linked States	Region 8	Office of
Environmental Protection	1860 Lincoln Street	Analysis and Evaluation
Agency	Denver, Colorado 80295	Januarv 1980
&EPA 208 Plan Certification
and Approval
Anaiysis and Status
of Pending PSans

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i). 17 I
Final
er
QOO}>
0*2-
208 PLAN CERTIFICATION AND APPROVAL:
STATUS AND ANALYSIS OF
PENDING PLANS
REGION VIII
Planning and Management Branch
Water Division
Office of Analysis and Evaluation
Management Division
January 1980
Prepared by

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TABLE OF CONTENTS
Acknowledgements	1
Summary of Conclusions and Recommendations	2
I.	INTRODUCTION	4
II.	BACKGROUND	4
III.	PROCEDURES	7
IV.	203 PLANS LACKING STATE CERTIFICATION OR EPA APPROVAL	7
A.	Background	7
B.	Unresolved Issues/Problems which are resulting in delays to Plan
Certification and Approval	12
C.	Implications for Continued Funding of 208 Agencies Lacking Plan
Certification or Approval	17
D.	Conclusions	19
E.	Recommended Actions	22
V. DETAILED ANALYSIS OF THE 208 PLAN APPROVAL PROCESS	24
A.	Background	24
B.	Reasons Cited for Delays	24
C.	Recommendations for Improving the Process	30
VI. APPENDICES
1.	Chronologies of 208 Plan Approvals	33
2.	208 Questionnaire on Plan Approvals	46
3. Typical Workload for a 208 Project Officer During Past Year & a Half..49

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Acknowledgements
This report was prepared jointly by the Planning and Management Branch
(Water Division) and the Office of Analysis and Evaluation. The Planning and
Management Branch provided information on 208 plan certification and
approvals, identified existing problems and recommended a course of action to
remedy the problems. Rick Claggett, Roger Dean, Doug Johnson, Mike Streiby,
Bruce Zander, and Pat Godsi 1 were the key individuals who provided this
information to the Office of Analysis and Evaluation. Terry Anderson of the
Office of Analysis and Evaluation was responsible for collating and analyzing
this information and making recommendations to the Program Office regarding
solutions and future program direction for them to consider. Terry Anderson
is the principal author of this report. Martha Nicodemus, Paul Ferraro, and
Pat Godsil provided editorial assistance.
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SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
Of twenty-eight (28) plans within Region VIII there are ten (10) that have
not been certified to EPA and five (5) others awaiting EPA approval. The most
significant reasons that these plans have not been approved are due to delays
resulting 1) from changes in 208 staff or 2) deficient draft 208 plans which
required many months to revise.
All of the outstanding plans though are expected to be conditionally
approved by EPA once they are completed and certified. Those 208 agencies
that have had a poor record in 208 planning are either voluntarily
relinquishing their 208 responsibilities or funding constraints are forcing
them to reduce or eliminate their involvement in 208 planning. Prior to
fiscal year 1979, there were no direct consequences of not having a certified
or an approved 208 plan. Today, the lack of certification and approval
results in the withholding or loss of 201 and/or 208 funds. Specific
recoircnendations for those plans lacking certification or approval are:
1.	A firm schedule should be developed in cooperation with each state as
to when 208 plans will be certified to EPA. This schedule should
provide the basis for formulating future regional positions in
respect to 208 funds.
2.	Region VIII should continue to implement the April 2, 1979 regional
policy which requires a 208 agency to have a certified plan in order
to expend FY 1979 funds.
3.	Region VIII should implement the FY 1980 funding policies and May 23,
1979 regulations as they affect the award and expenditure of future
208/201 funds. No 201 grants should be awarded to applicants not
covered by an approved 208 plan and no FY 1980 208 funds should be
awarded to 208 agencies lacking an approved 208 plan unless the
criteria for exceptions are satisfied.
4.	EPA should take no longer than 30 days to approve 208 plans once they
are certified.
5.	The Governor of Wyoming needs to be contacted and the implications of
not having plan certification and approval need to be explained to
him.
The only aspect of the 208 certification and approval process for which
EPA has complete responsibi 1 ity is approval of plans. As of January 1, 1980,
EPA had approved thirteen (13) plans. The average approval time per plan has
been 183 days. The 1975 regulations allowed EPA 120 days to approve a
certified plan once it was received by EPA. The 1979 regulations which
superseded the 1975 regulations allows EPA and the State 120 days to
concurrently review and certify the final plan. EPA has an additional 30 days
beyond the 120 days to complete its approval of the 208 plan.
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The most common reasons cited to explain the length of time taken to
approve a 208 plan are as follows:
1.	Lack of familiarity with a 208 plan within EPA after receiving a
certified plan.
2.	Approval of 208 plans were given lower priority than other activities.
3.	The individuals responsible to prepare approval letters experienced a
significant increase in workload about the time the plans were being
submitted to EPA for approval.
4.	Prior to Spring of 1979, no serious consequences resulted from not
having either a certified or an approved plan.
Due to the May 23, 1979 regulations, the following recommendations are
made in an attempt to comply with the 30 day period in which to approve a 208
plan once it is certified to EPA.
1.	The approval letter should be typed and ready to be routed for the
Regional Administrator's signature the day the certified plan is
received by EPA.
2.	Concurrences on the "final" approved letter should be restricted to
the program office, Division Director, Office of Legal Counsel, and
Regional Administrator's Office. All other concurrences should be
obtained on the "draft" approval letter.
3.	Once a pi an is being considered for certification, the program office
(Planning and Management Branch) should establish a schedule to
prepare the necessary approval letter and other concurrent activities
should be given lower priority.
4.	The Planning and Management Branch should revise its commitment to
review 201 facility plans and place more responsibility for these
reviews on 208 agencies that have approved 208 plans.
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I. Introduction
The 208 program is nearing completion of its first phase; that is,
developing plans which are certified by the State and approved by EPA. It has
been five and a half years since the first 208 agency received its initial
grant to develop a water quality management plan. Since its beginning, the
208 program has experienced numerous difficulties which tended to complicate
the implementation of the 208 program. This report focuses on those problems
associated with certification and approval of 208 plans.
II. Background
The first 208 plan to be certified and approved within Region VIII was
Pikes Peak's plan which was certified on February 10, 1977, and approved on
June 10, 1977. At the Regional 208 conference held in Salt Lake City during
February, 1977 plan certification and approval was discussed as a major agenda
topic. At this meeting, each of the states were encouraged to develop a
process to follow when certifying plans. At the time of the February meeting
all the states except Colorado had not given much thought to what is required
before the Governor could certify a plan. Also at the time, EPA was also
formulating its requirements for plan approval. The first program guidance
memorandum on review and approval of Water Quality Management Plans was issued
by Headquarters on August 8, 1977. The Region saw the need for each state to
formalize its certification process so in April/May 1977, a letter was sent to
each state requesting that such a process be formally established and
submitted to EPA for concurrence. 8y December 1978, all the states had
complied with this request. In March/April 1979, another letter was sent to
the states, this time pointing out EPA's concern that the statutory and
regulatory dates for certifying numerous plans had been exceeded. The 1972
FWPCA Amendments contemplated that plans would be certified to EPA within two
years after initiating plan development and that EPA would take action on
these plans within 120 days after receiving the certified plan. If strict
adherence to the Statute had been achieved, the last plan to be approved
within Region VIII would have occurred November 14, 1978. It was not until
the May 23, 1979 regulations were published that there was any incentive to
certify or approve 208 plans. Rather it was not until a plan was approved
that other programs (i.e., 201 and NPDES) would be affected by a 208 plan.
As of January 1, 1980, out of 28 plans in Region VIII, ten (10) have not
been certified by the State and five (5) others have not been approved by
EPA. The status of plan approvals and certification compare to the national
average is indicated below.
PLAN CERTIFICATION AND APPROVAL
(As of December 31, 1979)
Region VIII
Total Plans
Nati onal l.y
28
226
Number Certified
18
155
Percent
64
58
Number Approved
13
116
Percent
46
51
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This report discusses the status of these plans and identifies some of the
problems contributing to their lack of approval. The implications of not
having a certified or approved plan are also discussed in terms of its effect
on future 208 grant awards to these agencies. No detailed analysis was made
in this report regarding the success or failure of the plans or determining
the adequacy of planning agencies to continue 208 planning.
Another aspect of plan certification and approval discussed in this report
is the time required by the States and EPA to take action on 208 plans. Both
the States and EPA have taken more time to certify and approve plans than was
contemplated in the Statute and its subsequent regulations. This section of
the report discusses the problems frequently cited by project officers as to
why it has taken so long to approve a 208 plan, and recommendations for
correcting these problems are presented.
As Table 1 shows, EPA has invested $25.2 million in 208 planning within
Region VIII compared to a national investment of $366.5 million. Although
this report does not attempt to evaluate the effectiveness of the 203 program
in terms of its successes and failures, it does address a significant problem
that presently confronts the management of the 208 program within Region VIII
as well as nationally. That problem is the current lack of certified and
approved 208 plans and the time required to get through the certification and
approval process.
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TABLE I
FISCAL YEARS 1974-1980: SUMMARY OF 200 FUNDS
(1000's Dollars Unless Noted Otherwise)

FY '71
& '75
FY
'76
FY '
77
FY '78
FY '79
FY J00
TOTAL FY 74-01
National Appropriation
$163M

S53M
$14M
$69M

$30M
$37.5M
$366.5M
Basis of Allocation to Region
a

75/25 (Net)
85/15 (Gross)
70/30
(Gross)c
Needs
Nonpoint
Source Needs

Regional Allocation
12,939
(7.7%)
2,590 (4.7%)
659
(4.7%)
4,447
(6.44%)
2,009
l,756d
25,200 (6.9%)
Oasis of Distribution to States
a

a

b

70/30
(Gross)
Needs
Nonpo t nt
Source Needs

Col orado
1,212
(33.6%)
415
(16.5%)
280
(42.5%)
1,427
(32%)
762 (26.4%)
469 (26.7%)
7,565 (31.3%)
Montana
2,245
(17.9%)
600
(24.0%)
144
(21.9%)
710
(16%)
403 (13.9%)
302 (17.2%)
4,412 (18.1%)
North Dakota
400
(3.2%)
565
(22.6%)
20
(3.0%)
532
(12%)
225 (7.0%)
124 (7.0%)
1,066 (7.5%)
South Dakota
750
(6.0%)
466
.6 (10.6%)
27
(4.2%)
57/
(13%)
390 (13.5%)
376 (21,4%)
2,506 (10.7%)
Utah
4,097
(32.7%)
197
(7.8%)
140
(22.5%)
757
(17%)
668 (23.1%)
359 (20.4%)
6,226 (25.6%)
Wyomi ng
1,235
(9.8%)
347
(13.0%)
39
(5.9%)
401
(9%)
233 (8.0%)
	
2,255 (9.3%)
I nd i ans






35
(1%)
200 (7.2%)
71 (4.0%)
314 (1.2%)
55 (undistr ihi
'00 Funds)
a.	Funds were allocated on a first come first serve basis.
b.	Funds were distributed based on needs to maintain staff.
c.	AH but $11 million was distributed based on 70/30 formula.
d.	Proposed distribution awaiting approval from Headquarters. $51,750 of total has not bcc-n distributed.
tJOTC: Totals may not add up due to rounding and do not include State/local contribution for FY '7C> and following years (npprox. $/l.l million)-

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III. Procedures
This report is based on an extensive data gathering effort and numerous
interviews with staff in the Planning and Management Branch. The approach
followed in this analysis is twofold.
First, a chronology was compiled for each 208 project which documented key
decisions from the time the plan was drafted until it was approved. These
chronologies were prepared based on a complete search of the 208 files and
supplemented by information provided directly by each project officer. The
chronologies were used to document the length of time between key decision
points and to identify where possible delays occurred during the plan
certification and approval process. The chronologies can be found in Appendix
I and served as a significant data base for completing the analysis under
Chapter IV, "Detailed Analysis of the 208 Plan Approval Process."
A second part of the analysis involved numerous interviews with EPA Region
VIll's 208 staff and the use of a questionnaire on 208 plan approvals. Both
the questionnaire, which was completed by the 208 staff, and the interviews
provided the basis for the discussion found in Chapter III, "208 Plans State
Certification or EPA Approval," as well as Chapter IV.
As a result of the data gathering and analytical activities, several
recommendations were presented to and discussed with the Planning and
Management Branch. The recommendations presented in this report have been
endorsed by both the Planning and Management Branch and the Office of Analysis
and Evaluation.
IV. 208 Plans Lacking State Certification or EPA Approval
A. Background:
There are fifteen (15) 208 state and areawide plans as of January 1, 1980
which lack either State certification or EPA approval. In addition, there are
nine (9) plans for Indian Tribes which have not been approved by EPA. Table 2
lists each of the agencies falling into this category and when each agency
received its initial 208 grant. The following discussion focuses on the
areawide and statewide plans since they are the nearest to completion. A
subsequent report will discuss the Indian 203's in more detail. The May 23,
1979 regulations require EPA to approve the Indian 208 Plans. To date, no
Indian Plans have been submitted to EPA for approval. The upcoming report
will address what EPA approval of a Indian 208 means legally and what
procedures should be followed when approving such a plan.
Of the fifteen (15) areawide and statewide plans remaining to be approved,
five are in some stage of plan development. These five are the Colorado
Statewide; the Mid-Yellowstone Areawide; the Utah Statewide; the Southeast
Utah Areawide; and the Wyoming Statewide. All the others have been submitted
to the Governors for certification, except for Northwest Colorado, which has
been submitted to EPA for approval.

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TABLE 2
208 PLANS LACKING STATE CERTIFICATION
OR EPA APPROVAL
Date of	State
Agency	Initial Grant	Certification
Areawi de/Statewide
Colorado Statewide	6/03/76	No
NW Colorado COG	6/04/75	Yes
Colorado West Area COG	6/06/75	No
Montana Statewide	5/28/76	No
Mid Yel1owstone	6/04/75	No
SECOG, SD	6/06/75	Yes
NO Statewide	6/04/76	Yes
Lewis & Clark, ND	6/06/75	Yes
Utah Statewide	6/04/76	No
SE Utah AOG	5/21/75	No
Five County, UT	6/04/75	Yes
Wyoming Statewide	6/04/76	No
Powder River APO	6/06/75	No
SW Wyoming WQPA	6/06/75	No
Teton, CO 208	6/12/75	No
Indi ans
Three Affiliates Tribes, ND	9/28/79	N/A
Turtle Mountain, ND	9/27/79	N/A
Ft. Belknap, MT	1/23/77	N/A
Assiniboine, Sioux, MT	4/17/78	N/A
Northern Cheyenne, MT	9/28/78	N/A
Blackfeet, MT	1/23/77	N/A
Utes, Utah	9/16/79	N/A
Chippewa Cree, Rocky Boy, MT	1/23/77	N/A
Shoshone and Arapahoe, WY	9/28/79	N/A
EPA
Approval
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
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Three Wyoming areawide projects (Powder River, Southwest Wyoming, and
Teton Areawides) have been in the certification and approval process longer
than any of the other 208 plans. It has been 12 to 15 months since these
plans were submitted to the Governor for certification.
Several of the 208 planning agencies that were responsible for preparing
208 plans which are still awaiting state certification no longer are in the
business of 208 planning or have disbanded. The agencies that fall into this
category are Powder River and Southwest Wyoming; and Middle Yellowstone,
Montana. In addition to these agencies, the Colorado West Area COG and West
Oesert AOG in Utah are scheduled to discontinue their 208 activities within
another year.
Table 3 presents a complete history of how much and when 208 funds were
awarded to the 208 planning agencies lacking EPA approval of their plans. All
the grant awards made in June 1979 were done to obligate FY 1979 208 funds
prior to the end of June 1979. It is Region VIII's policy not to allow a 208
agency to use the FY 1979 208 dollars until that agency has a certified plan.
For the agencies listed in Table 3, Northwest Colorado COG is the only one
which has been authorized to be reimbursed for 208 activities using FY 1979
funds. This policy and its implications are discussed further later in this
report.
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TABLE 3
SUMMARY OF 208 GRANT AWARDS
MADE TO STATEWIDE AND AREAWIDE PLANNING AGENCIES
LACKING A CERTIFIED OR APPROVED PLAN
Agency
COLORADO
Colorado Statewide
Grant Award
Northwest Colorado
Colorado West
MONTANA
Montana Statewide
Mi ddl e-Yellowstone
NORTH DAKOTA
ND Statewide
Date
06-03-76
03-10-77
02-22-78
12-14-78
01-19-79
06-29-79
06-04-75
03-08-78
07-24-78
03-15-79
06-29-79
06-06-75
03-28-78
09-28-78
06-29-79
05-28-76
02-11-77
01-16-79
06-28-79
09-13-79
06-04-75
01-16-79
06 -04-76
02-11-77
12-29-77
12-22-78
06-29-79
Amount
$414,600
$20,000
$15,600
$215,500
$326,109
$227,492**
$1,219*301
$530,000
$14,644
$81,437
$39,563
$55,153
$720,797
$362,000
$14,200
$60,000
$42,150*
$478,350
$600,000
$59,900
$592,871
$200,250**
$24,750**
$1,477,771
$735,000
$16,125
$751,125
$564,000
$42,000
$20,000
$533,427
$168,750
$1,244,577
Lewis & Clark
06-06-75
$400,000
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TABLE 3 (Cont'd)
Agency	Grant Award
Date	Amount
SOUTH DAKOTA
SECOG	06-06-75	$375,000
UTAH
Utah Statewide	06-04-76	$189,300
01-19-79	$70,000
02-27-79	$52,400
05-25-79	$71,900
06-29-79	$259,108**
$642,708
Southeastern Utah	05-21-75	$380,000
08-22-78	$9,000
05-25-79	$41,998
06-29-79	$75,000*
$505,998
Five County	06-04-75	$380,000
11-29-78	'$30,742
03-13-79	$18,258
06-29-79 $29,900*
$455,900
WYOMING
Powder River	06-06-75	$415,000
01-13-78	$15,250
06-26-78	$2,850
09-24-79	- $9,287
$423,813
Southwestern	06-06-75	$450,000
05-23-78	$5,000
$455,000
Teton Co.	06-12-75	$370,000
03-22-78	$3,330
08-21-78	$1,450
$374,780
Wyoming Statewide	06-04-76	$346,899
11-17-78	$160,800
06-11-79	$236,140
06-29-79 $174,750**
$918,589
* Grant award conditioned to require that plan must be certified.
** Statewide 208 agency must have certified all areawide plans plus submitted
to EPA statewide plan for approval.
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B. Unresolved Issues and Problems which are Resulting in Delays to Plan
Certification and Approval:
The issues and problems surrounding each of the plans lacking EPA approval
or state certification are discussed separately below:
1.	Colorado Statewide - The statewide plan in Colorado is being prepared
in several segments. Separate technical plans are being prepared for
each that were not included under designated areawide plans. In
total, there will be ten (10) sub-plans comprising the technical
portion of the statewide plan. In addition to the technical plans,
there is a state framework plan which encompasses all the 208
planning areas, including areawides. All ten (10) of the technical
plans have been prepared in draft and the majority have been
revised. Public hearings have been held on all ten (10) plans and
six (6) of the ten (10) are presently being considered for
certification by the Water Quality Control Commission. The state
projects that the statewide plan will be completed and certified to
EPA in March of 1980. This differs from an earlier projected date of
June 1979. Based on a review of the draft technical plans and the
statewide framework plan, the 208 project officers do not have any
serious problems with the plans and believe they can be conditionally
approved. The length of time required to develop and submit a
certified statewide plan to EPA is a result of a combination of
factors most of which can be attributed to a lack of staff and funds
to develop ten (10) separate plans and oversee the development and
certification of six (6) areawide plans. Some of the plans are
fairly general and lack specificity. However, it is the opinion of
the regional 208 staff, that the nature of the problems and the areas
covered by these plans do not warrant a lot of detail. As Table 3
shows, $227,492 of FY 197 9 funds are being held awaiting plan
certifi cati on.
2.	Northwest Colorado COG - This plan has been certified and a final
approval letter has been routed to the Regional Administrator for
signature. EPA's approval is being held in abeyance pending the
resolution of a procedural question about the State's certification
of the plan. The State Court has ruled that the plan was certified
improperly and not in accordance with the State's Procedures Act.
The parties to the suit have requested clarification of the judge's
ruling, but clarification has not been provided. If the court's
position stands, EPA will not have a certified plan upon which to
take action. The Region's position at the present time is to keep
the plan and await a final resolution of the procedures issue. There
is no good estimate of when this issue will be resolved in that the
state is likely to appeal the case if the present ruling is not
changed. Another major issue regarding plan certification is the
designation of only general purpose governments as management
agencies. To date, EPA has accepted the Governor's designation of
general purpose governments as management agencies and have supported
the State's position on this issue. This issue is being re-evaluated
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by the Office of Regional Counsel with the purpose of deciding
whether or not the Region should continue to support the State.
EPA's approval of the plan is likely to trigger some lawsuits on this
issue. The extent of local authority in regard to regulating
transbasin diversion projects is also an issue. It is the opinion of
legal counsel this issue ultimately will be litigated as well.
3.	Colorado West Area COG - The plan has been submitted to the State to
be certified. The State intends to complete the Statewide plan prior
to certifying the Colorado West Area 208 plan. It is the opinion of
the State that the West Area Plan will not be implemented since the
primary emphasis of the plan was to establish an environmental data
baseline rather than to make many recommendations which will be
implemented in the future. The Council of Governments intends to
work on those 208 matters related to plan approval and
certification. The Council will terminate the 208 staff within a
year and transfer responsibility for 208 planning to the State. Much
of the time during the past two years have been idle or spent
revising the 208 document. During that time, two new project
directors have been hired and during the periods when the Council was
without a project officer, no work was accomplished on revising the
203 plan. The draft had several major deficiencies. For example,
the draft plan did not include any recommendations for management
agencies. The lack of staff combined with the need to make major
revisions to the plan has caused the lengthy delays in getting the
plan approved. As Table 3 indicates, $42,150 of FY 1979 funds are
being held pending plan certification.
4.	Montana Statewide - This plan is complete except for including a
section covering the Middle Yellowstone River Basin (see next
discussion). The Governor has had a certification letter to sign for
at least a month. The Montana Operations Office has prepared a draft
approval letter which will be transmitted to :fe Regional Office for
signature once the Statewide plan is certified. There are no
significant issues with the statewide plan, except for completing the
Middle Yellowstone portion of the plan which is discussed below. As
Table 3 shows, $225,000 dollars of FY 1979 funds are being held
pending certification of the plan.
5.	Middle Yellowstone - A draft plan was prepared in May/June of 1978.
The 208 staff resigned in August 1978 (due in part to EPA's funding
policies and associated job insecurity) and very little happened
until recently to revise the plan. The certification letter for the
Montana Statewide Plan includes an action to de-designate the Middle
Yellowstone 208 planning agency in addition to providing a schedule
for when it will be revised and submitted to EPA for approval. The
plan is currently being revised under contract and is scheduled to be
certifi ed i n June 1980.
6.	North Dakota Statewide - At the time this was being written, an
approval letter was being circulated for signature by the Regional
Administrator. The 208 Plan was generally good and no major
deficiencies were cited in the approval letter.
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7.	Lewis and CI ark - In September 1978, the Lewis and Clark planning
effort became part of the Statewide effort and the plan for this area
was submitted to EPA in conjunction with the Statewide Plan. EPA is
conditionally approving the plan concurrently with the Statewide
Plan. While the Lewis and Clark 208 was in business, EPA issued a
stop work order due to the problems meeting deadlines, poor quality
of work products, and staffing problems. The State provides the
Lewis and Clark 1805 Regional Council some pass through funds in
order to maintain a minimum support effort in respect to implementing
the plan for this area.
8.	SECQG, SD - Southeastern Council of Governments in South Dakota
became part of the Statewide program in June 1979. The State
provides some pass through funds to the Council to conduct a minimum
208 effort in the Sioux Falls area. Of the three plans prepared in
South Dakota, the SECOG plan was the weakest. A draft approval
letter had been prepared by EPA; and if signed would conditionally
approve this plan which is expected prior to the end of January 1980.
9.	Utah Statewi de - The plan has been drafted and presently is being
revised for two out of three areas (i.e., the Six County and West
Desert areas). The third area, Bear River, has been submitted for
certification which is expected by the end of January 1980. The
other two, the State hopes to certify to EPA by April 15, 1980. The
plans have been reviewed by EPA and comments provided to the State
and the delegated agency preparing the plan. Six County and West
Desert had the most deficiencies in the draft plans that were
submitted. A lack of water quality data in the West Desert area
prevented an in-depth study of the water quality problems in the
area. It is the opinion of EPA that the water quality problems are
not significant enough to require a detailed analysis. For this
reason, the West Desert area would be a low priority to receive
future 208 funds. The Bear River Plan has utilized the assistance of
the soil conservation districts to develop a non-site specific plan
for non-point sources. The lack of site specific information has
precluded the plan from containing recommendations for site specific
controls. This lack of data resulted in rejection of their
application for a rural clean water project. A major issue with the
State's effort in these three areas has been the lack of waste load
allocations for point sources.
10. Southeastern Utah - Five out of eight subbasin plans are completed
and awaiting state certification. The five plans are a vast
improvement over the earlier draft and provide a good basis for
building and implementing the 208 plan. Numerous problems, such as
inadequate staff, have plagued this 208 planning effort prior to the
addition of the new project director in May 1978. The completed plan
is expected by the end of February and should be certified to EPA
during March or April. No significant issues remain with the five
subbasin plans since their revision and EPA expects to conditionally
approve all eight subbasin plans once they are certified.
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11.	Five County AQG - The Five County 208 Plan has been certified and is
awaiti ng EPA approval which is due by the end of January 1980. The
AOG desires to continue work on a groundwater study. Other areas
that still need additional work in the Plan are: population
projections, problem assessment, and stream classifications.
12.	Wyoming Statewide - A draft 208 Plan has been prepared. The major
substantive issues identified in EPA's review will be dealt with in
EPA's conditional approval. The State has adopted an approach
identical to Colorado's regarding management agency designation.
Wyoming will be designating only general purpose governments as 201
management agencies. To date, no opposition has been voiced against
the state's proposed designation of management agencies. However,
this may become an issue similar in intensity to the management
agency issue in Colorado. The Statewide plan will be submitted to
the Wyoming Environmental Quality Council on January 20, 1980 for
their consideration and subsequently recommended to the governor for
certification. However, some problems exist with the level of detail
found in the plan. The plan presently lacks technical detail and is
process oriented. There is no definitive program of action to
correct specific water quality problems. One major recommendation of
the plan is to assign responsibility for future 208 planning
activities to local/regional units of government. The Wyoming
Department of Environmental Quality's 208 staff recently has resigned
and members of other programs are being used to fill the void. For
the past year, DEQ has not taken a leadership role in getting
areawide plans certified.
13.	Powder River - In 1975, a planning agency was formed specifically to
develop a 208 plan for Northeastern Wyoming. The planning agency
disbanded in March 1979 after having completed the task of developing
a pi an and submitting it to the Governor for certification. The plan
has some technical deficiencies and recommends special districts as
201 management agencies for all unincorporated townships. The latter
recommendation is in conflict with the recommendation in the
Statewide plan. The State is in the process of correcting some of
the deficiencies and will not accept the recommendation that special
districts be designated as 201 management agencies. Major issues
have not been surfaced or directly discussed with the Governor. The
State needs to prepare a certification letter and brief the Governor
on the issues. With no local or state 208 staff, no one is taking
the lead to expedite certification of the plan.
14.	Southwest Wyoming - The planning agency was formed in 1975 for the
purpose of developing a 208 plan to be submitted to the Governor for
certification. The agency dissolved in August 1978 after completing
its assignment. The state's review of the plan identified several
technical deficiencies in the plan, some of which the state has
corrected since the planning agency disbanded. The state's
certification is expected to contain numerous conditions especially
in the area of salinity control, water quality standards, and stream
classifications. Most of the plan's recommendations in these areas
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dealt with matters over which the State has jurisdiction and
therefore, are being conditioned pending further documentation and/or
formal adoption by the appropriate State agency under a separate
procedure. The State needs to actively pursue certification of this
pi an.
15. Teton County - Of the three areawide plans prepared within Wyoming,
Teton County's is the best. Unlike the other two areawides, Teton
County is maintaining a minimum staff to follow through on
implementation of the plan. This position is being supported
entirely with local funds. The Wyoming Department of Environmental
Quality has completed a detailed evaluation of the plan and is
recommending to the Governor that it be certified with conditions.
The certification letter needs to be written and significance of the
proposed conditions need to be discussed with the Governor. Numerous
recommendations in the plan have been implemented, an example of
which is developing a self supporting 208 position.
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C. Implications for Continued Funding of 208 Agencies Lacking Plan
Certification or Approval:
The regulations dealing with plan certification and approval changed under
the May 23, 1979 regulations. Prior to publication of the May 23, 1979
Federal Register, the regulations did not specify any timeframe for a state to
take action on a plan once the plan was submitted for certification. Neither
did the preceding regulations provide EPA with any sanctions it could impose
on a state if a state did not certify a plan in a timely fashion. The May 23,
1979 regulations provide EPA with some leverage when dealing with the states
about certification and also specify that the states must take action on a
plan within 120 days of its submittal for certification. The prior
regulations allowed EPA 120 days to approve a plan once a certified plan was
received by EPA. Under the new regulations, EPA and the State have 120 days
for concurrent review and EPA has 30 additional days to take action on the
pi an.
The May 1979 regulations established a more rigorous set of requirements
for plan certification and provided EPA with a set of actions it could take if
plans were not certified to EPA within a specified timeframe. Paragraph
35-1523-3(c) of the regulations states: "Where the Regional Administrator
determines that the Governor has failed without good cause to meet in a timely
manner the certification requirements of paragraph (a), the Regional
Administrator shall withhold an appropriate portion of funds otherwise
available to the State under this subpart pending compliance with the
requirements, and may suspend or terminate current funding in accordance with
30.915 (stop work orders) and 30.920 (terminations) of this chapter."
The May 23, 1979 regulations also require the Regional Administrator .to
withhold 201 funds (regardless of step) if the applicant requesting 201 funds
is not covered by an approved plan. Table 4 shows which 201 grants may be
affected by this regulation (about $2.8 million).
In addition to the regulations, EPA has issued several policy papers which
also provide the Regional Office with specific guidance and requirements to
deal with states which are delinquent in certifying plans. The FY 79-80 208
Funding Policy developed by EPA, Region VIII and signed by Alan Merson, April
2, 1979, stated that FY 1979 208 "funds will be obligated to Areawide Agencies
only if they have a certified plan" and to a State 208 agency only if it has
certified all the areawide plans and submitted to EPA a certified Statewide
plan for review. An exception is made for agencies having submitted a plan to
the State and the State has not provided good reason for not having certified
the Plan to EPA. The August 16, 1979 "Policy and Procedure for FY 80 Section
208 Funds, (Information Memo 79-100) states that no agency will be eligible to
receive FY 80 208 funds unless it has an approved 208 plan. This is national
policy and is reiterated in more recent policy memos as well. A recent policy
memo received December 26, 1979, states that the region must obligate all its
FY 1980 funds by May 2, 1980, and that all unobligated '80 funds will revert
to Headquarters for re-obligation.
The asterisked grant awards found in Table 3 on pages 8 and 9 show what
amounts of FY 1979 funds cannot be used agency by agency due to the regional
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TABLE 4
CONSTRUCTION GRANT APPLICATIONS PENDING WHICH
MAY BE AFFECTED BY THE LACK OF 208 PLAN APPROVAL
(as of December 31, 1979)
State/Community	Step	Amount Requested
Colorado
Durango	2	570,000
Granby	<_	10,275
Grand Junction	3	3,146,250
Rifle	2-«3	1,152,045
Salida	2	153,600
Upper Eagle	3	954,750
Total	5,986,920
Montana
Chester	2	10,500
Nortn Uakota
19 Step i's	233,585
South Dakota
Renner	3	757,500
Utah
Castle Valley	1	10,500
Wyomi ng
Buffalo	1	483,750
GreybulI	1	23,925
Kaycee	1	18,750
Yoder	2+3	367,900
Total	894 ,i75
TOTAL	6,SS9,005
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policy. The total amount of FY 1973 funds unavailable for use by these
agencies equals about $1 million. In addition, there is a potential of
$711,000 of FY 1980 funds which may be affected Dy these policies ^CO -
$291,000; MT - 5285,000; and Utah - $35,000).
In addition to the above funding constraints, the May 23, 1979 regulations
state: "After fiscal year 1979, no funds under section 208 of the Act will be
available to any planning agency which developed a certified and approved
plan, uniess a significant portion of the plan is being implemented." The
Planning and Management Branch ranked all the 208 agencies based on the
project officers' evaluation of the degree to which agencies had implemented
tneir 208 plans regardless of their certification and approval status. The
agencies were ranked into three groups: 1) those agencies having implemented
a large number of items in relationship to all other plans, 2) those agencies
having implemented an average number of items in relationship to all other
plans and 3) those agencies having implemented the fewest number of items in
relationship to all other plans. The results of this ranking are shown in
Table 5 and represents another factor that must be considered before awarding
FY 1980 grants.
In surrmary, failure of a state to certify a 208 plan can result in a loss
of, or a aelay in receiving 208 or 201 funds.
D. Conclusions
1.	Assuming that Region VIII is allocated its request of $1,756,000 of FY
1980 208 funds, there are at least $1.7 million of FY 1979 and 80 funds in
jeopardy of being held indefinitely while waiting for the outstanding 208
plans to be certified and approved.
2.	The quality of each 208 plan varies from agency to agency and is
dependent upon numerous factors. An evaluation of the quality of 208
plans in relationship to these factors may be the subject of a future
study but such an evaluation is not within the scope of this report. The
major conclusion derived in this study regarding the quality of the
outstanding plans is that in the opinion of the responsible project
officer, each of these plans can be approved with conditions. The
relative quality of each plan is just one factor each project officer
considers when determining a planning agency's standing in terms of
receiving future 208 funcing. However, a good planning product, when
combined with implementation, usually results in a higher priority to
receive 208 funds.
3.	Prior to the May 23, 1979 regulations and recent policy memos, EPA did
not have many options when considering what action to take against a state
that was delinquent in certifying plans to EPA. These policies and
regulations now make it mandatory for EPA to withhold future 208 funds
pending certification and approval of a 208 plan. This is currently a
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major issue with the Wyoming Department of Environmental Quality which has
been negligent in taking the initiative to get areawide 208 plans
approved. Little hao happened since April 1979 regarding certification of
these plans.
4.	The major reasons for delays in certifying or approving 208 plans fall
into two categories: 1) problems with staff or 2) major deficiencies in
the draft plan submitted to EPA for review.
5.	Of the ten (10) uncertified plans, four of tne agencies responsible for
preparing these plans have either disbanded, discontinued their role in
203 planning, or intend to terminate their involvement in the 208
program. Several other local agencies that contributed to the development
of Statewide plans also are no longer active in 203 planning.
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TABLE 5
RESULTS OF PLANNING AND MANAGEMENT BRANCH'S RANKING
OF 208 AGENCIES' DEGREE OF PLAN IMPLEMENTATION
Agencies Well Above Average in terms of Implementation of 208 Plans:
Northwest Colorado*
Larimer-Weld, CO
Pueblo, CO
Pikes Peak, Cu
Montana Statewide - Lewis and Clark SCD**
South Dakota Statewide - DWNR
Salt Lake County, UT
Weber River, UT
Mountainland, UT
Teton County, WY**
Agencies Near the Norm in terms of Implementation of 208 Plans
Colorado Statewide - WQCD, SCD, Districts 9 & 10**
DRCOG, CO
Montana Statewide - WQB, DNR**
Blue Ribbons, MT
Flathead, MT
6th District, SD
South Dakota Statewide - SCC
Utah Statewide - Dept. of Ag., Bear River**
Southeastern Utah**
Uintah, UT
Five County, UT*
Agencies Below Average in terms of Implementation of 208 Plan
Colorado Statewide - Districts 8 & 13**
Colorado West, CO**
Middle Yellowstone, MT**
Yellowstone Tongue, MT
North Dakota Statewide - Health Dept. and Conservation Commission*
Lewis and Clark, ND*
SECOG, SD*
Wyoming Statewide - DEQ, Powder, Southwestern Big Horn**
Utah Statewide - uept. of Health, West Desert, 6 County**
* Plan certified but not approved.
** Plan not certified
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E. Recommended Actions
General Recommendations:
1.	A firm schedule should be developed in cooperation with each state as
to when 208 plans will be certified to EPA. Table 6 represents the best
available information on when plans will be certified, but these dates
should be confirmed with the State. This schedule should provide a basis
for formulating future 208 policy within Region VIII.
2.	Region VIII snould continue to implement the April 2, 1979 funding
policy. EPA should exercise its right to withdraw funds from an agency if
the status quo in terms of plan certification continues.
3.	Region VIII should implement the FY 1980 funding policies and May 23,
1979 regulations as they affect the award and expenditure of FY 1980
funds. The states should be advised that EPA will not accept any new
applications for 201 grants or process existing 201 grants for those
applicants not included in the approved 208 Plan. EPA should notify each
State and areawide agency that after June 30, 1980, FY 1980 funds that
have been awarded to 208 agencies and which are conditioned on receiving
208 Plan approval will be withdrawn. The only exception to withdrawing
the the FY 1980 208 funds as of June 30, 1980 is if EPA fails to approve a
plan within 30 days after receiving the certification. Implementation of
this policy requires that states certify plans to EPA by no later than May
31, 1980.
4.	EPA should take no longer than 30 days to approve a certified plan once
it is received by the Regional Office. The next chapter recommends
several changes in EPA1s approval process which need to be implemented as
part of this reconmendation.
Specific Recommendation:
Wyoming - A letter should be prepared and sent to the Governor of Wyoming
which informs him of the certification problems in Wyoming and describes the
ramification of not having certified and approved 208 plans. The letter
should inform the Governor that the EPA/Wyoming IPA agreement will be
terminated in June 1980 and suggest that the remainder of the IPA's time in
Wyoming could be used to help resolve this problem.
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TABLE 6
PROJECTED SCHEDULE FOR PLAN CERTIFICATION
Colorado Statewide
Colorado West
Montana Statewide
Middle Yellowstone
Utah Statewide
SE Utah
Wyoming Statewide
(including 3 areawide plans)
March 1980
March 31, 1980*
end of January 1980
early June 1980**
April 15, 1980
March 1980**
May 1, 1980***
* 120 days from date submitted to state for certification.
** These dates are based on the project officer's best judgement as the State
was not conmitted to a firm data.
*** Commitment date in 1980 State/EPA agreement.
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V. Detailed Analysis of the 208 Plan Approval Process
A.	Background:
Through January 1, 1980, the average amount of time EPA spent on plan
approval was i67 days per project, or about six months. This is also the
average amount of time each state spent on plan certification if Wyoming is
excluded. Nine (9) out of the thirteen (13) plans approved by EPA as of
January 1, 1980 required more than the 120 days allowed by the November 28,
1975 regulations. This amount of time is especially critical in light of the
May 23, 1979 regulations which now allow EPA 30 days to take action on a plan
after it is certified. Of the five plans in the approval process as of
January 1, 1980, four had already exceeded the 120 day requirement and the
other one will have been in the office 30 days as of January 11, 1S80. Table
7 summarizes the time taken by EPA to approve 208 plans. Table 8 compares
EPA's experience with the time taken bv the states to certify plans and also
the time taken by 208 planning agencies to go from a draft plan to a final
p I an.
B.	Reasons Cited for Delays:
The following reasons were the most coimion ones provided by project
officers to explain the extra time required to approve a 208 plan.
1.	Lack of familiarity with the 208 plan at all organizational levels
within the Regional Office once the certified plan was received.
Changes in project officers of numerous 208 projects during the
time the plan was being certified created delays as the newer
project officer needed time to become familiar with the plans. In
addition, the eighteen (18) month average time to go from a draft
plan to certified plan required the 208 review teams and project
officers to refami 1iarize themselves with the Plan. Supervisors
and other senior managers required special briefing sessions to
become familiar with a plan even after the approval letter was
circulated for concurrence. This is evidenced by the fact that for
some plans, up to 40 days were required to get concurrences on the
approval letter.
2.	Plan approvals were given lower priority than other Branch,
Division, or EPA activities. Activities which frequently took
precedent over plan approvals were 1) processing and awarding
106/208 grants, 2) developing regional 208 funding policies and
plans, 3) 201 facility p 1 a.i reviews, 4) State/EPA agreements, 5)
water quality 5 year needs assessment, 6) approval of population
projections, 7) RCWP activities, and 8) National Urban Runoff
Projects (NURP). After Zero Based Budgeting for FY 79 and 80, the
Enforcement and Surveillance and Analysis Divisions were cut
sharply in terms of the resources they could devote to 208 plan
review and which was reflected in a five position cut in the
Planning and Management Branch's decision unit. Consequently, 203
plan review and approval were given lower priority in these
divisions as we'll as within the Planning and Management ciranch.
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TABLE 7
APPROVAL TIME
Agency
Colo. Statewide
Pikes Peak
Denver
Larimer/We Id
Pueblo Area
NW Colorado
Colorado West
Montana Statewide
Flathead Drainage
Mid-Yellowstone
Yellowstone/
Tongue
Blue Ribbons
ND Statewide
Lewis & Clark RCD
SD Statewide
6th District
SECOG
Utah Statewide
Mountainland
Weber River
Salt Lake County
S.E. Utah
Uintah Basin
Five County
Wyoming Statewide
Powder River
SW Wyoming
Teton Co.
Date
Certified
Plan Recv'd
2/10/77
1/13/78
2/23/79
11/14/78
6/28/79
Date of
EPA
Approval
6/10/77
8/5/78
5/16/79
1/24/78
In Process
8/17/79	11/5/79
to be de-designated
8/17/79
8/17/79
7/24/79
7/24/79
11/14/78
11/14/78
11/14/78
8/31/78
1/20/78
4/30/79
11/22/78
12/12/79
12/26/79
12/26/79
In Process
In Process
8/28/79
10/18/79
In Process
3/23/79
5/H/79
12/11/79
10/02/79
In Process
Plan Approval
Time
92a
100 b
82
71
186*
80
132
132
160
160
216 c
347
421*
204
172
225
314
20*
* Number of days in process as of January 1, 1980
Average Time Per Plan (excludes those in process) = 167 days
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TABLE 7 (Cont'd)
ADJUSTMENTS TO PLAN APPROVAL TIME
Footnotes:
a.	DRCOG
1.	EIS preparation time (time from certification date
to EIS publication date = 88 days)
Minimum estimated increase in processing time to
EIS preparation	44 days
2.	Comment period (60 days)
Estimated increase in processing time due to comment
period	60 days
3.	Time from end of comment period to notice of final
EIS action (56 days)
Estimated increase in processing time is accounted 0 days
for under b. Note: This time would have been re-
quired regardless. Its occurrence was shifted from
earlier in the process to later in the process		
Total Estimated Time Savings	104 days
4.	Adjusted Processing Time 204 - 104 =	100 days
b.	Pikes Peak
1.	EIS preparation time (7 days)
2.	Comment period (50 days)
3.	Estimated potential time savings 50% of 57 days =	28 days
4.	Adjusted Processing Time 120 - 28 =	92 days
c.	South Dakota Statewide
1.	Certification received 11/14/78
2.	Plan received 2/2/79
3.	Adjusted Processing Time 296 - 80 =	216 days
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TABLE 8
TIME BETWEEN DECISION POINTS
Draft Plan
Final Plan To
To Final Plan Certified Plan
Certified Concurrence
Plan To
Approval
Letter
Time On
Approval
Letter
COLORADO
Colorado Statewide
Pikes Peak
Denver
Larimer/Weld
Pueblo
NW Colorado
Colorado West
3	months
8	months
5	months
11	months
10	months
17	months
6 months
1 month
months
months
months
4 months
6 months
2	months
1 month
3	months
1	day
14	days
15	days
31	days
1.5 months3
MONTANA
Montana Statewide
F1athead
Mi d-Yeli owstone
Yellowstone Tongue
Blue Ribbons
NORTH DAKOTA
ND Statewide
Lewis & Clark
SOUTH DAKOTA
SD Statewide
6th District
SECOG
UTAH
Utah Statewide
Mountainland
Weber River
Salt Lake County
SE Utah
Uintah
Five County
WYOMING
Wyoming Statewide
Powder River
SW Wyoming
Teton County
7.5 months
21 months3
5 months
18 months
2 months
14 months
2 months
14	months
30 months
4 months
15	months
13 months
11	months
12	months
18 months
12 months
1 month
5 months
1.5 months
7 months
11 months
S.5 months
14 months
5 months
.5 month
1. months
8 months
12 months3
15 months3
12 months3
Average Time/Project 11 months	7 months
a. Time in process as of January 1, 1980
2.5 months
4 months
4 months
4.5 months
4.5 months
8.5 months
11 months
8.5 months
5.5 months
6 months
9.5 months
5 months
41 days
41 days
35 days
8 days
25 days
33 days
35 days
3 days
26 days
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3.	Project officers experienced an increase in workload after June/July
1978, thus reducing the amount of time they could devote to plan
approvals. The number of project officers for the 208/106 programs
was at a high of eleven people during 1977. This number has been
recently reduced to six including the Montana Operations Office. The
reduction work force in combination with increased responsibi Iity for
each project officer has inevitably led to some delays in plan
approvals. The increase in responsibility for each project officer
resulted when 106 and 208 statewide project officer duties were added
to the existing responsibilities of areawide project officers, a
typical workload for project officer is attached as Appendix 3. It
identifies the major activities which a project officer was involved
in during a year and a half period.
Within the last month, two senior staff members have taken other
positions within Region VIII. It is anticipated that these vacancies
will not be filled with experienced individuals. Time to fill
vacancies within the Planning and Management Branch has been a
problem in the last two years with some positions being vacant up to
six months or longer. In the spring and summer of 1978 both section
supervisors left the program to fill other positions within the
Regional Office. The change in staff vacancies during recent years
combined with the inability to fill vacancies quickly has added to
the overall workload problem confronting the Branch. Another project
officer is expected to be lost during the next two months, as well.
4.	Generally, the consequences of missing mandatory approval dates are
slight and slippage did not hinder the operation of other Regional
programs. NPQES permits have been issued with or without approved
208 plans. Often, interim outputs sufficed to satisfy agency demands
especially in the area of population projections to be used in the
preparation of 208 facilities plans. Until recently, the major
effect that 208 plans had on the NPDES and 201 programs occurred
after plan approval. The exception was the Rural Clean Water
Program, which depended upon plan approval before RCWP funds could be
used under a RCWP project. In the case of the RCWP, plans have been
approved in a timely fashion to allow the expenditure of RCWP funds
within Region VIII. Since October 1, 1975, an approved 208 plan has
been made a prerequisite to receiving a 201 grant. However, within
Region VIII, eleven 201 grants have been awarded to communities which
did not have an approved 208 plan (see Table S). This problem is
presently being corrected as the Water Division is notifying each
State of this requirement and will not award 201 grants to areas
lacking an approved 208 plan unless the criteria for an exception are
satisfied. Of the eleven projects awarded without an approved 208
plan, all eleven satisfy the criteria and the Office of Awards and
Grants Adminstration is checking to make sure the reasons for the
exceptions are documented.
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Table 9
CONSTRUCTION GRANT AWARDS SINCE OCTOBER 1, 1979*
Community/State
Idaho Springs, CO
Pueblo, CO
Big Timber, MT
Roman, MT
Shelby, hT
(lob ridge, SD
Rapid City, SD
Ravinia, SD
Spearrish, SD
Springdale, LIT
Bryon, WY
Evanston, WY
Guernsey, WY
Lusk, WY
Manaerson, WY
Mills, WY
Rancnester, WY
Step
3(cont1d)
2+3(cont'd)
2+3
1
2(cont'd)
3
2(cont'd)
2(cont'd)
3(cont'd)
Amount
37,500
1,647,000
247,800
418,020
9,075
12,900
331,725
12,375
1,800
581,820
26,385
30,600
25,455
18,300
12,000
117,600
27,750
Date Awarded
11/27/79
10/30/79
11/20/79
11/26/79
11/23/79
11/27/79
11/27/79
11/29/79
11/29/79
11/29/79
208 Plan Apprv'd
Prior to Awardb
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
Grant increases are not included in this list since they do not
constitute a new grant award.
All the comnunities receiving grants without being covered by an
approved 208 Plan are allowed to do so if the "Regional
Auministrator determines in writing that the facility related
information was not within the scope of the WQM work program or
that the award of the 201 grant is necessary to achieve water
quality goals." (35.1533-(b)(1). This determination was not made,
in writing, for the above grants.
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C. Recommendations for Improving the Plan Approval Process
Several things can be done to improve EPA1s performance in reducing the
approval time for the ten plans yet to be certified.
1.	The approval letter should be typed and ready to be routed for
signature the day the certified plan is received by EPA. In order to
stay within the existing 30 day limitation set forth in the May 23
regulations, the approval letter must be prepared prior to receiving
the certification letter. Project officers should be responsible to
prepare this letter by working jointly with the state as the plan is
being certified. Where a state will not cooperate with EPA, the plan
by itself should serve as a basis for preparing the approval letter.
If possible, a draft copy of the certification letter should be
obtained from the State by the project officer to minimize the need
to make last minute changes in EPA's approval of the plan. If this
procedure were followed for example, approval letters could have been
written for all the Wyoming designated areawide plans by now with or
without the cooperation of Wyoming.
Approval of statewide plans is a different matter. It is
imperative that the project officer keep abreast of the status of
plan preparation and certification. It is advisable that a draft
approval letter be initiated shortly after reviewing the draft of the
Statewide plan and that EPA's review letter of the draft plan be
written in the format used for approval letters.
2.	Concurrences on the "final" approval letter should be restricted to
tn-.? program office, Division Director, Office of Legal Counsel, and
RA's Office. All other concurrences should be obtained on the
"draft" approval letter following the same process used by the Office
of Awards and Grants Administration. The "draft" approval letter
should be routed to all program offices, including those offices that
the final letter will be routed for concurrence, for the purpose of
receiving comments and preliminary concurrence. Once a final
approval letter is routed for concurrence, no changes to the letter
should be necessary. Clarification of specific points in the letter
should be obtained when the "draft" is circulated for review. Only
changes suggested during the review of the draft approval should be
reflected in the final version and all other comments received after
the comment period on the draft closes should be ignored. Those
offices that have concurrence only on the draft letter should note
appropriate changes on the draft. It is the responsibility of the
project officer to incorporate changes into the final and to resolve
any differences that may exist between offices.
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3. The program office should adopt a schedule for plan approvals which
takes priority over all other concurrent activities. Plan approvals
are important to the award of 106/201/208 grants, issuing NPDES
permits, and awarding RCWP grants. Consequently, priority should be
given to approving 208 plans by the Planning and Management Branch.
Opportunity should be given to other program offices to provide input
to the P & M Branch regarding plan approval. However, the P & M
Branch should be under no obligation to consider comments if they are
received after the established time frame. The following is a
reconmended time frame for completing the several steps of approving
a p 1 an:
-	After a plan is submitted to the state to be certified, solicit
a schedule from the state which identifies when the draft and
final certification letters will be prepared.
-	Circulate final plan internally within EPA for final review and
receive comments (allow two weeks).
-	Prepare draft approval letter (allow two weeks).
-	Circulate the draft approval letter internally within EPA and
receive comments and concurrences. A copy of draft approval
letter should be sent to State as well (allow two weeks).
-	Solicit and obtain a copy of draft certification letter from the
state when available.
-	Prepare final approval letter (allow one week).
-	Keceive certification from the state.
-	Route approval letter for signature (allow one week).
A specific schedule can be developed based on the schedule
adopted by the state. For example, for Teton County the scnedule
might have been:
2/01/79 -	Final plan circulated and review requested.
2/15/79 -	Comment period on final plan closed.
3/03/79 -	Draft approval letter circulated for comment.
3/17/79 -	Comment period on draft approval letter closed.
4/08/79 -	Received draft certification letter from state.
4/15/79 -	Final approval letter prepared.
5/01/79 -	Certification of plan received by EPA.
5/08/79 - Approval letter signed.
The supervisor is responsible to work out a schedule with each
project officer once a plan is being considered for certification.
The supervisor needs to be conscious of this schedule and not make
priority time consuming assignments to a project officer during
periods when the project officer is assigned to work on approving 208
p1ans.
The states may not like EPA preparing its approval letter while
the state is developing its certification letter. However, EPA has
no cnoice if it is going to comply with the May 23, 1979, regulations
and the states must understand that the certification/approval
process must be a joint process, or that EPA will be forced to
prepare its approval letter without the benefit of state input.
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4. Planning and Management Branch needs to revise the commitment to
review jQl facility plansT In the past, some 208 project officers
have spent as much as 0.4 my of effort working on Step 1 facility
plans. Colorado and Utah historically have had the most problems
which required input from the Planning and Management Branch to
resolve. The implementation of the 205(g) agreements in Montana,
South Dakota, and Wyoming, now assign responsibi iity for facility
plan review to these states respectively. EPA still retains
responsibility to review each facility plan for compliance with NEPA
which is the responsibi1ity of the Environmental Evaluation Branch.
In addition, EPA conducts a full review of 20 percent of the facility
plans. Wnat this means in terms of workload for the P & M Branch is
that for example, out of 25 Step l's being reviewed in South Dakota
only five would require review by EPA. However, these five will
generally be the facility plans with the most problems Consequently,
a 80 percent reduction in EPA's workload will not be realized.
Colorado, Nortri Dakota, and Utah are committed to assume
responsibility for facility plan review and approval in the first
quarter of FY 1S81, third or fourth quarter of FY 1980 and the second
quarter of FY 1980, respectively. The Planning and Management Plan
should entertain the possibility of reviewing only 20 percent of
facility plans immediately with these states as well by relying more
on the reviews of 208 agencies that have approved 208 plans. Under
the regulations agencies that have approved 208 plans also have the
responsibi1ity to conduct a review of facilities plans within their
jurisdiction to determine if the facility plan conforms to the
approved 208 plan.
The way this can be accomplished is by executing agreements with
each of the active 208 agencies that have approved 208 plans to
transfer some of this responsibility from EPA to the 208 agency. For
state agencies having 201 facility plan review and approval
responsibi1ity under 205(g), such an agreement is not necessary.
Where States refuse to use local 208 agencies to review Step 1 plans
for conformance with 208 plans, the States need to understand that
they have full responsibility for the 201/208 conformance review.
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APPENDIX I
Chronology of Key Events for Plans not yet certified/approved
- Chronology of Key Events for Plans which have been approved
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COLORADO PLANS NUT YET CERTIFIED/APPROVED
COLORADO STATEWIDE 208 PLAN
04/07/78	Draft plan received by EPA
07/26/78	EPA comments on draft plan provided to Northwest
02/20/79	Final plan received by EPA
06/25/79	Plan certified by State
06/28/79	Certified plan received by EPA
09/17/79	State letter clarifying certain points of certification
letter sent to EPA
09/21/79	EPA approval letter circulated for signature
10/01/79	Concurred on by Water Division
Letter being held in Office of Regional Counsel pending
result of court case
COLORADO WEST 208 PLAN
02/16/77	Preliminary plan received by EPA for comment
05/20/79	EPn conments on preliminary plan sent to COG
05/08/78	Draft 208 plan received by EPA for comment
06/07/79	EPA comments on draft plan sent to COG
10/16/79	Final plan submitted to State for certification
02/13/79	Data by which plan must be certified to EPA (120 days from
10/16/79 assuming this is the date the plan was received by
the State)
03/15/79	Date by which EPA must take action on the plan
Appendix 1-A
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MONTANA PLANS NOT YET CERTIFIED/APPROVED
MONTANA STATEWIDE
08/16/79
11/27/79
01/31/80
03/03/80
03/03/78
05/15/78
8/78
12/78-4/79
01/31/79
06/01/80
Draft Report printed and distributed for review
Final Report completed
Anticipated certification date
30 days after certification date (date by which EPa needs
to take action)
MIDDLE YELLOWSTONE
Draft Report printed and distributed for comment
InLernal memo transmitted requesting review of executive
summary
Resignation of 208 staff
Series of meetings with State and MYAPU to discuss
possibility of resurrecting planning effort at local level
Expected date by which contract to revise Middle
Yellowstone plan will be signed
Plan certified ana submitted to EPA as an addendum to
Statewide Plan.
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SOUTH DAKOTA PLANS NOT YET CERTIFIED/'APPROVED
SOUTHEASTERN COG 208 PLAN
SECOG 208 PLAN
10/11/77	Preliminary 208 Plan submitted for review
11/29/77	EPa comments provided to SECOG on preliminary 208 plan
12/77	Volume III - Final 208 Plan printed and distributed by SECOG
01/11/78	Ehh internal memo requesting review of final Plan
02/08/78	Internal EPA meeting held to discuss Plan (no formal
ccrments were provided to SECOG as a result of the review
of the final document)
11/14/78	Certification letter received by EPA. EPA draft approval
letter prepared and distributed for comment. Anticipate
approval letter by the end of January
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UTAH PLANS NOT YET CERTIFIED/APPROVED
04/79
04/17/79
05/04/79
06/02/79
08/16/79
12/07/79
06/77
07/77
05/78
01/80
08/77
08/24/77
09/14/77
10/18/77
10/27/77
01/78
02/21/78
02/23/78
02/28/78
04/(3-6)/78
04/79
04/79
06/79
12/12/79
12/79
UTAH STATEWIDE 208 PLAN
Draft partial plan received by EPA for review
EPA internal memo requesting review of draft plan
EPA acknowledged receipt of partial draft plan and
requested time frame for
submitted
EPA comments provided to
EPA comments provided to
EPA comments provided to
when remainder of plan would be
the State on Bear River portion
the State on West Desert portion
the State on 6 County portion
submitted to
a revision
SE UTAH 208 PLAN
EPA review of draft 208 documents completed
Project Director resigns
New Project Director on board and supplemental grants made
to update and revise 208 Plan.
Five out of eight subbasin plans completed and
EPA (these are entirely new documents not just
of draft reports).
FIVE COUNTY 208 PLAN
Initial draft Plan received by EPA for review including
summary document
EPA internal memo requesting 208 Team to review draft Plan
EPA commented on Land Use document
EPA corrmented on Facilities document
lPA commented on Water Quality Management Phase document
Second draft submitted to the State and EPA for review
EPA commented on Water Quality document
EPA conment letter requesting air quality impacts be
included as part of the Plan
Headquarters assisted review of draft Plan completed
EPA held meeting in St. George to discuss MPS portions of
the Plan with the SCS & SCDS, and to provide oral comments
on entire Water Quality Management summary document
Technical documents and summary document revised and
printed in final format
State received final documents for review and certification
EPA received final documents for review and approval
EPA received certification package
Approval letter being drafted -- anticipate final approval
by Mid-January
Appendix 1-A
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WYOMING PLANS NUT YET CERTIFIED/APPROVED
WYOMING STATEWIDE 208 PLAN
11/28/77
12/15/77
03/14/78
01/05/79
02/01/79
10/03/77
10/27/77
11/23/77
12/13/77
09/19/78
10/05/78
02/01/79
02/23/79
Requested review of draft 208 Plan
Requested review of draft 208 Plan policy recommendation
EPA comment letter sent to Powder River 208
Final plan received by EPA
Memo requesting review of final plan transmitted to EPA 208
review team
SOUTHWESTERN 208 PLAN
Preliminary draft of plan circulated within EPA for review
Meeting held within EPA to explain and discuss preliminary
draft
Meeting held within EPA to discuss proposed comments on
preliminary draft.
EPA comments on preliminary draft sent to 208 agency
EPA internal memo transmitted requesting review of final
dr aft
Final draft transmitted to Salinity Forum for review
EPA internal memo transmitted requestin review of final plan
DEQ's recommendations for certification circulated for
comment. (Governor is waiting to certify plan pending
completion and certification of Statewide Plan.
Certification letter has not been prepared.)
12/77
01/23/78
03/29/78
12/78
02/01/79
04/05/79
TETON 208 PLAN
Draft plan printed and distributed
Memo requesting review of draft plan transmitted to EPA
review team
EPA comments on draft plan sent to Teton 203
Final plan printed and distributed
Memo requesting review of final plan distributed
DEQ's recommendation for certification circulated for
cormient (Governor is waiting to certify plan pending
completion and certification of Statewide Plan.
Certification letter has not been prepared.)
208
Appendix 1-A
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COLORADO APPROVED PLANS
DRCOG 208 PLAN
03/31/77
April 1977
04/29/77
05/17/77
05/18/77
06/08/77
07/15/77
12/20/77
01/03/78
01/10/78
01/13/78
01/24/78
04/11/78
05/05/78
05/15/78
05/26/78
06/10/78
06/19/78
06/23/73
06/28/78
07/07/78
07/19/78
07/24/78
08/05/78
August 1978
letter)
position on
Options paper prepared discussing the inclusion of the 208
Plan in the Overview EIS
Draft Plan received by EPA for comment
Notice of Intent to prepare an EIS on the DRCOG 208 Plan
issued
Action Board briefed on substance of Plan
EPA comments sent to DRCOG redraft Plan (21 pg
Draft letter addressed to DRCOGoutlining EPA's
Plan; circulated within EPA for review
Preliminary position on Plan sent to DRCOG
EPA received final 208 Plan
Options paper concerning plan approval circulated for review
State certified 208 Plan
EPA received certification letter
EPA acknowledged receipt of certification letter and
advised State that 208 Plan was covered in the Overview EIS
EiS circulated for comment (30 days)
EPA advised by State that the State was in the process of
revising its certification of the Plan
Notice to extend connent period to June 10, 1978 issued
State sent EPA a second certification letter
End of EIS commend period
First draft of approval letter cicrculated within EPA for
comnent
Action Board meeting to
Second draft of approva"
Action Board meeting to
Third draft of approval
EPA
EPA final approval letter routed for signature
EPA approval letter signed
Final Action Document for EIS issued (included copy of 208
approval letter)
discuss Plan approval
I circulated
discuss Plan approval
letter circulated for
review within
LARIMER-WELD 208 PLAN
04/28/78
08/11/78
09/78
02/14/79
02/23/79
03/21/79
05/01/79
05/16/79
Draft Plan received by EPA
EPA comments on draft Plan provided to Larimer-Weld
Final Plan received by EPA
Plan certified by State
Certified Plan received by EPA
Draft approval letter circulated for review within EPA
Final approval letter routed for signature
Approval letter signed
Appendix 1-B
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05/26/76
08/76
08/04/76
02/07/77
02/10/77
02/10/77
03/01/77
03/10/77
03/18/77
03/25/77
05/19/77
06/08/77
06/10/77
08/04/76
07/77
07/21/77
09/77
09/30/77
10/77
12/15/77
02/13/78
08/04/78
08/15/78
10/02/78
11/02/78
11/14/78
12/11/78
12/20/78
01/24/78
COLORADO APPROVED PLANS (CONT'D)
PIKES PEAK 208 PLAN
Draft plan submitted to State and EPA (Comment "letter never
officially sent; typed for signature after receiving final
plan; oral comments and a draft of the letter were provided
to Pikes Peak)
Final Plan submitted to State and EPA
Letter from RA to Division Directors directing the staff to
respond to earlier erquests for comments on draft Plan
State certified Plan to EPA
EPA received certified Plan
Meeting with Action Board to discuss State's certification
and EPA's options
EPA acknowledged receipt of certified Plan
Action Board Meeting to discuss proposed EIS action
EPA issued notice of intent to publish an EIS on the Plan
Draft EIS issued
End of corrment period on draft EIS
End of comment period on final EIS
EPA approved Plan
Letter from RA to Division Directors directing the staff to
respond to earlier requests for comments on draft Plan
PUEBLO 208 PLAN
Draft of Volumes I and 2 received by EPA
EPA comments on Volumes 1 ana 2 sent to Pueblo
Draft of Volume 3 received by EPA
Pueblo's response to EPA comments on Volumes 1 and 2
Volume 3 circulated and comments received (informally
transmitted to Pueblo)
State commented on Pueblo's draft Plan
State and EPA met with Pueblo to discuss replacement of 208
staff and schedule for completing 208 plan
Pueblo responded to State's comnent letter
State held public hearing on Plan
WQCC adopted the Plan
State certified Plan to EPA
EPA received certified Plan
EPA draft approval letter circulated for comments
EPA final approval letter routed for signature
EPA approved 208 Plan
Appendix 1-B
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MONTANA APPROVED PLANS
BLUE RIBBONS 208 PLAN
2/78	Draft Report printed and distributed for comment
03/27/78	Internal memo transmitted requesting review of draft
01/11/79	Joint State/EPA review letter sent to Blue Ribbons on draft
8/79	Revised plan printed and distributed
08/17/79	Governor's certification received by EPA
11/15/79	Approval letter routed for signature
12/26/79	Approval letter signed
FLATHEAD
6/77	Draft report printed and distributed for comment
2/78	Final plan submitted to State and EPA
02/07/78	Internal memo transmitted requesting comment on Final Plan
08/17/79	Certified plan received by EPA
11/05/79	Approval letter signed
YELLOWSTONE/TONGUE 208 PLAN
10/77	Rough draft printed and distributed for comment
11/02/77	Internal memo requesting coimients transmitted
12/30/77	Comment letter on draft sent to 208 agency
3/78	Final report submitted
03/27/78	Internal memo requesting comments on final draft
08/17/79	Certified plan received by EPA
11/15/79	Approval letter routed for signature
12/26/79	Approval letter signed
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NORTH DAKOTA APPROVED PLANS
NORTH DAKOTA STATEWIDE 208 PLAN
10/26/78
03/79
08/24/79
12/07/79
12/27/79
Memo requesting review
review team (no record
State)
Final Plan printed and distributed
Certification of PI and received by EPA
First draft of approval letter typed
Second draft of approval letter typed,
by mid-January
of draft Plan transmitted to 208
of formal comments being sent to the
Anticipate approval
LEWIS AND CLERK 208 PLAN
08/11/77
08/24/79
12/07/79
12/27/79
EPA internal memo requesting review of draft Plan
transmitted to 208 review team (no record of formal
cormients being sent to Lewis and Clark)
Certification of Plan received by EPA
EPA first draft of approval letter typed
EPA second draft of approval letter typed. Anticipate
approval by mid-January
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SOUTH DAKOTA APPROVED PLANS
SOUTH DAKOTA STATEWIDE 208 PLAN
08/78
09/26/78
10/(4-5)/78
10/06/78
11/14/78
11/20/78
12/28/78
01/17/79
02/02/79
07/24/79
08/28/73
Preliminary draft of 208 Plan printed and distributed
EPA received second draft 208 Plan for review
Public hearings on Plan held
EPA letter sent to State indicating submittal is incomplete
and, therefore, EPA cannot do a full review.
State's certification letter received by EPA
tPA acknowledged receipt of certification letter and
rtquested additional copies of the Plan. Noted that
Statewide Plan was missing from the package.
Letter from Governor amending 11/14/78 certification letter
received by EPA (letter affected only Statewide Plan).
EPA acknowledged receipt of amendment to certification
letter
Statewide Plan mailed to EPA. Statewide Plan received by
EPA
EPA approval letter routed for signature
EPA approval letter signed
SIXTH DISTRICT 208 PLAN
05/77
04/06/78
04/07/78
05/02/78
05/17/78
11/14/78
09/20/79
10/10/79
10/18/79
Resignation of 208 staff
Final 208 Plan submitted to State for certification
Kinal 208 Plan received by EPA
EPA internal memo requesting review of final 208 Plan
EPA comments due on final 208 Plan (files show that no
cormients were recieved).
State certification of Plan received by EPA
Draft approval letter - comments requested within EPA
EPA final approval letter routed for signature
EPA approval letter signed
Appendix 1-8
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UTAH APPROVED PLANS
MOUNTAINLAND 208 PLANS
06/ 27/77
07/28/77
08/25/77
06/08/78
08/02/78
08/18/78
08/31/78
12/ U/78
02/27/79
03/23/79
urdifz Plan received by EPA
uPA review letter sent to Mountain land
nnal Plan received by EPA
State's initial certification letter received by EPA
EPA's rejection of certification due to lack of designated
management agencies
State's designation of management agencies thus completing
certification of Plan
EPA received complete certification package
Draft approval letter prepared and circulated for review
within EPA
Final approval letter routed for signature
Approval letter signed
06/77
08/77
10/13/77
12/77
02/23/78
11/22/78
12/13/78
12/28/78
03/08/79
04/05/79
04/30/79
06/25/79
09/25/79
09/28/79
UINTAH BASIN 208 PLAN
Preliminary draft received by EPA
Revised draft received by EPA
EPA comments on draft provided to AOG
Final 208 Plan received by EPA
Headquarters assisted review of 208 Plan through contract
completed
Certification letter received in RA's office
Certification letter received by Program office
EPA acknowledged receipt of certification letter (cited
April 12, 1979 as date by which EPA must take action).
EPA requested U.S. Fish and Wildlife review
U.S. Fish and Wildlife review letter recommending that EPA
add conditions to its approval of the Plan
Internal meeting to discuss F & to letter was held
EHA response to F & W letter sent with draft copy of 208
Plan approval letter
EPA approval letter routed for signature
EPA approval letter signed
WEBER RIVER 208 PLAN
09/02/77
09/06/77
12/09/77
11/20/78
12/13/78
03/79
(2nd week)
03/08/79
04/08/79
05/11/79
Final Plan submitted to State for certification
Weber River WQPC staff's briefing of EPA personnel
regarding contents of Plan
EPA comment letter on Plan sent to Weber River 208
Plan certification received by EPA
EPA acknowledged receipt of certified Plan (cited 3/20/79
as date by which EPA must act on ?" on)
Draft approval letter circulated for review within EPA
EPA requested U.S. Fish and Wiidlife review
EPA final approval letter routed for signature
Approval letter signed
Appendix 1-3
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UTAH APPROVED PLANS (Cont'd)
SALT LAKE COUNTY 208 PLAN
10/03/77	Draft Plan received by EPA for comment
02/10/78	EPA approved designation of Salt Lake County Department of
/later Quality and Water Pollution Control as the 208
planning agency to replace the Association of Governments
02/13/78	EPA review letter sent to 208 agency
04/27/78	EPA followup review letter sent to 208 agency
11/14/78	Certification of that part of 208 Plan dealing with the
South Valley Regional WWTP
12/01/78	EPA approved portions of 208 Plan dealing with the South
Valley Regional WWTP
12/04/78	Final 208 Plan submitted to Governor for certification
12/08/78	Copy of final 208 Plan received by EPA
02/12/79	EPA received certification of Central Valley Regional WWTP
portion of 208 Plan
04/30/72	Certification of remainder of the 208 Plan - letter
received by EPA
05/18/79	EPA letter requesting clarification of management agency
responsibi1ities
05/30/75	Response to EPA's 05/18/79 letter received by EPA
06/25/79	EPA approved portions of Plan dealing with the Central
Valley Regional WWTP
11/06/79	EPA final approval letter routed for signature
12/11/79	EPA approval letter signed
Appendix 1-3
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APPENDIX II
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208 QUESTIONNAIRE
208 PI an Approvals
1. How important do you think 208 plan approvals are in terms of:
a)	setting priority for the expenditure of future funds either
among 208 agencies or among 203 program activities?
b)	affecting the expenditure of 201 (Step 1, 2, or 3) funds?
c)	affecting the writing of NPDES permits?
d)	other (please specify)?
2. What sort of priority did you personally give to approved 208 Plans?
For example, as a project officer, did you ever refuse to review a
faculty plan or attend intra-office meetings because of the need to
complete the approval of a 208 Plan? If you are a supervisor, did
you ever sit down with a project officer prior to the end of the 120
days to adjust workloads and/or develop a schedule for approving the
208 Plan?
3. What is your perception of the priority given to 208 Plan review and
approval during the past year by the following groups? Compared to
previous years?
a) RA's office
b) Other Divisions
c) Water Division
a) Headquarters
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4. For those plans taking longer than 120 days to approve, please
identify the three most significant reasons for requiring the
additional time. Be specific—project by project if you are a
project officer.
5. May 23, 1973 regulations call for a concurrent certification and
approval process. How have you implemented or how do you propose to
implement these regulations?
6. Do you have any specific suggestions on how to improve the 208 Plan
approval process?
7. What do you think is a reasonable amount of time required to approve
a 208 Plan once a certified plan is received by EPA, assuming a
normal workload? 	 (days/project)
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APPENDIX III
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Typical Workload for a 208 Project Officer
Sept 78	- Assume Areawide from Rakers
-	Assume Statewide from Schroeder
-	Transition Quarter Grants - 106 - 208
Nov 78	SD SEA
Nov 78	FY 79 SD 106 Grant 1/2
Feb-Apr 79	FY 78 208 contracts for Statewide
Feb-Mar 79	Lake Herman MIP
Feb-Mar 79	RCWP Activities
Feb-Mar 79	SD 106 Grant
Apr-May	SD 208 Needs FY 79
June	Take over ND Statewide and Lewis & Clark from Zander
June	SD FY 79 208 work plans
June	ND FY 79 208 work plans
July	SD 79 208 Grant Award
July	ND 79 208 Grant Award
Aug	SD Statewide 208 Approval letter--3 weeks work, 2,000
pages to read--draft was never commented on—over 8
retypes, one for major format changes--13 weeks to
get out after last written submittal.
Aug-Oct	SD FY 80 208 Funding Plan
Aug-Oct	ND FY 80 208 Funding Plan
Aug-Oct	SD FY 80 SEA
Aug-Oct	ND FY 80 SEA
Oct-Dec	ND Construction Grants Issues
Oct-	Population Disaggregations
Oct-	Indi an Grants
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October-December Support OPAIR on P.P. Grants
Oct	6th District 208 Plan —3 weeks to do, 500 pages, 5
6 retypes. Draft was never commented on.
Oct-Nov	FY 80 needs for 208 selection
Oct-wov	Hunting Season
Nov-Uec	StCOG 208 Plan--800 pages, 3 weeks to do. Draft wa
never commented on—typist backlog.
Dec-J an	Rapid City NURP work plan
Dec-Jan	ND 5 year needs assess
Dec-Jan	SD 5 year needs assess
Jan 80	ND FY 79 contracts review
Jan 80	-	SD FY 79 contracts review
-	NURP detailed work plan
-	Big Sioux Aquifer Study
-	ND FY 7S 208 grants release
-	SD FY 79 208 grants release
Jan-Mar -	ND FY 80 208 work plans
-	SD FY 80 208 work plans
Jan	-	land treatment seminar for consultants
-	SD population disaggregation review
-	ND population disaggregation review
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