health against  the economic   costs  of
September 1990                                                   Page 59

reducing risk. Most agree,  however,  that both regulators and the
public need to achieve  a better understanding of risk assessment.
     Even   if   scientists   and  policymakers   improve   their
understanding  of these  issues, there  may be little agreement on
which kind of risk should be reduced. In Unfinished Business, for example,
EPA  identified  four kinds  of risk.  The  first  two  focused on
relative risk  to human health, including cancer health risks and
non-cancer  health  risks.  Some  decisionmakers  might  prefer to
minimize these risks.
     But EPA also found that there are two other measures of risk:
the   risk  of   ecological   losses,   such  as   elimination  of
environmentally  sensitive species, and the risk  of  welfare losses,
such  as reduced  opportunities for recreation  or  declining  land
values adjacent  to  polluted bodies of  water.
     Moreover,  some would  argue  that setting  priorities  on the
basis of any kind of comparative risk is unwise.  Neither public nor
regulatory  agencies, they  argue, have sufficient  information to
understand  fully human health risks or  risks  to  ecosystems. In
addition,  risk  assessment  is resource  intensive  and  may  be an
inefficient use  of  limited  public resources.
     Our challenge  is to improve our understanding of whether and
to what extent risk analysis can contribute to priority setting or
whether,  for example,  environmental priorities might be better
established   based  on  whole   ecosystem  effects,   including
consideration  of all environmental media.

     The  relationship  between  water quality  and water quantity
suggests that  much of our activity designed to improve the quality
of surface and ground waters will benefit drinking water supplies.
For example, better planning to protect watersheds will ultimately
reduce the cost to treat drinking water. Yet many issues regarding
the  provision of  safe  drinking water  remain  unresolved.   For
example,  much  of the  cost of  treating  water  to the standards
required in the Safe Drinking Hater Act is currently shouldered by
users—who are not  necessarily  the ones responsible for polluting
drinking water sources.
     In addition, the  expanded drinking water regulatory program
presents a significant  infrastructure problem, especially to small
communities. These  small systems generally have much higher costs
of service because they lack the economies  of scale needed to bring

September 1990                                                  Page 60

treatment  costs  down. They also  generally  lack the  management
expertise   to  assure   problem-free   operation  of   relatively
sophisticated treatment  works or, indeed, to  establish adequate
pricing or billing systems. Moreover,  small communities generally
pay higher capital costs to borrow funds to build treatment works
because they  are unknown to most lenders and buyers of municipal
bonds. In addition, some communities cannot afford the high fixed
costs of borrowing through the bond market.
     Our challenge, therefore,  is to  acknowledge the benefits of
high-quality  drinking  water,  protect  water  supplies,  develop
technologies  that deliver  such  supplies  without  harming other
media, price  the delivery  of this resource to adequately reflect
its value, and assure that all communities have access to and can
pay for equally high-quality drinking water.

     In many areas across the nation,  urban and suburban sprawl is
replacing  forests,  agricultural  lands,  and  coastal and  other
natural areas at an alarming rate.  Sprawling development increases
surface areas exposed to disturbance, increasing storm water runoff
and  sedimentation and aggravating  the risks  of  failed septic
systems that pollute ground and surface waters.  Such development
forces the  use of automobiles for most  aspects  of daily living,
leading  to  increased  highway development  and causing more air
pollution.  The challenge we face is to manage and control growth
in  a way that respects watershed  integrity and  minimizes both
direct and cumulative  impacts of water quality.

     Central to all these water quality and resource  issues is the
question of funding.  Finding adequate resources for water programs
may be considerably more difficult in the  future than it has been
in the past.  The dimensions of our funding challenge include:

     o  Securing sources of funds from public  and private sectors;

     o  Allocating  funds among competing  environmental controls
        and monitoring of media;
September 1990                                                   Page 61

     o   Managing funds  effectively to address the  full range of
        water quality problems; and

     o   Evaluating the  effects of  funding programs  in terms of
        public health and environmental results.
September 1990

                        V.  THE NEXT STEP

     This report, which concludes Phase II of Water Quality 2000's
work, contains findings regarding current and future water quality
problems as articulated  in the  reports of  ten  work groups and in
the deliberations of Water Quality  2000's  Steering Committee and
Member Congress.  Water quality professionals  from  all  levels of
government, academia,  industry, the professional  community, and
environmental interest groups contributed to these deliberations.
     This report has presented a profile of the current condition
of  the  nation's  water resources.  It  has  described  the sources
currently  impacting these resources and  the  importance  of each
relative  to  total  impairment.  Both   causes  of  pollution and
impediments to  improving the physical, chemical,  and biological
integrity of the nation's waters have been discussed in detail. The
report has characterized the root causes of water quality problems
emanating from the fabric of our society. Impediments to solutions,
in  comparison,  generally have been  attributed to inadequacies of
current water policies or programs.
     As water quality professionals  representing all perspectives,
the contributors  to this report feel confident that it presents  a
balanced description of today's key  water quality problems.  We are
confident that  these conclusions will  stand as a sound foundation
for the formulation of solutions in  the next phase  of  our work. We
eagerly  look  forward to  Phase  III  of  our project and extend an
invitation  to  all who wish to  contribute  to  a continuing  debate
over solutions  to support Water Quality 2000.
September 1990                                                   Page 63


1.   U.S.  Environmental Protection Agency, National Groundwater Supply Survey,
     Office of Drinking Water, June 1982.

2.   National Council  on  Public Works  Improvement, Frayte Foundations: A
     Report on America's Public Works, February 1988.

3.   U.S.  Environmental Protection Agency, Environmental Investments: The Costs
     of A Clean Environment,  (forthcoming 1990) .

4.   U.S.  Environmental Protection Agency, National Water Quality Inventory, 1988
     Report to Congress,  Office of Water,  March 1990.

5.   U.S.  Environmental Protection Agency, Toxic Release Inventory.

6.   U.S.  Environmental Protection Agency, National Survey, March 1988.

7.   U.S.  Environmental Protection Agency, National Water Qualify Inventory, 1988
     Report to Congress,  Office of Water,  March 1990.

8.   Judy, R.D., Jr.,  et  al.  1984. 1982. National Fisheries Survey, Vol. I.,
     "Technical Report: Initial Findings." FWS/OBS-84/06. U.S.  Fish
     and Wildlife  Service, Washington,  D.C.

9.   Miller,  R.R.,  et al.  1989.   "Extinctions of  North American
     Fishes During the Past Century,"  Fisheries (Bethesda)  14:22-38.

10.  U.S.   Geological  Survey,  Testimony before House Public Works
     and Environment Committee, April  25, 1990.

11.  U.S.  Environmental Protection Agency, National Croundwater Supply Survey,
     Office of  Drinking Water, June 1982.

12.  There is   some  controversy  regarding  the  definition  of
     wetlands.  According  to  federal  regulations,   an  area  is
      considered a wetland  if  it has certain soil, hydrologic, and
      biological conditions.  In contrast,  many define wetlands  as
     marshes,   swamps,  bogs,  and  similar  wet   areas  that  are
      transitional between  open water  and dry land  (uplands). The
      second definition would exclude many areas considered wetlands
      under federal regulations.

September 1990                                                     Page 64

13.  U.S.  Fish and Wildlife Service, Wetland Lasses in the United States, 1970s to
     1980s, A  Report to Congress,   U.S.   Department   of  the  Interior,
     Washington, D.C.,  July 1990.

14.  Williams,  J.E.  et  al.  1989.   "Fishes  of  North  America-
     Endangered,   Threatened,   or   of   Special  Concern,"   Fisheries
      (Bethesda) 14:2-20.

15.  Ebel, W.J. et al. 1979. "The Columbia River: Toward  a  Holistic
     Understanding." Pages  205-19 in D.P. Dodge,  ed. Proceedings
     of the International Large Rivers Symposium. Canadian Special
     Publication of Fish and Aquatic Sciences.

16.  Sport  Fishing  Institute,  Aquatic Contaminants: A Threat to the  Sport Fishing
     Industry,  Washington, D.C.,  1986.

17.  U.S.  Environmental Protection Agency, National Water Quality Inventory, 1988
     Report to Congress t  Office of Water, March 1990.

18.  Congressional Budget Office, Environmental Regulation and Economic Efficiency,
     March 1985.

19.  U.S.  Bureau of the Census,  Government Finances Series, various

20.  Environmental Protection Agency, 1988 Needs Survey,  Office of Water,
      February  1989.

21.  U.S.  Environmental Protection Agency, A Preliminary Analysis of Public Costs
     of Environmental Protection:1981-2000,   Office   of   Administration  and
      Resources Management,  May  1990.

22.  U.S.    Environmental   Protection  Agency,   State Funding Study-Draft
     Recommendations,  Office of Water,  1989.

23.   U.S. Environmental Protection Agency,  1988 Needs Survey, Office  of
      Water,  February 1989.

24.   National  Council  on Public  Works  Improvement,  Fragile Foundations,
      February  1988.
September 1990                                                       Page 65

25.  U.S.  Environmental Protection Agency,  National Water Quality Inventory, 1988
     Report to Congress,  Office  of Water,  March 1990.

26.  U.S.   Department  of  Health  and  Human  Services,  Evaluating the
     Environmental Health Work Force, prepared  by  Levine  and  Associates,
     Rockville,  MD, January 1988.

27.  Richard  C.  Atkinson,  "Supply  and  Demand for  Scientists  and
     Engineers:  A National Crisis in the Making," Science, April 27,

28.  U.S.  Bureau of Labor Statistics as cited in Robert  Pool,  "Who
     Will Do  Science in the 1990s?" Science,  April 27, 1990.

29.  Personal  communication  with  Steven  Moehlmann,  Executive
     Director,  Association  of Boards of  Certification,  May  30,

30.  Association   of    Boards    of   Certification,    "Operator
     Certification:  1980 Status  Report,"  Journal of the Water Pollution Control
     Federation,  December  1981.

31.  USAToday,  April 20,  1990.

32.  Cambridge Reports,  Trends and Forecasts, September  1989.

33.   Institute of Public  Administration, Special Districts and Public Authorities in
     Public Works Provision, prepared for  the National  Council on Public
     Works  Improvement,  July 10, 1987.

34.  Commuting in America, The  Eno Foundation, 1988.

35.  U.S.  General Accounting  Office,  Environmental Protection Agency: Protecting
     Human Health and the Environment Through Improved Management,  August 1988.

36.  U.S.   Environmental  Protection  Agency,  State Funding Study—Draft
     Recommendations,  Office  of Water,  1989.

37.   Many  of these systems, such as  those that serve mobile home
      parks,   recreation   areas,   or   institutions,   are   not   in
      continuous use  by the public.
 September 1990                                                       Page 66

38.  For details,  see Environmental Financial Advisory Board to the
     U.S.  Environmental Protection Agency,  Statement an Environmental Tax
     Polity, Draft,  March 1990.

39.  U.S.  Environmental Protection Agency, Report to Congress, Water Quality
     Improvement Study,  Office  of  Water  Regulations and Standards,
     September 1989.

40.  U.S.  Environmental Protection Agency, A Preliminary Analysis of the Public
     Costs of Environmental Protection: 1981-2000,  Office of Administration and
     Resources Management,  May 1990.

41.  This  estimate  may overstate shortfalls,  to  the degree  that
     states  leverage  their capitalization grants.  See:  National
     Council on Public  Works Improvement,  The Nation's Public Works: Report on
     WastewaterManagement, prepared by Apogee Research, Inc., May 1987.

42.  American Society of Civil Engineers,  Civil Engineering in the 21st Century,

43.  National Science Foundation, Science and Engineering Indicators -1989, 1989.

44.  Richard 6. Luthy and Mark  M.  Benjamin,  "Solving Groundwater
     Contamination   Problems   Through  Graduate  Education  in
     Environmental  Engineering," Water Environment and Technology,  January

45.  Testimony of John Neuhold before the House of Representatives'
     Science,   Space, and Technology  Committee,  Subcommittee on
     Natural Resources, April 3, 1990.

46.  Richard C. Atkinson,  "Supply and Demand for Scientists and
     Engineers: A National  Crisis in the Making," Science, April 27,

47.  see  Atkinson,  1990.

48.  Paul L. Busch and William C. Anderson, "Education of Hazardous
     Waste  Engineering Professionals,"  presented  at  the  116th
     Annual  Meeting  of the  American  Public Health  Association,
     Boston, Massachusetts,  November  15,  1987.

49.  National Science Foundation, Science and Engineering Indicators • 1989, 1989.

September 1990                                                      Page 67

50.  See  Testimony of  John Neuhold, April  3,  1990.

51.  Long Island Sound Study Policy Committee, Long Island Sound Study 1988
     Annual Report.  1989.

52.  Great Lakes Water Quality Board, Report  to the International
     Joint Commission,  The 1987 Report on Great Lakes Water Quality,  Windsor,
     Ontario, 1987.

53.  U.S. Environmental Protection Agency, Pesticides in Ground Water Data Base,
     1988 Interim Report, Washington,  D. C., 1988.

54.  Peter Rogers  and  Kenneth  I. Rubin,  "Management  of Water
     Resources in the U.S.: Current Context and Future Strategies,"
     presented  at  the  Institute  of  Public  Administration  of
     Canada's Conference on Management of Water Resources, Harrison
     Hot  Springs, B.C., April 24-26, 1985.
September 1990                                                     Page 68

                               APPENDIX A

Organization, Goal, and Mission of Water Quality 2000

   Water Quality 2000 was initiated in 1988. In July of that year, leaders of 26 national, state, and local
organizations met to assess the effectiveness of current water quality policies, the process by which
these policies are established, and ways in which this process could be improved. At the conclusion of
the conference, an ad hoc committee was formed to explore the feasibility of a formal cooperative effort.

   This ad hoc group developed a mission statement, agreed upon a vision and goal, and created an or-
ganizational structure for the effort. These documents were refined and ratified by representatives of 31
Mission Statement

   The mission of Water Quality 2000 is stated as follows:

   Representing a broad range of interests in America, propose and promote national policies and
goals for the 21st century that will protect and enhance water quality, with a specific agenda for action.

   In carrying out this mission, the following principles will be applied:

        • Broad representation will be achieved;

        • The perspective will be long-range, visionary, and holistic;

        • Maximum consensus on "national principles" will be sought;

        • Water quality, not water quantity, is the focus, but with a balanced view of surface,
          ground, and atmospheric waters; and

        • The product of Water Quality 2000 will include a specific agenda for action.

Membership and Governance

   To date, membership in Water Quality 2000 has included more than 80 organizations, representing
industry, government, the environmental movement, the professional and technical community, and
academia (see Appendix B for a list of Member Organizations). Membership is balanced to reflect the
diversity of interests concerned with water quality. Each organization has an equal voice in the Member
Congress (except that federal agency  members do not vote). A twenty-member Steering  Committee,

September 1990                                                                Page 69

elected in September 1989, provides overall leadership and direction for Water Quality 2000 (see Appen-
dix C for a list of Steering Committee members and their affiliations).
Water Quality 2000 is a Four-step Process

   The work plan approved at the 1989 conference divides the activities of Water Quality 2000 into four
distinct phases (see box). Phase I, Feasibility and Plan Development, was completed in May 1989. The
adoption of this report completes Phase ft Problem Identification. This report assesses the current con-
dition of the nation's water resources, explores the underlying causes of water problems, critiques the
policies and programs in place to deal with these problems, and identifies impediments to their solu-
tion. In doing so, it provides the foundation for Phase ffl, Development of Recommendations. This next
phase of the project will seek consensus on policy recommendations that correspond to the problems
identified in this report. These recommendations will be completed in 1991. During Phase IV, Im-
plementation, Water Quality 2000 will publicize and explain these recommendations to Congress and
all who influence water quality.
                         The Four Phases of Water Quality 2000

                 Phase I       —      Feasibility and Plan Development

                 Phase n      —      Problem Identification

                 Phase QI      —      Development of Recommendations

                 Phase IV     —      Implementation
 Methodology for Problem Identification

    To provide the broadest possible perspective on problems with current policies and programs, ten
 work groups of 15 to 25 members were established (see box). Efforts were made to ensure a balanced
 membership that would reflect the diverse composition of those concerned with water quality. Work
 groups were asked to arrive at their conclusions by a process of discussion, debate, and consensus. Over
 150 individuals participated in the work group process between August 1989 and May 1990 (a list of
 work group participants is attached as Appendix D).
 September 1990                                                                  Page 70

                   The Ten Work Groups Convened During Phase II
        •  Agriculture

        •  Aquatic Ecosystems and Habitat

        •  Community

        •  Energy and Resources Extraction

        •  Industry

        •  Legislation

        •  Recreation

        •  Transportation

        •  Watershed

        •  Water Supply
   The groups were charged with identifying the most critical water quality issues in each area of con-
cern. The groups were asked to approach this task in a visionary and futuristic manner, measuring cur-
rent conditions against the Water Quality 2000 Vision Statement and Goal (see Appendix E for the full
text of both). Each group addressed three broad topics: (1) water quality problems; (2) causes of these
problems; and (3) impediments to solutions.

   Draft reports from each work group were circulated for review by all Member Organizations. Com-
ments submitted as a result of this review were considered by the groups in developing their final
reports. The Steering Committee reviewed the ten reports, used them to develop this document, and in
some cases, augmented them. This report — the official product of Phase n — synthesizes the findings
of the ten work groups, identifies major themes and oosscutting issues, and provides a framework for
the consideration of solutions in Phase m.
September 1990                                                                    Page 71

                                 APPENDIX B

                             Water Quality 2000

                         Member Organizations

                Academy of Natural Sciences of Philadelphia
                American Academy of Environmental Engineers
                American Association of Port Authorities
                American Association of State Highway and Transportation Officials
                American Consulting Engineers Council
                American Farm Bureau Federation
                American Farmland Trust
                American Forestry Association
                American Institute of Chemical Engineers
                American Paper Institute/National Forest Products Association
                American Petroleum Institute
                American Planning Association
                American Public Works Association
                American Recreation Coalition
                American Rivers
                American Society of Civil Engineers
                American Water Resources Association
                American Water Works Association
                Association of Environmental Engineering Professors
                Association of Metropolitan Sewerage Agencies
                Association of Metropolitan Water Agencies
                Association of State Drinking Water Administrators
                Chemical Manufacturers Association
                Chesapeake Bay Foundation
                Citizens For A Better Environment, California
                Colorado Environmental Coalition
                The Conservation Foundation
                Edison Electric Institute
                Environment and Energy Study Institute
                Environmental Defense Fund
                Environmental Law Institute
                The Fertilizer Institute
                Friends of the Earth
                Green Bay Metropolitan Sanitary District (Wisconsin)
                Great Lakes Commission
                Harvard University - Division of Applied Sciences
                Heidelberg College - Water Quality Laboratory
                International City Management Association
                Interstate Commission on the Potomac River Basin
                Izaak Walton League of America
                Kansas Water Office
                Legal Environmental Assistance Foundation
September 1990                                                                   Page 72

                Lower Colorado River Authority (Texas)
                Michigan Department of Natural Resources
                National Agricultural Chemicals Association
                National Association of Conservation Districts
                National Association of Counties
                National Association of Regional Councils
                National Association of State Universities and Land Grant Colleges
                National Association of Stormwater and Hood Management Agencies
                National Association of Water Companies
                National Food Processors Association
                National League of Cities
                National Parks and Conservation Association
                National Recreation and Parks Association
                National Society of Professional Engineers
                National Wildlife Federation
                Natural Resources Defense Council
                North American Lake Management Society
                NSI Technology Services, Inc.
                Occidental Petroleum Corporation
                 Reliance National Insurance Company
                 Rock River Water Reclamation District
                 Rural Community Assistance Program
                 Soil and Water Conservation Society
                 Spill Control Association of America
                 Sport Fishing Institute
                 Trout Unlimited
                 Urban Land Institute
                 United Shipowners of America
                 U.S. Army - Corps of Engineers
                 U.S. Dept. of Agriculture
                     Agricultural Research Service
                     Forest Service
                     Soil Conservation Service
                 U.S. Dept. of Commerce - NOAA/National Marine Fisheries Service
                 U.S. Dept. of Interior
                     Bureau of Reclamation
                     Fish and Wildlife Service
                     Geological Survey
                 U.S. Dept. of Transportation
                 U.S. Environmental Protection Agency
                 Vanderbilt University
                 Virginia Polytechnical Institute and State University
                 Water Pollution Control Federation
                 Water and Wastewater Equipment Manufacturers Association
                 Wisconsin Wildlife Federation
September 1990                                                                         Page 73

                                APPENDIX C
                            Water Quality 2000
  Steering Committee Members and Their Affiliations
Bob Adler (Vice Chairman)
   Natural Resources Defense Council

Judy Campbell Bird
   Environment and Energy Study Institute

Brenda Cuccherini
   Chemical Manufacturers Association

Clifton Curtis
   The Oceanic Society (9/89-7/90)

John Doyle (9/89-3/90)
G. Edward Dickey (3/90-)
   U.S. Army Corps of Engineers

Clark Duffy
   Kansas Water Office

Linda Eichmiller
   Association of State and Interstate Water
   Pollution Control Administrators (9/89-6/90)

Nancy Foster
   NOAA/National Marine Fisheries Service

Chuck Fox
   Friends  of the Earth

Frank Friedman
   Occidental Petroleum Corporation

Margot Garcia
   American Planning Association
Jerome Gilbert
   American Academy of Environmental

Mack Gray
   USDA /Soil Conservation Service

Patricia Hill
   American Paper Institute/National Forest
   Products Association

Carolyn Olsen
   Association of Metropolitan Sewerage

Ruth Patrick
   The Academy of Natural Sciences

Ann Powers
   Chesapeake Bay Foundation

Rudy Rosen (7/90-)
   National Wildlife Federation

David Stahl
   Urban Land Institute

Ernest Shea
   National Association of Conservation Districts

Paul Woodruff (Chairman)
   Water Pollution Control Federation
                          Steering Committee Alternates

                Walter Bishop, alternate for Jerome Gilbert
                Jim Burt, alternative for Mack Cray
                Stan Chanesman, alternate for Nancy Foster
                Jessica Landman, alternate for Bob Adler
                Ernie Rosenberg and Catharine deLacy, alternates for Frank Friedman
September 1990
                                  Page 74

                                 APPENDIX D
       Water Quality 2000:  Work Group Participants
American Forestry Association
   Gerald Gray

American Society of Civil Engineers
   William R. Johnston

Association of State and Interstate Water Pollution
Control Administrators
   Linda Eichmiller

Chesapeake Bay Foundation
   Patrick Gardner

Environmental and Energy Study Institute
   Judy Campbell Bird

Farmer, Casselton, North Dakota
   Robert Sinner

Fertilizer Institute (The)
   Karl Johnson

Heidelberg College, Water Quality Laboratory
   David Baker

Lower Colorado River Authority (Texas)
   John Hall
   Kolleen Wilwerding

National Agricultural Chemicals Association
   Thomas Gilding

National Association of Conservation Districts
   Ernest Shea

National Association of State Universities and
Land Grant Colleges
   Terry Nipp

National Association of Wheat Growers
   Margery Williams

National Com Growers Association
   David Stawick
National Food Processors Association
   Paul Halberstadt

National Research Council, Board on Agriculture
   Craig A. Cox

Natural Resources Defense Council
   Thomas Kuhnle
   Justin Ward

Soil and Water Conservation Society
   Norman Berg
   Richard Duesterhaus

U.S. Department of Agriculture
   Richard Amerman, Agriculture Research Service
   Ronald F. Follett, Agricultural Research Service
   Mack Gray, Soil Conservation Service
   Doral Kemper, Agriculture Research Service
   Jack McDougle, Soil Conservation Service
   Peter Patterson, Soil Conservation Service
   Marc Ribaudo, Economic Research Service
   Ed Schlatterer, Forest Service
   Peter Smith, Soil Conservation Service
   Mark Waggoner, Soil Conservation Service

U.S. Environmental Protection Agency
   Robert Barles, Office of Water
   Robert Bastian, Office of Water
   Peter Caulkins, Office of Policy, Planning and
   Rosanna Ciupek, Office of Water
   Rebecca Hanmer, Office of Water (Chair)
   James J. Jones, Office of Policy Analysis
   Jeanne Melanson, Wetlands Protection
   Carl Myers, Office of Water
   Clayton Ogg, Office of Policy, Planning and
   John Reeder, Office of Water
   Lynn Shuyler, Chesapeake Bay, Region m
September 1990
                                     Page 75

Environmental Defense Fund
   Rodney Fujita
   Mary Voytek
Green Bay Metropolitan Sanitary District
   Harold Day
   John Kennedy
National Council for Air and Stream Improvement
   Dennis Borton
National Oceanic and Atmospheric Administration
   Stan Chanesman, National Marine Fisheries
National Wildlife Federation
   Rudy Rosen
NSI Technology Services Corporation
   Robert Hughes
Oceanic Society
   Boyce Thome Miller
Sport Fishing Institute
   Gilbert Radonski
US. Army Corps of Engineers
   Mary Landin, Waterways Experiment Station
VS. Department of Agriculture
   Gordon Haugen, Forest Service
VS. Department of Interior
   Mary Gessner, Fish and Wildlife Service
VS. Environmental Protection Agency
   David Davis, Office of Wetlands Protection
   James Giattina, Water Division, Region V (Chair)
   Charles Sutfin, Water Division, Region V
Virginia Polytechnic Institute and State University
   James Karr
Wisconsin Department of Natural Resources
   Scott Hausmann
Woolpert Consultants
   Warren High
 September 1990
                                     Page 76

American Academy of Environmental Engineers
   Walter J. Bishop
American Consulting Engineers Council
   Pat Marchese
American Planning Association, Virginia
Commonwealth University
   Margot W. Garcia
American Public Works Association
   Richard Sullivan
Association of Metropolitan Sewerage Agencies
   Ken Kirk
Association of State and Interstate Water Pollution
Control Administrators
   Chuck Evans
Citizens for a Better Environment, California
   Denise Fort
City of Atlanta, Department of Water and Pollution
   George Barnes
   Carolyn Hardy Olsen
City of San Diego (California)
   Susan C. Hamilton
City of Tulsa (Oklahoma)
   Lloyd C.Coffelt
   Bob Pool

Green Bay Municipal Sanitary District (Wisconsin)
   Harold J. Day
Louisville and Jefferson County Metropolitan
Sewer District (Kentucky)
   Bud Schardein
Lower Colorado River Authority (Texas)
   David Freeman
Municipality of Metropolitan Seattle (Washington)
   John B. Lampe
National Association of Regional Councils
   Richard Hartman

National League of Cities
   Carol Kocheisen
Natural Resources Defense Council
   Jessica Landman
Passaic Valley Sewerage Authority (New Jersey)
   Carmine T. Perrapato
Philadelphia Water Department (Pennsylvania)
   Dean A. Kaplan
Puget Sound Water Quality Authority (Washington)
   Kathy Fletcher
Rock River Water Reclamation District
   Ron Holm
   Jon Olson (Chair)
U.S. Department of Agriculture, Forest Services
   Gordon Stuart
U.S. Environmental Protection Agency, Office of
Municipal Pollution Control
   Mike Quigley
September 1990
                                      Page 77

   Peter Keppler

American Petroleum Institute
   Stephanie Meadows

Columbia Law School
   Frank Grad

Edison Electric Institute
   Rich Bozek

Environmental Law Institute
   BUI Futrell
   Jim McElfish

National Wildlife Federation
   Cathy Carlson
Natural Resources Defense Council
   Lisa Spear
Occidental Petroleum Corporation
   Frank B. Friedman (Chair)
   Catharine deLacy
   Ernie Rosenberg

US. Department of Agriculture
   Doreen Christian, Forest Service
US. Environmental Protection Agency
   Mahesh Podar, Office of Policy Analysis
   John W. Wilson, Office of Policy, Planning, and
Western Governors Association
   Philip Shimer
American Consulting Engineers Council
   Eric Lappala
American Electroplaters and Surface Finishers
   Erich Salomon
American Paper Institute/National Forest Product
   Patricia Hill (Co-chair)

Chemical Manufacturers Association
   Jim Baker
   Brenda Cuccherini

Citizens For A Better Environment, C A
   Denise Fort

Colorado Environmental Coalition
   Ross Vincent
Edison Electric Institute
   Rich Bozek
Environmental Defense Fund
   Ann Maest
Natural Resources Defense Council
   Diane Cameron
US. Department of Agriculture
   Richard Cline, Forest Service
US. Environmental Protection Agency
   Mark Luttner, Industrial Technology

Water Pollution Control Federation
   Eugene DeMichele
   Carl Huber (Co-chair)
   Michael Saunders
 September 1990
                                    Page 78

American Association of Environmental Engineers
   Walter]. Bishop
   Jerome B. Gilbert
American Petroleum Institute
   Stephanie Meadows
American Water Resources Association
   Alfred Duda
   Madge Ertel
Association of Metropolitan Sewerage Agencies
   Kevin McCarty
Association of Metropolitan Water Agencies
   Diane VanDe Hei
Association of State and Interstate Water Pollution
Control Administrators
   Linda Eichmiller

Chemical Manufacturers Association
   Dell Perelman
Congressional Research Service
   Claudia Copeland

Environmental Law Institute
   Lisa St. Amand

Friends of the Earth
   Chuck Fox
Great Lakes Commission
   Michael Donahue
Harvard University
   Peter Rogers
Izaak Walton League of America
   David Dickson
National Agricultural Chemicals Association
   Jean Toohey
National Association of Conservation Districts
   Steve Meyer
National League of Cities
   Carol Kocheisen
Natural Resources Defense Counci
   Jessica Landman (Co-chair)
US. Department of Agriculture
   Warren Harper, Forest Service

US. Environmental Protection Agency
   Don Brady, Office of Water Regulations and
   Martha Prothro, Office of Water (Co-chair)
   Linda Wilbur, Office of Water Regulations and
Wastewater Equipment Manufacturers Association
   Dawn Kristof
 September 1990
                                      Page 79

American Fisheries Society
   Paul Brouha
American Fishing Tackle Association
   Dallas Miner
American Recreation Coalition
   Derrick Crandall
American Rivers, Inc.
   Susan Wilkins
Living Lakes
   Tim Adams
National Recreation and Parks Association
   Barry Tindall
New York State Department of Environmental
   Ron Miller
North American Lake Management Society
   Jerry Filbin
Resources for the Future
   Carol Jones
Soil and Water Conservation Society
   Mel Bellinger
Sport Fishing Institute
   Gilbert Radonski
Trout Unlimited
   Bob Herbst (Co-chair)
U.S. Department of Agriculture
   Elizabeth Estill, Forest Service (Co-chair)

US. Department of Commerce
   Wylie Whisonant, Jr.
U.S. Environmental Protection Agency
   Mary Jo Kealy, Economic Analysis
   Ralph (Skip) Luken, Economic Analysis
   Brett Snyder, Economic, Analysis
   George Walker, Chesapeake Bay Program
Wisconsin Wildlife Federation
   Ray Felton
American Association of Port Authorities
   Joseph Birgeles
   Richard Gorini (Co-chair)

American Association of State Highway and
Transportation Officials
   Francis Francois
   Mel Thomas
Great Lakes Commission
   Michael Donohue
   Steve Thorp
National Association of Dredging Contractors
   Mark Sickles
National League of Cities
   Nicholas Yaksich
Oceanic Society
   Clifton Curtis
Spill Control Association of America
   Marc K. Shaye
U.S. Army Corps of Engineers
   David Barrows
   Robert Engler
   Dave Mathis

U.S. Department of Agriculture
   David Badger, Forest Service
U.S. Department of Transportation
   Joseph F. Canny (Co-chair)
   Larry Isaacson
U.S. Environmental Protection Agency
   Ken Mittelholtz, Office of Federal Activities
Vanderbilt University
   Edward L Thackston, Department of Civil and
     Environmental Engineering

Water Pollution Control Federation
   Walter A. Lyon
September 1990
                                     Page 80

American Public Works Association
   Pam Bissonnette
American Water Resources Association
   Raymond Herrmann, National Park Service
   Charles Mosher, US. General Accounting Office
Association of State and Interstate Water Pollution
Control Administrators
   Linda Eichmiller
Chesapeake Bay Foundation
   Ann Powers
Interstate Commission on the Potomac River Basin
   Roland Steiner
Kansas Water Office
   Clark Duffy
NSI Technical Services
   Andrew Kinney
University of Michigan
   Jonathan Bulkley, Natural Resources and Civil
University of Washington
   Dennis Lettenmaier, Department of Civil
U.S. Department of Agriculture
   Karl Otte, Soil Conservation Sendee
US. Department of the Interior
   Stephen Ragone, Geological Survey (Co-chair)
U.S. Environmental Protection Agency
   Thomas Davenport, Nonpoint Sources,
     Region V
   Tudor Davies, Office of Marine and Estuarine
   Michelle Hiller, Office of Marine and Estuarine
                                   WATER SUPPLY
American Planning Association
   Margot Garcia
American Water Works Association
   John Sullivan
   Edward Tenny (Chair)
Association of Drinking Water Administrators
   G. Wade Miller
Association of Metropolitan Water Agencies
   Diane VanDe Hei
City of Portland, Bureau of Water Works
   Jeanne McCormick
Environment and Energy Study Institute
   Janet Edmond

National Association of Towns and Townships
   Amie Edelman
National Association of Water Companies
   Jim Groff
National Rural Water Association
   John Trax
Philadelphia Water Department
   Dean Kaplan
University of North Carolina
   Daniel Okun (retired)
U.S. Department of Agriculture
   Warren Harper, Forest Service
US. Environmental Protection Agency
   Mike Cook, Office of Drinking Water
   Joe Cotruvo, Office of Health and
     Environmental Review
Water and Wastewater Equipment Manufacturers
   Dawn Kristof
September 1990
                                     Page 81

                                APPENDIX E

      Water Quality 2000:  Vision Statement and Goal

   Vision Statement: Society living in harmony with healthy natural systems.

   Goal: To develop and implement and implement an integrated policy for the Nation to protect and
enhance water quality that supports society living in harmony with healthy natural systems.

   To achieve this goal, this policy should


        • all phases of the water cycle, including groundwater, surface water, and atmospheric

        • water as one part of a total environmental management plan, to avoid transferring
         problems from one environmental medium to another;

        • the link between water quality and land use;

        • the relationship between water quality policy in the United States and global
         environmental issues;

        • the need to maintain a healthy economy.

        • source reduction and waste minimization;

        • water conservation and reuse;


        • healthy aquatic, estuarine and marine ecosystems;

        • healthy drinking water supplies and adequate water quality for other uses;

        • protection of human health from water quality hazards associated with recreation, fish
          and shellfish consumption, and other water uses.

    Adopted 5/19/89

 September 1990                                                        "    Page 82

                               APPENDIX F

               Summaries of Work Group Reports

   The attached documents are summaries of Water Quality 2000*5 ten Phase n work group reports.
These work groups  included  more than 150 environmental  professionals. These summaries are
products of the individual work groups and may not reflect the views of the Water Quality 2000 Steer-
ing Committee or the participating organizations. The Steering Committee used the work groups' full
reports as background for this Phase D report. Copies of the full reports of the work groups are available
on request from Tim Williams, Water Quality 2000,601 Wythe Street, Alexandria, Virginia, 22314-1994,
(703) 684-2416.

   We wish to thank all the work group participants for their efforts and look forward to their con-
tinued contribution in Phase HI of Water Quality 2000.
 September 1990                                                              Page 83

                     Agriculture  Work Group

                          Executive Summary

   In many areas of the United States, agricultural pollution creates water quality problems that result
in ecological damage, economic losses and health risks for humans and livestock. Termed "nonpoint,"
agricultural and other diffuse sources of pollution  are increasingly viewed as important environmental

   The Agriculture Work Group's Phase II Report identifies sources of agricultural pollution — soil
erosion and sediment, nutrients, irrigation, conversion and loss of wetlands and riparian habitat, pes-
ticides and animal production — and discusses the scope of the problems and impediments to solving
them, including costs of management practices, gaps in information and institutional impediments.

Scope of the Problems

Surface Water

   Assessments by states under Section 319 of the Clean Water Act and sampling by the U.S Geological
Survey provide considerable insight  into pollution problems. More than half of the nation's rivers and
lakes have yet to be assessed, but, of those that have been studied, a third of the river miles and a fourth
of the lake acres were found to be impaired for some designated uses. Polluting sources include:

        • Sediment from agriculture and other nonpoint sources, which accounted for 42 percent
          of the impaired river miles, while pesticides accounted for 10 percent. Economic studies
          place costs of sediment damages in the billions of dollars per year.

        • Nutrients accounted for 49 percent, sediment for 25 percent and pesticides for five
          percent of impaired lake acres.  More recent findings suggest that pesticides occur in
          surface waters, including drinking water, more widely than previously realized.

        • Agriculture accounts for 70 percent of phosphorus loadings, which are often the
          limiting nutrient for lake  eutrophication problems. Sediment and animal wastes are
          major contributors to phosphorus loadings; animal wastes can also cause serious
          localized pathogen problems.

        • Agricultural practices have destroyed a large amount of wetlands and have damaged
          vegetation on streambanks, eliminating areas that filter sediment and nutrients and
          provide many other ecological benefits.

September 1990                                                                 Page 84

   In several western states, irrigation-related damage from salt costs downstream urban, industrial
and agricultural water users hundreds of millions of dollars yearly. Irrigation can also leach toxic chemi-
cals into surface waters and groundwater.


   Less is known about the affect of agricultural practices on groundwater. Nitrates in groundwater ex-
ceed current health standards levels in virtually all states and occur in 5 to 20 percent of sampled wells
in the Western Corn Belt and Mid-Atlantic states. Pesticides have also been found in groundwater in
most states; however, pollution levels are usually below health advisory standards of contamination.

        • A primary cause of nitrate problems is poor synchronization of nitrogen supply with
          crop needs.

        • The lack of data on health risks from consuming nitrate-nitrogen and pesticides,
          especially for low levels of concentration, complicates assessments.

Impediments to Solving Problems

Economic Impediments

   Agricultural producers are driven by the profit motive, therefore economic realities determine, to a
large extent, the way they run their farms.

        • Agricultural producers are generally subject to substantial risks for which they receive
          relatively small returns. Significant impediments to reducing agricultural pollution
          include the unavailability of technical expertise and perceived or actual economic risks
          associated with adopting more environmentally oriented farming practices. However,
          alternative methods of farming that reduce production costs may stimulate the
          adoption of more water quality protection practices.

        • Because they operate within a competitive system, individual farmers are generally
          unable to pass the incremental costs of environmental remediation on to consumers,
          which reduces their ability to adopt best management practices (BMPs) economically.

        • Increased agricultural productivity across the U.S. has intensified fanning practices.
          When chemicals are used and livestock are concentrated in small areas, the increase in
          wastes and related pollutants elevates the risks of water pollution. This kind of
          intensified agriculture poses a serious challenge to improving water quality.
September 1990                                                                   Page 85

Political Impediments

   Farmers are strongly affected by government at all levels. Some government programs have already
been modified to support wetland preservation and soil conservation, with a greater emphasis on at-
taining water quality goals. Nonetheless, the work group identified gaps in these efforts and conflicts
with environmental goals.

        • Farm programs often inadvertently operate to frustrate or undercut environmental
          policies by encouraging intensive production that, at times, occurs on environmentally
          sensitive lands. Current program rules that base payments on recent planting of grains
          encourage monoculture at the expense of crop rotations that may require the use of
          fewer pesticides and increase the benefit to the soil. This problem has been recognized,
          and there are a number of legislative proposals under consideration in the U.S. Senate
          and House of Representatives.

        • Even with the expansion and targeting of soil conservation expenditures based on
          control of erosion, a remaining impediment is the difficulty of coordinating these
          federal soil conservation programs with state-led programs to improve water quality.

        • State water quality programs are beginning to address agricultural nonpoint source
          issues. However, much work remains to be done on water quality standards, localized
          risk assessments and management planning.

        • Mandatory environmental regulations often exempt agriculture, reflecting a general
          preference for voluntary programs. Reliance on voluntary approaches makes it difficult
          to target remediation efforts to the worst problems. Continued reliance on voluntary
          programs without increased government funding is a key impediment to achieving
           national water quality goals.

        •  The lack of resources for controlling nonpoint source pollution, generally, and
           agricultural pollution, in particular, is a serious impediment.
 Information-related Impediments

    Effective water quality protection programs require sufficient data to establish goals, fix respon-
 sibility and design and implement pollution abatement practices. The work group identified a number
 of information impediments.
 September 1990                                                                    Page 86

       • Since agricultural pollution emanates from millions of locations, the states and the
         federal government have been unable to pinpoint the absolute and relative
         contributions of various sources. This has impaired government's ability to design
         effective remediation programs based on area-specific water quality objectives.

       • There is incomplete farm-level information on water quality BMPs and alternative
         agricultural systems. For example, data are needed for quantifying the effectiveness of
         different kinds of BMPs, and dissemination of the substantial knowledge that does exist
         is limited.

       • Data gaps for many pesticides include information on health risks, especially at low
         levels, risks from break-down products and risks from exposure to multiple pesticides.
         There are significant gaps in data on pesticide-use patterns and the extent of surface
         water and groundwater contamination.

       • Additional information on nitrates is needed for more comprehensive soil tests and
         related data to allow fanners to meet but not exceed plant nitrogen requirements;
         improved methods for irrigation water management to reduce leaching; and data on
         health effects, especially on  cancer risks.
September 1990                                                                     Page 87

              Aquatic Ecosystems and Habitat

                          Executive Summary

   The Aquatic Ecosystems and Habitat Work Group was assigned the task of describing the ecological
effect of human activities that degrade this nation's freshwater, estuarine and marine surface water
resources. To accomplish this task, we looked beyond water quality from a purely chemical standpoint
and examined the full range of physical, chemical and biological factors that contribute to the degrada-
tion of aquatic ecosystems. In doing so, the work group concluded that aquatic resource  management
programs have not used biological indicators — such as the health of aquatic organisms and the ter-
restrial life that depends on these organisms — to identify problems and develop solutions and there-
fore have failed to adequately protect the biological aspects of those resources. The result of this over-
sight is a fragmented and, at times, contradictory approach to aquatic resource management.

Scope of the Problems
   Aquatic ecosystems have been degraded and destroyed by a broad  range of human activities that
have occurred locally, regionally and globally. In particular, urbanization, agriculture, silviculture and
livestock grazing have drastically altered the integrity of the landscape, resulting in runoff of soil and
chemicals to receiving waters and affecting essential aquatic and terrestrial habitat. Further, alterations
of waterways (damming, channeling, sedimentation and mining) and water withdrawal for human con-
sumption and agricultural and industrial use  have altered and eliminated important  habitats and
destroyed major fisheries.

   Population growth and the resultant disposal of wastes and by-products of human activities has led
to extensive toxic contamination of water and sediment, creating lethal conditions for aquatic life and
threatening human health. Finally, overharvest of fish and shellfish resources and introductions of
species have altered native aquatic communities, often reducing natural biological diversity. Evidence is
mounting that disparate impacts are cumulatively resulting in alterations worldwide such as global
warming and ozone depletion. In addition, pristine environments are jeopardized by the atmospheric
transport of pollutants.

Work Group Recommendations

   To reverse this history of aquatic resource degradation, the Aquatic Ecosystems and Habitat Work
Group urges the Water Quality 2000 Member Congress to adopt the goals of achieving no  net loss of the
functions and values of aquatic ecosystems and expanding the resource base by restoring damaged
aquatic  ecosystems. The Member Congress should then encourage the immediate adoption and im-

September 1990                                                                Page 88

plementation of these goals by federal and state executive order and, ultimately, should work toward
their adoption as national policy in all federal and state legislation affecting aquatic ecosystems.

   To effectively work towards the achievement of these goals, we must better understand and protect
the structural and functional integrity of aquatic ecosystems, attributes that are intimately related to the
values of those systems, and recognize the cumulative, degrading effect of seemingly disparate, and
often minor, impacts. Furthermore, we must be more aware of the potentially destructive ecological af-
fects of human actions while addressing equally complex social and economic problems.

   The factors responsible for the massive degradation of aquatic resources can often be identified. Al-
though we know how to reverse some trends towards resource degradation, other trends seem to be ir-
reversible. As a society, we must engender understanding and respect for natural resources. By foster-
ing enhanced  stewardship through knowledge, we can gamer the public mandate  and  financial
resources to ensure the continued existence of pristine environments (Le. areas virtually unimpacted by
human actions), healthy aquatic and marine ecosystems and sustainable aquatic resources.
September 1990                                                                     Page 89

                    Community Work Group

                          Executive Summary

   A community's water quality can be affected by waste management problems that create ongoing,
cross-media pollution. The Community Work Group identifies these water quality problems by physi-
cal sources—effluent discharges, surface  runoff, groundwater pollution and air pollution—and ex-
amines the problem of resources lost or wasted as a result of certain community water use and waste
disposal practices. Finally, the work group discusses the political, financial and cultural impediments
that  community decisionmakers and officials will face when they attempt to solve water quality

Scope of the Problems

Effluent Discharge

   Communities discharge trillions  of gallons of effluent each year after treating wastewater from
homes, businesses and industries that release their wastes into public sewers. If inadequately treated,
the effluent received into waters will produce problematic levels of suspended solids, nutrients and
toxics and cause a wide range of health and environmental problems.

        •  A U.S. Environmental Protection Agency (EPA) survey taken in 1988 indicated that
          almost 70 percent of the nation's treatment and collection facilities had caused
          documented water quality problems. Therefore it is reasonable to suspect that the
          existing publicly owned treatment works will experience additional difficulties as they
          attempt to cope with the volume and composition of sewage generated by communities
          in the 21st century.

        •  Treatment-induced problems generated through processes such as dechlorination and
          disinfection through chlorination can be significant, as the final effluent may contain
          unacceptable levels of toxics. Community discharge can also introduce nontoxic
          problems such as turbulence and temperature disparity into the receiving waters.

        •  Pretreatment can leave waste generators with highly toxic sludge residues that, if not
          disposed of properly, harm water quality. Additional problems result when
          pretreatment programs are delegated to the local level where enforcement ordinances
          are sometimes weak.
September 1990                                                                Page 90

        • Combined sewer overflows are problematic in times of wet weather when combined
          sewer flow, possibly containing unacceptable pollutants, is discharged directly into
          receiving waters. Older cities, especially in the northeastern U.S., are often served by
          combined sewers.

Surface Runoff

   Materials placed on the land or erosion from land development become major contributors to water
quality problems when surface water runoff carries them into waterbodies.

        • Pollution assimilated from a variety of sources on community surfaces can contaminate
          receiving waters. Such runoff includes asbestos and lubricants from roads, materials
          from construction sites and fertilizers and pesticides from lawns. Runoff from
          agricultural impoundments, golf courses and domestic plots can also contain toxics and
          problematic levels of nutrients.

        • Environmental changes can result in nonpollutant water quality problems. Construction
          activities, for instance, can increase sediment runoff to receiving waters and thus block
          sunlight to biota, clog fish gills and disturb spawning beds. Drainage system
          modification, floodplain development and wetland development can adversely alter a
          system that once efficiently removed many pollutants and controlled hydrological

        • Planning and land use decisions contribute to water quality problems if made without
          consideration of geographic impacts. Examples of such decisions include insufficient
          setbacks from waterbodies, excess densities and high intensity land uses near sensitive

Groundwater Pollution

   The integrity of the nation's groundwater is threatened by landfilling of solid and hazardous wastes
and sludges, badly maintained septic systems  and deteriorating  sewage collection and treatment

        • Moisture leaching through landfills can contaminate groundwater. Although landfill
          lining can reduce leachate, only 15 percent of the nation's  landfills are lined and 5
          percent incorporate leachate controlling systems; less than 30 percent of landfills are
          equipped with groundwater monitoring systems. Operators attempt to prevent
          leaching by capping off the landfill and pumping, but the process is expensive and
          often only  partially  successful Alternative methods such as incineration still require

September 1990                                                                     Page 91

           some landfill space and consume large amounts of energy, while recycling can create
           sludge with high concentrations of hazardous constituents that may eventually leach
           into groundwater.

         • On-site septic tank systems are used by about 25 percent of all U.S. housing units;
           however, only about 30 percent of the nation's soil is suitable for on-site systems, and it
           is reasonable to assume that some systems are installed in unsuitable sites. Many of
           these systems are poorly designed or outdated for handling the wide range of chemicals
           in today's household water. Inadequate permitting and inspection procedures can
           exacerbate the problem.

         • Exfiltration from defective or deteriorating sewage collection lines and treatment
           facilities is increasingly a problem as more and more of the nation's sewer structures
           approach the end of their useful lives.

         • Special hazardous waste may add to future water quality problems. Such waste
           includes post-incineration treatment facilities' sludge ash containing high
           concentrations of inorganic pollutants, household solid waste containing hazardous
           materials and some cleaning supplies  and paints containing toxic solvent. Improper
           disposal of such wastes can also threaten water quality.

Air Pollution

    Much of the pollution in the air falls on surface waters and the land, where it eventually infiltrates
into groundwater. Other contributors to water  pollution include new compounds, which form air-
suspended particles that react with other chemicals (acid rain), and improperly incinerated solid waste,
which creates toxic organic compounds.

Potential  to Turn  Waste Materials Into Resources

    Communities sometimes ignore the potential for using waste materials as productive resources,
thereby aggravating the pollution problem. The  work group highlighted several waste materials that
are potentially useful resources including wastewater, sewage nutrients and solid waste.
September 1990                                                                     page 92

Impediments to Solving Problems


   Increasingly, local governments are relied on not only to legislate improvements to water quality
but also to implement, enforce and finance such improvements. In many cases, this responsibility places
local authorities in the difficult position of creating and enforcing laws that can cause hardships such as
citizen disapproval, industry relocation or job loss for authorities or  their constituents. In addition,
when the pollution problem crosses boundaries, the local government may need to relinquish  its
autonomy to the regulatory power of a state or regional authority.


   EPA estimates that $84 billion will be required to construct treatment and collection facilities and to
enlarge, upgrade and replace existing treatment works. The estimate approaches $150 billion when
solutions to other problems such as  premature wastewater system deterioration, inadequate was-
tewater reserve capacity, runoff pollution, combined sewer overflows and stormwater inadequacies are

   Meeting these needs presents a significant financial burden for society and, more specifically, com-
munities. Communities must balance water quality solutions with many other pressing social needs. In
addition, many local governments that have used landfills have  the additional burden of retroactive
liability. With growth and technological advances, communities will face additional expenses for con-
struction and maintenance of community water quality facilities. Furthermore, many local communities
have no  funding mechanisms for coping with such problems  as combined sewer overflows and
stormwater management.


   Part of the overall problem is the  public's lack of understanding about the nature of the environ-
ment, including its fragility and society's impact on the environment. Furthermore, there is a tendency
to focus on the short term—to thoughtlessly consume resources and produce waste. Only an informed
minority  is aware of the severity of the problems and need for solutions. Federal, state and local govern-
ments play an increasingly critical role in environmental education,  but  the problems must be ad-
dressed societywide.
 September 1990                                                                   Page 93

         Energy  and Resource Extraction
                            Work Group
                      Executive Summary
   Energy and mineral extraction activities may have a variety of impacts on water quality, many of
which are controlled by a large and complex body of regulations and project review procedures. Some
adverse impacts on water quality still occur, however, because of past practices, gaps in the existing
regulatory system and lack of enforcement. Moreover, existing regulations generally do not address or
support energy and mineral resource conservation or the use of alternative energy sources, both of
which would contribute toward reducing water quality impacts.

   The Phase II Report of the Energy and Resource Extraction Work Group identifies water quality im-
pacts associated with exploration and production of energy and mineral resources but does not discuss
impacts associated with activities further down the production process, such as petroleum refining and
mineral smelting. The report notes the  potential for energy conservation and efficiency—as well as
materials re-use and recycling—to reduce water quality impacts.
Scope of the Problems

Oil and Gas Industries

   The location, assessment and recovery of oil and gas resources entails operations that inherently
cany the potential  for affecting surface water and groundwater resources, as well as species that
depend on them. Although the effects of these operations are controlled directly by various federal,
state and local regulations and indirectly through environmental review procedures, adverse water
quality impacts may still result from oil and gas operations. The report identifies the  following
problems, which are not yet resolved:

        • Lower energy prices in recent years have reduced incentives to implement energy
         conservation technologies to improve efficiency. Technological efficiencies can reduce
         pressures to develop new energy resources or rely on marginal reserves, thus
         decreasing the water quality impacts potentially associated with mineral extraction.
September 1990                                                             Page 94

          Small operations producing oil and gas from marginal reserves often may not be as well
          maintained and may create greater water quality impacts than large operations.

          Ineffective facility designs allow stonnwater runoff from oil and gas facilities to collect
          and transport pollutants to surface or ground waters. Where facilities are inadequate,
          stonnwater runoff from oil and gas facilities can collect and transfer pollutants.

          Improper containment and disposal of wastes from oil and gas exploration and
          production activities may result in contamination of surface and ground waters or the
          marine environment. A1987 EPA report to Congress documented numerous cases of
          inadequate containment and improper disposal of drilling and production wastes
          associated with oil and gas extraction activities.

          Current regulations, if not adequately enforced, do not adequately control the water
          quality impacts resulting from disposal of produced waters from oil and gas extraction

          If improperly managed, oil and gas production wastes may severely contaminate

          Improperly closed and abandoned oil and gas wells, which can seriously impact
          underground sources of drinking water.

          Spills or leaks from storage tanks can contaminate surface waters, soil, and
          groundwater. Existing regulations for aboveground storage tanks are inadequate to
          minimize risks of such contamination.

          In addition to platform and tanker accidents, discharges or runoff from offshore
          exploration or production operations can impact quality in marine waters.
Coal and Mineral Extraction and Processing

   Most of the water quality impacts from processing of mining and minerals are problems associated
with nonpoint source runoff. Surface waters are contaminated by stonnwater runoff from mining sites,
and groundwater is polluted by seepage from waste impoundments and storage areas.

   Problems occur with direct discharges of wastewater from mining and minerals processing ac-
tivities because many states do not apply water quality-based permitting to mining operations. Other
problems identified by the report relate to acid mine drainage from coal mines and trace metal pollution
September 1990                                                                     page 95

from metal mining operations. Coal mining can potentially conflict with wetlands preservation when
deposits are located below or near these waterbodies.
Impediments to Solving Problems

   Improvements in energy conservation and efficiency and materials re-use and recycling have the
greatest potential to reduce water quality impacts from energy and mineral development Implementa-
tion of these practices, however, is often not amenable to regulatory mandates. Furthermore, conserva-
tion technologies may not be available or economically practicable. Lack of communication regarding
the benefits of conservation measures hinders reorientation of pollution control efforts to incorporate
such measures.

   The need to protect water quality in areas subject to energy or mineral extraction often conflicts with
society's need to use energy and mineral resources. The difficulty of choosing how to improve efforts to
protect water quality without excessively restricting development of energy or mineral resources is a
major impediment to strengthening the existing regulatory system. In general, enforcement efforts are
hampered by  difficulties in identifying those operations that will potentially cause water quality
September 1990                                                                   Page 96

                      Industrial Work Group
                          Executive Summary
   Despite considerable progress in cleaning up industrial discharges—most notably in controlling
conventional pollutants such as oil and grease and suspended solids—many waters in the US. still suf-
fer from industrial pollution. Among the many human and natural activities contribute to water pollu-
tion, industrial discharges can cause considerable problems in some waterbodies. Toxic wastes have
contaminated both ground and surface sources of drinking water, affecting human health and the
vitality of many aquatic species and resulting in economic and aesthetic losses.

   Several impediments hamper effective protection of water quality from industrial pollution:

        • Institutional limitations, such as lack of sufficient resources at all levels of government;

        • Inadequate scientific bases for developing criteria and standards;

        ' Regulatory reliance on technology-based, end-of-pipe effluent controls rather than
          pollution prevention;

        • Inadequate public education and inadequate professional training; and

        • A lack of cohesion and consistency in federal regulatory programs that gives rise to key
          policy problems with respect to industry and water quality.

Scope  of the Problems

   The nation's waters continue to be affected by contaminants from a variety of sources, including sig-
nificant contributions from industry, municipal discharges,  agriculture and urban runoff.  These con-
taminants can adversely affect both human health and the integrity of ecosystems.

   Although there are monitoring gaps in evaluating the impact of discharges on both human health
and ecosystems, data from several sources and sites around the country suggest that both ongoing and
past industrial activities continue to threaten water quality. For example, in 1988,21 states issued a total
of 135 bans on fishing in selected waterways and 39 states  reported a total of 586 fishing advisories,
restrictions that represented major economic and recreational losses. The pollutants most commonly
identified as causing advisories or bans were PCBs, chlordane, mercury, dioxin and DDT.

   Many wildlife species suffer from the often subtle and long-term impacts of exposure to industrial
toxins. Instances of high rates of liver tumors in bottom-dwelling fish such as bullheads and white suck-

September 1990                                                            "     Page 97

ers have been correlated with the presence of poh/nudear aromatic hydrocarbons, which are found in
industrial wastewaters, some of which are carcinogens.

   Industrial land use practices also stress aquatic ecosystems. Construction and use of industrial com*
plexes can create severe watershed impacts such as erosion and sedimentation, higher stonnwater flows
in local streams, loss of riparian habitat and, with the loss of natural infiltration, increased loadings of
pollutants in stonnwater runoff. In addition, some developers site facilities in wetlands, thus destroying
these valuable aquatic resources.

   Insufficiently treated industrial wastewater discharges are a significant source of adverse ecological
effects in U.S. waters. The dean Water Act established a goal of zero discharge by 1985, but it also
created a permitting system that allows discharge of pollutants up to certain limits. States have only
recently begun to adopt water quality-based standards for toxics and have barely begun to insert water
quality-based limits or monitoring requirements for toxics in industrial discharge permits. As a result,
there are varying incentives among states for industries to reduce discharges of toxic wastes.

   In addition, states have focused on the outfall pipe as the source of contamination, and placed less'
emphasis on other modes of industrial water pollution such as surface runoff from industrial sites
where toxic pollutants are spilled or stored, leachates from landfills and deep well injections that con-
taminate groundwater on or off industrial sites, and deposition of airborne industrial emissions. Lastly,
scientific research into past industrial practices has identified previously unrecognized residual toxic
contaminants that must now be addressed.
 Impediments to Solving Problems

    Implementation of water quality goals has been hampered by a variety of institutional impedi-
 ments, including lack of resources, lack of a coordinated permitting process for all environmental media
 and an institutional focus on point sources. The resulting institutional situation impedes development
 of innovative solutions to industrial pollution problems.

    The lack of scientific understanding of the release, fate and transport of contaminants in ecosystems
 restricts assessment of the impacts of pollutants on ecosystem components. As a result, there is a lack of
 scientific knowledge upon which to base water quality criteria and standards. Moreover, the absence of
 effective and inexpensive analytical procedures for monitoring environmental releases contributes fur-
 ther to this lack of scientific knowledge.

 September 1990                                                                   Page 98

   Conventional risk assessment approaches only partially incorporate the full range of impacts to
human health and the environment. Many risk assessments focus solely on cancer, even though it is
only one of many human health effects caused by waterbome pollutants. Furthermore/ human health is
not the only area to consider—effects on ecosystems must also be fully considered in risk assessments.
Incorporation of these additional factors is restricted by lack of scientific understanding, which results
in impretisions in modeling the fate and transport of contaminants in surface and ground waters.

   One of the most prevalent factors that clouds the use and interpretation of scientific information is
inadequate, conflicting or imprecise data. Generally, there is little or no data on the generation of in-
dustrial hazardous  waste that  is consistent nationally; deficiencies in monitoring programs may also
create significant data gaps. As a result, basic information about the relative health or degradation of
waters nationwide is unavailable.


   The historical emphasis on end-of-pipe treatment technologies for industrial water pollution control.
has resulted in a focus on control objectives that are specific to a single medium—air, surface water or
groundwater—without giving adequate attention to cross-media transfer of contaminants. This focus on
treating wastewaters prior to discharge has not of itself, provided a stimulus for preventing pollution
before it is generated. The lack of innovative technologies to facilitate adoption of multi-media ap-
proaches and pollution prevention is a significant impediment to improving water quality in the U.S.

   There continue  to be impediments to the adoption and expansion of industrial practices that can
reduce generation and discharge of wastes and wastewaters. Opportunities for source reduction and
recycling are impeded by the lack of adequate technologies as well as by interpretation of regulations by
permitting authorities and limited technology transfer, especially between large and small companies.
Adoption of best management practices is also hindered by both technological and informational bar-


    Industry, regulators, scientists,  environmental groups,  the media and the public are not well-in-
formed about most  aspects of environmental pollution, in part through gaps in scientific knowledge but
also because of inadequate education and training and the difficulty of communicating available infor-
mation about complex dynamic issues in easy-to-understand terms without political bias. Consequent-
ly, as a nation we have not yet sufficiently institutionalized an environmental ethic that incorporates a
concern for human  health and healthy ecosystems or the concept of pollution prevention. An additional
problem is the shortage of trained professionals in many environmental disciplines.
September 1990                                                                     Page 99

Policy Problems Related to Industrial Discharges
   Federal regulatory programs suffer from a lack of cohesion and consistency. Because of the way
regulatory and statutory programs have evolved, the method for regulating a pollutant depends on the
media to which it is discharged. Differences also exist in requirements for direct and indirect dis-
chargers. In addition, the flexibility discretion given states in establishing water quality standards has
resulted in uneven water quality protection from state to state and even within individual states.

   These and other issues, such as the appropriate use of risk assessments, the lack of coordination be-
tween land use planning and water quality policies and the need for dedsionmakers to act in the ab-
sence of complete scientific information, pose significant challenges for policymakers at all levels of
 September 1990                                                                 Page 100

                    Legislation Work Group

                        Executive  Summary

   Since 1960s, the catalog of legislation to restore water quality has grown, as has public concern
about water pollution. Recently, legislation has stressed increased regulatory responsibilities for the
federal government, attempts to fill gaps left by previous legislation, increasingly explicit requirements
for the treatment of toxics, and precisely detailed  statutes. However, despite an intensified focus on
water quality issues, legislation is often a patchwork with conflicting objectives.

   The Phase n Report of the Legislation Work Group identified a number of areas where legislation
has either created problems or failed to address important issues:

        • Statutory gaps, overlaps and conflicts;

        • Inadvertent conflicts and inappropriate  incentives or disincentives;

        • Inadequacies in assessing progress;

        • Legislative and regulatory impediments to timely action;

        • Intergovernmental conflicts;

        • The gap between funding levels and the national mandate for dean water;

        • Multimedia pollution; and

        • Control of contaminated runoff.

   Jurisdictional conflicts in both the legislative and executive branches of the federal government im-
pede solution of these water quality problems.

Scope of the Problems

Protecting Environmental Values

   Laws related to water quality often have unclear objectives. Competing concerns among environ-
mental issues — and between environmental issues and other national priorities — can lead to ineffi-
cient overlaps and inconsistencies among the various laws.
 September 1990                                                              Page 101

        • Four categories of environmental values compete for prominence: ecological effects,
         cancer and non-cancer health risks and welfare effects. Often there is no dear
         delineation or agreement as to the relative importance of these categories.

        • Environmental values must compete with other goals such as administrative efficiency,
         competitive equity among states and industry, economic vitality, private property
         rights, national security and human health needs. Powerful constituencies battle over
         the relative importance of each goal which hinders the aggressive pursuit of
         environmental values.

Statutory Gaps, Overlaps and Conflicts
   Environmental laws do not cover water quality issues efficiently because the complicated commit-
tee system in Congress impedes coordination. Since the focus on these issues varies, laws can be need-
lessly repetitive in some areas, while leaving gaps in others.

        • Unclear jurisdiction among congressional committees leads to multiple referrals that
          can slow passage of a bill.

        • Legislation often addresses specific constituencies and fails  to be comprehensive. For
          example, there are at least 15 federal statues on water quality. This piecemeal approach
          can leave important gaps in some regulations, yet create redundancies in other areas.

Inadvertent Conflicts  and Inappropriate Incentives or Disincentives

    Legislation not related to water quality can have adverse effects on environmental goals. Examples
include changes in the U.S. tax code that inadvertently restrict local governments' ability to use tax-ex-
empt financing for water infrastructure needs and farm programs that often conflict with water quality

Inadequacies in Measuring Progress

    Laws often do not require baseline data collection to measure environmental results. Inadequate
data can contribute to such program problems as lack of accountability, inadequate oversight and poor

Legislative and Regulatory Impediments

    Statutory deadlines, essential to timely regulatory action, can become so numerous that they exacer-
bate an already slow regulatory process.
 September 1990                                                                 Page 102

        •  When too many deadlines are placed upon federal agencies, the result can be a "triage
          approach" to programs in which only the most important deadlines are met

        •  Complicated EPA rule-writing procedures, combined with Office of Management and
          Budget (OMB) clearance requirements, greatly impede the timeliness of the regulation
          writing process.

Intergovernmental Issues

   Both interstate and interagency issues can be barriers to successful local state and federal partner-

        • Interstate issues: States have difficulty agreeing on the best way to protect shared
           waterbodies; they also tend to be less aggressive in abating pollution when there
           are only downstream impacts.

        • Interagency issues: Federal agencies have different missions, mandates and
           priorities. Legislation often fails to define linkages between agencies that are
           required to work together, making interagency cooperation difficult

Funding-Mandate Gap

   Since 1980, constant dollar funding in the EPA budget for water quality programs has dropped 12
percent. In the future, financial restraints wiH reduce the ability of all levels of government to meet their
water quality mandates.

Multimedia Pollution

   Current legislation tends to be focused on identifiable sources of pollution on a media-specific basis.
As a result, programs that solve one pollution problem can create others of a cross-media nature.

Contaminated Runoff Control

    Contaminated runoff accounts for an estimated 60 percent of the remaining water quality problems.
The types of regulatory mechanisms that work for point source pollution will not be effective in control-
ling diffuse sources.
 September 1990                                                                 Page 103

Impediments to Solving Problems

Jurisdictional Conflicts

   Jurisdiction^ conflicts over water quality issues occur in both the legislative and executive branches
of the federal government, as well as among state governments. Developing comprehensive and effec-
tive water quality programs is difficult when responsibilities are not dearly delineated.

        • Multiple jurisdictions among congressional committees will continue to prevent a
          comprehensive approach to water quality legislation. As a result, legislation aimed at
          new issues is likely to have gaps and overlaps that will prevent effective action.

        • In the executive branch, there is no dear delineation of responsibilities among the
          various agencies that have an interest in water quality issues. This makes writing
          legislation difficult because it is not always dear who should administer new programs.

        • On the intergovernmental level, water quality laws are not dear as to when federal
          responsibility ends and state responsibility begins. Similarly, states often cannot agree
          on the division of responsibility for shared bodies of water.

 Cumbersome Bureaucratic Procedures

    Effective regulation writing cannot take place until bureaucratic procedures are streamlined. Cum-
 bersome internal rule writing at EPA is exacerbated by OMB requirements.

 Fiscal Restraints

    Competing national priorities ensure that the budgetary crisis will not ease soon. Legislators will be
 reluctant to allocate new funds for water quality programs in the face of pressure to cut the budget This
 period of fiscal tightness comes during a time of demands for increased funding to confront new water
 quality issues.
  September 1990                                                                Page 104

                     Recreation  Work Group

                         Executive Summary

   Participation in outdoor recreation, especially water-based recreation, is an American way of life.
Ninety percent of US citizens use the out-of-doors for recreation. In addition, our outdoor recreation
sites attract an increasing number of foreign visitors every year.

Scope of the Problems

   The water quality and quantity of this nation's lakes, rivers and streams affects the demand for and
supply of these recreational opportunities. On the other hand, since so many people participate in out-
door recreation, there can be potentially adverse environmental impacts from these activities, including
pollution from both water- and land-based point and nonpoint sources and land use problems.

   Water-based recreational activity can have an adverse impact on water quality, particularly when
activities attract large numbers of participants. Compared to the more widespread effects  from most
sources of pollution, degradations in water quality that result from recreational activities generally are
localized. Such degradation can be significant if it occurs in sensitive and pristine areas. For example,
participating in  recreational use of rivers has increased to the extent that certain prime river recreation
areas have experienced extreme overuse.

   The UJS. Environmental Protection Agency (EPA) does not have readily available data on water
quality trends that can be used to determine the national recreation benefits from its program-induced
water quality improvements. Such information would be extremely useful both for assessing progress
in reducing and avoiding damage from pollution and for strategic planning at all levels of government.

Impediments to Solving Problems

   Before  there can be improvements in  both the quality and quantity of water-based recreational
resources, impediments to change must be identified. Obstacles, which can be both institutional and
political, include the lack of information needed for sound management, inadequate financial resources
and insufficient public education about recreation's effect on water quality. Illustrations of both the im-
pediments and programs to overcome them are  given in sections on the Great Lakes and Chesapeake
Bay.  In addition, since most decisions about recreational water resources are made by the states and
local governments, their dean water strategies are discussed in detail.

   With a few exceptions, the development of organized and comprehensive water resource manage-
ment policies has not been encouraged at the state leveL Therefore, practical and economic sue
September 1990                                                               Page 105

have been poorly documented, leaving no foundation for policy development This general lack of data
and the poor dissemination of information are major impediments to environmentally sound recrea-
tional development  Similarly, there is not a comprehensive water resource management policy at the
national level Therefore, a national central information system and center for water data that could be
used for education and training is of primary importance.

   Finally, since development of recreational water resources will be impeded by lack of state and
federal funding, local communities must be prepared to shoulder the costs of many future projects.
September 1990                                                                  Page 106

                  Transportation Work  Group

                          Executive Summary

   Almost every aspect of the transportation sector can  affect water quality adversely. In its Phase n
Report, this work group identified the most serious  impacts  from transportation activities and
categorized them in the following three areas:

        • Runoff from transportation facilities;

        • Spills of harmful substances; and

        • Impacts from dredging and/or filling.

   Although not all of these impacts can be eliminated, most can be reduced through greater attention
to proper planning, design, construction, maintenance and operation.

   The term 'transportation facilities" includes all equipment and facilities for moving goods and
people, including  highways, railroads, airports, pipelines, harbors, cars, waterways, parking lots,
trucks, trains, ships and other carriers, as well as the associated storage facilities, maintenance facilities,
fuel storage and transfer areas.

Scope of the Problems

   Runoff from transportation  facilities degrades water quality. The magnitude of the pollution
depends on planning decisions and the design and construction of facilities as well as their operation
and maintenance. The actual impact of runoff on water quality depends on such factors as volume, flow
(peak rate and total discharge) and constituents. Other environmental characteristics that determine the
seriousness of the impact include land use patterns in an area, characteristics of the transportation mode
and infrastructure, the geography, geology and plant cover of the drainage basin and the hydraulics,
chemistry and biology of the receiving waters.

   Transportation facilities must be planned, designed and constructed carefully or they will be  a
threat to water quality, especially if they are built near sensitive waters. Appropriate structures and
methods of construction  to minimize potential adverse effects,  such as best management practices
(BMPs) to control  runoff, erosion and sedimentation are usually specified in the planning and design
stages, but at times they may be neglected as the project advances into construction.

    Almost all maintenance and  operation activities have the potential to harm water quality, such as
those related to building yards; storage and dispensing of fuel, oil and antifreeze; and application

September 1990                                                                 Page 107

methods for maintenance materials. The lack of collection facilities contributes to the problem by im-
peding collection of small quantities of by-product materials.

    Spills and unplanned discharges occur frequently but randomly. Since large quantities of petroleum
products and other chemicals are produced, transported and used annually, every community is at
some risk.  While large spills often capture the attention of the media and the public, smaller spills,
often overlooked, may have equally serious cumulative impacts, and most could be prevented.

    To further complicate the problem, the known principles of spill prevention and mitigation are still
not widely understood or adopted at all operational levels, which sometimes results in avoidable spills
from equipment failure and human error.  Furthermore, research on new mitigation methods has been
drastically reduced in recent years. Therefore, response to spills is often inadequate.

    The dredging and filling issues that have received the greatest attention are

         •  The types and concentration levels of contaminants present in the sediments;

         •  The potential for contaminants to be stirred up or made bioavailable to aquatic

         •  The short-term and long-term effects of such bioavailability; and

         •  Alternative placement sites and methodologies.

    Alternative placement sites for dredged material include confined disposal facilities. However, im-
 proper design and operation of these facilities can result in overflow that carries suspended solids and
 associated contaminants back to the waterways. Runoff from rainfall on a confined disposal facility can
 erode dredged material,  carrying  contaminants to surface waters or leaching them  into the
 groundwater. Relocating "dean" sediment in water environments instead of using it for beneficial uses
 (beach nourishment, wave attenuation and wetland creation and restoration) may  also contribute to
 short-term water quality problems such as turbidity and interference with aquatic life, and, in addition,
 fails to take advantage of a valuable resource.

    Dredging or filling, especially for new facilities, often impacts wetlands. In spite of general support
 for a goal  of no net loss, citizens still have problems with its application, the decisionmaking process,
 and with understanding terms such as "wetland value/ "mitigation" and "no net loss."

     Secondary impacts from development  stimulated by or  made possible by new transportation
 facilities are usually much greater than those from the facilities themselves. The public seems to favor
 low-density development, which requires more individual, private  transportation. There has been an
 overall institutional failure to integrate transportation planning and land use planning and to recognize
 and respond to secondary growth-related water quality impacts.

 September 1990                                                                     Page 108

Impediments to Solving Problems
   There are many impediments to solving problems created by tansportation activities, including the

        • Lack of collection facilities for used ou, antifreeze and other materials used for
          transportation maintenance by individuals and small maintenance and repair shops.

        • Lack of knowledge about how (and how much) individual pollutants and pollutant
          combinations affect wetlands and their functions.

        • Inadequate response teams for handling major hazardous material spills.

        • Inadequate research funds for developing better methods for preventing and
          controlling spills, especially in the open ocean.

        • Lack of standards on levels of contamination of sediments that might require special

        • Lack of sound technical basis for interpreting the ecological significance of contaminant
          uptake from sediments.

        • The continued public desire for dispersed, low-density development, which forces
          reliance on more highways and more travel by individual cars and produces more
          pollutants than would high-density, planned development served by mass transit
 September 1990                                                                  Page 109

                   Water Supply Work Group

                          Executive Summary

   Achieving an adequate, safe, potable water supply is getting more and more difficult as increased
pressure is placed on current sources. The Phase n Report of the Water Supply Work Group identifies 12
problem areas that need to be addressed: infrastructure, institutions, technology, water quality, water
quantity, sources, small systems, human resources, legal issues, economics, conservation and public

Scope of the Problems

        •  Infrastructure. The annual investment in capital and operation and maintenance
           for water supply facilities relative to the total value of plants reflects an on-going
           disinvestment in the nation's water supply infrastructure. This disinvestment is
           exacerbated by several factors, including numerous infrastructure needs competing
           for scarce funds; changes in tax laws restricting funds for capital investment* public
           undervaluing of drinking water; inadequate distribution systems; decentralized
           and fragmented water supply industry; and lack of a comprehensive public water
           systems program.

        •  Institutions. Institutions responsible for water delivery include private
           corporations, municipal corporations, special utility districts, cooperatives and
           individual owners. Such fragmentation has inhibited a rational water plan based
           on watershed or aquifer boundaries.

        •  Technology. Technology development and demonstration in water supply lags
           behind the need for new, cost-effective methods, procedures and equipment for
           controlling contaminants. As EPA develops new regulations to protect the public
           from new contaminants, the gap between available technology and technology
           needs increases.

        •  Quality. Many communities do not provide an acceptable standard of water
           service. Some basic causes include inadequate treatment technology; lack of fully
           established, cost-effective technology for certain contaminants; inadequately
           protected watersheds; and lack of adequate monitoring of drinking water quality.
 September 1990                                                              Page 110

          Quantity. Many factors have increased pressure on the available quantity of
          potable water, including population growth, lack of conservation, contamination,
          legislation precluding developing available sources, inability to resolve competing
          demands, an inadequate framework for development planning and lack of
          incentives to maximize efficient use.

          Sources. Many watersheds, rivers and aquifers are fully committed. Watershed or
          basinwide planning for water supply is lacking nationally, resulting in inefficient
          use of water.

          Small Systems. Community water systems serving less than 3,300 people commit
          over 90 percent of Safe Drinking Water Act violations. Small system managers,
          operators, boards and consumers are not well informed about the state and federal
          regulatory requirements or of the implications of poor quality water supplies.
          Efforts to upgrade and monitor small systems are also limited by insufficient
          technical expertise, financial resources and basic management skills.

          Human Resources. Jobs in the water industry require sophisticated technical and
          management skills. There is some concern that the work force is not adequately
          prepared for such highly skilled jobs.

          Legal Issues. The complexity of the legal environment can inhibit rational
          detisionmaking by both the private and public sectors, which frequently interferes
          with attainment of water quality and water supply goals.

          Economics. Government subsidies have hidden the true cost of providing safe
          drinking water. Elected officials and regulators are reluctant to raise rates to cover
          capital costs for small system upgrades that can be prohibitively expensive.
          Despite the lack of federal assistance for municipal systems, tax incentives do not
          promote privatization of utilities.

          Conservation. Conservation attitudes vary across the country. While many citizens
          desire conservation, they are unwilling to accept higher prices, creating conflicting
          social values.

          Public Education. The public is not well informed about water supply issues. For
          instance, the public is unaware of the true cost of providing potable water; the
          dose relationships between water supply, water use and water pollution; and the
          concept that water is a depletable resource that must be used efficiently.
September 1990                                                                    Page 111

Impediments to Solving Problems
           Federal and State Technical and Financial Support Federal support of the water
           industry has been insufficient and has dampened progress in several areas:

           • Research and demonstration projects to enable technology to keep pace with new

           • Centralized and comprehensive approach for contaminant removal; and

           • Strong enforcement at both the federal and state levels to force technology

           • In addition, small system managers and operators have found it difficult to obtain
             financial and technical assistance at the state and federal level.

           Legislative Support. Legislative and judicial bodies support the "not in my back
           yard" phenomenon, impeding new water supply projects. As tax payers and rate
           payers continue to resist funding the supply and treatment projects mandated by
           legislation, cooperation among levels of government is becoming difficult.

           Political Support In the political arena, water issues have not been high on the
           agenda. State lawmakers and the public are unclear as to how to handle the
           tradeoffs between cost, quality and quantity. In addition, without an immediate
           crisis, it is difficult to generate support for immediate action to deal with future
           water scarcity problems. Changes in water use or water supply tend to create
           political turmoil (development that is viewed as environmental degradation;
           transfer of water rights that creates economic dislocation; interbasin transfers that
           are viewed as lost future opportunities in own area; and patchwork laws that
           inhibit movement of water to its highest economic use). In general, political leaders
           have not accepted strategies for maximizing the existing water supplies, such as
           conservation methods or rate incentives.

           Public Education. Attitudes and traditional practices are difficult to change
           because the current system of water pricing hides the true cost of water use; the
           public is accustomed to cheap water and not readily accepting of rate increases;
           and the sense of crisis, necessary for change, has not been reached. In addition, the
           public does not have a sound understanding of the costs and benefits of
September 1990                                                                   Page 112

          Industry Fragmentation. The fragmented nature of the water supply industry and
          the generally small size of systems make it difficult to provide the necessary
          resources to assure quality. In addition, the water supply industry does not have a
          sufficient number of qualified employees (engineers, chemists, microbiologists).
          Fragmentation among states and institutions in water policy and law also inhibit
          coordinated planning for water development and use.
September 1990                                                                    Page 113

                     Watershed Work Group

                         Executive Summary

   Progress has been made in cleaning up the nation's waters since the passage of the dean Water Act
Amendments of 1972, but the quality of our surface water and groundwater is still seriously threatened
by a broad range of pollutants and pollution sources. The Phase E Report of the Watershed Work Group
identifies a number of issues affecting basinwide water quality management, including fragmented ap-
proaches, responsibilities and accountability as well as conflicting laws, the predominance of a local
planning focus, the lack of analytical techniques and the incorporation of risk.

Scope of the Problems

Fragmented Approaches

   Total pollutant loadings from nonpoint and point sources within a river basin are not adequately
addressed by existing pollution control programs, which are inefficient and economically wasteful
These piecemeal efforts to address multiple sources result in fragmented approaches to control that fan
to reduce pollution and may simply transfer contamination from one medium to another. Examples in-
clude incineration of solid waste, which has polluted both air and water, and improper pretreatment of
industrial wastewaters entering municipal sewers, which has created  a new problem associated with
the disposal of contaminated sludge.

Fragmented Responsibilities

    The responsibility for water pollution abatement and control is divided among a number of federal
and state agencies and local governments. Moreover, even within individual government agencies and
organizations, responsibility for water pollution control programs is frequently divided among several
divisions. Therefore, it is difficult to hold any  single agency or group of agencies accountable for most
water pollution problems.

    The lack of federal funding and leadership often places  these burdens entirely upon local units of
 government. Within the current system, decisionmakers tend to focus on local pollution concerns that,
 in many cases, may be of lower priority than regional concerns. Moreover, solutions devised to address
 only local water pollution concerns are a fragmented approach that cannot effectively protect water
 September 1990                                                               Page

Fragmented Accountability

   Measures of success that are currently being used to evaluate progress toward meeting pollution
abatement goals and objectives may not be appropriate; in fact, many are not reflective of the basic
tenets of the dean Water Act. For example, accountability systems currently used by the Environmental
Protection Agency (EPA) to evaluate and redirect water pollution control programs are oriented toward
bureaucratically derived measures of success rather than true measures of environmental results. It is of
little value to measure program success on the number of discharge permits if issuance of those permits
has little impact on the overall improvement of water quality or protection of living resources within a

Conflicting Laws

    Conflicting laws and programs that are inconsistent with national environmental goals and objec-
tives are also problems that undermine federal state and local governments' ability to protect water
quality. In this time of declining federal funds, many environmental laws are not adequately imple-
mented by water quality agencies to protect watersheds expediently and cost-effectively by noting and
attacking priority problems first and preventing future problems.

Local Focus

    Recent federal policy places the burden for planning and executing pollution controls at the state
and local  level but has not established  clear  accountability or responsibility for those programs. Fre-
quently, the responsibility is not matched by the financial resources or political independence necessary
to accomplish the job. For example, the federal grant  program funding construction of municipal
sewage treatment plants is being phased out.  It  has been replaced with a program that encourages
financing of plant  construction through state revolving  loan funds. Establishment of these funds has
posed some difficult political and financial questions for both state and local governments. Problems
can be anticipated in implementing any new program or approach to pollution control; however, cur-
rent national management systems may not be flexible enough to respond to them.

 Lack of Analytical Techniques

    An additional  problem confronting federal and state water pollution control agencies is the slow
 pace in developing and using new scientific techniques to address broad water pollution problems. The
 less flexibility we have to focus on broad and complex priority problems, the more planning suffers be-
 cause local peculiarities cannot be  factored in. When new methodologies are not employed and
 problems are not approached on a watershed basis, it is difficult to determine not only impacts but also
 sources of pollution.
 September 1990                                                                   Page 115

Incorporation of Risk

   The current approach to water quality management exercised by EPA through its various program
offices should be revised to comprehensively address priority issues that focus on environmental as
well as human risks. Existing environmental programs generally focus on specific media such as air or
water and not on geographic regions. This does not make scientific or programmatic sense from a
watershed perspective and exacerbates the fragmentation of efforts, making it extremely difficult to
clearly define priorities, develop integrated solutions to pollution problems and carefully cany out
comprehensive strategic planning.
Impediments to Solving Problems
   The previously addressed problems resulted from the lack of a holistic watershed approach to
basinwide water quality management These issues can be characterized by the following deficiencies:

        • A fragmented approach to planning and management;

        • The lack of cumulative impact analysis on a watershed basis;

        • The lack of strategic planning;

        • Lack of connection between data collection and dedsionmaking; and

        • The lack of attention given to public outreach, education and public involvement.

Fragmented Approach to Planning and Management

   There are several layers of governmental responsibility that are often accompanied by an additional
layer of regional authorities. Because these political jurisdictions usually do not coincide with water-
shed boundaries, there are often conflicting management decisions. Clearly, there is a need for a nation-
al coordinating institution that would provide necessary connection and communication between the
layers of government

Lack of Cumulative Impact Analysis  on a Watershed Basis

    The majority of controls in point source permits are primarily based on achieving a certain con-
centration in the water at a specific site  instead of using a total pollutant loading analysis for the
tributary, river, or downstream lake or estuary. Downstream concentration or uses to be protected are
not considered and bioaccumulation of pollutants has not received the attention that it deserves.
 September 1990                                                               Page 116

Lack of Strategic Planning

   Environmental regulators axe often unable to anticipate present and future problems. Requirements
of laws have focused institutions' concentration on point source reduction rather than overall preven-
tion that would include waste  recycling, nonpoint source reduction and general waste control

Lack of Connection Between Data Collection and Decisionmaking

   Institutions fail to use existing information and regularly call for  more studies or plans before
making a decision that will result in action. In addition, data collection is not always timely and often
does not include the information needed for effective environmental management dedsionmaking.

Lack of Attention Given to Public Outreach, Education
and Public Involvement

   Environmental education curricula should be developed for all levels of education. An informed
public can provide the impetus for governmental action on water quality problems. For example, in the
Chesapeake Bay area, public involvement has not only forced government to take action on both
nutrient reduction and living resource restoration but also has carried the momentum between political
 September 1990                                                              Page

                                     APPENDIX G

Major Milestones in Federal Water Quality Legislation


Rivera and Hubon Act
   Water Pollution Control

   Federal Water Pollution
   Control Act

   Federal Water Pollution
   Control Act Amend

   Water Quality Act
   Federal Water Pollution
   Control Act Amaodmenu
   dean Water Act
          Prohibited discharge of refuse into waterways that would interfere with
          navigation without a permit from the U.S. Army Corps of Engineers

1948      Provided limited federal financial assistance to local governments for
          construction of municipal wastewater treatment facilities

1956      Increased federal financial assistance for municipal wastewater treatment

1961      Increased federal financial assistance for municipal wastewater treatment

1965      Required states to develop state water quality standards for interstate
          waters, and created the Federal Water Pollution Control Administration
          to establish broad guidelines and approve stale standards

          Increased federal financial assistance for municipal wastewater treatment

1972      Greatly increased federal financial assistance for municipal wastewater
          treatment facilities

          Instituted uniform technology-based effluent limitations for industrial
          dischargers and a national permit system for all point source dischargers

          Designated  the U.S. Army Corps of  Engineers as the  permitting
          authority over discharge of dredged or fill material into U.S. waters

1977      Encouraged states to accept delegation of the national permit system and
          assume management of the construction grants progiam

          Added control of priority toxic pollutants to the federal program
    Municipal  Waatewater
    TVeaunent  Construction
    Orant Amendments

    Food Security Act

    Water Quality Act
                           1981      Reduced federal financial assistance for municipal wastewater treatment
                           1985      Established erosion control programs for agricultural lands

                           1987      Phased out federal grants for construction of municipal wastewater
                                     treatment facilities; provided capitalization grants to state revolving

                                     Required EPA to develop regulations for stormwater runoff control

                                     Required states to prepare non-point source management programs
September 1990
                                                                                      Page 118

Major Milestones  in Federal Water Quality Legislation
Sato Drinking Water Act
Safe Drinking WIRY Act    1986
Required EPA to establish  national drinking water standards  and
regulations tat state underground injection control programs

Required EPA to establish drinking water standards for additional

Required states to establish wellhead protection programs to protect
    iground drinking water sources front contamination

Federal  Water Foliation
Control Act,
Marine  Protection.    1972
Research and Sanctuaries
National Ocean Pollution    1978
Planning Act
Water Quality Act
1961      Redefined interstate waters to include coastal waters

1972      Provided  federal  grants  to  coastal  slates  for  developing  and
          implementing state coastal zone management programs and plans

          Provided federal grants for state acquisition of estuarine sanctuaries

          Established a system to regulate dumping of materials into die oceans

          Authorized federal designation of marine sanctuaries through National
          Oceanographic and Atmospheric Administration (NOAA).

          Required NOAA to establish a comprehensive ocean pollution research
          and development and monitoring program

1987      Created  the  National Estuary Program to  develop  die-specific
          management plans for significant estuaries

Migratory Bird Hunting    1934
Stamp Act

Federal  Water  Pollution    1972
Control Act Amendments

Food Security Act           1985
 Emergency  Wetlands     1986
 Resources Act
          Authorized the sale of duck stamps to hunters to help fund federal
          acquisition of waterfowl habitat, primarily wetlands

          Required permits for discharge of dredged or fin material into U.S.
          waters, including wetlands

          Denied federal farm benefits to farmers harvesting an annual crop on
          converted wetlands

          Increased federal funding for wetlands acquisition and conservation
September 1990
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