AREAWIDE
WATER QUALITY
MANAGEMENT
PROGRAM
SURVEY
PREPARED FOR
WATER PLANNING DIVISION
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
-------
AREAWIDE WATER QUALITY MANAGEMENT
PROGRAM SURVEY
OCTOBER, 1976
PREPARED FOR
WATER PLANNING DIVISION
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
Centaur Management Consultants, Inc.
-------
PREFACE
This case study survey, which samples twenty areawide water quality management
agencies, was prepared by Centaur Management Consultants, Inc. under EPA
contract number 68-01-3577. A Preliminary Summary Report of this evaluation (2/q-
was published in August, 1976.
This is the first round of- a three-year series of surveys evaluating the
activities of selected areawide water quality management agencies as they
progress through the planning and implementation phases of the water quality
management (WQM) program.
Included in this report is a series of recommendations developed by the
project staff on the basis of their extensive local interviews. In addition,
detailed case studies are presented for each of the twenty agencies. The
final Section of each case study (Section V) contains an evaluation (to date)
of the local agency with respect to likelihood of plan completion, public
involvement, current and continuing planning processes, and the significance
of local elected officials' involvement.
The project staff, directed by Cheryl Dinneen and supported by Jane Nowak,
Constance Castle, Ann Hoffman, Rob Arnold and Elizabeth Haskell, is grateful
for the cooperation and support provided by the local WQM agencies, the
EPA Regional Office staff and the EPA Water Planning Division in Washington,
D.C.
Michael L. Frankel
Centaur Management Consultants, Inc.
-------
TABLE OF CONTENTS
Page
PREFACE i
PROGRAM RECOMMENDATIONS 1
PROJECT DESCRIPTION 5
CASE STUDIES
Chattanooga Area Regional Council of Governments/
Tennessee Development District CA-1
Delav;are Valley Regional Planning Commission DV-1
East West Gateway Coordinating Council EWG-1
Houston-Galveston Area Council HG-1
Lower Rio Grande Valley Development Council LRG-1
Martha's Vineyard Commission MV-1
Miami Valley Regional Planning Commission MV-1
Mid-America Regional Council MA-1
Middlesex County Planning Commission MC-l
Mid-Willamette Valley Council of Governments. MW-1
|t? Municipality of Seattle - METRO MS-1
Nassau-Suffolk Regional Planning Board NS-1
Ohio-Kentucky-Indiana Council of Governments OKI-1
Southeastern Wisconsin Regional Planning Commission.... SEW-1
Southern Kennebec Valley Regional Planning Commission.. SKV-1
Southwest Florida Regional Planning Commission SF-1
Sussex County Council. SC-1
Teton County 208 Planning Agency TC-1
Ventura Regional County Sanitation District VC-1
11.1 1 I nr.. I ¦ III!.— ¦ "* I" Hlll»llll —
Yellowstone-Tongue Areawide Planning Organization YT-1
-ii-
-------
RECOMMENDATIONS
Each of the twenty individual case studios presented in this report conclude
with an analysis of the WQM planning process (Chapter V). It is from these
analyses that the following recommendations are made. (A discussion of
common issues affecting this sample of WQM agencies, which helped shape
these recommendations, is presented in Areawide Water Quality Management
Program Survey Summary, August 1976.)
WQM PROGRAM EXPECTATIONS
As WQM agencies continue their planning, their perceptions about water
quality management begin to change. In part, this is due to changing Federal
guidelines regarding the coordination of WQM agencies with other planning
programs. WQM perceptions also are affected by the agency's sense of
urgency regarding deadlines, their reassessment of their own ability to
complete work within the given timeframe and their assessment of what is
politically realistic.
The net. result is that expectations of the WQM program vary by project area.
The following recommendations are intended to help eliminate WQM agencies'
uncertainties over these expectations.
1. EPA should elaborate and clarify what allowance they will make for WQM
agencies not reaching the water quality goal. In those instances
where the goal will not be reached, local. WQM agencies should be
required to define specifically the reasons why the implemented
plan will not reach the water quality goal. Reasons for not reaching
the goal (under the legislative caveat of "where attainable") are
expected to include conditions of natural background pollution,
unreasonable use clsssifications, and economic considerations. EPA
must define clearly these conditions prior to their review of the WQM
plans.
2. EPA Regional Offices should plan to evaluate WQM plans on the basis
of planning targets previously negotiated with the WQM agencies.
Such targets should exhibit an understanding of the complexity es
of the water quality problem, institutional setting, area resources,
and local goals. The case-by-case negotiation might comprise:
c a milestone approach toward WQM planning and implementation
with each area proceeding at its own pace;
© a "contract" negotiated between EPA and local agencies on
success criteria:
1
-------
e a local commitment on the content of future continuing
planning activities to undertake those planning elements
not completed during the initial WQM plan.
EPA's review process should be specified clearly and made available
to the local WQM agencies.
3. EPA reviews of WQM plan interim outputs and/or decisions should be
conducted continuously throughout the planning period to both avoid
surprises over the final plan's content and to lessen the burden
of final reviews. Such reviews should be documented formally and
tailored to the progress being made by a WQM agency on its specific
work plan.
4. EPA should encourage areawide planning agencies to have their WQM
plans incorporated into state-wide WQM plans. Since both planning
efforts are proceeding concurrently, it is important to have this
coordination take place continuously, otherwise the plans may not
accurately reflect each others strategies. Coordination between state
and local planning agencies should be monitored and reviewed by the
EPA Regional Offices and inadequate or insufficient coordination
should be brought to the attention of both parties.
5. EPA should assist local planning agencies in developing WQM plans
that can accommodate changing conditions which may develop in
future years during the continuing planning process. The WQM plans
must not be static, inflexible instruments unable to deal with
unforeseen conditions such as changing upstream discharges, new
community development patterns, relationships between point and
nonpoint source contributions, etc. This assistance should come
about as a result of continual EPA technical plan reviews high-
lighting plan flexibility.
6. EPA should ensure that Regional WQM project officers are well-trained
in all aspects of WQM planning including related programs such as
air quality and solid waste planning. Such broad training will be
required to meet the daily technical assistance needs of local
WQM agencies as well as to review final WQM plans. The training
will be especially valuable in reviewing a local WQM agency's assess-
ment of the plan's environmental impacts. National and Regional
training seminars exclusively for WQM project officers should become
part of their continuing training programs.
PUBLIC INVOLVEMENT
All WQM agencies recognize EPA's requirement to include public involvement
in their programs. Many also have state or local requirements for public
participation. However, the character of public involvement programs and
the WQM agencies' commitment to them vary considerably, depending on the
public's perception of its water quality problems, the extent of public
involvement in other planning programs in the area, the WQM agency's own
2
-------
experience with public involvement activities, as well as economic, geographic
and political factors which characterize the WQM area.
The following recommendations made on the basis of the case studies emphasize
the need to concentrate public involvement efforts toward elected officials
and to consider public involvement beyond the planning phase into the
continuing planning and implementation phases.
1. EPA should encourage areawide agencies to continue their public
involvement efforts toward local elected officials. Efforts to
reach the elected officials should he undertaken even at the
sacrifice of reaching the general public since the elected officials
are representative of the public. Furthermore, local agencies should
de-emphasize expensive efforts to reach public interest groups.
These groups will get involved by the WQM process without prompting.
National efforts toward encouraging and assisting public involvement
efforts should also concentrate on methods to maintain ongoing contact
with local and state legislators. Such encouragement and assistance
should focus on WQM program objectives, progress, and potential for
future legislative activity. The need for legislative contacts
should not be viewed as predicated on specific needs for legislative
authorities but, rather, as aiding the legislative assessment of
related efforts such as budget requests for water quality activities.
2. EPA should encourage WQM agencies to develop planning alternatives
for public review as soon as possible. The planning period is
too short and restrictive to accommodate major plan revisions in
the final stages. Early public involvement can avoid major contro-
versies during the plan approval phase. EPA's continuing review of
the local agency's planning schedule should pay particular attention
to this ill terms of well-defined public involvement milestones.
3. EPA should encourage WQM agencies to include a public involvement
mechanism in their WQM plan for the continuing planning process
and implementation phases. These mechanisms should be reviewed
by EPA in their analysis of management agencies and institutional
arrangements as proposed in the WQM plan.
4. EPA should encourage WQM agencies to translate their technical jargon
into lay terms to enable the public to understand the WQM process.
Particular attention should be given to the relevance of each plan
element to the overall WQM plan. The language used in WQM reports
should be checked continuously during EPA reviews of interim outputs.
PLAN IMPLEMENTATION
Although most WQM programs are in the early phases of the planning period,
some groundwork for the ultimate aim of the program plan approval and
implementation —has already been laid. Current expectations regarding
plan approval and implementation are highly speculative and depend on the
3
-------
final outcome of the plan, continuing funding and the extent of political
support. Accordingly, local elected officials and others involved in WQM
are reserving judgment on the WQM process in a spirit of "watchful waiting"
for the final plan. Generally acknowledging the present low visibility of
water quality issues, WQM planning agencies are taking incremental steps
towards plan implementation.
The recommendations for plan implementation are intended to facilitate the
continuing planning and implementation phase of the WQM program. Two of
the case studies, i.e., Ohio-Kentucky-Indiana and Miami Valley (Ohio) afforded
an opportunity to study agencies nearing completion of their WQM plan.
1. EPA review of state water quality actions (e.g., priority lists
for construction grants, NPDES permits, water quality standards,
use classification) should emphasize compatibility with areawide
WQM plans. EPA review of state annual program plans, 305(b) reports
and state-wide WQM plans also should emphasize the required coordina-
tion between these reports and the areawide WQM plans throughout the
state, EPA Regional Offices must be encouraged to view all of these
separate water program activities under the overall strategy of
WQM plans.
2. EPA should advise the organizations with A-95 review authority to
take the WQM plan into consideration during clearinghouse review on
local Federally-funded activities. >
3. EPA should encourage the Federal Regional Councils to coordinate
their activities with areawide and state-wide WQM plans to assure
the consistency, compatibility and coordination of Federal efforts
within the Region.
4.' EPA should encourage other Federal agencies to provide continuing
assistance to the WQM program beyond just the planning phase.
Such assistance may prove necessary in meeting the requirements of
implementation and continuing planning phases.
5. EPA should clarify the situation with regard to continuing funding
beyond the two year planning period. This clarification must
consider the transition phases between completing the plan,
getting it approved and embarking on plan implementation. Local
agencies require advice when allocating their funds for these critical
times, especially since coordination and possible plan revisions may
require the continuing services of the planning staff.
6. EPA should encourage both local agencies and other Federal agencies
to coordinate or consolidate water sampling programs conducted by
various agencies in the area (e.g., SCS, USGS, state agencies, local
agencies) to maximize their potential in support of ongoing data
gathering and analysis efforts. This encouragement should be
particularly useful in identifying resources for the continuing
planning process.
4
-------
PROJECT DESCRIPTION
[As part of the EPA Water Planning Division's continuing evaluation of the
[water quality management program, Centaur is conducting a review of twenty
selected areawide water quality management agencies. With the help of
Regional Offices, these agencies were selected to become part of a three-
year study. Each WQM agency was visited by a member of the Centaur staff
for an initial series of interviews. The initial interviews covered a
wide range of topics including: water quality problems, planning strategy
and results to date, local expectations, varying perspectives of the WQM
program, and an analysis and conclusions. Subsequent interviews by telephone,
mail or in person will cover a variety of topics depending on the needs of
EPA Headquarters and the Regional Offices. The Centaur staff will continue
to talk with WQM planning staffs, consultants, state agencies, members of
advisory committees, local elected officials, and citizens of the areas.
The objective of this project is to conduct an ongoing review that can be
used by EPA Headquarters and the EPA Regional Offices to document achieve-
ments and program elements most directly related to success and to highlight
potential sources of problems so that they can be corrected and eliminated
to the greatest extent possible.
The continuing review will attempt to define and measure the successes and
constraints of the areawide v/ater quality management process in attaining and
maintaining the 19S3 water quality goals and in meeting the requirements of
the Act. The WQM program has multiple objectives that include implementation
of a management system as well as establishment of an ongoing planning process.
The review, therefore, is designed to study such issues as the planning process,
implementation schemes, plan approval process, start-up of management agencies
and implementation of areawide management plans. The review also is designed
to examine the extent of intermedia, intergovernmental, intersource, and inter-
functional coordination as well as the degree to which WQM areawide planning
supports the control of other pollutants and their standards.
The selection criteria for the twenty agencies were based upon agency
characteristics found to have significant variations among the WQM agencies.
The selection criteria were:
1. Geography - at least one from each Region;
2. Coastal area;
3. Significant amount of WQL segments;
4. Pristine/preservation area;
5. Significant groundwater problem;
6. A recreation/tourism area with- seasonal population problems;
7. Significant NPS problems - agriculture, mining, forestry,
urban runoff;
5
-------
8. An energy area;
9. An area experiencing rapid growth;
10. An area'with a large amount of land under federal management;
11. An urban, highly populated area;
12. An agency created specifically to do WQM planning;
13. A very experienced planning agency with multi-functional
responsibilities;
14. An agency that also did a 303(e) plan;
15. An area where no 3c or 303(e) plan has been done;
16. An agency with a high amount of State involvement;
17. Two areas that received WQM grants in 1974 (one in Nov. - Dec.,
one in June); and
18. Two non-COG agencies (e.g., state, county government, municipal
government, sewer district).
The list on the following page is the final sample of WQM agencies in the
survey. Table I contains a categorization of interviews conducted on each
site visit.
6
-------
Region
I - Boston
II - New York
III - Philadelphia
IV - Atlanta
V - Chicago
VI - Dallas
VII - Kansas City
VIII - Denver
IX - San Francisco
X - Seattle
Agency
^Martha's Vineyard, Mass.
Augusta, Maine
Nassau-Suffolk, N.Y.
Ni Middlesex County, N.J.
Philadelphia, Penn.
^ Sussex County, Del.
x<" Sarasota Ft. Meyers, Fla.
Chattanooga, Tenn.
Dayton, Ohio
^Milwaukee, Wise.
^ Cincinnati, Ohio
^ Houston, Texas
^ Lower Rio Grande, Texas
^Kansas City, Mo.
^ St. Louis, Mo.
^ Teton, Wyoming
Southeast, Montana
^ Ventura County, Calif.
Seattle, Wash.
^ Salem, Oregon
Criteria
Coastal/Recreation
High degree of State
Involvement
Groundwater Problem
Urban-Industrial Area
Large Urban Area
Non-COG
Coastal/Recreation
Institutional Approach
Early Designation
Urban Area
Tri-State
Industrial
Agricultural Problems
Bi-state
Urban/Industrial
Nev; Agency
Energy Area
Non-COG
Urban, Long History of
Water-Related Experience
Agricultural Problems
7
-------
Table I
Categorization of Interviews Conducted
June - August, 1976
Local State Water
WQM
Director
Other
Staff 1
Exec.
5
Dir.
Elected-
Off icials
Citizens
Quality
Agency
State
Legislators ^
6
Appointed
Other
Total7
Martha's Vineyard, Mass.
1
1
1
2
2
1
1
1
11
Augusta, Maine
1
1
2
3
1
2
1
10
Middlesex County, Hew Jersey 1
2
1 t
2
3
1
1
1
12
I.'assau/Suffolk Counties,
1
2
1
1
1
1
1
Governor's Staff
9
New York
Member
Philadelphia, Pennsylvania
1
2
1
1
3
2
1
1
11
Sussex County, Delaware
1
2
2
3
1
2
County Administra-
tor and Treatment
Plant Operator
11
Chattanooga, Tennessee
1
2
1
1
2
1
1
1
TVA engineer
10
Ft. Meyers, Florida
1
1
2
1
2
2
1
Director County
Planning
10
Cincinnati, Ohio
1
3
1
3
(1)
(2)
2
Planning Commission
and Comm. Dev. Dir.
13
Dayton, Ohio
1
3
1
2
3
1
14
Milwaukee, Wisconsin
1
4
1
3
1
3
13
St. Louis, Missouri
1
7
1
1
3
3
1
1
18
Kansas City, Missouri
1
2
1
2
2
2
1
1
12
Houston, Texas
McAllen, Texas
1
1
3
2
1
1
2
2
4
3
(3)
(1)
1
1
2
Navigation District
17
16
and Legislature Staff
Member
Broadus, Montana
1
2
2
1
2
1
1
3
County Planners and
13
Proj. Dir. for Indian Res.
Jackson, Wyoming
1
2
3
2
2
1
Town Administrator
9
Ventura County, Calif.
1
1
1
2
3
1
1
1
"¦ .
Seattle, Washington
1
1
1
1
3
1
2
1
11
Salem, Oregon
1
1
1
2
1
1
2
1
10
TOTAL
20
41
15
35
46
24
18
21
13
230
1. Other staff members interviewed were most often engineers (8), community involvement persons (13), or planners (10).
2. In three cases the Executive Director of the parent agency was the same as the Director of the WQM program. In two cases, the designated
agency was a County so the County Administrator was interviewed.
3. Local elected officials included county commissioners and supervisors (14), town councilmen (11), and mayors (6).
4. One agency was bi-state. Two states each had two agencies in the sample. Thus a total of 24 interviews in 16 states were made.
Parentheses in the chart indicate when a State interview covered more than one project.
5. See note 4. A total of 19 interviews were made with legislators from lf> States.
6. Appointed officials were those concerned with facility planning. These included City and county engineers (10), and Directors of
sewer agencies, public works departments and water quality boards (7).
7. Agency totals include state interviews shared at the state level. Overall total does not double count these.
-------
AGENCY: ' CHATTANOOGA AREA REGIONAL COUNCIL OF GOVERNMENTS/
SOUTHEAST TENNESSEE DEVELOPMENT DISTRICT (CARCOG/SETDD)
REGION: IV - (Atlanta)
GRANT AMOUNT: $949,000
GRANT RECEIPT: June 4, 1975
STARTING DATE: October, 1975
STATUS AT TIME OF INTERVIEWS: Were awaiting approval of work plan from
States of Georgia and Tennessee and from
Region IV. Approval expected shortly.
REASON FOR INCLUSION IN SAMPLE: This is a bi-state area. With six counties
and a number of competing authorities in
the area, there is a very complex institu-
tional setting.
CA-1
-------
I. BACKGROUND1
A. Area Description
The area encompasses much of the population of the SMSA of Chattanooga.
This includes three counties in the State of Tennesses (Marion, Sequatchie,
Hamilton) and three counties in Georgia (Catoosa, Walker, Dade). The total
population of the area is 370,010 with most of this being in Hamilton County
(254,230).
The area had recently experienced a chemical spill that shut off the water
system for two days, and there have been a couple of fish kills in recent
years. Although this brought increased concern for water quality, the WQM
effort could not immediately capitalize on these dramatic situations because
the work plan was not approved.
Hydrologically the area is unified, but politically it is split. Besides
being split between two states and six counties, there are a number of
organizations in the area with overlapping authority which makes for a
complex institutional setting. For example, CARCOG/SETDD, the designated
agency, is a joing COG and Development District for ten Tennessee counties.
The three Georgia counties are in the COG but belong to the Coosa Valley
Planning and Development Commission of Georgia. The SMSA comprises all
13 counties, but the WQM area includes only six of these, three each in
Georgia and Tennessee. While CARCOG/SETDD provides areawide planning
assistance to the entire area, a number of agencies provide local plan-
ning assistance. These are .-
o For Hamilton County, by the Chattanooga-Hamilton County
Regional Planning Commission;
o For Marion and Sequatchie Counties, by the Southeast
Tennessee section of the Tennessee State Planning Office; and
o For Catoosa, Dade and Water Counties, by the Coosa Valley
Area Planning and Development Commission.
In addition to these, TVA has conducted regional planning in the area for a
number of years. There are three TVA-sponsored Tributary Area Development
Organizations concerned with natural resource and economic development in
their respective areas.
B. Water Quality Problem
Based on review of River Basin plans from each State and based on interviews
with Federal and State agencies concerned with water quality, four problems
Information for this Chapter was taken from designation package from
CARCOG/SETDD Overall Program Design, 1977-70; from 208 Newsletters;
from numerous mimeographs from CARCOG and WQM files; and from interviews.
CA-2
-------
were identified for consideration during the initial planning phase. The
first is an analysis of urban runoff. Such analysis has never been made
in this area. Septic tank malfunctions will be studies under this project
element. Streams of high concern for runoff include Lookout Creek, Chattanooga
Creek, Citico Creek, South and West Chickamauga Creeks, Black Creek and
Stringers Branch.
The second priority problem involves water quality outside the metropolitan
area and includes agriculture, construction and mining-related pollution.
These problems are often seasonal in nature, but they have recently resulted
in some fish kills which have dramatized their importance. Impacted streams
include the Sequatchie River, North, South and West Chickamauga Creeks, Chat-
tanooga Creek, and Woftever Creek.
The third problem to be considered is that of solid wastes, including both
leaching garbarge dumps and industrial and municipal sludges. Impacted
streams include Chattanooga Creek, Lookout Creek, Citico Creek and a number
of minor tributaries which drain illegal dump areas.
The fourth problem to be considered is that of municipal and industrial
point sources. Affected streams include Wolftever Creek, Rock Creek, Waconda
Bay, Chattanooga Creek, Citico Creek, South, West and North Chickamauga and
Lookout Creek.
A large number of water and sewer studies relevant to the WQM effort have
been conducted in this area. These have been done by the State, TVA,
the Soil Conservation Service and by CARCOG. Furthermore, much of the area
is covered by one or mroe comprehensive land use plans prepared by a variety
of State, areawide and Jocal agencies. A Tennessee River Basin Plan has
been prepared for the area by the Tennessee Water Quality Control Board and
the Tennessee Department of Public Health which includes a physical descrip-
tion of the basin and an evaluation of social and economic conditions. Further,
it defines water uses, discharge limitations and projections through the year
2020. Finally, the basin plan establishes a State permit system to be used
in addition to the NPDES.
Currently, a 201 Facilities Plan is being prepared for the Chattanooga metro-
politan area. Although smaller, the 201 boundary overlaps much of the area
of the WQM study, so the two will be closely coordinated. A second relevant
.study currently ongoing is the low flow study of point sources being conducted
by TVA. Both the 201 and the TVA -study were started ahead of the WQM study,
and their data should be available for use by the WQM agency.
C. Designated Agency
The designated agency is both a regional council of governments and a develop-
ment district. First incorporated as a COG in 1967 under the laws of Tennessee,
it has grown both in authority and in area jurisdiction. Three Georgia counties
were included, one from the onset and two others subsequently. The Development
District was created in 19G9, and to avoid complications of adding a fifth
planning staff in the area, the COG and development districts were joined. A
third staff responsible for health planning in Georgia and Tennessee was
CA-3
-------
also merged. In 1974 the organizations adopted joint by-laws and established
a single policy board under an interlocal cooperation agreement.
CARCOG/SETDD presently conducts a number of planning activities including:
interstate mass transit, solid waste collection and disposal, interstate
air pollution control, interstate health services, housing, and interstate land
use. An Overall Program Design coordinates the various planning activities
with the intention of eliminating duplication between projects and assessing
inter-program impacts.
There are two key advisory committees. The Areawide Planning Advisory
Commiteee is composed of elected officials and is headed by the Chairman
of CARCOG/SETDD. The Regional Water Quality Task Force includes technicians
and staff of other agencies, and it is chaired by the Executive Director of
CARCOG/SETDD.
The staff consists of a Project Director, Project Engineer, Planner Advisory
Draftsman. In addition, the services of an IPA from the Soil Conservation
Service have been procured for a 15-month period. Finally, four staff
members of the CARCOG/SETDD are also working part-time on the WQM study.
Three consulting firms have been hired to complete elements of the plan.
An engineering firm will prepare the Point Source Sub-plan, Management
System Sub-plan (with others), and a Solid Waste Residuals Sub-plan.
An environmental consultant will prepare the Urban Nonpoint Source Sub-
plan and will conduct the Enviornmental Assessment. The management con-
sultant will prepare the Management System Sub-plan. In addition to
these private firms, TVA will work on the WQM Nonpoint Source Sub-plan;
the Soil Conservation Service will prepare the Rural Nonpoint Source
Sub-plan and Coosa Valley APDC will design and carry out the public
participation program.
CA-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
In its initial preparation of a multi-year program, CARCOG/SETDD surveyed
local elected officials in ten counties regarding their priorities for
fifteen functional planning activities. It is -interesting to note that
"Water Supply and Sewage" and "Refuse Collection" received first and
second ranking, respectively.
Organizationally, the WQM planning effort falls with the Regional Planning
and Development Program. The main goals of this element are to provide a
comprehensive planning and community development guide to development and
use of the area's resources. A second goal seeks to eliminate duplication
of planning efforts and to address program needs in the most cost-effective
manner possible. The program seeks to develop a common data base, to
provide assistance to member governments in seeking Federal funds, and to
implement capital improvement planning and budget processes for all local
governments in the region. Each element — land use, transportation, housing
and water quality — has its own objectives. For water quality there are
two:
o Establishment of a continuing water quality planning and
management process; and
o Completion of the initial areawide water quality management
plan.
,B. Technical Component
The WQM project is divided into three parts. The first two recite to
treatment and control of point and nonpoint source pollution problems,
third involves creation of an overall management system.
Basic iii -entory work for point sources will come from the ongoing 201 planning
effort effe>_.We for most of the area, from Tennessee and NPDES permit systems,
from the basin and from the TVA Assimilative Capacity Study. The
inventory for nonpox/i- sources will be concerned primarily with urban
stormwater runoff, hydroscphic modification, residual waste disposal, agri-
culture, mining, silviculture construction activities. After inventories
of point and nonpoint sources are made, sc'<.-:dules for detailed examination
of control possibilities will be made, leading the preparation of two
subplans.
A series of projections of residential, commercial and in^"';trial wastes
will be made. Wasteload allocations for stream segfnents targ,_*ed at both
point and nonpoint loadings will be devised to achieve desired ut, - standards
and 1983 goals. The work plan anticipates development of a Simulati-~''. model
to test alternatives.
CA-5
-------
It is anticipated that a substantial amount of point source corrections will
be needed in Marion and Sequatchie Counties. For much of the other areas,
the 201 planning is expected to address issues of waste loads and wastewater
flows, including corrective measures where necessary. Some of the technical
point source issues expected to receive special attention are the multitude
of package treatment plants, the possibilities for joint municipal-industrial
facilities, and storm water discharges.
In preparing the nonpoint source sub-plan, the work plan indicates that
emphasis will be placed on those sources with highest priority. Land use
measures are expected as part of the control strategy, but only within the
limits of viability and cost effectiveness.
C. Management Planning
Management planning will begin with analysis of existing Georgia and Tennessee
laws and local administrative arrangements and with identification of
legally authorized management options. Concurrently, an analysis will be
made of existing institutional and staffing capacity, and analysis will be
made of present financial commitments and obligations of local governments.
These analyses will determine the need for necessary statutory refinements
and the ability of governments to undertake a new management arrangement.
Working memoranda will be prepared in each case.
Building upon the analysis discussed above, the next step will be to prepare
a management plan which addresses facility design, construction, operation
and maintenance; administration and financing; and implementation of a
regulatory program. The work plan emphasizes use of existing institutional
capabilities, particularly those respecting the differences between the two
States. The Project Manager, however, indicated a definite possibility of
creating a new regional authority.
D. Public Involvement Program
A Public Participation Plan for the WQM effort is currently being prepared by
contract to the Coosa Valley Area Regional Planning Council. This plan
will define the use of newsletters, questionnaires, exhibits, mailings and
news media contacts. Appropriate links to the Advisory Committee and project
staff will be recommended along with a schedule for necessary meetings. A
number of public hearings will be held throughout the planning period.
E. State and Federal Involvement
The Tennessee Public health Office has been very helpful in the project thus
far and is becomi increasingly involved. The Tennessee coordination system
in general, is '^od.,- The—Projeet-.-Director felt that Geqrgia_is_iian.ti-W.QM",
but they been building a good relationship. It has been important to
make su.-r that Georgia is involved in all meetings, a step sometimes forgotten
by r;>A. The WQM agency has given $37,000 to the States for coordination.
CA-6
-------
.The Project Director described a friendly relationship with the EPA Regional
Office, but one^sometimes marked by_ lack of communication. He noted^ that
the; RegionaljJffice^is severely understaffed and they must sometimes compete
with other WQM agencies for attention. He also felt that the Region may be
becoming too involved in management through PERT charts, approvals take too
long and other things are neglected. The biggest problem has been that the
work plan is still not approved and permission to proceed not received.
The Project Director perceives an attitude on the part of EPA Headquarters
and the Regional Office that WQM is not a high priority, but he feels that
this may be changing. Given the regional staffing situation, the Project
Director preferred not to have to keep asking for EPA permission to do things.
He definitely did not want guidance subject to change because that becomes
a disruptive factor in the work program.
F. Scheduled Outputs
Scheduled outputs for the WQM plan have been closely coordinated with anti-
cipated outputs -from the 201 Facilities Plan. Data collection will, for the
most part, be completed within the first six months. At that time, land use
plans,and 'policies will be analyzed for the following six to eight"months.
Projections will be completed within six months and wasteload allocations will
be completed within the following eight months. The Point Source Sub-plan
will be prepared between the fifth and thirteenth months; while the Nonpoint
Source Plan will be prepared between months 14 and 19. Management task
elements will be conducted throughout most of the" planning period. A combined
set of alternaitve plans will be prepared during months 18 through 21,
followed by committee and public review.
Each of the four plan elements will have a number of outputs. These will
include a series of working memoranda to local officials delineating the
implications of water quality management upon other plans and policies.
Each element — analysis of land use plans and policies, point and nonpoint
source sub-plans, an'd the management plan — will be combined to form a
series of alternative final plans, testing feasible combinations and options.
The State has requested that three tasks be added to the work plan: an
examination of D.O. levels in Chickamauga Dam, analysis of pump storage on
Raccoon Mountain, and evaluation of thermal effects of the Sequoia Nuclear
Plant. Although the WQM agency did not really want to take on these added
tasks, it now appears that they will, although details are unclear.
G. Achievements to Date
The Project Director described five accomplishments to datp. The first involves
creation of a relatively good data base. For the first time, .environmental
data for the whole area is mapped on a common scale. The second accomplish-
ment listed was that all existing land use information for the area has been
pulled together. The third accomplishment is the establishment of a policy-
making group made up of elected officials. This group has had three major
meetings and has made important decisions at each meeting. The fourth and
CA-7
-------
fifth accomplishments are institutional in nature. An SCS employee hired
as a 15-month IPA has been concentrating his efforts on achieving coopera-
tion across state lines.
The Project Director felt that one of the greatest accomplishments is that
they have already entered a management mode. Through the A-95 review
process, they have forced some changed in 201 plans. They have succeeded
in convincing the State to consider accommodations of future population in
review of the 201 plan and have urged the State to be more involved in NPS
work. Finally, they have supported a city ordinance which, if adopted, would
provide for pre-treatment by industry and cost recovery in the municipal
system.
So far, the staff has been hired and communittees formed. The Project
Director has spent much of his time trying to get the work plan approved.
In the meantime, other staff members have been collecting environmental,
population and land use data. Much of it has been mapped on a common
scale, a capacity not formerly available in the area.
There have been some start-up problems. The COG is very coordination-oriented
and less geared to problem-solving. Although the WQM was staffed prior
to last September, the COG was re-organized in December, which inevitably
affected staffing patterns. Finally, the WQM staff identified some problems
in coordinating the three area planning agencies. Data was at three
different levels of detail and had to be transposed to a common base.
Scheduling was somewhat of a problem and the planning agencies' workloads
did not always fit when the WQM staff needed the data. Similarly, although
river basin plans were completed for the area by both Georgia and Tennessee,
and of much assistance, some parts are already out of date. Further, each
State used a different model and different delineation techniques, which
complicates the water quality analysis.
Coordination with other agencies is a major accomplishment. TVA, SCS and
other planning agencies have been contracted with for elements of the plan.
Agreements have been made for coordination with the HUD 701 Program and
the 201 study. A State Coordination System allows the designated agencies
in Tennessee to have a regular exchange of information. The Project
Director has taken steps to involve both States in design of the work program.
The Policy Board composed of 31 elected officials has been formed for over
a year. They have elected a Chairman and a Vice-Chairman, approved the
work program and milestones, and set a budget. The local Engineering Task
Force met to help advise in the consultant selection process.
Consultant selection has been complete for several months, but no work has
been done by consultants pending approval of the work plan by the EPA
Regional Office. Selection followed a multi-stage process. First,
qualification statements were obtained from seventy firms. These were
narrowed down to three to five for each proposed contract and each firm was
asked to submit a proposal. The Engineering Task Force then ranked their
several choices. Unfortunately, in one case the Task Force's recommendation
CA-8
-------
was not followed, and the firm that has historically done 201 work in the
area was selected. This situation led to criticism by the Task Force members
and considerable unfavorable publicity in the media.
The IPA from Soil Conservation Service is developing a series of best manage-
ment practices for agricultural, mining and construction activities for
the two-state area. So far, he has collected soil, water and vegetation
data from SCS, Districts and -the .Forest Service, and he is surveying
technical guides for controlling rural water quality programs. The Project
Director has worked closely with the Technology Transfer Office of EPA
in Cincinnati on agriculture and silviculture pollution problems.-1- The
Project Director also was on the panel for Technology Transfer seminars in
Framingham, Massachusetts and in Atlanta, Georgia.
The staff is just beginning to work with the Coosa Valley Area Regional
Planning Council who has been contracted with for the public participation
program. However, a number of presentations have been made to service clubs
and agencies. Two public hearings were held in May to elicit participation
in the process of delineating water quality problems. Three issues of
the newsletter have been mailed.
This was written up in one of the EPA newsletters.
CA-9
-------
III. EXPECTATIONS
A. Water Quality
The qgrj_eraA._?£I1j?.e.!?-§1rls was that the water quality will be improved, but that
the 1983 goal will not be ..met in _all__ streams. Both the COG Director and
the Director of the local Public Works Department felt that they would
come close to meeting the 1983 goal, but the nature of the area's industry
(chemical plants) would make this difficult and there would always be spills.
A local elected official felt that the extent to which they meet the 1983
goal will depend upon the availability of national funding. The Project
Director, v.'ho felt that quality of waters would be improved, questioned the
standards and the definition of "swimmable".
The Georgia water quality staff member thought the 1983 goal would definitely
be met in the major streams; the Tennessee Public Health staff member,
however, did not expect the goal to be met in all cases because of the
need for additional municipal facilities grants, and because there is a time
lag before effects can be seen. He definitely expected eventual improvements
in all areas where problems were being tackled.
B. Plan Approval and Implementation
Both the Project Director and one of the State water quality persons pointed
out that approval and implementation are inseparable. The Project Director
felt that based on the experience in getting an Air Pollution Board approved,
likelihood was between four and six on a ten point scale. He felt it was
possible, but unexpected things can always happen. The most essential persons
would be the elected officials on the Policy Board. He felt that implementa-
tion could be fully achieved within three years. The COG Director, who is
in fairly close touch with local elected officials, felt that the Mayor of
Chattanooga, who is a former Public Works Commissior-^r, would be most
essential because the plant is owned by the City.
The TVA Engineer felt approval was nearly certain and guessed that chances
for implementation were 7.5 out of 10, but that some parts would definitely
be implemented. He said that, so far, elected official support has'been fair,
in the future it would be essential to show them something in the plan is
to be implemented. The elected official interviewed felt that approval is
likely (7-8), but implementation is less certain (3-4), although he added
that it is too early to know yet. The State legislator said that they would
have a success if full implementation is achieved in twenty years, so long
as, in the meantime, they are always working toward that goal.
A Georgia State water quality staff member felt that the plan would be approved
with a lot of conditions. His Tennessee counterpart felt that the likeli-
hood of approval at the State level is eight, and at the local leve.1 is six
because of the fragmented nature of municipalities.
CA-10
-------
The re we re a variety of opinions about the need for 1 e qi s l^tive cj lane e s a n d
_local ordinances, buteveryone agreed th a t noth ing had yet been done to
obtain what is needed. The Project Director felt that they would need local
ordinances to control urban stormwater and soil erosion problems. He felt
that state laws were most appropriate for controlling highway construction,
mining, and municipal and industrial wastes. The elected official felt that
current laws are adequate.
The Tennessee water quality staff member said that all regulations (e.g.,
street sweeping, guidelines for agricultural and silviculture practices on
steep slopes, and controls over unauthorized dumping) should be local.
He felt that WQM is the most difficult and controversial program ever in
the field of water quality, and that, at some point, WQM and land use will
run into each other and law suits will result. In an urban setting, he does
not think that there is always legal precedent for all that WQM has to do.
The Georgia water quality person felt that the State laws, particularly the
model Erosion and Sedimentation Act were adequate.
The Tennessee State Legislator interviewed is on the COG Board. He felt
that the climate for environmental issues was weak, that they have "gone
too far on too many screwball issues". He felt that it is time for making
reasonable tradeoffs, but added that the State water quality agency is
usually successful in getting what is needed. He felt that the Jaws on the
books should probably be updated, but that this usually does not happen
until there is a crisis. This legislator felt that the most pressing need
is some kind of land use law to save farming.
The local elected official felt that whatever management system was decided
upon, they should have the power to make it work; not just serve to advise.
He feels that if it is put to a referendum, however, it would fail. The COG
Director felt that a management system could be paid for through a user charge.
He said that this power is already available through the Local Cooperation Act
and it has already been used to create a two county water district and a
transportation district.
C. Continuing Planning
Most interviewees felt that continuing planning would be a shared State and
local responsibility with the local agency updating the plan and the State
overseeing it. Both States held this view. The Tennessee representative
felt that the local role would widen particularly in the area of land use.
He added that if the City fails to pass the pre-treatment ordinance, the
WQM will have to become involved in that issue.
The Project Di.rector felt that continuing planning will continue to "pull
the pieces together". Either the planning agency or the managemeng agency
would "sharpen the focus on facilities priorities" and would become more
involved in other commnnjty programs such as capital improvements, HUD
community development, and EPA action plans. The TVA Engineer expected
continuing planning to involve updating the plan and serving as a clearing-
house for development projects. The elected' officials were less clear about
what continuing planning wou]d involve, but were certain of one thing -- it
must be accountable to elected officials.
CA-11
-------
The Project Director estimated that continuing planning would cost $150,000
to $200, 000 annually, and did no t_ exp..e.c_t_10.0.. per.cen.t-Ee.dexal ..funding- He,
said that the Policy Board understands t±iat they _.rnust_pay, ^ but,_they_.have nade
no commitments yet. This view seems consistent with attitudes expressed
by the elected officials. The COG Director said that the costs could be
paid for by sewer and water charges. The TVA Engineer predicted that it would
be paid for by a combination of Federal funding, sewer tax revenues, and
the local CARCOG assessment.
D. Relation to Other Water Quality Programs
The Project Director said that looking at a regional system is a priority
item of the work program. He feels that the WQM plan will control the
location, size, type and design of future facilities. He felt that
assisting in passing the pre-treatment ordinance and current hearings
on whether to expand the existing plant or to build a new one are two ways
the WQM can impact ongoing 201 work. The work plan describes a relationship
of coordination and communication to achieve maximum consistency without
letting the WQM effort "unduly delay" the facilities planning already in
progress.
Neithe_r_ of the State JLi aisons felt that the WQM program would have too much
impact on the 201 study, but both agreed that it would eventually be the
"guiding influence". The Public Works Director, who is an elected official,
felt that in the future the WQM agency will do Step I plans. The TVA Engineer-
feels that they are putting the "cart before the horse". He said that the
WQM plan should overrule the 201, but they should certainly be compatible.
There were a variety of opinions regarding the impact that WQM planning will
have on permitting and vice versa. The Project Director said that there
would be no impact -- it is a State responsibility. The TVA Engineer said
that the VJQM agency should review all applications. The Georgia representa-
tive said he did not know about impacts. The Tennessee representative said
they have discussed having the WQM agencies do permitting but was not sure
whether the federal law allows it. He feels that the ideal arrangement would
be a cooperative one where the WQM agency' provided technical support for
field work and inspection and the State does review and sign-off. He hopes
that WQM will recommend combining the EPA and State permits into a single
permit procedure.
E. Local Definition of Success
Everyone had a slightly different view of what would consti.tute a success.
These included:
o Project Director - if some group or agency is clearly defined
as a regional management authority with planning capacity,
monitoring ability and its own source of continuing funding.
CA-12
-------
o COG Director - if they get their plans off the ground
and can manage things regardless of who owns them.
o Local Elected Official - a management system with enough
authority to regulate and finance itself.
o Public Works Director - a regional treatment system.
o TVA Engineer - if they get rid of all the package treatment
plants. If water quality problems are put on a priority
list with associated costs. If a management system is set
up.
o State Legislator - if the plan is implemented over 20 years.
If river banks are zoned.
o Georgia State Water Quality Representative — if they create
a management system with local backing to control critical
areas. Further, if an authority keeps an inventory of
industrial raw materials and by-products and lists who needs
to dispose of what wastes. Ultimately, a "detoxification
unit" for industrial residuals.
CA-13
-------
IV. VARYING PERSPECTIVES
A. WQM Staff
The CARCOG staff members working on the WQM have a consistent viewpoint about
what they are and should be doing. There is some concern that the work
plan has not been approved yet, and therefore, they are not officially
proceeding. In the meantime, they have collected much of the data that
will be needed and they have organized approaches to the various work
elements. Major differences in views are, for the most part, a matter
of perspective reflecting the respondent's position in the organization.
The COG Director takes a more comprehensive and long-range look at. the
project. He sees it as a long-range element of the COG's overall program
and adds that the WQM plan is his agency's first priority, in part because
of the short time frame. In general, he feels they are further ahead than
most other projects in Tennessee "because we have all the pieces together".
Here, he is speaking of getting the several related agencies involved in
the project. He acknowledges that there are possible fights based on previous
antagonisms. The COG staff itself has undergone a recent reorganization in
response to internal and external criticisms. The COG Director's greatest
interest is in helping educate the local elected officials about the program.
He feels that, in the long run, they are taking the best approach for
all communities, although right now he feels that everyone does not see it
that way. He hopes to be able to show local officials that WQM planning is
in their best interest, and that everyone will pay equally. He is convinced
that the area is closer to a regional approach to solving a number of
problems than anyone now realizes.
The Project Director takes a public administration approach. He sees WQM
as an experiment in regional management and the way communities set priorities
in looking for grants (although he is not sure that EPA is ready to
accept this). In the past, each locality raised its own funds. A logical
starting point is merging air pollution and water quality interests. He
is particularly interested in seeing the Federal Regional Council become
stronger.
The Project Director said that setting up the WQM project and monitoring the
several contractors is a "major headache". The COG had to be reorganized
to create the kind of accounting and staffing system needed to manage WQM
planning. At times, the WQM position within the COG can be frustrating. For
example, they must clear all Policy Board meetings through the Executive
Director. In general, however, because they account for over half the COG
budget, they have access to most of the agency's resources, staff and financial
data. He feels that they have played a major role in the COG in pulling
together a data base, land use plans and a mapping system. He hopes that
they will also lead the way toward improved capital improvements and municipal
budgeting processes.
CA-14
-------
The shortened planning period (because work plan was late in being approved)
puts them in an uncertain position as to whether the project can be
completed on time. Any delays, such as needing EPA approvals, can
jeopardize meeting their deadline. The Project Director sees the staff role
as coordinator, and the other agencies and consultants as technical planners.
The staff will ultimately be responsible for selling the plan to the local
governments.
Other staff members interviewed were an Engineer and a planner- Most often,
their concerns centered around technical matters. For example, existing
land use plans are often not up to date and what data does exist is in
different scales. The staff feels that they are correcting these problems.
Because they have collected so much of the data, they feel that they are in
an excellent position to monitor the consultant work. The staff agrees
that the biggest strength of the project is that it provides a focal point
for all water related agencies to get together. This is a fairly new
arrangement, particularly in that it enables the States to participate at
the local level. The greatest weakness noted is that it takes so long to
get things done because of all the "channels".
B. Citizens
Because no public participation program has been_de^igngd_for_ this area^, no
citizens were identified to be interviewed.^ Views of an Engineer from TVA
who was on the Consultant Selection Task Force will be reported under
Appointed Official (Section IV D), because he more appropriately represents
an agency view.
C. Local Elected Officials
Two local elected officials were interviewed: the Public Works Commissioner
for the City of Chattanooga and a Walker County (Georgia) Commissioner.
The Public Works Commissioner said that he has been briefed on the WQM study
and even attended one of their meetings, but he is unaware of details. He
was under the "general impression that it's for a management system". Two
members of this man's staff, who are more involved with the WQM study,
present at the interview. The Commissioner also relies heavily on his
chief 201 consultant, who is also a major consultant for the WQM. In general,
the attitudes expressed were cautious with regard to CARCOG. He feels that
people are often unhappy with actions they have taken, and particularly with
the fact that Chattanooga has only one vote on the Council. The Commissioner
said that he would be opposed to any management system that is not answerable
^to elected officials. He felt that his department should be consulted more
often for their input into the plan. In general, lie said he was "committed
to the 1983 goal" and as evidence, cites that his agency is now pursuing an
ordinance for pre-treatment and cost recovery.
CA-15
-------
The County Commissioner has been quite active in planning, and he is Chairman
of the Policy Board. He said that he became interested in WQM because he
saw the management system crossing county and State lines, and he wanted
to be sure to have input. He felt that those elected officials involved
in the planning do not see a problem in crossing lines, but some of those
not involved, do. The Commissioner is pleased with the way his input has
been received, despite the "minor" problem in selecting consultants. Although
the Commissioner feels that there is only medium support for a regional
management system and only weak support for funding one, he felt it is
essential that the system have enforcement authority if it is to work and
not be merely advisory.
D. Appointed Officials
The official in charge of the area sewage treatment plant is elected, and
has been discussed in the previous section. The official whose views
are discussed in .this section is an Engineer for TVA.
The Engineer saw his role as providing technical expertise. TVA worked or.
the River Basin Plan (303e) and his historically been involved in the area's
water studies. Up to this point, TVA's role has been to provide the WQM
agency with data on background levels and pollution rates. Now TVA is
"zeroing in on combined sewer overflow". The Engineer hopes that they
will be able to prove that it is not a problem. The TVA monitoring network
will be extensively used as guidance on nonpoint source problems and they
will do additional sampling for areas with a particular problem such as ir
a community located beside an industrial plant. The Engineer served on the
consultant selection task force and is fully familiar with the WQM work
plan. He believes that EPA is not sufficiently familiar with the local area
and therefore is opposed to studies of certain activity-specific problems
and wants additional studies where TVA does not believe there is a problem
(for example, agricultural runoff).
The Engineer says that the hardest problem for the WQM staff will be fighting
the lack of confidence in CARCOG. He feels that people see it as a bureau-
cratic money waster, but is hopeful that WQM can improve that image. He
predicts that there will be some trouble when they start offering management
alternatives, but he believes that a regional concept could work here.
Opposition is particularly strong in the smaller communities which distrust
one of the consultants, believing him to be partial to the City's interests
and not looking after their own. Nevertheless, he sees a great potential
for solving a lot of local problems. He feels that the best way to improve
support is by getting the professional organizations involved.
E. State Legislators
The State Legislator interviewed is a recent appointee to the CARCOG Board.
Although he has not been involved in the WQM study, he has heard one of
their presentations. Although he is "suspicious of any federal program",
he believes it should be more than just a p]an. This Senator first became
involved with CARCOG because of his opposition to an industrial park
about to be built near a clean stream. He hopes WQM will carry on this and
similar battles.
CA-16
-------
F. State Water Quality Personnel
The Tennessee Liaison is in the local field office and was involved with
problem definition, identification of monitoring points, review of the
work plan and consultant selection. The State was instrumental in adding
at least three tasks to the work plan. He felt one of the problems so
far has been that the designated agency is not a water quality agency, so
they had a lot to learn. He sees his role as helping them learn, and
therefore move faster. He expects'to be on the Technical Advisory Committee,
although it has not yet been appointed. A State strategy has not been
written yet, so it is unclear how it will incorporate the WQM study. But
this person sees a significant role for WQM in the permit program.
Specifically, he would like to see the WQM agency conduct field work and
draft initial applications. He feels that permitting and other water
regulations are best done at the local level because they take more pride
in their work. The danger, he feels, is that if mismanaged, a local
regulation program can more easily become ineffective.
The Georgia Liaison has been involved in problem appraisal, designation and
work plan approval. He hopes to be a member of the Technical Advisory
Committee. This staff person has serious doubts as to whether the plan
can be completed on time, in part because of the difficulty in managing a
program that crosses State lines. In general, he is satisfied with his
involvement with the exception of the situation where the consultant
selection committee's recommendation was not followed. As in Tennessee,
the Georgia State plan is still being written, and he feels that, given
the very recent designation of three areas in Georgia, it will be some time
before the State decides upon the appropriate role for each agency.
CA-17
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
The plan_ probably will be coirtpleted^although possibly in a soirrgwhat^s^caled
down version. The fact that the work plan was not approved made everyone
anxious about meeting the deadline. In the meantime, they have accomplished
a lot of data gathering, mapping and task definition refinement which, over
the long run, will make the planning run smoother once it is underway. The
consultants are selected and ready to start as soon as approval is received.
The State of Tennessee has added three major work tasks, but it is difficult
to see how these can be done without cutting back on some of the original
tasks.
Emphasizing coordination with other agencies -- TVA, the City, and other
planning agencies — was a wide strategy for helping to achieve plan completion,
approval and implementation. It was necessary to rely on other planning
agencies for population, economic and land use data,and projections. In
addition, these planning agencies are experienced in working with the rural
areas. TVA has shared much of the load for technical water quality work
elements. They, are also experienced in this kind of work and in working
with the local agencies.
Support from the City of Chattanooga is likely, but by no means definite.
The Mayor, a former Public Works Commissioner, is on one of the Committees
and is fairly well versed on the subject. The current Commissioner is less
involved, although he does send representatives to meetings. The 201 Facili-
ties Plan being performed for his department will have a large impact on
alternatives available to the WQM in the area of point sources.
There may be some problem in gaining support for implementation from the rural
towns. There is an historic antagonism between them and the central city,
and this is compounded by the choice of the City's facilities consultant as
one of the WQM consultants, (made over the objections of the Consultant
Selection Task Force). A Policy Committee which is made up of elected
officials has been formed, and seems to have become a knowledgeable and
effective decision-making group.
Unfortunately, the COG has a poor reputation with some people and this could
harm chances for implementation. On the other hand, they are working hard
to change these opinions and the WQM staff has done several tilings to begin
management, even during the planning period. For example, they participate
in A-95 review and are supporting the pre-treatment ordinance. This has
made the group known publicly and has started people thinking about water
quality.
There are many signs that this area could achieve a regional management
system. There have been past regional authoritj.es for a transportation
district and two water districts. The COC, WQM staff and consultant
are experienced with the institutional setting and have thought about
their needs. The most difficult obstacles to regionalism is that^the
area covers parts of. two States. Many were skeptical that a workable
framework could be created, or if one was, that it would be manageable
within the dual restrictions of two States.
CA-18
-------
B. Public Involvement
So far, public involvement has been limited to local elected officials
and to staffs from other public agencies. There have been articles
in the local newspaper about the WQM project; unfortunately, many
stemming from the consultant selection controversy. There also have been
presentations to service clubs and three issues of a newsletter. Finally,
two public hearings were held when problems were being defined. It is
unclear how successful these efforts have been.
The WQM agency seems to have made a diplomatically wise move in asking
Coosa Valley Area Planning Council to design and carry out the public
involvement program. First, it ensures their involvement. CVAPC itself
had originally applied for designation as a WQM agency, but were turned
down. This arrangement brings them into the process. Second, CVAPC is
located in Georgia and among the mo.re rural parts of the designated area.
Their sponsorship should help overcome the distrust of Chattanooga by the
rural towns. Third, it means the public involvement program can draw upon
the contacts and experiences of at least two agencies.
C. Current Planning Process
The work plan encompasses a very large scope. Fortunately, the work
is shared among other agencies with many years experience (e.g., TVA, SCS).
The work program intends to cover point and nonpoint sources, whi]e
management planning will go on throughout the work period. Alternative
plans will combine all three elements.
Whereas these tasks are somewhat general, the tasks added by the State are
very specific. It is, therefore, difficult to see exactly how they fit into
the work program, except as supplementary reports. Similarly, they do
not really fit into the staff and consultant structure as it existed at
the time of the interview. The new tasks are:
o Examination of dissolved oxygen leve]s in Chickaniauga Dam;
o Analysis of pump storage on Racoon Mountain; and
o Evaluation of thermal effects of Sequoia Nuclear Plant.
Other comments about the planning process would be premature at this time,
except to re-emphasize that the staff has accomplished a considerable amount
while waiting for work plan approval. This is testimony to their commit-
ment and ability to perform the required planning.
CA-19
-------
D. Continuing Planning Process
The Project Director has several ideas about what could be done in
continuing planning. These include ways to become more involved in
capital improvements, budgeting and community development programs.
More likely, continuing planning will include plan update and clearing-
house" activities for water re]ated issues. If the WQM pushes others
to look at processes for development and community involvement, however,
that will be aconsidered useful.
In this area, both staff and elected officials seem to have done more
thinking about how planning (and implementation) would be paid for, than
some of the other areas examined. They thought about funding implies
an assumption that planning will ^continue.
E. Significance of Local Ejected Officials Involvement
The Policy Board, which consists of 31 elected officials, seems to have
evolved into an effective decision-making group. Support of the Mayor
of Chattanooga must be maintained, both because the City owns the treat-
ment plant and, therefore, has influence over certain, point sources,
and because of the City's dominance within the region. As in other areas,
elected officials are pairticularly concerned that WQM maintain political
accountability.
The rural elected offi c ial s a re least know1 edgeable a^ou^J^QM^yej^th^i^r
support is essential if a regional system is to be achieved. A Com-
missioner from a rural Georgia County is Chairman of the T?olicy Board.
This should set an example in other rural areas which have to gain from
cooperation. This Commissioner is strongly in favor of a management
system with enforcement rather than advisory authority.
CA-20
-------
AGENCY:
DELAWARE VALLEY REGIONAL PLANNING COMMISSION (DVRPC)
REGION: II - (New York) and III - (Philadelphia)
GRANT AMOUNT: $3,852,032 plus $935,140 from State of Pennsylvania
GRANT RECEIPT: June 30, 1975
STARTING DATE: July, 1975
STATUS AT TIME OF INTERVIEWS: Problem definition and data gathering
were completed under the Pennsylvania
COWAMP program prior to receipt of the
grant.
REASON FOR INCLUSION IN SAMPLE: This is a complex urban-industrial area.
The designated agency is simultaneously
carrying out three WQM planning projects.
DV-1
-------
I. BACKGROUND1
A. Area Description
The designated area of the Delaware Valley Regional Planning Commission
(DVRPC) includes five counties in southeastern Pennsylvania - Bucks,
Chester, Delaware, Montgomery and Philadelphia. The area is part of
the Piladelphia SMSA, fourth largest in the United States. The 1970
population of the area was 3,865,810. Although 87 percent of this is
in the metropolitan Philadelphia area, there is a range of attitudes
and needs, with the most rural found in the northern counties. Both
staff and other participants agreed that this diversity must be reflected
in the planning process if the Pennsylvania 208/COWAMP (water quality
management) plan is to be implemented.
The Philadelphia area is a leading manufacturing, distribution and
transportation center. Over half of the industrial establishments
will require pre-treatment in order to establish compatibility with
municipal wastewater. More than one-half of the area's direct in-
dustrial dischargers (101 of 181) are classified as having serious
water quality impact. The designated WQM area is included in the
State Water Quality Management Study Area #1, although the State pro-
gram (COWAMP) also includes Berks and Schuylkill counties. The five-
county area is included in an EPA Air Quality Maintenance area,
although the AQM area also includes parts of New Jersey. Finally,
the area is part of a regional planning area for which DVRPC conducts
HUD-701 comprehensive planning and DOT comprehensive transportation
planning.
The DVRPC is simultaneously conducting WQM planning for three separate
areas in its nine-county planning area. Besides the Philadelphia area
for which $3,852,032 was received, grants totaling $1,264,800 have
been received for the tri-county New Jersey area, and for $974,145
Mercer County, New Jersey. Together, these areas comprise the main-
stem Delaware River estuary. Planning for the three areas is being
closely coordinated, but remains separated because of special funding
arrangements and differences in status of water quality planning
between the two States.
B. Water Quality Problem
There are sixteen watersheds in the WQM designated area. All but one
has been designated as water quality limited by the Pennsylvania
Department of Environmental Regulation (DER). DER has established
Information for this Chapter was taken from the DVRPC Dssignation
Application; the DVRPC Project Control plan; State literature on COWAMP;
and from interviews.
DV-2
-------
uses for each of the streams and has promulgated criteria and standards
for these uses.
There was consistent agreement that the major water quality problems in
the area is the Delaware River estuary. Sources of this pollution are
municipal and industrial dischargers, stormwater, and benthic sludge
deposits (up to 15 feet in places). Tributaries of greatest concern
are the Schuylkill River (dissolved oxygen problems) and Perkiomen Creek
(nitrate and phosphate from agriculture runoff).
The three Philadelphia treatment plants treat the majority of both
City and suburban flows. However, there are over 77 other plants
operated by over 50 governmental units and sewer authorities, and an
additional 125 non-municipal plants (e.g., commercial packing plants).
Nearly one-half million residents use on-site septic systems which become
the source of both BOD and suspended solids pollution.
There is a considerable urban storm drainage problem. Over 75% of the
area is unserved by either combined sewers or a separate.storm sewer
system. In Philadelphia, where the need for a system is greatest,
a combined sower system is in use which discharges into the Delaware
and Schuylkill Rivers. Cost for separating the system has been set at
.8 to 1.6 billion dollars, which is considered a prohibitive expense.
Other nonpoint source problems include landfill runoff and leachate,
lagoon spillage, and agricultural and construction runoff.
C. Designated Agency
The DVRPC was established by interstate contract between the states of
Pennsylvania and New Jersey in 1967. The geographical jurisdiction
covers five counties in Pennsylvania and four in New Jersey. In addi-
tion to water quality, the agency is responsible for land use, water
supply, transportation, parks and recreation, housing and open space
planning, and has A-95 authority. DVRPC is currently updating its
comprehensive plan under the Year 2000 project. The 208/COWAMP plan
will comprise the Water Quality Chapter of that effort.
DVRPC has prepared a regional water supply pollution control plan for
HUD which has served as regional policy for review of over 200 facility
construction grant applications. Storm drainage plans for the region
have recently been completed. The Commission is under contract to the
Philadelphia DER to prepare a coastal zone management plan for the
Delaware River estuary.
The WQM planning project is a joint effort with the statewide Comprehen-
sive Water Quality Management Planning (COWAMP) program administered
by the DER.- COWAMP was well underway before WQM was initiated and DER
had contracted with DVRPC for technical and public participation services.
DV-3
-------
When the Federal WQM program was introduced, it became reasonable to
merge it with COWAMP because they are compatible in scope and philosophy,
and a merger would avoid costly duplication of effort. COWAMP was
altered slightly to include additional work on nonpoint sources and
institutions, and the WQM study area was expanded (with an additional
$975,000 in State money) to include Berks and Schuylkill counties.
The consultant under contract to DER was retained by DVRPC. It was
agreed that the completed project will become a major section of the Penn-
sylvania State Water Plan which is concerned with both water quality
and overall water supply.
At the staff level, 18 persons are assigned to WQM planning, although
many of these work on all three WQM projects. In addition, many DVRPC
staff persons spend part time, on WOM planning. The major consultant
has received nearly half the funding. This is used in part by a con-
sortium of subcontractors in five study areas: legal, social/economic,
groundwater, mathematical modeling, and biological/ecological. In
addition, contacts have been let with:
o
The University City Science Center, for stormwater
modeling;
o
All counties, for public participation assistance,"
o
The State, for printing and administrative assistance,'
o
The Philadelphia Water Department, for stormwater
data collection; and
o
The Delaware River Basin Commission .for estuary work.
Dy-4
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives ¦
Problems, goals, needs and objectives were defined by staff and circulated
through committees. The final determination was the result of a five month
committee on Plan Selection Criteria. Many of the issues had been identi-
fied in previous reports. Specific objectives for the immediate planning
period include cleaning up the gross pollution of the estuary — defin-
ing problems and recommending remedial action or additional study.
Other objectives included conducting an analysis of institutional manage-
ment, regulatory and financial issues. The issue of antidegradation
was addressed in Alternative Futures Workshops.
The WQM goals and objectives are clearly part of a larger set of regional
plans currently being developed under the Year 2000 peoject. In fact,
WQM planning served as a major impetus toward getting that effort under
way. The planning process for Year 2000 is cost-shared by WQM, DOT and
HUD. It is outlined in the Study Design and addresses the following:
o Determination of regional issues, goals and policies/
o Development and screening of 8-12 scenarios for regional
development;
o Preparation of three alternative sketch plans for regional
growth; and
o Preparation of detailed functional plans.
When citizens and elected officials were asked how WQM fits into the
overall objectives of the region, there seemed to be a consensus that
it was consistent and that the improvement of water quality is a priority
objective. Local areas obviously differed in their attitudes toward
growth, depending on the extent of present growth. No area of the WQM
expected to contradict local desires. In Chester County, for example,
it is believed that WQM will complement and enhance local goals of
preservation of agricultural land, protection of open spaces and orderly
development. There was some concern that 208/COWAMP and Year 2000
projects represented a duplication of effort.
B. Technical Component
Data from existing sources will be identified and used for both defining
problems and fashioning alternative solutions. Monitoring of low flow
conditions and dischargers will be conducted on seven tributaries to
help calibrate models. Analysis and evaluation will depend heavily on
modeling.
DV-5
-------
A new model for the Delaware estuary is being developed at a cost of
$732,000 plus $150,000 in-kind services (mostly lab work) from the
City of Philadelphia and computer time from the EPA in Annapolis.
The stormwater model is being developed by the University City Science
Center. Again, the Philadelphia Water Department if helping with data
collection so this model can be calibrated and verified. Stormwater
monitoring will be conducted in both urban and rural areas. The WQM
Chief Planner said he would have liked to have handled more nonpoint
source work under the program, particularly to have made gross allot-
ments of stormwater, agriculture, construction and landfill pollutants.
He felt collecting more data would have been helpful, but that NPS
analysis was most hampered by the poor state-of-the-art for NPS modeling
C. Management Planning
Management planning was just getting underway. Responsible staff
members were beginning to compile an inventory of existing agencies
and authorities. It was believed that, given the large number of local
agencies and the complexity of institutional authorities, the "manage-
ment" portions will be a major element of the study.
The agency's approach is to conduct management planning simultaneously
with technical planning so that each is analyzed in terms of feasibility
for the other. Because of the tremendous volume of water quality
.inventories needed, management planning fell fouj^months behind.schedule
It is expected that the institutional inventory and analysis will be
(finished by the time technical sketch plans are prepared.
D. Public Involvement Program
The key to the public participation program is the committee structure.
The Policy Advisory (PAC) is composed of representatives of eight
counties, and designees of municipal government and the general public.
The PAC provides policy guidance to Pennsylvania DER and to DVRPC.
The Technical Advisory Committee (TAC) consists of 29 members from
regulatory agencies, county and regional planning commissions, Federal
agencies, county health departments and the Philadelphia Water Depart-
ment. The TAC provides technical review and assistance to the PAC
and the consultant. The Study Advisory Committee (SAC) consists of two
representatives of each SAC subcommittee and delegates of county public
participation programs. The SAC's purpose is to provide policy guidance
from a local perspective. Four subcommittees are associated with SAC:
Industrial Dischargers, Municipal Dischargers, Agricultural, and
Environmental/Conservation/Public. Membership on these subcommittees
is open and flexible. All committees and subcommittees meet bimonthly.
Committees are active, but in all cases are more advisory than parti-
cipatory. In addition to the committee structure, the public partici-
pation program consists of a bimonthly newsletter, slide presentations.
DV-6
-------
and quarterly advisory meetings at the county level. So far, five
rounds of county meetings have been held, the most recent meetings
were on the subject of "Alternative Futures".
•The Section Chief seemed well aware of weaknesses and_criticisms
Ln the public paretic ipation_prqgr^am^.^ She described at least five
sources of dissatisfaction:
o
The commission has a variety of other committees which
compete for some of the same people's time,'
o
The watershed associations want funding,"
o
o
More money should be spent on public information and
less on committees,"
There needs to be better effect in getting the local
elected officials to participate,"
o
Some committees are unsure of the role they should play.
There was a sense that the public participation effort was as effective
as could be expected at this time. When it was time for more decisions
to be made, people would be more actively involved. The three citizens
interviewed were all very knowledgeable about and active in the WQM
project. They had been involved for over six months and had formed a
number of opinions about WQM — from both a local and a national per-
spective.
E. State and Federal Involvement
Because they are understaffed, EPA's guidance has been minimal, with
little or no technical guidance. The EPA Project Officer is involved
by telephone on almost a daily basis and visits are made between EPA
and DVRPC 2-4 times per month.-'- DVRPC feels greater coordination is
needed with air, water, solid waste and residuals management. Earlier,
they would have liked to know what the plans would include, but feel
such advice now would put them back on first base trying to fit their
work into another formula. Finally, the Chief Planner felt he would
like greater sympathy from EPA regarding timeframe and budget constraints.
He felt he needed greater flexibility to make trade-offs. The relation-
ship with Pennsylvania was described as excellent and friendly.2 The
man who had been involved most deeply was very recently promoted, but
they expected a similar relationship with the new appointee who had
also been involved from an early stage.
This has not been true of Region(II.where telephone contact is biweekly
and less than 2 visits total have been made.
Relations with New Jersey for those portions of the plan were described
as hostile,_with the State providing no useful input and almost total
interference. This is the situation as described by DVRPC and as it was
not part of the study sample.
DV-7
-------
F. Scheduled Outputs
The PCP described' how the five interim outputs and the sixteen WQM
outputs required by EPA will be completed. These tasks and outputs
are keyed according to the five-digit COWAMP Integrated Work Plan
system for consistency. The schedule for meeting these outputs, (see
Exhibit I) is taken from the PCP.
According to the WQM Chief Planner, final outputs are expected to be a
13-chapter report with extensive data, an Executive Summary of approxi-
mately 100 pages, and a capsulized popular brochure for massive dis-
tribution .
Interim outputs were considered useful and essential outputs for planning,
but the imposed deadline was a hindrance and consequently was ignored
to fit a more appropriate work schedule.
G. Achievements to Date
The WQM Chief Planner listed three major achievements to date. First,
they have completed the first round of the estuary program despite
overwhelming logistics. Second, a complex computerized data management
system has been established. Third, a reasonable public participation
effort is underway. The Regional Development Guide is expected to be
ready in September or October, 1976 and the estuary model is also scheduled
for completion in the fall. The staff seemed to feel that they were on
schedule only because they had a one year head start in the COWAMP
program.^ The staff director did not feel keeping to the proposed
schedule was important, so long as the final two year schedule is met.
The State COWAMP Program Manager also felt that the WQM agency might
not be meeting the PCP schedules, but agreed that this was to be
expected and not a matter for concern. Among the reasons cited were:
o There are always unanticipated technical problems;
o The sheer volume of information available slows the pro-
ject down,"
o People have questions that need answers and they need
time to react,"
o A six week review time is insufficient/ and
o Integration with the Year 2000 program has slowed
Ph i1adeIph i a down.
Although not the subject of this study, the New Jersey portions of the
study were considered far behind. Consultants were not even hired and
thus tasks and budgets could all bo expected to change. It was also
believed that the New Jersey portions were underfunded by as much as a
half million dollars and it was hoped that some of the "NARC money"
might be made available.
DV-8
-------
Exhibit I
Quarter
January-March 1976
April-June 1976
July-September 1976
January-March 1977
April-June 1977
October-December 1976
PROJECT MILESTONES
DVRPC
Event
Refined PCP submitted
All data inventories completed
Water quality surveys designed
Water quality models selected
Water quality surveys initiated
Data management system designed
"Present/projected population and
employment
"Preliminary revised wasteload
allocations
Present/projected land use
Delineation of proposed service areas
Wasteload and flow projections
Plan selection criteria finished
Water quality surveys completed
Water quality models calibrated
(b) Water quality assessment and seg-
ment classification
(d) NPS problem assessment
(e) Water quality standards and revisions
(f) Total maximum daily loads and gross
Delaware Estuary Model Completed
Total maximum daily loads and gross
allotments for Delaware Estuary
Alternative plans developed and
evaluated
Interim Report released
(a) Planning boundaries delineated plan
selection process initiated
Plan selection completed
(c) Inventory and ranking of point sources
(g) Point source allocations
(h) Municipal waste treatment systems
needs
(i) Industrial waste treatment systems
needs
(j) NPS control needs (BMP)
(k) Residual waste control/land disposal
needs
(1) Urban and industrial stormwater
systems needs
Ac tivi ty
11000,
12000
various
32000
61000
32000
21000
24000,
51000
61000
24000,
51000
75000
55000
65000
32000
61000
32000,
56000
32000
32000,
56000
) 61000'
67000
67000
94000
17000'
95000
95000
various
101000
101000
101000
101000,
102000
101000,
102000
101000,
102000
DV-9
-------
Quarter
Even t
Ac I iv1Ly
(m) Target abatement dates
(n) Regulatory programs to implement
the plan
(o) Management agencies to carry
out plan
July-September 1977 (p) Environmental, social, economic
impact assessment
Recommended Plan submit Led to
Governor, EPA for preliminary
review
October-December 1977 Public hearings on Recommended Plan
Review by local elected officials
Final submission to Governor for
review and certification
Source: DVRPC, Areawide Wastetreatmant Management Plan, 1976.
101000, 102000
102000
102000
1030G0
19000
19000
19000
19000
DY-10
-------
The State sees its role as helping to keep the schedule, but more im-
portantly, to assure the technical quality. The State holds regular
progress meetings, keeps a log of obligations, and meets regularly
over scheduling and methodology problems between DER, DVRPC and the
consultant. The State COWAMP Program iXanagerand WQM .Chief. Planner,
each felt that the regulations and guidelines are extremely ambitious,,
particularly in the area of NPS analysis. They also felt there was
not enough time to do everything within the required timeframe,„jvepm
if they had the money. These constraints had been incorporated into
the PCP, so there was no need to revise the work plan.
DV-11
-------
III.
EXPECTATIONS
A. Water Quality
There was a general feeling that water quality has improved and will
continue to do so. Many felt that the Philadelphia region was far
ahead of the rest of the country. WQM planning is expected to provide
valuable information for identifying major sources and assuring the
most results for the_money spent. Stormwater problems were not expected
to ^improve. Along with other_p_rograms _ such as p_ermi ttin gt. the WQM
project is expected to have a definite effect on water quality in the
_ region. Persons interviewed felt a greater emphasis is now needed
on enforcement, to make sure that there is an improvement. Several
persons emphasized that this was only a plan, that improvements
would be gradual and phased over time. WQM plan was seen as a guide
and a policy framework towards achieving improved water quality.
The WQM Chief Planner mentioned that the expected immediate reductions
in sedimentation and that the leachate problem would be cleaned-up.
He expected state water quality standards to be re-examined, and in
some cases lowered.
I There was general agreement that the 1983 goal would be met where
attainable. That is, not in all water bodies because it would be
unrealistic. Three examples cited of where it was unreasonable are:
o The upper headwaters where there is no technology
available to solve the substantial nonpoint source
problems;
o Where stormwater enters the estuary and cannot be
treated without unreasonable expense; and
o In the port area where contact recreation is an appro-
priate goal.
For many areas, the fishable goal was expected to be reached, but not
the swimmable goal. Several persons doubted that the goal v/ould be
reached by 1983. In part, this is because it simply takes so much
time to "flush out" the system.
B. Plan Approval and Implementation
Each person was asked to rank the likelihood of plan approval on a scale
of one (lowest) to ten (highest) at the local level and at the State
level. There was unanimous agreement that there would be approval by
the State (10), in part because that State was so involved and would
have no choice but to approve. For the local level, there were a
variety of answers. Half felt approval was likely because most problems
were being solved as they came along. One citizen answered "zero or
ten depending on whether they do it right", but said approval was
DV-12
-------
probable. One citizen felt the term local approval was inapplicable and
acceptance was more appropriate. Several respondents felt that local
approval was a fifty-fifty possibility, expecting a possible power play
depending on how the final plan was written.
Each person was also asked to rank the likelihood of plan implementation
One citizen and one local official felt they could not answer until
they better know the outcome of the plan. The Commission Director
felt it was very good (8 or 9), but that the extent of implementation
would depend on finances. All others questioned felt likelihood of
implementation to be around 5 or 6. Specific limits to implementation
mentioned include:
o If the plan is written as guidelines, it will be more
readily accepted;
o If it is too deti'aled and does not allow for flexibility
in growth and development, it will have problems;
o If they are successful in obtaining public input,
people are educated to the aims and benefits of the
project, and people truly feel involved, it will meet
with greater success; and
o Although everyone assumes there will be regulation, there
opposition to this being done at the State and federal
levels.
There was general agreement that the people essential to plan implemen-
tation included the public, the local sewer authorities, and political
persons from the counties. Many such people were being actively in-
volved through the SAC, TAC, and PAC committees as well as the DVRPC
Board.
It is DVRPC's position that creating new management agencies is not
feasible and would jeopardize implementation. The State legislator
also felt that citizens, local officials and the legislature would all
be opposed to creating new institutions. Regardless of what management
structure is finally selected, additional funding would be needed to
increase enforcement, for more collectors and for solving the problems
of water quality and water supply. It was suggested that much of
these costs would be greater than what could legally be called a service
fee, particularly if NPS and groundwater improvements are included.
There seemed to be a consensus that new State laws would not be needed
to implement the plans. The WQM Chief Planner specifically stated that
he expected to steer away from the kind of recommendation. There was
agreement that the Pennsylvania DER had most of the implementation
DYt-13
-------
authority needed through the Environmental Amendment-'- and the Clean
Streams Act. Because Pennsylvania cannot delegate its regulatory
authority under the Act, the DER was expected to keep these pero-
gatives with no additional delegation of authority needed. The local
official interviewed hoped there would be no new State laws because
he felt they were over-regulated already.
The State legislator and State COWAMP Project Manager felt it was
possible that new state laws and/or local ordinances might be needed
for urban stormwater controls. The legislature also hoped to see new
land use laws to protect agriculture, but did not feel these would
necessarily come about only because of WQM.
C. Continuing Planning Process
All persons wore asked about jtheir expectations concerning the WQM
project, and given a list of possibilities. Only two, a citizen and
alocal official, _said it would_go away after two years; all_jpther s
said it would not. One citizen felt the entire timetable of PL 92-500
would be set back. The same citizen felt DVRPC was getting too power-
ful and beginning to go beyond its authority. He felt that the
Delaware River Basin Commission (DRBC) had the necessary authority
and was more properly the lead agency. No one felt that the State
would solely take, over water quality planning; rather, it would
remain a shared function with both the State and DVRPC playing im-
portant roles. Most felt that WQM would have an impact on future land
use and development decisions, and some felt new policy would be
generated in those areas. Because it is generating a good data bank,
it is expected that WQM will be useful not only for land use planning
but also as a basis for making permit and construction grant decisions.
Most said they expected WQM would be completed within two years, but
the State COWAMP program manager pointed out that WQM should never
be considered completed because it must be treated as an ongoing
function.
Continuing planning was seen as a constant update of the WQM plan.
Because of the size of the City, the Philadelphia Commissioner of
Water expected the City to continue to be a major influence in both
management and planning.. He expected stormwater to eventually be.
studied, but not for many years. The WQM Chief Planner saw his role
The COWAMP program originated with the 1970 amendments to the Pennsylvania
Clean Streams Law, and EPA Regulation 18 CRF 601 (later incorporated
in PL 92-500). Further State commitment came in the form of the
Pennsylvania Environmental Amendment (adopted in 1971) which states
that "People have the right to clean air, pure water and to the esthetic
values of the environment". Although similar to NEPA in objective,
the Amendment requires environmental evaluation throughout planning and
a testing of alternative environmental choices.
DV-14
-------
in continuing planning to be one of monitoring compliance (institutional,
financial and water quality) and plan update. He expected a five
year transition period. The State legislator expected that by the time
the plan is finished, everything will have changed and it will all
have to be done over.
There was considerable uncertainty as to how continuing planning would
be funded. One citizen and the Commission Executive Director felt
State and Federal assistance would be a necessity. The State legislator
felt the State would continue to support water quality with funding,
although there was some opposition because of dissatisfaction with
the slowness of permitting procedures. A Pennsylvania House Select
Committee to Investigate the COWAMP program will soon recommend a full
investigation of State spending for water quality, a reflection that
some feel there has been waste. The local official felt water quality
should be paid for at the local level because there was less chance
for waste. He further felt that the existing study area was too large
and, in the future, WQM should be conducted on a watershed basis.
This view was not shared by others. Both the State COWAMP Program
Manager and the WQM Chief Planner estimated the cost of continuing
planning to be a half million dollars per year. The Commission
Executive Director felt that this cost would fluctuate, but that they
were currently staffed at the appropriate level for continuing plan-
ning. Although funding for continuing planning had not been discussed
at the policy level, the DVRPC Board is aware of the need and is interested
in the issue. The WQM Chief Planner speculated that some possible
funding sources might inlcude charging for A-95 review, block grants,
State subsidy, county funds, shift of 106 funds, and/or retaining
a percentage of permit fees.
D. Relation to Other Water Quality Programs
There was general agreement that WQM would be used as a guideline to
help determine size, location and discharge of municipal plants. Most
felt that 201 plans would have to be consistent with WQM. The WQM
Chief Planner believed WQM would have no impact on work .already..
underway (beyong Step II). The State COWAMP Program Manager-expected
both 201 planning^ and WQM would, need constant revisions.,, Currently the
state has _a._..backlp_gi of .Step. I.applic_ajLioris_. If qranted,_these.would .
foreclose a lot of WQM planning. The State is attempting to solve
both short-term local needs and the longer range regional needs.
A range of expectations regarding the relationship between NPDES and
the WQM program was expressed. One member of the Industrial DIS
Subcommittee believed WQM would have little effect on permitting,
although it might possibly affect future permitting for plant locations.
A second citizen felt the WQM should simply adopt the existing State
DV-15
-------
permit procedures because they are adequate. The WQM Chief Planner
felt that WQM nonpoint source analysis might indicate the needs for
a reduction in point source allocations. The State COWAMP Program
Manager felt WQM would provide segment-by-segment maximum daily leads
from which allocations could be derived. Currently, EPA operates the
permit program, but it is expected that the State will probably take
it over. WQM data will probably not be ready for second round per-
mitting.
E. Local Definition of Success
All persons were asked what they would consider a successruj. wyM effort.
Several mentioned that success would be achieved if a WQM plan is
adopted and implemented by all governments, while the WQM Chief Planner
noted it would be successful if implemented with 4-5 years (rather
than immediately). Several noted that in the final analysis, upgraded
water would be the measure of success, both the State legislator noted
that this must not be at the cost of "bringing everything else to a
screeching halt". One person felt WQM would be a success if it solved
small problems in various areas.
No one defined success in terms of a document. One citizen specifically
mentioned that WQM must not be a detailed plan, but rather a concise
guideline. Several persons saw success in terms of establishing a
particular approach or process. To the COG Director, success would be
creating a preventive versus a mitigating approach. To the State Water
Quality Liaison, success would be establishing a process with greater
efficiency, accountability and support. To one citizen, WQM success
would be creating guidelines that could be used by a range of groups
such as the State for permitting, and local agencies for planning and
zoning. Another citizen felt WQM would be a success if it educated
people and expanded their thinking about land use in the direction of
a metropolitan urban/suburban approach. The State Liaison felt success
would be achieved if there was greater dialogue among various levels
of government.
Everyone expected water quality benefits from the WQM plan, but felt
these benefits would be small and incremental because of Philadelphia's
relatively good water conditions. Greatest benefits were expected to
be in the area of providing reasonable input to land use planning and
more orderly growth. The State legislator saw WQM providing more clout
to the goal of preserving agricultural lands. One citizen mentioned
WQM would serve as a training ground for achieving better local coopera-
tion at a regional level for all issues. One interviewee felt the
greatest benefactors would be small communities; the cities were well
studied and are relatively self-suffcient. Technicians generally
agreed that a proper mathematical model would result.
DV-16
-------
Everyone expected WQM costs to be paid by the taxpayer (rather than
industry or through a users fee), and probably at the local level.
One citizen expected reduced costs because of decreasing emphasis
on the environment; another citizen felt it would cost more but this
was a small expense campured to the saving. Cost for continuing plan-
ning has not been officially discussed at a policy level.
DV-17
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM staff felt they had adequate support and resources from the
Commission to adequately run their project. Planning programs within
the Commission are linked through the Regional Development Guide
(Year 2000) program, which over the long run, will improve consistency
and compatibility, but over the short-term tends to slow down the
WQM schedule. There was a general sentiment that the work previously
completed under the State COWAMP was useful, had given them excellent
experience and put the project ahead of where they otherwise would
be. -1-
)
The Commission's Executive Director felt the biggest problems with WQM
was communications with the many small member governments. He also
felt that coordination with the State was complicated because the pro-
gram had formerly been State managed. He also felt that, for the
same reason, there was a greater capability within the program and it
/ seemed closer to policy.
B. Citizens
The first citizen interviewed was on the Industrial Dischargers Committee
and SAC. He felt that WQM was a mammouth undertaking and difficult
to manage because of all the data. He was concerned that there was
a tendency to get to "solutions" too fast. He felt they should make
sure all the facts and information were there, that motivatious for
various input should be weighed and that solutions should not be
rushed. As a committee member, he felt that the consultant was not a
good choice. In one .instance, he felt the consultant had inadequately
responded to Committee comments on chapters.
The second citizen interviewed was on SAC and PAC and has been extremely
active in other citizen efforts for Montgomery County. He felt that
citizen involvement is an ingredient to implementing and enforcing
the plans, yet there was not enough flexibility within time constraints.
Hefelt the staff^was _recept.ive to input, but it was usually too'late
have much impact. Advisory groups need adequate time to review, process
and report on work. This topic has been widely discussed in committee
meetings and sentiment is that, if input is not used, there will be no
future public participation. A working draft paper on this issue is
currently being written by a subcommittee.
The third citizen interviewed is Chairman of the Environmental/Conser-
vation/Public Subcommittee. He repeated the concerns about use of
This was not the case for the New Jersey projects. 303(e) planning there
is underway, and data is available, but it is not useful. The New
Jersey models do not work.
DV-18
-------
Committee input and added some additional concerns: committees do
not understand their charge; individuals are asked to go to too many
meetings - this is a particular burden for unpaid persons and inevitably
leads to adivision of public input. This citizen also felt that early
problems with attendence were improving, but not solved. Finally,
he was critical that committees do not reach the general public where
there was widespread ignorance of what WQM is all about, and no one
knows how to inform them.
Citizens and local officials seemed to feel that greatest problem with
WQM was deciding what to do. They felt they had a list of problems,
but were still not sure what they are supposed to come up with. There
was also some feeling that jargon and constantly changing scenarios
often got in the way of understanding and full participation by the public
Finally, there was some feeling by citizens that the project was being
rushed to meet EPQ imposed schedules resulting in insufficient time
for adequate public input and review. There was a sense that WQM repre-
sents a very large scope of work and there was a tendency to try to
find solutions too fast. Citizens and local officials repeatedly
preferred to go slower, making time for their input. They also clearly
saw the connection between having their input properly received and
ultimate plan approval and implementation.
'The Public Participation Section Chief felt a variety of interest
groups (such as recreation and sportmens clubs, civic associations,
farmers groups, SCS, realtors, environmentalists) were represented
through the committee structure. She felt that labor educators and
land developers should be more involved. There .are ten elected offi-
cials on the PAC, although some usually send a delegate - (e.g., a
Director of Planning), the Section Chief further noted that with over
352 municipalities in the area, there was a wide range in sophistication;
thus, public participation was more successful in some areas than in
others.
C. Local Elected Officials
A Chester County Commissioner was interviewed by telephone. He formerly
participated in the Bradywine Valley Watershed Association and on a
COWAMP citizen subcommittee. He was concerned about possible dupli-
cation of effort by COWAMP, WQM and Year 2000. As a County Commissioner,
he helped create a Water Resources Authority to represent county
interests.
This official's view of WQM was that the area was much too large. He
felt that water quality problems were best approached on a watershed
basis, solving one small problem and then applying the solution else-
where. He also felt this kind of work should be paid for at the local
level so there would be less waste. He was definitely opposed to
additional State laws and regulatory agencies and felt policy-making
should be only at the local level.
DV-19
-------
The WQM Chief Planner felt that input from local elected officials
thus far had been minor - they "haven't been able to drag them
(elected officials) out of the bushes". He felt the officials most
essential to implementation were the eight counties, four cities
and two States. All are represented on the PAC and on the Commission
Board.
D. Appointed Official
The official interviewed is the Water Commissioner for the City of
Philadelphia. He is Chairman of the PAC for the 208/COWAMP program.
Because his official role as head of an operating sewer agency requires
him to be initimately familiar with PL 92-500, he sees participation
in WQM as a continuation of those responsibilities. He expects to
continue to be responsible for treating the wastewaters of Philadelphia
and over 20 surrounding communities, and feels the size of Philadelphia
alone dictates that he must play a key role in any planning program.
The Commissioner felt that, in the future, 201 will work through WQM,
although there must be a mechanism for continually updating WQM plans.
He said that the area would complete high secondary by 1982 and that
this capacity should last until 2000. His own agency's biggest problem
seemed to be compliance with the requirement aht he discontinue sludge
disposal at sea.
E. State Legislators
The State Representative from Chester County was interviewed. He has
attended DVRPC Year 2000 meetings and his wife is on the Conservation
Subcommittee of Year 2000, but he has had no direct contact with the
WQM program. This Representative is on a House Select Committee to
investigate the COWAMP program. The Committee was originally formed
in 1974 because of opposition to DER estimates for agricultural
consumptive water use in Chester County. In 1975 the Committee mandate
was extended to investigate all water planning in the State (including
COWAMP and the two joint 208/COWAMP projects). Hearings before the
Committee illustrated the problem areas listed below.
o Putting Philadelphia in the same data base as the
surrounding communities makes a great difference in
the statistical results.
o Much of the data is out of date.
o Although the concept is good, costs are out of hand.
There is a great deal of duplication in data gather-
ing. There was some sentiment that contractors are
charging as if this was new data, when it is really
old data.
DV-20
-------
The committee will continue its investigation next year, and is suggesting
that the Federal government investigate their part of the expenditures.
The legislator felt that the State would continue to financially support
water quality and other conservation measures. He sensed growing
opposition to DER because of slow permit approval procedures, a loss
in priority for environmental issues (e.g., a floodplain law had
recently been defeated), and an opposition towards creating new insti-
tutional arrangements. He did feel, however that existing laws such
as Clean Streams and existing powers such as those held by the River
Basin Commission would enable them to meet the 1983 goal. He expected
the greatest results would be in respect to helping achieve some shared
goals relating to land use planning,
F. State Water Quality Personnel
The State Department of Environmental Resources has been intimately
involved in the project since the early stages of writing the designa-
tion package. Because the WQM is so closely connected to the COWAMP
program, they have remained closely involved in all parts. The COWAMP
Program Manager attends PAC meetings and other Department staff attend
TAC and SAC meetings. The State clearly feels its role also includes
helping to keep the project on schedule through regular progress
meetings and joining consultant/state/DVRPC policy meetings. The
State, however, sees its primary role as assuring quality technical
planning. The State believes that there are always unanticipated
technical prolbraes, and that needs for public participation and
other program coordination may further slow things down, but that
technical quality must be maintained above meeting time deadlines.
In general, the State DER seems satisfied with the role they are play-
ing. They did mention that they would like to participate more on a
national level (they had helped work on revision of the regulations).
The State COWAMP Program Manager felt the biggest problems with WQM
to be assuring public participation, assuring statewide consistency
and acquiring competent staff and consultants.
Dy-21
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan' Completion, Approval and Implementation
'Because there seems to have been a considerable amount of data collected
in past studies and an even greater amount of start-up organization ac-
complished under the Pennsylvania Comprehensive Water Quality Management
Planning (COWAMP) program, Philadelphia has an excellent chance for plan
approval and implementation. Their work program is well thought out and
generally understood by all those interviewed. The one exception to
this statement might be in the public participation program where citi-
zens seemed to be struggling with what role they should play.
The citizens involved have participated in a number of other planning
programs including the DVRPC's Year 2000 project currently underway.
The broader planning context encourages citizens to assess the WQM
process' comprehensive approach to regional problems. On the other hand,
the broadscale effort promotes citizen concern that the process slow
down to allow for adequate time for review and comment. On this point,
the State had agreed that greater time was needed for meaningful citizen
input. Further, citizens felt that time constraints allowed only super-
ficial study. The State also cited the time problem and underscored
the State's preference for a quality product to a punctually completed
plan.
The joint WQM/COWAMP effort is probably the greatest factor in whatever
accomplishments result. The goals and objectives of the conjunctive
effort, consultant selection, and design of the public participation
program were all thought out before WQM planning officially started,
which affords DVRPC at least 2 one year head start. Moreover, State
participation is so extensive in DVRPC WQM activities that the State
is essentially an integral part of the process and will aid greatly in
obtaining State approval. State laws gives DER broad responsibilities,
many which DER may not delegate.
Because local elected officials are not extensively involved, inter-
viewees rated the likelihood of plan implementation at around fifty-
fifty. DVRPC expects to rely on existing agencies and authorities
for implementation, which should enhance the prospects for implementation.
In addition, the State has broad implementing authority which promises
support for implementation.
For the most part, implementation problems may arise in making existing
management structures work. DVRPC does not intend to create new manage-
ment agencies. The management/institutional analysis will focus on
identifying those areas where no authorities exist and allocating
necessary authority to existing agencies. It would seem that utilizing
DV-22
-------
existing agencies promotes plan implementability, although depending
upon DVRPC's success in achieving workable management arrangements.
Existing management agencies include EPA which has permit authority;
State DER with broad planning regulatory powers; DVRPC and Delaware
River Basin Commission at the regional tier; the counties which have
planning and advisory powers; municipalities which have zoning authority;
and sewer treatment agencies at the county level and primarily in
MCD's. One potential area of conflict is the role of the Basin Commission.
The Commission is competitive with DVRPC for certain management respon-
sibilities. Although there is some concern that, because of its make-
up, the Commission is less accountable, there are those who believe the
Commission possesses the necessary implementing authority and is the
most logical WQM agency. The conflict between the two regional bodies
will not be readily resolved and potentially could increase in the course
of the WQM planning process. Overall, there seems to be a growing
sense that many problems must be approached regionally and that WQM
is somewhat of a testing ground for that concept.
B. Public Involvement
The public involvement program is well developed and has a full-time,
experienced staff. The public participation effort has the support
of the entire agency and the commitment of the full staff towards
achieveing true involvement. The staff felt that they have a relatively
successful program, although they are still looking for ways to improve it.
The advisory committee membership represents a range of interest
groups and many of those involved could be termed "professional citizens".
To the extent that the public participation program emphasizes the
committee structure, it falls down to some extent .in efforts to inform
and educate the general public. The quarterly rounds of county meetings
seem an honest attempt to involve citizens in the planning process
for decisions needing the broadest input. For example, the most recent
attempt presented "Alternative Futures", for public comment and was
considered one of the more successful outreach programs. However, it
was still felt that citizens are not used to being involved in the
early stages of planning and it is easier to gain involvement when
alternatives have been formulated and can be reacted to, and when
decisions must be made.
C. Current Planning Process
The planning process"is at a point of continual feedback. Goals and
objectives were identified in preparing the WQM/COWAMP program, but
dissatisfaction by the citizens committee can be seen, in part, as a
re-examination of those goals in relating them to more local goals.
Also, because .the WQM is part of a larger set of regional goals (in
the Year-2000 effort), goals are being constantly re-examined as they
relate to other goals. One effect of WQM has been to force just
this kind of regional examination of objectives, particularly for land
use and growth policies for the different parts of the region.
DV-23
-------
Data gathering was completed mostly'by the State, however, additional
data is being collected and modeling completed in the area of storm-
water pollution. Data collection of existing management, regulatory
and financial institutions and authorities has only recently begun.
Once this is completed, technical and institutional planning will
continue in formulating alternatives that are both compatible and
feasible. Feasibility will be determined, in part, by reaction of local
elected officials and the public (through committees). Because
alternatives have not been formulated, impact assessment has not begun.
DVRPC expects to do considerable analysis of air quality impacts,
and this analysis wil] provide continual feedback in reformulating
alternatives. ¦*- Finally, plan approval and implementation will depend
upon the degree of success in these earlier planning stages in achiev-
ing consensus of objectives, and in involving a wide range of interests.
D. Continuing Planning Process
There^isr^s.uch^.hi^Qhijicommitment to this proqr.am, by. bo.th. .the State and
DVRPC that it is extremely likely_that continuing planning will
occur here. There is wide support by citizens for obtaining cleaner
water. However, there is great hesitation about finding new sources
of money to do this. It is not believed possible through DVRPC
resources (which come from meirhier governments) , although a scaled
down version would be possible. If this were the case, DVRPC role
would be as an overseer of implementation. DVRPC does not have
the legal authority for regulation and does not anticipate seeking it.
The State does have such authority and is committed to using it,
J2. Significance of Local Elected Officials' Involvement
Local elected officials are involved to a variety of degrees. The
Water Commissioner, who represents the Mayor of Philadelphia on such
matters, is actively involved in coordinating WQM with his department's
201 activities. The eight counties are on PAC and they are generally
also on the DVRPC Board. Most of time send delegates, usually the
Planning Board Director. The minor civil divisions (MCD's) are not
considered essential to plan implementation. In general, local elected
officials have not been very involved, despite efforts by the staff.
It is believed that involvement will increase as time for more
decisions comes closer.
There i.s some dissatisfaction that Region II has not approved similar
air quality impact assessment for those, parts of the program.
DV-24
-------
AGENCY: EAST WEST GATEWAY COORDINATING COUNCIL (EWGCC)
REGION: VII- (Kansas City, Missouri)
GRANT AMOUNT: $2,243,000
GRANT RECEIPT: Nay 23, 197 5
STARTING DATA: January, 1976
STATUS AT TIME OF INTERVIEWS: The planning effort began in January, 1976,
upon completion and acceptance of the work
plan. The program is currently in the data
collection phase.
REASON FOR INCLUSION IN SAMPLE: The area is representative of an urban-
industrial environment.
EWG-1
-------
I. BACKGROUND1
A. Area Description
The East-West Gateway Coordinating Council (EWGCC) is the designated
regional planning organization for the Missouri portion of the St.
Louis SMSA. The area covers 2,713 square miles. This includes the
City of St. Louis, Missouri and the four surrounding counties of
Jefferson, St. Louis, St. Charles and Franklin. The Illinois portion
of the SMSA contains a contiguous WQM planning effort which is being
undertaken by the Southwestern Illinois Metropolitan and Regional
Planning Commission (SIMAPC). The Missouri study area contains approxi-
mately 65 percent of the SMSA land area and 77 percent of the SMSA popu-
lation. St Louis is the eleventh largest SMSA in the country. The 1970
study area population is 1,827,635.
St. Louis City and County represent 86 percent of the population of
the study area. The City of St. Louis is the only jurisdiction ex-
periencing a decline (-17%) in its growth rate. Franklin, Jefferson
and St. Charles Counties are predominately agricultural in land use,
however, they are experiencing significant growth in industry and popu-
lation. The area.is characterized by a complex institutional setting
with 244 general purpose units of government. The majority (152) of
these jurisdictions are located in St. Louis county.
Population projections for the region indicate that approximately a 20
percent increase in growth is expected by 1995. If present trends con-
tinue, the majority of this growth will occur in Franklin and Jefferson
counties.
Water quality is not a high priority issue in the St. Louis region. The
Merimac River is exceptional, however, because there is a high level of
citizen interest in its preservation for recreational uses. Rivers are
a strong political issue with a high level of concern over institutional
arrangements in developed area, and over the acquisition of services in
rural areas.
1
Information for this Chapter was taken from Water Uses in the St. Louis
Region, EWGCC, 1976; Regional Water Quality Profile, EWGCC, 1976; and
various interviews.
EWG-2
-------
B. Water Quality Problem
The St. Louis region is located at the confluence of the Mississippi
and Missouri Rivers. The Merimac River runs through the southern por-
tion of the region before emptying into the Mississippi.
Water uses in the St. Louis region are varied. A primary water use is'
transportation, a large number of St. Louis industries utilize barges
for shipping and receiving commodities. Recreation is a less fiequent
water use and is generally centered on the Merimac River. The use of
water for recreational purposes has been steadily decreasing over the
past 30 years. This is partially attributed to a worsening of the water
quality. Other contributing factors cited were improved access to out-
lying areas, the disappearance of beaches and the absence of large lakes
for motorboating. The primary industrial use of water in the study area
is fcr cooling or condensing purposes. Sixty-six percent of wastewater
discharged from industry is cooling water.
Both surface and groundwater are sources of water supply in the. region.
The St. Louis area has a growing water supply problem. Low flow periods
currently jeopardize the present supply. Additionally, many of the un-
developed areas use septic systems on unsuitable soils. This constitutes
a health hazard in many cases and is a threat to the preservation of
the quality of the groundwater.
In addition to five water quality limited tributaries, there are a number
of water quality limited segments on the Merimac River and Coldwater
Creek. Standards violations for ammonia, dissolved oxygen and phenol
occur. Non-point sources of pollution (agricultural and urban runoff,
and combined severe overflow) threaten the 1983 goal achievement. A
complex institutional setting adds to the burden of the water clean-up
effort with over 400 existing sewage treatment facilities.
C. Designated Agency
The East-West Gateway Coordinating Council is a bi-state regional plan-
ning council established in 1965 for the St. Louis SMSA. The EWGCC has
a membership of 128 general purpose units of government. Two WQM studies
are being undertaken in the separate States. EWGCC is doing the Missouri
portion and Southwestern Illinois Metropolitan and Regional .Planning
Commission is doing the Illionois portion.
EWGWCC is experienced in water quality planning. Major studies include:
o St. Louis County, Water Pollution Control, Phase II
Areas Tributary to the Merimac River, (1972),'
EWG-3
-------
o 1995 Water Facilities Plan* (1974,*
o Sub-regional Water and Sewage Planning, (1972),* and
o 3(c) Water Quality Management Planning Study.
Programs at EWGCC which share a data base with WQM planning are HUD 701
and transportation planning. No coordination has yet occurred with
Air Quality Planning because Illinois and Missouri have not decided
how air quality planning is to be administered. EWGCC conducts other
programs including solid waste, mass transit, health, A-95 review and
air pollution. EWGCC also has a contractual relationship with the Corps
of Engineers concerning data gathering in the Urban Studies Program.
There is no conqprehensive plan for the region. Program coordination and
prevention of duplication are the responsibility of individual program
directors.
The WQM staff consists of 11 professionals: the Project Director, the
Project Coordinator, 3 Engineers, 2 Management Specialists, 3 public
participation/information specialists, and 1 A-95 coordinator. One of
the engineers is a part time consultant, whose major function at.this
time is liaison with Regional EPA.
There are three committees associated with the WQM effort. The Policy
Committee is composed of the chief elected officials, water associated
industry representatives and citizens (25%). This Committee is delegated
major review and approval functions in. the planning process. The Citizen
Advisory Committee is delegated a review function. The staff stated that
considerable and successful efforts were made to attract a varied repre-
sentation of business, industry and environmental interests. The Technical
Committee, assembled for previous work with the Corps of Engineers, is
playing an advisory role in the WQM planning effort.
Two consultants, have been contracted for the duration of the planning period.
They are involved in every aspect of the process. One firm is primarily
responsible for nonpoint source, residual waste and municipal and in-
dustrial point source work. The other is primarily responsible for the
management/institutional aspects of the study. The EWGCC functions include
public involvement, project coordination, monitoring and facilities coordi-
nation. The State of Missouri has contracted for review and technical as-
sistance.
EWG-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
EWGCC is currently undertaking a water clean-up planning effort which
emphasizes citizen input. A public information program and workshops
are being actively used to educate the public and obtain local input
on water goals, uses, problems and solutions. One priority of the study
is to define alternative management systems which consolidate some of
the 400 operating agencies in the region. Another priority of the study
is to clean up the Merimac River for recreational purposes.
B. Technical Component
Consultants have been employed to do the technical aspects of the study.
This includes point and nonpoint sources work and residual waste planning,
however, the State of Missouri will be doing the nonpoint agricultural
work in the study.
EWGCC is providing the land use and population data from previous studies.
The primary addition by WQM planning will be aggregating the data on a
watershed bases. The study places emphasis on the lower Merimac Valley
because of its recreational value. The state data was reported to be
somewhat helpful, but in need of refinement, especially the location
of point sources of pollution. EWGCC is also doing some 201 Step I
work for local areas in need of technical assistance. This element
was written into the plan before EPA guidelines made 201 work ineligible.
C. Management Planning
EWGCC is presently conducting an inventory of approximately 25 existing
management agencies. The size of the sample may be expanded depending
upon the information gathered in the initial effort. Factors inventoried
include: type of agency, facilities, capacity, operating characteristics,
and institutional, fiscal, and legal arrangements. An additional survey
of local ordinances and codes is also being conducted.
An unusual aspect of the St. Louis operating agency structure is the ex-
istance of private treatment companies. The Private companies are signi-
ficant in both number and area served, and it has become difficult to
coordinate the public and private roles in regional waste water management
systems. There seemed to be a consensus that the role of the private companies
would be diminishing, given the new emphasis on planning and coordinating
wastewater treatment on a regional basis, and the increasingly active role
of all levels of government in the wastewater treatment process.
EWG-5
-------
The following alternatives are being considered in the management analysis:
a bi-state system, various degrees of regionalization, the expansion of the
role of St. Louis MSD, and individual county systems.
D. Public Involvement Program
EWGCC places great emphasis on an active public in the WQM planning pro-
cess. The staff has designed a program to both educate and obtain input
from the public. The public information and education program includes
presentations (on request), newsletters, exhibits, technical reports,
radio and television programs, and newspaper releases and articles. One
publication, a citizens glossary of water quality terms, is published
jointly by EWGCC and SIMAPC (East St. Louis WQM). Public input is ob-
tained through committee meetings and workships. The citizens committee
meetings have been well attended and the source of active input from a
concerned group. In addition to the Citizens Committee, there is a
Policy Committee, whose membership is 25 percent citizens. Seventy-five
percent of this committee consists of local elected officials. Each county
in the study area and the City of St. Louis is represented. Points for
Committee approval are clearly indicated in the planning process. The
EWGCC Board approval is scheduled for the end of the process because a
portion of the Board is not involved in the study area.
The work plan schedules one workshop for public input on each phase of
the planning process. The phase one workshop was held May 15, 1976.
The purpose of the workshop was to gain input on water goals,
uses and problems. The costs of alternatives were presented and public
preferences were then tabulated. The workshop received a 10 percent
acceptance rate on a mailing list of 3,500, however attendance was
somewhat lower. The staff performed a careful analysis of the workshop
for input into the planning process and. refinement of the design of the
next workshop. The second workshop is scheduled for mid-November and
the third for mid-June. EWGCC also intends to employ a "town meeting"
approach using television, in which people are encouraged to call
in to ask questions and express ideas about water quality.
E. State and Federal Involvement
The State of Missouri presently has a locally based Liaison in a state
regional office for the St. Louis WQM effort. The State office is pre-
sently understaffed, placing time constraints on the present Liaison.
The state is looking for an additional full-time employee to fill the
WQM Liaison position. The present Liaison spends approximately 15
EWG-6
-------
percent of their time per week with WQM planning efforts.
Both the State and EWGCC agree that State input has been moderate to
date. The State Liaison attends meetings frequently and keeps informed
on progress of the planning effort. Other functions performed are re-
viewing contracts and reports, and providing technical advice. The
State Liaison expects the State to take a more active role as the process
continues.
Relations between EWGCC and the State of Missouri are friendly and sup-
portive, and each is satisfied with the others activities to date. The
WQM Director said, however, that more information about'State water
quality activities would be helpful to the local efforts. He also said
that the State had been a good source of technical information, when avail-
able.
The Federal relationship, on the other hand, has been characterized by
tension. The Executive Director and staff felt that there is a lack in
overall program direction and little understanding of what EPA's final
expectations will be. Additionally, there have been differing opinions
on staffing and contracts. The staffing issue was that EPA wanted a
more technically experienced staff. The contracts issue was caused by
different approaches to the scope of service and consultant selection.
The staff felt that EPA had caused significant and unnecessary delays in
the process. These delays have created a discouraging work environment.
The hiring of an experienced water pollution engineer, whose duties' are
to act as liaison with Regional EPA, has apparently contributed to smoother
relations.
F. Scheduled Outputs
The EWGCC has a four-phased WQM planning schedule which begain in January,
1976. Phase I has been completed and consisted of defining the scope of
work, preparing and letting contracts, holding workshop and preparing the
Phase II work plan.
Phase II extends from June of 1976 to January of 1977. EWGCC is presently
in this phase. Ten weeks have been allotted for preliminary data collection1
and analysis and twelve weeks for developing a water quality model.
Twelve weeks are then - allotted for the development of our products scheduled
for completion by mid-November, 19 76. These are:
o Municipal and Industrial Alternatives,
o Nonpoint Source Alternative Analysis,
1
Water quality, waste systems, land use, environmental, demographic,
economic and institutional data are collected.
EWG-7
-------
o Residual Waste Disposal Alternative Analysis, and
o Institutional Alternative..
A recommendations report which compiles the above alternative analyses
is the subject of discussion in the Phase II workshop, scheduled in
November. The workshop will produce a final alternative selection report.
The results of Phase II are then fed into a detailed Phase III work plan.
Phase III begins in January, 1976. Four weeks are allotted for final
data collection which refines and augments the preliminary effort. Twelve
weeks are then set aside for the analysis and development of final alter-
natives. This effort produces three final technical reports:
o Municipal and Industrial Report,
o Non-Point Source Report, and
o Residual Waste Residual Report.
These three reports are then compiled into a final report which is to be
discussed in the phase III workshop. Plan selection is based upon
workshop results and Policy Committee approval. Additionally, an en-
/ vironmental assessment will be prepared in the month of August. Phase
IV, commensing in September, 1977, consists of four months for local,
state and Federal plan and approval and the development of detailed
monitoring and implementation procedures.
, ' The staff of EWGCC stated that the planning effort was approximately four
months behind schedule at the time of the site visit primarily because of
delays in EPA approval. The staff was confident '"hat much of the work
could be made up during the planning period, however, an extension or
deletion may prove necessary.
G. Achievements to Date
The WQM Director stated that the workshop approach is an innovative method
for involving'the public in the planning process. There was a high level of
confidence that this approach was effective in terms of gaining public in-
put and increasing the awareness and support for water quality issues. A
thorough analysis of the workshop was performed which highlighted successes
and improvements to be made in the format for the two remaining workshops.
The staff also expects that the environmental impact matrix being developed
for the environmental assessment will be a particularly useful product of
WQM planning.
EWG-8
-------
III. EXPECTATIONS
A. Water Quality
The major expectation for water quality clean-up in the region was in
the recreational areas of the Merimac River. No one interviewed expected
or wanted the quality of Mississippi or Missouri Rivers to improve as
a result of WQM.
The EWGCC staff expected a water quality improvement in selected areas,
and was placing a high priority on the technical work in the Merimac.
The one local elected official interviewed was looking for a clean-up
in the local streams in his small town area. The local appointed official
felt that the Mississippi and the Missouri were clean enough and that
the application of secondary treatment would not result in measurable
improvement. This official concurred that the cleaning up of the Merimac
was a top priority of the area. The citizens had a variety of expectations
one was looking for an insured water supply, another for the preservation
of recreational waters, and a third for improved water quality resulting
from stormwater controls. The State expected that improvements in facili-
ties and treatment will result in improved regional water quality.
Most interviews did not expect to achieve the 1983 goals for a variety of
reasons. The State liaison felt that the amount of available time-was
too short and that there was not enough money to solve existing problems.
The Executive Director thought that the goals were unachievable in cer-
tain areas and that water quality decisions should be made on a balance
of environmental and economic factors. The WQM Director thought the
goals were undesirable for each stream, particularly the Mississippi and
Missouri Rivers. These Rivers would only be swimmable and fishable at a
prohibitive cost. One citizen did not comment, and the other two thought
that the goals were achievable if the standards were not raised.
B. Plan Approval and Implementation
All interviewees seemed moderately optimistic about plan approval and im-
plementation. Most thought that State approval would be easier to obtain
than local approval. The local appointed official felt that if the WQM
plan contained land use controls, it would have extreme difficulty passing
in some counties. Comments on plan implementation included:
o EWGCC would not develop a plan that could not be
implemented (208 Director),
o If EPA is forceful, the plans will be implemented
(Executive Director), and
EWG- 9
-------
o Implementation depends on more money (citizen).
The local elected official, a citizen, and the State Liaison felt it
was too early to comment.
The staff is presently conducting an inventory of 25 exisiting manage-
ment agencies. It was considered to early to discuss the management
alternatives; however, the role of MSD will be a crucial aspect of
management planning. The staff expected some difficulties in working
out acceptable arrangements with the private sewer companies. A few new
State laws and local ordinances were anticipated for stormwater and
erosion controls. The Merimac was considered a target area for controls
because of the high level of interest in improving the water quality. No
work has been undertaken to secure this legislation. It was considered
too early to comment on the magnitude of funding needed to implement the
WQM plan.
C. Continuing Planning Process
The WQM Director expected the continuing planning process to outline
the impacts of future water quality decisions and to collect more data
on which to support these decisions. He saw EWGCC as the likely body
to do this planning. No estimates were given as to the cost of continuing
planning; however, EPA was seen as the likely source of these funds.
D. Relation to Other Water Quality Programs
The staff at EWGCC, the State Liaison and the local an appointed official
expected WQM to guide and set priorities for 201 planning in the future.
For others, it was considered too early to judge what the effects of the in-
creasing importance of WQM will be on 201.
In speaking of the relation of NPDES to WQM, the State Liaison expected
a reduction in the number of permits because of the regionalization and
enlargement of facilities. He considered it too early to discuss how
NPDES would be coordinated with WQM. The WQM Director expected WQM to
have a significant impact on permitting and thought the State would be
revising permits based on input from WQM planning.
E. Local Definition of Success
A variety of definitions of success emerged ranging from making water
quality a more visible issue to effective growth contx'ol. Both the
State Liaison and the EWGCC staff included aspects of the plan in their
definitions of success. The Executive Director looked for an approved
plan that provided a basis for upgrading existing facilities. The WQM
Director added that success would entail looking at these improvements
EWG-10
-------
on a regional scale. He also expects more effectively functioning in-
stitutions and considers the fact that people will be thinking and
talking about water quality to be a success.
The local appointed official hoped that WQM would develop controls for
growth where growth is not practical. A local elected official also
considered water clean-up for recreational purposes a success for WQM.
The preservation of p'Btable and contact waters, and getting people to
work together to solve water quality problems constituted a success
for two citizens. Another citizen hoped for a mechanism for achieving
control of point and nonpoint sources of water pollution that is both
cost effective and environmentally sound. Benefits expected from WQM
planning include improving recreational opportunities on the Merirr.ac
bringing water quality decision-making to the local level, and better
local services for water quality control.
EWG-11
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM staff was confident of their ability to innovativelv and success-
fully achieve WQM goals for the St. Louis region. The staff viewed them-
selves as dedicated, politically astitute, and ready shape and improve
existing institutional arrangements. There is a strong sense of the need
for including a wide range of public participation in the decision-making
process, and this is reflected in their study, design and the variety
techniques for public involvement. The optimism for a successful effort
seems partially due to the feeling that the political situation is ripe
for the kinds of changes and improvements that WQM will be proposing.
This is particularly true in regard to the issue of regionalization of
wastewater facilities. The area is characterized by institutions which
are not regional; however, most feel that a new sentiment for cooperative
arrangements makes this an opportune time for WQM planning.
B. Citizens
Three citizens were interviewed. All were numbers of the Citizen's
Advisory Committee and two were also on the Policy Committee. Two
interviewees were members of the League of Women Voters in separate
counties; one individual was an active environmentalist, while the other's
interest centered on preserving the county water supply. The remaining
citizen was an attorney who was interested in improving the environment
and increasing public awareness of water quality issues.
All citizens were pleased with their input and the receptivity of EWGCC
to date; but all stressed the importance of keeping the citizens involved
in every step of the process. One interviewee discussed the importance of
going beyond Committee input and developing imaginative ways to include
the general public. He views the committee members as representatives
of the citizenry because members eventually become so involved in the
process that they loose sight of their roles as citizens. He felt a need
for strong citizen education programs, preferably television and radio, ^
that would begin to communicate water issues to the general public.
Another citizen was a resident of a rural county and wanted to insure that
the county was included in the decision-making process of the region.
Rational control of growth was a primary concern. She felt that the
county had been fighting zoning, planning and regionalism for too long,
and that the absence of controls was resulting in a depletion of natural
resources and undesirable development. In her county, there is a group
actively oppossing to WQM called the Citizens for Better Government.
This group was vocal at WQM meetings, and had gained some momentum. She
was optimistic, however, that WQM could make progress despite some of
the opposition in the county.
EWG-12
-------
A citizen from the city of St. Louis was concerned about local opposition
to land use controls and thought that was a major obstacle to be overcome
before plan implementation. She felt alternatives had to prove that it
was cost effective to engage in WQM. She said that local elected officials
were suspicious of WQM, but were involved to see what they could get out
of it. If alternatives are convincingly presented with benefits and
costs relative to WQM objectives, she hoped that the strong feelings for
local autonomy would subside.
C. Local Elected Officials
The local elected official interviewed was the mayor of a small rural
town - seven blocks in area. He had only recently learned of WQM plan-
ning, and had attended two meetings. His primary interests were cleaning
up the streams of the area for swimming and obtaining sewers and services
for his town. Presently, the city has open trenches which are served
by a private sewer company.
The mayor was very pleased with the assistance from EWGCC, and hoped that
WQM would lay out water quality alternatives for the city. He was currently
not very familiar with WQM, but expected to become more involved in the
near future.
D. Appointed Officials
The General Council for the St. Louis Metropolitan Sewer District (MSD)
was interviewed for opinions on WQM. He had participated in consultant
selection and had acted as a liaison with the Regional Office when pro-
blems arose. He sees regionalization and the expanding role of MSD as
logical outgrowths of WQM planning, and feels the political sentiment is
heading in the same direction. His role has been providing local elected
officials with the implications of water quality decisions in their juris-
dictions. He feels the logic and benefits of the regionalization of
wastewater facilities should win over the previous preference for local
wastewater facilities. He hopes WQM will clearly delineate the water
quality implications of growth and provide an impetus for accepting
land use controls.
E. State Legislators
I
The State Legislator interviewed was not familiar with WQM, and stated
that environmental issues are not a priority in the legislature. This
was evidenced by the fact that the legislature's Environmental Committee
was eliminated in 1973. He did think that WQM would have a difficult
time getting land use control to pass in various counties because of
strong opposition to such controls.
EWG-13
-------
F.
State Water Quality Personnel
The State of Missouri's St. Louis Regional Office provides the WQM
Liaison for EWGCC. The Liaison and the Director of the Environmental
Division of DNR were interviewed for opinions on WQM. The State's
Regional Office is presently looking for a full time person for the
Liaison position. The present Liaison is overburdened and spends 15%
of his time on WQM. His functions include reviewing contracts and reports,
attending meetings, and monitoring the planning effort. He saw WQM
as a stepping stone for an ongoing institutionalized water quality
planning process. The State input has only been moderate to date; how-
ever, the Liaison expected a considerable increase in the State role
as the process continues and when the additional position is filled.
EWGr14
-------
V.
ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
There is little doubt among the staff that the plan will be completed.
Although the planning effort is presently four months behind schedule
due to delays in contract approval, the staff is confident that the
work can be made up. However , the WQM Director indicated that an exten-
sion of time or compression of work elements may be necessary. The work
plan also has built-in flexibility by allowing for refinement of the
approach at the end of each phase. At this time, however, no major
revisions are expected.
Although there is a high degree of optimism about plan approval, no
one portends that it will be an easy task at the local level. The general
feeling is that the political situation is opening up to regional con-
cepts, although a plethora of locally based institutions are still in
place. Difficulty can be expected in obtaining plan approval if land use
controls are included in the plan. Most interviewees felt that the locals
are not yet amenable to such controls. The staff intends to try pilot
solutions to make sure they are effective before advocating region-wide
land use controls. A careful reading of the local political barometers
at the frequent points designated for input should provide sufficient
indicators of what will be locally acceptable. The amount of optimism
concerning plan approval inay be justified with the program's heavy emphasis
on public involvement. Mo problems are expected in obtaining State and
Federal approval at this time.
Less difficulty was expected with plan implementation than plan approval.
Most thought that EPA roles will become a crucial aspect of plan implementation.
Both financing and sanctions (requiring 201 to conform) were considered ne-
cessary aids for successful plan implementation.
B. Public Involvement
The EWGCC has placed a strong emphasis on public involvement in WQM
planning. This is reflected in both the number of staff (3) allocated
for public involvement and the design of the work plan. The public
involvement program has various components aimed at attracting
the interest and input of a variety of groups.
The committee structure includes citizens on two committees. The Citizens
Advisory Committee (CAC) is composed of representatives of a range of com-
munity interests. The Policy Advisory Committee (PAC), is composed pri-
marily of local elected officials, and is delegated a major review and
EWG-15
-------
approval function at key points in the planning process. Twenty-five per-
cent of the PAC is composed of representatives of the CAC. In addition
to what was reported to be active committee participation, there are three
workshops designed to gather input from a large cross section of the general
public. One workshop is scheduled at the end of each of the three phases for
product review. The Phase I workshop was held May 15th, 1976. Although
the attendance rate was not as high as the acceptance rate, the staff was,
for the most part, pleased with the process and the results. A careful
analysis of the workshop produced suggestions for refining the procedure
in Phase II. The citizens who were interviewed displayed a working aware-
ness of WQM which speaks well for public involvement efforts to date.
C. Current Planning Process
The EWGCC staff has clearly prioritized elements of WQM resulting in a
realistic planning strategy for the two year period. Additionally, the
work plan has ? flexible design which includes ample allotment of time for
defining, refining and evaluating alternatives. The Merimac River, a
priority area, has been chosen for collecting technical data and defining
pollution control strategies. All interviewees expressed a strong pre-
ference for upgrading the Merimac1s water quality for recreational
uses.
The staff's high level of confidence in their ability to tackle both
political and technical problems, and the cooperative spirit evidenced
in interviews, speak well for the planning effort. The staff's interest
is further evidenced in weekly sessions held to discuss "what is WQM
going to look like". The willingness to work toward institutional
change and trying innovative solutions for existing water quality pro-
blems is a significant factor in the development of a plan that both
meets its objectives and is responsive to concerns in the region.
The staff reported that considerable difficulty and delays had been
experienced with the regional EPA since the beginning of the program.
These difficulties were in the areas of contract approval and staff selection.
The situation has improved somewhat with the hiring of a water pollution
engineer who has been able to improve communications with the Regional
Office. These early experiences have made this relationship particularly-
sensitive, however, and this factor could affect productivity as the
planning process continues.
D. Continuing Planning Process
Little thought had been given to continuing planning at this stage in the
planning process. Most persons felt the necessity to institute ongoing
efforts, but had little notion of what these efforts would entail. The
WQM Director did mention two functions: 1) to outline the impacts of
future water quality decisions and 2) to collect data on which to base
these decision. Additionally, EPA was seen as the likely source of
funds for ongoing planning.
EWG-16
-------
E.
Significance, of Local Elected Officials* Involvement
The site visit for the St. Louis WQM effort coincided with election week,
resulting in unavailability of local elected officials for comment on
WQM. One local elected official was contacted and was anxious to be
involved in the WQM process. Unfortunately he had only recently become
involved in WQM activities. Consequently, the involvement of local elected
officials could not be assessed. Its importance, however, was recognized
in interviews with the staff, and in the program design.
EWG-17
-------
AGENCY: HOUSTON-GALVESTON AREA COUNCIL (H-GAC)
REGION: VI - (Dallas)
GRANT AMOUNT: $1,798,300
GRANT RECEIPT: June 6, 1975
STARTING DATE: April, 1976
STATUS AT TIME OF INTERVIEWS: Negotiating fine points of contracts;
completed population projections.
REASON FOR INCLUSION IN SAMPLE: The Greater Houston Area is an intense and rapidly
growing complex of urban and industrial activity.
Operating within a pro-growth area traditionally
opposed to planning and land use controls, the
H-GAC's approach to WQM planning is particularly
interesting.
IIG-I
-------
I. BACKGROUND1
A. Area
The Houston-Galveston Area Council (H-GAC) was designated on April 22, 1975
as the WQM planning agency for the Greater Houston Area. The designated
WQM area consists of Harris County and parts of five contiguous counties.
The area is about one-fifth of the 13-county region serviced by the H-GAC, but has
approximately 90 percent of the area's population. The City of Houston com-
prises between 60 and 70 percent of the WQM area, with the extra-territorial
boundaries of the city nearly coterminous with the WQM planning area. The
Greater Houston area is rapidly growing and the current population is estimated
at 1.9 million people. The area is known as the nation's energy capital, with
the world's largest petro-chemical complex, and the third largest port. Al-
though a sprawling urban-industrial center, the area also supports agricul-
tural activities such as rice farming.
All interviewees generally agreed that the prevalent attitude in the Greater
Houston Area is pro-growth and cited the fact that the area traditionally
has had no comprehensive land use controls. Two citizens noted the area's
lack of any publicly stated intent regarding growth policy.
B. Water Quality Problem
Water quality issues are framed in terms of the area's intense urban-industrial
complexion. Three hundred industries discharge directly into the receiving
waters of the WQM planning area and 7,000 industries discharge to municipal
systems. The H-GAC Environmental Manager indicated that there is a prolif-
eration of small domestic wastewater treatment plants, with 300 to 350 ac-
tive water districts authorized to build sewer systems. He also noted that
the area's unsequential growth has precluded the feasibility of regional
facilities. However, the Gulf Coast Waste Disposal Authority (GCWDA), created
by state legislation, has taken over a number of small treatment plants in Har-
ris, Chambers and Galveston counties. The GCWDA also has the authority to
service contiguous counties.
Intense industrial activity is located along the Houston Ship Channel, whz-ch
also receives Houston's domestic discharges and drainage from an area contain-
about 50 percent of the Greater Houston Area population. Most interviewees
believed that the WQM project's focus on the Ship Channel was due to its im-
pact on Galveston Bay. The Ship Channel feeds into the Bay, which supports
shrimp hatcheries, sport fishing and other recreational activities. Jj.aljjgSiQEL
Bay,. however,__is_no_t__in.cl.uded in the designated WQM area due to its
Information in this Chapter was taken from the Project Design Report,
April, 1976; and interviews.
HG-2
-------
extensive study under other funding sources. Two WQM advisory committee
members (a Houston City Councilman and an industrial engineer) stated
that examining the Ship Channel was pointless, as its transportation use
and location among heavy indistry rendered "fishable, swimmable" goals
undesirable. The H-GAC Executive Director generally agreed with this
statement and strongly recommended the Channel's reclassification.
In addition to the Houston Ship Channel, the WQM project will investigate
the problems of Lake Houston and the potential impact of future develop-
ment in the rapidly urbanizing Lake area. The Lake is a major potable water
supply for Houston as well as a major recreational center, attractive to new
suburban development. The WOM staff noted that a study of excessive Lake
algae, growth and eutrophication was not completed due to insufficient funds.
The area's nonpoint source problems involve drainage into the Ship Channel,
Lake Houston, Clear Creek, Spring Creek, Cypress Creek, the lower San Jacinto
River, eight bayous and several receiving waters. Pollutant sources include
urban runoff, septic tanks, bottom deposits, injection wells, shipping and
dredging, brine disposal, salt water intrusion, construction and solid waste
disposal. In addition, the study will analyze agricultural contributions
from irrigation return flows, plant nutrients, sediment and confined feeding.
Interviewees cited three problems related to the water quality issue: sludge,
subsidence and water supply. Two engineers believed sludge,- or residual wastes
from wastewater treatment plants, had direct and sizeable cost implications
for alternative disposal methods. As area soils are not suitable for land
disposal, a GCWDA engineer noted that sludge disposal comprised 60 percent
of GCWDA operating' costs. Subsidence, or the lowering of land surface eleva-
tion by groundwater withdrawal, is a phenomenon occurring in the area. Sub-
sidence potentially causes damage and flooding of sewerage systems and salt
water intrusion. Water supply in the Houston area is limited, and, as the
Texas Water Quality Board (TWQB) Planning Chief noted, affects the area's
growth potential. An engineer who served as the WOM Technical Advisory Com-
mittee (TAC) Chairman, felt that the water supply/water quality relationship
was generally not recognized or sufficiently emphasized by the WQM program.
The WQM staff as well as several other interivewees hesitated to prioritize
the area's water quality problems. The WQM Physical Planning Director ex-
pected prioritizing problem areas ot be a later stage of the WQM process.
The citizens felt that problems were interlinked insofar as "everything ends
up in Galveston Bay." However, they stressed the nonpoint source problem be-
cause it is the least recognized and controlled, and they felt that the WQM
project should address nonpoint concerns as the local agencies would not,
due to the growth constraints which nonpoint source controls imply. A GCWDA
official felt that nonpoint sources were larger offenders than point sources.
Other interviewees commented on the overall importance of the water quality
problem. A Houston City Coucilman and industrial engineer'felt that the
nonpoint. source problem was "not as great as some believe," and that most
HG-3
-------
people were not aware of the extensive industrial cleanup already achieved
along the Houston Ship Channel. They voiced opposition to more studies and
plans, and were generally not in favor of the WQM program. Their comments
were that the program is "a waste of resources as there is mandated treat-
ment regardless of further requirements" and ''another Federal boondoggle."
Although most respondents considered area awareness of the water quality
problem to be low, a local elected official active in environmental planning
felt that water quality was in the upper 25 percent of environmental concerns,
especially along the Gulf Coast, and that people are well aware of untreated
sewage in water courses. He also felt that area water quality concerns focused
on contact recreation uses and water supply, including irrigation.
C. Designated Agency
The Houston-Galveston Area Council (H-GAC) is a regional council of govern-
ments serving the thirteen counties of the Gulf Coast Planning Region. Or-
ganized in 1966, the H-GAC has over 100 member governments including 13
counties, 62 cities, 18 school districts, 11 soil and water conservation
districts, the San Jacinto River Authority and the Gulf Coast Waste Disposal
Authority.
Other H-GAC regional planning functions include transportation, solid waste
and HUD 701 comprehensive planning as well as areawide public services. The
cross-correlation of H-GAC planning activities is assisted by computerized
demographic data and other research department functions serving all H-GAC
divisions. H-GAC's experience in water resource planning includes: an eight-"
county regional sewer study (1970), a 13-county waste treatment management
study, a water supply study for Houston-Galveston, and rural water and sewer
plans.
Other plans or activities in the area relate to the WQM project. These plans
include the San Jacinto Basin Plan, the Galveston Bay Project, and Houston
master plans. Water quality-related agencies serving the area include the
Harris-Galveston Coastal Subsidence District which has been operating since
1975. The San Jacinto River Authority, the Gulf Coast Waste Disposal Authority
(GCWDA), and the City of Houston also perform water quality functions.
The Director of the Physical Planning Department of the H-GAC is the official
WQM Project Manager. Within the Physical Planning Department, the Manager of
the Environmental Division is responsible for overall WQM administration and
coordination off all environmental programs in conjunction with A-95 review.
The Environmental Coordinator coordinates technical and management planning
efforts by subcontractors and within H-GAC. In addition to the ten staff
members of the Environmental Division with WQM responsibilities, H-GAC Com-
munity Planning Division staff are involved in coordination, land use pro-
jections and overall WQM mapping requirements.
HG-4
-------
Taking a team approach to the WQM project, each of the non-management staff
is designated as a contact person for a work area, with back-up assignments
to ensure continuity, and is responsible for managing the relevant subcontracted
elements. Presently, H-GAC has awarded seven separate subcontracts to con-
sulting firms. In addition, the City of Houston is providing a water data
base inventory and the Gulf Coast Waste Disposal Authority (GCWDA) has pri-
mary subcontract responsibility for the sludge inventory and the solid waste
impact study. The GCWDA is coordinating the subsidence study with the
Harris-Galveston Coastal Subsidence District. The Texas Water Quality
Board is proficing simulation modelling at no cost to the project. The TWQB
is also providing technical and informational assistance under a $72,000
state participation contract as required by the TWQB.
HG-5
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
According to the WQM staff, the H-GAC WQM planning project is designed as
an ongoing planning process, and focuses on the development of basic method-
ologies which allow continual reassessment of the overall program; and which
is adaptable and available to any eventual management agency. Developing
the process (rather than producing a static plan) is a central aspect of the
H-GAC effort.
The WQM Project Director summarized his expectations for a successful project
as bringing together the Act's intent with a locally acceptable mechanism.
He added that, to enable informed decision-making regarding the extent of
and strategy for water quality improvement, a strong and credible technical
base was essential. In his view, the program must thoroughly identify and
communicate to the public the cost/benefit tradeoffs involved in selecting
WQM strategies. Further, in their "best management practive" approach to
nonpoint sources, the WQM staff felt that a strong data base was necessary
to justify monetary expenditures.
Due to time and funding constraints, the WQM Project Director and two staff
members agreed that WQM planning would fall short of a comprehensive effort.
They believed coordination with a solid waste disposal and air quality plan-
ning was necessary, as well as impact and economic assessments and sludge
analysis. Further, they noted that the area does not have a regional or
comprehensive p]an with which to coordinate the WQM project.
Exhibit I shows the general program structure. In organizing the work program,-
H-GAC divided tasks into 14 separate work packages which are defined as a set
of related tasks to be accomplished by a single agency or consultant. The
WQM project staff noted that they adopted a team approach to monitoring and
coordinating tasks and made decisions together regarding the direction of
the program. Each staff member is assigned lead responsibility for work
elements with backup assignments assuring continuity.
B. Technical Component
H-GAC is developing a technical base which the WQM staff believes can be
applied to any adopted level of management. Technical outputs will feed
into the criteria for selecting management strategies and agencies.
Technical planning responsibilities are divided among a number of agencies
and consultants, as shown in Exhibit I. Water data and inventories relating
to point source analysis will feed into a complete point source data base
HG-6
-------
Exhibit I
208 Program Structure - H-GAC
GULF CO^ST WASTE DISPOSAL AUTHORITY-SUBSIDENCE, SOLID WASTE, SLUDGE
CITY OF HOUSTON-WATER DATA, INVENTORIES, WASTE LOADS, SAMPLING
HGAC-PROJECT ADMINISTRATION PUBLIC PARTICIPATION PLAN APPROVAL SCREEN SUBPLANS
CONSULTANT
POINT SOURCE ANALYSIS
HGAC-SOCIO-ECONOMIC DATA
CONSULTANT
TECHNICAL SUBPLANS
CONSULTANT
NONPOINT SOURCE ANALYSIS
TWQB-MODELING
CONSULTANT
IMPACT ASSMNT.
CONSULTANT
MANAGEMENT ANALYSIS
CONSULTANT
LAKE HOUSTON STUDY
CONSULTANT
IMPLMNT RQMTS
TEXAS WATER QUALITY BOARD-STATE PARTICIPATION & COORDINATION
i—i 1—i 1 1—r
i i i i e 8 r
I 2 55&©73©K>llt20l4
A?R->
1973 !976
-j S ; p-
S 15 17 f3
J 1 1 » I I 1 1 1 VI i<|
£0 21 22 23 24 23 23 27 28 £3 50 31 32 33 34
FE3.I DEC.1
1277 -077
Source: Houston-Galveston Area Council, Project Design Report for the Areawide Waste Treatment Management
Plan for the Greater Houston Area, April 15. 1976, p. 3.
-------
and a detailed handbook of point source control strategies, cost and impacts
will be developed. Nonpoint source analysis will provide a preliminary as-
sessment of the pollutant loads contributed by urban stormwater runoff,
septic tanks,'agricultural and silvicultural activities, construction ac-
tivities, injection wells, shipping, oil field waste disposal, salt water
intrusion, dredging and bottom deposits. On the basis of existing informa-
tion, a sampling program will be designed including sampling points identi-
fied as receiving contributions from one quanrifiable source. A nonpoint
source handbook describing structural and non-structural strategies, costs
and impacts will also be developed.
As indicated in the Work Porgram, the consultant responsible for developing
alternative technical subplans will analyze point and nonpoint source infor-
mation by water quality segment in order to determine preliminary standards.
The WQM staff noted that the technical sub-plans will generate alternative
point and nonpoint source control strategies resulting in varying levels of
water quality. With attendant cost/benefit tradeoffs and impacts identified,
the optimum sub-plan selection will be a combined effort of the area's key
local agencies, WQM adivsory committees and public hearings.
C. Management Planning
At the time of the interview, the subcontract for the management analysis
work package was still being negotiated. The consultant will inventory the
existing legal authority and financial capability of existing WOM agencies
and local authorities. Ultimately, the consultant will develop a set of
alternative WQM systems and present their advantages and disadvantages in
terms of political, social, economic and environmental impacts. The WQM
Project Director noted that the public participation program would provide
a vehicle for "receptivity testing" of the management alternatives-
A second consultant will develop implementation requirements of the WQM
program and will integrate technical and management recommendations into
a cost-effective plan. This consultant will begin work before finalization
of technical and management systems and become familiar with the various
methodologies. For both technical and management components, the consultant
will detail the procedures for implementation in a step-by-step process in-
cluding a construction, operating and monitoring schedule and costs, as well
as chronological breakdown and allocation of responsibility for legislation,
local ordinances, agency reorganizations and intergovernmental agreements.
The work package includes provision for the continuing planning process.
D. Public Involvement Program
The WQM advisory committee structure is a major aspect of H-GAC's public
involvement program. In keeping with Executive Order 18, members of the
Planning Advisory Committee (PAC) were appointed by the Governor and the
HG-8
-------
Committee is comprised of various interest groups. However, the WQM Pro-
ject Director noted that the PAC was weighted toward business interests,
and had few environmental representatives and only four local elected of-
ficials. Generally, elected officials are more indirectly involved by
their participation on the H-GAC Executive Committee, the areawide policy-
making body. Although the H-GAC Executive Committee is the final decision-
making body in regard to WQM planning, the staff noted that only 10 of the
27 Executive Committee members represent the designated WOM area.
Assisting the PAC in its overall review responsibilities are the Technical
Advisory Committee (TAC) and the Citizens Advisory Group(CAG). The TAC mem-
bers were appointed by the H-GAC Executive Committee members and generally
are local operating agency officials. As described by two citizens serving
on the CAG, the CAG evolved from the initiative taken by citizens attending
the H-GAC's preliminary WQM information workshops. The CAG received official
Planning Advisory Committee recognition and is regularly allocated time on
the PAC meeting agenda. With H-GAC financial support, the CAG operates as
an open forum under its own structure and procedures. Attendance at monthly
PAC meetings ranges from 20 to 40. Minutes of the meetings, synchronized
with PAC sessions, are distributed to PAC members, The CAG has established
12 subcommittees according to work element areas and presently has been as-
signed by the PAC to develop program goals and objectives. The CAG has
conducted a preliminary mail survey of water quality goals toward this
end.1
The WOM project staff believed that the H-GAC Executive Committee has final
decision-making authority over the WQM process and were concerned with the
role of the advisory committees. The PAC, TAC and CAG do have considerable
review responsibilities. The Outputs Review Process, shown in Exhibit 2,
indicates the items subject to full review and the steps of the review pro-
cess. Other items may be selectively submitted to the TAC for review, such
as the Sludge Inventory or Subsidence Report, Working through the public
participation effort, the WQM Project Director feels that "receptivity test-
ing" regarding management alternatives may be achieved. Two citizens, however
stressed a stronger role for the CAG and were concerned that interest groups
participated in the program to protect their particular interests and in so
doing, "may subvert the intent of the program."
Other aspects of the H-GAC public participation program include a WQM brochure
a monthly newsletter co-authored with the Citizens for Environmental Action,
workshops and public hearings, and an "open office" concept. The work plan
itself was written such that the initial explanatory chapters can be used for
lay distribution.
The survey questionnaires were sent to persons having previously.made
.inquiries about the H-GAC program.
IIG-9
-------
r
i i
"1 !
i , '
T^nTTlTn-^^'TlWiTti ;rl'j.
GR£AvT£R: ; vAoaSroM i j
Ti CLR/S
, , : , i
,2.08 :
I. • OoTfurs.! Rsv\ap j Pfcoc^-ss1 MM
I i i
-1
4~— M0riTri: Ai-
! i
i !
-A-
V £
y 9
•5 5
ir^e
h*
a; ,'
I j I I i i • 2r
i ' 1 : : ' »t
-^•4
"^h"
i i
-L
I! \ff^\
11
i : i
! !
' i . i !
2.
I ! ! i I ;
T7^ ~T"
1! M M
I M ! |
Mil'!
— t^orJTV\ 3
rs r;"T
; i ! i i !
! ¦ : !
U'. | VI- {•
Jflt- %f-3>
^w. WLiS
i
!AI L. :
• |
&J-2 I
uiu.ii !
0 4* / j
!
i i
H— £-A*C
fen£vs/
i i
CjOJSUV-TAJAT;
iS»
:
raO
I V1 vo
! c7.
J
ifr
I 1 : !
i !
I ! !
TAC :
as.v \G.w
TV
i s 1 c
; I otu , ,
Mtj
i ~vv :
: ! 2'f '
: . l v» ^ ;
**»v: .^T
1 I
rt
1 ! !
! 1
i 1 !
i
! I
! UI
: tot
. . c/- **
! I 1 ; £ j*?¦
¦fili '*?*' ¦ ! "; i'i'f
it?,
\ , \ Y-C wSGc.!
. i ^ : i : . I :
I I
i i ; ' ;
! i M I i
i i
i j i J _j j
C-Cts-BOLTt^T
fc£.V\M0rJ5
I !
I i
l I ! ' I 1 I
1 ; i ! : ' ;
I !
M M ! i ]_ 1
: : I . !
I I
i I
.LL
i : i UJU.1-7
! i ¦ rsH
. 1 ; E^.
! I rrV-: Gs=ciDr^t^AS,jc><4p> ~''^oIrl 1 "Rjul/t
» pa put o,ti aN; ; : ¦'L-ftMcs' ; u<oirNT | *SooR.C£ ¦ j^JMrvCvs\S ! tEPoR.i 1 i
: I : , po\rJT ; joRcsl ; feu(>>\!js>a.: 'oeL<7»sM'noKA ^n^okr;
i • 'KuTEej^-nvs: j rrsc_nkij^ ! ^^>!p<~a^s! ic&appsxj
! ¦ I 1 ' ¦ II' - I i 1 ' • 1 ! 1 ¦_] I 1
~rrv >A/\st^crey\^>4T,"rtvvjsM^i viepoe.~r; i i
i 1 l , ¦).¦»•>> ¦• ! ¦ ¦ i i i . ¦ I , , | ' 1
; | ¦» 8^o<\o : A-vfcMCvtesAG.fj-r i cp-r\oA">j i ?-EPoET !
j | '•». FiKau, Tec^m CCsV_ I So&Plaj^S| 5i£Poftr: j ! i
1 j |sv^TG,rA| | ^'crej^fvnves, ,es.poft^ ! j
••' -t«v- - -t-m- :VteL-' j\s ¦'--( m 1: M ! 1! ;l M 11 M 11!
— o i«n ~ \-*~
i t
i Mi r
i i
I : 1
i !
Spuifcfe: H-JG^C WpMi staff
ir
I ;
I I
I I
I'M
I i ; i ! C
i i 1 i i i 1
:•!--! ill!
j L I : i.i.
I-M-I-! i!-
-------
E. State and Federal Involvement
The TWQB and EPA Regional office have a close relationship in working with
the designated WOM agencies. The TWQB was named the lead agency in review-
ing and monitoring the local efforts by a two-party agreement between EPA
and the TWQB.
The WQM staff noted that EPA's involvement is limited by lack of staff.
Only two project officers serve the entire State. Nonetheless, the WQM
staff felt that they had a good working relationship with the EPA Regional
Office and were impressed with the coordinat.ive effort shown within the
Regional Office. The WQM staff did not expect or desire detailed guidance
from EPA, as they felt that program interpretation should be locally oriented.
The State is a major participant in the designated WQM projects. Executive
Order 18 established that the Governor appoint members to the planning advi-
sory committees and designated the TWQB as the state reviewing agency. The
TWQB was also charged with the responsibility for developing criteria and
procedures in the form of State guidelines which are binding on the designated
WQM planning agencies. The TWQB also monitors compliance with the guidelines
including review of detailed workflow charts to determine whether WQM planning
agencies are on schedule and whether they understand their tasks. The WQM
Project Director and two staff members believed that the State has been
"dictatorial" in imposing constraints without recognizing local problems or
the local nature of the program. The TWQB determines what must be contained
in the work plan, reviews contracts and requires continual update of network
diagrams for- monitoring purposes. Two WQM staff members noted that changes
in the chart require six man-days and divert staff from their regular duties.
The WQM staff also cited contract delays resulting from TWQB review procedures
and estimated six weeks as the average TWQB "turnaround" time for contract
review.
In addition to a sampling and modeling contract, a State participation con-
tract for $72,000 was required by the TWQB for review and technical assistance.
The WQM staff felt that review and technical assistance services should be
provided as a matter of course. The WQM staff also noted that the State liai-
son person assigned to H-GAC also serves another large WQM project and con-
sequently has insufficient time to adequately respond to H-GAC's technical
assistance needs. The WQM staff and two citizens noted that coordination
among State agencies was not evident nor were State inter-agency relation-
ships clearly defined.
The portion of this section on State Involvement is expanded in Chapter IV
F, on Varvinq Perspectives of WOM.,
HG-11
-------
The TWQB Planning Chief noted that State involvement was necessary to assure
the compatibility and consistency of WQM planning in designated and nondesig-
nated areas. State WQM planning in nondesignated areas is proceeding concur-
rently with the designated WQM planning projects. Due to time constraints
for both State and local processes, the TWQB Planning Chief noted that the
designated WQM plans will not be incorporated into the present State planning
effort, but will be embodied in the State Plan update. She also believed
that, with ongoing State involvement, theyr merger should not present any
problem.
The TWQB Planning Chief observed that the H--GAC WQM project was one of the
two designated agencies having the most difficulty with the program.-'- She
felt that these two agencies were having difficulty adapting their strategies
to the time allowed and approaching the task as one of "short action response-
revition."
F, Scheduled Outputs
The work plan indicates that 30 reports are scheduled to present areawide
results, conclusions and recommendations. The list of reports and expected
completion dates is shown in Exhibit III. The WQM Project Director felt that
interim reports ''forced the agency to get something out and accepted," and
generally to be accountable to the process to date. He expected the final
product to consist of sub-product summaries including technical base reporting,
the WQM process and issues, "the state-of-the-art," and would culminate in
a series of policy alternatives and their impacts.
G. Achievements to Date
The WQM agency is currently revising its interim population and land use
projections for publication. Revision was necessitated by the figures'
incompatibility with Houston's construction grant program currently in
progress, A draft report on subsidence and its related effects on waste-
water collection and treatment facilities had recently been completed.
Although funded in June, 197 5, the WQM project received its start date in
April, 1976, The WQM staff noted that the work plan required 10 months,
although originally scheduled for only two months and, at the time of the
interview, EPA had not yet approved the work program. Contract negotiations
have required over four months, and several points are still being negotiated.
The other WO.'.l agency was the Lower Rio Grande Valley Development Council
(LRGVDC),
HG-12
-------
EXHIBIT III
PLAN OUTPUTS LIST
H-GAC
Release
Dates
Activity ft
Document/Report
Draft
F inal
4
Steady State Sampling Program Design Report
9/75
10/75
4
Steady State Sampling Data
3/76
Project Design Report
11/75,
4/76
15
Water Uses and Supply Report
7/76
8/76
8
Interim Land Use/Population Projections
5/76
7/76
7
Municipal Projection Methodology'
6/76
7/76
3
Point Source Inventories
5/76
7/76
5
Sludge Inventory and Report
3/76
5/76
10
Steady State Models Available
6/76
6
Existing Water Quality Data and Report
7/76
8/76
9
Waste Load and Water'Use Projections
8/76
13
Solid Waste Inventories and Report
5/7 6
8/76
14
Subsidence Maps and Report
6/76
8/76
15
Point Source Control Strategies
8/76
1/77
15
Point Source Problem Definition Report
11/76
1/77
16
Nonpoint Source Control Strategies
7/76
7/77
17
Segment Analysis Report
12/76
11/77
16
Nonpoint Surce Problem Definition Report
10/76
2/77
17
Technical Subplan Alternatives
3/77
18
Updated Land Use/Population Projections
4/7 7
5/77
27
Water Quality Data Management System
5/77
HG-13
-------
Release Dates
Activity ff Document/Report Draft Final
21 Alternative Management System Report 8/77
19 Lake Houston Study Report 8/77 10/77
21 Management System Recommendation Report 9/77 11/77
17 Technical Subplan Recommendations 6/77 11/77
17 Technical Subplan Implementation Requirements 9/77 11/77
24 Nonpoint Source Sampling Data 5/77 2/78
22 Impact Assessment Report 12/77 2/78
23 Implementation Requirements Report 1/78 3/78
Source: Houston-Galveston Area Council, Project Design Report for the
Areawirie Waste iTreatment Management Plan for the Greater Houston
Area, April 15, 1976, Table III (2)—12.
HG-14
-------
As a consequence, the project is already two months behind. This situation
has required H-GAC to reassess priorities and drop certain important items,
such as the Lake Houston Study and dynamic modeling work tasks. The H-GAC
Executive Director was concerned that the project may not be completed in
two years, but the WQM staff believed that some final plan would be produced
on time, although its quality and credibility may be constrained by in-
sufficient analysis.
For monitoring task schedules, the TWQB required H-GAC to submit and contin-
tually revise detailed workflow charts^ The WQM staff felt that workflow
chart revisions were time-consuming and diverted attention from regular
tasks.
Although the program is only recently underway, the WQM project staff cited
several achievements:
o The public participation program had succeeded in making the
WQM process visible and in establishing two-way communication.
o The level of State cooperation is better than that achieved in
other programs.
o The WQM staff teamwork approach with backup assignments was
a valuable agency achievement.
o The project design as a flexible, ongoing process, rather than
a static plan, provided basic methodologies adaptable to any
eventual management agencies.
HG-15
-------
III. EXPECTATIONS
A. Water Quality
There was general agreement that the WOM efforts would effect some degree
of water quality improvement, although most believed that the effort would
not achieve improvement as quickly nor to the levels expected by EPA. No
one expected that the area would achieve the 1983 goals, although the TWQB
[Planning Chief believed that goals would be achieved where attainable and
'the WQM process would define areas where goals were not attainable. Several
interviewees, including a local elected official and an engineer, believed
that industries along the Ship Channel had already achieved substantial
cleanup and expected further improvement to be marginal.
B. Plan Approval and Implementation
Most interviewees, including the WQm project staff, expected that the plan
would be approved locally if the plan reflected local preferences. The
H-GAC Executive Director noted that, although local governments had accepted
the WQM responsibility collectively, most were retaining a policy of "watch-
ful waiting" and were reserving judgment on the plan until it is completed.
A county official noted that not all local elected officials agreed on the
WQM program and the H-GAC Executive Director believed that the H-GAC Execu-
tive Committee's proportional voting system would pose potential problems
for plan approval.
The WQM project staff believed that an extensive amount of time was required
for the plan review process to adequately involve.the local public agencies
and officials, and to gain their support. The staff also felt credible data
was essential to the plan's acceptability. Both the thoroughness of the
data and the review process were seen to be limited by the program's time
and funding constraints.
State involvement in the H-GAC WQM program and State approval of the completed
plan were cited as potential problems by most interivewees, Most interviewees
expected that a plan reflecting local preferences would meet neither State
nor EPA approval requirements. In addition, an appointed official and two
citizens were concerned that State intervention in the WQM process may cause
a plan to be produced which is not locally acceptable, particularly if the
plan contained elements affecting land use.
The TWQB Planning Chief felt that, if properly executed and documented, the
State would support approval of the WQM plan to the extent possible, However,
the TWQB has the responsibility for determining whether the designated WQM
area plan is compatible with overall statewide interests and cost/benefit
tradeoffs.
HG-16
-------
Interviewees were asked to speculate on the outlook for plan implementation.
Views were generally mixed and interviewees couched their expectations in
terms of the implementation constraints which they foresaw.
o The WQM project staff believed that some aspects of the plan
would be implemented, but did not know the extent or time
period, and felt that this would depend on the recommendations
and funding availability.
o Most interviewees cited the program's time and funding constraints
as hindering the plan's analytic depth and credibility. The
WQM project staff also believed the limited time available for
the plan review process may result in a weaker plan which would
be difficult to implement.
o Several interviewees noted that implementation problems related
to the land use implications of the program, local attitudes of
autonomy, antagonism concerning State and Federal controls and
cost tradeoffs among water quality objectives. One City Council-
man believed that the WQM program was a "backdoor" approach to
controlling land and other resources, which he did not favor.
o Several interviewees commented on the general level of interest
in water quality efforts. Most agreed that there was a low
level of awareness, although the H-GAC Executive Director be-
lieved that there was a general acceptance that "something must
happen," Two citizens believed that economic interest groups
would oppose the plan or work within the planning process to
subvert the WQM program's intent, A local elected official
believed that some counties were not as interested in the WQM
project as others.
Expectations for likely management agencies focused on a strong preference
for local control. Two citizens were concerned that the State may assume
management functions. The WQM staff did not know the ramifications of the
fact that the City of Houston's extra-territorrial jurisdiction nearly coincides
with the WQM area boundaries and the city council has recently passed unlimited
annexation laws. The Gulf Coast Waste Disposal Authority may be part of a
consortium of management agencies, but generally, implementation was expected
to occur through general purpose governments.
The TWQB Planning Chief expected, due to time constraints, that very few
new implementing authorities would be,established by 1978. All State level
interviewees noted the political unreceptivity to regionalism. The TWQB
Planning Chief expressed the need for innovative approaches to management,
rather than State-imposed regional systems.
There was g?neral agreement at State and local levels that no legislative
needs had been specifically identified. The State is currently identifying
existing legal constriants and H-GAC has subcontracted for legal analysis as
HG-17
-------
part of the management analysis work package. However, several State and
local interviewees commented on the existing and required new authority to
implement the WQM plan. As presently there are no zoning, permitting or flood
plain controls beyond municipal jurisdiction. The TWQB Planning Chief sug-
gested the need to expand county authority and strengthen municipal extra-
territorial jurisdiction. County authority is weak with present controls
limited to regulating private sewage facilities, e.g., septic tanks, causing
pollution or injury to the public health. The WQM project staff expected
flood control-related programs to contribute some controls (e.g., flood
insurance). As noted by the WQM Project Manager, 14 of the area's 40 munici-
palities, including Houston, have not instituted zoning. However, the WQM
Project Director did not see zoning as necessary, but rather emphasized
the need for policies addressing the land use-water quality interface and
coordinating growth and capital improvements programming.
All sources mentioned the anti-planning attitudes prevalent in the State.
One State legislator called the Texas policy one of "unfettered growth".
He stated that the basic problem of the WQM program rested with the fact that
there are "no basic rudiments of land use regulatory power to implement 208".
The TWQB Planning Chief, as well as an official in the Governor's Office,
felt that an aim of the WQM process was to develop an innovative management
system, built upon existing authority such that extensive legislation would
not necessarily be a prerequisite to implementation. Land use controls
have not been authorized by State Statute except on a very limited basis, i.e.
to municipalities. Thus, according to the State's Continuing Flanning Process
"land use controls on a general basis are contrary to present state policy"
and "water quality management planning shall take full advantage of existing
authority and administrative capabilities".! Further, the TWQB is granted
broad police powers under the Texas Water Quality Act to "implement all plans
necessary to the Continuing Planning Process required by P.L. 92-500".
No legislative contacts have been initiated by the State or H-GAC. The TWQB
Planning Chief regarded such contact premature. One legislative staff member
felt that the WQM program would produce plumbing rather than innovative
solutions, and, as such, it would not require additional authority for
implementation. A State Senator as well as two legislative staff members
indicated that most legislators were not aware of the WQM program.
State officials interviewed noted that, should legislation be required, the
earliest realistic date for consideration is January, 1979, as the Texas
Legislature meets biennially. It was generally felt that legislation during
the January, 1977 session was not feasible. A Governor's Office staff
member noted that the timing of the WQM program did not allow for a "gap"
between plan completion and any enabling legislation required.
C. Continuing Planning Process
Most local interviewees expected some form of planning process to continue
after the initial planning period. One local elected official did not favor
continuation but expected the process to continue. The H-GAC Executive
Texas Water Quality Board, The State of Texas Continuing Planning Process,
April, 1976, p. 6.
HG-18
-------
Director expected the continuing planning process to be part of regional
planning activities which would include plan updates, monitoring and planning
for enforcement. Other interviewees were less clear as to who should per-
form the continuing planning function. One citizen did not favor a "super-
agency" to have this responsibility and two citizens expected that, if the
State funded continued planning, the State would also control the program.
The TWQB Planning Chief believed that the continuing planning process will
largely be a State responsibility and would consist of: (1) the verification
of signficant nonpoint sources and controls, (2) preliminary screening and
statistical collection of data regarding the biggest problems, and (3) an
emphasis on facility planning in order to provide an adequate basis for the
construction grants program.
The WQM project staff estimated that $225,000 per year would be required for
ongoing planning and preferred local funding sources. However, the WQM
project staff, a State official and other interviewees expected funding
from a mix of Federal, State and local sources. The WQM project staff noted
that no funding commitments had been sought or obtained. The State legisla-
tive branch interviewees believed that the Legislature was not adverse to
appropriating funds for water quality efforts.
D. Relation to Other Water Quality Programs
The local interviewees did not know the future relationship between the
WQM project and the construction grant and NPDES permit programs. The H-GAC
Executive Director expected the WQM plan to provide the basis for the two
Federal programs, but three citizens did not expect the WQM plan to have any
impact. One of these citizens was an engineer who believed treatment was
mandated regardless of the WQM plan and did not expect the WQM plan to alter
State and Federal requirements.
The TWQB Planning Chief viewed the helpfulness of the WQM program to depend
on the depth of the analysis, i.e., systems work. In regard to the WQM
plan's impact on the NPDES program, the TWQB Planning Chief expected the
designated WQM plans to establish sound objectives in areas not meeting
1983 goals and to provide a basis for revised wasteload allocations.
State and local interviewees agreed that WQM planning should have preceded
the construction grants and NPDES permit programs. The WQM project staff
viewed the extensive number of existing of ongoing construction grants pro-
jects to preclude the feasibility of WQM recommendations for regional facilities.
Two citizens felt that the construction grants projects were "dictating" WQM
planning. Moreover, the WQM project staff saw the local ongoing facility
planning efforts as based on population projections which differ somewhat
from regional projections. The staff also noted that the population projections
of the H-GAC WQM project and the City of Houston construction grants project
differed in their growth assumptions. Ultimately, H-GAC supported the
City of Houston's figures and revised its projections accordingly.
HG-19
-------
The WQM project staff believed that their extensive and costly review activities
should be an allowed WQM project expense in view of their A-95 review
responsibilities and the State directive to incorporate all construction
grants projects in the area and review discharge permits in cooperation
with the TWQB. They noted that the EPA Regional Officer did not currently
allow such billing to the WQM project.
E. Local Definition of Success
Most interviewees were asked to state their definition of a success for the
WQM planning effort. The WQM Project Director, an appointed official
and an industrial engineer generally defined success in terms of a plan which
is locally acceptable. The WQM Project Director expanded his definition as
bringing together the Act's intent with a locally acceptable mechanism,
and developing a cridible program which allows public understanding of the
tradeoffs involved. The H-GAO Executive Director believed that success would
constitute public and private sector acceptance of the Act's imperatives and
commensurate action. Other interviewees offered the comments listed below.
o Two citizens defined success as developing a rational
management system including some consolidation of local
agency responsibilities and establishing future necessary
or feasible actions.
o Two local elected officials did not know what may comprise
a success, one city councilman generally viewed the pro-
gram as "another Federal boondoggle".
o One citizen believed a successful project would produce
better information, increased awareness of, and some
impact on, the water quality problem.
o The State Water Quality Planning Chief felt a successful
WQM project would clarify needs for data regarding treatment
systems, develop realistic objectives and identify the origin
and solution to water quality problems.
Interviewees also mentioned direct and indirect benefits they expected from the
WQM planning effort. The WQM Project Director expected a direct benefit of
increased public appreciation of the pollution problem, its causes, and its
technically and economically feasible solutions. Indirectly, he expected a
benefit to result from the' increased extent of involvement, cooperation and
communication among all area authorities and levels of government regarding
the WQM planning program. Two citizens felt that the WQM project's examina-
tion of the nonpoint source problem was a benefit, regardless of implementation
concerns. An engineer, although he believed the program would centralize and
increase water quality information, generally believed the program was "a
waste of resources". A county official believed beneficial outcomes of the
effort would include better health and recreation, protection of property,
higher economic returns, and more orderly development.
HG-20
-------
IV.
VARYING PERSPECTIVES OF WQM
A. WQM Staff
The H-GAC WQM project staff views its role as developing a planning process
which is based on methodologies adaptable to changing conditions and institu-
tional arrangements. They did not believe that the "process" aspect of WQM
planning had been sufficiently recognized by EPA and that EPA was instead
pushing for "products". Central to H-GAC's position was the importance they
placed on developing a credible data base and explicitly identifying cost/
benefit tradeoffs involved in determining local water quality priorities.
Achieving such a level of analytical thoroughness was not seen as possible
within the funding and time allotted. The WQM Project Director stated that
the initial program design had been forced into the two-year period to
gain EPA approval and H-GAC "would then see what they could do".
The WQM Project Director believed that the H-GAC would "have to get something
approved locally" but a locally acceptable plan may not gain State and EPA
approval. He also believed that State and EPA roles in the WQM project may
determine the outlook for combining local-State and EPA approval requirements,
the WQM staff viewed the State as heavily controlling the WQM planning effort
and felt that the State had "lost sight of the local nature of the program".
The staff saw H-GAC's responsibility for the WQM effort as constrained by
State control such that "H-GAC sits between State and local interests" and
consequently must perform a sensitive balancing function. The H-GAC Executive
Director added that the WQM program's relationship to A-95 review was not
clear.
B. Citizens
The citizens interviewed included an Environmental Analyst, a representative
of the Audubon Society, a graduate student and an oil company Engineer. All
were active in the Citizens Advisory Group. The Engineer was also an appointed
member of the Planning Advisory Committee and Technical Advisory Committee.
The Engineer was involved in the WQM project because he was concerned with
the area's overall allocation of resources. He believed the WQM project to
be a waste of resources "as treatment is required regardless of a WQM plan"
and participated to assure further resources were not wasted or diverted
from other priorities.
Two citizens described their roles as part of a citizen initiative to organize
and conduct an open forum supplementing the closed membership of the PAC.
They believed that particular interest groups were participating in the WQM
effort "to protect themselves" and "may subvert the intent of the program"
as well as hinder plan implementation. They also believed that the H-GAC
and PAC have responded to their input, but it was not clear how their input
is used. They wanted more participation in the WQM process, but recognized
that participation was constrained by the funding and time allotted. Another
citizen noted that public participation is problematic in a technical
planning context and was pleased that H-GAC was backing the CAG-promoted
educational efforts.
HG-21
-------
All of the citizens were concerned with the State's role in the WQM project
and believed that State control would hinder local plan implementation.
All believed that the H-GAC would suggest a more effective WQM program than
the State. Overall, two citizens stressed the importance of addressing
the nonpoint source problem because they believed land use implications
and economic interest groups would effectively oppose local level dis-
cussion of nonpoint source problems.
C. Local Elected Officials
A County Judge and Houston City Councilman were interviewed. Both served
on the H-GAC Executive Board. The two officials had opposite perceptions
of and interest in the WQM program.
The Houston City Councilman was opposed to more planning and studies. He
believed the WQM program "was being pushed down their throats", and suspected
the WQM program to be a Federal "backdoor" approach to control land and other
resources. Although he felt that local officials had embraced WQM planning
as a "worthy cause", he believed officials were reserving judgment until
the specific WQM strategies were defined. He felt that his input to the
WQM process conflicted with State and Federal program directives and that
these directives "tied the hands" of the H-GAC.
The County Judge supported the effort, but noted that not all elected
officials agreed on the WQM program direction and that some counties were
pot as interested in the program as others. As his county was becoming
more urbanized, he was interested in planning ahead. Toward this end,
he desired county authroity for controlling wastewater discharges (e.g.,
wastewater treatment requirements in subdivisions over ten acres) and
favored land capability analysis and performance standards for controlling
nonpoint sources. He believed that the plan should be only, advisory to
local governmental actions, which he saw as the proper vehicle for plan
implementation.
D. Appointed Official
The appointed official, interviewed served on the staff of a regional waste
disposal authority and was appointed by the Governor to the Planning
Advisory Committee. He was also asked by the H-GAC staff to serve in the
Technical Advisory Committee. He noted that he serves on the two advisory
committees as a technical expert and not as a representative of his agency.
The official was critica,l of the WQM progaam on several counts. First, he
felt that the program's funding limitations would affect the quality of the
final outcome. Second, he was concerned with the limited attention to
the water supply/water quality relationship, as he saw water supply affecting
quality controls. Third, he strongly felt that the State and EPA were
directing the plan's development despite "saying it's a local plan". Con-
sequently, he believed participation in the WQM planning effort was necessary
to protect local interests. He noted the local antagonism to State and
Federal intervention in local affairs. He did not expect the plan to be
implemented, although he believed the Gold Coast Waste Disposal Authority
could operate in a consortium management arrangement, perhaps with monitoring
responsibilities. He did not believe the area was receptive to a regional
WQM agency.
HG-22
-------
E. State Legislators
One State Senator was interviewed, and supplemental legislative information
was obtained from a staff member of the Office of the Speaker, Texas House
of Representatives, and a legislative committee staff member. All indicated
that most legislators are not aware of the VJQM program.
The State Senator believed that EPA made a false assumption "that States
would come around with land use regulatory authority" to implement
nonpoint source controls. He felt that Texas would not legislate land
use regulatory powers as its current policy is one of "unfettered growth".
He also expected VJQM planning to be handled bureaucratically rather than
legislatively, and that legislative involvement would be limited to agency
budget appropriations. Although he believed legislators were not adverse
to appropriating funds for water supply and water quality activities, he
felt that the TWQB would need to improve its relationship with the Legislature
to obtain the needed support.
I
Neither the State Senator nor the staff member of the Speaker's office ex-
pected legislative support for strengthening the authority of councils of
^governments and generally viewed regional bodies to have "few friends" due
ito preferences for local control and overall anti-planning attitudes in the
Legislature. All noted that, as the Legislature meets once every two
years, no legislative activity could occur until 1979.
F. State Water Quality Personnel
Three State agency officials were interviewed: two planning personnel in the
Texas Water Quality Board and one staff member of the Special Advisor to the
Governor on Natural Resources. As defined in Executive Order 18-A issued
March 23, 1976, three State agencies have responsibilities related to water
quality planning for designated and nondesignated areas. The Texas Water
Quality Board (TWQB) reviews all WQM planning and conducts WQM planning in
nondesignated areas other than that dealing with nonpoint sources related to
agricultural and silvicultural practices. These nonpoint sources are the
responsibility of the Soil and Water Conservation Board (SWCB). The third
State office involved is the Special Advisor to the Governor on Natural
Resources. The Special Advisor is the individual with primary responsibility
for WQM planning in Texas and, as such, the TWQB and SWCB must seek the advice
and concurrence of the Special Advisor in all aspects of WQM planning in
both designated and nondesignated areas. The Special Advisor also chairs the
State Management Committee which was established to direct nonpoint source
management planning in nondesignated areas and to coordinate nonpoint source
management planning with point source planning both in nondesignated areas
and with designated area WQM plans.
KG-2 3
-------
Overall, the State's position with respect to designated WQM planning areas
is to be involved throughout the WQM process. Executive Order 18-A established
that the Governor appoint members to the policy advisory committees, which
include representatives of the Special Advisor and TWQB. The Executive Order
also charged the TWQB with responsibility for developing criteria and pro-
cedures in the form of State guidelines which are binding on the designated
WQM planning agencies. The TWQB monitors compliance with the guidelines,
including review of detailed workflow charts to determine whether WQM planning
agencies are on schedule and if they understand their tasks. The TWQB also
provides technical assistance through a State participation contract with
designated agencies. The H-GAC WQM project has such a contract for $72,000
and, in addition, provides sampling and modeling services.
The TWQB Planning Chief noted that State involvement was necessary to assure
the compatibility and consistency of WQM planning in designated and non-
designated areas. She also indicated that the designated area plans will
be incorporated into the update of the State WQM Plan and, with ongoing State
involvement, their merger should not present any problems.
The TWQB Planning Chief felt that the Act's intent of State versus local
control is unclear, and that the Act seemingly "holds the State responsible
for WQM planning while telling locals it is uheir program". Further,
she noted that locals feel that water quality standards should be a local
option, but that the State retains responsibility for a Statewide perspective
'on the WQM problem. As this Statewide perspective is reflected in review of
designated WQM planning efforts, she felt that State-local conflicts occur.
Although she indicated that the State-local dialogue is currently effective,
it is not always friendly or congenial. She expected the State to
approve designated WQM plans "if they are properly .done and documented".
The TWQB Planning Chief has commented on the State's role in relation to manage-
ment and continuing planning. She did not expect the State to impose regional
management systems, but rather expected innovative management approaches
utilizing or expanding upon existing authority to be developed by the designated
agencies. Nonetheless, the TWQB is granted broad police powers under the
Texas Water Qualty Act to "implement all plans necessary to the continuing
planning process required by PL 92-500". As noted in Chapter III, the State
expects to have primary responsibility for continuing planning.
HG-24
-------
V.
A.
ANALYSIS AND CONCLUSIONS
Likelihood of Plan Completion, Approval and Implementation
The WQM project staff expected that a plan would be completed within the
planning period, but would fall short of the credible and comprehensive
analysis they had wanted initially. The WQM Project Director noted that
/ their initial program design had been forced into the time allotted in
order to gain EPA approval. The staff initially had expected to gain
additional time and funding to allow a more thorough analysis. Currently,
with a time extension and additional funding unlikely, the WQM project
staff is concerned that the plan will be based on weak data, causing its
I credibility and acceptability to suffer. During the plan approval process,
the WQM staff intends to openly discuss the plan's recommendation as
qualified by both process and data limitations.
Speculating on the likelihood of plan approval is difficult considering
the early stages of H-GAC1s WQM effort. The H-GAC Executive Director
felt officials were reserving judgement on the effort until the plan
is completed. The Houston City Councilman believed officials had
embraced the effort as a "worthy cause" but all support depended on
the specific means recommended for WQM action. A county official was
fairly optimistic about the prospects for plan approval, although he
noted that area officials were not uniformly supportive of the efforts.
Procedurally, the plan approval process may encounter difficulties.
Final plan approval authority rests with the H-GAC Executive Committee
which is composed of 27 local elected officials representing counties,
cities, school districts, and water conservation districts. Although
only ten of these officials serve the designated WQM area, the entire
H-GAC Executive Committee must approve the plan. Expectations regarding
how the entire Committee will vote on a sub-area concern were not soli-
cited, but the H-GAC Executive Director did note that the Committee's
proportional voting system may be a problem for plan approval.
A further complexity is the dominance of the City of Houston, which
covers most of the designated area and whose city council recently
passed unlimited annexation laws. Consequently Houston's assessment of
the plan's merits may alter the likelihood of plan approval. In this
light, the view of a Houston city councilman serving on the H-GAC
Executive Committee is noteworthy. He did not generally favor the
WQM program, calling it "another Federal boondoggle" and a Federal
"backdoor" approach to controlling land use and other resources.
Although the discussion of the likelihood of plan approval is highly
speculative at this time, there are indications that meeting local,
EPA and State requirements for plan approval will be a difficult task
for the H-GAC. Most interviewees expected the plan to be locally approved
if the plan reflected local preferences. However, they also believed
HG-25
-------
obtaining both local and State approval may be difficult. A locally
approved plan may not meet State requirements. For example, if the area
determines the Houston Ship Channel should be reclassified, and the
State determines that attendant recommendations had impacts incompatible
with statewide interests (e.g., protecting Galveston Bay), the State may
not approve the plan. Conversely, if the State is involved in an on-
going way, a plan may be produced which is not in keeping with local
priorities and, thus, cause local rejection. Several interviewees believed
State intervention may have produced such a result.
The outlook for local plan approval and implementation is clouded by
similar factors including unreceptivity to imposed controls, general anti-
i planning attitudes, and a low awareness of the water quality problem.
Point or nonpoint source control recommendations which imply growth or
land use controls will likely be ill received in this "pro-growth" area.
However, as land use controls are not authorized by State statute, land
\ use controls are not likely to emerge as plan recommendation. Rather,
WQM strategies are expected to utilize existing authority, but nonethe-
less must mesh with local policy if plan recommendations are to be
acceptable to and implemented by local governments. That is, if the
plan is only advisory to local authorities, imp-lamentation depends on
local disposition toward taking action. Considering that Houston has
no publicly state growth policy, it is particularly vexing to assess
Houston's receptivity to WQM recommendations. However, the assumption
that locals will have full say in WQM activity after 1978 is, perhaps,
premature. The Greater Houston Area WQM effort would be less likely
ignored if sanctions coerced certain local actions. At this point, it
is not clear what role the State or EPA will assume in WQM plan imple-
mentation and, accordingly, how State and local responsibilities will
be balanced.
B. Public Involvement
The public participation effort is central to the H-GAC WQM project.
The H--GAC seemingly has recognized its primary constituency as key
local public agencies and local elected officials from the outset.
Although officials reaching local elected directly is problematic (as
discussed in Section 5E), the WQM project has involved technical experts
of public agencies on advisory committees and provided them with im-
portant review responsibilities which further their involvement,
effective input and, hopefully, support of the effort. Moreover, sub-
contracting with local public agencies for work elements, (e.g., City
of Houston and Gulf Coast Waste Disposal Authority), -provides an ongoing
coordination with an important linkage to local agency activities and
interests.
II
The WQM project staff believed that they had succeeded in establishing a
visible planning process with two-way communication. The Planning
\
HG-26
-------
Advisory Committee (PAC) and Technical Advisory Committee (TAC) ore
involved in ongoing review, as is the Citizens Advisory Group (CAG),
which is a citizen-initiated involvement effort subsequently supported
by the H-GAC and recognized officially by the PAC.
If the H-GAC succeeds in integrating advisory committee input with
project objectives and in utilizing the committees for "receptivity
testing", the H-GAC effort will be a long way towards cementing local
support. However, if interest groups emerge in opposition to the
project's direction, the H-GAC will be faced with the difficult task
of determining how input is-to be balanced with programmatic impera-
tives. Two citizens interviewed were concerned that interest groups
were participating with the aim of subverting the program's intent.
The dilemma for the H-GAC seems to be how to weight the "advisory"
input of various interests in determining the shape and direction of
the WQM project.
C. Current Planning Process
The H-GAC WQM program was designed to address comprehensively both point
and nonpoint source problems and to focus on developing basic methodo-
logies which underscore a planning process rather than produce an end-
product. The WQM project staff is concerned primarily with developing
a credible data base, particularly for nonpoint sources, to explicitly
identify cost/benefit tradeoffs among water quality objectives and to
justify monetary expenditures resulting from recommended actions.
vThe time and funding' limitations precluded the fully comprehen-
sive and thorough analysis the WOM project staff believed essential to
the plan's acceptability. Despite H-GAC's considerable attention to
' analyzing nonpoint sources and their management, the WQM project staff
believed the nonpoint data base to be weak and require supplementary
sampling programs. Additional areas of weakness or in attention
during the allotted time included sludge analysis, impact and economic
assessment, and coordination with air quality and solid waste planning.
All of these areas are part of a proposal H-GAC currently is presenting
to the EPA Regional Office for funding. As proposed, these elements
which augment the present WQM study would be part of the ongoing planning
process.
Seemingly important to the flexibility and adaptability of II-GAC's
planning process is their teamwork approach to project management.
The WQM staff is large enough to allow primary and backup assignments
for monitoring subcontracts and becoming directly involved in the work
elements. This "hands on" management of subcontracted work tasks
enables ongoing assessment of work progress, coordination of work
elements, and necessary adjustments in strategy. Further, the entire
WQM staff is .involved in determining program direction and strategy.
HG-27
-------
Probably the most difficult strategic decision will be determining the
appropriate cut-off points for analysis in order to allow adequate time
for plan review and approval. A State water quality board official had
criticized the H-GAC as unable to adapt its strategy to a first-cut
analysis approach, and believed H-GAC was reluctant to base their initial
steps on a necessarily limited analysis. Considering the nature of the
council of governments as a voluntary association of local authorities,
and the potential political controversy surrounding WQM planning and
implied controls, H-GAC is in the delicate position of serving local,
regional. State and EPA interests simultaneously. It seems that the
open dialogue and "receptivity testing" H-GAC is trying to incorporate
into the WQM planning process is a justifiable incremental approach
to the politically, economically and socially complex problem of WQM.
D. Continuing Planning Process
Continuation of the WQM process beyond the initial planning period
seems to depend on local commitment and funding. It is not clear that
the H-GAC will be able to generate sufficient support to continue the
WQM process, although Federal and State funding would greatly increase
the likelihood of continued planning.
Most interviewees expected the planning process to continue but were
not clear who would perform the tunc lion. The H-GAC WQM staff and
Executive Director believed the H-GAC, with funding support, could
continue WQM planning related to overall regional planning activities.
He harbored hopes that EPA would fund specific tasks augmenting
the WQM plan. These analytic tasks included nonpoint source sampling,
sludge disposal, coordination with solid waste disposal, air quality
planning, and impact and economic assessments.
The State is a likely candidate for conducting continuing planning.
The State officials interviewed clearly delineated State objectives
for a continuing planning process and indicated that the State could
continue the planning process should the regional effort not be
locally supported. Along this theme, two citizens had indicated
that, if State funds support continued planning, they believed the State
would assume continued planning responsibilities.
E. Significance of Local Elected Officials' Involvement
Local elected officials, as members of the H-GAC Executive Committee,
have final plan approval authority and, as such, are the primary con-
stituents of the WQM planning process. Their support is essential not
only to plan approval, but also to continuation of the WQM planning
process and to plan implementation. However, as Executive Committee
members, local elected officials are not involved directly in the WQM
project. Rather, the Executive Committee will ultimately act on the
recommendations of the PAC which has output review responsibilities.
Only four elected officials serve on the PAC and the WQM staff noted
that they are not particularly active.
HG-2S
-------
Local elected officials may be relying on their technical staffs or
others more directly involved in the planning process to assist them
in their final review responsibilities. Fortunately, the H-GAC has
involved many of the area's key agencies as subcontractors for WQM work
elements and thereby achieved their exposure to, and support of, the
WQM project. Similarly, area technical experts have considerable
review responsibilities as members of the TAC, and may lend credibility
to overall plan recommendations.
Nevertheless, gauging the support of local elected officials at this
juncture is most difficult - especially considering the unknown
political ramifications of an as yet undetermined WQM strategy.
Political forces, propelled by economic interests in this pro-growth
area, framed by traditional anti-planning and anti-control attitudes,
and uncountered by a widespread recognition of a water quality problem,
may play the largest role in local decision-making regarding the
outcome of the WQM project, regardless of the data the H-GAC can
muster to document its WQM recommendation.
HG-29
-------
AGENCY: LOWER RIO GRANDE VALLEY DEVELOPMENT COUNCIL (LRGVDC)
REGION: VI - (Dallas)
GRANT AMOUNT: $775,000
GRANT RECEIPT: June 20, 1975
STARGIHG DATE: May 1, 1976
STATUS AT TTME OF INTERVIEWS: Work plan had not yet been approved and
contracts were being negotiated.
REASON FOR INCLUSION IN SAMPLE: Although the Lower Rio Grande Valley
is an economically depressed, rural-
agricultural area, it supports a mix
of economic activities affecting water
quality: developers; citrus-growers;
farmers; fisheries; shippers and light
manufacturing. The area is also growing,
but it is water-short, and present water
quality is poor. The water quality
issue is complicated by the impact of
the Rio Grande, poor migratory workers,
and international water source shared
with Mexico.
LRG-1
-------
I. BACKGROUND1
A. Area Description
In June, 1975, Texas Governor Briscoe designated the Lower Rio Grande
Valley Development Council (LRVDC) to conduct WQM planning for the
State's southern-most area. Bordering Mexico, the boundaries of the
designated area are within the Council's three-county region and in-
clude Willacy, Cameron and southern two-thirds of Hidalgo counties.
According to the 1970 Census, the area's population is 353,043. The
population is not highly concentrated, although the combined McAllen-
Brownsville SMSA covers most of the area. The seasonal influx of
tourists and migratory workers is not reflected in the population
statistics. Both groups have a substantial impact on the area's economy.
The Lower Rid Grande Valley is a leading producer of vegetables and
citrus fruit. Related food processing and apparel manufacturing ac-
count for much of the area's light industrial activity. The area also
produces natural gas, crude oil, and chemicals such as fertilizers and
insecticides.
The area is considered an economically depressed area with over 55
percent of the population below poverty level. Consequently, the
creation of jobs and the expansion of the tax base is important to the
area. However, a water shortage and need to protect existing agricul-
tural activity somewhat limits the area's ability to support future
growth.
B. Water Quality Problem
The Arroyo Colorado serves as a floodway for the Pa.o Grande and, in its
lower segment, as an inland waterway for ship transportation. The lower
25 miles of the Arroyo, which feeds into the Laguna Madre Estuary, is
designated by the Texas Water Quality Board (TWQB) as a Water Limiting
Segment with problems of high coliform count and low levels of dissolved
oxygen. Concern for pollutant impacts on the Laguna Madre largely arises
from its use as a fisheries nursery.
The WQM effort primarily will attend to the problems of the Arroyo Colorado
and, secondarily, to those of the Laguna Madre. The Arroyo receives all
of the Valley's runoff as well as the discharges of 30 wastewater treat-
ment plants. All municipal treatment plants are below standard and up-
grading these plants is a principal focus of the WQM effort. Although
the staff biologist did not expect nonpoint sources to be the major
water quality problem, the WQM project will analyze pollutants contributed
by septic tanks, saltwater intrusion, construction, dredging, mining,
silviculture, and agricultural practices including the pesticide, nutrient,
sediment and mineral content of irrigation return flows.
1 Information in this Chapter was taken from the Detailed Work Program^
May, 1976 , the Area/Agency Designation Package, and interviews.
LRG-2
-------
The limited ability of communities to pay for capital expenditures such
as wastewater treatment facilities is a-'contributing factor to the water
quality problem, as noted in the LRGV Area/Agency Designation Package.
An additional problem is the concentration of transient settlements
(colonias) adjacent to the Arroyo Colorado or next to borrow ditches
draining into the Arroyo. Typically, the colonias have primitive disposal
systems and septic tanks in unsuitable soils. The pollutants contri-
buted by these systems are as yet undefined. The spokesman for these
settlements felt that the colonias badly needed proper sewage disposal.
As a water source shared with Mexico, treatment of the water quality
problems of the Rio Grande is beyond the reach of the local VJQM effort.
However, water drawn from the Rio Grande for the Valley's extensive
irrigation system ultimately impacts the Arroyo as irrigation return flow.
The poor quality tailwaters which are high in saline content carry pes-
ticides, fertilizers, dissolved solids and other pollutants. Its impact
is enhanced by stormwater drainage during periods of heavy flooding.
From a water supply standpoint, the Rio Grande is of primary importance
to the area. This water-short area draws all of its water for irrigation
and consumptive uses from the Rio Grande. To those persons interviewed,
areawide concern for water supply is considerably greater than for water
quality; as water supply is critical to the area's ability to support
future growth. Water quality issues relevant to improving the water
supply (and consequently increasing the area's development potential) were
voiced as area priorities. There was also concern, however, that water
quality controls potentially may limit the area's capacity for growth.
Upgrading municipal wastewater treatment systems was noted as a primary
concern among elected officials and persons interviewed. However, each
also noted that the general populace is not particularly aware of the
water quality problem and that other more immediately felt social and
economic needs may have priority.
C. Designated Agency
The Lower Rio Grande Valley Development Council was created in 1967 by
a merger of the economic development district and council of governments
serving the three-county area. The member governments include three
counties, 25 cities, eight school districts and the McAllen Trade Zone..
In addition, 13 special districts hold memberships including several
water districts, navigation districts and utility boards.
The LRGVDC WQM activities are within the agency's planning department which
also conducts 701 comprehensive planning and DOT transportation planning.
The Inter-national Boundary and Water Commission to date has successfully
worked to divert a saltwater estuary from the Rio Grande but has yet to
ameliorate the point source discharges and the nonpoint sources of pollu-
tion, particularly the dumping of raw sewage.
Also of substantial concern to the Lower Valley is the high saline con-
tent of irrigation waters drawn from the Rio Grande which is causing
salt accumulation on the land. One estimate of the cost to desalinize
the irrigation water was given at $300 per acre.
LRG-3
-------
LRGVDC serves as an A-95 clearinghouse and provides areawide services in
housing, criminal justice, aging, health planning, and human resources.
The LRGVDC staff is headed by an Executive Director. The WQM Director
had been with the program two months at the time of the interview and
is assisted by a Biologist and a Planner. With only three professional
staff devoted to the WQM effort, most of the WQM funds ($775,000) will
be allocated tor professional consulting services. As required by the
State Guidelines for WQM plan preparation, the staff is retaining respon-
sibility for monitoring and coordinating subcontractor activities,
coordinating the plan with affected government units, and integrating
subcontractor outputs into the final reports. State Guidelines also
require that separate subcontracts be awarded for each planning element;
and presently the LRGVDC has awarded contracts for six major plan com-
ponents :
o Public participation (Resource Planning .Consultants);
o Management planning (Barnes and Crow);
o Impact assessments (Tereco);
o Point source analysis and alternative technical subplan
(Stevens, Thompson and Runyan);
o Socioeconomic data base (James A. Veltman); and
o Nonpoint source analysis (Roy F. Weston and Sigler,
Greene and Associates).
In addition, the LRGVDC has subcontracted with the Texas Water Quality
Board (TWQB) for sampling and modeling information and for general
State coordination and assistance.
LRG-.4
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The WQM agency staff expressed specific expectations for the project's
outcome which are shaping their planning strategy. As all of the area's
wastewater treatment facilities are currently operating below standard,
the WQM agency staff hopes to achieve a solution to the point source
problem which is publicly acceptable. The WQM staff viewed nonpoint
source problem identification to be an important product of the analysis
but expected it to " (potentially) result in conflict among the various
water users, e.g., irrigated agricultural areas using pesticides and
insecticides impacting fish nurseries. Local attitudes opposed to
imposed controls, regional solutions, increased costs and negative
growth impacts were cited as additional constraints on the program's
strategy. In light of these limitations, the WQM Director felt that
I informing officials and the public of the water quality problem sources
and recommending corrective alternatives were the extent of the agency's
political capabilities. Further, the LRGVDC Executive Director'noted
that the agency has to serve the interests of its member governments and
'he felt the WQM process would potentially generate a conflict of interest
ijfor the agency.
B. Technical Component
According to the Work Plan, the LRGVDC project intends to analyze compre-
hensively the point and nonpoint source contributions to the water quality
problem. Following this analysis, the LRGVDC will determine the appro-
priate emphasis on point or nonpoint source problem correction. The
WQM agency staff currently expects point sources to prove the major
pollutant. The WQM is also concerned with nonpoint contributions of
insecticide, pesticide and septic tank pollutants. The WQM staff and
the other interviewees did not yet feel they had a clear sense of the
level of detail required by the State or EPA, and they felt their analysis
would be constrained by the limited planning period.
Two State officials commented on LRGVDC1s concern with the-appropriate
level of water quality analysis. The TWQB Planning Chief and a Governor's
Office staff member agreed that the WQM program should be both product
and process oriented. Specifically, the TWQB Planning Chief stated that,
"Outputs are required to say where the program is going, but an ongoing
process is needed to evaluate what can be solved now and what additional
data is required". Thus, the State officials expected a first-cut analysis
within the time allowed with portions remaining unanswerable. The TWQB
Planning Chief felt that, if given more time, the designated WQM agencies
would try to solve everything and the result would be more and more
planning with no outputs. Accordingly, the TWQB Planning Chief stated
that the local WQM agencies were having difficulty adapting to the
"short aotion-response-revision" approach necessary to achieve outputs
within the given timeframe.
LRG-5
-------
C. Management Planning
Management planning is to begin in December, 1976 under subcontract
to the consulting firm of Barnes and Crow. The WQM Project Director
felt that it would be desirable to begin management planning earlier
and was attempting to secure the appropriate contractual arrangements.
Financial analysis and existing areawide waste treatment program identi-
fication proceeds independently to produce an existing management systems
report. Existing authority for nonpoint source controls will also be
inventoried and analyzed. Management and financial system criteria,
including political constraints, will then be developed and applied to
the point source technical alternatives and nonpoint control strategies.
The resulting management alternative report will then be integrated with
the technical subplan report.
D. Public Involvement Program
The WQM Policy Advisory Committee (PAC) was organized in December, 197 5.
The 45 committee members and the Chairman were appointed by the Governor
and represent the area's public agencies, including the several water
districts, public utilities, municipalities and counties, as well as
agricultural, private industrial and environmental interests. As local
elected officials serve on LRGVDC's policy-making body or Executive Board
their involvement on the PAC was not sought. According to the LRGVD
Executive Director and WQM Project Director, this design was necessitated
by the limited time commitments possible for officials who serve voluntar
in their elected capacities. The Management and Technical Subcommittees
of the PAC have reviewing responsibilities and, to date, have screened
and recommended consultants for the subcontracted work elements.
The WQM project was subcontracted with Resource Planning Consultants
to design a public participation program tailored to the various phases
of the planning process including implementation. In addition, the
consultant has the following tasks:
o Prepare a mailing list which specifies interest groups;
o Initiate a quarterly WQM newsletter;
o Assist in preparing educational materials including a
bilingual brochure and news release;
o Prepare a slide presentation;
o Train LRGVDC staff to carry out the public participation
program and provide ongoing technical assistance;
o Assist in sponsoring seminars fo.r PAC members and local
governmental officials;
LRG-6
-------
o Prepare working papers for local review describing the
various tasks of the public participation program; and
o Evaluate the participation program and recommend
actions for future public involvement in WQM planning.
This final report will be part of the WQM plan.
E. State and Federal Involvement
The Texas Water Quality Board and EPA Regional office have a close
relationship in working with the designated WQM agencies. By a two-
party agreement, the TWQB was named the lead agency in reviewing and
monitoring the local efforts. Both EPA and the TWQB representatives
attend Policy Advisory Committee meetings and maintain daily telephone
contact. Both agencies-also have¦had considerable input to the develop-
ment of the workplan. Although the LRGVDC project staff felt some EPA
and TWQB involvement was necessary and desirable, they noted that cumber-
some delays resulted from the coordination and procedural requirements
in working with the two agencies. The WQM Director noted that pre-
award audits required two to three weeks while one or two weeks were
involved in review of the contract.
The WQM staff stated that they had high regard for and good rapport
with the EPA regional project officer, but that they needed more
personal technical assistance. The WQM staff expressed the need for
personal EPA advice on the mechanics of coordinating and managing the
project.
The TWQB is a major participant in the WQM agency's project with a State
participation contract for $56,000 and modeling and sampling contract
for $14,000. State assistance was welcomed for monitoring and provid-
ing technical assistance to the project. However, the WQM Project
Director felt that they were "locked" into State guidelines and that
State involvement was so extensive that considerable delays resulted.
He also felt that the TWQB was not clearly defining the necessary level
of detail.
As State WQM planning is proceeding concurrently with the designated WQM
planning projects, close coordination is built into the two processes.
The State Plan is based on 15 planning basin areas, and the TWQB Planning
Chief sees the State approach as being very different from that of the
designated WQM agencies. Due to the time constraints for both State
and local processes, the TWQB Planning Chief noted that the designated
plans will not be incorporated into the present State planning effort,
but rather will be embodied in the future State Plan revisions. The
TWQB Planning Chief felt that the two processes could be developed in
a compatible and consistent manner in order to facilitate their eventual
merger .
LRG-7
-------
F. Scheduled Outputs
The Detailed Work Program summarizes the reports to be generated by the
project and their expected completion data. This summary is shown in
Exhibit I. However, expected completion dates were based on a May 1,
1976 start date rather than the actual start date of June 6.
G. Achievements to Date
Most of the effort to date has involved staff organization and the develop-
ment of the work program, which remains to be approved. The organizational
time required resulted in a late start date of June 6, 1976 for the project.
In the development of the workplan, the TWQB and EPA had considerable
input in order to coordinate the concurrent State and local planning
processes. The TWQB Planning Chief felt that such coordination would
be required on an ongoing basis and required the EQM agencies to submit
detailed workflow charts for the purpose of monitoring task schedules.
Following completion of the workplan, the WQM staff has spent all of their
time on the process of awarding and negotiating contracts. The staff
noted that the coordination and timing problems of the contract approval
process required by the TWQB and EPA have caused considerable delay.
The project is already one and one-half months behind schedule, although
LRGVDC hopes to catch-up through some lag time built into the schedule.
With a start date of June, 1976, the LRGVDC staff could not yet point to
specific achievements. The involvement of the advisory groups in the
consultant selection process was noteworthy, however. The Management
and Technical Subcommittees of the Policy Advisory Committee interviewed
and screened the various consultant groups and made final recommendations
to the PAC for approval. Also of interest was the plan for bilingual
public information materials and programs.
LRG-8
-------
TITLE DESCRIPTION
NUMBER
TITLE
2.36 Socio-Economic Report:
2.15 Existing Water Quality
Data Base Report :
r*
j 2.43 Modelina Report:
vO "
2.26 Point Source Report:
2.59 Non-Point Source Report
EXHIBIT I
REPORT SUMMARY
LRGVDC
PROJECTED PROJECT
CONTENT COMPLETION DATE MONTH (QUARTER)
Existing and projected
land use, population
economic conditions 8-1-76 3 (I)
Water qua!i ty and
use data, water quality
problem areas, quanti-
fied 1983 objectives 9-15-76 4? (2)
Samp Ii ng data and
calibrated and verified
model 11-15-76 65 (3)
Existing point Sources,
projected waste loads,
and control alternatives
including costs and im-
pacts
1-1-77 8 (3)
Identification of non-
point sources and loads;
control strategies, in-
cluding costs and impacts 1-1-77 8 (3)
-------
TITLE DESCRIPTION
NUMBER TITLE
3.30 Management Report I:
2.70 Technical Subplan Report
3.50 Management Alternative
Report:
4.3! Draft Report to include
voIumes on
Areawide Plan:
Technical Plan:
Management Plan
Environmental Assessmenh
CONTENT
PROJECTED PROJECTED
COMPLETION DATE MONTH (QUARTER)
Management and financial
analysis, political con-
straints, assessment of
existing areawide waste-
water treatment programs 4-1-77 II (4)
Segment analysis, alternate
discharge points, additional
segments for modeling, im-
pacts and costs of technical
subplans, screened subplans 7-1-77 14 (5)
Conceptual alternatives,
management and financial
system criteria, manage-
ment subplans 8-1-77 15 (5)
2-1-78 21 (7)
Major provisions of the
plan, update and implemen-
tation requirements
Technical details of plan,
results of previous tech-
nical reports
Management details of plan,
results of previous manage-
ment reports
Base line descriplion,
assessment
-------
TITLE DESCRIPTION
NUMBER
TITLE
CONTENT
PROJECTED
COMPLETION DATE
PROJECTED
MONTH (QUARTER)
6.40
Public Participation
Report:
Existing programs and
reguI at i ons (I 976),
program for pub Ii c
participation, results
of public participation
program
3-1-78
22 (8)
4.32
Final Report:
Identical to draft
report's, except for
changes made as a result
of local and state re-
view. Also, a section
will be devoted to publ ic
participation in the final
areawide plan report 4-1-78 23 (8)
I. Based on May I, 1976 start date
Source: Lower Rio Grande Valley Development Council, Detailed Work Program for Lower Rio Grande
Valley Areawide Wastewater Management Planning Program, May, 1976, pp. 19-21.
-------
III.
EXPECTATIONS
A. Water Quality
Most interviewees felt that the WQM process provided a start toward im-
proved water quality. Generally, control of point sources on the Arroyo
was expected to upgrade its water quality. However, it was frequently
noted that several municipalities would not be likely to accept the
facility planning recommendations due to their preferences for an
autonomous solution. Accepatable solutions to the several nonpoint
sources, particularly agriculture, were not expected. Nevertheless,
several PAC members, including local elected officials and employees of
water-related agencies, believed the WQM process generated informational
benefits which would contribute to water quality improvement, including
increased awareness of the importance of the water quality issue, and
related costs of improvement and better planning in the extension of
water and sewer lines. There was general agreement that the area would
not achieve the 1983 goals. A utility board official felt the standards
were too high for the area and that there was "a difference of opinion
regarding the definition of fishable, swimmable". The TWQB Planning Chief
felt that by 1983, the goals would be achieved where attainable and that
the WQM process would define areas where goals were not attainable.
B. Plan Approval and Implementation
Interviewees were asked to speculate on the likelihood of plan approval.
Although responses varied, they centered around a fifty percent or
less chance of approval. The WQM staff was less optimistic than other
interviewees. Most interviewees generally agreed that there is a lack
of interest in and understanding of the WQM effort and overall water
quality problem. As water quality is not particularly an area priority
relative to other concerns such as water supply, flood control and economic
development, all foresaw considerable and lenghty public exposure as a
prerequisite to plan approval. However, the WQM Project Director believed
the program's time constraints limited the agency's ability to "sell"
the plan to local officials. He also believed a locally acceptable plan
would be more flexible and negotiable than seemingly allowed by the
State and EPA. Several interviewees expected the area's predominant
attitude of local autonomy and the plan's cost implications to be po-
tential obstacles to plan approval. Although the LRGVDC Executive
Director stated that local elected officials had so far not voiced
opposition to the WQM planning process and felt they were committed to
the extent that their resources would permit, two officials expressed a
/more skeptical view of the plan. One board member of a public utility
believed selling the WQM program to his community would be a problem,
as the community would be reluctant to relinquish any control of its
presently successful, self-supporting treatment system. Another elected
LRG-12
-------
official stated that although, she was interested in the WQM goals, she
would support a plan only if it produced locally beneficial results
and allowed local control and maintenance of the current tax level.
The TWQB Planning Chief stated that the State would support the WQM plan
to the extent possible. However, the TWQB has the responsibility to
look at the whole State and determine if the local WQM plan is compatible
with overall interests and cost/benefit tradeoffs.
As with plan approval, speculation regarding the likelihood of plan
implementation was evenly split. Generally, the likelihood of imple-
mentation seemed to hinge on funding availability and plan acceptability.
o Most felt that the economically depressed nature of the
area limited resources and causes other social and
economic concerns to have higher priority. One local
elected official was determined to protect the taxpayer
from increased costs and doubted that the plan would offer
a local advantage.
,o The majority of the interviewees, including the WQM staff
and two local elected officials, expected" some municipal
regional opposition to treatment facilities, due to a
strong preference for local control as well as the failure
of a previous regional wastewater treatment effort.1
o As with plan approval, there was general agreement that
the major difficulty with implementation was "selling"
the plan locally, particularly considering the area's
anti-regional philosophy.
o The diversity of interests in the area -- farmers, colonias,
fisheries, citrus growers, developers and municipalities —
was seen to potentially conflict regarding appropriate
water quality controls affecting growth and land use.
o The WQM staff felt that nonpoint source controls would
encounter substantial opposition from agricultural in-
terests.
o One specific problem noted by several interviewees was
the potential impact of controls on migrant settlements.
A locally initiated planning effort for regional wastewater treatment
facilities prompted the establishment of an implementing authority.
The eventual failure of the authority was widely felt to be caused by
EPA's lack of support. Although the authority still exists, it operates
only three systems on a contractual basis.
t.rp,-] 3
-------
Because of the social and economic complexity of the
problem, no one expected the WQM plan to provide an
implementable remedy.
o Most of the interviewees felt that nonpoint source
controls would be limited by the lack of land use con-
trols in the area.
Expectations regarding alternate management agencies focused on a strong
preference for local control. Most interviewees felt that the LRVDC
was not a feasible management agency primarily because of its voluntary
nature and its design for planning. The WQM staff did not expect the
State to be an implementing authority although the LRGVDC Executive
Director felt that a State management agency was necessary for uniform
standards and cited the TWQB's present authority for this purpose.
The TWQB Planning Chief expected that very few new implementing authorities
would be established by 1978 due to time constraints. All State level
interviewees noted the political unreceptivity to regionalism. The TWQB
Planning Chief expressed the need for innovative approaches to manage-
emnt, rather than State-imposed regional systems.
Several State and local interviewees commented on the existing authority
to implement the WQM plan. All sources mentioned the anti-planning
attitudes prevalent in the State. One State legislator called the
Texas policy one of "unfettered growth" and stated that the basic problem
of WQM rested with the fact that there are "no basic rudiments of land
use regulatory power to implement 208". Presently, there are no zoning,
permitting or flood plan controls in the area beyond municipal juris-
diction. Although Texas counties are capable of regulating private
sewage facilities, a local elected official noted that only Cameron
County has been enforcing septic tank controls.
There was general agreement at State and local levels that no legislative
needs have been specifically identified. The State is currently identify-
ing existing legal constraints and LRGVDC has subcontracted for legal
analysis with the professional consultants responsible for management
planning. The TWQB Planning Chief suggested the need to expand county
powers and to strengthen municipal extraterritorial jurisdictions. One
local elected official felt that legislation would be required in all
aspects of point and nonpoint source control, particularly for the
protection of prime agricultural land.
No legislation contacts have been initiated by the State or LRGVDC. The
TWQB Planning Chief regarded such contact as premature because the WQM
program could not yet "be sold". A State legislator as well as two legis-
lavtive staff members indicated that most legislators were not aware of
the WQM program.
LRG-14
-------
State officials interviewed noted that, should legislation be required,
the earliest realistic date for consideration is January, 1979, as the
Texas Legislature meets biennially. Generally, it was felt that legis-
lation during the January, 1977 session was not feasible. A Governor's
Office staff member noted that the timing of the WQM program did not
allow for a "gap" between plan completion and any required enabling legis-
lation.
C. Continuing Planning Process
Local expectations for continuation of the planning process after the
initial two years were generally mixed. Several respondents indicated
that the process should be continued. Among the various reasons cited
were the need to address problems as they arise, the long-time period
required for problem resolution, and to revise and update the plan.
The WQM Director felt that program continuation had a fifty-fifty
possibility, with funding, flexibility of the plan and plan approval being
the primary factors. The Executive Director of the Colonias responded
that continuation depended on local commitment. The LRGVDC Director,
PAC Chairman, and one citizen, felt that the WQM process would not be
completed in two years. One local elected official felt that if the
plan could not be done in two years, the effort should be abandoned.
There was not much local response to the question of who should be re-
sponsible for continuing planning. Generally, this issue was tied
to whether they believed if funding would be available or if plan-
ning should or would be contined. One citizen noted that there were
only two existing areawide, agencies LRGVDC and the Chamber of Commerce.
The Executive Director noted that LRGVDC could retain the planning func-
tion but he was not sure that it should. One citizen hoped that a new
agency would be created which was more representative of the area's
interests.
The TWQB Planning Chief believed that the continuing planning process
would largely be a State responsibility and would consist of: (1) the
verification of significant nonpoint sources and controls; (2) preliminary
screening and statistical collection of data regarding the biggest
problems; and (3) an emphasis on facility planning in order to provide
an adequate basis for the construction grants program.
Interviewees generally expected State and Federal financial support for
continued planning. The official from the Governor's Office expected
some mix of Federal, State and local funds and the State legislative
branch interviewees felt that the Legislature was not adverse to appro-
priating funds for water quality efforts. There was general agreement
that continued local planning efforts would not be locally funded.
The ]jRGVDC Executive Director expected any local contribution to depend
on the identified benefits of continued WQM planning. One local elected
LRG-15
-------
official preferred local funding of WQM activities to retain a small
scope and a cautious approach to spending.
D.
Relation to Other Water Quality Programs
Overall, interviewees expected the WQM plan to have some impact on the
construction grants program. The WQM Director and LRGVDC Executive
Director expected the plan to indicate appropriate funding priorities.
The TWQB Planning Chief viewed the helpfulness of the WQM program to
the construction grant program as depending on the depth of the analysis,
i.e., systems work. One citizen hoped the WQM plan would have a voice
in getting substandard facilities upgraded. ne spokeman for the
colonias hoped the plan would provide the colonias with eligibility for
facilities grants. Another local elected official, however, did not
favor the facility funding program which she felt coerced unrealistic
and costly regional solutions.
Most of the interviewees expected the WQM effort to impact the NPDES
permit program, but were uncertain as to the extent. The WQM Director
expected the approved plan to provide the basis for NPDES permits.
One citizen relt that present discharge standards were "ridiculous"
and hoped the WQM plan would provide a more realistic basis for future
permits. The Planning Chief of the TWQB, which has NPDES permitting
authority, had a more specific view of the WQfl impact on the NPDES pro-
gram. She expected the designated WQM plans to establish sound objec-
tives in areas not meeting 1983 goals and to accordingly provide a
basis for revised wasteload allocations.
E. Local Definition of Success
Each interviewee was asked to state his/her definition of a success for
the WQM effort. With two exceptions, interviewees generally defined
success in terms of some degree of water quality improvement, particularly
point sources, and an acceptable plan. Specifically, their statements were:
o
(WQM Director) — A solution, which is publicly acceptable,
to the point source problem within the time and funding
framework.
o
(COG Director) — A degree of improvement in water quality.
o
(Mayor) -- A plan that locals would accept and the elimination
of dumping raw sewage into the Arroyo.
o
(Director of Migrant Settlements) -- Program that affects
construction grants planning, deals with the problems of
the colonias, sets up a democratically controlled mechan-
ism, and meets with generally, favorable support.
o
(Citizen) -- A complete study of all sources of pollution,
including drainage and irrigation systems.
LJ^G-16
-------
o (Public Utility Board Official) — Not hopeful that it
will be accepted.
o (Navigation District Engineer) — An organization where
all municipalities and the rural area work together to
solve problems, as heretofore each has been contributing
to the other's problems.
o (Citizen) — Proper drainage and distribution of water.
o (State Water Quality Board Planning Chief) -- A clarifi-
cation of needs for data regarding treatment systems,
the development of realistic objectives, and an identi-
fication of the origin and solution to water quality problems.
Each local interviewee was also asked to indicate the direct or indirect
benefits they expected from the WQM process. One local elected official
expected "nothing new that will work"; another official, while not in
favor of the WQM effort, expected good, usable data as a benefit. Overall,
the informational/planning outputs of the WQM program were cited as
beneficial in several ways. The following benefits were mentioned:
o Public education;
o Better zoning;
o Improved recreation;
o Better planning in extending water lines;
o Technical advice regarding compliance with water quality
standards;
o More efficient systems for sewage disposal;
o More information regarding the water quality problem of
the colonias;
o Influence on local political bodies; and
o Clean water.
LRG-17
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM agency staff generally viewed their role as providing an identifi-
cation of the water quality problem and making recommendations to local
agencies for problem correction. They saw their role in the context
of the planning function performed by the Council of Governments and
not to include management or enforcement responsibilities.
The staff felt that WQM programs placed the agency in a delicate position
regarding the interaction of water quality, growth and land use, e.g.,
developers, municipalities, farmers, citrus-growers, and fisheries.
In addition, the WQM agency staff'saw EPA and State WQM requirements as
potentially causing a conflict of interests for LRGVDC.
B. Citizens
The five citizens interviewed included: a Water District Manager, the
Director of Migrant Settlements, an Environmentalist, a Navigation
District Engineer and An Oil Plant Chemist. All were Policy Advisory
Committee (PAC) members.
Four citizens were satisfied with their involvement and felt that
the WQM staff was responsive to their input. Further, one felt that
the PAC had considerable influence on the shape and direction of the
project.
A fifth citizen was dissatisfied with his involvement. He expressed
frustration with the cursory level of discussion and felt the PAC should
be talking more about area issues rather than the mechanics of the WQM
studies.
Most of the citizens believed the area attitude of local autonomy
would hinder the prospects for a successful project. One citizen
believed local elected officials must be better informed regarding the
WQM project. He was concerned that, with the area decision-makers
serving on the LRGVDC Executive Board and not on the PAC, reaching them
may be a problem. Two citizens also believed the State may not approve
a plan reflecting local priorities and preferences for WQM.
Two citizens had specific objectives for their participation. One
wanted to obtain sewerage for the migrant settlements. The other
wanted to have some input to the ongoing coastal zone management program
in the area.
C. Local Elected Officials
One local elected official was interviewed. She was Mayor of a small
community and the only elected government official serving on the PAC.
LRG-18
-------
She also -serves on the LRGVDC Executive Board. She viewed her role in
the WQM project as protecting the area priority of preserving agricul-
tural land and generally protecting taxpayers from costly regional
solutions not beneficial to her area.
She was interested in the WQM goals but primarily was concerned with
improving water quality related to the present poor quality of water
supply and irrigation water as well as obtaining proper sewage disposal.
Although her community has need for sewage disposal, its small size
precluded priority eligibility for Federal construction grants. In
her view, regional facilities were not acceptable because of the loss
of local control over taxes. Instead, she was seeking innovative
sewage treatment methods which could operate within limited local
resources. Generally, she saw the limited local ability to pay as
a major obstacle to WQM plan approval and implementation.
She felt the WQM planning function should terminate with presenting the
plan and providing information regarding the importance of the water
quality issue. Although she did not support continuing WQM planning,
she foresaw the PAC as a potential body for continuing areawide WQM
policy-making.
D. Appointed Official
A public utility board member answered interview questions in this
category. He serves as a member of the PAC as well as Chairman of the
board managing a city water and sewer facility.
The board member believed that, although the WQM process would generate
information useful to operating agencies, he generally did not expect
his board to approve the plan if their present management responsibilities
were disrupted. For other communities, he saw a similar preference for
local control, which he noted had worked against previous regional waste-
water treatment efforts. Further, he believed officials were unable to
keep up with the WQM demands because they lack necessary revenues for
building facilities.
E. State Legislators
One State Senator was interviewed and supplementary legislative information
was obtained from a staff member of the Office of the Speaker, Texas
House of Representatives, and a legislative committee staff member.
All indicated that most legislators are not aware of the WQM program.
The State Senator believed that EPA made a false assumption "that States
would come around with land use regulatory authority to implement non-
point source controls". He felt that Texas would not legislate land use
regulatory powers, as its current policy is one of "unfetbered growth".
LRG-19
-------
He also expected WQM planning to be handled bureaucratically rather than
legislatively and that legislative involvement would be limited to
budgetary appropriations for State agencies. Although he believed
legislators were not adverse to appropriating funds for water supply and
water quality activities, he felt the TWQB would need to improve its
relationship with the Legislature to obtain needed support.
Neither the State Senator nor the staff member of the Speaker's Office
expected legislative support for strengthening the authority of councils
of governments. All noted that, as the Legislature meets every biennium,
no legislative activity could feasibly occur until the 1979 session.
F. State Water Quality Personnel
As defined in Executive Order 1S-A issued March 23, 1376, three State
agencies have responsibilities related to water quality planning for
designated and nondesignated areas. The Texas Water Quality Board
(TWQB) reviews all WQM planning and conducts WQM planning in nondesig-
nated areas concerning nonpoint sources related to agricultural and
silvicultural practices, which is a responsibility assigned to the
Soil and Water Conservation Board (SWCB). The third State office in-
volved is the Special Advisor to the Governor on Natural Resources.
The Special Advisor is defined as the individual with primary responsi-
bility for WQM planning in Texas and, as such, the TWQB and SWCB must
seek the advice and concurrence of the Special Advisor in all aspects
of WQM planning in both deisgnated and nondesignated areas. The Special
Advisor also chairs the State Management Committee which was established
to direct nonpoint source management planning in nondesignated areas
and to coordinate nonpoint. source management planning with point source
planning in nondesignated areas and with designated area WQM plans.
Overall, the State's position with respect to designated WQM planning
areas is to be involved throughout the WQM process. Executive Order
18-A charged the TWQB with responsibility to develop criteria and pro-
cedures in the form of State guidelines which are binding on the desig-
nated WQM planning agencies. The TWQB monitors compliance with the
guidelines including review of detailed workflow charts to determine
if WQM planning agnecies are on schedule and if they understand their
tasks. The TWQB also provides technical assistance through a State
participation contract with designated agencies. The LRGVDC WQM project
has such a contract for $56,000 in addition to a sampling and modeling
services contract with the TWQB for $14,000.
The TWQB Planning Chief noted that State involvement was necessary to
assure the compatibility and consistency of WQM planning in designated
and nondesignated areas. She also indicated that designated area plans
will be incorporated into the update of the State WQM plan and, with
ongoing State involvement, their merger should be no problem.
LRG-20
-------
The TWQB Planning Chief felt that the Act's intent of State control was
unclear and that the Act seemingly "holds the State responsible for
WQM j)lanning while telling locals it is their program". Further, she
noted that locals feel water quality standards should be a local option,
but that the State retains responsibility for a Statewide perspective
to the WQM. Although she indicated that, to date, the State-local
relations are effective, they are not always friendly or congenial.
She expected the State to approve designated WQM plans "if they are
properly done and documented".
The TWQB Planning Chief also commented on the State's role concerning
management and continuing planning. She did not expect the State to
impose regional management systems, but rather expected innovative
management approaches utilizing or expanding upon existing authority
to be developed by the designated agencies. Nonetheless, the TWQB
is granted broad police powers under the Texas Water Quality Act to
"implement all plans necessary to the Continuing Planning Process
required by PL 92-500". As noted in Chapter III-C, the State expects
to have primary responsibility for continuing planning.
LRG-21
-------
V.
A.
ANALYSIS AND CONCLUSIONS
Likelihood of Plan Completion, Approval and Implementation
Although the LRGVDC project is just getting underway, the WQM staff and
other interviewees were already concerned that the planning effort may
not be completed. Delays in workplan development and contract negotia-
tions have already put the program behind schedule. The WQM staff attri-
buted delays to extensive EPA and State involvement in the WQM project
and the continuing coordination required for working with the two
agencies. LRGVDC has much to accomplish in the planning period insofar
as all point and nonpoint sources are being analyzed. Following the
technical determination of the relative source contributions to the water
quality problem, it seems likely that LRGVDC will need to identify and
prioritize particular problems. To date, LP*GVDC expects point sources
to be so identified. Should nonpoint sources prove a larger problem
than presently anticipated, the WQM strategy may need considerable
adjustment to achieve a completed plan in two years.
The LRGVDC has expressed hope for a project extension and for additional
funding in order to complete the plan. The State has encouraged wqm
agencies to adopt their strategies to the planning period allowed, but
did indicate that a one-year extension may be possible although continued
funding was not indicated. From the State's perspective, designated WQM
plans will not be incorporated into the State WQM plan until the State
plan revision/update. However, the EPA Regional Office recently notified
ILRGVDC that a project extension or additional funding would not be allowed
land that LRGVDC must tailor its program to fit the current planning period.
[In this light, WQM program cutbacks are likely.
Obtaining both State and local approval of the WQM plan may be difficult.
As the WQM Director noted, time constraints may limit the WQM agency's
ability to gain local approval, especially given the area's predominant
attitude of preserving local autonomy and the uncertainty of the plan's
ramifications, such as costs and enforcement. Further, the heavy State
and EPA involvement in the WQM project may cause a plan to be produced
which is not in keeping with local priorities. Although it is not clear
that there will be a disparity among State, EPA and local requirements
for plan approval, coordination between these three entities may prove
difficult for the LRGVDC. Several factors which pose potential difficulties
for plan approval and implementation are:
o Unreceptivity to cost increases together with the social
and economic priorities competing for limited revenues;
o The failure of a previous regional waste water treatment
effort;
LRG-22
-------
o Potential controversy among economic interest groups re-
garding nonpoint source controls; and
o The political sensitivity of enforcing septic tank controls
in the substandard settlements of poor migrants.
LRGVDC, as a voluntary association of governments, will not be a management/
enforcement agency, nor does the State expect to impose any regional
systems. Consequently, management will undoubtedly occur at the local
level with the WQM plan offering recommendations for implementation. Two
local elected officials interviewed were generally not in favor of the
WQM plan, except as a data resource. This situation does not support an
optimistic outlook for plan implementation.
B. Public Participation
The WQM advisory committees include a range of interest groups and public
agency officials. Members have had major program responsibility for
screening and selecting subcontractors for WQM work elements. In so
doing, they have had a definite impact on the direction of the WQM pro-
gram and, by their involvement, have become acquainted with the WQM plan-
ning process. However, interviewees representing local agencies were
somewhat skeptical of the WQM process but felt they should take an active
role to represent and protect their various interests. With LRGVDC
serving the area at the pleasure of local support, the advisory commit-
tees, as well as the LRGVDC Executive Board, may play a significant role in
shaping the outcome of the WQM planning process.
Aside from the advisory committees, LRGVDC has not begun any public involve-
ment efforts. The consultant responsible for designing the public parti-
cipation program is to train and assist LRGVDC staff in its execution.
Because of low public awareness of the water quality problem, the need
for public education is sizeable. Further, with the potential controversy
among economic interest groups (e.g., fisheries, citrus-growers and
developers) regarding nonpoint source controls, LRGVDC will need to expand
its involvement efforts effectively to reach these groups. LRGVDC1s
public involvement efforts may have to go beyond the educational materials
and seminars, however, this may be the extent of involvement achievable in
the limited time and funding period. Ideally, LRGVDC should build
support and educational linkages with ongoing related agencies to extend
the reach of its present resources.
C. Current Planning Process
LRGVDC is in the phase of problem identification and, following isolation
of the relative importance of point and nonpoint source problems, will
adopt its WQM strategy accordingly. Although emphasis is expected to be
placed on facility planning, LRGVDC is also'devoting attention to all
nonpoint sources. With no likelihood of project extension, the LRGVDC
will be forced to tailor its WQM planning strategy to fit the time allowed
and may face difficult decisions regarding cutoff points in its analysis.
LRG-23
-------
With only three professional staff devoted to the WQM planning effort,
the demands are extensive for monitoring and coordinating subcontracted
work tasks, coordinating WQM efforts within LRGVDC and with the State
and EPA, and working with public involvement programs. More State
and EPA technical assistance on a personal scale was desired by the
WQM staff which was clearly feeling overwhelmed by its programmatic
responsibilities and limited resources.
D. Continuing Planning Process
i
Continuation of the WQM progess beyond the initial two years seems to
depend on local commitment and funding. It is not clear that LRGVDC
will be able to generate sufficient support to continue the WQM process,
although Federal and State funding would greatly increase the likelihood
of continued planning. The State seems the most likely candidate for
continuing planning should the designated agencies not have that capa-
bility. The State WQM planning process is already in high gear with
clearly delineated objectives for a continuing planning process. The
State's approach, based in 15 planning basins, includes elaborate localized
committee structures which could well absorb the LRGVDC effort.
E. Significance of Local Elected Officials' Involvement
Local elected officials are the primary LRGVDC constituents of the WQM
planning process and their support greatly affects the likelihood of
plan approval and implementation as well as continuation of the WQM
planning process. Although their support is essential, the WQM advisory
committees include only one local government official. This official is
not generally supportive of the WQM effort, but participates to protect
her community's interests.
Although the LRGVDC Executive Board members are the locus of areawide
local elected official participation, they are only remotely involved
in the WQM project. Serving voluntarily in their elected capabilities,
local officials generally do not have the time to devote to direct
involvement, nor do they have sophisticated expertise regarding WQM.
The LRGVDC keeps in contact with governmental staff members (i.e., city
managers) to reach these officials indirectly, but no such staff
exists for many of the small communities.
As a voluntary association of local governments, LRGVDC primarily serves
the interests of member jurisdictions and, consequently, must .frame
its WQM approach diplomatically according to what is locally acceptable and not
according to which water guality improvement is required. Strong attitudes
of maintaining local control and autonomy, preventing tax increases and
avoiding politically sensitive controls, (i.e., land use and septic tank)
will not be dealt with easily in a two-year planning period.
LRG-24
-------
AGENCY: MARTHA'S VINEYARD COMMISSION (MVC)
REGION: I - (Boston)
GRANT AMOUNT: $216,000
GRANT RECEIPT: June 16, 1975
STARTING DATE: June 16, 1975
STATUS AT TIME OF INTERVIEWS: The agency was beginning its second year
of scheduled two year planning period.
REASON FOR INCLUSION IN SAMPLE: Martha's Vineyard is a coastal/recreational
area posing unique pressures on a limited
water supply and currently high quality
water resources.
MVtI
-------
I. BACKGROUND1
A. Area Description
Martha's Vineyard is a small island community lying five miles off
the coast of Cape Cod, Massachusetts. It has been described as an
"island preserve consisting of quaint communities, small shops and
aesthetic appeal wrapped in a strong sense of place and loosely federated
with the rest of the world by ferry boat, telephone, television, radio
and the U. S. Postal Service."2 The local economy, once based on
farming, now centers on tourism, services and construction as they
relate to the resort industry. Each summer, the population swells
six times more than the normal year round population figure as
tourists flock to the Island to enjoy its cultural charm, beauti-
ful beaches and fine harbors. Most of the Vineyard's population
is clustered in three of the six towns, The interior, although still
rural in character, is quickly succumbing to development pressures.
The entire Island is incorporated into six townships, each with
its own elected Board of Selectmen. The Town meeting is still a
very influential form of governmenta and is actively supported by
local citizens. Although the Vineyard constitutes a county, the
Island's county government is very weaK, as is true throughout
Massachusetts. Only two of the six towns are zoned "although all
are empowered to do so. Local land use planning has been almost
non-existent. There is only one municipally owned and operated
wastewater treatment plant on the Island although several towns
are currently in initial stages of planning individual plants.
The most unique element in the Island's government and regulatory
structure is the—Martha1 s—Viney:ard_Commi ssion (MVC.) , a multi-town
land use planning and management program with regulatory and enforcement
responsibilities. The MVC was created in 1974 in reaction to the
threat of a Federal Nantucket Sound Islands Trust Bill, which would
have established a Federal commission to protect Nantucket, Martha's
Vineyard and the Elizabeth Islands from uncontrolled development.
The proposed Federal legislation was opposed by the Islanders
who feared loss of property rights, Federal interference and lack
of resident involvement in decision-making. Through the efforts of
the All-Island Selectmen's Association and a broad based Citizen's
Consensus Committee, Martha's Vineyard secured special State legislation
establishing its own Commission in lieu of a Federally controlled
body. The MVC is designed to share regional planning and regulatory
functions with the Island towns. Its land use powers are similar
Information for this Chapter was taken from the Martha's Vineyard
WQM Work Plan, 1975, and interviews.
2
August, Robert M. and Lawrence C. Beal, "Landmark Legislation:
The Martha's Vineyard Commission" in A Massachusetts Heritage,
Vol. xiii, No. 1, March, 1976.
MV-2
-------
to those of municipal zoning authorities but are restricted to Districts
of Critical Concern and Developments of Regional Impact. It also functions
as the WQM agency.
B. Water Quality Problem
There are no substantial bodies of surface water on Martha's Vineyard
with the exception of a few salt water ponds. However, some pollution
of groundwater resources has been noted recently in the form of salt
water Intrusion of private wells. Oil spills and high B.O.D. levels
have also caused some problems in the harbors. Although these pollution
problems are not serious at this time, they do exist and are threatening
to increase as island development expands.
In recent years, the very nature of Martha's Vineyard's tourist-oriented
economic activity has threatened the Island's quality of life and
economic base. A study by Metcalf and Eddy Engineers of Boston has
shown that easy access from major population centers of the Northeast -
has resulted in substantial population growth and subsequent development.
Between 1970 and 1975, the year round population increased from 7,250
to 51,250. Similarly, unplanned, inappropriately situated development
has strained the Island's sensitive aquatic environment. Limited drinking
water supplier-, has limited the six towns' ability to provide municipal
services. Conservation, commissions, environmentalists and local elected
officials, therefore, focus their environemntal concern on preservation
and protection of the. Island's water resources.
Most current pollution problems are believed to stem_from diffuse.
nonpoint sources, both agricultural and domestic, (i. e. septic.
system leachate). ^Discharges from the Edgartown .i^rii^pj^v/astewatej:^
treatment plant and j?il spills from commercial and recreational boats
also contribute to harbor problems as noted earlier.
(With the exception of' incomplete USGS maps, spotty bacterial studies
'and well-drilling records from private homeowners, the Island has
been lacking in basic geological and hydrological data. This paucity
of data has caused"'considerable problems and expense in locating water
supplier^ana pr~oE'ec'tTng "aquifers jrrompossible degradation. Several
"areas have already suffered from salt water intrusion of drinking
supplies due to unplanned development and subsequent overdraft. Pro-
tecting the harbors has also been difficult due to an inadequate under-
standing of the area's ecosystem. Collecting basic data is, therefore,
a major concern on the Island.
1
"Districts of Critical Planning Concern are defined as areas which
have an impact on two or more towns. This includes significant
environmental areas, cultural or histor.ic resources, future economic-
development areas, major public investment areas, and natural hazard
areas. Developments of Regional Impact are activities which have a
regional significance. Regional significance is determined by the
nature or magnitude of the development, or its effect on the surrounding
environment."
August and Beal, op cit.
MV-3
-------
Since the WQM grant accounts for the greatest portion of MVC's operating
funds, it holds highest project priority with the Executive Director
and the planning staff. The Commission and the public, on the other
hand,are more concerned with the immediate regulatory actions being
taJcen by the Commission. However, as the WQM project begins to produce
technical outputs and management recommendations the Executive Director
feels that the WQM project will assume greater status with the Com-
mission and the public.
C. Designated Agency
The Martha's Vineyard Commission (MVC) is the officially designated
WQM planning agency for the Island. As described earlier, the MVC
is a unique land use planning and regulatory body with the power to
exercise innovative land management approaches such as land use control
on the rate of growth, design review for aesthetic quality and devel-
opment rights transfer in specially designated areas. The MVC reviews
all large scale development proposals which may effect more than
one Island town or the Island as a whole. It can compel towns to
enforce local ordinances and powers which MVC deems necessary to protect
regional interests.
The Commission is composed of 21 appointed representatives: nine at-
large, six from the individual Island towns, one from the County
Commissioners of Health, four non-resident tax payers and one State
representative appointed by the Governor. The Commission meets
regularly on a weekly basis to carry out its regulatory responsibilities.
Because of land ownership patterns and the protective concern of Islanders
over the character of the Island, citizen interest in MVC activities
is active and sustained. This is particularly true in view of the
threat of Federal intervention should the Island Commission fail.
The Commission's professional staff is the WQM staff. It includes:
o Executive Director, in charge of administration;
o Regulatory Planner responsible for assisting in
determination of critical areas and regional impacts;
o Regional Planner responsible for social and economic
planning;
o Cartographer;
o The WQM Project Manager; and support staff.
The staff functions as technical assistant to the Commission, research-
ing, investigating and reporting on items of special concern to the
MVC. Most' staff members, with the exception of the WQM Project Director,
spend part of their time on other planning-activities being conducted
by the MVC in the areas of housing, transportation, economic development,
coastal zone management and A-95 review. Depending on funding levels
for these programs, the staff may be enlarged in the near future.
MV-4
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A.
Agency Objectives
The objectives of the Martha's Vineyard WQM program as stated in the
project control plan are to:
o
develop land use plans;
o
suggest controls for point and non-point sources
of pollution; and
o
investigate alternative management solutions which
minimize the need for capital intensive treatment
faciliti es.
The plan suggests that the WOM study will take a comprehensive look
at all possible point and nonpoint pollution problems in the area
in order to protect and preserve the Island's water resources. Inter-
views with the planning staff and MVC members indicated, however,
that the most basic goal of the WQM agency is to collect as much scientific
and technical data as possible to support the immediate regulatory
activities of the Commission and the anticipated comprehensive land
use planning efforts of the staff.
Prompted by a_suggestion fromnthe WOM study, the MVC is currently
embarking on a comprehensive planning process which will integrate the
planning activities it is now conducting. The.jre_su.lt._y/i.31 be
a land use, plan which will_.assist_b_oth,the..individual towns and the
•Commission in exercising their respective_regulatory authorities.
The comprehensive planning program will introduce greater interface
among project areas.
The Commission staff anticipate that enhancing credibility of the
MVC will promote areawide cooperation. Local elected officials
expect that the plan will also suggest management techniques in
addition to data inventories.
B. Technical Component
Since Martha's Vineyard has no history of prior water studies, the
first year of the project was devoted to data gathering. Information
relating to groundwater protection originally was considered the
highest priority in view of the stress that the seasonal population
places on the water supply. The technical team began work early .in
the study to determine more precisely the water table profile of the
Island, the recharge areas and actual or potential sources of pollution.
MY- 5
-------
Groundwater soon lost its priority status, however, when the cost
of. sinking test wells became prohibitive. The Project Manager and
the Executive Director then redirected the study's efforts toward
monitoring harbor waters and sampling a limited number of other re-
presentative sites around the Island. This strategy was selected
because such water studies were less expensive and could yield tangible
results within two years. This would enable the public to appreciate
the Island's water quality problems and assist the Commission in re-
viewing development impacts. The groundwater study is continuing now
under a U.S. Geodetic Survey project which developed subsequent to the
start of the WQM program.
Point source problems related to the Edgartown wastewater treatment
facility (currently the only operating facility on the Island) and
other proposed facilities on the Island are being addressed by individual
Island towns. The towns in need of facilities were already engaged in
Step I facilities planning prior to the WQM study. The WOM staff has
had negligible impact on these planning activities with the exception
of the request for an EIS on a local facilities planning project.
C. Management Planning
Given the presence of the MVC and the towns' unwillingness to surrender
any more local autonomy, management planning has been forced to work
within the constraints of existing institutional frameworks. In the
area of nonpoint source pollution, improvements for zoning, with
regard to subdivision controls, health codes and other land use regulations
are being examined. Possible recommendations for consideration include:
o
Explicit reference to water consumption
maximums in land-use classification;
o
Explicit reference to waste character-
istics in land-use classifications;
o
Provision of special facilities and mainte-
nance programs by developers and purchasers;
o
Provision of water table monitoring faci-
lities as part of subdivision control;
o
Special on-lot water management systems
for fragile areas;
o
Controlling or pricing the production of
solid waste;
MY-6
-------
o Licenses or permits for the extraction of
water as well as the introduction of waste;
and
o Inducements to preferred site selections for
various land uses.
The planning staff has already begun work with some local health
officers to revise septic system regulations. They have also suggested
that Island towns consider jointly hiring one septic system inspector
to serve all communities. The staff is also influencing management,
decisions being made through MVC actions on critical planning areas
and developments of regional impact. The present staff policy discourages
structural solutions. Where structural solutions are necessary, however,
the study hopes to encourage a regional approach to problem-solving.
D. Public Involvement Program
The public involvement process outlined in the work plan is geared
toward public education and public contribution to data collection.
The program calls for:
o Press releases on sampling programs, alternative
plans and sampling program results;
o A questionnaire to the general public on desired
future land use patterns and water table levels;
o A reporting system on possible incidences of well
water contamination;
o Workshops with we 1.1 --drillers , harbormasters, shell-
fish wardens and dumpkeepers on the subject of
identifying harbor pollution problems and controls;
and
o An advisory committee composed of local officials
and special interest groups.
Since the program budget did not provide for a public participation
s.taf f...p_erson., responsibility for^this work_ fej.1 to^the__Project Director.
Once the study was underway, however, the Project Director soon found
himself overwhelmed with othe program commitments and the public in-
volvement program began to flounder. With the exception of a few press
releases issued during the course of the program, the press has not been
used extensively. Although workshops with harbormasters and shellfish
wardens were very effective, according to the Project Director, other
planned workshops did not materialize. The Advisory Committee has met
only two or three times.
MV-7
-------
Part of the problem is explained by the fact that Islanders participate
in town meetings, public hearings, MVC meetings, Conservation Commission
meetings, etc. - all of which are actively supported and attended
by residents. Large-scale public participation in yet "another land use
or water study" is unrealistic, according to the Chairperson of the
League of Women Voters. The_MY.C„s_taf f. is unconcerned^ about_ the minimal
_-p.ublic-in.vol.v.emen.t_to_date_since, until now, the study has concentrated
on technical studies. They believe sufficient interest and input will
be obtained when plan alternatives are developed and reported later
"ili'ti^e^ro]*e^t'^" ^During the^next^year, the'"PYoj e c t ~Director"!ntends to
reach decision-makers through slide shows, preliminary reports and
more personal contacts. The Executive Director hopes to increase the
public involvement budget by shifting money away from fringe benefits.
E. State and Federal Involvement
MVC's contact with the State occurs through the Division of Water
Pollution Control (DWPC), the official State liaison for WQM planning.
Each designated agency in Massachusetts entered a contractual arrangement
with DWPC to conduct State review of PCP's and program outputs, facili-
tate coordination among designated agencies and with statewide activ-
ities, and provide technical assistance where needed.-
To date, the State's contact with the Martha's Vineyard study has beer,
very limited due to budget constraints and the desire of the designated
agency to keep State intervention to a minimum. The DWPC reviewed the
Vineyard's PCP and made several comments to the Commission concerning
consultant workload. These recommendations were acted upon but since
the time of the initial review, no further contact has taken place.
Relations with the Regional EPA office are much more cordial and frequent.
EPA personnel are in constant contact with the WQM staff, rendering
technical assistance and even occasional direct staff support, particu-
larly in the preparation of reports.
F. Scheduled Outputs
The original schedule of outputs was prepared by outside consultants
without staff imput. This schedule was found to be too general and
all-encompassing to be of much use to the Vineyard study. The Project
Director, with the help of the MVC and ,EPA Regional Office, revised
the plan to reflect specific Island needs.
The revised PCP schedule of tasks to be completed within the two years
planning, period appears in Exhibit I. This list hasbeen modified some-
what during the planning process in that groundwater study efforts
ceased and the number of representative sample sites was reduced. Also,
the public participation program, management, financial and land use
studies are behind schedule.
MV-8
-------
EXHIBIT I
PROGRAM OUTPUT SCHEDULE
MARTHA'S VINEYARD
ITEM
Project Management Section
DATE
Project Direction Meeting
Alt. plans (preliminary)
Narrowing process by MVC and
Island Selectmen
Revised and refined plans final draft
Consideration and suggestions for
further revision
Final Plan
Public Meetings
Early November 1975
May 31, 197S
June 1 to August
31, 1976
April 30, 1977
April 30 to
June 30, 1976
July 31, 1977
October 15, 1975
June 15, 1976
October 20, 1976
May 1977
Public Participation Section
General Program Description
Press Releases
Sampling Program
Alternative Plans
Sampling Program "Results
Land Use Questionnaire
Water Table Level
Workshops
Well-drillers
Shellfish Wardens - Harbormasters
Dumpkeepers
October 15, 1975
September 5, 1975
April 1976
May 30, 1976
October 31, 1976
November 30, 1975
November 30, 1975
September 11, 1975
January 1976
July ]975
October 13, 1975
June 30, 1976
February 15, 1976
November 18, 1976
My-9
-------
PROGRAM OUTPUT SCHEDULE
-2-
Advisory Committee Meetings
Interviews
Boards of Health
Planning Board
Conservation Commission
Land Use & Environmental Planning
Method for developing land use
maps (preliminary)
Final
NRP Program (anticipated)
Maps, except Recharge and
Water Table Map
Summary of existing land use and
CZM land use maps
Subdivision Map and Summary Report
Land Use Consumption trends discussion
" " " projections
Criteria for developing land use plans
Preliminary Land use plans and controls
Selection of plans for in-depth study
Select recommended plan
MV-10
September 10, 1975
October 1, 1975
October 29, 1975
November 22, 1975
January 7, 1976
April 1976
June 1976
August 1976
October 1976
December 1976
February 1977
April 1977
July 1977
September 1977
September 16, 1975
September 17, 1975
September 23, 1975
September 24, 1975
October 14,. 1975
September 30, 1975
February 28, 197 6
June 30, 1973
October 31, 1975
December 31, 1975
January 31, 1976
January 31, 1976
February 28, 1976
March 15, 1976
May 31, 1976
August 31, 1976
by July 15, 1977
-------
MAP OUTPUT SCHEDULE
maps will be prepared at scale 1" = 2000'
Surficial Geology October 31, 1975
Soils October 31, 1975
Drainage patterns. . . . October 3] , 1975
Erosion October 31, 1975
Recharge Areas preliminary February 28, 1976
Water Table Depth preliminary January 31, 1976
Wetlands and Tidal Zones October 31, 1975
i '
Wildlife October 31, 1975
Potential Non Point Pollution Sources... November 30, 197!;
Coliform Bacterial Surveys December 15, 1975
Zoning October 31, 1975
1972 Potentential Subdivision September 30, 197
1975 Update of Subdivision January 31, 1976
Areas served by Stormsewers December 31, 1975
Areas served by Sanitary Sowers January 15, 1976
1951-1972 Newhousing density map January 31, 197S
Plans of Solid Waste Sites January 31, 1976
Spot Soil Surveys January 31, 1976
Program Sampling Stations December 31, 1975
Potential Areas requiring sediinent-eros.i on
controls..February 28, 1976
Land Use Maps December 3] , 1975
Current update February 28, 1976
MV-11
-------
PROGRAM OUTPUT SCHEDULE
-3-
Ground Water Supply Section
Review available data
Coordinate efforts with USGS
Analyze groundwater hydrology
Water Budget
Water Table Map
Future water use effects
Alt. water supply management plans
Non-Point Source Control
Formulate analysis plan
Well installation
Sampling Program
Estimation of other pollution sources
Estimation of potential non-point sources
Alternative non-point source controls
Preliminary
Final
Point Source Control
Review of existing data
Existing sources
Preliminary report
Final report
Estimation potential point sources
Alternative controls
MV-12
September 30, 1975
December 31,. 1975
November 30, 1975
January 31, 1976
January 31, 1976
February 28, 1976
October 15, 1975
December 31, 1975
November 30, 1975
April 1976
June 1976
August 1976
September 1976
June 30, 1976
August 31, 1976
May 31, 1976
October 31, 1976
March 31, 1976
December 31, 1975
December 31, 1976
August 31, 1976
May 31, 1976
-------
PROGRAM OUTPUT SCHEDULE
-4-
Population & Economic Analysis
P9pulation projections
Economic Analysis
December 31, 1975
February 28, 1976
Legal, Institutional fc Financial
Analysis of existing controls
Alternative controls
Preliminary recommendations
Final recommendations
March 31, 1976
May 31, 3 976
December 31, 1976
Alternative Management Programs
Identify Criteria for Assessing Alternatives
Combine Alternative plans into
Management Programs - Preliminary Report
Final Report
Evaluate Impacts of Alternative Programs
Select Recommended Alternative
Management Program
Final Report
November 30, 1976
July 15, 1976
March 15, 1977
March- 31, 1977
April 30, 1977
July 3], 1977
Source: Martha's Vineyard WQM Work Plan,
MY~ 13
-------
Although the Project Director voiced disappointment in the program's
inability to achieve original expectations, he admitted that the ori-
-ainal.-schedule was far too ambitious given the absence_o.f_w.a.ter_g.uality^
data, limited staff time, and budget any limits. Data gathering activities
¦ will cease this fall to allow time for analysis and formulation of
management alternatives. Data collection and land use planning efforts
that have taken place are viewed as important foundations for continuing
planning efforts.
The Executive Director, citizens and MVC representative interviewed
did not consider the delay in institutional planning a problem since
most Islanders assume that the Commission and the local Boards of
Health and zoning will share responsibility for the proposed management
and regulatory programs. The overall consensus is that existing author-
ities are in a position to carry out any acceptable arrangements without
the need for additional enabling legislation. Financial planning
has received some initial consideration, however, the Executive Director
appears to be purposely awaiting a statement on future funding com-
mitments by EPA before he devises any local financing arrangements.
As for the public involvement program, the Project Director feels
that there is still time to reach the public given their general
awareness bf environmental issues and land use activities of the
M7C. Currently, the Executive Director and the Commission are attempting
to change PCP budget allocations to hire a -public participation staff
¦person using- funds presently earmarked for fringe benefits. Hiring
an additional staff member at this late date, however, was not expected
to make a significant difference.
G. Achievements to Date
Despite the program's shortcomings, the project director indicated
that the study has been a technical success to date in that the
water sampling programs have produced valuable data for ongoing
planning and management. For example, information on slope, runoff
and the potential effect of septic tank leachate on the local shellfish
industry has helped the Commission block (at least temporarily) the
development of 800 units along the banks of a salt marsh. This salt
marsh is critical to the entire scallop fishing industry on the Island.
The WQM*study was also successful in identifying pollution problems
stemming from the Edgartown municipal wastewater treatment plant.
Although the staff has not been allowed to participate officially
in individual town facility planning efforts, it is in a position
to influence these plans, if necessary, through the MVC.
The Project Director also noted that private citizens have been
very helpful in data gathering efforts. Many have contributed by
submitting private well-drilling records thereby lightening the burden
of water table studies. Observation reports by shellfish wardents
and harbormasters also have helped to form an effective informal
monitoring system along the coastal shores.
MV-14
-------
III. , EXPECTATIONS
A. Water Quality
Since the waters on Martha's Vineyard are generally of good-to-excellent
^quality, the pertinent question on the Island is not whether the 1983^_
goals for Clearwater can be ,niet._but.y..^ther,.whether ,they_ can jbe_ maintacined_
in theface of seasonal population stress and rapid development.
All persons interviewed felt that the technical and scientific output
of the WQM study,coupled with the current activities of the MVC/ were
the Island's best chance for maintaining quality water resources.
B. Plan Approval and Implementation
Each person interviewed was asked to evaluate the likelihood of plan
approval at both the local and State levels. Although a few people were
reluctant to make a statement since the nature of the plan is still
unknown, most people were very optimistic about both State and local
reaction to the plan. The Project Director was a notable exception.
He ranked^ the probability of local acceptance very low sj.ncer he _fe.lt
that the towns had not yet made a comfortable adjustment to ^he coneept
of regionalism embodied in the Commission. As such, he felt they
may have trouble in accepting any suggestions for further regionalization
.moves. Most others felt that the towns would have no" choice but to
accept the plans when they are presented. A local elected official
noted there would be no problem if responsibility for plan implementation
rested with existing units of government.
There was a greater consensus of opinion on the issue of State approval.
All felt that the past record of the State's cooperation suggested
no problem for continued approval of Island actions. The Division
of Water Pollution Control spokesman felt that^pproval would be
almost automatic if the plan was geared toward Inland-wide application
and suggested steps for future management action.
Interviewees_ ranked the probability of plan implementation onlyj^lightly
lower than plan approval. Generally, the respondents assumed that
the MVC would be seleo.ted^as^the^primary_iinana.g.emen.t_1,a.g.enc.y_and„that
the Commission ....in- turn would Jiave no problem in carrying out this
-responsibility. " B
All were a little reluctant, however, about the reaction of the local
government to a relative increase in the power of a regional body
vis-a-vis their own powers. Recently, one of the six Island towns
voted on a referendum to disassociate itself from the MVC due to the
town's fear of losing local control in matters of land use. However,
the local elected officials and citizens noted that such problems
could be alleviated if the WQM study team was successful in communicating
the intent and nature of the plan and if the plan allowed for flexibility
on the local level.
MV-15
-------
^ I Several persons also' noted that if Plan implementation required
jj ^substantial, outlay 9^ funds at the l^caj^e?el^full implementation
J be j-n jeopardy. Like most local units of government throughout
[ the country, the towns find it difficult to raise additional revenue.
All respondents perceived the plan in terms of an advisory tool
to assist local units of government and the MVC in its regulatory
actions and future planning efforts. One local elected official
hoped that the plan also would have some added strength to help
encourage locals to take action and enforce recommendations made
by the plan.
The key persons essential to plan implementation were identified
as the town Selectmeen and Boards of Health. The Project Director
has made informal contact with most local decision-makers and the WQM
staff is scheduled to begin what the Project Director terms a "road
show" of slides, maps and preliminary findings to keep the officials
well informed of plan developments. This should make it easier to
secure their approval at the end of the two year period. The Project
Director also hoped to schedule more frequent meetings of the advisory
committee now that concrete study results and alternatives were beginning
to emerge.
The Island's general approach to management planning is to develop
and refine appropriate alternatives (such as dispersed cluster development,
concentrated growth plans, etc.) which the Commission and the towns
find acceptable. Once these alternatives unfold, the staff will work
with the advisory committee and other key local officials and interest
groups to decide whether authority should rest with the individual
towns, the Commission or a new agency. Fiscal and environmental con-
sequences of each alternative will also be delineated so as to help
in the final selection process.
C. Continuing Planning Process
When respondents were asked to select from a range of expectations
about the future of WQM, all indicated their hope for the continuation
a of WQM planning after the initial two year time period. Most indicated,
however, that the future of the planning effort hinged on forthcoming
Federal funds since they felt the Island was not in a position to
support WQM planning_at_its_ current level of operation. Also a few people
"noted that continuation is contingent upon the staff's presentation
of findings in a form that is useful for implementation.
With the exception of the State Division of Water Pollution Control
spokesperson, all respondents felt that the State of Massachusetts
would not assume responsibility and authority for•WQM planning in
the future because the State could never generate the necessary funds.
and, more imx^ortantly, because the locals would never conte-
nance such action.- Because of land ownership patterns, historic concern
MV-16
-------
for retaining the character of the Island and basic distrust of any
"outside interference", proposals for State intervention would meet
with general opposition from the Islanders. The State Liaison, on
the other hand, felt that the State Office of Planning could do a
much more efficient and proficient job of planning if that Office
would take the initiative to do so.
From the perspective of the Project Director, local officials and
citizens, continuing planning will involve extended monitoring of
ground and surface waters so as to augment the Island's data bank.
This information will contribute to the planning and regulatory
activities of the MVC and individual towns. Further development
of institutional means to deal with water quality problems is also
anticipated. Finally, the WQM hopes that ongoing planning will provide
a means for heightening the public's awareness of the limitations of
the Island's ecology and, hopefully, generate their support in preser-
vation efforts.
The State Liaison expressed the opinion that the more difficult and
less pressing issues which could not be settled within the first
two years would be addressed in continuing planning. After presen-
tation of the initial plan to the Governor, the State Liaison feels,
that the Division of Water Pollution Control will polish the report and s
mit it to EPA to meet the requirement for second phase basin plans. He
anticipates the use of Section 106 monies to complete this refinement one
WQM money is gone.
Both the Executive Director and the Project Director estimated continuing
planning will cost approximately $25,000 a year. This estimate is
based on the current salaries of a Planner, Cartographer, and Technical
Assistant. An unknown additional sum of money for technical sampling,
analysis and scientific equipment was also mentioned.
No alternatives for funding continued planning has been officially
considered to date. The Executive Director speculated that two
possible sources might be a recently acquired Coastal Zone Management
grant or an indirect subsidy from developers through required moni-
toring of new wells. The general hope, however, was for continued
funding from the Federal level of government.
D. Relation to Other Water Quality Programs
_TcL.j.g..,.jjQii.~gtujV— has had no effect on facilities planning.
Those towns currently engaged in 201 planning have specifically
banned WQM staff members from speaking at public_meetings in hopes
°f -* "» The Executive Director indicated
that. this_ sjAujat.i on_wil1_ continue_with _regard__to plans started pri.or
to the WQM study but that in_tho future, the WOtTstudy will identify
MV-17
-------
,-t-hp. nppd fnr npw or improved facilities. Actual planning will be left
to the locals but Regional solutions will be promoted. The MVC hopes
to do this by pointing out the economics of the latter approach.
According to the State Liaison, the effect of WQM plans on NPDES permit-
ting will be minimal, especially since the Island has no substantial
industry and currently has only one municipal wastewater treatment
facility. In the opinion of the spokesman, the Massachusetts NPDES
permits were written in haste to meet deadlines. WQM plans around the
State will help correct existing faults and inadequacies.
E. Local Definitions of Success
Most local definitions of success are colored by a general perception
of the WQM study as a scientific, data gathering effort. As such,
_program success on Martha's Vineyard is usually equated with developing
comprehensive^ land use plans and identifying critical areas and devel-
-Jopmentslof_regi onal,impact so as to protect the Island's sensitive
environment whiJLe still promoting compatible economic activity.
Local elected officials,, in particular, stress the need to define imple-
mentable approaches for management and regulatory" actions rather "than
_simply a cataloguing of resources.
Citizens defined success in terms of opening channels of communication
among the six Vineyard communities and initiating cooperative, possibly
regional action on Island-wide concerns. Appointed officials indicated
this would be particularly helpful on water supply and health-related
issues. Many persons felt that the most immediate benefit of the
study would be scientific proof that life on the Island as it presently
exists cannot go on without careful planning.
The Executive Director also defined success in terms of tangible,
money-saving aids to Islanders. These will take the form of free
well-sampling advice that the MVC planning staff would render as part
of their continuous monitoring and surveillance program planned for
the future. In addition, it is anticipated that increased data on
soils and land capability will actually lower the cost of building by
eliminating problems of purchasing land which later is discovered to
be unusable for residential purposes.
MV-18
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM staff view themselves as support staff to the Martha's Vineyard
Commission. All persons involved feel that the study has been geared
to meet the current data needs of the Commission and to assist it in
future regulatory and planning activities. The staff currently attends
MVC hearings to substantiate Commission actions when needed and responds
to specific research requests in addition to carrying out its scheduled
WQM work program. The Executive Director hopes to broaden the scope and
usefulness of the study by making it the fulcrum of a comprehensive plan-
ning project scheduled to begin later this year.
Generally, the staff is quite optimistic about the potential success
of the VJQK program. In their opinion, any amount of data collection
is of help to the Island in view of the area's previous lack of water
studies. WQM Staff feel that they already have succeeded in convincing
at least a few more local elected officials and citizens of the need
to plan ahead for continued water supplies, recreational opportunities
and commercial fishing, to mention but a few areas of concern. Gaining
the trust and respect of local communities should result in a greater
local planning support fole for the staff. The WQM Executive Director
feels that the program is helping to foster cooperation among local
municipalities which traditionally, have remained separate in their
planning and decision-making.
B. Citizens
Two citizens were interviewed at Martha's Vineyard. One is a local
newspaper editor; the other, the chairperson of the League of Women
Voters. Both feel it is their responsibility as Island residents
to keep abreast of any activities associated with the protection of
Island water supply and preservation of its unique natural and cultural
environment. Neither are directly involved with the WQM program but
both closely follow the activities of the MVC.
According to the editor, the general public is interested in and
supports the MVC. The public is unable to participate actively
in the WQM study, however, because of the study's technical orientation
to date. Unaware of the program's shift toward management planning,
he voiced concern that the prograin would not move beyond scientific
data collection and generalities to actual, public discussion of issues
and alternatives.
MV-19
-------
The League of Women Voters representative was^ actually, quite surprised
to hear about the WQM study's potential for shaping future management and .
'decision-making. The League is very actively involved in MVC activities'
but views the WQM study merely as a scientific data gathering project.
As with several other interviewees, the League representative does not
view the lack of public involvement in the WQM study as a problem since
she considers the MVC to be the most likely management agency and feels
that the general public has adequate opportunity to become involved in
its activities.- The League woman feels that, even if more WQM public
meetings were held, they probably would not be attended since many Islanders
already attend two to three public meetings each week.
C. Local Elected Officials
Two local elected officials were interviewed: the Chairperson of
a town Board of Health and the Chairperson of the Board of County
Commissioners. The first local official is a member of the WQM
Advisory Committee and, as such, reviews the project's outputs as
they arise. She is particularly interested in the project because
of her commitment to public health. Her complaint about Jthe WQM .
program is its failure to disseminate information^on a regular basis
to elected officials and advisory bodies. She also feels that the
project's data gathering activities may be insufficiently focused
on pertinent or pressing Island issues. The degree of responsibility
she will feel toward securing funds for- water quality planning and
management will depend upon how relevant the study's findings are
to her concerns for public health in her community.
'The second local official is not a member of the WQM Advisory Committee
but is a representative to the MVC. As a member of the Commission,
she reviews outputs of the study and has close contact with the WQM
planning staff through the advisory role of that group to the Commission.
As a member of the Commission, she would like to see an increased
flow of information from the WOM study which can be used to define
non-buildable areas with regard to water constraints. She recognizes
that the success and validity of the Commission's regulatory decisions
will depend greatly on the justification presented by the WQM study
In her opinion, the greatest problem facing the WQM study is the in-
dividual towns' reluctance to enter into any joint ventures due to
their fear of losing their autonomy. Since the Board of County
Commissioners has no power to collect revenue, she views her responsi-
bility for seeking planning and management funds as only one of moral
I support. Both local officials feel that the WQM program will be a suc-
I cess only if it plays an advisory role and allows for some flexibility
/.of local application.
MV-20
-------
D. Appointed Official
The appointed official interviewed wears several.hats. He is a Com-
missioner to the MVC, a former Selectman, member of the local conser-
vation commission and a very active citizen in his community. As a
member of the Commission, he receives monthly progress reports from
the WQM in addition to periodic special reports in relation to Commission
regulatory actions. Since he feels identification of the natural
capacity of the land is a prerequisite for good land use planning
and regulation, he views the WQM study as one of the most important
programs to have ever been conducted on the Island. Because an existing
agency (i.e., the MVC), is the most likely management agency, he feels
that the plan will be approved and implemented to the benefit of all
Islanders.
E. State Legislators
The State Senator interviewed was not actively aware of the activities
of the WQM study but closely follows the Commission's activities
because of the great controversy over the establishment of a Vineyard
vs. a Federal regulatory body. Although he has consulted with the
WQM staff on site specific environmental concerns, he generally defers
to the legislative Committee on Natural Resources for a stand on policy
issues related to the WQM program. He does not anticipate and in fact
is opposed to seeking new State legislation for implementation of the
WQM plan.
The Senator felt that, although the concept of WQM is laudable,
it does not hold highest priority on the state level given other pressing
social and economic problems facing the State. Since the Vineyard
already has good quality water, he does not feel that WQM will require
large expenditures of money.
F. State Water Quality Personnel
The State spokesman interviewed is the supervisor of the Division
of Water Pollution Control's liaison personnel. In his opinion,
the State's role has been limited throughout the WOM planning period
by a limited budget arrangement with the MVC. Each designated WOM
agency in Massachusetts supports State liaison work by allocating
la portion of its grant to the DWPC. According to several sources,
/the Vineyard's desires to retain as much- local control over the
f WQM program as possible, resulted in a low budget allocation to the
State. As a result, the DWPC staff cannot make frequent site visits
or engage in active program monitoring.
The State spokesman feels that the DWTC should hcive been appointed
the grantee for the Martha's Vineyard study DWPC since it has a larger
staff, more equipment and greater experience in conducting water
studies. He also feels that the DWPC would be a more logical agent
for areawide planning since it has been charged with responsibility
for coordinating areawide plans into a State plan. In his opinion,
MY-21
-------
designated WQM agencies are basically wasting Federal money by re-
treading basin plans in their distrust of the State's findings.
He appears rather pessimistic about scheduled management and insti-
tutional planning. On a more positive note, the State hopes to use
technical data generated through the WQM to update its NPDES permits
MV-22
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
Unlike some areas of the country, Martha's Vineyard has no history of
prior water studies. Given the general absence of hydrological and geo-
logical data and the general hesitancy of the planning staff to make
recommendations without full technical knowledge, the original MVC work
plan proposed massive data collection efforts on the full range of
possible water quality issues on the Island. EPA Region I and the State
recognized that the "shotgun approach" would make it difficult if not
impossible to complete technical studies let alone conduct management
planning within the study's two year time-frame. They suggested, therefore,
that the MVC concentrate its efforts on these areas which the Commission
felt were most significant and which could be handled within the WQM
study period.
As a result, the revised Vineyard work plan is much more concentrated in
scope and balanced between technical and management planning efforts.
This approach should help the agency produce a management plan within two
years from the start of the program and still allow time to develop a
data base for future planning efforts by local planning and zoning
boards.
The planning staff appears to have overcome some of its original fear
of planning without complete data. After a year of almost exclusive
concentration on technical studies, it has somewhat hesitantly brought its
data collection efforts to a close and is nov; embarking on management
planning. Should the MVC continue any of its efforts into data collection
for any reason, however, the agency will be hard-pressed to_comp1ete_a
management plan and/or to secure plan approval by the end of the study.
Efforts at securing plan approval have centered; to date, on decision-makers
rather than on the general public. So far, the Project Director has made
informal contact with most local health officials, selectmen, and the
Commission members. These contacts appear to have stirred their interest
in the study and nurtured a growing trust in the staff's expertise.
As to the general public, the Islanders are already quite sensitive to
the need to protect their groundwater; both to ensure domestic drinking
supplies and to protect the harbors and offshore waters that are so
important to the tourist industry. Given the proliferation of issues
already competing for the general public's interest, the shortage of
staff time and money and the program's emphasis on data gathering over
the past year, the WQM agency was probably correct in selecting the
public involvement strategy it has followed (see following section).
MV-2 3
-------
NPV..fchs*jr. prog,ram Jl^s jsntffred^ its second year, however, the WQM
program must not take the public's awareness for granted as an automatic
app'roval"for 'My'^plan^"r^aHed~"to~watel: 'quality. Islanders are very much
concerned about the ways in which their property rights are affected.
The WQM staff must somehow elicit the emotional support of the public
for the water quality programs it proposes. It must also take steps
to more actively involve the public or their representatives in actual
development and selection of plan alternatives.
The existence of the Vineyard's regional environmental protection and
land use legislation has, and will probably continue to work to the
advantage of the study. With the Martha's Vineyard Commission already
in place, management/institutional planning is greatly simplified and
chances of plan approval and implementation enhanced. Although some
towns are still uneasy about their relationship with the Commission, none
of them have disassociated themselves from it. They are beginning to
understand how the Commission can work to their advantage in protecting
local interests. For example, the Commission recently took action
against a large proposed development project. .The proposed project not
¦only threatened the regional environment but also was inconsistent with
the local community's land use and growth preferences. If the Commission
can continue to set favorable precedents over the next year, approval
and implementation of the WQM plan should result.
Some degree of opposition to increased Island-wide action, however,
should be anticipated. Here, the controversy over Federal intervention
¦under the Island Trust Bill will work to the advantage of the MVC. The
towns realize that if they do not take action themselves, the Federal
or State government will. In short, the political climate is right and
the plan has a good chance of being approved and implemented as the
lesser of two evils.
B. Public Involvement
In the eyes of the Executive Director and the Project Manager, public
involvement is the weakest element in the water quality planning effort.
The media has not been used effectively, public meetings have not been
well attended, and the advisory committee has not met regularly over the
past year. The initial efforts at public education only succeeded in
making some of the public aware of "some kind of water study".
This self-criticism may actually be too harsh since the WQM agency
appears to be judging itself against public involvement standards
suggested in EPA guidance which do not necessarily reflect local conditions
on Martha's Vineyard. The public involvement program proposed in the
work plan seems to have responded to EPA guidav\ce.
MV-24
-------
Once the WQM agency made the decision to concentrate rather exclusively
on technical studies during the first year of planning, however, there
was probably little sense in trying to get the general public involved
through public meetings and committees. Since data was not being
converted into issues interesting to the public, one can argue that there
was nothing to which the public could react.
In some ways, the Martha's Vineyard WQM study does not fit the image of
WQM planning suggested in the national legislation. However, since both
the State and the Federal government .approved the work plan, they must
now access public involvement and other elements of the particular
planning process accordingly. Martha's Vineyard may not have conducted
a formal public involvement program suggested in EPA guidance, but the
program need not be criticized on this count. Local conditions must be
taken into account.
Greater efforts are needed now, however, to keep the public aware of
program developments and to involve them throughout the management
planning phase. The MVC still has a year of planning remaining. Taking
into consideration the WQM agency's proposed actions for reaching the
public, which include more active use of the media,-additional staff,
more frequent public meetings and more active involvement of influential
public interest groups, the program may still have enough time to gain
their support.
C. Current Planning Process
In the course of revising its work plan, the MVC chose to focus its attention
on nonpoint sources of pollution, primarily oil spills, septic systems
and landfill leachate. The Commission considered these to be the most
important factors threatening the quality of the island's water resources.
Due to the absence of basic data, the WQM staff began by concentrating
exclusively on technical studies.
In conducting these studies, the"WQM program management concentrated on a
few representative sites rather than Island-wide sampling and monitoring
studies. With hindsight, this decision appears to have been most efficio:^;,
given the agency's limited budget and the exorbitant cost of scientific
studies. Although the technical studies are not comprehensive in area.
coverage^ Regj.on^I__feeis_t.hat_the jdive_rsity^ and^ number^of sites selected
ensures jsufficient^coverage^ to extrapolate to almost any area on the
Island. The success of a WQM program must be judged on the program goals
and its design and achievements relative to local definitions of needs.
In the case of Martha's Vineyard, the study may prove successful in that
it promises to produce needed data for planning.
MV-25
-------
Management planning is now concentrated on developing programs for
o
Operation and maintenance of septic systems;
o
Control of harbor pollution by marinas;
o
Number and location of landfill sites;
o
Land use through MVC designation of critical areas; and
o
Developments of regional impact.
Emphasis is on areav/ide as opposed to structural solutions. The WQM study is
occurring at a very timely moment in that it has resulted in the request
by the MVC for an EIS on a proposed sewage treatment plant before the
facility plan proceeds any further. Those problem areas which cannot be
covered within the WQM planning period have been left to other water-
related programs, such as 201 and NPDES, to local planning bodies or for
continued planning under the MVC.
Planning appears to be occurring according to the approved workplan schedule.
The staff is continuing in its technical support role to the Commission,
thereby contributing to the letter's visibility and credibility. This is
extremely important in view of the anticipated management role of the MVC.
The staff is also integrating its WQM activities with other planning
programs being currently conducted both within and outside of the agency.
The V70M study has led to a proposal for an Island-wide, comprehensive land
use plan and to a cooperative agreement with a USGS groundwater study
currently taking place at the Vineyard. WQM planning is, therefore,not only
timely but a stepping stone for further planning and implementation programs.
Interim output requirements have been met with the help of the EPA Project
Officer and reports on technical studies are now being distributed to the
Commission members and local elected officials. Making this data and
analysis available to the decision-makers at this time should help spur
their interest in management planning.
D. Continuing Planning Process
The Executive Director and Project Director conceive of continuing planning
in terms of extended scientific and technical studies and continued techni-
cal support to local and regional planning bodies. The staff is sensitive
to the political setting i.n which it is working. In order to affect decisions
made at the local and regional levels, the WQM staff must convince the
'decision-makers of the WQM staff's expertise on water quality. This expertise
will also give validity to MVC regulatory decisions which might result in
court actions.
MY" 2 6
-------
The level of future planning efforts depends on the availability of funds,
but the continuation of planning appears to be certain in the eyes of
the staff since the staff will continue to support the MVC no matter who
provides financing. If the proposal for Island-wide comprehensive planning
is approved and funded, it may outline a more concrete role for continuing
planning.
E. ' Significance of Local Elected Officials' Involvement
|Local elected officials have been only passively involved in the first
year of WQM planning through informal contact with the Project Director.
They are, however, all aware of the activities of the Commission and will
probably take a more vocal role in WQM planning as the political, economic
and social implications of alternative management suggestions begin to
surface. The Island is small enough to allow for active involvement of
all towns and their officials. With the tradition of strong local govern-
ment, little action will pass without their careful attention.
Although local communities generally have supported the MVC in face of the
threatening alternative of Federal or State intervention, some towns
are still uncomfortable with the concept of regionalization and land use
as mentioned earlier. If the WQM staff hopes to p_roniot,e further regionali-
zation or land use control,_it has to convince local officials that such
action is indeed_needed in order to protect and preserve^ the Island's water
resources"! It" would- seem that the besi. way to do this is to involve them
in management planning as soon as possible. How well the agency does,
remains to be seen within the next year.
MV-2"7
-------
AGENCY: MIAMI VALLEY REGIONAL PLANNING COMMISSION (MVRPC)
REGION: V - (Chicago)
GRANT AMOUNT: $1.5 million
GRANT RECEIPT: June 28, 1974
STARTING DATE: January 1, 1975
STATUS AT TIME OF INTERVIEWS: The project is closing in January, 1977. The
WQM staff were preparing for the six-week
review period for screening alternative subplans.
REASON FOR INCLUSION IN THE SAMPLE:
The Dayton are project is one of the
early designates. It serves an urban/
industrial area with reprotedly a "pro-
growth" climate.
MV-1
-------
I. BACKGROUND1
A. Area Description
The Miami Valley Region includes the four counties comprising the Dayton
SMSA (Montgomery, Preble, Miami and Greene Counties) and also Darke County.
According to a 1973 estimate, the heavily urbanized area contains approxi-
mately 899,000 people.
Industries in the area are largely manufacturing, such as rubber, plastics,
electrical machinery, paper and allied products, printing, and publishing.
Agricultural and extractive activities occur in Darke County.
The area's predominant attitude of "pro-growth" was expressed by most in-
terviewees. One citizen noted that the loss of manufacturing employment
in the area contributed to the area's pro-growth climate. Along with the
local interest in economic development, the State is also emphasizing growth.
The WOM project staff expected this State policy to affect their WQM efforts.
B. Water Quality Problem
The Great Miami River has water quality problems in regard to domestic anc
industrial waste discharges in addition to stormwater runoff from urban arid
agricultural areas. The City of Dayton has an inadequate trickling filter
system for wastewater treatment compounded by pretreatrnent deficiencies ir.
the wastes of 21 industries discharging to the municipal system. The
City of Dayton has an ongoing construction grants project for developing
steps toward problem resolution.
Obtaining wastewater treatment for smaller communities is a high priority
in the area, and generally, there was agreement that the WQM effort was
weighted toward municipal wastewater treatment.
According to the MRV'PC Pre-Application for Designation, fourteen communities
have no treatment and seven small communities have combined sewer systems.
The WQM Project Manager noted that local officials saw the WOM planning pro-
cess as the path to the construction grants program or as "another federal
carrot" for areawide planning which succeeds because of the area's need
to meet mandated water quality standards. The County Sanitation Engineer felt
the WOM project's emphasis on facility planning resulted i.n costly upgrading
of facilities while pollution from other sources, including industrial and
nonpoint contributions, continues. Dependency of the area on groundwater
resources has caused attention to groundwater for contamination potential
from septic tanks, inefficient municipal facilities, and leaching of sludge
lagoons, and, to a small extent, to insufficient water supply.
Nonpoint sources of concern are largely urban stormwater and agricultural
1
Information in this Chapter was taken from the Miami Valley Pre-ApplicaLion,
May, 1,•J 974, the Areawide Water Quality Issues in the Miami Valley Region,
June, 1976 and interviews.
MY-2
-------
runoff. Dayton stormwater runoff contributes a large BOD load, and suspended
solids, nitrate, lead and zinc pollution problems. Agricultural runoff is
being examined in Painter's Creek and Spring Creek for a first-cut deter-
mination of the water quality problem according to a rural runoff model.
However, one citizen noted the WQM projects' lack of data on the nonpoint
pollution problem was such that the effort lacked a perspective on the rel-
ative magnitude of the point and nonpoint_source problems^ Generally, J
the WQM Environmental Engineer agreed that the nonpoint source data was
particularly weak.
Protection of scenic rivers to prevent further degradation is an area water
quality concern. The Little Miami River through Greene County is designated
as a Federal Scenic River while the Stillwater River and Greenville Creek in
Montgomery, Miami and Darke Counties are designated State Scenic Rivers.
Although MVRPC is attempting to identify high quality waters, the WQM Environ-
mental Engineer noted that Ohio has no antidegradation policies.
Interviewees generally agreed that water quality is a low priority in the
area. The Chairman of the Water Resources Committee, the body advisory to
the WQM project, believed the area's prevalent attitude was that the WQM
planning effort "will not change anything". In a similar vein, a local cit-
izen felt people were unwilling to pay the costs of cleaner water.
C. Designated Agency
The Miami Valley Regional Planning Commission (MVRPC) is a regional planning
agency serving the five-county area. The service boundaries of the Commis-•
sion are coterminous with the Ohio Planning Region 2A for which MVRPC is des-
ignated the Regional Planning and Development Organization. Membership in
the Commission represents 98 percent of the area and 97 percent of the total
population.
MVRPC has responsibility for the full range of regional planning functions
including HUD 701, rapid transit and DOT transportation planning as well as
housing, criminal justice and health planning activities. The WQM project
is located within the Physical and Economic Resources Division which also
performs planning services in land use, open space, solid waste, economic de-'
velopment, public finance, transportation and local community assistance.
Within the agency, linkages among activities are achieved through ,the use
of a common data base, staff meetings and a coordinating office for citizen
participation. Coordination with the Regional Air Pollution Control Authority-
which included the five-county area and Clarke County - is ongoing regarding
the environmental impact assessment element of the WQM plan.
The MVRPC WQM Project Manager is the Deputy Director of the Physical and
Economic Resources Division. He heads a WQM project team of eight profes-
sionals who provide the framework for directing and coordinating the sub-
contracted work elements.
MV-3
-------
Technical aspects of the plan are being developed under contract to the
Water Conservation Subdistrict of the Miami Conservancy District (MCD).
The Miami Conservancy District is a well-established public agency in the
area concerned with flood control and water quality and headed by a three---
man Board of Directors who are responsible for implementing determinations
of a Conservancy Court of nine judges. In fact, because of its water quality
expertise, MCD had been considered a candidate to direct the WQM project;
the designation eventually fell to MVRPC due to its areawide planning exper-
tise and political base, but with the locally imposed condition that MVRPC
work in partnership with the MCD.
The MCD has received $750,000, or half of the entire grant, for water quality
measurement, assessment and projections, along with the development of tech-
nical alternatives and their impacts.
Management analysis is being conducted by Linton & Company for $81,000 in
close coordination with the MVRPC WQM staff. The WQM project staff has
retained responsibility for population and land use projections as well as
the environmental impact assessment.
The Ohio Environmental Protection Agency (OEPA) is involved in the WQM
project through a contract of $33,000 for coordination of services. Although
not required by the State, MRVPC sought these services as the need for coor-
dination became apparent. Problems have arisen pursuant to State level con-
\flict regarding personal services contracts and, as a result, the State WQM
(staff had been suspended for over one month at the time of the interview.
According to the OEPA Environmental Planning Coordinator, this situation was
'expected to be remedied in the near future.
One of six WQM projects in Ohio, the MRVPC area is contiguous to the tri-State
Cincinnati area WQM project, the Ohio-Kentucky-Indiana Council of Govern-
ments (OKI). OKI is also an early designate under the WQM program. Coor-
dination between the two agencies is achieved by participation of agency rep-
resentatives on their respective governing boards.
MV- 4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The WQM Project Director believed that the planning strategy was shaped by
MVRPC's time schedule. The WQM application had been developed within a
month of initial notification of funding availability. A month later, funding
was received and MVRPC launched into its planning period in July 1974. With
such a quick turnaround time, MVRPC found its "gearing up" time eating into
the planning period. The WQM Project Director believed their necessary haste
caused the work plan to suffer, it was not until December, 197 5 that MVRPC
learned of the six-month extension, but by'then, compromises in the work plan
held already been made.
All interviewees noted that the time constraint caused a considerable push to
completethe process_and consequently believed the product will be less than
what was initially expected. The WQM Project Director indicated that the WQM
""project i~itjally proceded according to the Act's intent but some adjustments
were made in going through the process. The MVRPC Executive Director observed
that the. orginally planned "technical bite was more than they could chew"
within the time and funding allotted. Both the MVRPC Executive Director and
the WQM Project Director described the planning strategy as aimed at what
was 100 percent locally acceptable and implementable rather than what may be
intended by the Act. Both believed that the technical work can be done, al-
though it is "haunted" by limited data, and their greatest concern was the
time required for going through the political process to achieve commitments
to the WQM effort.
I Citizens and an appointed offical commented on the overall WQM planning
strategy. All believed the project was focusing on certain problems and
ignoring others. Two citizens believed the process'was™not" sulfficient 1 y
open to allow a prioritization of water quality problems and rather had
assumed municipal facilities were the appropriate target. One citizen had
hoped for determining the nonpoint source problem impact and an overall assess-
ment of where area resources should be concentrated. The appointed official
also criticized the proiect's emphasis on municipal facilities, as he felt
costly facility improvements unreasonable while other point and nonpoint
sources continued to pollute. He believed political pressure for area econ-
omic development caused the weak analysis of industrial pollution. He also
believed the most overlooked aspect of the WQM effort was the need to address
water quality problems economically. He believed "people must be given choices
with the costs attached" and that the effort lacked a mechanism for determining
cost-equalization. Consequently, he foresaw continued fractionalization of
authority due to local politics and little improvement over past efforts.
As the Regional Comprehensive Plan was adopted just prior to the inception
.of the WQM process, the WQM Project Director believed the 1973 plan's goals
and policies statements were adequate. Ra'ther than repeat the goals process
at the outset of the project, the WQM Project Director believed soliciting
MV-5
-------
goals input could be more meaningful in a latter stage of the process. He
also expected a continual interchange among the area's planning programs
would achieve a "refitting" for overall plan agreement.
B. Technical Component
\ Technical planning has concentrated on municipal point sources and agricultural
nonpoint sources. Urban runoff and other nonpoint sources, e.g. pesticides
(and salts, have received less attention. The WQM staff noted that the sub-
contractor for point source analysis was not examining the industrial loads
as much as it could.
MVRPC's rural runoff model is making a first-cut determination of the agri-
cultural runoff pollutant contribution. Monitoring in rural catchment areas
is proceeding by kinetic stream survey and grab samples. However, the WQM
Environmental Engineer believed the nonpoint source data was particularly
weak and noted that the technical effort had not distinguished a dominance
of point over nonpoint source problems. He noted that budgetary and time
constraints required that more thorough data needs remain unmet and a cut-
'off in the technical analysis was essential to allow staff attention to
"selling the plan".
All of the interveiwees were uncomfortable with the technical planning com-
ponents and noted that MVRPC has had considerable difficulty with the sub-
contractor for technical analysis, which is a well-established public agency
in the area. The WQM Project Director noted that the subcontractor had not
utilized their existing staff expertise but rather had employed entirely new
staff for the WQM effort. Consequently, considerable delays in technical
planning arose because of the subcontractor's "gearing up" time. Further
delays in the entire process resulted from the subcontractor's belated gen-
eration of interim outputs. An appointed official believed the technical
work was poor and that, as technical elements are "handed out in spoonfuls,"
it was difficult for those persons involved in the process to keep a perspec-
tive on the projects. A citizen was critical of the MVRPC for not initially
writing a sufficiently binding contract to hold the subcontracting agency
accountable.
C. Management Planning
As in the technical planning arena, MVRPC was pioneering in management plan-
ning far in advance of Federal guidelines and without any "model" efforts.
MVRPC's particular approach was to examine existing legal, financial and man-
agement capabilities and experience. The management analysis has also iden--
tif ied._25^differenj;^legal^ auj^iorities e ssential for realistic implementation.
Comparing required and existing authority, no single agency possessed all of,
the authority expected to be required. The analysis recommends that the
implementing vehicle may be some cooperative arrangement among local, region-
MV-6
-------
al and State agencies which is optimum in terms of benefits/costs and com-
patibility with proposed technical solutions.1
D. Public Involvement Program
The WQM advisory committee structure is central to the MVRPC's public in-
volvement program. Three bodies have functional responsibilities for re-
viewing the WQM effort. The overall Commission, which governs the areawide
agency, is the final WQM planning authority and has responsiblities for A-95
and WQM project review. The Commission is entirely composed of local elected
officials. Input to Commission review tasks is made by the Water Resources
Committee (WRC), which is the lead WPM advisory body, and the Technical
Advisory Committee (TAC).
The WRC and TAC adopted a specific WQM output review procedure which defined
the interrelationships of the full Commission, WRC and TAC.
o The consultant will submit draft copies of reports to the
MVRPC staff.
o The MVRPC staff will review and comment on the draft reports
and work with the consultant to produce a complete report.
o The MVRPC staff will present the complete report to the
appropriate committee (TAC or WRC) with a staff recommendation.
o In the case of technical reports prepared by the Miami
Conservancy District, the TAC will review each report and
make a recommendation concerning it to the WRC. The WRC will,
if it deems it appropriate, direct that the report be presented
to the full MVRPC for final action.
o In the case of management reports prepared by Linton and
Company, Incorporated, the WRC will review each report.' The
WRC will, if it deems it appropriate, direct that the report
be presented to the full MVRPC for final action. 2
In addition, the WRC regularly reviews facility plans, and water-related pre-
applications for HUD community development grants. The WRC has reviewed an
application to construct a low dam in the Great Miami River.
"'"MVRPC, "208 Water Quality Notes", May, 1976
2
MVRPC, "208 Water Quality Notes", December 1975
MV-7
-------
The WRC voting membership is 51 percent local elected officials and, in
keeping with Commission policy, 25 percent citizens. TAC membership is
primarily open to those having technical expertise, including public of-
ficials and citizens.
Citizen members were selected as part of MVRPC's overall process for appointing
advisory committee members. This process involved soliciting nominations from
25 to 30 environmental and citizen-activist groups in the area. The Commission
subsequently appointed citizen members to the agency's committees, of which
the WRC is one. The WPM citizen coordinators, at one point in the project,
sought to increase citizen members' attendance, and surveyed those citizens
frequently absent from WRC and TAC meetings. If their participation was not
possible, they were replaced by new appointments.
MVRPC utilized a series of activities to disseminate information and involve
the public.
o MVRPC held a series of "Touch Base" meetings with public of-
ficials and organizations. Meetings with such groups as -Jie
Optimist Club, city recreation steering committees and
river priority boards, were set up through public officials.
WRC members often were part of the program which presented the
WQM project and its potential impacts and provided for answering
questions.
o MVRPC also solicited extensive public involvement in developing
the land use sketch plans for input to the water quality an-
alysis. In each community lacking a land use plan, MVRPC staff
held meetings to collect local preferences for growth and land
use patterns. The WQM staff noted 300-400 attended the meet-
ings. Preliminary sketch plans based on community impact were
reviewed by the community.
o In communities already having land use plans, MVRPC met with
local officials to update plans to reflect real or anticipated
growth patterns.
o The WQM staff designed a WQM display for the Dayton Horse Show,
at which they distributed 4,000 brochures. The display was
subsequently exhibited in several locations in the area.
o As part of its environmental education effort, WQM staff made
presentations to high school classes.
o WQM staff conducted a random telephone survey of 250 area
residents.
o The WQM project regularly publishes a monthly newsletter and
disseminates information through brochures and newspapers.
MV-8
-------
o Thirty-second media spots were a recent public awareness effort.
o Summaries and full texts of all WQM reports are placed in pub-
lic depositories, e.g. public libraries, university libraries
and courthouses.
o MVRPC has also publicized a "Clean Rivers" public information
telephone number.
|The WQM Project Director noted that local elected officials plan an impor-
tant role in the WQM process and he felt that the process had been designed
to be responsive to officials. By ongoing contact with officials' adminis-
trative aides, the series of community meetings with local elected officials
and full Commission and WRC involvement in the A-95 and WQM output review
process, the WQM staff believed they had achieved officials' exposure to the
WQM effort. Further, they believed increased officials' involvement had
built upon MVRPC's record of extensive contact with its constituent govern-
ments o However, the MVRPC Executive Director and WQM Project Director felt
that the WQM effort had failed to attain priority, interest, .of,officials.
Rather, both.saw officials primarily interested in. Federal, aid, programs.. and
less receptive to programs demanding local resource commitments without _
commensurate funding support. Moreover, the WQM Project Director believed
areawide planning had historically achieved local support because of Fed-
eral funding and accordingly saw officials participating in the WQM project
because they saw it as a path to gaining construction grants. On the other
hand, the MVRPC Executive Director believed many technical people in-
volved did not expect the Federal government "to be serious" about fol-
lowing through on the Act1s intent.
'Citizens and local officials, including the head of an operating sewer
agency, commented on the involvement of local elected officials. All agreed
that local elected officials had little grasp of the WQM program and were
participating in the effort in anticipation of its ties to future Federal
funding programs. A county official stated that the prevalent attitude
among public officials was that the WQM program "would not change anything".
An appointed official believed officials did not expect Federal backing of
the WQM program, but rather believed the Federal government "was running a
bluff" such that officials were not taking the WQM project seriously. He
also noted that officials were not in frequent attendance at WRC meetings.
Seeing this vein, an official serving on the WRC, believed local officials
have limited time to devote to the WQM project, as they serve voluntarily
in their elected capacities. A citizen noted that officials were not publicly
stating support for regional planning or for the MVRPC.
Overall, the WQM staff experienced satisfaction with the public involvement
MV-9
-------
effort insofar as they had made the best effort possible. They also believed
the successes of their efforts would contribute to improved public participa-
tion in other areas. However, the WQM staff felt they could not assess how
effective their efforts had been and the MVRPC Executive Director stated that
II , ~*-r> ts-i laraiTnnrpfdmiM—»————
^still, for the amount of effort, (he) saw little change in the degree of pub-
lic interest" in the WQM project. On a more positive~no1:eT~the ^MVRPC "
Executive Director believed the data generated by the project has heightened
an awareness of the longer term effort and commitment required to guide growth.
The WQM staff noted the difficulties in achieving citizen participation in
long-range planning. One difficulty was retaining interest in the effort
without immediate tangible outputs to which the public can react. Second,
the number of past or present goals-setting programs in the area, e.g.
Bicentennial Horizons, Model Cities, has contributed to a local emphasis
on tangible results. Third, the delay in technical planning caused outputs
to be available for review only in the latter project stages. These delays
have caused the most important aspect of public review - the alternatives
screening process - to be squeezed into a six-week period. Finally, the MVRPC
Executive Director believed the WQM project was still "unable to answer a
lot of hard questions".
The citizens and public officials interviewed also commented on their involve-
ment in the WQM effort and generally expressed some frustration with program-
' matic and time constraints which affected their involvement as well as some
criticism of MVRPC's public involvement strategy.
%
o All noted the voluminous amounts of material to be reviewed by
the WRC and TAC precluded thorough study, and that the time con-
straint forced them to pass outputs quickly through the review
process in order to meet the completion date.
o Three citizens did not feel that their comments were being in-
corporated into the project and believed the time constraint
largely at fault.
o A county official believed his input was received and used to
the extent that; it fit into the staff's perception of the W2M
program.
o One citizen questioned why the MVRPC citizen coordinators seemed
outside of the planning process and development of the plan.
She was concerned with overall program coordination and com-
munication among the various parties involved in the WQM project.
o Three citizens believed MVRPC should be concentrating more on
building the public as its constituency and accordingly initiate
more outreach efforts.
o One citizen was concerned with how a continuing citizen part-
icipation effort would be structured and wanted more discussion
of this aspect of the process.
MV-10
-------
An Ohio Environmental Protection Agency (OEPA) official also commented on WQM
public participation efforts. He generally believed regional agencies could
not achieve large scale public education and must be heavily supplemented
by massive public relations programs. He_ believed, this._was_. appropriately
EPA's role and that overall public education had been "a huge...void". in_the
WQM program.
E. State and Federal Involvement
As an early designate, MVRPC has not operated under the EPA controls that
later WQM projects have experienced. Initially, MVRPC received little guid-
ance from EPA. The WQM Project Director noted that this was a cost as well
as a benefit of being an early project, insofar as there were no model
projects to follow but also fewer restrictions. He felt that MVRPC could
have used management guidance as.they proceeded to expand functions. At this
point, he did not desire additional EPA guidance and "just wanted to get
through."
The EPA Region V Project Officer has a good relationship with MVRPC. She
attends WQAC meetings and makes frequent contacts by telephone. She also
serves as the project officer for the contiguous WQM project in the Cincin-
nati area which fosters coordination between the projects.
The State of Ohio became involved in the project about one year after the
MVRPC WQM effort was underway. MV£PC sought State involvement in July, 197 5
following EPA funding authorization for State participation. EPA increased
MVRPC's WQM planning grant to cover the $33,000 contract with Ohio for
coordinative services. The Ohio Environmental Protection Agency (OEPA) pro-
vided a liaison person to MVRPC. However, at the time of the interview, the
OEPA Liaison had been temporarily suspended due to legal problems with State
personal services contracts, but was expected to be reinstated in the near
future.
The WQM Project Director indicated that the State has been minimally involved
in their efforts. He believed State involvement was limited by current State
/ administration policies of attracting economic development. This policy
rendered WQM planning a low state priority. He felt State policy affected
WQM planning insofar as the State encouraged municipal facilities plans to
provide excess capacity to &llow for growth potential.
Although the OEPA Environmental Planning Coordinator believed that two early
designates, MVRPC and the Cincinnati area WQM project, had the greatest
likelihood of success, he was dissatisfied with the limited State participation
in the early designated WQM programs. Primarily, he felt that EPA, in the
program's first year, provided no vehicle for State involvement and has felt
very excluded from all designated WQM efforts in Ohio. He did not feel that
State input was being used by the agencies, although the agencies were re-
sponsive to State comments. He also noted that EPA Region V Project Officers
for these early agencies do not make an effort to keep OEPA informed. He also
MY" 11
-------
felt that there was animosity between State and EPA levels of involvement such
that the designated WQM agencies were uncertain as to "whom they have to
please". OEPA has just recently received funds for State WQM planning. Ohio
has completed no basin plans, but has determined wasteload allocations for
NPDES purposes. The OEPA Environmental Planning Coordinator did not expect
the State to assume the designated WQM agency's functions. Rather, he ex-
pected that State-local shared WOM responsibilites would enable a review of
construction grant and NPDES programs for compatibility with locally estab-
lished priorities. He did not see OEPA1s role to include recommending leg-
islation.
F. Scheduled Outputs
MVRPC has scheduled outputs in three phases:
o Background information,'
o Technical/Management alternatives and their impact assessments,*
and
o A final document describing the selected alternative.
The second phase of the project is just being completed and MVRPC's
full Commission review is slated for October. Project completion is
expected by January 30, ]977.
The WQM Project Director noted that the technical planning had been ser-
iously delayed. The subcontracting agency for technical planning under-
took their work tasks with a new staff rather than using their existing
expertise and the start-up of their efforts was fully one year behind
schedule. The WQM Project Director also felt the subcontractor had not
understood the overall planning process which requires their continual re-
porting for review purposes. Consequently, the MV1JPC had considerable dif-
ficulty in eliciting interim technical reports from the subcontractor.
The delays have caused a heavy output review schedule for the advisory committees
in order to meet the required project completion date. Several WRC committee
members had expressed the need for more review time, but recognized that pro-
ject funding carried the project only to the end of January.
G. Achievements to Date
MVRPC has produced several background reports such as population and land
use projections and environmental baseline information. The draft population
and land use projections were completed in June, J 976 and approved by the
Water Resources Committee.
MV-12
-------
The WQM Project Director believed the population and land use effort had been
a particular achievement from the aspect of putting all area planning efforts
on a similar base of reasonable scale, and of achieving considerable public
input as to local preferences for growth and land use. The population and
land use input to the WQM effort was based on information collected by the
MVRPC and extensive community participation. For communities with previously
adopted land use plans, MVRPC sought to update plans to reflect real or
anticipated growth patterns and achieved this through discussions with
local elected officials. For communities without previous land use plans,
MVRPC held 18 community meetings to seek citizen and public official in-
put regarding future growth. This information was incorporated into land
use sketch plans. All communities received prelimiary land use plans
in the year 2000 for review and further input. Preliminary plans were also
distributed in local newspapers. Local observations were then incorporated
into the land use patterns and delineation of service area boundaries.
In addition, the total management package has been completed and approved
by the Water Resources Committee. The eight reports will be released sim-
ultaneously as a full text and as summaries for lay distribution.
o A review of federal programs impacting regional water quality
management;1
o A review of state agencies impacting regional water quality
management;
o A review of regional agencies impacting regional water quality
management;
o A review of local agencies impacting regional water quality
management,*
o Experience and potential for regional water quality management,-
o Financial critical factors analysis;
o Legal critical factors analysis;
o A review of critical factors impacting regional water quality
management.
Eleven technical reports have been produced by the subcontractor for the
technical planning component and are being reviewed by the advisory committees.
Summaries of these reports will also be available for lay distribution.
o Existing water Quality Data,
o Climatic Data,
"^EPA Headquarters has distributed this report to all State and designated
WQM programs.
MY-13
-------
o 1975 Point Source Waste Discharge Loads and Stream
Data;
o Inventory and Evaluation of Nonpoint and Intermittent Point
Source Controls;'
o Water Resources and Critical Dry Weather Criteria/
o Design of Sampling Programs, Data and Analysis for Nonpoint
and Intermittent Source Loadings;
o Land Characteristics, Stream and Basin Parameters;
o Inventory and Evaluation of Point Source Structural
and Nonstructural Controls;
o Application of Point Source Wastewater Controls;'
o Application of Nonpoint and Intermittent Point Source
Wastewater Controls; and
o Water Quality Models.
My-14
-------
III. EXPECTATIONS
A. Water Quality
Most interviewees expected some improvement in water quality, although an
appointed official was uncertain if the WQM effort would have any effect.
The WQM Project Director stated that the WQM process would reveal the best
way for achieving improvement, but actual improvement depends on "the
will and the push" to take necessary actions. An elected official and two
citizens expected improvement primarily through upgrading municipal facilities
and generally agreed that the NPDES and construction grants programs were al-
ready achieving point source improvement. There were mixed expectations
regarding nonpoint source improvement. An appointed official and two citizens
did not expect the WQM project to impact the nonpoint source problem. On the
other hand, two elected officials expected nonpoint source improvements which
one official believed would be achieved through educational efforts in con-
cert with SCS and Farm Bureau functions.
The OEPA Environmental Planning Coordinator felt improvement would be achieved
through the review of construction grants and NPDES permits for compatibility
with locally established priorities and he expected such review would in-
stitute a better processing mechanism available to both State and local effort
No one believed the 1983 goals would be achieved and most questioned whether
the goals of fishable, swimmable waters were reasonable or realistic. The
MVRPC Executive Director believed water quality goals would have to vary by
use of the water body. He also postulated that reliance on local funding
resources for WQM efforts precluded meeting the 1983 goals. He also was un-
certain whether the State weu±tT"Se willing to support WQM plans aimed at
achieving the goals insofar as such plans may be incompatible with current
State economic development policy.
B. Plan Approval and Implementation
Interviewees were asked to state their expectations for plan approval. All
believed some form of a plan would be adopted by the Commission. The WQM
Project Director indicated that the entire design of the WQM planning process
was aimed at producing a locally approvable plan, although he did expect some
towns to accept the plan less readily. He noted that the major "selling"
point of the WQM plan was its emergence from a locally-based process and the
MVRPC Executive Director added that the plan's flexibility was another im-
portant factor in gaining local approval. Although a local elected offical
actively serving on the WRC believed a locally created plan would be acceptabl
he stated that most officials felt the plan had yet to be an integrated whole
and, while parts of the plan received seem "innocent separately", the delin-
eation of management responsibilities may be controversial. Two citizens
agreed that local versus regional management was sufficiently controversial
MV-15
-------
to cause plan recommendations to reflect the preferred local control. One
citizen also expected the plan to skirt politically sensitive land use elements.
Several interviewees also commented on local officials' involvement in the
WQM process which may affect plan approval. An appointed official ex-
pected some officals to be "surprised at the time of (plan) adoption",
because, to date, they have not actively participated in the process or
taken the WQM effort seriously. He also expected the area's largest mun-
icipality may be reticent in approving the plan. A citizen believed of-
ficials would assess the plan's acceptability in terms of its ties to
funding eligibility for the construction grants program. Another citizen
expected some difficulties for plan approval to arise from a turnover in
elected officials following the November, 1976 county elections. As the
plan approval process is to occur on the heels of the election, continuity
in local support may be affected.
Most interviewees expected State approval of the plan. The WQM Project
Director felt ongoing State participation assured a high probability of
State approval. The Ohio Environmental Protection Agency (OEPA) official
also expected State approval to be no problem.
To the WQM Project Dirctor and MVRPC Executive Director, plan approval and
plan implementation were somewhat inseparable in the WQM planning strategy.
They underscored MVRPC's explicit directive to local officials to approve
plan components only if they expect to locally implement them. Accordingly,
the WQM Project Director and MVRPC Director expected to solidify political
support for incremental and realistic steps toward water quality problem
resolution rather than for a politically unrealistic, comprehensive effort.
In addition, the MVRPC Executive Director stated that MVRPC did not intend
to commit political suicide by offering a locally unacceptable plan.
Other interviewees were also asked to speculate on the outlook for plan
implementation. Most, including the WQM Project Director, expected EPA
sanctions to play a major role in the extent of point source problem cor-
rection, particularly ties between the WQM plan and the construction grants
program. In this vein, a local elected official believed implementation would
occur to the extent it is mandated. He believed opposition to increased sew-
erage rates for upgraded facilities would be subordinated only as local gov-
ernments are "forced" to improve them. However, this official as well as
a head of an operating agency believed the prevalent attitudes among local
officials were that the Federal government was "running a bluff" and the WQM
program would not be backed with enforcement authority. Consequently, he felt
that it "would not change anything."
Most interviewees were uncertain what nonpoint source controls would be
locally undertaken, but generally did not expect the WQM plan to have a
significant impact on the nonpoint source problem. The MVRPC Executive
Director, _the WQM Project Director and the Environmental Engineer believed
MY-16
-------
the weakness of the nonpoint source data may not sufficiently demonstrate
the nonpoint source problem to their_loc.al constituency. The MVRPC Exec-
utive Director added that the uncertainty surrounding future 701 comprehen-
sive planning funds complicated their ability to "see" the WQM program in
light of a compatible local planning process. Commenting on MVRPC's over-
all capacity to interrelate land use and water quality planning was one
citizen who saw MVRPC currently terminating its WQM staff such that the
necessary expertise was being lost. She also observed that the WQM program
provided no incentive for local governments to implement nonpoint source
measures, but, nevertheless, MVRPC should have made an effort to work with
agricultural and construction industry interests. A local elected official
did not expect local governments to readily accept water qulaity as an im-
portant factor in land use decision making although he believed the WQM plan
may have some informational impact.
Overall implementation concerns focused on the predominant attitude of
retaining local control. One local elected official favored regional water
quality actions but another official summarized local officials' attitudes
toward WQM as "wanting a plan with the least amount of interference in
local decision making" and consequently officials were "suspicious" of re-
gional planning. With this latter view, three citizens agreed triere was "no
great publicly stated support for MVRPC" as local officials perceived re-
gional planning to threaten the erosion of local authority.
I Two additional factors cited by several interviewers as limiting plan
implementation were costs associated with water quality improvement and pro-
growth attitudes. The MVRPC Executive Director expected Federal funding
shortfalls would restrict plan implementation and, in addition, doubted that
' local government would commit local resources to a long range plan without
knowledge of their future bonding capacities. Three citizens believed devel-
opment pressures would work against plan implementation, particularly as
State policy explicitly encouraged economic development.
A key component of implementation is the management structure. According
to all interviewees, the designation of management agencies was a politically
sensitive issue. The WQM Project Director expected management to consist
of intergovernmental cooperation in assuming different roles. He believed
no new agencies were feasible in the short term, because the new experience
of integrating the many processes involved in WQM precluded the practicality
of simultaneously shifting the area's political balance. However, most
of the non-staff interviewees believed the MVRPC and the Miami Conservancy
District (MCD) were vying for lead management responsibility. Several in-
terviewees noted the history of the MVRPC-MCD relationships in WQM. Both
had sought designation as the WQM planning agency. MVRPC met EPA guidelines
for designation although lacking the water quality/technical expertise of the
MCD. Provided that MVRPC and MCD share the WQM planning functions, local
MV-17
-------
governments agreed to MVRPC's lead responsibility. Hence, the MCD was to
provide the technical, planning component. Although most non-staff inter-
viewees maintained the two agencies were seeking management agency designation,
an appointed official heading the TAC expected no umbrella agency would em-
erge. Rather, he believed management functions would possibly be divided
among the MCD, City of Dayton, and Montgomery County and, if funds are avail-
able, continued planning may fall to MVRPC. A local elected official opposed
management by a regional planning agency, especially if the agency had veto
power over local decision-making.
The WQM Project Director commented on existing and needed authority for plan
implementation. He stated that the plan will be predicated on existing local
authority and agreed with a local elected official that implementation can-
not depend on new legislation. Hov/ever, he believed that MVRPC could begin
legislative activity if the Commission so moved. In any event, he felt a
locally adopted WQM policy must precede legislative considerations.
The OEPA Environmental Planning Coordinator expected a need for extensive
legislation although he had not yet examined what authority currently exists.
He did not expect any legislative activity for at least one year and did not
view recommending legislation as an appropriate State role. Contrary to
the OEPA1s position were two state legislators' view that the State should
be working toward needed legislation.
The two Ohio State Legislators interviewed have had no involvement with
or awareness of the WQM program. Their perceptions of various WQM roles
and responsibilities in regard to legislation is given in Section IVE.
C. Continuing Planning Process
Interviewees expectations for continuation of the WQM planning process after
the initial funding period were closely linked to three factors: extent of
llocal support, Federal funding, and EPA requirements. Most interviewees were
(skeptical that local support exists for continued planning due to the low
priority of water quality planning and dubious support of areawide planning
efforts. The WQM Project Director stated that "the WQM program is naive1
and "pretends that a commitment to broaascale areawide planning exsists."
A citizen and elected official noted that MVRPC's support is under continued
threat, as certain member governments have intermittently threatened to with-
draw from the regional commission. Their actions were noted to be predicated
by conflicts surrounding regional versus local decision-making. In this light,
an appointed official did not expect continuation of WQM planning and an elected
official believed continuation would be locally supported to the extent that
their support is mandated. A citizen also noted that obtaining local support
was complicated by the upcoming county elections which affect a significant
portion of the officials serving on the Commission and WRC.
MV-18
-------
All interviewees expected continuing planning to depend on substantial Federal
(funding support, with perhaps some local and State contribution. An elected
official believed local contributions would be commensurate with the local
share required for eligibility for construction grants programs. The WQM
Project Director indicated that no local funding sources had been committed
to continuing planning but postulated several possible sources. These included a
fee structure attached to the construction grants program and contracted
services.
The OEPA Environmental Planning Coordinator saw the WQM program as
appropriately regional and not as a State function. However, the State of
Ohio will share responsibilities with designated WQM agencies in the State's
continuing planning process which the designated agencies had a-major role in
generating. Issues of a continuing nature were water quality standards,
wasteload allocations, and plan update among others not yet identified. The
focus of the continuing process, in his view, depended on the success of
the WQM effort.
The WQM Project Director and MVRPC Executive Director outlined several is-
sues the continuing planning effort might address, although they expected
the design of the process to reflect the available funding support. These are:
o Update plan,'
o Integrate further the construction grants programs currently
underway ,*
o Verify results of agricultural and urban stormwater runoff
portions of technical planning;
o Define annual financial responsibilities,' and
o Develop process whereby growth can be evaluated through impact
assessment and ameliorate potential conflicts with other policies,
e.g. housing.
The MVRPC Executive Director added that a reduction or elimination of 701
comprehensive planning funds would affect the scope of the continuing plan-
ning process, e.g. data.
The WQM Project Director estimated that a minimum of $150,000 was necessary to
continue the WQM planning function and that the ultimate cost would depend
upon the continuing planning roles assumed at the local, state, and Federal
levels. Both the WQM Project Director and the MVRPC Executive Director were
concerned with continuity of the planning process and believed MVRPC would,
as a minimum^require a token force for transition purposes.
MV-19
-------
D.
Relation to Other Water Quality Programs
The WQM Project Director outlined the MVRPC's approach to working simul-
taneously with ongoing construction grants programs in the area and with the
WQM planning project. The process combines A-95 review and WQM planning
responsibilities. The WQM staff is involved in every step of reviewing
and approving ongoing construction grants projects, which involves pro-
viding information, suggesting alternatives, and assessing the construction
projects in terms of their compatibility with the emerging areawide WQM
plan. Following staff review, the water resources committee (WRC) studies
the construction project and after full Commission review and formal ap-
proval, the construction project becomes an adopted portion of the regional
plan. The WQM Project Director believed that the process had a significant
impact on meshing the ongoing construction grant and WQM projects such that
no ongoing construction grant projects had precluded WQM alternatives. The
MVRPC Executive Director added that he hoped this process would be con-
sistently supported by State and Federal actions.
Other local interviewees generally expected the WQM effort to impact the
construction grants program. However, the head of an operating facility
said that he was discouraged with the interrelationship of the two programs
and was uncertain that the programs could effectively mesh.
Regarding the NPDES permit program, the WQM Project Director hoped future
permits would reflect any modifications indicated by the study's findings.
Specifically, he expected findings regarding the nonpoint source problem
may evoke pressure to modify the wasteload allocations. Other interviewees
either expected some general impact of the WQM project on the NPDES program
or deferred the matter to a State concern.
The OEPA Environmental Planning Coordinator stated that most WQM efforts
in Ohio were out of phase with issuing the_jnext__round of NPDES permits and
generally ^did_not_expect timely input from the WQM agencies, although he
felt that WQM would institute a processing mechanism for reviewing the com-
patibility of both construction grant and NPDES permit programs with locally
established priorities.
E. Local Definition of Success
Most interviewees defined a success for the WQM effort in terms of a plan/
process which is useful to local decision-making and enhances public under-
standing of the water quality problem.
o The WQM Project Director emphasized the development of a real-
istic management structure.
MY- 2 0
-------
o The MVRPC Executive Director believed that the WQM project
would be successful if there is sufficient continuity, e.g.,
staff retention, following plan completion to take steps
toward plan implementation. He also believed a successful
outcome would be EPA-State-local agreement on the WQM plan
and their alliance in future WQM steps.
o One elected official saw success as a plan that achieves the
WQM program goals, is acceptable to local and regional inter-
ests, and functions within the framework of existing statutes.
Another official saw a success simply as a well thought out
plan.
o An appointed official considered success in the form of an
understandable, reasonable plan used as a guide by affected
agencies.
o One citizen viewed a successful WQM effort as a comprehensive
assessment of the water quality problem, including water supply
and development of a process by which local decision makers are
informed of the impacts of potential development. She hoped
the plan would establish parameters for various types of dev-
elopment and indicate the best manner for addressing develop-
ment impacts.
o Two citizens defined success in terms of increased awareness
of the need for improved water quality and the associated costs.
o The OEPA Environmental Planning Coordinator defined a success
as aggreement on a plan/process, acceptance by the Governor
and any substantial portion of the plan which can be implemented
within six months.
Interviewees also cited benefits generated by the WQM planning project.
These generally fell into the following four categories:
o Greater intergovernmental cooperation/
o Progress in new technical areas, e.g., nonpoint sources and land
capability analysis, which are tools for better local planning
for growth;
o Increased public and political awareness of the water quality
problem through efforts to involve citizens and local elected
officials;
o Better regional planning through becoming articulate with
local officials in the water quality arena and developing
a process for public participation.
MV-21
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM Project Director and the MVRPC Executive Director agreed that the
WQM planning strategy was formulated to produce a 100 percent locally accept-
able and implementable plan. Accordingly, they viewed MVRPC's role as serving
the interests of local governments, although the WQM effort may fall short
of the Act's intent. They both noted that the major "selling" point of the
areawide WQM effort was its locally-based, flexible process. They expected
to solidify political support for incremental and realistic steps toward
water quality problem resolution rather than for a politically unrealistic,
comprehensive effort. The MVRPC Executive Director added that MVRPC did
not intend to "commit political suicide" by proferring a locally unacceptable
plan.
Both noted that the MVRPC staff is advisory to the Commission which has final
authority in A-95 review as well as WQM planning review. He cited the
Commission's role of reviewing all ongoing construction grants programs as
exemplary of the officials' involvement in water quality decision-making
within the emerging areawide WQM context. Further, the .WQM Project
Director saw his staff's role as coordinating planning activities in the
area and attempting to "sensitize all decision-making processes to water
quality issues."
The MVRPC Executive Director and the WQM Project Director expected MVRPC
to provide further coordinative services in the continuing planning process,
although the scope of the continued WQM planning effort would be defined by
the available funding. At a minimum, they were concerned that MVRPC should
retain a transitional staff following the project's completion such that
continuity is not lost.
A WQM staff member was also concerned with continuity. He noted that,
with time and funding running short, various members of the WQM planning
staff were being released and others were continually uncertain of their
position's longevity. Consequently, he felt staff morale was suffering
just at the plan review and approval stage when staff commitment to the
project was most important.
B. Citizens
The three citizens interviewed were active on the WQM advisory committees
v/ith two serving on the Water Resources Committee (WRC) and one on the
Technical Advisory Committee (TAG). As noted in Section lid, all three
citizens generally expressed some frustration with programmatic and time
constraints which affected their involvement. Due to project output delays
MY-2 2
-------
and the resulting condensed report review period, they did not feel that
their comments were being incorporated into the WQM project. They also
noted that the massive amounts of technically complex material to be re-
viewed by the TAC and WRC precluded adequate, study and the approaching
completion date forced the committees to quickly adopt reprots with only
cursory review.
The three citizens also were concerned with the overall public involvement
program. They generally agreed that MVRPC should be concentrating on reaching
the public to build a WQM constituency. One citizen questioned the role of
the WQM citizen coordinators which was seemingly outside of the process of
developing the plan and therefore was concerned with the overall effective-
ness of communication among the parties involved in the WQM project. She
also noted a lack of attention to a continuing citizen participation effort
following the plan's completion.
They-also commented on the involvement of local elected officials. Each
of the three citizens believed that public officials yet had little grasp of
the WQM effort and were participating only in anticipation of the future
WQM program ties to the construction grants program. They also noted that
the officials had not evinced support of regional planning efforts and were
"suspicious" that the regional project threatened an erosion of local author-
ity. Consequently, they expressed skepticism regarding the likelihood of
local implementation of a significant portion of the plan.
Tied to their view of public officials as MVRPC's primary WQM planning con-
stituents, was the belief that the WOM planning strategy reflected the most
politically expedient route to gaining officials support. Accordingly,
they observed the plan emphasizing municipal facilities and avoiding the
potentially controversial nonpoint source problem which implies land use
controls. The area's pro-growth attitudes were cited as the crux of the
controversy. In addition to the limited attention to the nonpoint source
problem, all three citizens were critical of the overall quality of the
technical planning components.
C. Local Elected Officials
Two local elected officials, a county engineer and a mayor, were interviewed.
Both serve on the Water Resources Committee and felt that their views had been
considered to some extent, although one county official believed his input
was used to the extent that it "fit the staff's perception" of the WQM pro-
gram. The county official also commented that local elected officals
were participating in the WQM effort only because of its expected future ties
to the construction grants program.
The two officials were involved in the Committee's report review process.
They both believed the condensed time for review may affect the quality of
the final plan. The county official added that the plan's components, as
they are reviewed separately, appear "innocent" and he had reservations re-
MV-2 3
-------
garding the acceptability of the integrated plan, particularly the management
component. Although the Mayor, who presided over a growing bedroom community
outside Dayton, favored regionalism, the county official strongly believed
the areawide attitude advocated local control such that the WQM plan should
advise local governments and proffer the least amount of interference in
local decision-making. However, the county official also foresaw local im-
plementation of the plan to occur only to the extent that it is mandated.
Although he expected the plan may have an informational impact on land use
decision-making, he did not believe public officials would readily accept
water quality as an important factor in land use decisions.
D. Appointed Official
The appointed offical interviewed was a county sanitary engineer who served
as chairman of the Technical Advisory Committee and member of the Water
Resources Committee (WRC). In his role on the advisory committees, he
has had considerable report review resonsibilities and, in his professional
capacity of heading a county operating agency, he expected to assume some
management responsibilities as part of an intergovernmental cooperative
arrangement.
Overall, he was critical of the technical planning components in terms of
quality and focus, and the process by which the advisory committees review
technical reports. He believed that "obvious problems" were being over-
looked, particularly industrial pretreatment inadequacies, which he felt
were due to the political pressure for economic developments in the area.
He felt the result was an overemphasis on municipal waste, which would
be upgraded at great cost while other pollutant sources continued unchecked.
He also emphasized the fact that the WQM project lacked a mechanism for as-
sessing equalized costs, and that the WQM project "will not tell us the cost"
associated with alternatives. In regard to reviewing technical reports, he
stated they were "handed out in spoonfuls" such that the committees could not
maintain a perspective on the WQM project. With the heaviest review demands
at the end of the process, he faulted the time constraints of the WQM pronect
with forcing the advisory committees to quickly approve reports so as not
to cause further delay in light of the rapidly approaching deadline for com-
pletion.
He observed that the local officials on the WRC were not attending, nor seem-
ingly taking, the WQM effort seriously. He expected "a point of realization"
when the time for WRC and Commission adoption arrives.
E. State Legislators
One of the two Ohio State legislators interviewed was a State Senator and
Majority Whip who also served on the Senate Energy and Environment Committee.
He has had no involvement with the WQM program and has-not been contacted by
any WQM agencies. He felt that his awareness of the program was limited and
My-2 4
-------
noted further that the legislature is generally not aware of the WQM pro-
gram or its objectives. He strongly recommended that attention of legis-
lators might be gained if the program were presented to them in a form re-
tainable for future use and which highlights the fact that related legis-
lation may be required. He felt that water quality was not a priority issue
in the legislature. He generally saw legislative and public support for the
protection of industry, although he saw support for upgrading and regional-
izing municipal systems. Recent legislative land use study committee hearings
were noted to have received considerable testimony opposed to land use controls.
A freshman representative to the Ohio House of Representatives also had not
been contacted by any WQM agencies and had no awareness of the WQM program.
She felt it was the responsibility o~f the WQM agencies to keep legislators
informed. She felt it was OEPA's responsibility to suggest any needed
water quality legislation, but believed present State administration's
priorities for attracting jobs and industrial development may conflict
with water quality objectives.
F. State Water Quality Personnel
The Environmental Planning Coordinator was dissatisfied with OEPA's limited
participation in MVRPC's efforts which he felt was caused by EPA delay in
providing a vehicle for state involvement. Although MVRPC was responsive to
State comments, he did not feel that State input was bing used. He also felt
that there was animosity between State and EPA involvement, such that the
designated WQM agencies were uncertain as to "whom they have to please."
Although Ohio is just beginning State WQM planning, the OEPA Environmental
Planning Coordinator expected continuing planning to be a State-local shared
responsibility. He viewed the designated WQM plan, based on locally estab-
lished priorities, to provide input to the construction grant arid NPDES pro-
grams. He did not see OEPA's role to include making legislative recommend-
ations nor to assuming designated WQM functions. He voiced several major
criticisms of the WQM process. He felt that EPA has not worked toward
massive public education and participation which he felt was essential given
the low level of awareness of the water quality problem and the limited ab-
ility of the agencies to reach the general public. He also felt that the
relationship between water quality and water supply had not been emphasized
and noted that State planning for nondesignated areas will encourage the
incorporation of related water supply and solid waste elements.
My-2 5
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
Speculation regarding the outlook for plan completion is couched in terms
of the rapidly approaching January 30, 1977 termination date. Considerable
delays in producing technical planning outputs (no ted to^be__caused by the
subcontractor's "gearing up" time and recalcitrant generation of interim
reports)have caused a squeeze in the final planning stages. This is "felt
.particularly in the output review procjss^involving^^^the advisory committees.
Because of time constraints, MVRPC's schedule for advisory committee screening
of alternative plans prior to public hearings does not allow for any flex-
ibility. Should the advisory committees balk at immediate endorsement of
the alternatives, MVRPC may experience an untimely setback in the extensive
public hearings already scheduled for November and December. Any setbacks
in the public review of alternatives would render a pessimistic outlook for
a final plan approval process in January.
For this reason, an MVRPC staff member noted that MVRPC and concerned
State officials were meeting to consider the feasibility of additional
funding. A six-month funding period beyond the original January ter-
mination date would enable MVRPC to have the flexibility necessary for
a throught and responsive review process. In this event,, if the
advisory committee and public comment did require alternatives and final
plans revisions, MVRPC would not be faced with the dilemma of releasing
its V3QM staff due to funding shortfalls just as their expertise was most
essential.
In light of the above, the final plan approval process over the six-month
extension may allay some of the concerns voiced by the public officials and
citizens serving on the advisory committees. To date, they had felt the con-
densed process for reviewing the massive amounts of technically complex material
resulted in only cursory study and hasty approval of the reports to expe-
dite the plan's completion within the funding period. Further, as two public
officials noted, up to this time the Committee's exposure to the plan com-
ponents has been piecemeal and has lacked a perspective of the WQM project.
Consequently, a totally integr a ted _ p1 an _ w ilJL_ likely rcqu i r e__ thorxd ugh^jstu dy
and discussion prior to P3an approval^. The lengthier review period will
allow a fully responsive process to occur. This seems especially imperative
given interviewees's opinions that local elected officials have not been ac-
tively participation in the WQM project. The situation is complicated by
the county election, affecting a good number of the Commission members. .
A January approval date would collide with the officials' turnover period
and force a vot ewithout sufficiently exposing the new officials to the
WQM effort.
However, interviewees did expect some form of a plan to be approved and gene-
rally noted that the planning strategy had been designed with the aim of
gaining local approval. Non-staff interviewees had commented that the stra-
tegy reflected a WQM approach which was most politically expedient, skirting
MY-26
-------
politically sensitive issues_s.uch_as_land_use. This strategy was likely to
recommend a management structure built on existing local authority, and
emphasising municipal treatment. The WQM Project Director as well as several
local officials interested and support.
At this point, the outlook for implementation is highly__unc.erj:.ain,., Most
interviewees, including the WQM Project Director, expected EPA sanctions
to affect the extent of point source problem correction. The case was stated
more strongly by an elected official who expected that meeting Federally im-
posed requirements may be the maximum action taken by local officials. Re-
garding nonpoint sources, most expected little impact of the._rather_w.eak^
data on local decision-making. Even if the data could demonstrate the water
quality impact effectively, the development pressures in this pro-growth
area would pose a considerable obstacle to instituting nonpoint source
controls. As a citizen noted, there is not incentive forlo.cal_gc>yer nmen.t
to implement nonpoint source controls and her view was somewhat confirmed
by a local official's statement that local governments may not readily accept
water quality as an important factor in decision-making. Nonetheless, MVRPC
has provided the are with population/land use projections based on extensive
local input. Together with the land capability analysis, the projections
offer a generally agreed lypon basis for future local decison-making
in many areas related to water quality. The WQM Project Director
stated his belief that the WQM project can only show a way to handle
water quality problems. Hence, the WQM project provides tools useful
to local governments, but cannot direct how the information is used.
My-27
-------
B. Public Involvement
To date, most of MVRPC's public involvement in shaping the WQM project has
remained at the level of the advisory committees. Their ongoing role in
reviewing WQM outputs and water-related A-95 reviews has provided some op-
portunity for input to the project, but that input has been constrained by
the limited planning period. Delays in technical planning components have
caused an unfortunate bunching of review responsibilities close to the end
of the project, such that adequate committee review of the plan's components
was precluded. Interviewees' comments indicated some frustration with the
hastily processed reports whose technical complexity seemingly demanded more
thorough study. Consequently, the WRC and TAC members interviewed seemed to
be left wondering if their comments had cr could have any impact on the
rapidly developing plan. A six-month extension which is being considered
for funding by the State would alleviate some of the stress in the import-
ant phase of evaluating plan alternatives as well as final plan approval.
The advisory committees have not provided the only input to the WQM effort.
MVRPC conducted a laudable outreach effort to involve the public in devel-
oping future land use sketch plans in areas lacking plans and to work with
officials in updating existing plans. They also provided opportunities
through telepnone surveys, "touch base" meetings, the use of media as well
as other tactics to solicit public comment. But the question remains, as to
how effective these efforts have been. Notev?orthy is the MVRPC Executive
Director's comment that, for the amount of effort expended by MVRPC to
reach the public, he saw little change in the degree of public interest in the
WQM project. As tangible, integrated WQM alternatives became available for
public review and were presented at public hearings, MVRPC hoped to elicit
more public response. However, it is not clear whether the time constraints
of the process, even with the six-month extension, will allow for the area's
range of constituents (public officials, interest groups, and the gneral
public) to digest and react fully to the WQM plan. As plan implementation
is seemingly contingent upon the willingness of the public to pay for improved
water qualty (e.g., increased sewage rates) public education regarding the
water quality problem is paramount to corrective action.
C. Current Planning Process
As an early designate, MVRPC has not been subject to the EPA directives af-
fecting later WQM planning efforts. This was, as stated by the MVRPC Exec-
utive Director, both a benefit and a cost. Lacking models after which to
pattern their efforts, MVRPC was a pioneer project and vulnerable to mistakes.
Scheduling was difficult for MVRPC to handle without adequate time for full
preparation. MVRPC also had no knowledge of the "startup" time extension
until midway through the process. At the outset MVRPC initially pro-
ceeded according to the Act's intent, and its strategy did change as the pro-
gram proceeded.
My-28
-------
The WQM staff defined their approach primarily as developing a flexible plan
based on local preferences. The WQM Project Director and MVRPC Executive
Director emphasized that the strategy was aimed at producing a 100 percent
locally acceptable and implementable plan. Accordingly, they expected_to_
solidify political support for incremental and realistic_steps_towar^
-------
E. Significance of Local Elected Offlcals' Involvement
Primarily involved in the WQM project as commission members, local elected
officials have final authority in approving the WQM plan. With the aim of
developing a locally acceptable plan, MVRPC staff indicated that local of-
ficials were vested with considerable responsibility throughout the WQM plan-
ning process. The Water Resources Committee (WRC) is comprised of 51 per-
cent local elected officials. The WRC reviews WQM planning outputs as
well as water-related projects subject to A-95 review. The WRC reports its
recommendation? to the overall Commission which then takes final action.
Conceptually, the linkages for effective communication with local decision-
makers have been structured. _ln_actuaJLicy,.^there is_lj/ttle evidence
of local officials' commitment to areawide WQM planning. As noted by several
interviewees, including MVRPC staff members, local elected officials were
participating somewhat in anticipation of future WQM program ties to con-
struction grant eligibility, but, nevertheless, did not expect
Federal sanctions to be imposed. Consequently, their rather token attention
to the WQM to date is a result. Review of the WQM alternatives and the in-
tegrated final plan, however, may evoke increased interest, particularly in
regard to management agency recommendations.
The support of local officials is essential to plan implementation, as well
as to continued WQM planning. Except to the extent that plan implementation
is required, the plan is expected to be advisory to local actions. With
the frequently mentioned attitude of retaining local control over decision-
making and the prevalent pro-growth climate in the area, plan implementation
would likely depend on the receptivity of officials to incorporating water
quality consideration in their decision making process. Moreover, nonpoint
source data was acknowledged generally to be weak and, as the WQM program
lacks an incentive for implementing nonpoint source controls, the outlook
for officials' serious attention to nonpoint source problems is not promising.
Unfortunately, continued planning, which may provide a vehicle for verify-
ing data and perhaps credibly documenting water quality problems, is not
particularly well-supported. Consequently, a means for translating the
informational base into local planning efforts may be lost or at least
so undercoinmitted as to portend a WQM planning tool which rests on the shelf.
My- 3 0
-------
AGENCY: MID-AMERICA REGIONAL COUNCIL (MARC)
REGION: VII - (Kansas City)
GRANT AMOUNT: $1,400,000
GRANT RECEIPT: June 13, 1975
STARTING DATE: July 1, 1976
STATUS AT TIME OF INTERVIEWS: Data gathering stage subsequent to EPA ap-
proval of work plan.
REASON FOR INCLUSION IN SAMPLE: MARC is representative of a bi-state
planning effort.
MA-1
-------
I.
BACKGROUND1
A. Area Description
The Mid-America Regional Council (MARC) is the planning body for the Kansas
City metropolitan area. The total region extends over 3800 square miles
in the States of Kansas and Missouri. The 1970 Census figures indicate
that the region's population is 1,327,266. Missouri represents 65 percent
of the total popultaion.2 Missouri counties include Cass, Clay, Jackson
and Platte. Kansas represents the remaining 35 percent; its counties in-
clude Johnson, Wynadotte and Leavenworth. Only Leavenworth county is not
in the SMSA.
The Missouri River and numerous streams and highways are the major features
of the land. Agricultural uses comprise 80 percent of the land on the
Kansas side and 50 percent on the Missouri side. The major employer in the
region is industry, accounting for 42 percent of the labor force. Services
and retail trade follow with 19 and 15 percent of the labor force, respectively.
MARC projections indicate an expected employment growth rate of 65.63 percent
between 1970 and 2000.3 Efforts are underway to insure this growth through
a program to attract light industry sponsored by the Chamber of Commerce.
The area presents an interesting situation for regionalization. The States
of Kansas and Missouri do not have a history of cooperation, dating back to
the Civil War. The political lines are drawn almost as clearly as the
geographical lines. An apparent reason for this lack of cooperation is the
fear of regional dominance by Kansas City, Missouri. The political party
affiliations of the states are different. Missouri is predominantly Dem-
ocratic, while Kansas is predominantly Republican.
In addition to the inherent differences in perspectives on each side of the
river is a strong preference for local government - - the smaller the better.
For example, many of the smaller towns on the Missouri side are not pleased
with Kansas City's vigorous annexation program. Accompanying this preference
for small government is a dislike of the Federal Government and its programs.
WQM came to Kansas City as the least of three evils. The first two were the
States or the Corps of Engineers being responsible for water quality planning.
Perceiving these as the only alternatives, the area chose to retain as much
control as possible. Consequently, MARC was chosen as the vehicle for WQK
[planning. One sentiment shared by both sides is an aversion to land use
I controls.
1
Information for this Chapter was taken from the MARC Designation
Package, MARC, 1975; WQM Grant Application, MARC, 1975; and various
interviews.
2
MARC Designation Package, March, 1975
3
Includes construction, manufacturing, wholesale trade, transportation,
communications and public utilities.
MA-2
-------
Environmental quality and clean water are not considered priority issues
in the Kansas City Region. Interest groups with water quality goals exist,
but most interviewees felt that there was not much pub]ic knowledge of or
support for water quality activities. Two general reasons for this were
cited. The first is that water quality has improved significantly in the
past ten years without being a "hot" issue. The second is that the major
bodies of water are not highly valued for aesthetic or recreational factors
which would increase the level of public awareness.
B. Water Quality Problem
The Missouri River is the major river in the region. The confluence of
the Missouri and Kansas Fivers is in the approximate center of the devel-
oped part of the region. The Kansas River runs through the participating
Kansas counties before joining the Missouri River. With the exception of
the Marais Des Cygnes (Kansas) and the South Grand (Missouri), a]1 major
watersheds in the region discharge directly into the Kansas and Missouri
Rivers. The WOM Director stated that the major water quality problems exist
in the tributaries — not in the major streams. The sources of pollution are
vaired, including municipal, industrial and nonpoint source pollutants.
Dissolved oxygen and biological oxygen demand were cited as major pollution
problems. Heavy metals and toxics are the predominant pollutants in indus-
trial areas.
According to the Designation Package, another problem is the lack of water
quality data on all streams in the region. Most of the previous studies
were conducted on a State or basin level and are not specifically tailored
to the water quality data needs of the metropolitan area. In addition to
the water quality problems of an urban industrial area, the MARC WQM effort
/faces a complex institutional setting. There are .presently 168 wastewater
[operating agencies in a bi-state region that is traditionally separatist.
lAnti-regional sentiments in each state further complicate efforts to con-
solidate the disparate operating agencies.
Most interviewees felt that the completed 3 (c) management plan for the
Kansas City Metropolitan Region provides a sound plan for meeting the 1977
water quality standards. Additionally, the 3 (c) study proposed a pol-
itically acceptable regional management system which provided a good start
for WQM planning. Many looked upon the WQM study as a vehicle for completing
and implementing work under the 3 (c) study (See Management Planning, Chapter
II) •
C. Designated Agency
MARC was organized in 1972 as an Inter-state regional council of governments.
MARC was an outgrowth of the Metropolitan Planning Commission, established
in December of 1966. The Regional Counci] is composed of twelve general
purpose units of government and one sewer district. Representation on the
MA-3
-------
governing board is made up of local elected officials or delegated represen-
tatives .
Planning functions which relate to WQM through sharing the same data base
are HUD 701 and transportation planning. Other planning programs conducted
by the Agency include airport, emergency medical, manpower, aging and re-
source recovery planning. MARC also acts as a coordinating agency for six
designated Air Quality Maintenance areas. Previous studies of water re-
sources include: "Sewer and Water Facility needs — Kansas City Metro
Region: (1967); "Storm Drainage Study" (1970); and "Comprehensive Area-
Wide Water & Sewer Plan for Johnson County, Kansas" (1972).
The size of the MARC WQM staff fluctuates with the various projects of the
WQM process. The WQM Coordinator estimated that there is a ful.l-time equival-
ent of 12.5 professionals. The actual number may vary from six to twenty
individuals at varous stages of the process. There are four main positions
which will remain constant over the two-year period. These are one
engineer (point and nonpoint source pollution and project coordinator),
one public administrator (financial/management), one planner (land use)
and one lawyer.
It was apparent from both agency and non-agency interviews that regional
planning is not a popular activity in the Kansas City area. Anti-regional
sentiment in the area necessitates the low-profile approach of the planning
agency. Several non-agency interviewees view regionalization as another
function of- an already too active and too large Federal government. WQM
is seen as a vehicle to keep local control through the combined effort of
local governments. The individual nature of each constituent jurisdiction
was a paramount consideration for politically feasible alternatives in
the region.
MA-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The goals for the WQM study were defined in previous studies, primarily by
the 3 (c) study and the staff through their work with local elected officials
These goals are part of a set of MARC's regional comprehensive plans. The
staff conducts a comprehensive yearly review of all MARC programs in develop-
ing an Overall Program Design. This effort ensures that all programs are
compatible and coordinated.
J The highest priority of the MARC WQM plan is to develop a politically
[feasible management system for the interstate area. Antidegradation is not
an issue in the MARC region. The primary effort will be directed toward
bringing stream water into compliance- with the standards.
MARC's final work plan had just been completed at the time of the visit,
following two unsatisfactory submissions to EPA. Stated reasons for the un-
acceptable plan were that the internal project management was not sufficient!
detailed. The final product was developed by Stanley Consultants for $50,000
The MARC staff stated that the approach is basically the same, however the
final product will be able to reach a much wider audience. Although the MARC
Board had not approved the plan, little difficulty is expected.
B. Technical Component
MARC is relying heavily on consultants in the technical aspects of the plan!
$ 300,000 of the $ 1.4 million grant will be contracted for work on point
and nonpoint source modeling. The Study Design stated that the nonpoint
source modeling efforts were to be a simplified attempt at defining the
problem.
Basic data-gathering for the study will be done either in-house or contracted
to local governments. The MARC staff stated that the land use and population
information was current and needed only to be aggregated on a watershed
basis for the WQM study. MARC plans to contract with five local agencies
for data collection in the areas of land use, point and nonpoint source
pollutants, and management information. Additionally, these contracts
include the functions of review and comment throughout the planning process.
Analysis of the management alternatives will be done in-house.
C. Management Planning
Most interviewees felt that the 3 (c) study provided a politically
management plan. The MARC staff indicated that EPA had encouraged
revamping of the management analysis, however, EPA said that the 3
vided a sound basis and only needed refinement and state approval.
feasible
a total
(c) pro-
The
MA-5
-------
3 (c) plan consolidated 168 operating agencies into 12 management agencies.
The plans call for keeping seven existing agencies and forming five new
ones through consolidation of districts in outlying areas. The 3 (c) plan
keeps management authority in separate States — apparently the only politically
feasible alternative at this time.
D. Public Involvement Program
The public involvement program is scheduled to begin this October, the
fourth month of the planning period. The work plan calls for designating
the public involvement program at that time. The MARC staff readily ad-
mitted that general public involvement is not a high priority in this study
due to a low level, of public interest and involvement in a recent transit
study.- The MARC staff expects to assemble a citizen's committee this
September. The process for their input was not yet developed.
The staff discussed the general approach for public involvement over the two-
year period. Public education and information dissemination would comprise
the activities for the first year. The next eight months would entail al-
ternative plan analysis, followed by four months of plan selection.
E. State and Federal Involvement
Both Kansas and Missouri have assigned one full time person to work with the
MARC VJQM. Both liaisons and the WQM Project Coordinator have a weekly
meeting. The staff indicated that there is a good working relationship
in terms of exchange of information, although there has not been a major
impact on the plan as a result of state involvement. The States, on the
other hand, felt that their input had been significant. Both States felt
that there was sufficient opportunity for state input throughout the plan-
ning process.
The long-standing lack of cooperation between Kansas and Missouri was alluded
to by most interviewees. Two years was considered to be too short a time to
overcome the political barriers to the developement of a single management
agency. Legislators in both States were not specifically aware of the WQM
program, but were equally pessimistic about interstate cooperation, especially
when considering land use controls.
The States are doing the agricultural nonpoi.nt source work elements in the
WOM study area. This includes 80 percent of the land on the Kansas side and
50 percent on the Missouri side. The results of the States' work will be
incorporated into the final l.'QM plan.
The MARC staff reported that a good working relationship has been established
with the Regional Office. As the offices are located in the same city, the
proximity has apparently facilitiated frequent communication. The staff gen-
erally considered regional guidance to be adequate. EPA, however, was said to
MA-6
-------
be slow to respond in terms of work plan and contract approval.
F. Scheduled Outputs
The MARC WQM Study Design consists of approximately 78 products, reports
and memoranda in the area of point source, nonpoint source, financial and
institutional analysis. Committee input is clearly defined by requiring
approval at key points in the process. The two bodies designated for primary
input are the MARC Board and the Utilities Policy Committee. The latter
is a permanent agency committee composed primarily of elected officials.
The Committee's role is to make substantive policy recommendations to the
MARC staff and Board.
At this time, MARC is one month into the two year planning process. The first
products requiring approval are not scheduled until the end of the second month.
These are:
o Report on previous institutional recommendations (Utility
Policy Committee approval required);
o Memorandum on selection of water quality model (Utility
Policy Committee approval required); and
o Memorandum on decision making process recommendations
(MARC Board approval required).
No revisions of the study Design are anticipated presently. Some inter-
viewees felt that the design was ambitious, and could need trimming as the
need arises. The MARC WQM planning effort began July 1, 1976. No outputs
had been scheduled at the time of the site visits.
G. Achievements to Date
The WQM Coordinator stated that as a result of the refinement of the work
plan, the approach in the MARC Study Design is exceptionally well-directed,
and thus should succeed in achieving its objectives. As the MARC effort
had been in operation for only one month, no planning achievements could
be reported.
MZ\-7
-------
III.
EXPECTATIONS
A. Water Quality
A variety of expectations emerged when interviewees were asked in what
ways they expect the water quality to improve. Generally, no one expected
major improvements. Either they expected no change, continuation of exist-
ing fclean-up efforts, or they expected a selected aspect of the study to be
implemented which would become part of the ongoing clean-up effort.
The MARC staff and the Kansas State Liaison expected that the WQM effort would
help insure the continuing improvement in water quality that has occurred
during the past ten years. They did not think that WQM would have a drastic
effect on"water quality. The Executive Director thought that WQM planning
would provide a better method for making community development decisions by
having water quality data to feed into the decision-making process. State
of Missouri officials expected a clean-up in the smaller streams through an
improvement in regional wastewater control. A local appointed official ex-
pected storm water management control, presently non-existent, to be a
product of WQM planning. Additionally, he expected some improvement in flood
control. One local elected official and a representative of local elected
officials stated that they did not expecc improvements in water quality for
varied reasons. One reason was that the rural county did not have water
quality problems, the other was that they did not expect completion of the
study. However, better control of development relative to water quality
objectives and insured recreational use of certain segements was anticipated.
Responses on the 1983 goals were not quite as varied. A citizen thought
that there should not be a problem meeting the 1983 goals, if people were
willing to spend the money and effort. Ail others interviewed did not ex-
pect to meet the goals. The Executive Director thought that the thrust of
the goal was admirable, but that it went too far. One official stated that
swimming and fishing in some of the bodies of water in the Kansas Ci.ty area
i.s not considered desireable "unless you want to do it in a mud pool."
The MARC staff stated that even Lewis and Clark throught the water was
unsuitable in 1783. The cost of interceptors, treatment and the elimination
of combined sewer overflow were considered too vast to be absorbed by 1983.
B. Plan Approval and Implementation
Questions as to the likelihood of plan approval and plan implementation once
again brought a variety of responses. It is interesting to note that despite
all the discussion of local political problems, people generally expected the
fewest problems with local plan approval.
The WQM staff expected the States to encounter problems with bi-state coop-
eration, and EPA to encounter problems with the locally acceptable multi-
agency separate State management system. A local appointed official and the
MA-8
-------
State of Missouri official interviewed were confident of plan approval.
The former's reasoning was that it would get "pushed through one way
or another"; the latter's was-that if the plan was followed, the State
approval should come easily. The Kansas Liaison and a citizen thought
that it was premature to comment.
People were much more reticent to comment on the likelihood of plan imple-
mentation. The major factor inhibiting implementation for those who com-
mented was the avialability of money. If the construction grants program
and capital improvements money were able to fund the plan implementation,
the major obstacle should be removed. The political climate was also
mentioned as a possible factor affecting plan implementation, however, that
was considered an unknown at this time. No work has been currently under-
taken to build the legal foundation for plan implementation, however, con-
sideration of management alternatives did begin on the first day of the
planning period. The expectations for the management system are heavily
colored by local bi-state area political conflicts. Most feel there is
little chance for a single authority for this plan. There was a feeling
that over time, however, some of these obstacles could be lifted and thus
enable serious consideration of a single management system. (See discussion
of 3 (c) plan under Chapter II, Management Planning.)
C. Continuing Planning Process
The major factor affecting the existence and extent of continuing planning
activities was money. Most felt that EPA would have to share some of the
burden. Although a matching grants program was considered desirable, the
local share was predictably low. The amount of the local share was depen-
dent on the amount of overall funding. The Executive Director gave a rough
'estimate of $ 250,000 for a coordinating function. The WQM Coordinator-
mentioned a "low profile encouragement" function for plan implementation.
Others interviewed felt it was too early to discuss continuing planning
because it was dependent on the results of the planning effort.
D. Relation to Other Water Quality Programs
The relationship between WQM planning and other water quality programs
{201 and NPDES) was not clear at this stage of the planning process. There
were, however, a number-of ideas expressed concerning the potential effects
of WQM on 201. The MARC staff thought that if capital grants were contingent
on the WQM plan, it would provide a strong incentive for WQM implementation.
A local elected officials's primary interest in the WQM effort was insuring
future sewer monies for his community. The citizen stated that if 201 money
became contingent on the WQM plan and if the WQM plan differed from state
priorities, then Kansas would be inclined to use its own money. One local
appointed official stated that if WQM was conducted as the law required, it
should pre-empt at least step one of the 201 program. He added that in reality,
the WOM plan probably will not be used to guide 201 because the plan will not
MA-9
-------
cover the issue of facilities in sufficient detail.
The States did not believe that the WQM plan would have a significant effect
on 201. In Missouri, the 201 areas are outlined and the State expected MARC
to follow the State's regional priority list. The State of Kansas thought
the WQM planning effort and 201 had imposed too many planning requirements
on facilities construction. The official stated that the State had fallen
five - years behind schedule because of Federal requirements.
Most people interviewed did not perceive a strong relationship between WQM
and NPDES, although the need for coordination was realized. The Kansas
Liaison felt that NPDES had confused and complicated the state permitting
system which was established in 1907. Missouri officials stated that they
did not expect much impact on NPDES from WQM, but said that the State was
open to input from the WQM effort. Neither State expected inherent conflicts
between the WQM plan., and NPDES.
F. Local Definition of Success
The majority of responses to the question regarding individual definitions
of success centered on the institutional aspects of WQM planning. This co-
incided with the study, as the selection of a management system is the first
priority. The Executive Director expected institutional change in terms of
moving toward more cooperative efforts in wastewater management. Local el-
ected officials also considered the consolidation of sewer districts a success.
One expected consolidation within his county whereas another was looking at a
larger scale but did not expect the system to cross State lines. The citizen
was hopeful of a bi-state authority by 1978, but v/as aware of the political
obstacles to be overcome in such a short period of time. The Kansas Liaison
estimated that a bi-state authority may be implemented by the year 2000, but
certainly not in 1978. Missouri officials considered a successful finished
product to be that which was politically acceptable, economically sound and
provided effective control of pollution.
A few interviewees expected additional benefits from the WQM planning effort.
The Executive Director expected better methods of controlling development
to result from the study. A local, appointed official hoped only for better
land use data for his city. The citizen expected a variety of benefits: a
savings to the taxpayer in the form of more cost-effective solutions, an in-
creased awareness of growth implications, and a better understanding of
the need for regional planning.
MA-10
-------
IV.
VARYIN.G PERSPECTIVES OF WQM
A. WQM Staff
Neither regionalism nor the Federal government are popular political issues
in the Kansas City area. This fact was pointed out by the MARC staff and
confirmed in local and Stat-e interviews. The importance lies in how these
attitudes color MARC's approach to WQH planning. It was readily pointed
(but that WQM was not a coveted program in Kansas City. WQM planni.ng was
undertaken by MARC in order to insure local control over water quality,
and more importantly, land use issues.
Consequently, the MARC staff emphasized that the low-profile encouragement
approach was the only politically viable strategy for their agency. A
strong emphasis is placed on pleasing their politically diverse Board of
local elected officials. The COG Director felt that EPA does not always rec-
ognize the fact that local consensus governs all regional planning decisions.
The emphasis of the study, according to the WQM Coordinator, is on the manage-
ment system for municipal facilities. There are few expectations for any land
use controls from the WQM effort. The Executive Directo.r stated that the MARC
goal is to achieve consensus. He views WQM as a difficult task because of its
progressive, liberal nature. In an area dominated by conservative suburban
governments, the task that lies ahead calls for significant change. He views
the two year time frame as sufficient for the technical work, but definitely
inadequate for the major institutional and ideological changes necessary for
implementing a "comprehensive" WQM plan.
B. Citizens
Two citizens were interviewed for their perspective on WOM. As the citizens'
committee had not been assembled (one month into the process), the views
could not be obtained on MARC's WQM efforts to date. Both citizens were
members of the MOKAN Coalition for Water Quality, a locally active environ-
mental group. One citizen sits on MARC's standing Environmental Review
Committee. The MOKAN Coalition for Water Quality had written a letter re-
questing membership for the other citizen on a WQM Committee. No response
had been received at the time of the interview. It was felt that MARC had
a tendency to play down active environmentalist roles because of the con-
servative nature of its constituency.
The citizen on the Environmental Review Committee criticized MARC's defining
the "public" as local elected officials. She would like to see citizen in-
put considered from the earliest stages of plan development throughout the
process. As it stands, she will be attending her first meeting next month,
but had, through her own efforts, become very knowledgeable on the WQM pro-
gram. Both citizens felt that there is a knowledgeable clement of the cit-
MA-11
-------
izenry that would be able to actively participate in MARC's activities.
The citizens did acknowledge that water quality was not an issue in the
Kansas City area, and that people are not generally aware of water quality
issues. One person had been giving lectures of what P.L. 92-500 means to
citizens in an attempt to increase public awareness of the condition of the
water in the metropolitan area. The other citizen considered the develop-
ment of a bi-state management authority a success for this WQM effort, but
was 'also aware of the major political obstacles which would have to be sur-
mounted in order to accomplish this.
C. Local Elected Officials
One urban County Commissioner on the Kansas side and one representative of
rural local electee! officials were interviewed. Both interviewees are
members of the Utilities Policy Committee which has been delegated a majcr
technical review function in the WQM planning process.
The rural priorities for WQM consisted of the consolidation of 20 sewer
districts within one county. Although it was considered too early in the
planning process to comment on WQM activities, the rural officials' reaction
was that MARC was satisfactorily "feeling its way" at this time. Although
he'felt that there was enough money for planning, he doubted the availability
of funding for the structural improvements necessary to raise the water
quality in the area. His opinion of the role of the Utilities Policy Com-
mittee was thatj in the past, MARC has been very receptive to committee in-
put. He hoped that the document would be primarily advisory, laying out water
quality alternatives, costs and benefits. His rural county is against region-
alization because of the fear of dominance by the larger cities. He believed
that the unpopular aspects of the WQM (regionalization and land use) could
be imposed by EPA through regulations, however he felt that the local residents
would not be receptive to a substantial amount of regulation.
The urban county in Kansas saw WQM planning as insurance for future sewer
monies. A study of water as a health hazard was also a county priority.
The Kansas official preferred a concentration on point source rather than
nonpoint sources of pollution and "didn't want any part" of the land use
aspects of WQM. Although he "agreed with WQM in principle," he disliked
any strong Federal role in local affairs. Like the rural Missouri county,
the urban Kansas county was against the concept of regionalization. Once
again, there was a preference for management systems in the separate States,
such as the previously proposed 3 (c) management system.
D. Appointed Officials
The Director of Water Pollution Control for Kansas City, Kansas, was inter-
viewed for opinions of the WQM program. The Director is an engineer who
acts as a representative for the mayor and wi]1 participate on a WQM Advisory
Committee. Additionally, Kansas City, Kansas will be contracted for one of
MA-12
-------
the local data-gathering efforts. The Director docs not see Kansas City
as reaping major benefits from the WQM effort. Facilities plans for the
entire city are completed. Accurate mapping would have been a useful tool,
but that could- not be done under WQM planning. The Director considered the
study to be considerably underfunded. He felt that sound conclusions could
not be drawn because not enough data would be gathered to substantiate con-
clusions .
He reiterated the same anti-regional sentiments as all other interviewees
had expressed. He alluded to political difficulties in consolidating
Kansas side. Additionally, Kansas City, Kansas feels that its twin city is
dominating MARC activities, and feels it is overpaying for presently pro-
vided sewer services. Although the Director expects some benefits in the
area of stormwater management and flood control, WQM is not a current,priority
for his area. The priority in the Kansas City, Kansas area is the elimin-
ation of combined sewers, for which a $75 million outlay over the next six
years has been projected.
E. State Legislators
'A representative for an urban area of Johnson County, Kansas was not familiar
with the WQM program. She had worked with MARC previously and was the only
person spoken to who was in favor of the concept of regionalization if it
proved to be the most cost beneficial alternative. Unfortunately, she stated
that she felt that present cost differed widely. She was hopeful that WQM
would provide the necessary data on which to base decisions for regionalization.
F. State Water Quality Personnel
Interviews were held with officials from the States of Kansas and Mis-
souri. On the Missouri side, three offi.cials of the Department of Natural
Resources were interviewed: the Chief of the Environmental Division, the
Chief of Water Quality Management (Regional and WQM Coordination), and the
Chief of Statewide WQM Planning. On the Kansas side, the WQM Liaison was
interviewed. Both States will be doing all aspects of the agricultural non-
point source study in the WQM area.
The Kansas Liaison feels that the State had significant input in the plan
design. He sees his role as "bringing Kansas' wishes" to MARC, and as one of
encouraging rather than directing the MARC effort. To date, MARC has been
very receptive to state input which is generally received in weekly meetings
with the WQM Coordinator. His opinion is that the, plan may include too much
in the areas of land use and nonpoint sources. Although he stated that he
was not in disagreement with the concept of regionalization, he did not ex-
pect that a- bi-stal-e authority would be a politically acceptable alternative
for the WQM effort. He slated that the separatist sentiment is deep in the
present political structures, and that it will require a new generation to be
MA-13
-------
open to consideration of regional alternatives. Certainly, no major
changes can be expected by 1978; a single authority may possibly be devel-
oped by 2000.
The Liaison felt that Kansas has seen significant water quality improvement
in the past ten years, and did not expect WQM to do more than to continue at
the same rate. He added that working with the Federal system is burdensome
because of the bureaucratic processes that must be followed.
The Missouri officials also felt that the State had significant input into
the study design, and plans to watch the outputs very closely. The study
design requires state approval,, and officials do not foresee difficulties if
the present plan is followed. Additionally, a committee of the ten executive
departments of the DNR v/as set up for WQM to insure coordination among all
State programs and WQM planning. The State feels that MARC has been respon-
sive to its input, and hopes that State participation throughout the process
will make it possible to automatically incorporate the WQM plan into the
State Water Quality Management Plan. The State of Missouri expects the mast
significant water quality improvement in the small streams and tributaries,
through the elimination of direct discharging. The concept of regionalization
and the bi-state conflict v/as not as sensitive an issue .with Missouri DNR
officials as v/ith all others interviewed.
MA-14
-------
V.
A.
ANALYSIS AND CONCLUSIONS
Likelihood of Plan Completion, Approval and Implementation
In the past year, MARC has concentrated on developing a work plan that
is acceptable to EPA. The final study design was completed in July, 1977,
and the two year planning period began at that time. The MARC staff's
confidence in the final study design as an appropriate and workable plan
indicates successful plan completion. The staff considers the plan to be
readily understood by the various interest groups involved in the WQM plan-
ning process (local elected officials, appointed officials and citizens) be-
cause of its well-ordered layout and the clear treatment of technical information.
As the planning process continues, the MARC staff and the Kansas State
Liaison felt that there may be a need for a reduction in the level of detail
within specific work elements due to either an overambitious work plan or to
"normal" delays in the planning process. It was felt that these adjustments
could be made without deleting major plan elements. The Kansas State Liaison
said that land use and urban nonpoint source work were most likely to be
affected by this de-emphasis. Inasmuch as these elements did not receive
high local priority and are the most controversial aspects of the study,
their de-emphasis is not surprising.
Generally, less difficulty is expected with plan approval at the local" level
than with the States or EPA. Although serious concern exists over the pos-
sible consolidation of sewer districts, most interviewees were confident that
MARC could develop a final plan reflecting -the concerns of the local member
units of government. Problems were expected with the States because of the
historical unwillingness of Kansas and Missouri to work together. Prob-
llems were expected with EPA because it was felt that a management system
|which is locally acceptable may not be as acceptable to EPA. More specific-
ally, all involved thought that EPA expects a single, bi-state management
agency by 1978, and that locally palatable alternatives such as the 12 agency
alternative proposed in the 3 (c) plan would not meet with EPA approval.
The Executive Director and the WQM Coordinator stated that it was too early
in the planning process to discuss the likelihood of plan implementation.
This reaction was true for most interviewees. There was consensus on one
aspect of plan implementation that its likelihood was dependent on EPA1s future
financial committment. This financial committment; was seen in terms of funds
for both capital improvements (combined sewer overflow, interceptors and
wastewater treatment) and ongoing planning activities.
B. Public Involvement
MARC's public involvement program design is scheduled for October, four months
into the planning process. In the meantime, however, newsletters are
being distributed and committee meetings are being held. MARC will
MA-15
-------
be emphasizing the participation of local government officials rather than
that of the general public. Consequently, permanent committees, the MARC
Board and the Utilities Policy Committee(composed of local elected officials
or their representatives) are delegated the major review functions in the
WQM planning process. The MARC staff was cognizant of the fact that the
program underplayed the role of the general public in the decision-making
process. The reason given was that the staff had been disappointed with
public involvement efforts in a recent transit study; the low involvement
level having stemmed from an inability to arouse citizen interest.
Although the design of the public involvement program has not formally
commenced, the staff indicated that the general framework will probably
consist of one year of public education, followed by one year for review
and approval. Additionally, the MARC staff feels that their contracts with
local governments for data collection are an import vehicle for obtaining
public input. Citizens generally were critical of the lack of emphasis on
general public involvement because they felt that an interested group
exists which is available to participate in WQM.
It is too early in the process to predict the repercussions of MARC's ap-
proach to public involvement. To the extent that water guality seems to be
a politically live issue only with environmental groups, the MARC approach
may be realistic as well as appropriate, given the amount of resources avail-
able. However, an uninvolved citizenry may cause problems later in the
planning process.
C. Current Planning Process
MARC is undertaking the management aspects of the entire study area, while
the respective States will be addressing agricultural nonpoint source activities.
Agricultural lands comprise 50 percent of the Missouri study area and 80
percent of the Kansas study area.
The collection of land use, nonpoint source (urban areas) and financial
data is contracted to five local jurisdictions. This work is designed to
increase the participation of the local jurisdictions, and requires analysis,
review and comment by these jurisdictions. MARC will be playing the role of
the coordinator. The design of these work elements is consistent with
MARC's emphasis on actively including local elected officials and their staffs
in the planning process.
All interviewees indicated that the major priority of the WQM effort is the
study of alternatives for the consolidation of sewer districts. Additionally,
all interviewees stated that the locally approved 3 (c) study provided a sound
basis for the WQM planning effort. The 3 (c) plan provides for the consoli-
dation of 168 operating agencies into 12. Seven of these agencies presently
exist, and five would be developed through the consolidation of districts in
MA-16
-------
less populated, outlying areas. No districts would cross State lines. The
WQM effort is seen as a way to refine the 3 (c) effort and acquire the States'
approval.
There seems to be some discrepancy between EPA's position on management
analysis and the MARC perspective of that position. The WQM Coordinator
and the Executive Director stated that EPA would like to see the management
analysis redone without significant reliance on the 3 (c). On the other
hand, EPA stated that MARC could refine and begin implementing 3 (c). There
appears to be a significant misunderstanding between MARC and EPA on this
issue.
The strong negative reactions to land use regulations in the Kansas City
area has resulted in a de-emphasis on land use in the study. MARC has as-
sumed this backdoor approach because avoiding the term "land use" makes
working with the concept possible. The approach seems to be fairly suc-
cessful, and they are presently considering a model construction practices
ordinance.
D. Continuing Planning Process
Most interviewees expressed the need for planning to continue after the two
year period, and for EPA to provide funding for this continuing planning.
The Executive Director thought that a matching grants program would be more
effective. He felt that, when local governments are forced to spend their
own money, they are more thoughtful about how it should be spent. He added
that if planning was totally dependent upon lccal funds, it would not occur.
He saw the major function of continuing planning as low profile encouragement
for plan implementation by MARC. The States and the citizens felt that the
continuation of plann.ing will be dependent on the outcome of the plan.
With the exception of the Executive Director, it generally was considered
too early for continuing planning to be an issue in the Kansas city area.
E. Significance of Local Elected Officials' Involvement
Although the concept of treatment plant regionalization did not rest well
with local elected officals, most supported MARC and were aware of'the need
for participation in the MARC planning process. The MARC staff, realizing
their position is neither politically strong nor popular, currently assumes
a low profile and attempts to achieve consensus among local governments.
This seems to be the only politically realistic approach for MARC, given
the strong belief in local government. To date, it has been relatively
effective.
The role of local elected officals is defined clearly in the WQM planning
process. Review and approval of plan outputs is delegated to the Utilities
Policy Committee or the MARC Board. The approach of Jetting contracts to
MA-17
-------
local governments for data collection was also seen as a means of insuring
active local participation. Although MARC is only one month into the plan-
ning process, there was a definite awareness of WQM and water quality issues
on the part of local elected officials. These local attitudes were generally
similar, and consisted of a dislike of both regional water quality solutions
and a strong Federal role in local water quality issues. Local elected of-
ficials' strong desire to insure that WQM planning will reflect local prior-
ities is operating as a significant inducement for active participation in
the WQM planning effort. It is too early in the planning process, however,
to foresee how much of a problem this will pose in choosing an acceptable
solution.
MA-18
-------
AGENCY:
MIDDLESEX COUNTY PLANNING COMMISSION (MCPC)
REGION: II - (New York)
GRANT AMOUNT: $1,420,000
GRANT RECEIPT: June, 1975
STARTING DATE: June, 1975
STATUS AT TIME OF INTERVIEWS: The agency was ending its data collection
phase and beginning to concentrate on
development of management alternatives.
REASON FOR INCLUSION IN SAMPLE: The area was selected because of its
high urban-industrial concentration.
MC-1
-------
I. BACKGROUND1
A. Area Description
The Lower Raritan/Middlesex County WQM area consists of 380 square
miles in northeastern New Jersey. The WQM area includes all of
Middlesex County and those portions of Union and Somerset Counties
containing contiguous watersheds. New York City lies directly northeast
of Middlesex County, across the Arthur Kill.
Most of the 731,550 people vjho live in the region reside in the highly
urbanized and industrialized northern and eastern portions of the desig-
nated area where large manufacturing plants of the American Cyanamid,
Dupont, National Lead and other companies are located. The rest of
the designated area contains large undeveloped tracts of land which
are currently available and attractive for both home and industrial
development. With the pressures of overcrowding in neighboring New
York City, the availability of ]and in the WQM area and the possibility
of oil and gas exploration off the coast of New Jersey, the Middlesex
County Planning Board expects the designated WQM area will experience
significant population and economic growth over the next few decades.
Population in Middlesex County alone is expected to rise from 583,813
in 1970 to 700,436 in 1980.
The designated area is composed _p_f_a=hlghly^complex i nstitutional
network of 34 individual municipalities, three countilfs',^"a~varie'ty
of special purpose districts and authorities^o£~the"iState of^Ne'w"
.J.ers.e.y- The County planning boards, composed of elected freeholders,
are chiefly advisory in nature with no significant regulatory powers
or-responsibilities. The special districts are concerned with specific
issues such as wastewater treatment and soil conservation. The State,
on the other hand, exercises a variety of powers related to environmental
quality standards and development reviews. The most powerful regulatory
authorities on the local level still rest v/ith individual municipalities
which derive their strength from the power to zone and provide municipal
services.
Currently, the chief water related management agency in the designated
area is the Middlesex County Sewerage Authority (MCSA) which was created
in 1950 by a resolution of the Board of Freeholders of the County
of Middlesex. The Authority is empowered to construct, maintain and
operate sewerage facilities in and around Middlesex County. Construction
on the existing plant began in 1954. Today, the primary treatment
1
Information presented in this Chapter was taken from "Work Plan for Area-
wide Treatment Management Planning under Section 208 of PL 92-50". May,
1975; and various interviews.
MC-2
-------
plant services 24 municipalities including some outside of the County
and 10 industries which participate directly. MSCA is currently expand-
ing its facilities and upgrading waste water treatment to the secondary
level. This action will allow the Authority to accept and treat the anti-
cipated increased volume from current sources as well as from additional
clients, most notably, the City of Woodbridge.
Other management agencies in the area include county soil conservation
districts created by the State. These soil conservation districts have
latent land use control powers which have never been used, partly because
of the cooperation the districts have received from landowners without
the use of sanctions and partly because their rulings may be overturned
by a petition of 25 landowners. Under the recent State Soil Erosion and
Sedimentation Control Act, the soil conservation districts acquired addi-
tional power to review all surface-water disturbances caused by construc-
tion projects. Jurisdicational confusion between the...districts .and.._loc-al
zoning inspection boards has unfortunately resulted in a confusing system
wlTi~cK"Ts: 'o'fteri inefficient and ineffective".in dealing_with .wat e.£..qua 1 i,ty.
problems "in the area.
The general public has been highly concerned with environmental
issues of late, because of widely publicized environmental health
studies establishing a connection between industrial G-hemical pollutants
and cancer. These studies have added urgency to the public's cry
for growth controls to eliminate the possibility of spreading industrial
problems throughout the designated area. Possible contamination of
aquifers essential to the area's water supply is one of the major
concerns of local environmental groups.
B. Water Quality Problem
The major bodies of water in the Middlesex WQM area are the Raritan
River, the Arthur Kill and the Raritan Bay. All three bodies of water
are badly polluted and have been classified "effluent limitated".by
the State Department of Environmental Protection. Part of the Raritan
is so badly polluted that it has been classified "water quality limited".
Indeed, with the exception of limited segments of the county's surface
water, portions of all the major waterways within the proposed area
are "water quality limited". Of the three major waterways, the Raritan
is most heavily used for recreation while the other two are used almost
exclusively for industrial and shipping purposes.
Most of the WQM area is presently or will soon be with existing and
planned facilities operating at secondary sewered treatment levels.
According to recent studies, urban runoff and non-point sources in-
cluding mining and construction actually contribute more to pollution
loading than does treated effluent from recorded point sources. The
WQM staff felt that the key to understanding problems in the Raritan
system will be urban runoff including that from industrial sites.
MC-3
-------
More than half of the area's present and future water supplies come
from aquifers, parts of which have already been polluted by salt
water intrusion and industrial pollutants. The latter are leaching
from poorly located, under-managed solid and liquid waste sites.
Prior studies have indicated a need for areawide groundwater recharge
area protection and for coordinated efforts to develop point source
discharge, urban runoff borne waste, solid waste, toxic and hazardous
waste control plans to prevent further degradation of aquifers.
The continued availability of water from aquifers is partly contingent
upon the availability of waste treatment effluent for reuse in industrial
processes and possibly for recharge augmentation to halt salt water
intrusion. The viability of reuse depends on consideration of pretreat-
ment standards for industrial wastes entering public treatment systems
and the degree cf treatment provided.
To supplement the current water supply in ancitipation of growing
domestic and industrial demand, a major reservoir project has been
proposed on the main stem of the Raritan River. Whether the quality
of upstream water is now or can be made and kept suitable for its
intended use as a drinking supply and recreational resource is an
unresolved question.
Even though a number of water studies have been conducted in the
Middlesex area, a great deal of State 303(e) data was not available
at the start of the WQM project. Most of available information had
been collected under previous studies conducted by the County, State,
private industries and local communiti.es. The Raritan Bay is being
studied by the New York City WQM agency since most of the Bay's pollution
originates in the New York area.
C. Designated Agency
The Governor of New Jersey designated the Middlesex County Planning
Board as the official WQM planning agency in May, 1975. The MCPB
represents 25 communities in Middlesex County. It is governed by
an elected Board of Freeholders , many of whom represent real estate
and industrial interests. The Board is responsible for policy decisions
and selection of planning staff.
The MCPB has conducted a variety of planning activities including tri-
state transportation, delivery of social services, solid waste manage-
ment, air quality and reservoir studies„ It is currently engaged
in planning for mass transit, housing, floodplains, coastal zone manage-
ment and air quality maintenance. It is also awaiting money to conduct
an off-shore oil study to determine secondary impacts of energy develop-
ment on land use and the environment.
All of MCPB's planning activities are tied together through the Board's
major planning endeavor - a comprehensive, land use county-wide planning
effort aimed at achieving a balance between economic, housing, trans-
portation and environmental interests,, Each of the MCPB's project
MC-4
-------
staffs feed into the land use planning program, in addition to carrying
out the functions and responsibilities of their individual programs.
For example, the WQM Land Use Specialist and the Economic Planner
calibrate models jointly in order to balance out the interests of both
groups. Joint weekly staff meetings are also held to ensure communi-
cation and exchange of information among project staffs. The WQM
program currently holds high priority within the MCPB because it repre-
sents the largest program budget and because its comprehensive scope
complements the data needs of the comprehensive land use plan.
The WQM staff consists of seven persons:
o Project Manager;
o Water Quality Specialist;
o Land Use Specialist;
o Institutional Analyst;
o Public Involvement Specialist;
o Draftsman; and
o Support Staff.
The Project Manager serves as Staff Coordinator and Liaison between
the agency staff and consultants. The Water Quality Specialist is
responsible for technical aspects including analysis and overseeing
of monitoring, sampling and modeling efforts by consultants. The
Land Use Specialist is actually more closely tied to the MCPB's compre-
hensive planning program. His responsibility is to facilitate an inter-
face with the WQM effort and to oversee the nonpoint source management
study. The Institutional Analyst is responsible for a review inventory
of the existing legal/institutional structure and the development of
new arrangements and institutions where necessary. The remaining
positions are self-explanatory.
Approximately two-thirds of the WQM agency's total grant is committed
to outside consultant work, primarily in technical water quality sampling,
modeling and analysis. The three prime consultants are large engineering
firms; among the minor consultants is a review group from Rutgers Universi-
ty. The latter is assisting in technical review of engineering consultant
work. The WQM agency has also contracted with the New Jersey Department
of Environmental Protection for coordination on statewide activities
and for reveiw of program outputs. The State is also facilitating
coordination among other WQMs adjoining the Middlesex designated
area namely, Monmouth County, Mercer County and Upper Raritan.
MC-5
-------
11 • PLANNING PROCESS
A. Agency Objectives
According to the Middlesex County WQM work plan, the purpose of the WOM
program is to maximize achievement of the following goals:
o Ensure and protect adequate quality and capacity
of all surface and groundwater storage systems;
o Protect and enhance existing recreational, cultural
and aesthetic amenities; and
o Meet the 1983 goals of PL 92-500 in an economically
efficient manner throughout the designated area.
In order to meet these overall goals, the WQM program has been designed
around the following objectives:
o Determine reasonable land use distribution and
controls;
o Develop a water data file for continued planning;
o Work with the State to identify water quality criteria
to be achieved;
o Coordinate with ongoing WQM projects to dtermine
facilities needs;
o Assist the State in setting waste load allocations;
o Integrate WQM planning with related planning efforts,
particularly solid waste;
o Implement point source controls;
o Determine ways to protect groundwater supplies;
o Develop alternative wasy to deal with urban runoff
and nonpoint sources;
o Recommend a plan and implenientation strategy; and
o Implement an ongoing planning program.
MC-6
-------
According to the Project Director, primary emphasis of the program is
focused on groundwater protection, municipal point source identification,
urban runoff and residual wastes management. The WQM staff would have
also liked to investigate toxic wastes and unreco rded discharges_v
The program had to forego these studies, however, in order to concentrate
on more basic point source and stream quality data collection. Even
industrial source studies had to be scaled down since a thorough study
would require monitoring of 700 to 800 industries. According to the
Assistant Executive Director, any amount of data would be a boom to the
County which is anticipating a water supply crisis in the near- future.
Most interviewers indicated that environmental concerns were the
motivating factor behind that WQM study. A different opinion was .voiced
by a State legislative assistant. According to the Assistant, water
quality is a "noble goal for the program", but the real goal of the
program is to use the WQM data to "justify growth controls for their
own ends". He did not consider growth control and environmental
protection incompatible, but he objected to what he perceived as public
deception on the part of the MCPB.
B. Technical Component
The technical component of MCPB's planning strategy consists of two
elements: data collection and data analysis. The water quality data
gathering effort focused on:
o Municipal and industrial pollutant discharges;
o Particular trouble spots exhibiting low D.O.
levels, thermal pollution; etc.
o Hazardous and solid waste production and disposal.
Land use data was also collected early in the process and more closely
tied to technical planning than is usually true in traditional water
quality studies. This approach reflects the MCPB's commitment to
investigate the full range of water pollution problems and to consider
nonstructural solutions where 'possible. It also reflects the MCPB's
interest in developing a comprehensive county-wide land use plan.
On the basis of historic data and State classifications of the designated
area's waters, the WQM staff and consultants designed an analysis
program to verify and project water quality impacts of future growth
and land use configurations in the WQM area. The program consists
of surface and stream sampling, stormwater/urban runoff surveillance
and simulation modelling using models developed previously by the
consultants. Problems identified for study include eutrophication,
groundwater degradation and surface water pollution. The eutrophication
study was undertaken to identify areas of actual and potential
MC-7
-------
eutrophication and to provide guidelines for allocation of allowable
nutrient loadings. The groundwater study was designed to monitor de-
mands, describe the system as it connects with surface water, and
assess the decline in groundwater quantity resulting from loss of re-
charge area and increased groundwater demand. The surface water degra-
dation study focused on pollution resulting from direct pollutant
discharges, erosion and sedimentation, nutrient build-up, and runoff
borne pollutants.
Careful attention was given throughout the technical phase to the
interrelationships of WQM planning with other County and local data.
These data include:
o Population and economic growth plans;
o Community development plans and programs;
o Transportation plans;
o Air Quality maintenance plans;
o Water supply plans;
o Sanitary sewerage facilities plans;
o Storm drainage and flood control plans; and
o Solid waste management plans.
Particular care was given to the data needs of the MCPB's comprehensive
planning effort.
C. Management Planning
The Project Manager acknowledged the need for some technical analysis
before management planning begins in earnest. However, due to the
short time frame of the study, management planning has taken place in
tandem with technical planning.
The management planning strategy basically consists of an inventory
and analysis of the current and potential legal/institutional structures
needed for water quality manaqement. The anticipated outcuts of management
planning include:
MC-8
-------
o Structural and non-structural alternatives to water
quality problems;
o Alternative institutional frameworks to implement
pollution control strategies;
o Assessment of social, economic and environmental
impacts of alternative strategies;
o Assessment of public and public acceptability of
strategies;
o Selection of a comprehensive plan and implementation
strategy;
o Development of an ongoing planning process.
Currently, most direct water quality management,powers_^are^held,by_the.
State^while indirect powers of zoning and land use controls rest in.the.._
hands of local units of government. _The goal of the WQM management
component is to get the two series of powers coordinated and enforced.
The WQM program is considering the option of creating a new level of
government by:
o Establishing a new areawicle land use authority;
o Creating a decentralized DEP with an agency for
each drainage area; and
o Reorganizing the State Division of Water Resources
down to the basin level.
In the face of the already complicated jurisdictional patterns in the.
area, however, the prospoect of introducing another authgrity into the
County appears dim. The preference is definitely for utilizing existing
local agencies and strengthening them where needed. The overall consensus
was that most of the State laws and local ordinances necessary for
water quality management are already in existence with possible exceptions
in the areas of urban stornwater runoff and oil exploration. No
action to secure such legislation had been taken yet, nor was it antic-
ipated in the near future in view of more pressing local planning
and management matters and the current climate in the State legislature.
MC-9
-------
D. Public Involvement Program
The public involvement program is designed to both disseminate information
and obtain feedback from the general public, public interest groups
and local elected officials. Primary vehicles for heightening the
public's awareness include:
o A newsletter sent to all local elected officials,
interested citizens and interest groups, newsletter
reports on program development and major issues to
be discussed at upcoming committee meetings/
o Slide shows presented upon request at public interest
group meetings and other public gatherings,' and
o Press releases to local newspapers.
The major route for public involvement is the committee structure —
primarily the Policy Advisory Committee, the three area task forces
and the Steering Committee. The Policy Advisory Committee serves
as a policy setting and decision-making group. It is divided into
six sub-committees delineated along drainage basin lines, with each
sub-committee allocating one vote to an environmentalist, an industrial
representative, a private citizen and a representative from each of
the municipalities within the basin. The three task forces are drawn
across geographic areas with one member from each basin in the area.
the task forces are responsible for assessing credentials of ptaff
and consultants, reviewing committee agendas and making policy suggestions
to the WQM staff. Members of the general public, interest groups
and local elected officials also serve on the WQM Steering Committee.
Committee meetings have been generally well attended, according to
the Public Participation Specialist, with the exception of local
elected officials who are often too busy with municipal affairs to
attend committee meetings. The staff attempts to compensate for this
through phone contacts and frequent mailings to public officials.
The Public Participation Specialist and Project Manager admitted however,
that contact with local officials has slacked off recently and that
efforts will have to be regenerated if the WQM program hopes to receive
local approval of the final plan.
Another elaborate system designed to secure public involvement in
the WQM process is the rise of surveys designed by outside consultants.
One mail-out survey was conducted to compile data on public goals,
values and objectives to be considered in the development and evaluation
of various plan alternatives. Unfortunately, the survey was poorly
designed and elicited few complete responses.
MC-10
-------
The Assistant Executive Director of MCPB acknowleged the difficulty
the program has had in obtaining a pi^lie consensus on water quality
issues. He attributes part of the problem to the agency's lack, of
experience with public involvement programs.
The Project Manager attributes lack of local officials' interest to the
fact that 201 planning and money is not a major issue in the area. Since
most areas in need of facilities are already into planning or are awaiting
grants, the thunder was stolen from WQM.
E. State and Federal Involvement
As noted earlier, MCPB entered a contractual agreement with the State
DEP to provide assistance in the WQM process. According to the State
Liaison assigned to the Middlesex VJQM study, the State's responsibilities
are to:
o Provide technical assistance in the form of facilita-
ting data dn reviewing consultant work;
o Assist in the selection of consultants;
o Review and monitor program outputs to ensure compatabi-
lity with State and Federal policies,-
o Act as liaison between the WQM agency and the County; and
o Coordinate activities among New Jersey WQM agencies.
According to the Project Manager, the State Liaison is beginning to pro-
vide useful services to the program by supplying information where needed.
Until recently, however, the State's role has been minimal with little if
any useful exchange of information.
Middlesex's contact with EPA occurs through the Regional Office in
New York City. Communication takes the form of on-site visits by the
Project Officer once or twice a month. The Project Manager was somewhat
frustrated with EPA's belated dissemination o.f_policy__s tatemen tsoand
untimely issuance of technical guidance which some.tirngs^r.es.u1,ted., in„the
need to redo work elements hurriedly, and haphazardly. The Project
Manager was particularly annoyed at EPA's tardiness in reviewing its
consultant's testing labs. The delay resulted in a general setback in
the project's technical and management planning schedule. He also
expressed concern over what he perceives as the low Federal priority
of WQM planning in EPA's scheme for water quality.
MC-11
-------
F. Scheduled Outputs
A list of MCPB's scheduled outputs appears in Exhibit I. All of the
outputs have taken slightly longer to produce than orginally anticipated.
The most significant schedule disruption, (i.e., in land use, can be attributed
to the delayed delivery of technical reprots from consultants, and the
unexpected overall scarcity of basic environmental data. The Project Manager
felt that this delay was not disrupting the flow of the project, however,
and that there would be time to complete the entire work schedule by the
end of the planning period. The State Liaison expressed more concern over
the delays. In his opinion, they will drain time and energy away from de-
veloping alternatives and ensuring plan implementation. He felt that there
was little the State or WQM agency could do to change the situation at this
late date.
The overall work plan was revised after the initia,l starting date of the
program. Because the WQM staff had to spend the first five months of
the program in this revision, it received a three month extension on the
final date for plan completion. The extension of time was not
accompanied by an increase in grant funds. All original budget allocations
of the program were maintained with the exception of public involvement
which has taken more time and more power than originally anticipated.
G. Achievements to Date
Although the program is somewhat behind schedule, the Project Manager
could report a number of achievements to date. Among these were:
o The establishment and operation of advisory
committees which have brought environmental
and industrial interests together in common
discussions. (These committees are working to
the general satisfaction of the WQM staff.)
o The completion of goals and objectives survey
(despite incomplete responses and a relatively
low number of returns, the Public Participation
Specialist felt the findings were significant
because they confirmed the original program
goals defined by the WQM staff).
o The completion of the land use inventory, in-
stitutional and legal inventory, and some
water quality sampling programs (all of these
have contributed to the county's data base
for future local and county planning).
MC-12
-------
o Increased public awareness of water quality
issues (the most dramatic evidence is a Citizen's
petition to ban further use of a chemical
disposal site until an environmental impact
study is conduced on the effect of waste
leachate on the underlying aquifer).
o Good cooperation between the WQM study and the
MCPB's comprehensive land use planning program
(according to the Assistant Executive Director of
MCPB's, both programs have benefited from the
arrangement).
MC-13
-------
EXHIBIT I
MIDDLESEX 208
Monthly Milestones (Outputs)
1975
Technical Advisory Committee and Policy Advisory
Committee created
Consultants engaged
Work Plan completed
Project Control Plan prepared
Major point sources indentified
Land use input nekds defined
Land use inventory, designed
Newsletter Number 1 issued
Public Meeting Number 1 (water quality/use
goals)
Phase I Low Flow sampling carried out
Point source sampling carried out
Phase I Eutrophication sampling carried out
Initial available point source data inventoried
Existing historical stream quality data collected
Newsletter Number 2 issued
Public Presentation Number 1 prepared (Introduction
to 208 Planning - "What is 208")
L * n d ~ ~ s ^ n^ r*
Environmental Base data collected for land use
(DYLAM) model input
Urban analysis areas identified
Weekly monitoring program designed and implemented
High and low trend population and employment
projections prepared for 1980, 1985, 1995 and
2000 for the study area
Newsletter Number 3 issued
Public Meeting Number 2 held (Policies for land
use distribution)
Phase II Eutrophication sampling carried out
i
Analysis report on sampling to include:
. analysis of low flow data to date
. analysis of point source data to date
. analysis of eutrophication data to date
. report on methodologies, scheduling and evaluation
of on-going an(j future low flow and storm sampling
. analysis of geometry survey data to date
Narrative statement on use of DYLAM model generated
land use data to develop runoff pollutant loadings
attributable to alternative land use patterns
Interim Report on interfacing; SWMJl and stream
water quality model
MC-14
-------
-2-
- Status Report, on refinement and calibration of
water quality model to include:
. identification of streams by segment, to be
modelled (both for low flow and storm conditions)
. identification of input needs
. identification of water quality parameters and
criteria for each modelled segment
. procedures for and timing of model verification
- Interim Report on Task 6 to include:
. preliminary non-urban loadings
. definition of SWI1M usage
. complete delineation of four urban areas
. description of selection of urban analysis
areas and storm water sampling points
„ completion of land use inputs for SWI4M
- Calibration of DYLAM model for Trend projections
- Refinement of land use acreage requirements for
high and low trends completed
- Interim Report on "major"and "minor" point source
inventories
May 1976 - Status Report on Public Participation Programs
- DYLAM attributes reflecting water quality planning
policies defined and coded
- DYLAM land use outputs for 1980,'1985, 1995 and
2000 (high and lov; trends) based upon "tr^nd"
policies
- Interim Report on "winter" storm sampling data
analysis
- Interim Report on Groundwater analysis to include
groundwater inventory and hydrogeologic description
of the study area
June 1976 - Tested DYLAM land use outputs for 1980, 1985, 1995
and 2000 based upon "planned" policies
- Public presentation Number 2 (land use and water
quality issues)
- Newsletter Number 4 issued
- Public Meeting Number 3 (land use outputs, pre-
liminary water quality problem identification)
- Phase III Eutrophication Analysis carried put
i
July 3 976 - Preliminary report on perceived surface and ground-
water water quality problems in the study area from
field survey, sampling and historical data analysis,
results and public input through surveys, PAC, TAC, etc.
- Interim Report on Institutional analysis to include:
. inventory of all local agencies and programs
related to water quality management
. analysis of resources and powers of existing
agencies and programs based upon reports and
legislation
August 197 6 Report describing methodologies to be used to evaluate
eutrophication, non-point, urban•runoff, and point
'source water quality problems
MC-15
-------
-3-
- Phase IV Eutrophication sampling carried out
- Identify water use factor's and waste Generation
factors for domestic, industrial and commercial
activities in the study area
September 1976 - Report on completion of interview process for
State and federal level institutional elements
Interim Report on "spring"/"summer" storm
sampling data analysis
- Phase II Tidal Raritan sampling carried out
- Phase II Diurnal D.O. sampling carried out
- Phase II Low Flow 'sampling carried out
October 197 6
Final sampling report including:
. complete low flow sampling analysis
. weekly monitoring results
. stream storm sampling
. urban storm sampling
eutrophication sampling
• tidal Raritan sampling
. dye studies
. stream geometry
. diurnal D.O, variation sampling
Report on finalized waste load allocation factors
relating water use, waste generation and water
conservation for major land use/activities
ir iMUiTujci" 5 issued
November 1976
"December 197 6
January 1977
February 1977
March 1977
Report on completion of tidal and non-tidal
water quality model calibration and verification
Report of preliminary waste load allocations
Interim Report on hazardous and solid wastes
inventory
Report on prioritization ol water quality problems
Report on land use refinements required
Newsletter Number 6 issu'ed
Public presentation Number 3 prepared (priorities
of water quality problems - structural versus
non-structural approaches
Public Meeting Number 4 held (water quality problem
priorities and structural versus nonrstructural
approaches)
Report on inventory analysis of local study area
institution's (legal, financial, organizational)
Point source control alternatives identified
Non-point source/urban runoff control alternatives
identified
201 analysis completed
Alternative groundwater strategies identified
¦Alternative strategy evaluation criteria report
prepared
Newsletter Number 7 issued
Public Meeting Number 5 held (input on alternative
strategy evaluation criteria - cost, environmental,
social impacts)
MC-I6
-------
-4-
April 3.977
May 1977
Interim Report on existing and proposed
institutions required
Report on results of modelling tests of water
quality impact of alternative point and non-
point source control and groundwater management
strategies
Report on Final waste load allocation (30 3e) and
point source management input evaluation
Complete evaluation report of management alterna-
tives to inclutle :
. environmental impact; political feasibility/
public acceptance report based upon planning
balance sheet approach; legal/institutional
constraints; financial constraints.
June 1977
Legal action required for implementation identified
Funding sources for on-going planning and implemen-
tation identified
July 1977
Environmental impact assessment issued
Draft Report completed including:
. point-source strategy, non-point/urban runoff
strategy, groundwater strategy, legal-institu-
tional, financing strategy
Newsletter Number 8 issued
Public presentation package (Draft P.eporL sur~""?i"
Public Meeting Number 6
August 1977
September 197 7
October 1977
Report on Draft Report review and revision
On-going planning program designed
Final Report prepared
Issuance of final summary report for public
distribution
Report on financial and institutional status for
implementation
Adoption of Final Report
(Water Quality Management Plan)
SOURCE: Work plan for Areawide Waste Treatment Flanning under Section 208 of
PL 92-500, MKPC, August, 1975.
WJK/jl
3/30/76
MC-17
-------
III.
EXPECTATIONS
A. Water Quality
Given the highly urbanized and industrialized nature of Middlesex
County, few expect the WQM program will precipitate major improvements
in existing water quality. Two rather optimistic citizens expected
to witness improvements in many local streams and brooks, but according
to the Project Manager, such improvements will probably be minor and
evident in only a few isolated areas. The State Liaison and a local
elected official noted that some rivers will show improvements, but
that these will result chiefly from facilities improvements initiated
prior to the WQM study. On the other hand, most people expected that
the WQM program would help prevent further water quality degreadation
through stricter controls over industrial water use, solid waste
disposal and wastewater treatment facilities. The major anticipated
public benefit was the protection and preservation of groundwater
aquifers which furnish most of the area's drinking supply.
-All— per-sons-.in,ter-viewed„felt_that—'the_19„83_.aoals would never be met
...in^.the^. I-liddle_sex^ar_ea^_be_cause the cost of solving current water pollution
problemswould not only be exhorbitant, but would"most likely^require
sacrifice of the local economic base. Needless to say, these conse-
quences would be totally unacceptable to local communities; especially
since the 1383 goals were not ever meaningful in some parts of the
area. For example, no one cares to fish or swim amidst the ships and
barges in the Raritan Bay„
B. Plan Approval and Implementation
Most people were quite optimistic about the likelihood of plan approval
both by local communities and the State. The Project Manager based
his optimism on what he perceived as a sound public involvement program.
He and a citizen member of the Policy Advisory Committee felt that
general community in the program was running high and that local input
into the process would insure widespread approval of the final plan.
One local elected official felt that local communities would approve
the plan because there were few perceivable negative consequences,
j at least at this time. The fact that the WQM agency is concentrating
I on the use of existing institutions rather than new, regional bodies
lhas helped. A few interviewees felt that concern over an imminent
1 |wate shortage would prompt most local decision-makers to approve the
plan if for no other reason than to protect their political positions.
On the other hand, one citizen voiced considerable concern over the
fact that local elected officials were not concerned about or involved
iii the process. She felt that active attendance at PAC meetings
by industries, environmentalists, and other public interest groups'
would not compensate for the absence of public officials when the
time for plan approval arrived. Optimism on the State's reaction
to the plan ran high among interviews because of generally perceived
MC-18
-------
close working relationship between the WQM staff and the State DEP.
Most people felt that this relationship provided adequate occasion to
overcome any differences of policy along the way. As long as no
conflicts arose, and the plan did not place a financial burden upon
the State, no problems were anticipated in State review and acceptance.
The one exception was voiced by the State Liaison who chose to reserve
judgement on the issue until he could assess whether the plan required
an additional legal basis for implementation.
On the subject of legal foundations, the Project Manager and the State
legislator's assistants concurred on the need for additional State laws
and local ordinances in the areas of mining, oil exploration, land
management and particularly urban storm water management. They indicated,
however, that actions toward securing this legislation could be deferred
without affecting approval or implementation of the plan. Most inter-
viewees felt there was a sufficient legal basis for implementating the
final WQM plan - that the real problem was one of directing and prompting
enforcement of existing powers and authorities.
The interviewees ranked the likelihood of implementation only slightly
lower than that of WQM plan approval. Among the possible problems they
felt might arise and hinder implementation were:
o Lack of program understanding by some local elected
officials;
o Prohibitive costs;
o Opposition of interest groups such as developers and
industries;
o Disagreement on tradeoffs between environmental and
economic considerations; and
o Opposition from local rights groups.
However, with the exception of one citizen and one local elected official,
most felt the WQM program's public involvement program would deal with
these problems before the implementation period began.
C. Continuing Planning Process
The outlook on continuing .planning varied by type of person interviewed.
The Project Manager, Assistant Executive Director and two of the three
citizens felt that, if money was available, planning should and would
continue since the need for continued technical studies and public
education will persist beyond the two year sLudy time-frame. Two local
elected officials voiced radically different opinions. One felt that
WQM planning should not continue beyond the initial planning period be-
cause of the cost involved. In his opinion, continued planning would be
MC-19
-------
no more than a worthless duplication of effort - a problem common to the
Federal government and to be avoided in Middlesex if at all possible.
The other local elected official felt that the initial WQM plan would
be sufficient unless a dramatic change in the economy facilitated more
implementations, thereby necessitating more planning. All interviewees
assumed that continuing planning would be conducted by the MCPB.
According to the Project Manager, continuing planning will be concerned
with further identification of unaccountable point source pollution,
particularly from toxic and hazardous wastes and residual waste disposal.
It will also delve more deeply into the issue of preserving drinking
water supplies.
The Project Manager was unable to fix a cost on continuing planning. The
Assistant Executive Director, however, noted that it may be rather high
if the agency tries to deal with land use in highly populated areas.
He assumed that the County Board would supply some of the money needed
to finance continuing planning, but that the source of the remaining sum
was questionable^ The Project Manager stressed the absolute necessity
for Federal money and felt reasonably certain^ that this money would be
made available, if not immediately after plan completion, then sometime
soon after.
D. Relation to Other Water Quality Programs
According to the Project Manager, WQM planning will have little if any
effect on 201 facilities planning since most of the area is already
sewered, in the process of planning municipal water treatment facilities,
or has applied to do so. If all of the proposed facilities plans
materialize, there will be little need for additional work in this area
except to recommend upgrading where needed. Even this role will be
limited, according to the State Liaison, because the WQM study is not
conducting the level of^echnjlcal studies needed to^thoroughly substantiate
their reocmmendatlons. Without sufficient data, the State would never
act upon WQM^suggestions.
The primary agent for 201 planning in the County is the Middlesex County
Sewerage Authority. The Director of the MCSA felt that the WQM plan
might effect his activities indirectly through its land use elements.
If the WQM management agency has authority over the location and timing
of land use, the timing and the expansion of MCSA's capacity could be
directly effected. He felt this was also possible with regard to storm
water management.
MC-20
-------
As to the NPDES program, the Project Director indicated that the role
of the WQM agency will be to review industrial and municipal point source
permits. He felt the State would be forced to rely on the WQM agency
because the agency will have better data than the State by the end of
its two year planning effort. The State Liaison acknowledged the value of
the WQM information jn issuing and renewing permits. However, his per-
ception of the WQM agency's role in NPDES is much more passive than that
of the Project Manager. According to the State Liaison, data produced
through the WQM model will be interpreted by the State, not the WQM agency.
E. Local Definition of Success
Definitions of success seemed to center around two issues: prevention of
further degradation and involvement of the public's. In the opinion of
a local elected official and a State legislator's assistant, a WQM
success would be meeting the ultimate 1983 goal. However, since success
has to be measured in degrees, they would be satisfied if water quality
conditions were first stabilized at their present condition. Any improve-
ment beyond present conditions would be a bonus. The Project Manager
shared their view, expressing a particular concern for maintaing some
recreational and wildlife resources which are currently few and precious
in the designated area. An appointed'official felt the WQM agency would
be successful if it took into account development which had been unchecked
in the past and if it helped implement a more economically meaningful
system of land use controls that would eliminate further degradation and
need for additional treatment facilities. The only person to take a
less flexible stand was the State Liaison who defined success in terms
of meeting all of the WQM agency's goals and objectives outlined in
the work plan. He felt that the WQM program would be especially successful
if it generated useful information on the area's stormwater problems
and the secondary impacts of land use patterns.
One local elected official and two citizens defined success in terms of
establishing and operating a meaningful public involvement process.
For the local elected official, this constituted a real challenge since
he felt it will be very difficult to convince participating "cities and
towns to cooperate in a regional apx^roach to problem-solving. For the
citizens, true responsiveness to public involvement has been minimal, if
attempted at all, in other planning programs. Whether or not the WQM
process changed this pattern would determine success in their estimation.
MC-21
-------
Among the direct and indirect benefits expected from the WQM program were:
o Improved recreational potential;
o _ Presearvation of drinking water supply and quality;
o . Maintenance of the current economic base;
o Maintenance and/or enhancement of quality of life; and
o Possible increase in property values.
Among the more basic long-term benefits were increasing the public's aware-
ness of water quality issues and augmenting the data base for future planning.
MC-22
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
There was a general consensus among WQM staff members about the goals and
strengths of the Middlesex project. All agreed that the overall objectives
of the WQM study are to heighten public awareness of water pollution
problems and to promote a regional approach to problem solving. All felt
that the Middlesex project was the best in the State because of its
comprehensive approach to planning, its emphasis on implementation and its
elaborate structure for public involvement.
Since most of the technical data gathering, modeling and analysis work
is being conducted by outside consultants, staff members viewed the WQM
program [Ifrom the perspectives of management/institutional planning and
public involvement. They considered these the most crucial roles in the
program because of the area's extremely complicated institutional setting
and the anti-regional attitudes prevalent among most loca] elected officials.
All voiced a common concern that current efforts at public involvement
were not reaching local decision-makers and that this would cause problems
when the plan comes up for final plan review and approval. The staff felt
some frustration in selecting the most appropriate approach to their pro-
blems. One staff member expressed a need for more coordination among
work elements and tighter overall program management. Presently, some
staff people felt isolated in their position and thereby hindered in, their
ability to most effectively carry out their duties.
The Project Manager shared his staff's concern over poor participation
of local elected officials. However, unlike his staff, he felt confident
that informal contacts through newsletters and phone calls were keeping
them well informed of program progress and would balance out their
current lack of active involvement. He also felt that the agency was
doing all that was possible to run a smooth effective program. He
attributed most of the agencyj^ problems _to__an insufficient start-up
time which impeded maximization of time and funds.
The Project Manager viewed the WQM project as more of an integrated
whole than did his staff. As the direct link between the WQM program and
the MCPB's comprehensive land use planning effort, he recognized the WQM
project's unique opportunity to influence future land use decisions with
water guality concerns. Even if the WQM program does not continue on
a large scale after the initial two year period, he indicated that the
data collected and the contacts made during that time would have an
effect on the area through other MCPB's planning activities.
MC-23
-------
B.
Citizens
Three citizen members of the WQM Policy Advisory Committee were interviewed.
One was a representative of a large manufacturing firm; another was the
owner of a local marina; the third was chairperson of a local environ-
mental commission. Two of the citizens were very pleased with their
roles in WQM planning, indicating that the WQM staff was very receptive
to their ideas and suggestions. These citizens felt that the public
involvement program was particularly successful because it was divided
along sub-basin lines, thereby making it easier for people to relate to
the program through problems and issues of local importance. They were
also pleased with the balanced representation of environmental and
economic interests which facilitated discussion and compromise^between
-the two groups.
Unlike the first two citizens, the third citizen was very vocal about
her dissatisfaction with the public involvement process. She felt that,
earlier in the program, pre-arranged meeting agendas left no room for
open discussion, thereby eliminating the public's chance to influence
program direction. The agenda problem was apparently resolved as the
program progressed. However, she still felt that public involvement was
too heavily directed by the WQM staff who "insulted the publics intelli-
gence" by limiting discussions to only the most elementary levels. She
wanted to hear more about the technical data which supported the staff's
recommendations. Her suggestion was to occasionally hold joint meetings
between the Technical Advisory Committee and the PAC and to require some
technical staff attendance at all PAC meetings to answer the public's
questions.
The industrial representative also mentioned that some PAC members were
dissatisfied with what they considered a one-way flow of information,
rather than a two-way exchange of ideas. In his opinion, however, WQM
technical information was generally beyond the technical understanding
of most committee members. In fact, he felt that the people who serve
on the PAC represent such narrov; self-interests that there was no need
to include them in the WQM planning process. In his opinion, the only
true spokesmen for the public as a whole are local elected officials.
All three citizens felt that local elected officials were not sufficiently
involved in the process. Each expressed concern that lack of local interest
might seriously impede final plan approval and implementation, since the
area is generally opposed to regionalism and fairly unfamiliar with the
types of issues the WQM program raised. They also felt that failure to
address the chemical waste disposal issues would diminish the WQM study.'s
credibility.
MC-24
-------
C. Local Elected Officials
Two local elected officials were interviewed; both were representatives of
sub-basin committees of the PAC. According to one official, the issues
raised at PAC meetings were appropriate but the manner in which they were
presented clouded their meaning and disguised their political and economic
consequences. This frustrated many committee members and discouraged
local elected officials' participation. All committee decisions to date
were made on a consensus basis with little (if any) controversy. He anti-
cipated more debate and possibly more interest, however, when actions
involving trade-offs come into focus.
The second elected official was not actively involved in the public
involvement process, nor did he feel the need to be, since his community
was already highj-y developed and therefore would not be effected by
land use controls or other anticipated WQM outputs. He also felt that his
community was too small (1.6 miles) to be of consequence in the total
water quality management scheme. As far as he was concerned, responsi-
bility for water quality management rests in the hands of the County.
In general, both officials noted that antipathy toward regionali-sm was
common throughout the designated area. Both felt that the WQM program
was not producing, or circulating sufficient evidence to convince local
elected officials of the need to cooperate on water quality issues. They
felt that air, for instance, was more widely acknowledged as a major
problem, and that ameliorative programs in this area were, therefore, more
likely to receive local political and financial support.
D. Appointed Officials
The Executive Director of the Middlesex County Sewerage Authority
described his role in the WQM process as one of overall cooperation and
active technical support to the WOM staff and consultatnts. The Director
indicated that EPA Region II had originally considered the MCSA the most
logical candidate for WQM planning since it had conducted most of the
area's 201 planning, possessed the most complete water quality and land
use information in the area, and was already empowered with regional
management authority. However, since the MCSA's enabling legislation
would have to be changed inorder to conduct WQM planning, the MCPB was
selected instead.
The Director indicated that he was pleased to have been of assistance in
WQM planning. He expected that MCSA's advisory role would continue into
the management phase in the form of:
MC-25
-------
o Review of population projections;
o Identification of industrial pollution sources; and
o Sale and dispersal of treated effluent for industrial
processing and cooling water.
He felt that WQM waste load allocations would influence plans for future
waste water facilities but that 201 decisions would ultimately remain
in the hands of the MCSA Board of Directors unless a substantial change
in legislation was made. He also felt that WOM implenentation would mean
more money for MCSA and more 201 work.
E. State Legislators
The State legislator selected to participate in the evaluation study was
not available at the time of the site visit. His two legislative aides
acted as spokesmen in his behalf.
The Senator's interest in WQM planning stemmed from his overall interest
in environmental affairs and more specifically from his membership in
the Agriculture and Environmental Committee and chairmanship of the
Finance and Appropriations Committee. He made speeches on behalf of WQM
planning at the time of MCPB's designation and continued to speak on the
program's behalf throughout legislative discussions. The Senator was not
directly involved in the WQM process but that he was kept in contact with
the program through his aides who regularly attended sub-basin PAC
meetings.
According to the aides, the Senator was the only State legislator to take
an active interest in the Middlesex WQM program and, therefore, was
about the only one aware of the program's intentions and activities.
Most legislators are simply too busy to get involved becasue of their
existing responsibilities and the number of other issues competing for
their attention. As in most other States, New Jersey legislators tend
to rely on the recommendations of special committees when decision-
making situations arise.
In the opinion of the aides, water quality currently ranks low among the
State's needs and priorities. Without improvement in the tax structure,
they felt there was little hope for continuing State financial support
of the WQM program.
F. State Water Quality Personnel
The current State Liaison to the Middlesex WQM project has begun to take
an active role in the process. Unlike past Liaisons from the DEP, this
Liaison attends WQM staff meetings regularly and is present at PAC
meetings where he renders technical advice and explains State policies
MC-26
-------
when requested. He has found the WQM agency generally receptive to his
suggestions but not as receptive as they are to EPA's guidance and
directives. His implication was that he would like to change this
situation and indeed felt more confident about playing a more influential
role now that 303(e)'s were firmly underway. According to the Liaison,
water quality planning had a low priority in the past but with WQM and
heightened public awareness, he expected the State to take action in areas
WQM agencies indicated.
MC-27
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
The Middlesex WQM program is operating within a highly complex urban,
industrial and institutional setting where continuation of water supply
is threatened, recreation and aesthetic resources are disappearing, and
demands for expanded facilities are constantly increasing. In the eyes
of the Middlesex County Planning Board, therefore, the comprehensive
scope of the WQM program was tailored to their needs. The MCPB designed
a work plan that addressed a broad range of water quality problems, and
both structural and non-structural solutions to these problems. The
land use studies are particularly relevant to the comprehensive parent
agency's county land use efforts.
The Middlesex WQM work plan clearly addresses all the program requirements
ments and suggestions of EPA and the law itself. But the problem with
the approach is that it may be too ambitious for the two year planning
timeframe. Given the area1s dearth of water quality data, magnitude
of water quality problems, complicated institutional setting and general
anti-regionalism sentiments, the program may have been wiser to focus
on a limited number of problems; particularly those identified by the
public as most important and worthy of immediate attention. The WQM
project could then concentrate more time on management planning and local
elected officials' involvement.
Problems with the WQM work schedule were already in evidence at the time
P.f_the_in1;eryiews.,„ ^Management,planning^ had,J)een jset^back because.,of
late consultant technical reportsAs a result of this delay, the WQM
staff may have to limit its data analysis and management planning in order
to' produce a plan on time. Whether or not the staff can now complete
all it originally planned to do is rather questionable, especially since
it will have to reserve some time for plan approval.
To date, efforts to ensure plan approval have relied on the rise of
policy advisory committees, surveys and newsletters. These mechanisms
have been somewhat successful with special interest groups and industries,
but have failed to reach local elected officials. The staff has tried
to compensate for this problem by making a few direct contacts and by
mailing newsletters and memos to public officials, but the interviews
suggest that these efforts have proved less than successful. One local
elected official, for example, felt that the designated area'swater
quality^ problems were too complicated to be effected by his torn1s
action or lack of action. He seemed to expect that other towns or the
MC-28
-------
County would take positive steps thereby relieving his community of the
burden. Judging by the attendance of local elected officials at PAC
meetings, his sentiment is evidently shared by others.
The Project Manager acknowledged the problem but was relying on
controversies surrounding the development of plan alternatives to arouse
more attention from local elected officials. The program, however, may
not be in a position to take such a risk since there is so little time
at the end of the program to convince local communities to take
affirmative and cooperative action. Widespread plan approval will be
difficult to secure if the plan proposes controversial action such as
stricter land use controls or further regionalism which preliminary studies
have suggested. The likelihood of plan approval may also be hindered
by the fact that the WQM study did not address the environmental/health
consequences of toxic chemical waste disposal which is of primary concern
to the area. Failure to speak to this issue may lower the credibility
of the study in the opinion of some persons interviewed. As to plan
implementation, the staff may be dismissing potential problems too
lightly. There is little evidence now that more than a handful of
towns feel enough immediate need to take action,^esjpecially_since_the_
incentive of 201 money is not a factor and since there is no financial
planning to help local communities finance nonstructural solutions where
additional funds will be needed. These and other unresolved problems,
particularly those related to anti-regional sentiments, may make chances
for implementation somewhat dim except in the most innocuous and most
visible issues.
B. Public Involvement
The Middlesex WQM program has designed an elaborate public involvement
program to involve the general public, public interest groups and local
elected officials in the planning process through sub-basin Policy
Advisory Committees, surveys and newsletters. The indication from at
least some of the interviews, however, is that the program is not as
effective as one might expect. The two surveys were involved because
of misdirections and a low response rate; the newsletters have experienced
irregular publishing and the committee meetings leave much to be desired.
Citizen input on selection of program goals and objectives, for example,
was untimely and too elementary to be of much use to the public or the
WQM staff. Most of the PAC meetings have continued to be a one-way flow
of information rather than a two-way exchange of ideas. Meeting agendas
are still primarily pre-determined by WOM staff with little opportunity
for the participants to raise questions. When questions are answered,
some citizens feel that the staff is withholding information because they
underestimate the technical capability of the public. The public
participation person, on the other hand, is a junior staff person who,
like other junior staff, has a compartmentalized view of the program and,
therefore, is often unable to answer hard questions on technical issues
or policies.
Although attendance at PAC meetings is still higher than at other
advisory meetings sponsored through the MCPB, attendance is diminishing as
the program progresses. The first to leave were most of the local elected
MC-29
-------
officials who responded to early invitations to participate. Only
a few remain active in the PAC.
Despite the fact that the PAC's have only attracted environmentally -
oriented interest groups and individuals and industries which stand
to be effected by the plan, the WQM program continues to concentrate
all of its public investment staff time and money on these sub-basin
committees. , The lack of local officials involveme nt_in_PAChas been
one of the greatest failings of the public involvement program since
there is no other method for soliciting their input. The Public
Involvement Specialist has tried to keep them informed of program
progress through newsletters, but this does not provide an opportunity
for them to raise their questions or resolve their disagreements with
the plan. This may present a problem at the time of final plan review
and approval.
C. Current Planning Process
As noted earlier, the Middlesex WQM program is geared toward a
comprehensive look at the area's water quality problems and possible
solutions. Since it had little basic water data with which to plan,
the WQM agency chose to concentrate a substantial period of time on
technical studies. This action is understandable in that the agency
needed this data to develop management alternatives and to gain credi-
bility in the eyes of local communities. However, in trying to tackle
such a wide range of issues, it j^uldnJt_studyatan^problem in depth
and it lost time from management planning.
Rather than hire in-house technical expertise, the agency decided to
contract out for sampling and modeling. This decision was probably
the most efficient view of the fact that the consultant already had a
working model for-the designated area. However, heavy reliance on
consultants meant that a large portion of the qrant^and^study was
outside of the WQM agency[s direct control. This has led to problems.
Delay in technical studies, for example, has set back management planning
thereby leaving very little time for plan approval.
The problem with the Middlesex WQM planning process seems to be that
the agency has not been flexible as problems in the original work plan have
become evident. If the agency can become more flexible over the
remaining year, particularly by concentrating on a few issues of
widespread concern and by making a more efficient public involvement shift
away from the general public and into local elected officials, the program
may still have time to register some successes. More specifically, the
WQM program may influence a few immediate management practices and pave
the way for continued, meaningful water planning.
MC-30
-------
D. Continuing Planning Process
The interviewees' attitudes toward continuing planning seemed to reflect
their understanding of the program's intent and tneir attitude toward
implementation. Those who perceived the WQM project strictly as a data
gathering study to be stored on a shelf saw no need to continue planning
beyond the two year period- Similarly, those who felt that the cost of
plan alternatives would limit implementation considered further planning a
wasteful extravagance since nothing additional could be done until more
money was available for implementation. On the other hand, those who
perceived of the WQM plan as a true management tool felt that the planning
process should continue to analyze the data collected and to develop
cost effective solutions for changing problems and needs,
The Project Manager was uncertain about the future of WQM planning.
However, he suggested that if it did continue, the staff v;ould concentrate
on those issues which were not sufficiently covered during the first two
years and which could not even be addressed at that time due to a limited
budget and study timeframe. He hoped that local officials would become
more active during continuing planning especially since more specific
issues could be dealt with at that time.
E. Significance of Local Elected Officials Involvement
As noted earlier, local elected officials have not taken an active part
in the public involvement process. All communities signed resolutions
of interest to support designation of the MCPB as the WQM planning agency
but this resolution was not legally binding and did not oblige local
elected officials to become involved in the WQM study. Whether or not
development of plan alternatives arouses their interest during the second
year remains to be seen.
MC-31
-------
AGENCY:
MID-WILLAMETTE VALLEY COUNCIL OF GOVERNEMENTS (MWV-COG)
REGION: X - (Seattle)
GRANT AMOUNT: $446,300
GRANT RECEIPT: June 6, 1975
STARTING DATE: November, 1975
STATUS AT TIME OF INTERVIEWS: Work plan approved. Consultants hired and
working on technical and management task elements.
Citizen involvement program had not yet been
designed.
REASON FOR INCLUSION IN SAMPLE: This area has a significant number of nonpoint
source problems, particularly ones related to
agriculture.
MW-1
-------
I. BACKGROUND1
A. Area Description
The designated area includes thirty-three towns and cities and three
counties in the State of Oregon. The first two counties constitute
the Salem SMSA. The tri-county area comprises Oregon's Administrative
District III. Geographically, the area lies mid-way albng the Willamette
River which stretches north to south in the Oregon, comprising part of
a rich, fertile agricultural valley. Nearly 70 percent of the state
population lives in the full valley. To the north lies the Portland
area and to the south is the Eugene SMSA.
The -1970 Census population of the area was 226,871, with over half living
in the county of Marion. Approximately 67 percent live in urban areas.
The least populated portion of the area is Yamhill County. The rate
of area economic and population growth is significant, with the latter
over 3 percent per year, which is expected to double by year 2000.
Industrial activity varies widely by county. The largest industrial
activity in the area is food processing, which occurs primarily in
Marion County. Marion County also has a large amount of employment
in metal fabrication and paper products production. Lumber and wood
products provides the major employment in Polk County, while the
agruculture economy is expected to expand. The area is one of high
growth which is under significant development pressure. The timber
industry obviously is related to building and development. Too often,
however, people do not think of development in terms of its impacts.
Fortunately, the area is well zoned and there is a growing understanding
that land is one of the area's greatest assets.
There are two referenda on the November ballot which could have signi-
ficant impact on the WOM project. The first calls for elimination of
land use planning and the second calls for elimination of all COGs.
The opposition is directed towards MWVCOG. The former referendum was
prompted by the former LCDC Director's treatment of elected officials.
The anti-COG referendum is a reaction to some actions taken by Portland
CRAG to strengthen their powers. There is no general consensus about
the outcome of these referenda, although some believe it will only de-
pend upon the semantics in the referenda.
1
Information for this Chapter was taken from designation application;
work plan; Mid Willamette Valley Council of Governments Budget, 1976-77
and interviews.
MW-2
-------
B. Water Quality Problem
All twelve of the stream segments in the planning area have been
designated Water Quality Limited by the State, in the River
Basin Plan. In most cases, this is due to high coliform counts
and low dissolved oxygen levels due to inadequate flows and
changing periods of high summertime temperatures. In the North
Santiam, the classification is used for nondegradation since this
is a water supply source.
This area probably will face significant diffuse source problems
in the future. Expanding agricultural land use will increase the
use of fertilizers and irrigation water. In addition, project
population increases will require land use controls and wastewater
management techniques to prevent overload and degradation of Rick-
reall Creek and the Yamhill and Pudding Rivers. Point source con-
trol through allocations will be inadequate for meeting non-degra-
dation since the increasing nonpoint sources will be uncontrolled
by existing programs.
Some specific nonpoint problems in the area include combined
sewer overflow in the Salem area, groundwater pollution in Labish
Village and Turner, septic tank leakage in isolated area, construc-
tion runoff, and a variety of agriculture-related practices inclu-
ding irrigation and fertilization. The area's point and nonpoint
problems are complicated by lowflow conditions in the summer.
The three areas of highest priority will be the Willamette,
Pudding and Yamhill river basins because of their size and location to
future populations. Of somewhat less importance are the Huckiamute
River, Rickreal Creek and Ash Creek basins.
C. Designated Agency
The Mid-Willamette Valley COG was created in 1967 by the merger
of two intergovernmental organizations which had been in existence
for a decade. The Board of Directors is composed of the chief
elected officials of each member government — Chairmen of Boards
of Commissioners for each County, Mayors of each city and elected
chairmen of Special Districts — plus' an appointee of the Governor.
The COG provides staff and controls the administration of zoning
and subdivisions for both Polk County and the City of-Salem. It
also provides planning services to seven other cities and towns
and to a school district on a contractual basis. The COG conducts
MW-3
-------
planning in the following areas:
o Manpower;
o Criminal justice;
o Transportation;
o Aging;
o Human resources; and
o A-95 review.
The State recently passed a land' use law establishing the Land
Control Development Commission (LCDC). The LCDC prepared a set
of 14 development goals and contracted regional agencies for imple-
mentation. MWVCOG is the agency contracted for the Mid-Willamette
Valley area.
According to the Executive Director, these programs are all related.
For example, he sees WQM as one way to help strengthen the areas'
economic base. Most of the COG planning activities are coordinated
through the Regional Planning Department. The WQM staff consists
of a Project Manager plus three other professionals assigned to
the three major subplans anticipated (point source, nonpoint source
and management).
Before starting the WQM program, the COG prepared a Water Quality
Management Plan which was designed to achieve a cost-effective metho-
dology for evaluating sewage treatment and point source management
systems. This plan was never adopted officially but was used by
the State for granting permits. Another important and highly re-
lated COG activity is the recently established Urban Growth Boundary
and Policy Program. This innovative program, which was accepted
by the counties in 1974, created an urban growth policy for urban/
rural structure up to a capacity of 330,000 to be contained within
a definite boundary line. Urban service boundaries were asigned
and will be used to help carry out the policy.
Program guidance is provided by two committees. The first, a
Regional Planning Committee (KPC), consists of 13 members from
City and County Planning Commissions, County Commissioners, Mayors,
Soil and Water Conservation District representatives and two
at-large members. The second committee (ATAC) is composed of
28 technical representatives from Federal, State and local agencies.
MW-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The most basic objective of the WQM program is to set up a strategy
for the area to maintain its water quality. It is hoped that this
will begin an assessment process for the entire range of environmental
issues and provide a cornerstone for centralizing all environmental
concerns. The specific goal is to ensure water quality for a 20
year period.
Water quality is not a high priority goal in the areaibecause most
people do not perceive a water quality problem. A statewide battle
to save the Columbia River was fought in 1968 and most people be-
lieved that high water quality has resulted. Oregon has been known
for its concerned attitudes toward its natural resources, and if
any immediate problem became apparent, people would become committed
to resolviny it.
B. Technical Component
A second major task involves development of technical plans, par-
ticularly for municipal facilities. A series of technical memos
describing existing systems and their associated industrail^loads,
present and future, will be generated. 201 plans and needs for
two and five year increments will be indicated. Alternative struc-
tural and non-structural solutions for controlling wastes will be
outlined to include financial, institutional and management pro- .
cedures and priortization of future facilities. Each of these task
elements will be summarized in a separate technical memo. A residual
waste program also.will be studied and designed. .The second technical
sub-plan involves urban storm runoff and combined sewer problems.
The problem will be described and structural and non-structural
alternatives evaluated. These sub-plans will, comprise the point
source plan.
Nonpoint sources will be addressed, particularly those relating
to agriculture, silviculture and construction. A pilot study will
be conducted in South Yamhill basin and management practices will
be evaluated. Pollutant loadings from land uses and critical areas
will be estimated as will land use conversions. Basin-wide priorities
will be determined and results of the pilot study will be applied
to these areas. Areawide application including cost will be analyzed.
A second pilot study will be made of an area with septic tank
failure problems. An areawide priortization analysis similar to
that followed in the first pilot study will also be conducted. The
MW-5
-------
third study are will concern solid waste problems related to
water quality and this will result in a management plan for
future disposal needs.
For the point source sub-plan, two consultants have been hired, one
to do the urban stormwater runoff analysis and the other to con-
duct the industrial wastewater analysis. A staff person will
analyze areawide wastewater and residual wastes. The three counties
have been contracted to product land use data, population projections
and urban service boundaries.
Polk and Yamhill counties and the Soil and Water Conservation
Districts have contracted collection and analyses data for the South
Yamhill River basin pilot study. An environmental geology and
groundwater firm will analyze the areawide problem for septic tanks.
C. Management Planning
The third task calls for developing an overall management plan.
After compiling an inventory of existing institutional arrange-
ments in the tri-county area, existing deficiencies will be calcu-
lated and a final plan combining both point and nonpoint sources
will be delineated. This will include financial and regulatory
alternatives. The output will be a series of technical memos.
A consultant firm has been hired for management analysis and, at
the time of the interview, they were inventorying existing agencies
and the financial capabilities of all communities. No new insti-
tutional arrangements are expected to be created, so the emphasis
has been placed on developing workable relationships with, and
support from, local elected officials towards a continuing
planning process.
Management planning is being approached as a loose consortium of
tasks within the entire workplan. Basically, the program will
delve into a few concrete, issue-oriented areas. Management
planning has lagged somewhat behind technical planning but the
two are currently proceeding together.
Some specific management issues are beginning to surface. One
relates to management of the four proposed regional treatment
systems. A second relates to agricultural controls, primarily for
sediments (currently/ there are no State sediment standards).
A third management issue relates to management of subsurface
disposal. State laws do not go far enough, and the existing laws
relate only to new tanks. A fourth management issue concerns the
need for criteria pertaining to land disposal of sludge. The
staff is beginning to set priorities for examining these and
other issues.
MW-6
-------
D. Public Involvement Program
Currently, there exist three advisory committees point source,
nonpoint source and management. Each committee has twenty
members, all appointed by the Regional Planning Council. A
fourth committee on public involvement has just been approved.
A nine member Ad Hoc Committee has been formed for the purpose of
establishing a public involvement program. Although its members
had not been appointed at the time of the interview, the committee
representation was intended to reflect the impacted public. Its
membership included representatives of an industrial lobby group,
labor (cherry workers or cannery workers), small communities, the
counties, environmental groups, the State Extension Service, the
Regional Planning Council, the County Planning Department, and
agriculture. The group will meet in a concentrated effort through
September and October until a final program is designed.
E. State and Federal Involvement
The WQM feels that they have a good relationship with the EPA
Regional Office but they are receiving little policy guidance.
They are concerned about the EPA commitment to nonpoint source
controls, and are unsure how to interpret guidelines for things
lthey feel cannot be done. The Regional Office has not interpreted
this national guidance for them. In general, most direct contact
with the Regional office has been on a bi-weekly basis with the
Oregon field representative. Other than a site visit from a
group of Regional Office persons, contacts have been made chiefly
by telephone and letter.
WQM feel their relationship with the State Department of Environ-
mental Quality (DEQ) has changed recently from neutral to positive
but, generally, they feel that State input has been minor. There
is a feeling that WQM is giving a very low_priority by the State
because they have so much work to do. There has been no involve-
ment from persons in a policy position within the State. The only
involvement has come from the regional DEQ Administrator who has
been particularly active and helpful on technical matters. The
State Liaison believes he should play an advisory role in reviewing
their outputs, but feels he should not become too involved.
Currently the State is trying to complete its 303 basin plans.
There is considerable disagreement over these plans within the
State and with EPA. It is hoped that the plans will be completed
and available to the WQM by September, 1976. The State has not
really started developing their State strategy but they have asked
the WQM Program Manager to participate in its development. Presum-
ably, this implies that they intend to incorporate the WQM work as
MW-7
-------
part of their program, however, they do not see a great role for
WQM in either 201 or NPDES.
The next most commonly mentioned problem was the constantly changing
EPA requirements. The staff feel there has not been enough guidance
and direction by the Regional Office. The State has been even less
helpful in terms of assisting with program design and enunciating
statewide policy on water quality management. Given the complexity
of the WQM program and the fact that there were no tested programs,
EPA and State indecision frustrated the WQM agency.
F. Scheduled Outputs
The first task begins with project intiation (including the pro-
ject control program; creation of areawide technical advisory com-
mittees; prioritization of water quality problems; description of
goals and objectives; and processes for monitoring progress, ex-
penditure and quarterly reports and interagency coordination) .
Data requirements were identified after project initiation. A tech-
nical memo will be generated and will explain whether field
monitoring is necessary. The final sub-task will involve collection
of this data.
The second and third tasks describing technical and management
planning were described in Sections IIB and IIC respectively. Out-
puts include technical memos and three sub-plans (a full list
of outputs as found in the work plans is shown in Exhibit I). Drafts
of the technical sub-plans are scheduled to be completed by February,
1977 and the draft management plan completed by April, 1977.
The final output is expected to be a composite area-wide regulatory
and management plan and a number of appendices i:. subplan and tech-
nical memo form. The subplan will be for sewerage, stormwater
runoff, groundwater contamination due to septic tank effluents
and nonpoint sources.
G. Achievements to Date
The starting date for the project was November, 1975. The staff
was hired in January, 1976 and consultants have been hired since
then. Approximately $160,000 of the $44 3,000 grant will be spent
on consultant work. At the time of the interview, the WQM believed
they were a few weeks behind on some of the work elements. This
is not expected to effect the schedule of the final output.
Interim outputs have been submitted and were considered helpful.
The agency felt they would have preferred to have submitted copies
of the technical memos to fulfill the interim output requirement,
MW-8
-------
EXHIBIT I
Section E
OUTPUTS
WMVCOG
The planning effort is designed to develop a number of independent reports,
studies, maps and sub-plans, all of which will be. used to complete the final
208 plan. The following is a list of major outputs to be associated with
program elements:
I. Project Initiation, Data Requirements and Data Generation
A. Project Control Program (Task IA1) ; estimated completion date,
October 1S75
B. Report on Areawide Economic Projections (Task IC1; estimated
completion date, June 30, 1976)
C. Report on Areawide Population Projections (Task IC2; estimated
completion date, June 30, 1976)
D. Report on Areawide Land Use Projections and Urban Service
Boundaries (Task IC3; esM-nrpri rnmpletion date, June 30, 1976)
II. Technical Plans Development
A. Interim Report and Prioritization of Needed 201 Facility Plans
(Task ITA3, estimated completion date, May 31, 19 76)
B. Technical Point Source Subplans
1. Municipal Waste Treatment Element v.fasK. IIAzl)
2. Industrial Waste Treatment Element (Task IIA40)
3. Urban Stovnn-rater Runoff and Combined Sewer Element (Task ITA36)
A. Residual Wastes Element (Task IIA31)
(Estimated completion date B1-B4, February 15, 1977)
C. Technical Non-Point Source Subplans
1. Agriculturally Related Element (Task IIB1-14)
2. Silviculturally Related Element (Task IIB1-14)
3. Construction Activity Related Element (Task IIB1-14)
4. Land Disposal Related Element (Task IIBI5-28)
(Estimated completion date C1-C4, February 28, 1977)
D. Combined Technical Subplan
1. Combined Point Source Planning Alternatives (Task IIC1)
2. Combined Non-Point Source Planning Alternatives (Task 1IC2)
(Estimated completion date D1 and D2, March 15, 197-7)
III. Management Plan Development
A. Inventory of Management Data Base (Task IIIA)
(Estimated completion daLe Task "L11A, July 31, 1976)
B. Combined Management Alternatives (Task III3)
1. Institutional Arrangement Alternatives (Task II1B1)
2. Financial Capability Alternatives (Task lli"I'.2)
3. Regulatory Alternatives (Task 1IIB3)
4. Ongoing Wastewater Management Planning Process (Task. 1 1 IB'i)•
5. Draft Management Alternatives Memorandum (Task 1I.JB5)
(Estimated Completion date I11B1-3, March 15, 1977)
C. Combined Management. Subplaa (Task 111C)
(Estimated completion date, June 1, 197 7)
MW-9
-------
IV. Wastewater Management Plan and Management System Selection -
Select and Prepare Final Draft Plan (Task IVD; estimated
completion date, June 30, 1977)
V. Program Management
A. Public Involvement Study Design (Task. VA3; estimated completion
date, June, 1976)
B. Revise Final Draft Plan (Task VB3; estimated completion date;
August 31, 1977)
SOURCE: Project Control Program, Areawide Wastewater Treatment Management
Planning, MWV-COG, 1976.
MW-10
-------
rather than having to meet the nine month deadline.
The agency has not gone far enough into planning to have recorded
specific achievements. Both the Executive Director and the WQM
Program Manager noted that they are beginning coordination and
dialogue between local elected officials over land use and water
quality. They see WQM as a logical extension of all that the COG
had done in the past. These relationships should provide a mechanism
for action (one local official thought one major achievement was
the fact that two counties, Polk and Yamhill, were involved in a
regional activity for the first time).
The most common problem cited by the WQM staff involves ..getting
people interested and involved^ in the program. Because the wide-
spread impression that there are no water quality problems in
the area, people, including elected officials, do not understand
the need for planning. This will be one of the agency's biggest
challenges .througout the planning period.
MW-11
-------
III. EXPECTATIONS
A. Water Quality
The purpose of WQM in this area is to maintain existing water quality.
Therefore, the "problems" to be solved involve gaining a better
understanding of future potential problems so that pollution can
be avoided. The most direct benefits probably will be in some of
the smaller creeks. Two problems in particular were mentioned:
failing septic tanks and sedimentation from agriculture and silvi-
culture.
Everyone interviewed felt the 1983 "fishable swimmable goal" could
and would be met, primarily because they are so close to meeting
standards already. Notwithstanding an occasional problem, the goal
should be met in all parts of -he area.
B. Plan Approval and Implementation
Everyone interviewed felt that the likelihood of plan approval was
8 or 9 of 10 at the local level, and 10 of 10 at the State level.
Most explained that the high chance for approval is due to both
local communities and the State participation consequently, any
differences will be worked out within the final plan. One elected
official thought it likely that other local officials would not
understand what they are approving, but that they would approve
the plan nonetheless. The WQM Program Manager felt the most
essential officials in plan approval were the county and medium
sized city officials, all of which are represented on the
Regional Planning Council.
Most interviewees felt the likelihood of plan implementation was
about 8 of 10. Everyone explained that implementation would
depend on the final plan. Most persons felt that the degree to
which implementation would occur would vary throughout the area.
One elected official rated the three counties and Salem at 10 and
other areas between 3 and 8. Similarly, the COG Director said
the plan would be substantially implemented in most of the area
but only partially implemented in others.
A local official noted that the most effective way to ensure
implementation in his opinion, would involve the EPA linking
future finding to the degree of compliance with the plan. The
citizen interviewed saw implementation being limited only by man-
datory requirements by EPA and the State. She felt that financing
would be the most limiting factor for implementing point source
plans. • Nonpoint source control would be more difficult because
it'involves land owners' rights which have not previously been
MW-12
-------
regulated. She felt, therefore, that nonpoint source control
was best achieved by a public educational process.
The WQM Project Manager was more modest in his assessment,
putting the likelihood of implementation around 6. His main
concern was that some BMP's may prove unworkable. Program emphasis will
be on the continuing planning process and on establishing a trend toward
control. He said eight of the elected officials are involved
through the KPC and 18 are involved through the COG Board. In
September, the Project Manager intends to begin lobbying elected
officials on a one-to-one basis.
It is somewhat unclear as to which new state laws or local ordinances
will be needed for implementation, since preparation of an inven-
tory by the staff and consultant is not yet completed. Local
ordinances were expected to be needed for the areas of stormwater
runoff, residual management, agriculture, and soil conservation
practices. Several persons mentioned that any silviculture regu-
lations would have to come from State law. The State could also
set BMP practices although there are already some exising laws in
that regaru.
A wide range of opinions was about the need for new laws and for
possible local and. state re.crulatory changes, were voiced:
o
The WQM Project Manager mentioned that the
area could adopt a water conservation policy
at the local level. Residuals management was
most often seen as a joint State/local problem.
o
One State legislator expected to see additional
recycling laws for paper and other substances.
(A State bottle recycling law currently exists
in Oregon).
o
The State water quality agency representative felt
the most likely changes would be in methods of
funding water quality management, such as through
bonds or revenue sharing.
o
The State legislature added that he thought the bulk
of State action would be for financial assistance rather
than new laws. He felt that the larger degree of
public identity with the agriculture and the cattle
industry prevents passage of laws that are too re-
strictive .
MW-13
-------
o The legislator also stated that he did not foresee new
legislatiion without passage of additional State
appropriations. The governor has said he would veto any
legislation that calls for local expenditures,
so the legislature is avoiding this situation.
o Finally, both legislators agreed that there is
a growing feeling that they cannot be forced by
the federal government to change their laws, given
recent defiance of federal policy by the State of
California.
C. Continuing Planning Process
Everyone interviewed anticipated continuing planning conducted
by the COG and with State review and approval. Most saw con-
tinuing planning as a link to land use planning, especially
through the State land use law. Most also felt that implenentation
should remain local with continuing planning playing only an
advisory role by overseeing implementation. One local official
felt it was possible that the counties rather than the COG would
be responsible for continuing planning.
Both State legislators were concerned that the referendum would
pass and affect both implementation and continuing planning. One was
concerned that implementation by locals would not occur and the
State would jump in because of its enforcement powers. She felt
the State had a poor record in planning, as evidenced by the way
they had "bungled" health planning.
The WQM Project Manager saw ths role of continuing planning as
four fold. First, it would ensure uniform application of the pilot
studies. He felt it was necessary to constantly monitor and
motivate the implementing agencies. Second, it should provide
a medium for a dialogue about water quality between regulators
and those regulated. Third, it would provide a means for updating
the plan and for annual certification. Fourth, continuing planning
should serve as a watchdog for local interests over DEQ and State
programs.
D. Relation to Other Water Quality Programs
There were mixed opinions concerning the effect that WQM would have
on 201 facility planning. The COG Exeuctive Director felt WQM should
be totally controlling. The State DEQ Coordinator felt there would
be very little impact because most 201 planning was either completed-
or already underway. Others interviewed felt 201 and WQM should
be coordinated. WQM would set urban growth boundaries (this has
already been done for Salem) and 201 consultants would have to use
areawide population projections and allocations. Initiation of 201,
however, would still be local, and its design would be controlled
MW-14
-------
by the State. One elected official hoped that WQM would document
other problems, for example, proving it unnecessary to utilize
tertiary treatment. The citizen interviewed expected that 201
would not welcome WQM, but that some local officials would use it
as an excuse to do what they felt was needed. 201 agencies have
been invited to participate in the WQM program and some are
active. For its part, the WQM has commented recently on some
201 plans and they are currently establishing a review system.
The State and the 201 consultant felt the WQM review role should be
limited to planning, but the WQM hoped also to conduct some tech-
nical review.
There also was mixed opinion about the impact of WQM on the per-
mit system. The COG Executive Director felt WQM should be
controlling, while the State felt there would be no impact. So
far, WQM has not become involved in permitting. There are some
local opinions that permitting is too flexible (and, therefore,
inequitable) and that possibly WQM could improve this. The State
DEQ representative, however, saw no way for WQM to become involved
in the permit program.
E. Local Definition of Success
Some of the interviewees defined success generally in terms of the
guidelines:
o "Implementing something" (a state water quality agency;
o "Meeting the 1983 goals by 1983" (citizen);
o "Establishing a system with solid political support
for dealing with water quality issues" (COG Executive
Director); and
o "An indication of future wasteloads so they know what
they have to handle" (city engineer).
The WQM Program Manager defined success in two ways. First it
would be the establishment of and support for an ongoing continuing
planning process for water quality and wastewater management in
the tri-county area. If alternatives are unacceptable, they will
be redone. Second, success would be an attempt at BMP, (i.e., any
move toward regulation).
Interestingly, the most specific and thorough definitions of success
came from the two elected' officials interviewed. The County
Commissioner hoped to see model ordinances and regulations for con-
trol of nonpoint sources beyond a voluntary level. He was parti-
cularly concerned about compliance in three areas— agriculture,
timberlands and maintenance of septic tank effluents. The City
Councilwoman also saw three specific criteria for success. Her
MW-15
-------
first concern was that new guidelines be developed for road-building
and subdivision practices. She did not think it necessary that
these be uniform, but they must be consistent in all three counties.
Second, she felt data must be generated which would identify the
major -sources of problems in the area. Third, she felt it was
essential that the WQM continue its policy role. She was concerned
about the State/WQM relation and felt the local agency, not the
State, should be in charge of water quality management planning.
A number of indirect benefits to conducting WQM planning were des-
cribed by interviewees. The WQM Project Manager felt that it pro-
vided a forum for discussions on equity and economics, for public
awareness, and for persons to plead their case. He also felt that
WQM planning served as a watchdog for EPA and the State. Basically,
he felt the WQM would serve as a cornerstone for centralizing en-
vironmental concerns in the area.
One local elected official, a County Commissioner, felt that WQM
would complement the comprehensive planning process by improving
the compatabilty of development with the entire environment--beyond
just a concern for water quality. He felt the WQM study would help
locate areas for safe development. Most importantly, he felt
WQM would give people a feeling that they could control their own
destiny in all areas. He felt the costs of water quality management
would be borne by rising development costs, and by the agricultural
and timber industries.
The other elected official, a City Councilwoman, saw three chief
benefits to WQM. First, it would augment an understanding of the
valley as a single onit, regardless of political boundaries. She
saw a growing regionalism, particularly in the cities. The second
benefit was (hopefully) the development of new ways to build on
hills and ways of building less costly homes. This was believed
necessary to save the farmlands. The third benefit was a growing
understanding by the farmer that he needs controls in order
to fight urban encroachment. She saw the potential costs of
water quality management coming in the form of increased housing
costs, industrial costs, agricultural production (if insecticides
and fertilizers must change) and costs for installing storm
drains.
MW-16
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM planning effort holds a very high priority position within
the MWV-COG structure. The Executive Director, who oversees a
staff of nearly 100 persons, is intensely aware of the details of
the project and how it is working. The Executive Director frequently
speaks with numerous local elected officials and is aware of their
feelings. At this stage, the Executive Director feels 'that many
local officials are wary of the project, although none are
blatantly opposed. He finds them questioning what their role should
be.
The view most consistently held within the agency is that the chief
priority"of WQM is developing support for continuing pianninq.
The Executive Director, Director of Regional Planning and the Project
Manager all agree that they have undertaken an ambitious program,
perhaps more than can be expected within two years. If they focus
on setting up a continuing planning process, it will not matter
whether everything is completed in two years. What is more important
is "beginning a process to assess the entire realm of environmental
issues."
B. Citizens
As no public participation program has been started, only one citizen
was interviewed who, at that point, was involved in the WQM program.
This person is the citizen on the MWV-COG Regional Planning Council.
She became involved after losing a race for the state legislature
when her opponent appointed her to the RPC. She also serves on
the RPC Budget Committee.
This woman's main concern with WQM is with the public participation
program. She feels participation from active groups (League of
Women Voters, Agriculture, Chamber of Commerce) can be induced,
but has noted the difficulties in reaching these people and groups.
Public involvement also -has been a problem in land use planning.
It seems that a large-scale education program is needed.
The citizen described the experience of a Regional (15 county) Air
Pollution Agency, which she felt could be relevant to WQM. The
valley had established stricter standards than the State, and had
some problems with the administrator. Subsequently, the program
was proclaimed too expensive and duplicative of State efforts and
ultimately, it was abolished. So far, she did not feel these were
the attitudes about WQM, but it was something to consider when it
MW-17
-------
comes time for implementation.
C. Local Elected Officials
The two elected officials interviewed were knowledgeable about
their area's problems well-informed about the WQM program, in-
volved in its's planning, and highly committed to its's implementation.
They were realistic about the problems to be faced, yet optimistiic
about what could be accomplished by the program. They obviously
are the leaders in the project and can be credited for much of
what will be accomplished. Unfortunately, they were not considered
as typical of the general populous.
The first elected official is a City Councilwoman from Salem and
a member of the KPC. She participated in consultant selection,
although she believed that staff should be used as much as possible,
particularly for public participation. She is pleased that the
City is involved through the urban stormwater study. She sees
WQM as an implementing tool that complements the valley's goal of
guiding growth through urban growth boundaries. She saw WQM as
having some problems in getting all elected officials involved be
cause these officials are involved in so many other problems that
they are not fully aware of what WQM is all about, despite being
informed constantly by the staff. The Council women rates the staff
as high in both political judgement and water quality expertise
(10 of 10 on both).
The second local official interviewed is a Polk County Commissioner.
He is Chairman of the RPC, and saw WQM as tieing into all other
planning programs. He also put high emphasis on WQM as a tool
to guide development within the urban growth boundary, and as a
tool to be used against those who want to lessen the boundary.
He has been active in WQM, and spoke at the NARC Conference in San
Francisco. He believes that sanctions are essential to implementation.
For example, WQM compliance should be mandatory before receiving
a federal grant or a SCS farm plan. He strongly believes that
implementation must be more than just voluntary compliance.
He rates both the staff and the contractors highly uon their poli-
tical judgement and technical expertise.
D. Appointed Officials
The appointed official interviewed is a Sanitary Engineer for the
City of Salem. He is a member of one of the TACs (the City
Engineer is on another one), and, therefore, was involved in the
selection of consultants. He has been contacted by the consultant
MW-18
-------
and has supplied them with information. The Engineer found WQM
as "one more demand on his time". He is somewhat hesitant about
becoming too involved, but is continuing to attend meetings and
will decide later whether or not to keep going.
The Sanitation Department is responsible for operating two treat-
ment plants (one is currently being upgraded). Under the urban
growth boundary policy, the Engineer said he expects his agency
will be handling more of the area now served by septic systems.
He hopes the WQM will be able to provide future wasteload projections
so he knows what the city will have to handle.
E. State Legislators
The two State legislators interviewed were both knowledgeable about
water quality problems and WQM, but they were much less optimistic
about what could be accomplished than were the local elected officials.
They both felt there was an excellent chance.that the anti-LCDC and
the anti-COG referendum would pass, which would seriously affect
the WQM plan.
The first legislator interviewed was a State Representative from
Salem who was running for Secretary of State. She feels there was
always difficulty in- geLting'the city and county to do anything
progressive and that there is a habitual urban/rural split.
She said she knows very little about WQM and their activities, and
that most legislators don't even know it exists. Further, she
sees a rising intolerance for Federal intervention. The Represen-
tative believes that planners are constantly getting local govern-
ments involved in "Federal programs because of the lure of money,
but there are so many strings attached, not fitting what they
need or want, that the locals would be better if they did not get in-
volved in such programs.
The second legislator interviewed is a State Senator from Marion
and Lynn Counties. He was more familiar with what the State
DEQ is doing them with the WQM project, but said he was aware of EPA
requirements. The Senator was bothered by non-degradation aspects
of PL 92.500, because he sees them as counter to this area's goal
of redistributing the population into the less inhabited areas.
Realistically, he does not see the locals doing much implementation
which could mean water quality management will revert to the state
because of enforcement aspects.
Neither legislator expected WQM to result in new State laws. The
Representative felt nothing would be passed until dissatisfaction
MW-19
-------
with the land use law is settled. She felt existing standards and
institutional arrangements were adequate to deal with most problems.
She does expect continued investigation about use of fertilizers
and residuals management. The Senator saw no new State laws,
especially none that would require local expenditures.
F. State Water Quality Personnel
According to the State Liaison, WQM and the State Department of Environ-
mental Quality are working closely together. The State has
maintained an advisory role, reviewing the WQM work plan and out-
puts to make sure there are no conflicts with the State regulatory
powers. The State has not actually started developing a State
Strategy, although they have consulted all WQM Program Managers
on what should be included.
WQM is seen as another in a series of format changes for dealing
with water_qaality._ As _other. al so see it. the State is doxng _
everything "backward"^-,201, 208, 303. The 303 basin plans are
still being completed, so they are only available in draft
form for the WQM to use. River Basin plans were being done by
a consultant who did not complete them, leaving DEQ to "pick up
the pieces". DEQ was set farther behind the requirement to carry out
the NPDES program.
The State Liaison is on the Po^nt Source Technical Advisory Com-
mittee and another staff member is on the Indirect Source Technical
Advisory Committee. He assumes that the WQM agency is keeping on
schedule. He is pleased with his input so far. He currently spends
about ten hours per month on the Salem WQM project, but expects this
to increase as the committees get rolling.
The State Liaison feels WQM will have very little impact on either
facility planning or NPDES permitting. He sees the greatest value
in WQM as fighting pollution problems due to growth. He added that
WQM should establish urban growth boundaries for the various areas,
noting that, thus far, this has only been done in Salem.
MW-20
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
The agency has undertaken a very ambitious program. The area of
concern is geographically large and politically diverse. Several
consultant firms, Soil and Water Conservation Districts, local
governments, and the WQM staff are responsible for technical por-
tions of the plan which include a wide range of point and nonpoint
programs. This effort will involve extensive program management
to insure tha€ "all outputs are on time and suitable as inputs into
the" final plan. As they are now at data collection phase, it is
too early to judge the likelihood of meeting their schedule.
Acceptable management planning is the most important determinant
in whether the plan will be approved and actually implemented.
Because the main goal is to create an ongoing process for water
quality (and environmental quality) decisions-, WQM is concentrating
on developing workable relationships and support from the local
elected officials. This definitely has occurred with the two
officials interviewed. They were more than just aware of what
the staff is doing. They seem to see WQM as their own program
and are very involved, not only in those portions taking place within
their program, but also in the entire area. The elected officials
were more in favor of strict regulations than others. It is en-
couraging that the management consultant is examining financial
capaBi'lities ~of 'e^R~15ommufvit1yMost interviewees felt that elected
"officials in' general did not "understand the full implications of
WQM, but that cost,.would be. an important^determinant in whatever
h_appens. This is particularly so because currently, people do
not perceive an exisitng water quality problem. The results of
the planning program will be determined by its successfulness in
educating citizens and officials about the need for further programs.
The urban growth policy which was recently adopted by the counties
is an important aspect in any discussion of implementation in this
area. An urban/rural boundary line has been delineated around
Salem which would permit orderly growth within the urban portions
but which still retains the rural portions. Most of those inter-
viewed saw WQM as an implementation tool for this policy. This
is an encouraging sign that people are thinking about their future in
regionwide terms. The Executive Director did not see how other
programs could implement areawide WQM without first establishing
such a policy.
MW-21
-------
It is likely that nonpoint problems, specifically those dealing
with agriculture and silviculture, will be among the most difficult
to solve. This is why the elected officials believe control pro-
grams must adopt mandatory regulation programs rather than an approach
of voluntary compliance. However, it is probable that controls
will be implemented slowly, and only as their need can be documented.
B. Public Involvement Program
The public participation program is not yet underway. The WQM
agency has chosen to begin with elected officials who are involved
through the RPC, and with operating agency officials who are involved
through the Technical Advisory Committees. The public involvement
program will be designed in early Fall by a committee of "affected
groups". It is unclear whether they will pursue a program of edu-
cating the public, of involving them, or some combination. To the
extent that WQM problem areas have already been determined, it is
less likely that the public can have a role of involvement beyond
being informed and reviewing outputs.
C. Current Planning Process
The goals and objectives of the project have been determined and
defined in the work plan. Ultimately, the hope is to develop a
process that involves consideration of the entire realm of environ-
mental concerns starting with ^ater quality. A second objective
is to keep this assessment at zhe local level.
Currently, the project is at the stage of technical and management
data gathering. Data gathering is being conducted by a variety
of consultants working with the staff and other public agencies.
The project has not reached the analytical stage and consequently
has not formulated alternatives or assessed impacts.
The technical and management planning process concentrates on in-
depth analysis for selected problem areas that represent the range
of problems in the area. A regionwide management program will
be extrapolated and designed from these problem areas.
D. Continuing Planning Process
The continuing planning process should include an overseeing role
to make sure the regulatory program is implemented. The COG will
most likely be the continuing planning agency, as they have this
kind of authority. The COG does not have implementation authority
and does not anticipate seeking it. In the overseeing role the COG
expects to serve a watch-dog function for local operating agencies
MW-22
-------
and the State. The plan will be updated and certified yearly as
required.
E. Significance of Local Elected Officials' Involvement
The two local elected officials interviewed obviously were very
involved in, an committed to;the WQM project. Each will be in-
valuable in seeing the project implemented. One represents the
urban central city; the other represents a more rural county.
Their support demonstrates that the WQM project can be of value
to a range of jurisdiction^wi^hirwOie^^designated area.^
Just because some local officials were attracted to supporting
the WQM project does not mean others will be in the future. In-
terviewees repeatedly described local officials as unaware and some-
times even uninterested. Competing demands of exising problems
for staff and financial resources were believed to consistently'
outweight the importance of planning for some possible future pro-
blem. Despite this pessimism, the local officials did approve
the urban growth policy program and WQM is one way of implementing
that policy. By stressing the complementary nature of the two
programs and by pointing out the short and long-term advantages following
a WQM strategy, it should be possible for the agency to increase
interest and support from officials.
MW-23
-------
AGENCY:
Municipality of Seattle - METRO
REGION: X - (Seattle)
GRANT AMOUNT: $850,000
GRANT RECEIPT: June 19, 1975
STARTING DATE: January, 1976
STATUS AT TIME OF INTERVIEW: Work plan approved. Contracted with
City of Seattle, King County, and Puget
Sound Council of Governments for certain
work tasks. Committees in operation.
REASON FOR INCLUSION IN SAMPLE:
This agency has had a considerable
amount of experience in conducting
water quality studies. Main emphasis
of the study is an examination of
urban runoff problems.
MS-1
-------
I. BACKGROUND1
A. Area Description
The designated area boundaries include the Cedar and Green River
Watersheds within King County ar.d encompass much of the greater Seattle
area. The area is located on ar.d drains into Puget Sound. The area
also includes Lake Union, Lake Eammamishard and Lake Washington,
famed in recent years for its dramatic clean-up. Not included are
portions of Lake Washington lyir.g within Snohomish County (part of
another designated area) or the sourthwestern portions of King County
(Tacoma SMSA). Approximate population of the area was 1.1 million in
1970.
Industrial activity and employment are concentrated in the urban areas
and is dominated by manufacturing, principally aircraft and shipbuilding.
Other major industrial activity includes food processing, machinery and
fabricated metals, and lumber and wood products. METRO currently admin-
isters pre-treatment requiremen-s and an industrial cost-recovery
program to 120 industrial dischargers who discharge into the METRO
system. The few industrial dicharges not now connected are scheduled
to do so in the next few years.
B. Water Quality Problem
Interest in waters for recreation pruposes is particularly high, and yet
these same areas are threatened by increased urbanization. An in-
depth study of the area's water quality problems and alternative solu-
tions known as RIBCO, has recently been completed and is an important
backdrop to understanding the current WQM work plan.
RIBCO completed detailed water quality analysis for most of the designated
area. Although it has not all neen implemented, some of subjects treated
in the RIBCO study which will be expanded upon in the WQM study include:
o Identification of anticipated municipal and industrial
treatment works for twenty years; RIBCO studies involved
a computer simulation water quality model to describe
physical, biological and chemical processes in the aquatic
ecosystem. A land use activity allocation model was used
to determine cost effective treatment facility locations
and service areas for a twenty-year period. This work
will be adopted without extensive additions by the WQM.
Information for this Chapter was taken from the Seattle-METRO Work Plan,
Designation Plan, Prototype Flan, and Community Involvement Plan, 1976;
and interviews.
MS-2
-------
o Planning for Step II and III facilities grants over five
years; this task was completed through 1979 under RIBCO
and will be updated through 1981 under WQM.
o Identification of required urban stormwater control systems;
RIBCO completed this for flood control. WQM will do more
detail for water quality needs.
o Establishment of construction priorities for five and twenty
years; RIBCO has identified and prioritized needs for
municipal and industrial sources. WQM will identify non-
point source priorities in relation to traditional construc-
tion priorities.
o Establishment of a regulatory program to control point and
nonpoint sources; point sources are already controlled by
the METRO system. RIBCO has identified nonpoint sources.
WQM will designate implementing agnecies and mobilize
local governments to accomplish'areawide control.
Seven.of the eight water quality segments in the Green .and Cedar River
basins are classified as water quality limited. Limitations are due to
a variety of causes including: combined sewers; agricultural and urban
runoff; warm low flow temperature; saltwater intrusion; construction and
land development practices; and natural and induced eutrophication.
Under the METRO system, municipal and industrial systems deliver their
wastes to METRO for treatment and disposal. Component agencies contract-
ing with METRO for this service include thirteen cities and towns,
eleven sewer districts, two sewer and drainage districts, two water
districts and a State park. METRO operates four primary plants which
discharge into Puget Sound and one high secondary plant which discharges
to lower Green River. METRO believes there is no measurable effect
from these discharges and has repeatedly appealed for exemption from the
1977 requirements.
Stormwater has been recognized as a major problem in the area. The RIBCO
plan defines the problem and developes alternative designs for twenty-
seven sub-basins, but work is needed to make these plans implementable.
Seattle has recently separated sewers in much of the city but there are
still combined sewers in the City of Seattle as well as in Auburn and
Kent.
Other area problems which are more localized in nature and effect include:
agriculture runoff; saltwater intrusion (in the Dewanish); small lake
eutrophication; and boat seepage. No major groundwater problems have
been identified.
MS-3
-------
C. Designated Agency
METRO was first created in 1958 as the result of a citizen effort and
referendum to clean-up Lake Washington. At that time, METRO was given
planning, implementation and operational jurisdiction for waste water
management. In 1972 METRO'S authority was extended by popular referen-
dum to include planning and operation of public transportation. Finally,
METRO has planning authority for water resource management, urban drainage
management, and solid waste management.
METRO completed a comprehensive areawide waste treatment management plan
in 1964 and a public transportation plan was adopted in 1972. More
recently, METRO completed a three-year study and an Integrated Environ-
mental Management Plan (RIBCO).
The WQM planning effort is under the general direction of METRO Executive
Director and the Director of Operations and Planning of Treatment
Facilities. The WQM staff has six professional members but also draws
on many of the METRO service departments for support (e.g., community
involvement). Outside consultant work is minimal but a number of con-
tractural agreements have been made with local agencies to do parts
of the work program; specifically, the City of Seattle, King County and
Purget Sound Council of Governments.
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
There is an extremely high commitment to maintaining good-water quality.
In fact, METRO'S life revolves around this goal, having first been
created to clean-up Lake Washington. The community has consisentely
backed up this commitment through bond referenda obligating funds to
control pollution. The Regional Comprehensive Plan is behind schedule
and has not been incorporated fully into the WQM. However, the two
appear to be compatible and water quality has been something of a driving
force in the current planning effort.
Individuals in the area have a variety of development goals ranging
from encouraging new industry (Tukwila); to pro-growth with only "clean"
industry (in Bellevue); to some non-growth attitudes (Seattle).
However, there is a consistent commitment to the high quality of life
and water quality.
Because there have been a number of previous studies in this area, the
WQM project's chief objective i"s the establishment of management controls.
These are being tried on a demonstration basis in Juanita Creek and
Thornton Creek/Lake Union. In addition, the WQM will prioritize water
quality problems for the first time.
To some extent, METRO and residents of the area are questioning carefully
the cost of additional clean-up. For example, the requirement for
secondary treatment is consistently opposed because it is so costly
and would result in little known benefits.1 In general, the area's
water quality is fairly high and, without a particular "crisis" or
significant demonstrated pollution, it will be difficult to sell more
/ regulations.
B. Technical Component
The work plan cannot be divided appropriately into a technical water
quality and a management planning component. Because so much of the
technical studies were conducted under the RIBCO program, the present
effort uses RIBCO data and attempts to fashion management systems in
particular areas. Monitoring is a continuing function of METRO.
Another area that people question costs versus benefits is com-
bined sewer overflows. This condition might occur four to six
times per summer. In winter it is more often, but this is not a
contact recreation time. Cost of clean-up might be as high as $200
million, plus high operating expenses with little measurable benefits.
MS-5
-------
C. Management Planning
Basically, the entire program focuses on establishing a management system
which matches needs to the existing management resources, both staff
and financial. All work plan tasks intertwine around the management out-
puts so that management planning begin immediately. METRO does not expect
to be the management agency except for wastewater treatment facilities.
In fact, they expect very few changes in the existing institutional
structure. Management planning, therefore, involves detailed examination
in two demonstration or "implementation" areas. These areas have been
selected because they are typical of much of the rest of the area's:
socioeconomic characteristics, institutional setting, and type of water
quality planning. A management approach will be tested in each area.
In the meantime, a full inventory of .existing management/institutional
infrastructure will be made of -he entire designated area and a full sez
of recommendations will be made based on outcomes of the two detailed
study areas. The final management plan ("Action Plan") will include
specific bullets indicating legislative requirements and management
authorities keyed to particular problems.
This approach is a collaborative effort that involves the potential
management agencies (City of Seattle and King County) rather than use
of consultants. These contractural agreements are considered to be one
of the greatest strengths of the program because, if successful, they
promise potential fuller implementation. The City of Seattle is con-
ducting a management study of the Lake Union/Thornton Creek area and has
already tested their approach on the weed problem. King County will
conduct a demonstration study in Juanita Basin.' In each case, an analysis
of existing management structure will be made and a management system
implemented.
In addition to these two "implementation" studies, the League of Women
Voters will investigate a case study on financial and institutiona].
settings that led to citizens turning down a stormwater control system
in Bellevue. Finally, the Puget Sound Council of Governments contract
includes an analysis of management studies related to land.
D. Public Involvement Program
The METRO area has had extremely active public participation and many
citizens have been involved through several past programs. Involvement
is so great that when METRO started the Citizens Water Quality Advisory
Committee (CKPAC) it took applications for positions. This committee
began in the Fall of 1975, but prior to this, an Interview Committee
was established to recommend an approach to citizen involvement including
proposals for membership of the committee.
MS-6
-------
There was considerable political action before the final committee member-
ship was formed, being determined finally by the METRO Council. This
committee, which meets twice monthly, will be a permanent committee
within the METRO structure.^ The full staff is fully committed to ¦
citizen involvement as an element in planning. In part, this citizen
interest stems from a very recent experience with RIBCO when they got
"stung". The plan was accepted but never approved. The level of
citizen frustration at that point, was high.
At the staff level, public participation is organized within the Public
Services Department. The three member Community Involvement Section
serves to organize committees, to provide staff support, and to serve
in an 1Ombudsman position. A separate section of the agency specializes
in maintaining close contact with local agencies and, particularly, with
local officials. These two sections have only recently begun to work
together and there is still a clear delineation of function between the
two.
The Citizen Water Quality Advisory Committee was formed to examine jointly
WQM and facility planning in an umbrella approach. So far, they have con-
centrated on acquainting the Committee with goal's and issues, with under-
standing federal requirements, and with the "208/201 tie-in". They
have been trying to receive feedback on specific area concerns; on the degree
of public on the commitment to water quality and on the economic commit-
ment. The bulk of the work so far, however, has focused on 201'planning.
In part, this is because the 201 planning deadline is earlier (April,
1977 versus January, 1978), but it is also because the public finds it
more tangible and, therefore, easier to understand. The committee has
formed three Task Forces which report to the full committee, to staff
and to the METRO Council. These task forces have considered Treatment
Methods, Sludge and the Prototype Plan. Only the last is directly related
to WQM. The committee structure provides an ongoing group that is
reliable, informed and can question METRO intelligently; but does not
normally reach the general public.
A variety of techniques is being tried to increase awareness of water
programs. A series of monthly progress reports and brochure mailings
has begun using lists of over 20,000 names developed, from the voters list.
The first brochure included a survey which prompted over 700 responses.
Next, a paper culled from the first three months of citizen involvement
was prepared. For further education about the program, a film "Clean
Water Watch" was produced. Over forty requests for talks were received
as a result of these efforts and a speakers bureau has been proposed.
A second survey is projected and' a workshop ("Congress") to discuss
what also can be done about water quality has been proposed for the Fall.
Finally, a program aimed at "future voters" is presented in the school
systems.
METRO has a similar citizen group for its transportation planning.
MS-7
-------
Although METRO staff agree on the importance of public participation,
they express frustration over the difficulty of recruiting interested
individuals. Attaining public involvement is most successful when
aimed at a specific person or group. General participation is much
harder. METRO believes they have made every attempt to cover all bases.
E. State and Federal Involvement
The agency and EPA Regional Office seem to have a relationship of
mutual respect. Representatives of the Regional Office have visited
on a monthly basis and they attend committee meetings. Telephone
contacts are made at least weekly. Most guidance has been administra-
tive and little is technical. The agency's only feeling is that EPA
should play less of a regulatory role and be more involved in the plan-
ning process.
Currently the State agency is in a state of flux. They have been en-
gineer-oriented and only recently have become oriented to handle WQM
work. Thus, they have allowed the deisgnated areas to function some-
what independently while State participation has been limited. They
do, however, provide some technical help and serve as a political
force which reflects their potential usefulness.
Historically, there has been some animosity between METRO and the State
(see Section IV F). The State is dissatisfied with its position and will
try to improve their situation. Right now, their biggest concern is
inducing METRO to clarify what outputs can be expected from them.
F. Schedules Outputs
Work tasks described in the work plan fall into three major headings but
they can all be described as management-oriented. First, is a detailed
examination of management alternatives, selection and implementation of
nonpoint source controls (urban drainage and storm runoff) in two sub-
basins. These sub-basins are Thornton Creek/Lake Union, which is a
densely developed area that is unlikely to have land use changes; and
Juanita Creek, an area whose problems stem from urbanizing residential
patterns and rapid land use changes. The Thornton Creek study will address
the financial, legal and organizational problems in controlling storm-
water runoff in a developed urban area. The Lake Union implementation
area will address the problem of lake pollution caused by combined
sewer overflow discharges. The Juanita Creek implementation area
represents a condition in which unstructured urban growth has taken
place and, therefore, management solutions are more appropriate than
structural ones. These two sub-basins have been selected because their
political and socioeconomic characteristics are considered to be typical
MS-8
-------
of areawide patterns and, therefore, their experiences can be extra-
polated and used for other areas.
The City of Seattle has been contracted with to conduct the Thornton
Creek/Lake Union study. King County has been contracted to do the
Juanita Creek study. The general approach is to develop management
alternatives and test them in the sub-basins. Specific institutional
characteristics of these sub-basins will be identified and correlated
with situations throughout the area as identified in an areawide
institutional analysis. This approach was selected because it is be-
lieved that, although problems may be areawide, they are also suffi-
ciently unique to merit individual attention. This inductive study
approach will be tested by an institutional impact evaluation analysis, t
Phase I of the implementation studies includes data collectian_o.f
institutional factors of all sub-basins in the area. Phase II deals
specifically with the two implementation sub-basins. Phase III inte-
grates the findings of the detailed sub-basin studies with the known
institutional settings for the rest of the area and generates a general
areawide management/implementation strategy.
The second major work plan element is an evaluation of management
alternatives for abating problems caused by surface water runoff.
The third major work plan element will ''establish an overall management
program for an areawide program to meet total water quality objectives".
According to the Project Director, the final management plan ("Action
Plan") will itemize specific bullets for legislative requirements and
will have management authorities designated for specific problems.
Although it itemizes nearly 60 "outputs", the work plan is very conceptual
in nature. The State and EPA Regional Office has experienced some
dissatisfaction about METRO not clearly stating their expected outputs
in writing.
G. Achievements to Date
The project starting date was January, 1976 and, therefore, is in its
second quarter. According to the work plan outline, the program is con-
sidered on schedule, however, the State feels it is hard to-follow METRO
and is not sure whether or not they are on schedule. Because work is
tied so closely with the 201 planning, it is often difficult to separate
tasks to determine timing. For example, a joint 201/WQM Citizen Water
Quality Advisory Committee was established and has met several times.
In actuality, it has spent most of its time on 201 issues. Therefore,
it is' hard to assess realistically the accuracy/relevancy of a specific
schedule of tasks.
MS-9
-------
Interim outputs have not been submitted because they are tied so closely
to the 201 planning and did not fit that schedule. Of the two already
completed, no comment on either was recieved from either DOE or EPA.
Consequently, the group feels they performed a bureaucratic exercise
and is not in a hurry to complete the others. So far, both a consultant
monitoring procedure and a prototype plan have been developed and cir-
culated. Furthermore, under tha public participation program, an
advisory group has been meeting, a newsletter set up, several leaflet
mailings (with questionnaire) sent out, and a report written on what
was learned in the first three months.
The WQM Project Director listed three specific achievements to date.
The first was completion of the Prototype Plan, a bound volume where
format resembles the expected final plan; (that is, a description of
the kind of issues that will be includes behind each heading). The
Prototype Plan served at least two purposes: it provided the staff with
an opportunity to assimilate the entire outline well in advance; and
secondly, because it was widely distributed, it has given people an
opportunity to react from the cutset of the process. By its nature,
management planning is a difficult concept for most citizens and elected
officials to grasp. The Prototype Plan should ease this understanding
by providing a concrete vehicle for input.
The second achievement cited by the Project Director was the testing of
a management approach to the weed problem in Union Bay. WQM actually
has achieved something, and its. success helps spread the WQM name in
a concrete and positive way. Finally, the project will be used as a
test example for final proposals.
The third achievement cited was the level of community involvement and
an increased understanding about the program. Although increased in-
volvement was listed as an achievement, it was also mentioned as the
most difficult problem in conducting the WQM so far. This is due to
a variety of reasons.
First, because the waters are of such high quality^ people do not under-
stand why there is a need for improvement. The people feel they have
done much in the past, particularly in cleaning-up Lake Washington,
and feel they have solved their problems. Second, it is difficult
to separate the many water related projects - RIBCO, 201, WQM. Third,
management planning is so intangible, that most citizens find it hard
to understand. The agency experienced some initial start-up problems.
For example, it took a long time to establish a cooperative climate
and to draw-up memorandum of agreements with the three other government
units. Initially, there was disagreement over whether the grant should
go to METRO or PSCOG, since one a condition of the grant was that PSCOG
would be involved.
MS-10
-------
According to the Executive Director, the main problem has been in sorting
out WQM and 201 designated areas of involvement. Combined sewer problems,
for example, fit into both categories. There was general agreement
that it would have made more sense to do WQM first, but because the EIS
for METRO'S discharge permit is due to the spring, efforts have con-
centrated on facility work.
MS-11
-------
III. EXPECTATIONS
A. Water Quality
The general feeling of those interviewed was that WQM would serve an
antidegradation or maintenance function in protecting the high quality
of waters already found in the area. One citizen felt that avoiding
problems which will result from projected population increases would
be one positive result of WQM. Water quality problems that are
already known are localized and WQM will help control these problems.
The major problem being addressed by WQM is urban stormwater runoff
and combined sewer overflow. However, "solving" this problem through
use of structural solutions would be so costly that it would take years
before it could be implemented throughout the area. Management solu-
tions to urban runoff are not well enough understood at this point,
and therefore they are rarely mentioned as an expected aid for solving
water quality problems.
Everyone agreed that this area already meets the 1983 goals of fishable,
swimmable waters. The Executive Director of METRO noted that the two
areas that do not meet the goal, namely Lake Union and the Lower
Duwamish, will be helped by the WQM study. There was also general
agreement that, since WQM was serving a maintenance role, it could not
be accredited solely with accomplishment of the goal. The State
water quality agency coordinator said that chief credit goes to the local
program, to the Lake rehabilitation program, and to the State's shoreline
and solid waste programs. WQM is only attacking one part of the problem
(urban runoff and combined sewer overflow).
B. Plan Approval and Implementation
Persons interviewed agreed unanimously that there was excellent likeli-
hood of plan approval by the State (everyone gave a 9 or 10 out of a
possible 10). Some went so far as to say that State approval would
be a "rubber stamp", based on a similar experience in obtaining State
approval for the Shoreline Plan. The State Department of Ecology
coordinator agreed, saying that approval was assumed. He is, however,
somewhat uneasy because he does not feel that he has been given adequate
information about what the State is doing.
Opinions about approval at the local level were more varied, but still
fairly high (around 8 or 9). Most people said it would depend mostly
on plan content. If the plan recommends taking functions away from
locals, it will probably not be approved. Persons considered most
essential to plan approval were the "movers" on the Water Quality
Committee who will take it before the METRO Council.
MS-12
-------
The WQM Project Director predicted substantial implementation would be
accomplished (8 of 10). He hastened to add that no time constraint
could be put on measuring the implementation rate and that it would be
accomplished as funds become available. He noted that there are 25
drainage basins in the area and it would cost $150,000 for each basin
to do planning and design for controlling urban runoff and combined
sewer overflow. Obviously, these would have to be done on a prioritized
basis.
The WQM Project Director felt that the people most essential to plan
implementation are the local elected officials who sit on the METRO
Council. After them, in order of importance to helping plan implemen-
tation are officials of appointed agencies who will do the implement-
ing (Planning Commissions and Zoning Boards), special interest groups
who lobby (Audubon, Washington Environmental Group), staff and general
citizens (especially professionals). All others interviewed predicted
an unclear picture for implementation, usually giving a 5 or 6.
Everyone agreed that the biggest constraint would be financial. One
citizen was concerned that each jurisdiction has its own interests
and does not always do what is best for the whole region. The Executive
Director of METRO said he rated implementation at 50-50 because they
were facing such tough questions regarding who will be doing what (e.g.,
zoning, rate changes, etc.).
There was agreement that few State laws would be needed for implemen-
tation. One State legislator felt it would not be impractical for the State
to try to do anything about storm runoff without providing a way to
raise the money. Raising the money, however, would be an even tougher
problem. The same legislator felt that no State law changes regarding
either waste treatment or residual waste management would occur until
there was some technological breakthrough. For most other problem
areas, State laws were considered adequate but the process of enforcing
existing laws needs improvement. The mood in the legislature is toward
obtaining experience with their already progressive laws before passing
any more.
C. Continuing Planning Process
There was a variety of opinions about whether planning would be continued
after the two years, by whom and what topics would be covered. The
citizens and the local elected officials felt planning would not
continue unless additional funds were made available. One citizen
felt that there would always be more problems and never enough funds,
(so there would always be a need for this kind of planning. Most of the
'others were convinced planning would not continue regardless of funding
availability. The METRO Manager of Special Water Quality Projects
expected WQM to become a METRO long-range planning staff.
MS-13
-------
Everyone agreed that METRO - and not the State - was the appropriate
agency to conduct continuing planning. The local elected official
felt the State is too weak and that the METRO engineers are more
qualified to make decisions. The DOE coordinator agreed that METRO
was too powerful for the State to take away the planning function.
He added, however, that the State wants more say in what goes on in
designated areas. For this reason, the State will probably not designate
any other areas.
Most interviewees felt WQM would generate new policy in the area of
growth and land use. However, one citizen indicated skepticism about
this. She explained that there is constant fighting over land use by
local government members in the Puget Sound COG, most of whom are members
in METRO. Most interviewees agreed that WQM should become the basis for
NPDES permitting and 201 facility planning. Siting of 201 plants
was mentioned as one place where WQM plans could have input. Those
who were unsure of the 201/WQM relationship mentioned that the influence
of WQM and 201 would depend, in part, on whether EPA makes compatibility
with the WQM plan a 201 grant stipulation.
The WQM Project Director felt it was absolutely necessary- to continue .
planning because one of the major outputs is the recognition of a need
for coordination of management at a regional level. The scope of plan-
ning might change but management would not. The METRO Executive
Director expected the continuing planning process to address (first)
the issue of land use and (second) the issue of how much more are they
willing to pay for clean water.
The estimated cost for continued planning is placed between three and four
hundred thousand dollars per year (approximately the current level).
It was believed that $100,000 would suffice. This is in addition to
the $1 million spent yearly by METRO for monitoring. Expected sources
of funds are local, through normal revenues and new grants. The local
elected official was interviewed and is concerned about cost because
he felt people would not stand for a new rate increase. The two State
legislators interviewed felt it unlikely that money would be appropriated
to support continuing planning, except for normal funds going to DOE.
One legislator felt they may be able to get about 25 percent funding,
but in general the legislature is against new programs, against King
County, against Seattle and and against METRO. There was a feeling
that METRO can take care of itself.
D. Relation to Other Water Quality Programs
WQM is expected to have only limited effect on 201 facilities planning.
201 has been ongoing for many years and the treatment plants are already
built. The WQM/201 process is definitely out of sequence. In order
to comply with 1977 requirements, METRO is now conducting a 201 planning
project through year 2005. Although many of the elements are coordinated,
201 is, in factjthe leading force. Combined sewers is the issue where
the two are most related. The WQM Project Director noted that if allowed
to do what it should, WQM could re-prioritize funding. One of the
MS-14
-------
citizens felt that WQM should determine plant siting, and locations at
which to extend the system. But again, this would not happen for current
projects.
Interviewees were unclear what effect WQM would have on permitting,
except possibly to tie it to a more realistic schedule. In Washington,
the State has the authority for permitting. Review and initial draft-
ing for minor permits is done in the four Regional Offices. Major
permits (pulp, oil, aluminum, major idustries) are done directly in
Olympia. METRO has been delegated the permit authority for all dischargers
into their system (which will be all dischargers in the area within a
few years). Some industries - but not many - need a pre-treatment
permit as well. The DOE coordinator felt that some permits would
change, in order to get Statewide consistency, but that WQM's influence
would be limited by the State political process.
E. Local Definition of Success
When asked what constitutes success, all the citizens answered in terms
of sewer/land use relations, which probably reflects the issues that
have been discussed in the Advisory Committee. In particular, there is
a feeling that success for WQM would include: forcing accounting for
land use when planning for building of interceptors and treatment plants;
and applying further land use controls before the region's resouces
are lost. Several people defined success in terms of management needs.
One citizen said there must be a reasonable way to deal with their
problems. Going through either a totally local channel or through only
a state bureacracy would be unacceptable.
The METRO Executive Director felt that success would include plan approval
by local officials, a high level of understanding of institutional
changes, a sorting nut of roles and some implementation. He said the
final measure would be the willingness of local elected officials to
invest money in solutions along with their willingness to take restric-
tive actions. The recent passage of a user charge system for high users
(e.g., dairies, restaurants, etc.) and an industrial cost-recovery
program are evidence to him that this kind of success is possible.
Region X has required that all designated .agencies show how they intend
to implement at least 30 percent of their program by 1977. The WQM
Project Director, however, feels success should not be tied to time but
rather to quality of that being implemented. His definition of success
was in terms of reaching agreement on the solutions and then "moving to
implement".
The DOE Coordinator's opinion of success differed from most others.
He felt success would be first, if a management program for urban
runoff is•implemented in the two demonstration areas and second, if a
MS-15
-------
process is designed for applying these institutional and management
arrangements to other areas.^
WQM is seen generally as one more program in a continuum of programs
to achieve a better environment and a better quality of life.
People take pride in METRO and its accomplishments and see WQM as a
continuation of this good work. One citizen felt that an improved
environment means that people will migrate to Seattle. Young people
attracted to this king of environment and are going into the city,
improving homes and making the city more vibrant.
The other indirect benefit of WQM planning mentioned was also a continuum
function: WQM is seen as a educative tool, focusing awareness and
education in the area of nonpoint source pollutants. Because the
solution to future water quality problems rests with convincing people
to use best management practices, broad-based education is considered
essential.
The coordinator explained that a similar "demonstration" approach has
been taken in the other two designated areas of the state. In Vancouver,
the two demonstrations are in a lake rehabilitation process and in
water quality problems of the "rural fringe" where rural agricultural
lands are becoming urban and facing the associated problems (density,
taxing, open space conversion, septic tank problems and urban
runoff). In Snohomish County, the demonstration projects are establish-
ing BMP for small dairies, problems in lewlying agricultural drainage
areas, and problems of urban and industrial runoff and drainage. The
stage hopes to come up with a text book approach by which problems
similar to those being investigated by the designated areas can be
faced in the rest of the state.
MS-16
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
METRO is simultaneously conducting a major 201 project with its WQM
study. The two are sufficiently different [one deals only with point
sources, the other with nonpoint sources) to warrant separate staffs.
However, their subjects overlap to the extent that it is improtant that
all departments in the agency should be aware of what is occurring in
the others. Both 201 and WQM, for exanple, are concerned with the issue
of growth. Facility construction has a large influence on the amount,
location and type of nonpoint sources generated. Stormwater runoff and
combined sewer overflow can be seen as either a point or a nonpoint
source problem.
201/WQM overlaps in several other ways. Organizationally within METRO
the three service departments (finance, engineering, public service)
serve both water and transportation departments. Public involvement
for all programs is coordinated through two staffs — one primarily
concerned with local officials, the other concentrating on citizen in-
volvement. Similarly, there is one department for research and one for
engineering that is shared by all projects. In order to ensure that
all departments are aware how projects are advancing,"a coordinating
committee has been created and meets biweekly. Members include the
Director of Water Programs, the Manager of Special Projects in Water
Pollution Control, the WQM Project Director, Supervisor of Community
Involvement, Director of Engineering and the Head of Research. Because
everyone is informed of others' activities, METRO staff presents a
uniform view of what is happening.
The Executive Director of METRO oversees all programs. He explained
that WQM holds a high priority within METRO, although he acknowledged
that 201 is currently receiving more emphasis.-'- He feels that, in the
future, the Steering Committee, which now consists only of staff, may
be expanded to include City and County officials. The Executive
Director sees water issues as becoming more and more politicized.
Right now, the METRO Council is worried that the 201 study may force
an increase in the sewer rate; an increase they fear would not be
tolerated. He expects the WQM plan will have even more of a political
impact because it takes on even tougher questions of land use, zoning,
permitting, development and, more importantly, looks at who should
make these decisions. Although there definitely will be some implemen-
tation, he notes that WQM is actually talking about major institutional
changes.
This is because there is more money involved and because the time-
table is shorter. (April, 1977 versus November, 1977.)
MS-17
-------
The Supervisor of Community Involvement also sees the WQM project as having
wide implications beyond the initial two year study period. This is one
reason that the Citizen Advisory Committee was established as a full-
time METRO committee. Conscious of the frustrated citizen effort in
the RIBCO program, she finds her biggest problem is developing a
workable programmatic methodology that identifies and solves water quality'
problems. She feels that plan implementation, however, must involve
much more than citizen participation. Specifically, local officials
as policy-makers must be involved. A workshop to initiate this involve-
ment will be held in the Fall followed by a "Congress" of citizens and
local officials to talk about what can be done.
B. Citizens
All three citizens interviewed are members of the Citizen Water Quality
Advisory Committee and have been active in other METRO programs and
in other community planning programs.
The first citizen interviewed first became involved because of a concern
about the West Point Treatment Plant. She has been active in water
quality activities for three years and has been on committees including
the Sludge Task Force for one year. She also was involved in the committee
to create METRO and has been on other METRO committees. This citizen
feels that METRO has been conscientious in asking for and using citizen
input. Similarly, she feels that local elected officials are equally
responsive but it is too early to tell if how citizens will influence
the 201/WQM process. She sees WQM as a long-range planning effort,
concerned primarily with runoff pollution and with sewer separation.
She feels WQM's biggest concern is in enforcing a management system.
Because METRO is not an enforcement agency and because local general
purpose governments are overly concerned for their own automony, she
is pessimistic about lasting results. She does, however, see everyone
giving, at least, "lip service" to maintaining high water quality.
The second citizen interviewed was Chairman of the CWQAC. He first
became involved with METRO because of his conservation work with the
Magnolia Community Club. Also,he was active previously in RIBCO and
in the Water Treatment Advisory Committee. He strongly believes that
an active citizen group is an essential spark to getting things done.
He explained that, at the first committee meeting, citizens discussed
whether to "take a bite or nibble". At first there was some concern that
"briefings" might be interpreted as brainwashing sessions. The committee,
however, now trusts the staff and feel they know what is happening.
Since the outset, the committee has sent six resolutions to the METRO
Council." One was a goals report that tabulated anything that resembled a
community goal. Another resolution was on sludge treatment and the
latest resolution was on treatment sites. The Chairman feels that
the citizens should not be involved in the manaaemont/institution
MS-18
-------
analysis. Because of the backward timing of 201/WQM, he doubts that
WQM will handle many point source problems. He feels having perfect
water is an impossibility, but that, hopefully, WQM will provide
reasonable solutions to problems at minimum expenses and aggrivation.
The third citizen interviewed first became involved in water issues
by opposing a development construction in Bear Creek. Due to this
effort, she promised to help work towards comprehensive planning for
the county. Since then she was on the Policy Development Commission
for King County which drew up the goals and objectives for a compre-
hensive plan. She has also been on an Ad Hoc Committee that studied
stormwater controls, flood hazards, forest and alpine lands, and agri-
cultural lands. Her greatest concern is for eduring implementation
including regional land use controls. She is concerned that EPA
financing of 201 plans undermines much that WQM should be doing. She
is also concerned that no one looks at the cumulative effects of all
polluting sources on Puget Sound. For this reason she disagrees (and
is the only interviewee v/ho does) with the request that METRO be excused
from the secondary treatment requirements. She added that in her opinion,
METRO'S exemption would set a terrible precedent.
C. Local Elected Official
The local elected official interviewed is Chairman of the King County
Council and a member of the METRO Council. As a Council Member he
has been involved in water issues for a long time, including sponsoring
a 1974 ordinance on stormwater retention. He attended an early WQM
conference in Williamsburg and is familiar with PL 92-500. He feels
that congressional staff have come down hard on the Regional Administra-
tors who, in turn, have become inflexible. Consequently, most members
of the -community, especially industry, have come to dislike EPA.
The Councilor urges greater communication and more reasonable time
schedules.
The Councilor feels stormwater is the biggest county problem but notes
that there is not enough money to study the entire area. He agrees
with the WQM approach to study the management problem in one area while
estimating costs for the rest of the area. Beyond the narrow area under
study, solutions for the rest of the area will be planned only.
According to the Councilor, implementation will be possible only if
money is available and, if this is limited to local funds, it will
be greatly restricted and possibly dropped altogether.
D. Appointed Official
The appointed official interviewed is Manager of the 201 project for
METRO. His connection to WQM has been through the METRO Steering
Committee, a staff committee that meets biweekly and consists of six
MS-19
-------
other METRO staff connected with the WQM and 201 projects. The purpose
of the committee is to discuss the WQM/201 interface and to keep every-
one informed of what is happening. The manager sees the two related
most through combined sewer prcblem.
The manager feels the purpose cf WQM is to address nonpoint source
problems and to protect the area from any degradation. He see WQM's
problems as more political thar. technical and feels that the existing
management structure should probably have been changed as little as
possible to avoid conflict. After two years, he expects WQM to become
the long-range planning staff for METRO.
E. State Legislators
Two state legislators were interviewed; one from Seattle and one from
Pasco in the eastern part of the State (this interview was conducted)
by telephone). The Pasco legislator did not know anything about WQM.
He felt there is an attitude in the legislature that water quality
must be improved, but that DOE was the only agency needed to achieve
this purpose. In the rural areas, the water issue of greatest concern
is return flow of irrigation water. The legislature is working to
give irrigation districts the authority to deal with this issue.
He felt the State law is adequate for handling urban stormwater but
was less concerned because it is not a rural problem.
The Seattle legislator was on the Natural Resources Committee and now
is on the Ecology Committee.^ He felt that the 1970 legislature
passed a record amount of environmental legislation but that current
priority of additional legislation is low. Experience and better guide-
lines for working within existing laws is needed now. Rather than
more sweeping laws in the area of urban stormwater controls, he felt
it was impractical to act prior to raising the necessary funds. He
doubted that much money will be available from the legislature for
local agencies to do this as the State is already unable to pay for their
committed problems. Although this legislator is owner and manager of
seven neighborhood newspapers in Seattle, (and knowledgeable about
many environmental problems) he is not aware of WQM.
F. State Water Quality Personnel
The Supervisor of Water Quality Planning for DOE, who is also the WQM
Liaison, was interviewed. He has been involved in the project since the
The National Resources Committee was reorganized and is now the
Ecology Committee.
MS-20
-------
time of designation but now feels he is having difficulty ascertaining
METRO'S specific outputs. There is some feeling that METRO is like a
headstrong child. The staff are well qualified, knowledgeable and
have good government contacts but they have been used to working
independently. In the meantime, the State has been understaffed and
less able to participate effectively in the process. That situation
is changing and there are nine statewide WQM positions (six for the
designated areas). The State prefers to play a larger role, particularly
because the State must approve the plan. These plans eventually will
become part of the Statewide plan. The State feels METRO has been
funded to do only parts of two of sixteen required program elements.
The State wants to know what minimum level of detail will be needed
on the other items in order to guage METRO performance and to know
whether or not to certify the plan.
The State has delegated permitting authority to METRO for industrial
dischargers into the METRO system, which means there continues to be a
close relationship between these permits and WOM. The State does not see
a particular WQM/201 relation developing because so much facility work
has already been done and there is little in the work plan dealing with
201. Nonpoint sources are seen as a shared State/local responsibility.
The State has an interest, but they recognize it is necessary to have
local jurisdictions responsible for implementation when land use is
involved.
In the State's view, WQM should be developing a textbook approach for
dealing with problems that will have transfer value for other areas.
Management approaches should involve applying and testing a process
in certain areas. The States' concern must be with geographic areas
more than with particular problems.
MS-21
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
The plan has an excellent chance of being completed on time. METRO
has extensive experience in water quality planning and in supervising
consultants and should be able to keep the work schedule. Much data
is available from the RIBCO plan, some of it still unanalyzed, which
WQM can build upon. The RIBCO plan, although officially accepted,
never realized many of its highest hopes, and METRO is a bit timid
about trying to bite off too much. There are scars from the public
experience which left the populous highly frustrated. WQM must live
with the reputation of this controversial effort.
In part, because METRO decided to involve other public agencies so
heavily in the planning process, they will be dependent on others for
meeting the project outputs. The City of Seattle and King County have
had responsibility for the "implementation area" studies. The Puget
Sound Council of Governments is responsible for the economic, demo-
graphic and land use projections as well as for much of the analysis
and impact assessment work. Furthermore, the point source work is being
conducted by a separate staff within METRO who are developing a strategy
for how the agency will meet the 1977 goals of the Act.
The concurrent 201 planning program restricts those areas the WQM can
handle. The agency is more comfortable in planning sewers and is cautious
about infringing upon anyone's domain. The WQM is hesitant about pre-
senting any plan which might look like they are encroaching upon local
powers due ro the recent disagreements within the Puget Sound COG which
led to its dissolvement. Finally, the WQM is somewhat defensive about
their attempted accomplishments with nonpoint source controls. Past
efforts, particularly in restoring Lake Washington, were dramatic. But
the "big dragons have been slewn", according to one individual. WQM
must tackle problems that are not only less understood, but whose
solutions are much less ovbious.- sometimes intangible, or of questionable
benefit, and are more likely to influence people and their lifestyles
directly.
It is perhaps for several of these reasons that METRO has chosen a some-
what modest work program. Spec_fically, they are aiming at the problem
of urban runoff and combined seuers. More generally they are looking at
"nonpoint source problems". Th^s vagueness regarding outputs is currently
of concern to both EPA and the State. Plan approval will depend heavily
on the outcome of the two demonstration projects (Lake Union/Thorton
Creek and Juanita). Should these two test implementation areas fail, it
will be difficult to recommend an acceptable management plan. Everyone
will know what they don't want, not what they would want. If the two
MS-22
-------
tests are considered successful there is a good chance that the plans
will be approved and implemented. At this point, everyone is taking
a "wait-and-see attitude". The project to control weed growth in Lake
Union is considered successful so far, but the staff, understandably,
is cautious about describing this as an accomplished "success" in case
the project falters.
The entire focus of this WQM effort is towards a management system.
METRO will most likely not be the managing agency. Rather, the plan
will mostly involve dissiminating more information to authorities in
existing agencies. To the extent that the status quo is unchanged,
there is a greater likelihood of implementation. Further, the City of
Seattle and King County are serving as implementors of the two demonstra-
tion projects and should help achieve implementation in other parts of
the area. Several of the key elected officials are on the METRO Council
and must approve the plan. It is these same officials who will implement
it within their own jurisdiction.
One problem in selecting combined sewers as a prime target area is that
its solution is so costly. It is possible that, even if everyone agrees
on what should be done, the"action- may not be financially possible.
It is for this reason that the agency reacts to any success definition
that includes the two year time period. The plan will be implemented
to the extent that funds, both Federal and local, are available. The
more funds there are, the more that can be done.
B. Public Involvement
The public participation program is well underway in this area. It was
designed by a highly professional community relations staff and by an
Interim Committee composed of citizens. Based on experiences in the
RIBCO program, the Interim Committee recommended keeping the citizen
committee to a limited size of eighteen. The final appointments were
made by the METRO Council (all elected officials) which is significant
because the chief purpose of the committee is to make recommendations
to the Council. It was also decided that the committee would be a full-
time committee of METRO to last beyond the two years. This can be seen
as a symbol METRO'S commitment to citizen involvement. In this way,
they are more than just fulfilling an EPA requirement. The ongoing
mandate of the committee makes it easier to get citizen involvement and
should be an invaluable aid in overseeing implementation of the plan.
Citizens had to apply for membership on the committee and final selections
were made by the METRO Council. The result is a group of professional
citizens who have been actively involved in a wide range of previous
programs, many water-related, many planning-related and all community-
based. These people are familiar with the system and competent in over-
seeing the staff. Their input is thorough and well-studied. For example,
MS-2 3
-------
one of the Task Forces examined "goals". As most of these people had
been involved in previous community programs, they were familiar
with the community's goals and how WQM cound and should fit in. On the
other hand, it could be that there is a need for "new blood" in the system
and that these individuals 1 input would have been assimilated whether
or not they were committee members.
There was also a decision that the Committee should jointly handle WQM
and 201. On the surface this is a logical approach that avoids dupli-
cation. In fact, it has meant that the Committee has concentrated on 201,
the more tangible program, using the excuse that its deadline comes
earlier. All of the citizens recognize that this is the reverse of the
logical order and they do not understand why all 201 work cannot be
halted until the WQM plan is finished.
One disadvantage of the emphasis on the citizen committee is that there
is less success in reaching the general public; perhaps the more dif-
ficult task. The community involvement staff acknowledges that they
concentrate most on"the identified interest groups such as the Sierra
Club and Washington Environmental Council whose support will be necessary
for plan approval. There have been and will continue to be speeches,
brochures, surveys and newsletter mailings; but the feeling seems to be
that these have not been overwhelmingly successful. The staff seems to
feel they have considered all variables and that no one can fault them
for not trying. For some reason, however, it has not brought about the
interest and support they deisred. WQM lacks a popular, major dilemma, and
therefore, does not command widespread public attention.
At the staff level, commitment to public participation is high throughout,
from the Executive Director down. There are two staff assigned full
time to the citizen, committee plus a Supervisor (who also supervises
transportation committee work). Technical personnel attend committee
meetings and public hearings on a rotating basis so they too are familiar
with issues raised by the public. Public concerns are aired and dis-
cussed at the biweekly staff meetings.
The METRO Council, which oversees the WQM, is composed of elected officials.
They offer general philosophies for METRO and expect the staff to carry
out the specifics. So far, no elected officials have been involved in
WQM beyond their role as Council members. Everyone acknowledges the
importance of involving local elected officials, but, up to this point,
the staff organization has separated citizen and elected officials.
It is unclear how, if at all, this will change.
C. Current Planning Process
METRO has begun its planning process through implementation of the two
demonstration areas. The results of these management attempts will be-
come data input into formation of alternatives. Most of the water
MS-24
-------
quality data is already available, but additional institutional data
will be collected on existing conditions.
The area is already fairly well committed to its land use goals and
policies. WQM, in fact, provides feedback on these land use patterns.
WQM will discover which authorities are missing and will try to enlist
their aid. Because planning is a collaborative effort with at least
two of the potential managing agencies involved, there is constant
data analysis and reaction to possible alternatives.
A Prototype Plan has been written which should help everyone, staff,
elected officials, State, and EPA alike, understand WQM's ongoing
activities. So far there has been some confusion about the prototype,
what it is and whether it means that a final decision about the plan has
been made. However, once its purpose is better understood, it should
become an effective tool for developing a final plan.
METRO is incorporating an environmental assessment into the plan and
has developed preliminary guidelines as to hoy this should be done
(it involves a checklist type approach). The guidelines were developed
from past experience and were deisgned to satisfy the State EIS require-
ments which are stricter than NEPA's. Tnis move is, in part, a defensive
one since it is believed that they will be challenged"to prepare
an impact analysis if one does not already exist. There have been
threats to- sue EPA in this Region for not requiring full analysis of
all sixteen parts of a WQM plan as outlined in the guidelines.
D. Continuing Planning Process
In all probability, METRO will continue to do WQM planning. Depending
on METRO funding and their experience in the current effort, this plan-
ning will include either nonpoint sources or be limited to the more
conventional facility planning and, possibly, to separation of combined
sewers. METRO has recently approved a user surcharge for high uses as
well as an industrial cost recovery system. They have not specifically
considered any alternatives for funding continuing planning. It is
possible that funding could come from general expenses, although pro-
bably at a reduced level than currently enjoyed.
E. Significance of Local Elected Officials' Involvement
Local elected officials involvement has been limited to those officials
who are members of the METRO Council. The Council has been involved
since the early stages of designation and some officials were involved
in supporting passage of PL 92-500 (establishing the WQM program).
Local officials seem satisfied that the METRO staff is carrying out their
directives in appropriate ways, although there is constant concern about
high costs.
MS-2 5
-------
Two jurisdictions, the City of Seattle and King County, are involved
heavily because they have contracts for "implementation area" studies.
For the most part, local officials of the other communities are not
yet involved. METRO intends to start more active involvement by holding
a workshop in the fall.
So far, elected officials' commitment extends to the planning process.
Only a few individuals, realize what WQM could entail (the Executive
Director calls it the "208 iceberg"). The commitment to implement
policy will be tested next year as more financial and political problems
arise.
MS-26
-------
AGENCY: NASSAU-SUFFOLK REGIONAL PLANNING BOARD (NSRPB)
REGION: II - (New York)
GRANT AMOUNT: $5,207,000
GRANT RECEIPT: June, 1975
STARTING DATE: January 1, 1975
STATUS AT TIME OF INTERVIEWS: NSRPB is undertaking data collection and
modeling efforts.
REASON FOR INCLUSION IN THE SAMPLE: Nassau and Suffolk Counties were chosen
because of their groundwater quality prob-
lem. The quality of groundwater is par-
ticularly critical as groundwater is
the Island's sole source of water supply.
NS-1
-------
I. BACKGROUND
A. Area Description
Nassau and Suffolk counties, with a combined area of 1,372 square miles,
comprise all of suburban Long Island. Familiar natural characteristics of
£ong Island include its streams, lakes, rivers, ocean, bays and sound front-
ages which exceed 1,000 linear miles. These natural water resources offer
unique resort and recreational opportunities for millions'of residents and
visitors to the Island.
There are approximately 2.5 million people who reside in Nassau and Suffolk
Counties. Approximately 1.5 million persons live in Nassau. County and 1.1
million live in Suffolk County. It is projected that the population of the
Counties will grow to at least 3.3 million residents by 1985. Most growth
will occur in Suffolk County whose population will exceed that of Nassau
before 1985.
The topography of Long Island is uniform and contains a gentle to moderate
downward slope from the north to the south shore. There is a glacial ridge
which runs east and west through Nassau County and reaches an elevation of
about 300 feet above sea level. North of this ridge the topography becomes
abrupt with an overall slope to Long Island Sound. South of the ridge is
a long gentle slope terminating in the marsh and meadow land which borders
the bays on the south.
The major land uses are 45 percent residential, 33 percent vacant and 8
percent agricultural and 8 percent roadways. Commercial and industrial ac-
reage account for only two percent of Nassau and Suffolk's land use.
Nassau and Suffolk Counties are comprised of 13 towns, 92 villages and
2 cities. Each municipality controls its own planning and zoning for land
use. Major water related industries are commercial and shell fishing,
tourism and duck farming. Commercial fishing is a $3.3 million industry
per year, or 6.6 percent of the nation's catch. Long Island leads the
nation in hard shelled clams with a $5.5 million business annually. There
are 400,000 acres of active shellfish areas. The scallop catch can vary
from $100,000 to $700,000 depending on the survival conditions. The oyster
industry has declined 99% in the past 50 years, from a $50 million to one-
half million dollars. The following human factors are major reasons for
this decline:
o Bacteria from seepage,"
o Nutrient pollution from duck sludge; fertilizer and sewage;
c Destruction of wetlands;
Information for this Chapter was taken from Existing Land Use, NSRPB,
in 1968; The Status and Potential of the Marine Environment, NSRPB, 1966;
and various interviews.
NS-2
-------
o Spraying of DDT; and-
o Dredging of shellfish bottom.
Another industry which is dependent on wetlancfs, and that has had a detri-
mental effect on water quality is duck farming. This industry is a $15
million operation in Suffolk County. The tourism industry brings in $150
million annually. Long Island's coast line is a major attraction for both
residents and non-residents.
NSRPB is recognized as a reputable planning agency, an example of which is
the acceptance of the comprehensive plan for the region. All interviewees
had a generally positive attitude about'the benefits of regional planning
and the activities of NSRPB.
B. Water Quality Problem
Long Island is bordered on the north by Long Island Sound and the south by
the Atlantic Ocean. The Island is "fenced" off from ocean by their
barrier beaches creating the Great South Bay, appioximately 75 miles in
length. Four main watersheds are located in Suffolk County. These are:
the Nissequoque, Connetquot, Carmans and Peconic Rivers.
The water supply is obtained entirely from ground water. Natural replen-
ishment of this supply consists of approximately 42 inches of annual pre-
cipitation. It has been estimated that approximately 50 percent of the pre-
cipitation is lost due to evaporation, stream flow and other factors.
The estuarian marshes and the off-shore waters abound in a variety of shell
and fin fish. The fresh waters, particularly in Suffolk County, have an
abundance of trout and bass.
The Island's water quality probelms are primarily a result of human hab-
itation, rather than industrial pollution. Great South Bay has the major
water quality probelms. Causes of this pollution are runoff, duck farming
and boating. Additionally, the Bay has limited flushing action.
A major concern on Long Island is the preservation of groundwater quality
because it is the sole source of water supply for both Counties. Ground-
water pollution has occurred as a result of the use of detergents, pest-
icides and fertilizers, the leaching of heavy metals, and the runoff of
petroleum products and landfill contaminants. In most of Nassau and Suffolk
Counties, the upper aquifers are contaminated in certain areas. Recharge is
a major issue on the Island. To date, Nassau County has sewered much of its
groundwater out to sea. The County is presently facing salt water intrusion
problems in both streams and wells.
NS-3
-------
c.
Designated Agency
The NSRPB, established in 1965, is the regional planning agency for
Long Island. Membership consists of the two counties which make up
suburban Long Island - Nassau and Suffolk. There are 14 members on
the agency's Board of Directors. The Counties are represented equally,
each having 3 lay persons, 2 elected/appointed officials, the Commissioner
of Public Works and the County Comptroller. Other programs at NSRPB in-
clude HUD 701 (land use and transportation planning) and a CZM demonstra-
tion grant which entailed coordinating coastal zone planning with regional
planning. Programs which pass through the New York Department of Environ-
mental Conservation for the Tri-State Regional Planning Area (New York,
New Jersey £ Connecticut) are Air Quality Maintenance, Transportation and
Solid Waste Planning.
NSRPB employs 34 full-time employees, of which an average of 25 have worked
in WQM. The core of the WQM staff consists of an Executive Director (the
WQM Director)^, a Program Administrator (contracts) and Environmental En-
gineer and 2 Demographers.
Major water quality studies by NSRPB include:
o
Comprehensive Development Plan (with a Water Quality El-
ement) , 1970/
o
o
o
Comprehensive Water Supply Study for Suffolk County, 1970^
14 Marine Studies under the Sea Grants Program^
Coastal Zoning Management Planning (just completing planning •
effort), and
o
Oil Spill Studies under the Coastal Zone Management Program.
1
The current Executive Director of the agency is also the WQM Staff Director-
NSr4
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
WQM is seen as a comprehensive planning effort to improve/maintain surface
and groundwater quality. The Executive Director stated that there are no
priority elements in the Nassau-Suffolk WQM study. The knowledge of the
limits and implications of growth seems particularly important because of
the unique nature of the Island's limited source of water supply -- ground-
water.
B. Technical Component
The technical work elements of the study are contracted to private con-
sultants and one local government. Approximately 92 percent of the funds
($4.8 million) is allocated for data collection, sampling, modeling and
analysis under 20 separate contracts.
The surface water quality for Nassau County is well documented for South
Shore Bays and less so for North Shore Bays. Current data for Suffolk
County is not sufficient to support the required technical evaluations
concerning effluent disposal alternatives. In all cases, storm water run-
off data is not sufficient to support the technical evaluation. Much of
the groundwater data exists in the offices of the United States Geological
Survey, Suffolk and Nassau County Health Departments, Suffolk County
Deaprtment of Environmental Control, private water companies and the Suffolk
County Water Authority.
Existing models will be used in four modeling efforts. The steady state
and time variable will be used for marine waters and a two dimensional
digital model will be employed for fresh water. The finite element dig-
ital model, developed by Princeton University Water Resources Program, will
be utilized for groundwater for the South Fork of Suffolk County and a
5 layer electric analog simulation model developed by USGS will be used for
the rest of the Island.
The Peconic and Carlls Rivers in Suffolk County hav.e been selected for the
fresh water modeling because they appear to be viable receiving waters for
treated effluent or ground water recharge. It is expected that extrapolation
to other major streams in Suffolk and Nassau Counties will be possible.
Marine water quality modeling efforts will be undertaken in seven sites -
four on the northern side of the Island, two on the south and one on the
east between the Suffolk County Forks.
NS-5
-------
C. Management Planning
A range of 7 legal, adminstrative, management data collection activities
are scheduled for WQM to provide a basis for alternative development. These
include:
o Existing land use controls and land management authority at
. various levels of government;
o Erosion-runoff control ordinances and practices relating to
agriculture and construction;
o Agricultural chemical and agricultural waste management
practices,
o Irrigation water management practices;
o Design, construction,,, and maintenance practices for discharg-
recharge basins, wells, and ponds,-
o Landfill siting and operating practices,"
o Application and storage practices for highway deicing chemicals,'
o Well development, operation, and abandonment standards and
practices; and
o Septic tank/leachfield standards and design.
These alternatives are then evaluated for final selection of land use and
legal alternatives.
D. Public Involvement Program
NSRPB has established a citizens and a technical committee for obtaining
public input throughout the planning process. These committees form the
primary vehicles for public involvement in addition to a newsletter pub-
lished by the citizens committee.
The Technical Advisory Committee (TAC) is composed of representatives from
the Nassau County Departments of Public Works, Planning and Health, the
Suffolk Departments of Environmental Control and Health, and the Suffolk
County Water Authority. Other agencies on the committee include United
States Geological Survey (USGS), the U.S. Environmental Protection Agency,
NS-6
-------
the Tri-State Regional Planning Commission, the New York State Department of
Environmental Conservation, and representatives of the Citizens Advisory
Committee (CAC).
The CAC is composed of a voting membership of 20 persons, however, atten-
dance has reached up to 60 persons at some meetings. A variety of interests
are represented including environmentalists, the League of Women Voters,
Long Island Business Association, agricultural interests, and elected of-
ficials.
The Executive Director stated that one of the most difficult aspects of
WQM was melting together the various personalities of the committees.
He felt that this problem had been overcome, and that both committees were
working well together and having significant input into the process. An
example of such input was the issue of the inclusion of viral studies under
WQM. Apparently, the CAC was very active in their demand despite initial
EPA disapproval. The Executive Director staged that the citizens' per-
sistance was a major factor in gaining approval for the viral study.
E. State and Federal Involvement
The State of New York has a contract with NSRPB for lab work and coor-
dination. The State has assigned one full-time person to work with the
Nassau-Suffolk WQM. The staff reported that the State had been very coop-
erative and has supplied all available data.
The State reported that it had been the source of technical assistance in
plan development, definition of the problem and general start-up activities.
The State Liason presently sits on the TAC and is actively involved in the
planning process in order to insure compatibility with statewide plans
and monitor WQM plan progress.
NSRPC also maintains very good relations with the EPA Regional office. The
Executive Director stated that EPA has been extremely helpful, particularly
in its advice on consultant selection for the modeling work.
F. " Scheduled Outputs
Exhibit I lists the work elements of the NSRPB work plan. The Executive
Director stated that the planning effort is on schedule and that no revisions
in the work plan are presently anticipated.
NS-7
-------
EXHIBIT I
NSRPB Work Plan Elements
1.0 Determine Marine and Fresh Surface Water Quality
1.1 Review Existing Marine Surface Water Data
1.2 Marine Surface Water Data Collection and Analysis
1.3 Fresh Surface Water Data
2.0 Determine Ground Water Quality
2.1 Review and Evaluation of Existing Groundwater Data
2.2 Location of Saltwater/Freshwater Diffusion Zones
(Eastern Suffolk County)
2.3 Aquifer Transmissivity Determination
3.0 Identify and Evaluate Point Pollution
3.1 Evaluate Existing Point Source Data
3.2 Identify Storm Watsr Point Sources
4.0 Identify Nonpoint Pollution Sources into Ground Water and Surface Water
4.1 Evaluate Existing Monpoint Source Data Including Septic Tanks/
Cesspools/Leachfields
4.2 Identify Landfill Related Pollution
5.0 Evaluation of Water Quality Surface Waters (Marine & Fresh)
and Ground Water
5.1 Marine Surface Water
5.2 Fresh Surface Water
5.3 Hydrogeologic Modeling: USGS-PWR
5.4 Hydrogeologic Modeling: South Fork Suffolk County
5.5 Evaluation of Ground Water Quality
NS-8
-------
5.6 Statistical Interpretation of Water Quality Data
6.0 Establish Probable Future Pollution Loads
6.1 Review and Update Existing Land Use Data
6.2 Review and Update Zoning of Vacant Land and Probable
Land Use Changes
6.3 Develop Corrected Household/Population Projections and Revise
Projections of Districution of Economic Activity
6.4 Develop Future Pollution Loads
7.0 Evaluate Existing Wastewater Treatment Facilities
8.0 Identify Cost and Evaluate Technical Alternatives for Water
Treatment, Effluent Disposal, Sewage Sludge Disposal, Refuse
Disposal, and Stormwater Control
8.1 Develop and Evaluate Engineering Alternatives for the Control
of Point Pollution Sources Including Municipal and Industrial
Wastewater Discharges, Major Storm Sewer Discharges and Signif-
icant Private Waste Water Discharges
8.2 Identify and Evaluate Technical-Feasible Engineering
Alternatives for the Control of Nonpoint Pollution Sources
Including Neighborhood Storm Water Discharges, Agricultural
and Land Use Sources, Highway and Miscellaneous Sources
8.3 Identify and Evaluate Technical-Feasible Alternatives for the
Treatment and Disposal of Sludge
8.4 Identify and Evaluate Technical-Feasible Alternatives for the
Disposal of Solid Wastes and Hazardous Materials
8.5 Identify Cost and Evaluate Technical-Feasible Alternatives
for Treatment, Renovation and Distribution of Public Water
Supplies
8.6 Identify and Evaluate Surface and Ground Water Quality Targets
9.0 Identification and Evaluation of Legal, Administrative and .Management
Alternatives
9.1 Review and Evaluate Existing Land Use Controls and Land
Management Authority
NS-9
-------
9.2 Review and Evaluate Runoff Control Ordinances and Practices
Relating to Agriculture and Construction
9.3 Review and Evaluate Ordinances and Management Practices
Relating to Agricultural and Animal Wastes
9.4 Review of Irrigation Water Management Practices
9.5 Review and Evaluate Ordinances and Practices Relating
to Landfills, Well Development and Abandonment, Septic
Tank and Leachfields and Highway Deicing Chemicals
10.0 Develop Water Quality Management Plan for the Nassau-Suffolk Region
10.1 Develop "Best" Fet of Engineering Alternatives & Establish
Engineering Subplar.s. DeveJ.op Regional Facilities Plan
10.2 Develop "Best" Set of Legal, Management and Land Use Alter-
natives. Identify and Establish Preliminary Regulatory and
Compliance Programs
10.3 Economic & Environmental Evaluation of Selected Plan and/or
Subplans
10.4 Revision of Land Use Plans
Source: NSKPB Work Plan, NSRPB, 1975.
NS-10
-------
G. Achievements to Date
The Executive Director stated that the viral sampling being undertaken
by NSRPB will be a technical achievement of the WQM study. He added that
the study is somewhat limited in terms of depth, but will provide a major
step toward defining the problem.
The Executive Director also felt that the working structure of the WQM
Committees was a major achievement, and an effective example of bringing
a variety of interests to work together to solve a common problem.
NS-11
-------
III. EXPECTATIONS
A. Water Quality
All interviewees stated that the most significant achievement of WQM is
the preservation of groundwater quality. There is an acute awareness on
Long Island of the dependence on groundwater for water supply and the delicate
balance among the marine, fresh and groundwater systems.
The Executive Director also looked to WQM to effectively eliminate local point
sources of pollution and to provide the knowledge of the implications of
growth on Long Island. He also thought WQM would provide methods for pre-
vention of future degradation of the Island's waters. In addition to the
preservation of groundwater, the staff expected significant improvements in
marine waters as a result of WQM, and expected to see the marine water im-
provements much sooner than groundwater improvements.
The State official thought that WQM would provide a sound base of information
for treating water in problem areas and maintaining water in high quality
areas. He also expected to see a new emphasis on the prevention of ground-
water pollution.
Local reactions centered around finding a solution to the recharge issue.
The appointed official mentioned recharge in connection with the possibility
of alterina the ecosystem if the groundwater was not preserved. Local el-
ected officials were concerned primarily with the issue of water supply. The
citizen had an interest in preserving waters for shellfish life and swimming,
in addition to preservation of groundwater.
No interviewees expected to meet the 1983 goals in all areas by 198 3^ The
Executive Director stated that goal achievement in the Long Island area was
dependent on New York City's wastewater management. For example, the prac-
tice of bypassing the sewage treatment plant after 0.4 inches of rain will
continue to affect Long Island's water quality. The local appointed official
said that most waters already meet the goals, but that nonpoint source controls
would result in a significant clean-up in the shellfish areas. The citizen
thought that the 1983 goals would not be achieved on Long Island, but
that they were reasonable goals.
B. Plan Approval and Implementation
Most interviewees were extremely confident that the plan would be
approved with little difficulty. The citizen had no comment as she felt it
was too early to judge the likelihood of plan approval. Interviewees were
more hesitant to comment on plan implementation. The staff and the local
appointed official expected that the plan would be implemented, however,
this task was considered more difficult than obtaining plan approval. Others
NS-12
-------
did not have comments on plan approval.
The Nassau - Suffolk region is characterized by a relatively simple
institutional setting. The executive Director stated that the manage-
ment agencies already exist within the county structures. These groups
are actively involved in the WQM planning through membership on the TAC.
The ratification of the WQM plan by the Board carries with it an implicit
understanding of its implementation in the existing county structures.
NSRPC does not have to deal with a prolification of operating agencies.
Existing county management agencies apparently have all the necessary
powers to implement WQM. The state official indicated that most of
the legal aspects of WQM will be handled by upgrading existing legislation.
C. Continuing Planning Process
Most interviewers saw the need for WQM planning to continue after the
two year period. Most also thought that the likelihood of continuing
planning was dependent on the provision of Federal funds.
The Executive Director stated that the cost of continuing planning
would be approximately 10 percent of the WQM grant, or $520,000.
He thought that the money should come from the Federal government,
however, he was hopeful that NSRPB would find a way to fund necessary
planning functions if Federal funds were not forthcoming. The anticipated
functions of continuing planning are:
o Selling of the plan to local jurisdictions,-
o Updating of the plan;
o Coordinating with other programs related to WQM/ and
o Monitoring of growth.
The Executive Director stated that the selling of the plan after plan
approval was an extremely important function in order to insure plan
implementation.
Both local elected officials thought that planning should continue,
particularly if the present work indicates that ongoing planning is
essential to the preservation of water quality. One local elected
official thought that the State would be a likely source of funds, while
the other expected Federal funding. The citizen felt that a lot of
people are committed to ongoing planning, but thought that funding was
doubtful. The State official considered updating to be an essential
aspect of p]an implementation, and thought that the State would play
a joint role in the ongoing planning process.
NS-13
-------
D. Relation To Other Water Quality Programs
Most interviewees perceived that WQM would have a significant impact on
the Construction Grants Program. No interviewees expected WQM to have
a significant influence on the permitting program.
The Executive Director thought that WQM should guide 201, He believed
that this transition would be smooth^ as those engineers responsible for
201 jilans are members of the TAC and will play an active role in plan
development. The Executive Director was not sure what the impact of
WQM will be on the NPDES.
The local appointed official and citizen felt that WQM should guide 201
and that 201 should be held in abeyance until WQM was completed. The
citizen added that 201s in critical areas should continue without waiting
for WQM.
The State official said that 201 was virtually waiting for WQM because of
the dearth of facility funding at this time. He did think that future
201s should be guided by the WQM plan.
E. Local Definitions of Success
The local definitions of success were primarily seen in relation to plan
development. The Executive Director expected a plan for responsible
growth which would not destroy the existing ecosystem, while enhancing
the ammenities of Long Island. The local appointed official looked for
a comprehensive plan which addressed wastewater issues from an environmental,
economic and social perspective. Both local elected officials wanted
growth parameters and guidelines clearly laid out for decision-makers.
The citizen hoped that better lor.g-range planning and regional decision-
making would be made possible by the EWM efforts. The State official
expected an increase in the cooperation between the counties, a determina-
tion of economic and evironmental feasibility of wastewater recharge, the
implementation of a groundwater policy and the development of nonpoint con-^
trols to improve marine water quality.
The major benefit expected from WQM was the preservation of Long Island's
sole source of drinking water - groundwater. The Executive Director
added that the most cost-effective solutions should result from WQM, while
the citizen also looked for the preservation of marine life and swimmable
waters of the Island.
NS-14
-------
IV VARYING PERSPECTIVES OF WQM
A. WQM Staff
The NSRPB was extremely confident of their ability to develop a technically
and politically reasible plan which meets the wastewater management
needs of Long Island. The time constraints of WQM were considered
significant in all staff interviews. The staff felt, however, that
they had developed a flexible, innovative work plan that would achieve
WQM objectives without cutting corners. Achieving these objectives
was considered possible only because of a dedicated, hard working
staff that was willing to operate with significant time and financial
constraints. The Executive Director stated that the strengths of the
NSRPB effort were the exceptionally qualified consultants for the
technical work and the support of local governments for the agency and
its work.
B. Citizens
One citizen was interviewed who represented the League of Women Voters
on the Citizens Advisory Committee (CAC). She felt that the CAC had
significant input on the study and had beer particularly effective in
getting approval for viral and trace organic studies und.er WQM. She
also stated that effective communications had been established between
the TAC and the CAC despite different perspectives of WQM.
In her opinion, WQM had not encountered any substantial problems to date,
nor were problems expected with plan approval. She was looking to WQM
to insure the preservation of the Island's water supply and recreational
resources.
C. Local Elected Officials
Two Suffolk County legislators were interviewed for their opinions on
WQM. One is a voting member of the CAC, while the other attends CAC
meetings to keep informed of WQM activities.
The CAC member became involved in WQM because the County legislature had
approval entering into WQM planning, and because she is an environmen-
talist. Additionally, there was some concern in her district about WQM
holding up a most needed 201, and her membership on the related committees
(WQM 201) resulted in an active role in WQM. Her primary concern was
for the development of the sewage treatment plant regardless of WQM
because of her community's pressing need for the facilities. She does
look to WQM, however, for future growth guidelines and a plan for pre-
serving the Island's water supply.
NS-15
-------
The other local elected official became involved in WQM because he is
a member of the County's Environmental Committee. His town was basically
a bedroom community and had little awareness of local water quality
issues. He hoped that WQM would provide local decision-makers with the
growth parameters, relative to the water supply, but emphasized that
solutions that would have to be funded by local sources would not be
possible. Additionally, he wanted the WQM plan to be merely an advisory
document.
D. Appointed Officials
The local appointed official was a member of the TAC. Additionally,
the Environmental Department of his town was contracted for 50 percent
of the WQM marine sampling because of a large environmental staff.
This official relt he had significant input to WQM in the
marine resources area, particularly sampling lab methods and sewage
disposal. He saw the recharge issue as an essential aspect of the
Study. As most Long Islanders are environmentally conscious, he felt
those recommendations requiring no capital outlays will be passed.
There is not a willingness, however, to pay for environmental protection
at the local level.
E. State Elected Official
A Program Associate in the Governor's Office who had been active in the
designation process was asked about the role of the Governor in WQM. She
did not consider it her responsibility to keep in touch with New York
WQM agencies. Rather, she claimed it is the responsibility of the
New York State Department of Environmental Conservation (DEC). A good
working relationship exists between the Governor's Office and DEC in
which the Governor's Associate feels that relevant matters will be brought
to the attention of the Governor. She felt her responsibility lay in
keeping avenues of communications open among the various State departments.
The Associate stated that DEC's judgement and decisions provide the basis
for the Governor's position because of the respect for the Department's
previous work.
F. State Water Quality Persrmnel
The Chief of the Water Quality Division of the New York DEC had played
a very active role in the early stages of NSRPB's WQM effort. There is
also a full time Liaison who has ongoing responsibilities with Nassau -
Suffolk and who is a member of the TAC. The Liaison was not available
for interview.
The Chief of the Water Quality Division said that DEC personnel had
provided technical assistance in plan development, problem definition,
proposal review. Additionally, DEC helped to obtain permission to
undertake the trace organic and viral studies. In addition to coordina-
tion and technical assistance, laboratory services are being provided by
DEC as part of the contractual agreement.
NS-16
-------
The Chief stated that a good working relationship exists between DEC,
EPA Region II and NSRPB. It was confirmed in all other interviews
that WQM efforts had been highly cooperative among all levels of government.
Little difficulty was expected in the development of a quality plan
because of the expertise of the NSRPB. The Chief also anticipated
no difficulty with State approval because of the close working relationship
between NSRPB and the State throughout the WQM process. He was satisfied
with the Department's role to date, and felt that the State will continue
to play a significant role in WQM.
NS-17
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval And Implementation
All interviewees were confident that an acceptable plan to all local
State and Federal governments would be produced under WQM. Although the
staff commented on the immense size of the undertaking in such a short
planning period, the program was progressing as scheduled. Additionally,
the staff was confident that all activities could be completed within
the given deadline. No major plan revisions were foreseen at the time
of the interviews.
Little problem was expected with the implementation of the non-structural
(e.g., no-cost) elements of the WOM plan, however, a strong consensus
among„_lo.cal__interests exists that no local funds will be available
..for .WQM af.ter the_,two..year.rplanning_period. The Federal Government is
considered the logical source of these funds.
Two unusual aspects of the Long Island WQM are the trace organic and
viral studies. These studies are a major step toward defining the
extent of the groundwater problem on Long Island. An example of the high
level of interest in groundwater - the preservation of the water supply -
was the fact that the Citizens Advisory Committee (CAC)"was instrumental
in obtaining approval for the trace organic and viral studies to be in-
cluded in WQM planning.
B. Public Involvement
NSRPB relies primarily on their committee structures for public input.
This structure includes two committees: the Technical Advisory Committee
(TAC) and the Citizens' Advisory Committee (CAC). The TAC is composed
of representatives of local operating State and Federal agencies. The
The CAC is composed of representatives of various local interest
groups (e.g , business, environment and agriculture) and has been delegated
the responsibility of publishing the WQM newsletter. Both Committee
members and staff reported that zhe various interests have joined together
for cooperative and productive work since the earliest stages of WQM.
C. Current Planning Process
The Nassau Suffolk planning effort requires a significant amount of technical
work because of the unique and delicate hydrological conditions of the
Island. Four separate models are being utilized under WQM. Two government
models are designed to define specific conditions in relation to water
movement in salt/fresh water diffusion zones and flow conditions typical
of landfills, septic tanks, lagoons and other waste management practices.
Separate models also wil] be utilized in selected fresh and marine waters.
NS-18
-------
The high degree of interest in the water quality of Long Island
is based on the fact that the groundwater is the sole source of
water supply, in addition, water is highly valued as a commercial
and recreational resource. These factors have resulted in a variety
of active interests which were readily channeled into the WQM planning
effort. The water quality planning expertise of the NSRPB as well
as this high level of interest in water quality have resulted in a
quality planning effort that, at this time, seems both technically and
politically responsive to the needs of the Long Island community.
D. Continuing Planning Process
AS NSRPC has a strong history in water quality planning, there is no
reason to think it will stop after WQM. The Executive Director
stated that a major element of continuing planning'would be the selling
of the plan to local communities after plan approval. This seems a
logical function to insure the implementation of the plan. Additional
functions in the Executive Director's opinion are updating of the plan,
coordinating WQM with other related programs and monitoring growth.
The Executive Director and all other interviewees looked to the Federal
government as the source of funds for ongoing planning and estimated
the annual cost at $520,000. He was confident, however, that if Federal
funds were not forthcoming the monies would be available to undertake
at least some of the above mentioned activities.
E. Significance of Local Elected Officials' Involvement
The most significant elected officials involved in WQM seem to be the
elected County officials on the Board of the regional planning agency.
The Board is kept informed regularly of WQM activities by the staff,
however, they are not members of the Committees. County District Repre-
sentatives make up 20 percent of the voting membership of the CAC, however,
others attend in order to keep informed of WQM activities.
The Executive Director felt that the major link between approval and
implementation was the Planning Agency Board because, implicit in
their approval were directives to the respective county operating
agencies. Additionally, these operating agencies have had significant
input into WQM through membership on the TAC. Consequently, it seems
that the structure for local input at NSRPB is designed to be
responsive to their particular local institutions. Interviewees
confirmed this and expressed satisfaction with their input into the
process.
NS-19
-------
AGENCT: OHIO-KENTUCKY-INDIANA COUNCIL OF GOVERNMENTS (OKI)
REGION: V - (Chicago)
GRANT AMOUNT: $1.9 Million
GRANT RECEIPT: June 12, 1974
STARTING DATE: January, 1975
STATUS AT'TIME OF INTERVIEWS: Official planning period ends December 31,
1976. although OKI is currently seeking an
extension until July 1, 1977 for final plan
review and approval.
REASON FOR INCLUDSION IN SAMPLE: This is a Tri-State area and, as an
early designate, OKI did not operate under
the EPA guidelines which directed later
WQM projects. Consequently, the area's
WQM effort reflects its own particular blend
of technical and management emphases.
OKI has received national attention for
its technological approach to nonpoint
sources.
0KJ.-1
-------
1
I. BACKGROUND
Area Description
The ten-county OKI region includes areas in three States and centers
around the Cincinnati and Hamilton-Middleton SMSA's. The ten counties con-
tained in the OKI region are: Clermont, Warren and Hamilton Counties in
Ohio; Dearborn and Ohio Counties in Indiana; and Boone, Kenton and Campbell
Counties in Kentucky. The Ohio component constitutes the largest share of
the region with 1.2 million of the 1.65 million area residents residing in
Ohio. The area has a diverse economic base with manufacturing the leading
component. Major wet industries include chemicals, paper, soap, plastics,
textiles, steel, machinery, food processing and packing houses.
The areawide attitude toward economic development is one of controlled
growth, particularly in the Cincinnati and developing areas. A planning
commission member stated a concern for a planning process which would
contain development. A spokesman for a county official felt that growth
was determined by sewerage and consequently his primary interest in the
WQM project was facilities planning.
B. Water Quality Problem
The Great Miami River empties into the Ohio River below Cincinnati and re-
ceives discharges from 42 public and semi-public wastewater treatment plants
and 27 industrial sources, including paper, steel, chemical and metal
fabricating. Although the WQM project focuses on point sources in the
Great Miami River Basin, combined sewer overflow, rural and urban runoff,
organic and nutrient loadings are also being assessed. The Great Miami is
impacted by the Dayton area Miami Valley River Planning Commission (MVRPC)
upstream from the OKI area. In its analysis, OKI makes the assumption that
the MVRPC WQM project will achieva water quality standards. Further, coor-
dination of KVRPC and OKI efforts will be attempted for phosphorus load
reduction. On the east fork of the Miami River, OKI is approaching the
Corps of Engineers to achieve flow augmentation which would reduce the re-
quired capacity in wastewater treatment facilities currently being designed.
Mill Creek flows through the most industrialized portion of Hamilton County
to the Ohio River and is considered the most polluted. The large pollutant
loadings contributed by combined sewer overflow are enhanced by the 182
industrial dischargers to combined municipal facilities. These industries
discharging directly into Mill Creek, however, have achieved a good efflu-
ent quality. Mill Creek was noted to be virtually stagnant during dry
weather flows with the lower portion having considerable benthic deposits
on the river bed. Due to the severity of existing pollution, recharge of
the Mill Creek Valley groundwater supply is inadequate for the Valley's
needs, and groundwater quality is poor.
1
Information for this Chapter was taken from the OKI Work Program (Revised)
April, 1974, Interim Reports and interviews.
OKI-2
-------
The Little Miami River is of relatively good quality. It is a recreational
resource which is designated as a scenic river by the State of Ohio. A
portion of the Little Miami is also designated as a National scenic river.
Although there are no major settlements along the Little Miami, the 46 dis-
persed wastewater treatment plants on the river are being studied for
regionalization and required treatment. The river's municipal and few indus-
trial point sources are considered insignificant, with most emphasis being
placed on nonpoint source problems. The Little Miami has two reservoirs,
Ceasar Creek and East Fork, for which the WPM project is completing cost-
effective wastewater treatment plans.
Nonpoint sources are the major concern for the Licking River which drains
a rural area. The river, generally has good quality except for a segment
near urban areas where combined sewer overflow is a problem. Overall non-
point sources of concern are surface runoff, nutrients and heavy metals.
Although not a primary concern of the OKI project, WQM planning for the
Ohio River is being coordinated with the Ohio River Valley Sanitation Com-
mission (ORSANCO), the Ohio River Basin Commission (ORBC) and the several
States.
C. Designated Agency
OKI was established in 1964 and has broadened its functional responsibilities
since its inception. Originally a regional transportation planning agency,
OKI became a planning authority in 1967 and a Council of Governments in
1974. Today, OKI is designated as a regional planning and development or-
ganization with 219 member jurisdictions: 10 counties, 81 townships and
128 municipalities. The tri-state area overlaps the Ohio Suhstate Regional
Planning Area, the Northern Kentucky Area Development District and Indiana
Region 12.
In addition to its WQM planning responsibilities, the agency planning func-
tions include HUD 701, general transportation planning, and A-95 review.
The agency provides data base information and technical assistance to local
communities for their planning activities. OKI's three divisions - Transpor-
tation, Regional Planning and Environmental Quality Planning - are coordinated
by several mechanisms including staff meetings, a common data base and common
advisory committees.
Harza Engineering Company is the primary contractor for OKI's water quality
analysis and facility planning. The firm is also analyzing the combined
sewer overflow problem in Cincinnati and coordinating the Step 1 facility
planning being executed under five subcontractors. A total of 2 3 facilities
are being planned and developed for the WQM area.
Top managers in OKI include the Executive Director, the Assistant Director
for Environmental Quality Planning and a Water Quality Engineer. The WQM
staff also includes two Land Use Planners and two Citizen Participation
Coordinators. The land use data base and projects were completed in-housc
with assistance from the Aerospace Division of Bendix Corporation for NASA
satellite imagery.
OKI-3
-------
On OKI's initiative, contracts with'the three State WQM agencies for ad-
ministration and coordination were established. In July, 1975 OKI received
additional funding from EPA for this purpose with $34,500 allotted to Ohio and
$24,000 to Kentucky. No funds were requested by Indiana.
OKI is coordinating its efforts with other related activities in the area
including: the Ohio River Basin Commission, the Miami Conservancy District,
the Ohio River Valley Sanitation Commission, the Cincinnati Air Pollution
Control Division and the MRVPC. Coordination with the upstream MRVPC is
essential, as the two designated areas have overlapping basins. The MRVPC
and OKI share reports, maintain staff contacts, and participate in each
other's advisory committees.
OKI has previous experience in water supply/quality planning including re-
gional sewerage plans and a 1972 Regional water supply plan. Basin plans
are currently available only for the Little Miami (January, 1974) with the
plan for the Greater Miami in progress. The State of Ohio has done waste-
load allocations only for NPDES purposes.
OKI-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
A highly sophisticated, competent technical base was seen as essential to
the credibility and acceptability of WQM recommendations. Consequently,
the OKI WQM Director focused the project on what_ was_possible, technically.
This resulted in an emphasis on facilities planning.and a J.firstrcut J..
analysis of combined sewer overflow and aqr.icult.ur.al_nonpoinjt.-s.ources,.=.-
Staff were largely responsible for formulating the problems and objectives
the WQM project wohld address, taking information from various reports,
and applying it in terms of their familiarity with the area. The WQM
Director noted that all of the staff was drawn from the area such that a
ready grasp of the region's problems and institutional arrangements was
possible.
The WQM process is not part of an overall regional planning effort, but is
expected to feed into an ongoing OKI planning process, particularly the
detailed land use mapping and projections which had heretofore not been
done for the area. The WQM Management Planner noted that problems may arise
because WQM recommendations may not be consistent with regional goals. How-
ever, the transfer of the land use information and WQM land use subcommittee
to the ongoing regional planning effort should enable necessary revisions
and coordination with WQM implementation techniques.
B. Technical Components
From its outset, the OKI WQM project has had a three-pronged technical
emphasis; facilities planning, combined sewer overflow and nonpoint sources
in agricultural areas. OKI is producing 22 facilities plans for the area
and making composite reports of all existing and proposed facilities plans
for each of the ten counties in the area.
OKI is also making a preliminary assessment of the combined sewer overflow
problem, although the WQM staff cited several limitations to problem reso-
lution. First, data collection was viewed as insufficient for validation
within the planning period. Second, EPA guidelines regarding the degree
¦of problem correction required were not clear. Third, to remedy the com-
bined sewer overflow problem requires a large-scale commitment of funds,
particularly for the Cincinnati area. The WQM staff expected these limita-
tions to shape the final recommendations and corrective steps which will be
less than what Federal water quality standards would require.
For agricultural nonpoint source analysis, OKI has developed its own rural
runoff model which has been endorsed by EPA. Supplementing data from
other sources, OKI has been monitoring five rural watersheds since June,
1976. However, the WQM staff does not expect to achieve a sufficiently
defined and validated nonpoint source analysis within the planning period.
Determining the relative contributions of point and nonpoint sources is
OKI-5
-------
one technical difficulty. Additionally, the WQM staff noted the pro-
blems of quantifying sediment, pesticides and fertilizers.
The WQM Project Director intends to address residual wastes other than
sludge in the continuing planning program. These nonpoint source items
were not treated in the initial planning period because of the need to
focus the WQM project on other priorities. Moreover, the WQM Director
believed delay of certain nonpoint source analysis (e.g. septic tank
and leachate from sanitary landfills) was appropriate considering the
presently limited technical capability for quantifying their contributions
to the water quality problem.
The WQM project is using the same standards on all rivers and not incor-
porating an antidegradation element into the plan. TheJWQM,. staff noted
the Ohio EPA's ppsition that antidegradation was not an important issue.
Consequently, the Little Miami, although designated a Scenic River7 will"-
not receive exceptional emphasis.
Data gathering was extensive for the land use inventory and projection
completed by OKI. However, a WQM staff ir.ember noted that the relationship
between land use input and facility planning is only a one-way determina-
tion. He felt more analysis of the interaction between land use patterns
and water quality impacts would be in keeping with the WQM program intent.
Further, the OKI process had not dealt with future industrial growth which
was seen as an unknown. Rather, the WQM water quality analysis assumes
NPDES compliance. A member of the Land Use Subcommittee felt "uncomforta-
ble" about the projections because the tie between water quality and
growth was not specifically addressed. The subcommittee member felt OKI
should seek community input regarding preferred land use patterns.
C. Management Planning
Management planning began in October, 1974, with responsibility assigned
to one OKI Management Planner. The approach for facilities plans has been
to integrate management and technical planning within each basin. Techni-
cal alternatives are analyzed in terms of cost and institutional feasi-
bility, and the appropriate operating agency is then designated.
OKI's management strategy, for nonpoint sources is far more general. The
limitations of data, unavailability of specific cost figures, and the con-
troversial implications of nonpoint source controls required an "education"
or "recommendation" approach particularly for land use and sediment con-
trols as well as agricultural conservation practices. OKI did not inven-
tory the existing land use controls in the area. In addition, the investi-
gation of nonstructural techniques, (e.g. economic incentives) was a low
priority due to the technological inability to determine the relative
contributions and benefits of point and nonpoint sources.
QKI-6
-------
D. Public Involvement Program
OKI has an established committee structure to serve the entire agency as
well as the WQM effort. The Executive Committee is the policy-making body
of OKI and is composed of elected officials. A technical coordinating com-
mittee and a citizen participation committee serve the entire agency as well
as the OKI's Citizen Participation Coordinator's Office.
A Water Quality Advisory Committee (WQAC) has been established solely for
WQM purposes. The WQAC is composed of elected officials and various interest
group representatives with membership open to anyone requesting representa-
tion. The WQAC has overall review responsibilities and is divided into four
subcommittees: land use, facility planning, nonpoint sources, and implemen-
tation.
In addition to regular meetings by the various committees, OKI has recently
begun a monthly newsletter devoted to WQM activities. Facilities planning
information constitutes the largest component of the newsletter. A January,
1976 OKI publication outlined a communication process based on input from
the Implementation Subcommittee. The publication proposed strategies for
involving the plan's various constituents including county meetings with
officials and governmental administrators, slide presentations to community
meetings, a phased information packet presenting major plan elements as they
are developed, and the use of media and displays.
¦Citizen participation in the process has been problematic from several view-
points. The approach taken by_ the WQM^Direcbor__is_ that^ citizc^n^participation
should follow the technical planning component. Accordingly, he felt that
it was premature to involve the various advisory groups in the inventory
phases of the project. He noted that the several - interim reports generated
in 1975 were done at the request of the advisory committees who had wanted
non-involvement in the process.
The WQM staff felt that involvement of local elected officials and operating
agencies had been achieved, although a citizen participation coordinator did
not feel the WQM Project Director and OKI Executive Committee were directing
an extensive public involvement effort. Other than the facility plans,
he noted that the project to date has not produced tangible outputs
sufficient for public reaction. Although the community contact regard-
ing several of the facility plans was increasing the workload of staff
and consultants, all of the WQM staff believed the plans had generated
increased public awareness of the overall WQM effort. The several
citizens interviewed, including a planning commission official, were
also concerned with the limited citizen involvement to date.
E. State and Federal Involvement
As an early designate, OKI has not operated under the EPA controls that ]ater
WQM projects have experienced. Initially, OKI received minimal guidance from
EPA'and .later guidelines were not seen as helpful or clear. The WQM Project.
Director ft:It that the EPA Headquarters and Regional Office wanted to react
to documents rather than interpret guidelines. Consequently, OKI ultimately
OKI-7
-------
made its own interpretations and enjoyed, as the OKI Executive Director
noted, a fairly full reign over the project.
The EPA Region V Project Officer has a good relationship with OKI. She
attends WQAC meetings, makes frequent contacts by telephone, and is report-
edly quick to review OKI contracts and reports.
The three States became involved in the OKI project about one year after
the project was underway. OKI sought State involvement in 1975 following
EPA funding authorizations for State participation. Receiving an addi-
tional $60,000 for this purpose, OKI contracted for coordinative services
with Ohio ($34,500); Kentucky ($24,000) and Indiana (no funds requested).
The tri-State coordination effort has increased staff workload notably
including personal communications, meetings and paperwork.
OKI's relationship with the three States is diverse, although the WQM
Project Director felt satisfied with the current level of State involve-
ment. The Ohio Environmental Protection Agency (OEPA) provided a liaison
person to OKI whom the WQM staff saw as aggressive and effective. However.,
at the time of the interview, the OEPA liaison had been suspended tem-
porarily because of legal problems with State personal services contracts.
Kentucky is involved to a lesser extent, an-?, reportedly is slow in review
and reporting. The OKI staff felt that they had a rather neutral rela-
tionship with Kentucky. Indiana's participation has been limited to re-
view of reports and attending WOAC meetings. The WQM Project Director
noted that, although Indiana's State water quality function had not yet
been clearly organized, Indiana and WQM staff have a friendly relation-
ship.
The Ohio Environmental Protection Agency (OEPA) was the only State agency
interviewed. Although the OEPA Environmental Planning Coordinator believed
that two early designatees (OKI and MRVPC) had the greatest likelihood of
success, he was dissatisfied with the limited State participation in the
early designated WQM programs. Primarily, he felt that, as EPA in the
WQM program's first year provided no vehicle for State involvement, the
State has been excluded from areawide WQM efforts in Ohio. He did not
feel that State input was being used by the WQM agencies, although the
agencies were responsive to State comments. He also noted that EPA Region
V project officers for these early WQM agencies do not make an effort to
keep OEPA informed. He also felt that there was animosity between State
and Federal levelsrof involvement such that the WQM aqencles__wer^_ ujricertain
as to_"who^they_have.to_please".
OEPA has recently received funds for State WQM planning. Ohio has no com-
pleted basin plans but has determined wasteload allocations for NPDES
purposes. The OEPA Environmental Planning Coordinator did not expect the
State to assume the designated WQM agency's functions. Rather, he ex-
pected that State-local shared WQM responsibilities would enable a review
of construction grants and NPDES programs for compatibility with locally-
established priorities. He did not feel that OEPA's role included recom-
mending legislation.
OKI-8
-------
F. Scheduled Outputs
As an early WQM grant recipient, OKI does not have the scheduling require-
ments of later designates. However, OKI has outlined an output schedule
as shown in Exhibit I for the period July 1, 1976 to June 30, 1977. The
work schedule assumes a six-month extension of the project's completion
date which previously had been set for December, 1976. The WQM Director
noted that the basic obligations to the original contract would be com-
pleted by December 31, 1976. The extension was required for adequate time
for plan review, revision and adoption, and preparation of the ongoing
work program. In addition, technical assistance for implementing agency
activities was seen as essential during this period.
A draft final plan will be completed by December 31, 1976. For educational
purposes, an executive summary will be developed, A final version, after
review and revision, is expected by April 30, 1977.
Incorporated into the final plan will be management programs for each of
the river and creek basins, the environmental assessment, and most of the
22 facilities plans being produced by OKI. Although an environmental assess-
ment will be made for each recommendation throughout the plan, a summary chap-
ter of all environmental assessments will be included. Nine of the 22 facili-
ties plans produced as part of the project will be published and released
as they are completed due to the need to expedite the construction grants
process. In addition to the 22 OKI facilities plans, 35 other existing or
ongoing facilities plans will be summarized in county composite reports
contained within the final plan.
G. Achievements to Date
Although not required of early designates, OKI produced a series of interim
outputs for the benefit of the several advisory committees who had expressed a
need for more involvement in the decision-making process. To date, six
such interim reports have been completed by OKI.
o Population Projections and Acreages by Drainage Area
(June, 1975),'
o Precipitation Study and .General .Climatological Information •
(June, 1975);
o Land Use Inventory (August, ]975)"'");,
o Relationship Between 201 Local Facility Planning and Waste-
water Treatment Programs (September, 1975) '
Under contract to OKI, the Aerospace Division of Bendix Corporation
provided tapes from NASA's I.ANDSAT satellites and transferred data on
1.1 acre cells for land use inventory of rural and urban areas. Urban
area information was supplemental to data gathered by WQM staff.
OKI-9
-------
EXHIBIT I
WORK SCHEDULE
OKI
MOUTHS MONTHS
1976
147"
J 1 A 1 3 | 0
N 1 Q
a r
M | A 1 « 1 J
MSIESTCXES
1 I 2 1 3 I 4
a 1 o
t I 8
31"io in r tr
INTESGOVEKNHBTAL CCOHOIfttTION i
CITIZEN PARTICIPATION
(Governmental Consultations,
Comnittees, Personal Contact,
Presentations, Publications,
Media, ir.d Displays)
WATER QUALITY MANAGEMENT
1. A-Procsss for Mater Quality
Management
2. Characteristics of the OKI Region
3. Oeaiogripiilt, Economic And Land Use
Oenwgraphic
Economic
Land Use
4. Approach to Water Quality Manageserst
5. Watar Quality Management Program for
Uie Great Miami River 3asin
5. Water Quality Management ?r~nr*n for
the LittU- Miami River Basin
7. Water Quality Management Program for
' the Mill Crsek Basin
8. Water Quality Kanagenent Program for
tie Licking Siver 3asir.
9. Water Quality fenageoar.t Prograa for
Areas Directly Tributary to the,Ohio
River
10. Residual Masts
11. Environmental Assessment of the 203
Plan
12. Management and Institutional Aspects
of the 2CS Plan
FACILITIES PLANS
1. Waynesville-Harveysburg-Corwin-Caesar
Creek Reservoir Area, Warren County,
Ohio
Z. SuUitsville-Hebran-Burl ington,
Boone County, Kentucky
3. Kiddle East For):, Cleraont County,
Ohio
ON-GOING
ON-GOING
&
©
o
4
1
©
©
0
©
®
©
©
©
CCHPLETE3
COWLETE0
©
OKI-IO
-------
MONTHS MONTHS
(Cont.)
1976 J 1577
J
A 1 5
0 | N i 0
J
1 «
A
M I J
MILESTONES
1
2 1 3
4 i S | 6
/
¦8 I
lo
1 1
12
4. Glendale, Hamilton County, Ohio
5. Florence, Boone County, Kentucky
6. loveland, Hamilton County, Ohio
7. Felicity, Clermont County, Ohio
8. Milford, Clemioot County, Ohio
9. Harrison, Hamilton County, Ohio
10. Landen Farms, Warren County, Ohio
11. East Middletown, Warrer. County, Ohio
12. Owensville, Clermont County, Ohio
13. Independenca, Kenton County", Kentucky
14. Taylor Mill, Kenton County, Kentucky
15. Cold Spring, Campbell County, Kentucky
Alexandria-Clairyville, Campbell Co., Ky
17. West Mlddletown, Sutler County, Ohio
18. New Richmond, Clermont County, Ohio
19. Walton, Boone County, Kentucky
20. South Dearborn Regional, Dearborn
County, Indiana
21. Horner Run Area, Clermont County, Ohio
22. Ridgeview Hgts.-Beech Grove, Kenton
County, Kentucky
23. Warren County, Ohio Facilities Plan:
A Ccrcposit Report
24. Sutler County, Ohio Facilities Plan:
A Coraposit Report
25. Clermont County, Ohio 'Facilities
Plan: A Composit Report
25. Hamilton County, Ohio Facilities
Plan: A Composit Report
27. Boone County, Kentucky Facilities
Plan: A Ccmposit Report
28. Campbell County, Kentucky Facilities
Plan: A Ccmposit Report
29. Kenton County, Kentucky Facilities
Plan: A Composit Report
©
©
©
©
©
©
©
.
©
©
©
e
©
@
©
€>
©
©
©
COMPLETED
©
©
©
©
©
OKI-11
-------
MONTHS MONTHS
(Cont.)
1976
1977
J | A
0 1 M
0
J 17
M
A
M | J
MILESTONES
1
2
4 | 5
0
/
3
9
10
n i 12
30. Oearborn County, Indiana Facilities
Plan: A Ccmposit Report
31. Ohio County, Indiana Facilities Plan:
A Composit Report
©
©
203 PLAN
1. First Draft Report
2. Release First Oraft Report for Final
Review to:
Ohio, Kent'jcjiy, Indiana, U.S. EPA,
and local jurisdictions within ths
OKI Region, and committees (OKI
Executive Connittee, Water Quality
Advisory Comittee, and Subcommit-
tees)
3. Public Meetings on First Oraft Report
4. Secure Input'From PuLiic Meetings and
all Reviews (from I tents 0-2 above)
5. Modify First Draft Report in Accord-
ance with the Input from Public,
Meetings and Reviews
6- Final Report
PLAN ADOPTION/CERTIFICATION
PREPARE PROGRAM FOR ON-GOING PLANNING
1. 208/303(e)/NPDES
> 2. 208/201 (Plan Uodate)
3. Non-Point Source Management
4. Intermittent Source Management
5. Institutional Restructuring
TECHNICAL ASSISTANCE SERVICES
1. Facilities Plans
2. Irrternittent Sourcas
3. Other
©
©
©
0
©
©
©
©
©
&
©
ON-GOING
ON-GOING
ON-GOING
ON-GOING
SOURCE: OKI Council of Governments, Work Schedule July 1, 1976
through June 30, 1977, July 13, 1976.
OKI-12
-------
o Method for Assessing Rural Nonpoint Sources and i.t-s
Application in Water Quality Management (September, 1975) 1 ^
o Assessment of Hydrological and Ambient Quality of the Region's
Major Streams (October, 1975).
OKI has also produced a preliminary set of geographic and political boun-
daries to delineate facility service areas. In addition, the assessment of
the Great Miami River Basin and its management strategy have been completed.
Facilities plans for the Caesar Creek Reservoir Area, the Warren County
Ohio Composite Report, and the Bullitsville-Hebron-Burlington, Kentucky area
have been completed. The facilities plan for the Caesar Creek Reservoir
has already been "worked through" with local participation in determining
cost-shares and institutional arrangements. The facilities plan for the
East Fork Reservoir is currently undergoing a similar process.
The WQM Director outlined several additional achievements of tlie OKI effort.
o The WQM project has generated the first detailed analysis
of land use in the agency's history. The data base and pro-
jections filled a gap in the 701 planning effort and now
provides information regarding the capability of land areas
for development. The inventory, prepared using LANDSAT 1
satellite imagery, is available to anyone and is particularly
useful for environmental impact statement preparation. For
example, the WQM Director noted that industry may now. be
allocated to sites where they can best be accommodated in .
terms of land use and water quality.
o The rural runoff model, developed by OKI and endorsed by
EPA, enables a computation of surface erosion, sediment
yield, nutrient and organic loadings and as well as load
reduction achieved by various management techniques. Since
June, 1976, OKI has been monitoring the quantity and quality
of runoff from five rural watersheds.
o OKI has already achieved successes in completing and institut-
ing the Caesar Creek Reservoir Facilities Plan. A cost-
effective regional facilities plan, in cooperation with the
Corps of Engineers, was developed and has been locally nego-
tiated regarding costs and operating arrangements. A similar
process is currently underway for the East Fork Reservoir
area.
o Two outlying communities have been included in an existing
facility service area.
o The WQM Director believed that 90 pel'cent of the facilities
plans would be implemented and that the development of the
¦ 1
•The rural nonpoint source model endorsed by U.S.EPA is felt by the WQM staff
to be a particular achievement and will be discussed below.
OKI-13
-------
facilities plans has provided visibility and credibility
to OKI's overall WQM planning program, including future
nonpoint source management.
OKI--14
-------
III. EXPECTATIONS
A. Water Quality
The main effort in the OKI WQM process is directed toward correcting the
wastewater treatment problems of the area. The WQM staff believed facili-
ties implementation would make considerable progress toward achieving water
quality standards. Allintcrviewees(with one exception) agreed that upgrading
municipal facilities would make a substantial contribution to water quality
improvement. Several interviewees noted that increased awareness of identi-
fied water quality problems would contribute to improvement.
No one expected resolution of the nonpoint source problem in ,.the._.near ..future.
¦The primary deterrents were costs and lack of public awareness. A spokesman
for a county official felt that problems of construction practices, stream
sedimentation, and septic tanks should be resolved, but only in terms of
alternatives which enable profitable uses. An operating agency head doubted
any improvement in nonpoint source control would occur due to lack of fund-
ing, problem awareness and legislative commitment. The OEPA Environmental
Planning Coordinator felt improvement would be achieved through the review
of construction grants and NPDES permits for compatibility with locally es-
tablished priorities and he expected such review would institute a better
processing mechanism available to both State and local efforts.
No one expected that the area would achieve the fishable, swimmable goals
by 1983, although most expected goal achievement in certain segments, and
some progress in other areas. One citizen believed that the 1983 goals
would be revoked. Fishable, swimmable goals for Mill Creek were not seen as
realistic by WQM staff, as clean-up would not be cost-effective. One citizen
stated that the goals should be for selective and realistic clean-up efforts.
The WQM Director and Water Quality Engineer saw intermittent and nonpoint
sources as the major obstacle to 1983 goals attainment largely due to con-
siderable costs and technological limitations. Consequently, the WQM
Director believed that the goals may be achieved in 1990 or '95. Attention
to toxics, which are outside of the WQM process, was seen as necessary al-
though the technology is not currently available.
B. Plan Approval and Implementation
All of the interviewees expected the plan would be approved locally although
cost implications of plan recommendations may be a potential source of con-
troversy. Approval was seen to be assumed by the involvement of local
elected officials on the OKI Executive Board and the WQM Water Quality
Advisory Committee. Further, OKI staff expect the six-month extension of
the project to allow adequate time for plan review, revision and approval.
State approval was expected by the local interviewees as well as the OEPA
Environmental Planning Coordinator.
The likelihood of plan implementation is far more speculative. Generally, it
is believed that certain aspects of the plan such as the facilities plans will,
he implemented provided -that the management proposals are acceptable. In this
OKI-15
-------
regard, the WQM staff believes that the involvement of elected officials
and operating agency heads has worked toward establishing the appropriate
management linkages. However, officials' commitment to the planning
effort is perceived (by the officials) as necessary in obtaining construc-
tion grants. The WQM staff notes a good level of public involvement for
all of the facilities plans v/hich OKI has taken to the communities for
discussion, but this participatory process will not be possible for all
facilities plans being developed within the time allotted. Outside of
facilities plans, plan implementation is expected but only as several
criteria are met: funding, federal backing, increased public awareness
and the effectiveness of voluntary programs based on public education.
In no sense gas implementation of nonpoint source controls expected to
occur in the near future.
The WQM staff believed that certain nonpoint source controls may not be
possible due to the lack of verified data, the standards for sediment
and nutrients, and also due to the cost implications. Combined sewer
overflow control was viewed as particularly cost-prohibitive. Conse-
quently, the WQM staff expects plan recommendations to be general and
to approach implementation by providing technical assistance to local
agencies (e.g., drafting ordinances and land use planning). In agri-
cultural areas, conservation practices Traditionally have been under-
taken on a voluntary basis. Accordingly, OKI intends to approach rural
runoff controls by working through the SCS, ASCS and agricultural ex-
tension services and education programs. The WQM staff recommended that
a State level interagency committee in Ohio could assist in nonpoint
source control efforts. Further, the WQM Project Director believed
that federal funds should be allocated to a nonpoint source program
similar to the construction grants program or to the USDA for instituting
controls in this area.
The various interviewees cited potential factors important to or limiting
plan implementation:
-o Costs were a major and frequently mentioned constraint.
Two citizens felt implementation depended on Federal
funding, including funds for developing compatible
land use plans at the local level.
o Most of the interviewees believed public awareness of the
water quality problem to be very low, with most attention
centered on Cincinnati water supply issues of fluoride and
carcinogen contamination. One citizen expected the plan
would need considerable public exposure before any imple-
mentation was attempted.
o Two citizens cited potential problems with the building
industry, especially if septic tank and package plant
controls emerge from the plan arid, thereby, imply a no-
growth policy.
OKI-16
-------
o An operating agency head stated that plan implementation
depended on the acceptability of the management proposals.
He expected some minor disruption of existing agencies.
He added that the proposed regionalization of facilities
and their management were only somewhat disruptive and may
not be cost-effective solutions.
No new WQM agencies are expected to be established. The WQM staff, as well
as the OEPA Environmental Planning Coordinator and a planning commission
official expected implementation to occur through existing agencies, per-
haps through cooperative agreements. In no sense did WQM staff view OKI
as an implementing agency, but rather as providing continuing planning
assistance for facility planning and for nonpoint source implementation,
such as conservation planning. A spokesman for a county official expected
implementation on a regional scale, possibly a substate regional office,
although he was in favor of implementation mechanisms which were the most
cost-effective and locally acceptable. An operating agency head saw
the need to strengthen existing authorities, but aid not want enforcement
delegated to operating agencies.
The WQM Management Planner has identified the following gaps in authority
which affect plan implementation:
o A lack of consistency exists among local ordinances;
o Existing authority at the county level is weak. Counties
can regulate subdivisions although townships may opt for
developing and enforcing their own controls;
o Ohio enabling legislation for land use regulation does not
contain language requiring planning studies and environ-
mental impact statements;
o There exists a lack of attention to storm drainage other
than large-scale work done by the Miami Conservancy District*
o Septic tank controls are not enforced although Ohio enabling
legislation is good. The Kentucky Sanitary Code is con-
cerned with septic tanks as products rather than with their
performance;
o There is no policy regarding sewer extensions or coordina-
tion between -public facilities planning and programming
efforts;
o Local sediment controls are necessary, however WQM staff
believes local agencies are somewhat aware of this need.
No specific recommendations had yet been developed in regard to State legis--
lative needs. The WQM Director viewed legislation for nonpoint source con-
trols as part of the WQM continuing planning effort. Technically, OKI was
attempting to correlate point and nonpoint source contributions for each
water quality segment, and the WQM Director expected that, if nonpoint
OKI-17
-------
sources become a problem relative to point sources, steps toward legis-
lation will be taken. A planning commission official believed all neces-
sary laws had been enacted and the main question was one of implementation.
An operating agency head viewed legislative needs to depend on the agencies
with legal responsibility for WQM and the disparity among the county and
municipal ordinances.
The OEPA Environmental Planning Coordinator expected a need for extensive
legislation although he had not yet examined what authority currently ex-
ists. He did not expect any legislative activity for at least one year
and did not view recommending legislation as an appropriate State role.
The WQM staff's view that the State should be working toward needed legis-
lation was contrary to the OEPA's position.
C Continuing Planning Process
OKI's work schedule for July, 1976 to June 30, 1977 assumes favorable con-
sideration of its request for a time extension beyond the original termina-
tion date of December 1976. The extension was viewed as essential for final
plan review, revision and adoption as well as preparation for the ongoing
WQM process. OKI has sufficient funds for the six-month extension due to
extreme parsimony during the project period. The Work Schedule outlines
elements of the ongoing process which are expected to require a minimum of
two years. These elements are listed below:1
o Coordination of WQM and basic planning programs with the
States and review NPDES permits for consistency with the
WQM plan;
o Rural nonpoint management strategy including a coordinative
process for integrating WQM recommendations into SCS, ASCS
and agricultural extension services, i.e., establishing
priorities based on sediment runoff probabilities and pro-
posing criteria for allocating funds to conservation dis-
tricts for pollution control efforts;
o Intermittent source management including abatement activi-
ties related to combined sewer overflow and cost alignment;
o Institutional restructuring including OKI technical assist-
ance to local operating agencies;
o Public awareness program; and
o Technical assistance including financial reports for facili-
ties plans, incorporation of water quality criteria into
land use decisions, consultation with State legislative com-
mittees (i.e., nonpoint source controls and septic tank
standards), educational effort.with building and develop-
ment industry concerning urban runoff controls, advising
operating agencies regarding sludge handling techniques.
OKI-13
-------
OKI also wants to examine other residual wastes not addressed in the cur-
rent time frame and to continue monitoring on the great Miami River.
To maintain staff for execution of the foregoing activities, the WQM project
Director Celt that, in the absence of Federal funding, continued funding
(at a minimum of $300,000) possibly would come from several sources; State,
local, and operating agencies which contract with OKI. At this time, none
of these sources have made any financial commitments to the WQM process,
nor have arrangements been pursued.
All interviewees expected the WQM planning process to continue at the
regional level if federal funds are provided. Elimination or substantial
reduction of the program was expected if local funding were required al-
though a. federal-local match was possible. One citizen interviewee noted
jurisdictional problems of attempting uniform assessments throughout the
area. One operating agency head hoped the continuing planning function
would have a well-defined objective with built-in continuity and delinea-
tion of responsibilities. He thought "overagency" planning functions ,
should include a review of district interrelationships to avoid dupli-
cation of effort.
All agreed that State assumption of continuing VJQM planning responsibility
was highly unlikely because of the tri-State nature of the area. The
OEPA Environmental Planning Coordinator saw the WQM program as appropriately
regional and not as a State function. However, the State of Ohio will
share responsibilities with designated WQM agencies in the State's contin-
uing planning process which the designated agencies had a major role in
generating. Issues of a continuing nature were water quality standards,
wasteload allocations, and plan updates among others not yet identified.
The focus of the continuing process, in his view, depended on the suc-
cess of the VJQM effort.
D. Relation to other Water Quality Programs
OKI's WQM Project Director noted that the wasteload allocations were being
determined for each basin and, depending on their use by the State, ex-
pected appropriate revision of NPDES permits. The ongoing planning pro-
cess contains a work element for reviewing NPDES permits for consistency
with the WQM plan.
The OEPA Environmental Planning Coordinator stated that most Ohio WQM efforts
were out of phase in issuing the next round of NPDES permits. Generally,
he did not expect timely input from the WQM agencies. He felt, however,
that the WQM would institute a processing mechanism for reviewing the
compatibility of construction grant and NPDES permit programs with locally
established priorities.
The relationship between 201 local facilities planning and the WQM pro-
gram is outlined in an Interim Report which OKI released in September,
11975. The-report establishes an A-95 review procedure for ongoing facili-
ties plans within the designated area to assure compatibility with the WQM
OKI-19
-------
plan. Such review normally will occur in the early stage of the planning
process. OKI will continue its involvement to a lesser degree through
steps II and III.
OKI is putting substantial effort into facilities planning. OKI has al-
ready produced a preliminary set of geographic and political boundaries
to delineate facility service areas. The WQM project itself is developing
^ 22 facilities plans, nine of which will be published under separate cover
to expedite the construction grants process. The remainder of the facili-
ties plans will be part of the final WQM plan, along with composite re-
ports for each of the area's counties. The composite reports summarize
35 other existing or ongoing facilities plans in the area.
After adoption of the WQM plan, the Interim Report provides that new facili-
ties planning activities be supplemental to the WQM data analysis and that
new construction grants be made to designated management agencies.
OKI has been negotiating institutional and financial arrangements toward
implementing several facilities plans. The WQM Project Director saw an
ongoing role for OKI in providing similar technical assistance to operat-
ing agencies as facility plans are implemented. He also viewed OKI as a
possible consultant for Steps II and III, noting the sizeable cost savings
of facilities planning at the regional level. He estimated that OKI com-
pleted plans for two counties as part of HUD water and sewer plans.
An operating agency head believed the WOM plan would reduce the scope of
work necessary for Step I of the construction grant process although he
felt some recommendations would be based on insufficient data due to fund-
ing constraints. He believed the recommendations may become obstacles to
later necessary changes. He also felt that to avoid duplication of facilities
and data collection/analyses, an overagency with general planning responsi-
bilities was. necessary. He did not expect WQM planning to affect Step II.
Three citizens agreed that the WQM plan would have some impact on the con-
struction grants program including more efficient systems, proper staging
of facilities, and reduced data requirements for future facility plans.
E. Local Definition of Success
Most interviewees defined WQM success, simply, as any effort which would
achieve area-wide acceptance. Though one respondent defined success in
terms of the 1983 goal achievements, others agreed that the WOM plan probably
would fall short of the goals as expressed in the Act.
o Several persons agreed that -the plan should not dictate
or enforce policy, but rather should provide data and other
supportive tools for local decision-making.
o One citizen stated that a successful WQM plan would function
within the desired land use patterns of the area.
0KI-2Q
-------
o The OKI Executive Director defined success as adoption
and funding on a continued basis without compromising water
quality standards.
o The WQM staff felt that the joint-community, effort was a
success for the program and cited achievements in the facility
planning processes for Caesar Creek and East Fork Reservoirs.
o The OEPA Environmental Planning Coordinator defined success
as achieving agreement on a plan/process which was both ac-
ceptable to the Governor and,for the most part, able to be
implemented within.six months.
In addition to defining success for the WQM effort, interviewees cited bene-
fits arising from the WQM process:
o An increased awareness of the water quality problem,"
o Land use/site decisions affecting future growth;
o More efficient use of available pollution control funds
o Institutionalization of pollution control related industries; and
o A coordinated and cohesive plan to achieve a certain level
of water quality standards.
OKI-21
-------
IV.
VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM Project Director generally viewed OKI's role as producing a tech-
nically credible plan. As- discussed in Planning Strategy (Chapter II),
the WQM Director strongly disagrees with EPA's overall programmatic emphasis
on management. His approach is to consolidate support around a well-
founded technical base. He views management primarily as developing a
team of operating agencies which convinces the public of visible and pro-
ductive WQM authority. WQM strategies are to be applied locally through
OKI technical assistance to communities in the continuing planning process,
both in terms of facility plan implementation and public "education" and/or recom-
mendation of nonpoint source controls.
B. Citizens
The three citizens interviewed were active in two or more WQM advisory com-
mittees and, partially because of their backgrounds or interest group ac-
tivities, had considerable knowledge of the project. All supported the OKI
effort but expressed concern with OKI's public involvement.
o 3Vo citizens were satisfied with their involvement on
advisory committees. One citizen, however, was not satis-
fied and felt that OKI "fed" information to advisory com-
mittee members who she felt had little input in selecting
alternatives. She also considered the large number of WQAC
members to limit effective participation.
o Two citizens noted that the WQM program was so massive
and technically complex that intelligent input was most
difficult to achieve. Generally they felt the WQAC was
asked to approve technical reports which are confusing and
difficult to evaluate.
o Two citizens noted that public education regarding the water
quality problem was not occurring and that the plan would need
considerable public exposure prior to implementation.
o Two citizens were critical of particular aspects of the
planning process such as: 1) OKI not considering future
industrial development in forecasting future loads, 2) the
land use data base and projections were not discussed
locally for input regarding community needs and growth
preferences.
Citizens expected costs to be the major limiting factor in implementation.
One citizen hoped the plan primarily would provide data and background
information which would be advisory to local government actions. He also
praised OKI for using WQM project data in A-95 reviews.
OKI-22
-------
c.
Local Elected Officials
The OKI staff arranged interviews with a county planning commission member
and an assistant to a county judge who also directed the county community
development agency. Neither cf these officials are elected, but they serve
on the OKI Executive Committee. The Executive Committee's role in WQM is
to monitor the process, review policies to meet objectives and review final
reports and plans. One official also served on the WQAC and land use sub-
committee .
o Both officials supported the OKI effort and supported WQM
goals to protect water quality and control growth.
o Both officials considered obtaining funds for WQM imple-
mentation to be a sizeable problem. One official was not
certain that people would voluntarily go along with tax
increases and the other noted that his area did not have
the revenue for WQM.
o Both felt the plan function to be educational and advisory
to local elected officials. While one official felt the
plan must be stronger than advisory, the other believed
local support would be lost if the plan coerced local
officials to take action.
o Both were concerned with the need for compatible land use
planning. One official believed many planning commissions
do not consider the environmental impacts of zoning changes.
The other noted that his county has no land use planning
and felt WQM plan implementation would depend on the develop-
ment of a consistent land use plan.
D. Appointed Officials
The appointed official interviewed heads a two-country sanitation district
and serves as chairman of the WQM Facilities Subcommittee. He did not
expect the WQM project to affect his future activities other than per-
haps add to collection responsibilities. He expected the WQM plan to
reduce the scope of work necessary for Step I of the construction grants
program. However, he felt the cursory level of analysis in the WQM plan
will produce recommendations which later may prove faulty. The inter-
viewee felt the WQM program had not clearly defined responsibilities for
assimilative stream capacity, the interrelationship of WQM planning, basin
planning and the construction grants program. He could not yet see how
all of the facilities plans would be incorporated and was concerned that
recommended changes in operating agencies might not be cost-effective.
Overall, lie saw the need for an overagency with general planning responsi-
bilities to oversee major systems, prevent duplication of effort and define
responsibilities. He did not favor operating agencies as management agencies
or management agencies with enforcement duties.
OKI-23
-------
E. State Legislators
One of the two Ohio State Legislators interviewed was a State Senator and
Majority Whip who also served on the Senate Energy and Environment Committee.
He had no involvement with the WQM program and has not been contacted by
any WQM agencies. He felt that his awareness of the program was limited.
He also indicated that the Legislature generally is not aware of the WQM
program or its objectives. He strongly recommended that the attention of
Legislators might be gained if the program were presented to them in a
documented form which highlighted the fact that related legislation may
be required. He felt that water quality was not a priority issue in the
Legislature.
A freshman Representative to the Ohio House of Representatives was also
interviewed. She had not been contacted by any WQM agencies and was
not aware of the WQM program. She felt it was the responsibility of the
WQM agencies to keep Legislators informed. She felt it was OEPA's responsi-
bility to suggest any needed water quality legislation, but noted present
State administration's priorities for jobs and industrial development may
conflict with water quality objectives. She felt that water supply con-
tamination by carcinogens in Cincinnati, had elevated Legislative awareness
of certain v;ater quality problems.
F. State Water Quality Personnel
Although OKI serves a tri-State area, the OEPA was the only State agency
visited. The Environmental Planning Coordinator was dissatisfied with
OEPA's limited participation in OKI's efforts which he felt were caused
by EPA delay in providing a vehicle for State involvement. Although OKI
was responsive to State comments, he did not feel that State input was
being used. He also felt that there was animosity between State and Fed-
eral EPA involvement, such that the designated WQM agencies were uncertain
as to whom they were responsible.
Although Ohio is just beginning State WQM planning, the OEPA Environmental
Planning Coordinator expected continuing planning to be a State-local
shared responsibility. He viewed the designated WQM plan based on locally
established priorities to provide input to the construction grant and NPDES
programs. He did not feel OEPA's role should include making legislative
recommendations or to assuming designated WQM functions. He voiced sev-
eral major criticisms of the WQM process. He said that U.S. EPA had not
worked toward massive public education and participation and that this was
essential, given the low level of awareness of the water quality problem and
the limited ability of the agencies to reach the general public. He also
felt that the relationship between water quality and water supply had not
been emphasized and noted that State planning for nondesignated areas will
encourage the incorporation of related water supply and solid waste elements.
OKI-24
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
There is little doubt that the plan will be completed. Progress is being
made toward completion by the December 31, 1976 deadline. With the six-
month extension of the project until June, 1977, OKI has adequate time for
plan review, revision and adoption.
The extension seems critical to gaining public and political support. The
advisory committees have had limited exposure to plan components as they
are generated, and it will not be until the plan is completed that they will
have an opportunity to react to a totally integrated WQM strategy. The
size of the plan and its technical nature will hinder critical review unless
OKI develops executive summaries which clearly present the plan's assump-
tions and implications. Fortunately, OKI has the resources to complete the
plan review process. The six-month extension of the project with full staff
retention was possible only because of funds reserved by OKI through their
efforts to cut costs. Further, much of their work was completed within OKI,,
which made tighter financial management possible.
The question of State and EPA approval is more difficult. As Ohio is just
preparing for State WQM planning, OKI has a technical advantage over the
State,whose perspective has not yet been developed. Although the OEPA
Environmental Planning Coordinator currently expects to approve the OKI
plan, it is not clear when the plan will be certified. The OEPA Environ-
mental Planning Coordinator recently informed the EPA Regional Office that
no WQM plans would be certified until November, 1978. Although the EPA
Regional Office has not yet taken decisive action on OEPA's position,
delayed State certification would disallow OKI input to the NPDES permit
and construction grants programs.
Whether or not OKI's plan will meet EPA requirements remains to be seen.
On the one hand, EPA approval would seem likely because tighter scrutiny
of OKI appears inconsistent with the free reign it has enjoyed as an •
early designate. Usually planning far in advance of issued EPA guidelines,
OKI has autonomously interpreted the intent of the WQM program and
shaped its own best approach. In the case of combined sewer overflow,
however, OKI has already anticipated that plan recommendations for
corrective measures will fall short of achieving water quality-standards.
OKI is emphasizing point source control as a more immediate target for
water quality improvement and has taken an "education" or "recommendation"
approach to nonpoint source control which is to occur in the continuing
planning process.
The outlook for OKI facilities plan implementation is good. By develop-
ing plans at a cost savings to local communities and becoming directly in-
volved with determining cost share and institutional responsibilities, OKI
has become somewhat indispensable to local public agencies. OKI expects
to assist more local communities with cost and management determinations
and also expects local agencies to seek OKI assistance in developing Step
II and III plans.
OKI-25
-------
Aside from the question of federal funding, three other issues may present
difficulties to facility plan implementation. First, as one of the major
- facility operators noted, OKI proposal for reginalized facilities may
not be cost-effective. Because the proposals only" caXi"'Tor^milior'"c hanges
in existing management agencies, the costs of these changes may outweigh
their benefits. Second, small rural towns which have not been directly
involved in the VJQM planning process may oppose plan recommendations which
remove authority from their purview, and simultaneously impose higher
sewer charges. Third, as"the~WQM Management Planner "indiVated,_the OKI
land- use data base and projections prov_ided^the basis for_ facility^planning
without attention to. the impacts of facilities on_grov.'th and land use
patterns. Citizens had also criticized OKI for the lack of local input
to the facilities plans regarding local preferences for growth and land
use. As the areawide attitude seems to favor controlled growth, the
investigation of managed growth options as related to facility planning
would seem desirable. Some oppostion may arise if the facility plans
imply growth or land use patterns in conflict with local/regional goals.
OKI will not be making specific recommendations for implementation of
Q-Q.Q]^iji.t_ssotur.c.e_,c.qntrp,ls.. OKI.,._as__a_.yoluntary association of local govern-
ments, does not have the implementing authority to coerce local compli-',
ance'"""~At this juncture, the nonpoint source data is too weak to provide
credible support of regulatory actions. Recognizing its data limitations,
OKI hopes to use the continuing WQM planning process to verify data and
work with local governments to incorporate nonpoint source controls intc
local ordinances and land use plans. Hence, it would seem that future
implementation of nonpoint source controls would depend on the continua-
tion of OKI's VJQM planning and technical assistance capabilities.
A variety of variables affect their capabilities: the presently unknown
source of funding; the low level of public awareness of the water
quality problems; the fragmentation of authority among municipalities,
townships and counties; and the overall dubious receptivity of local
governments to instituting nenpoint source controls. In addition, the
disparity among or total lack of local land use plans complicates the
outlook for plan implementation. If available, the local land use plans
might provide some basis for determining local land use and water
quality interactions. OKI's scientifically determined land capability
analysis is not a substitute for locally determined land use patterns.
The usefulness and success of the OKI plan is contingent upon its
consistency and compatibility with local goals, as perceived by local
decision-makers.
In agricultural areas, OKI hopes to achieve improvement in the nonpoint
source problem through an educational approach. Rather than its own
staff, OKI hopes to utilize the personnel of the SCS, ASCS and agricul-
tural extension services which have considerable expertise in conser-
vation practices and agricultural productivity, and also have rapport
with farmers.
OKI-26
-------
B. Public Involvement
Public participation is one of the weaker_asp_ects_of the OKI effort.
Participation to date has been limited mostly _to_thg^.:W_OM_ advisory^qomr
mittees. The convmittees' effectiveness depends on their commitment
and capability to review the WQM process thoroughly on an ongoing
basis. However, one interest group representative felt that many
committee members were not particularly active because of other com-
peting environmental interests. He felt it was unfortunate that
the same citizens are performing advisory functions in all of the area's
environmental activities. Further, several advisory committee
members noted that the program was so massive and technically complex
that obtaining intelligent citizen input was difficult. A
citizen had voiced concern that committees served as "rubber stamps"
to end products, and criticized OKI for not discussing growth
implications and preferences at the local level.
The Project Director believed that the appropriate time for citizen
participation was after the completion of a technically competent plan.
Rather than soliciting citizen input on an ongoing basis, the Project
Director seemingly preferred to develop a technically convincing plan
which can be "sold" to the public. Contrary to this, however, OKI
Citizen Coordinators believed that a more extensive public involvement
effort should have occurred throughout the planning process. All agreed
that OKI was focusing on the plan review period to solicit citizen
input. Following plan completion, OKI intends to disseminate
summaries of major plan elements, hold public meetings and county-
level briefings for officials and agency heads, and use various media
techniques designed to increase public awareness. The Project Director
was fairly confident that public comment would not require significant
changes in the plan.
Although the WQM staff believed that local elected officials and
operating agency heads had been sufficiently involved, there was
general concern that their commitment extends only to the partici-
pation required for construction grant eligibility. This concern
prompted citizens serving on the Implementation Subcommittee to
push for more representation of local elected officials.
C. Current Planning Process
As an early designate, OKI has had few State and EPA directives. Conse-
quently, OKI has had fairly free reign over its WQM project. OKI
developed an approach to the water quality problem in terms of what
OKI could manage technically and political]y within the planning
OKI-?. 7
-------
period. In the initial planning period, OKI emphasized facilities
planning. By successfully consolidating support among the area's
operating agencies, OKI hopes to gain the problem-solving credibility
necessary for tackling the more time-demanding and technically complex
water quality problems; i.e., isolating the relative contributions
of point and nonpoint source loads.
The WQM Director placed most project emphasis on producing a technically
credible strategy and openly differs with EPA Headquarters on WQM
programmatic emphasis on management. Management planning was the
sole responsibility of one staff member who believed the task too
great for one person. The thoroughness of the management analysis
may be affected_ because existing land use autho_ritas not inven-
toried| nor were managed grov?t^options__explored. The seemingly
limited interaction.._of__land use,.and, water, gual.ij:y_ conce^pj;^ .together
. with_th„e„lack^of_.loca 1._ine garding land use/growth preferences,
,is_. an ..issue.^to.r wat ch_as . OKI '_s.,WQM_program reaches the approval
and implemen tation stages.
D. Continuing Planning Process
From the outset, OKI expected to use the continuing planning process for
strengthening its technical base and providing technical assistance to
local governments. Given the present weakness of the nonpoint
source data, analytically supported nonpoint source recommendations
will not emerge unless the OKI WQM planning process continues. Many
aspects of the plan's implementation, (technical assistance regarding
facility plans) rely on an ongoing WOM planning role for OKI.
WQM project continuation beyond July, 1977 seems to depend on OKI's
success in obtaining funding commitments from Federal and
county sources. OKI is currently pursuing demonstration project,
funding for its planning components which have national implications.
Counties are postulated as short-term funding sources because of
their need for OKI assistance in facility planning efforts. The
overall outlook for continuing planninghowever, appears to hinge
on the congressional indicators of longer term Federc^^support^
E. Significance of Local Elected Officials' Involvement
The OKI Executive Committee, or regional decision-making body, is the
center of local elected official involvement. The Executive Committee
purportedly has an impact on the shape and direction of the WQM plan and
is responsible for final review. Although WQM data is already being
utilized for OKI A-95 review at the Executive Committee level, and
the officials interviewed seemed to be well-informed of the WQM
OKI-28
-------
process, their commitment to the WQM project is unclear. As several
interviewees noted, local elected officials were committed to the extent
that their participation was required for construction grant eligi-
bility .
The commitment of local elected officials is important to the implemen-
tation of plan recommendations. The areawide interest in growth
control or selective development provides a political climate recep-
tive to plan proposals affecting land use patterns. With technical
documentation of land capability and water quality impacts, the
OKI plan may advise local governments of considerations useful in,
and supportive of, their decision-making process.
OKI-29
-------
AGENCY: SOUTHEASTERN WISCONSIN REGIONAL PLANNING COMMISSION (SEWRPC)
REGION: V - (Chicago)
GRANT AMOUNT: $2,607,000
GRANT RECEIPT: June, 1975
STARTING DATE: December, 1975
STATUS AT TIME OF INTERVIEWS: The program is'completing the date collection
phase.
REASON FOR INCLUSION IN SAMPLE: The SEWRPC is representative of a highly
urbanized area.
SEW-1
-------
i. background!
A. Area Description
The Southeastern Wisconsin Planning Region is comprised of Kenosha,
Milwaukee, Ozaukee, Racine, Walworth, Washington, and Waukesha Counties
in southeastern Wisconsin. (Sec Figure I.) Exclusive of Lake Michigan,
these seven counties have a total area of 2,689 square miles and to-
gether comprise about 5 percent of the total area of the State of
Wisconsin. About 40 percent of the state population, however, resides
within these seven counties, which contain three of the seven and one-
half standard metropolitan statistical areas in the state. The region
contains approximately one-half of all the tangible wealth in the State
of Wisconsin as measured by equalized valuation and represents the greatest
wealth-producing area of the state, and about 42 percent of the state
labor force is employed within the region. It contributes about twice
as much in state taxes as it receives in state aids. Region has been
subject to rapid population growth and urbanization and, in the decade
from 1960 to 1970 accounted for 40 percent of the total population in-
crease of the entire state.
Geographically, the region is located in a relatively good position with
regard to continued growth and development. It is bounded on the east by
Lake Michigan, which provides an ample supply of fresh water for both do-
mestic and industrial use, as well as being an integral part of the major
international transportation network. It is bounded on the south by the
rapidly expanding northeastern Illinois metropolitan Region and on the
west and north by the fertile agricultural lands and desirable recrea-
tional areas of the rest of the State of Wisconsin. Many of the most
important industrial areas and heaviest population concentrations i.n the
Midwest lie within a 250-mile radius of the region, and over 35 million
people reside within this radius, an increase of nearly 5 million persons
over the 1960 level. Preservation of environmental quality is considered
a desirable goal in the region because of the large numbers of bodies
of water (a predominant State geographic factor) and because of the
water's value as an economic asset for tourism and recreation.
Information in this Chapter is taken from The Study Design for Areawide
Water Quality Planning and Management Program for Southeastern Wisconsin,
1975-1977; The 1974 Annual Report; and interviews.
SEW-2
-------
FIGURE I
SOUTHEASTERN WISCONSIN REGION
STATE OF WISCONSIN
"""
p''
*. zuLiX
! <-T"" 'i ¦ •
Sou,ce: SEWRPC
SEW-3
-------
B. Water Quality Problem
There are 11 major natural watersheds in the region, which is traversed
by the subcontinental divide separating the Great Lakes - St. Lawrence
River drainage system from the Mississippi River Drainage system.
The Commission's experience in significant water resource planning
dates back to 1964. The natural watershed was selected by the Commission
as the basic water and water-reJated resource planning unit. Comprehen-
sive watershed plans have been completed for the Root, Fox, and Milwaukee
River watersheds, and are under preparation for the Menomonee and Kinnickinnic
River watersheds.
The basic purpose of watershed planning program is to permit public
evaluation and choice of alternative water-resource development policies
and plans and, through the preparation of a long-range plan for the de-
velopment of water-related community facilities, to provide for the coor-
dination of local, state, and federal water resource management programs
within the region and its watersheds.
The watershed plans also serve to refine and adjust the regional
land use plan, particularly in the riverine areas, and help achieve
a more complete integration of land and water resource planning. Additionally,
the Commission has completed a comprehensive sewerage plan for the region.
Extensive efforts in water resource planning make the WQM effort part of
an ongoing, institutionalized planning process. The Chief Environmental
Planner stated that the WQM study does not have priorities, but is looking
at all regional water quality factors. In terms of major problems, he
stated that:
o A water supply problem exists for suburbs,"
o Eutrophication of lakes is more of a problem than
stream water quality;
o A clear delineation of the relationship between public
and private sewage treatment facilities will be a
important factor of the study/ and
o A solution for the agricultural runoff problem will be a
difficult aspect of the study.
C. Designated Agency
The Southeastern Wisconsin Regional Planning Commission (SEWRPC) was established
in 1960 upon unanimous petition of the seven county boards concerned. There
are 154 general-purpose local units of government, of which all except three
(or 93 percent) are participating in the work of the Commission. The
SEW-4
-------
three non-participating local units of government are the village of Wess
Milwaukee and the towns of Vernon and Saukville.
The authority of the Commission rests with its 21 members - three from
each county. The Commission is assisted in its work by a full time staff
of approximately 90, and by 22 technical, citizen and intergovernmental
coordinating committees. The advisory committees include both public
officials ana interested private citizens who provide major input to both
the formulation and execution of the Commission's programs.
WQM planning is seen as a one element of a comprehensive regional planning
system which includes land use, recreation, air guality and transportation
planning. WQM planning is considered one of the two most critical programs -
the other being Land Use/Transportation planning. The nature of air
quality problems is not critical in the region.
The WQM staff consists of a Chief Environmental Planner, who heads the
Environmental Division of the Commission and who was responsible for the
Study Design. A WQM Coordinator interprets the study design and directs
activities. There is a Water Quality Analysis Coordinator who has admini-
strative responsiblities, and is responsible for contracts and the direction
of research aids. Additionally, there are three Junior Planners and the
equivalent of 20 part-time staff. A technical staff which consists of
two Senior Engineers, five full-time Junior Engineers/Planners and five
part-time staff is responsible for the in-house modeling work elements.
Although strongly held preferences for local (small) government still pre-
dominate, there is a sense of regional cooperation in southeastern Wisconsin.
The openess toward regional water quality solutions seems to be due to
the local respect for the SEWRPC staff and their technical expertise. Con-
sequently, there is a high level of public acceptance for the type of
activities bei^ig undertaken under WQM planning.
SEW-5
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
WQM planning is seen as a tool for updating, extending and refining pre-
vious studies and plans done by the Commission, while meeting the require-
ments of the FVJPCAA, 1972. WQM planning is intended to provide for:
o The full integration of water quality management planning
with regional land use planning;
o The conduct of a refined areawide water quality monitoring
and modeling program;
o The preparation of an areawide point and nonpoint
source pollution abatement plans;
o The preparation of a practical areawide water quality
management plans;
o The conduct of sub-area fac:lities planning for five
years following the completion of the WQM plan,' and
o The establishment of a continuing areawide water
quality planning and management program for southeastern
Wisconsin.
B. Technical Component
The SEViRPC work plan contains an extensive inventory component. The
technical aspects of the ninteen inventory products can be grouped into
the five major categories listed below (see Exhibit I for entire listing) .
o Base Mapping and Aerial Photography;
o Status of related water planning programs;
o Socio-Economic, Land Use, Natural Resources Data Base;
o Water Quality Data Base (Quality and Use for surface
water and groundwater);
o Point and non-point Source Inventory.
SEKJ-.6
-------
In some cases, the effort requires gathering exising data for use in WQM
alternative development. In other cases, data will be gathered either to
supplement or create a new information base. Technical elements of the
work plan include:
o forecasting growth and change;
o water quality simulation modeling,-
o wastewater needs," and
o land use and environmental constraints.
The SEWRPC staff was particularly proud of the modeling effort. They
felt the modeling was a state-of-the-art endeavor, and was enabling
the region to clearly define its water quality problems. This modeling
data will indicate the percent of time particular segments will be out
of compliance with the Standards.
Approximately 40 percent (1.1 million) of the grant will be utilized to
hire various consultants. About seventy-five percent of this amount will
be for technical aspects of the study. Most of the tasks are shared by
consultants and-sta,ff.. Some of the work elements requiring contractural
work are water quality sampling, mapping and modeling.
Seven Soil and Water Conservation Districts have entered into cooperative
agreements with SEWRPC for providing vegetative cover and domestic animal
data in addition to assisting in the development and evaluation of alter-
natives in both urban and rural areas. The Wisconsin Department of Natural
Resources has been contracted for lake studies and USGS for flow and water
quality monitoring. Sewerage and land use inventories are being done in-
house.
C. Management Planning
The management planning will be based on an inventory of:
o The state-of-the-art of wastewater management;
o Public financial resources,"
o Wastewater management institutional structure;
o Land management institutional structure; and
o Legal considerations.
SEW-7
-------
Additionally, the analyses and forecasts for management work elements in-
clude :
o Sewage sludge management needs; and
o Waste management institutional structure analysis.
The work elements of the state-of-the-art of Wastewater Management ($50,000)
and the sewage sludge management needs assessment ($250,000) are contracted
to consultants. It was considered too early to discuss likely management
systems, as alternatives had not been developed from the technical data
base.
D. Public Involvement Program
Three advisory committees have been established to assist the Commission
in conducting WQM planning. These are a Technical Advisory Committee,
the Intergovernmental Coordinating Committee on Water Quality Management
Planning and the Citizen Advisory Panel on Public Participation.
The technical Advisory Committee was established early in 1975 and provided
assistance in the preparation cf the project grant application and study
design. This Committee continues to be actively involved in WQM through
technical level representatives and elected officials, the various govern-
mental, business, industrial, agricultural, and university interests in
the Region, and assists the Commission in determining the basic technical
policy involved in the conduct of the progiam.
¦The Intergovernmental Coordinating Committee on Water Quality Management
Planning, was established for the basic purpose of reviewing those aspects
of WQM planning having important intergovernmental and interagency policy
implications. This committee is charged with the specific responsibility
of reviewing intra-regional priorities for the fundings of wastewater treat-
ment and x'elated sewerage facility construction, and for integrating and
coordinating these intra-regional priorities with those established for
other regions within the State of Wisconsin. The committee includes
senior level representatives from key Federal, State and local wastewater
management agencies involved.
A Citizen Advisory Panel on Public Participation was created in order to
provide guidance to the Commission in conducting the public participation
program. This panel provides a vehicle for representatives of citizen
interest groups to become familiar with and influence WQM planning.
Membership on the panel includes organizations such as the League of
Women Voters, the AFL-CIO, the Metropolitan Milwaukee Association of
Commerce, the Sierra Club, the Environmental Educational Council of Greater
Milwaukee, and the Restoration Councils for the Rood River, Cedar Creek,
the Milwaukee River, and the Menomonee River. The panel meets approximately
quarterly. These quarterly meetings provide a basis for briefing on the
progress of the program, and will offer an opportunity for members of
SEW-8
-------
citizen interest groups of all types to raise questions about and to
thereby influence the basic direction of WQM planning program. The panel
will also be requested to react to proposed public involvement efforts
designed to secure effective citizen participation in WQM planning effort.
Additionally, the University of Wisconsin extension (UWEX) has been
contracted for one full time staff person to develop and coordinate the
public involvement program. The public involvement program involves:
o Working with the citizens advisory panel;
o Establishing direct working relationship with each
county UWEX office/
o Utilizing UWEX State and Area Specialists;
o Enlisting support and cooperation with the Soil
Conservation Service, Soil and Water Conservation
Districts and Agricultural Stabilization and
Conservation Service Personnel; and
o Providing materials and information when*the above
mentioned groups are working with their publics.
The media will be a primary vehicle for information dissemination.
Survey cuestionaires, public opinion polls and fact sheets with re-
sponse postcards will be used to obtain public input. The staff also
considers the contractual data gathering efforts with various local
groups to be an effective means of keeping the various publics involved.
The SEWRPC staff also constantly attends local meetings of various groups
throughout the region in an effort to facilitate communication with the
Commission.
E. State and Federal Involvement
The Wisconsin Department of Natural Resources (WDNR) has provided one full-
time Liaison in-house and one full-time position at DNR. Additionally,
a good working relationship has been established with the district DNR.
Relations are characterized as friendly. The Chief Environmental Planner
reported that SEWRPC is not in need of technical guidance, but has a
coordinative relationship with DNR whereby both agencies are aware of the
others activities and may use all available data. All state data has been
provided for WQM planning, but the Environmental Planner also said that
the State often utilizes SEWRPC for conceptual and technical work.
-------
The SEWRPC staff felt that the EPA Regional Office is giving WQM high
priority. SEWRPC reported that a good relationship exists with the
region, but feels that SEWRPC has headed little guidance because of its
extensive experience in WQM planning.
F. Scheduled Outputs
Exhibit I indicates the schedule of outputs for the WQM planning effort.
At the end of the fourth quarter of the first year, SEWRPC had expended
62 percent of the projected program funds for that 12 month period.
This situation is attributed to time delays in getting the project
fully under way and achieving full staffing levels. The staff's schedul-
ing of the project was based on the assumption that inventory efforts
could be conducted independently of analytical effort. This assumption
proved incorrect, as early analytical results necessitated modified in-
ventory efforts. The effect of the above cited factors was an over
estimation of the amount of work to be done in the early stages of the
project. The staff is currently of the opinion that the goals of the
study can still be accomplished within the deadline. However, having
identified these scheduling problems, the staff intends to reevaluate
the schedule by refining assumptions and considering additional infor-
mation which has become available in the ten month period. In addition,
review of the scope of work and the budget will be undertaken. None of
this work had been completed at the time of the site visit.
'G. Achievements to Date
The Chief Environmental Planner stated that the Menominee River Watershed
study which was recently completed in preliminary form, is a state-of-the-
art effort in nonpoint source pollution control. The study contains data
and controls concerning stormwater, urban and rural runoff. The study
also includes land management practices for water pollution control on
a watershed scale.
SEW-10
-------
/exhibit "I
TIMING OF MAJOR WORK ELEMENTS OF THE AREAWIDE WATER
QUALITY PLANNING AND MANAGEMENT PROGRAM
FOR THE SOUTHEASTERN WISCONSIN REGION
kajop vopk clcmi:nt
Pr*>-Application
Period
Year One
Y'jar Two
1
7
3
4
b
b
7
e
9
10
11
I?
J
?
3
6
7
8
9
10
11
A. STUDY OPCANIZATIOM AMD DESIGN
1. Application Initiation,
Coordmat ion, and Review....
J. Ad^iiory Committee Service....
U. Citi?.en Pat t ic Lpat ion
5. Finalize Plc*i o/ Work
6. Wis. CNR Adninistration
b. \ ORKULATION Or OBJECTIVES,
PRINCIPLES, AND STANDARDS
I. Review of Pluvious
?. rofTtiulat ion of Sew
CONDUCT or invkntop.jls
1. base K.ips and Aerial Photo-
2. Inplymcntation Status of
Previous Wuier Quality
Re la ted P lans ... ....
3. Idenrificdt ion and Review of
Concurrent Writer Quality-
Felated Pldnnin?, and
S. Land Use and Community Plans
and ^.inin/; l^ata
6 Centra) Natural Fosource
and Environmental. Data.
7. Surface Water Quality Data--
0. Ci'jiifuiv/dl ';r Dat'i
9. Stirlace Wa(T Use Para..
10. Lxistinf and Proposed Sani-
tary S^woi C»y*">tcffts
11. Othor Point ^ourc1 Inventory..
I?. RxjsI jiy, hih) Projosed Storm
Writer H»wM^ tffivil j l ion Modo 1 i ri£
'J l»an»'iit I Uncut
f. I'i.AfI SI MM Il'N AM' AI'.Tl 10,'J
0. PI AN IMPLLH1 NTATION
I. LstaMisti Continuing Plaoning
?. Pvv^art' Tivcknc Hons (facility
I'l.ms)
,
:»ouiv«: r.iwrc.
SEW-11
-------
III. EXPECTATIONS
A. Water Quality
The WQM staff's expectations were generally stated in terms of meeting
the standards for fish and acquatic life. One local appointed official
hoped to minimize the impact to receiving V7aters by eliminating wastewater
plant discharge and dealing with the combined sewer overflow and nonpoint
pollution. Another local appointed official hoped for a plan which
prioritized wastewater facility development. Two local elected officials
expressed a strong desire to see local waters cleaned up, especially for
recreational purposes. The other local elected official said that re-
creation was not a water use in his area, and that his major interest
was obtaining sewers in his city. This citizen was also anxious to see
the area's water cleaned-up, and hoped for a new policy for looking at
resources.
In reference to achieving the 198 3 goals, all levels of the SEWKPC
staff indicated that goal achievement could be expected in moat areas.
Reasons for not achieving it in all areas. were tha L th.e_JEaci 1 ities .will
¦not be in place by 1983, and that there are not enough available funds
for solving the combined sewer overflow problems. One local appointed
official stated that "go al 'aclTievemen"t_b"y~l"9B"3 was impossible. He stated
that by 1985, plant discharges could be eliminated, and that by 2000,
combined sewer overflow could be eliminated. He added that the nonpoint
source pollution problem was too large, and that it was too early to
predict when tne region would get a handle on it. Another local appointed
.official was hopeful of meeting the goals in his area. The citizen, a
resident of the city of Milwaukee, did not expect that the goals would be
met in her lifetime. Local elected officials tended to be familiar with
the ongoing water quality planning processes of SEWRPC, but not specifically
with WQM planning. Generally, they were aware of the specific goals of
PL92-500.
B. Plan Approval and Implementation
An extremely high level of confidence for both plan approval and plan
implementation characterized all interviews. Both the Executive
Director and the Chief Environmental Planner were assured of plan
approval because of the effective public input throughout the process.
Additionally, both referenced the fact that all of the Commission's water-
shed studies had been accepted at the state and local level. The
Chief Environmental Planner said, however, that plan implementation is
dependent on funding - particu]arly the cost of eliminating combined
SEW-12
-------
sewer overflow. Local elected officials and the citizens also thought
the plan would be accepted and .implemented with little difficulty. The
citizens added that there may be some difficulty with approval in rural
areas, and that plan implementation may cause some animosity among de-
velopers .
It was considered too early to discuss the likely legal aspects of WQM
planning. The SEWRPC is in the inventory state which anticipates an up-
date of Water Law In Southeastern Wisconsin. It was also too early to
discuss likely management structures, as alternatives will be dependent
on planning results yet to come.
C. Continuing Planning Process
The estimate for the annual cost of continuing water quality planning
was listed as $150,000, in the 1975 annual report. Twenty perce.it of
the Commission budget is allocated for environmental planning. The
Executive Director delineated what he considered to be basic functions:
o Monitoring,
o Reporting,
o Plan reappraisal,
o Plan implementation, and
o Research.
Outside of the Commission, all expected SEWRPC to continue its ongoing
efforts in water quality planning for the region.
D. Relation to Other Water Quality Programs
WQM was perceived to have no significant effects on 201 or NPDES. The
Executive Director stated that both 201 and permitting had been done for
the region. The Chief Environmental Planner's reaction was that WQM and
201 type activities have always been related through the regional compre-
hensive sewerage plans. No other interviewers perceived major effects on
201.
In reference to NPDES, the Chief Environmental Planner did not perceive
WQM as having any control over the permitting system, but thought that
WQM would provide more specific information for permits, which would pro-
vide more justification for there issuance. Others interviewed did not
perceive a significant relationship between the two programs.
SEW-13
-------
E. Local Definition of Success
Local definitions of success were generally in the areas of plan imple-
mentation and public education. The Chief Environmental Planner con-
sidered a success to be finding a way to implement agricultural recom-
mendations. A local elected official looked for a definitive plan for the
development and construction of sewage treatment plants. This official
also thought that by virtue of having this plan, it should make the Federal
grants process more expedient. Ons local elected official hoped that WQM
would prove educational for the public in ways to keep southeastern
Wisconsin beautiful. He also thought that the region would have alterna-
tives presented in other than pure economic terms. Another local elected
official was looking to obtain sewers for his community, with or without
WQM. The citizen expected WQM to lay out a regional plan for sound en-
vironmental development.
A wide range of benefits were expected from WQM. The Chief Environmental
Planner hoped that the public would have an increased understanding of
the benefits of water resource planning. He also thought that each
jurisdiction would be made aware of its water quality responsibilities,
and that better regional water quality decisions would be made as a
result of WQM. The local appointed official stated that a major benefit
vhich was already in evidence was improved communications among the
various levels of government, and increased interest in WQM planning.
A local elected official felt that WQM would facilitate obtaining more
money from EPA. Another local elected official expected recreational,
aesthetic and environmental benefits for the streams in his community.
Clean water and a new way of looking at resources were considered benefits
of WQM by the citizen.
SEW-14
-------
IV. VARYING PERCEPTIONS OF WQM
A. WQM Staff
The SEWRPC staff sees WQM planning as part of the ongoing water quality
planning process established by the Commission in 1964. Water quality
planning is considered one of the two most critical programs at SEWRPC,
the other being land use/transportation planning. This is not surprising
because water is a major natural and economic resource in southeastern
Wisconsin.
The SEWRPC's staff view themselves as expert water quality technicians
with strong community support for their assistance and advice. The
staff entered WQM with a strong data base. Consequently, the staff sees
the SEWRPC WQM undertaking as a state-of-the-art endeavor designed to
refine and analyze data. This is particularly true with their work with
the Hydrocomp as a pilot text in southeastern Wisconsin.
B. Citizens
Only one citizen was available for interview. She was a member of both
the Citizens Advisory Committee and the- Policy Advisory Committee, and
represented the League of Women Voters. Her work on the Technical Com-
mittee was in the area of combined sewer overflow.
Ishe was happy with her involvement in WQM, but stressed the necessity of
/involving the general public from the earliest stages of plan development.
One concern which surfaced was that the same groups were active in all
of the Commission's'planning process. The staff's explanation for this
was that all interested groups had been contacted for involvement in WQM,
J but gaining the interest of the person on the street was a loosing battle.
C. Local Elected Officials
Three local elected officials were interviewed for their opinions on WQM.
One was a County Supervisor of a rural county, the other two were mayors
of towns with populations of 44,600 and 28,400.
The County Supervisor is a member of the Technical Advisory Committee,
and is on a sub-committee for consultant selection. He was an active and
knowledgeable participant in the process, having extensive experience with
Soil Conservation Districts in southeastern Wisconsin. He felt that
long-time practices of the Soil Conservation Districts had a chance for
SEW-15
-------
more extensive implementation under WQM. WQM was also seen as a pro-
cess to educate the public to environmental concerns. He did state
that he was not in favor of regional government, but was in favor of the
advisory role of SEWRPC. Apparently, his sentiments were similar to the
residents of his county - that the township was the best form of govern-
ment because it is most responsive to its residents.
One Mayor was most interested in an ongoing watershed study which en-
compassed his city and the impending choice for wastewater facility alter-
natives. He is a member of the Intergovernmental Committee, which
had held one organizational meeting. Consequently, he was not versed in
the WQM program per se, but was very active in an ongoing watershed study
which encompassed his community. The Mayor held high opinions of the
SEWRPC staff and their work, but stressed the importance of building
concensus among local governments, rather than forcing regional alternatives.
He was looking for a clean up of his community's waters for recreational
and aesthetic purposes.
The other Mayor was not directly involved in WQM, but was a member of an
advisory board to the Milwaukee Metropolitan Sewage District. His pri-
mary interst for his town was obtaining sewerage hook-ups. He did state
'that the cooperation from SEWRPC was excellent, and that his city utilizes
SEWRPC for technical assistance. Although a strong advocate of local
control, he welcomed input from SEWRPC cn local decisions.
D. Appointed Officials
Three appointed officials were interviewed for opinions on WQM including
the Chief Engineer of the Metropolitan Sewage District (MSD), the General
Manager of Water and Wastewater Utilities of a city of approximately
93,500 and the Public Works Director of a city of 12,000. All had very
different expectations from WQM.
The Chief Engineer of the Metropolitan Sewerage District is the Chairman
of the Technical Advisory Committee. He felt that the group assembled to
provide technical advise representing a variety of professions and interests,
and that the Committee had been given many opportunities for significant
input into the process. As a result, he felt that communications among
the various jurisdictions and levels of government involved in the waste-
water process had improved significantly. He is very confident that WQM
will result in more cooperation beteween regulatory and operating agencies,
and in a significant improvement in the region's water quality. His agency
had undertaken public education efforts, supportive of WQM objectives, ~o
show the cost of unplanned development. A very cooperative relationship
was evidenced between SEWROC and MSD.
A city's General Manager of Water and Wastewater Facilities is a member
of the Intergovernmental Coordinating Committee on Water Quality Management
SEW-16
-------
Planning. To date, this committee had met once, primarily to disseminate
information, and had not had input into WQM planning. This official
was looking for WQM to eliminate confusion in the building of wastewater
facilities, in terms of providing a plan and clarifying Federal regulations.
The other local appointed official, a Public Works Director, has been in-
volved in WQM through the provision of data, but was not actively involved
in the WQM planning process. His city contracts SEWRPC for all planning,
and thought highly of the technical expertise of the regional planning
staff. The official did state, however, that there are anti-regional
and anti-county government sentiments in his area because of the strong
belief in local government.
E. State Legislators
No State legislators were contacted on this site visit.
F. State Water Quality Personnel
The State WQM Liaison was unable to make his scheduled appointment, and
could not be reached by telephone for comment on WQM.
SEW-17
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
The SEWRPC staff is confident of their ability to complete the essentials
of WQM planning, despite the upcoming revisions in the workplan. The
stated need for revisions is that a heavy scheduling of inventory at the
earliest stages of the process proved somewhat untimely. Two factors
explain the scheduling problem. First, it took longer to locate key
staff positions than was initially expecte'd. This delayed the start of
initial inventory activities. The second factor was that the heavy
scheduling of the inventory at the early stages of the project was
based on the assumption that inventory ar_d analytical work could be con-
ducted separately. Early analytical results, however, necessitated modi-
fied inventory efforts. Despite the need for these plan modification, it
seemed that EWRPC's advanced data base and an experienced technical
water quality staff are indications of timely completion of a quality plan.
All interviewees were confident of plan approval. The staff's confidence
was based on the fact that all previous water shed studies had been
accepted by the respective communities. The local confidence seemed tc
fee based on respect for SEWRPC's previous work. An additional factor
which the staff felt would pave the way for plan approval was the effective
utilization of public input through the committee structure and local con-
tracts. Locals and staffs foresaw no problems with plan implementation;
jhowever, one staff member pointed out that the implementation hinges on
[funds which will not be available at the local level.
B. Public Involvement
The Southeastern Wisconsin residents are aware generally of water quality
issues because water is a major resource of the region. SEWRPC has already
helped increase this awareness through watershed studies which were initially
undertaken in 1964. The workplan provides a framework for input from the
various groups interested in WQM ei trier through committee structures or
a general public input.
There are three committees of each having varied roles in the process.
A Technical Advisory Committee, composed of both local elected officials
and technical representatives, has provided a forum for local technical
direction of the program. The Intergovernmental Coordinating Committee
SEW-18
-------
on Water Quality is a body established for reviewing policy with inter-
governmental implications, such as wastewater facility priorities.
This committee has met only once at the time of the site visit, and was
just becoming involved in WQM planning. The third committee is the
Citizens Advisory Committee (CAC) which is designed to provide guidance
on general public involvement and a forum for input from interest
groups.
The strong emphasis placed on local involvement was evidenced in both
staff attitudes and local knowledge of the program. These factors,
coupled with SEWRPC's involvement in local planning efforts (contract
and technical assistance work) are indicative of a plan that will
relfect the variety of interest in WQM.
C. Current Planning Process
SEWRPC entered WQM with a history of experience in water quality planning.
Comprehensive watershed studies for six of the eleven watersheds in the
region have been completed, as well as a comprehensive regional sewerage
plan. Consequently, WQM is seen as another step in an ongoing, institu-
tionalized WQM process.
SEWRPC is undertaking a comprehensive planning effort which includes a
major inventory to further define, point, nonpoint and institutional pro-
blems and solutions. The technical effort includes a state-of-the-art
endeavor in modeling, which consists of a pilot application of the Hydrocomj
in southeastern Wisconsin.
Both technical and management inventories are being conducted presently.
The Technical Advisory Committee has played a very active role during the
designation period. Additionally, SEWRPC has included local governments
in the process through data collection contracts. The high degree of
interest in water in the region has provided significant incentive for a
variety of interests to become involved in the process. SEWRPC has
established an open process which facilitated these active roles in WQM.
D. Continuing Planning Process
WQM is seen as part of the ongoing planning process at SEWRPC, therefore,
the interest in continuing planning in the region is assumed. Budget
requirements forecast in the 1975 annual report are approximately
$150,000 per year for water quality planning. The following possible
functions were outlined by the Executive Director:
o Plan monitoring;
o' Reporting system;
o Plan reappraisal;
JEW-19
-------
o
Plan implementation/service; and
o Research
The fact that water quality planning has been ongoing in the region since
1964 seems to be a reasonable indication that planning will continue after
the benefits of the present WQM effort.
E. Significance of Local Sleeted Officials' Involvement
SEWROC's committee structure provides opportunities for local elected
officials to become involved in the policy and/or technical wastewater
decision-making processes. The latter group has been extremely active
in the WQM process to date, and the former is just beginning to assume
a significant role. Additionally, local elected officials have had the
opportunity to become involved in water quality issues through the water-
shed studies conducted by SEWPRC.
Local elected officials interviewed displayed an awareness of a variety of
water related issues depending on the priorities of their community. One
official wanted to preserve the wetlands in this predominantly agricultural
county, and establish sound soil and water conservation practices.
Another's interest was in cleaning up local waters for recreational/aesthetic
purposes and developing an agreement for wastewater treatment facilities,
while another's single priority was obtaining sewers. Despite strong
feelings for local government, all interviewed displayed an awareness of
the need and a willingness to cooperate to solve the region's water quality
problems.
SEW-20
-------
AGENCY: SOUTHERN KENNEBECK VALLEY REGIONAL PLANNING COMMISSION (SKV)
REGION: I - (Boston)
GRANT AMOUNT:, $380,000
GRANT RECEIPT: June 9, 1975
STARTING DATE: June, 1975
STATUS AT TIME OF INTERVIEWS: The project was entering its second year of
planning and beginning to refine final plan
alternatives.
REASON FOR INCLUSION IN SAMPLE: The Augusta/Cobbasee Project was selected
because of the high degree of State coopera-
tion and involvement in the program.
SKV-1
-------
1
I. BACKGROUND
A. Area Description
The Augusta-Cobbassee designated area lies approximately 30 miles inland
from the central coast of Maine. It includes the capital city of Augusta
and eighteen surrounding communities in the southern Kennebec River Valley.
The area is dotted with a series of small lakes and ponds which are inter-
connected to form the Cobbossee Chain watershed. The designated area also
includes the Togus Pond drainage area and a segment of the Kennebec River
from Augusta to Richmond.
The Designated area is approximately 500 square miles in size with a popu-
lation of 55,000 people according to the 19 70 U.S. Census." With the excep-
tion of Augusta, the area is sparsely settled, rural in character and not
part of an SMSA. The major source of employment is the State government,
which is headquartered in Augusta. With recent strains on the State's bud-
get and the State's generally depressed economy, however', the number of
government employment opportunities have diminished. Tourism and related
employment opportunities, on the other hand, have been rising over the past
decade as more people are attracted to the area's lakes and woodland recrea-
tion grounds. Development along the lakes has increased rapidly as a re-
sult.
There are also a few large industrial plants along the Kennebec River, but
the area's economy relies more heavily on seasonal tourism and support in-
dustries .
The heavy dependence of the local economy on the quality of the lakes is widely
recognized by the general public and local elected officials. Many have
directly witnessed how their land values and summer cottage rentals have been
affected by lake pollution, while others have felt the threat of contaminated
drinking supply. Finally, a good number of people are long-time residents
of the area or have chosen to retire there because of the area's aesthetic
qualities. These persons take a very provincial, possessive attitude toward
the lakes and resent any interference with their water quality.
The State of Maine has been very active in statewide efforts to protect its
waters and regulate their use. In the Augusta area, several local watershed
associations have been formed in response to a perceived critical need to
take immediate preventative action, especially in view of the recent degre-
dation of several important lakes in the area. Since there are no air or
noise pollution problems in the area, environmental attention is clearly
focused on water concerns.
The entire WQM area is incorporated into individual townships, each with its
own Board of Selectmen. The townships held very active and effective town
meetings in the true New England tradition- Each town has the authority to
1
Information for this section was taken from the SKVRPC Work Plan, and
interviews.
SKV-2
-------
plan and regulate land use although many do not have zoning codes or sub-
division regulations.
'The area also has a number of special districts (usually consisting of a
few towns) empowered to construct and operate wastewater treatment plants
and ensure municipal water supplies. Presently, there are two wastewater
treatment facilities in the region. Those communities not tied into these
systems rely on private septic systems or collect and dispose of untreated
domestic waste into nearby lakes, streams or rivers. The public water supply
for the three largest communities in the designated area is the lakes in
the Cobbassee Watershed drainage area. Some of them have been used in the
past to receive untreated waste or poorly treated effluent.
Recognizing that the coordination of local communities on matters of waste
collection, facilities planning and land use controls is clearly essential,
the region has already taken some steps toward cooperation and joint problem-
solving. The State enabling legislation for the Regional Planning Commission
provides an institutional framework for coordinated waste treatment planning
and management throughout the area. Three communities have already agreed
to implement a coordinated areawide treatment system and a Cobbossee Water-
shed District was created, in part, to coordinate land use planning and
implementation in a portion of the WQM area.
B. Water Quality Problem
As previously noted, the designated area's water resources consist,most
notably, of the southern portion of the Kennebec River and the Cobbossee
•Chain of lakes. Although the area is chiefly rural, it is rapidly develop-
ing, creating significant point source and major nonpoint source problems
which preclude the simple application of national effluent limits as a
solution. The current water quality of the Kennebec segment within the study
area is below the State's "C" classification, i.e., not suitable for swimming
or fishing, while the Togus Pond and many of the lakes are classified "water
quality limited" by the Maine Department of Environmental Portection. Several
of these lakes are in advanced stages of eutrophication, and many more are be-
ginning to show signs of extensive plant growth. Groundwater resources have
been contaminated with salt in some areas affecting not only drinking supplies,
but also surface water.
The Kennebec's pollution problems have been traced to its use or misuse as
a dumping ground for mills and municipal wastewater treatment plants, as
well as the catch-all for agricultural runoff and septic system leachate.
A local woolen mill and paper products company are the primary industrial
sources in the area. As for municipal wastes, Augusta's wastewater treatment
plant is presently operating at a primary treatment level, thus emitting poor-
ly treated wastes into the Kennebec. The city of Hallowell does not treat
its wastewater but rather, channels it to an outfall pipe which deposits a
continuous brown slurry in the river. Most homes, particularly those on the
lake shores, still rely on individual septic systems.
SKV-3
-------
A great portion of the river's pollution problems are generated upstream
from the designated area. To reach class B-l in the Augusta area, all
industrial use of the river would have to end, according to the Project
Engineer. Since this is an economically unacceptable alternative, efforts
will be made to reach and maintain a Class c rating.
Reasons cited for lake pollution include natural runoff, agricultural run-
off and septic system leachate. Septic systems were thought to be the
primary source until the WQM studies showed that agriculture was a much
more serious nonpoint source of pollution. A particular problem was faced
with animal feedlot management during the winter months.
Although all persons interviewed were very much aware of the problems with
the Kennebec, discussion centered primarily on the lakes. They are the
focus of more immediate concern because of their clear relationship to the
area's water supply, land values, tourism economy and general character.
Also, they felt that their actions could make a substantial difference in
the guality of lake water, whereas changes in the river would only be miner
and too costly to consider, especially given the current status of Maine's
economy.
C. Designated Agency
The entire WQM area is within the Southern Kennebec Valley Regional Planning
Commission (SKVRPC) planning area. Governor Curtis designated the SKVRPC
as the official planning agency for the area in 1972. Commissioners to the
SKVRPC are appointed by local elected officials. The majority of SKVRPC
representatives are councilmen or selectmen, city or town managers, planning
board or conservation commission members. With the exception of three towns,
all municipalities in the WQM study are presently members of the Commission.
The major factor which led to the establishment of the Commission in 1967
was citizen concern with water quality and a desire for cooperative effort
across town lines. Since its inception, the Commission has assisted local
communities in planning joint sewer system projects and has served as the
focal point for other water-related studies conducted by individual communities
and sanitary districts throughout the area, The Commission is also conducting
housing, solid waste, transportation, land use, energy, medical care and
public safety planning. The Commission is currently engaged in a coastal zone
management study whose study area overlaps the easternmost portion of the WQM
area. All projects are coordinated through reliance upon a common staff. As
the major source of agency funding at this time, the WQM study holds top pri-
ority within the Commission, especially as it relates to future and current
facilities planning.
In conducting the WQM study, the Commission has established a cooperative
relationship with the Cobbossee Watershed District. The District is composed
of eight communities in the Cobbcssee drainage area which are empowered by
State enabling legislation to plan and implement activities assuring water
SKV-4
-------
quality and supply for the watershed. The Commission has allocated 35 per-
cent of its WQM budget to the District for water quality sampling and lake
studies by the District's staff and consultants. The watershed plan de-
veloped by the District will then be integrated into the regional WQM plan
by a joint Watershed/Planning Committee.
The Commission is using another 35 percent of the WQM grant for in-house
and consultant work on plans for the non-watershed towns in the designated
areas. Part of this money has been used to help the Augusta Sanitary Dis-
trict finance a large-scale engineering study on trunk line deficiencies.
The remaining 30 percent of the WQM grant will be used by the RPC staff
to integrate the individual WQM plan elements.
The Commission's WQM staff consists of the Executive Director, an Engineer-
Coordinator, a Land Use Planner and a Draftsman. The Executive Director
is serving as Project Manager for the WQM program with an Assistant Adminis-
trator also working part time on the project. Intra- and inter-agency staff
coordination are achieved through regular staff meetings, frequent inter-
agency contacts and joint authorship of reports.
Approximately $100,000 of the area's total $380,000 grant is being used for
outside consulting. Consultant assignments include facilities questions in
WQM, limited aerial photography, legal and financial advice, and general as-
sistance in monitoring and guiding the planning process.
At the time of the site visit, the Commission had entered its second year
of planning and had expended approximately one half of its allocated grant.
There have been no overexpenditures or major delays to date.
SKy-5
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The problems, goals and objectives of the WQM study were defined by the
SKVRPC staff in the work plan. The agency took a comprehensive approach
in that its program is designed to address all areas of water pollution
concern as suggested in EPA guidance. Many of the specific problems to
be addressed in detail were defined in previous studies by the Commission,
the State DEP, individual communities and the SKVRPC's Sewer and Water
Subcommittee. The overall program objectives as identified by the Executive
Director are to:
o Establish a framework in which to discuss a full range of
alternatives for all water quality problems;
o Develop a data base to recommend regulatory programs and
actions}
o Create a management system with communications between in-
dividual agents; and
o Support local planning efforts by increasing local communities'
capacity to plan.
The priority goals are to remove effluent and septic leachate from the lakes
and upgrade treatment facilities along the river.
An intentional decision was made by the Executive Director to delay local
refinement of WQM goals until after an overview study of existing water
quality problems and management agencies was completed. Local redefinition
of goals and priorities to be reflected in the final plan were being form-
ulated by the WQM Goals and Objectives Committee at the time of the site
visit. This committee is composed of representatives from the Sanitary and
Water Districts, trunkline groups, municipalities, the Cobbossee Watershed
District, lake associations and citizens. The first priority identified by
the Committee is to maintain local control over water quality management.
This statement highlights the area's general distrust of Federal interference,
an attitude strongly held by most citizens and local officials in the region.
Other local goals expressed by interviewees included protecting the local
economic base, preserving recreational amenities and avoiding increased local
expenditures.
B. Technical Component
The final WQM management plan will be based upon a series of technical and
management study sub-plan elements. In conducting technical planning, the
WQM agency benefited greatly from a history of prior water studies and the
SKV-6
-------
presence of 201 planning being conducted concurrently with the WQM project.
The SKVRPC contracted with the Cobbossee Watershed Association for lake
monitoring and water sampling and relied heavily on information supplied by
engineers conducting 201-related planning for local communities and sanita-
tion districts. Additional information on 201 issues was supplied by en-
gineering consultants to the WQM agency.
The first technical sub-plan consists of an overview of existing water quality
conditions, sources of pollution, projected water uses and long-range data
needs. The second sub-plan focuses on current and projected land use and
population patterns with an analysis of pertinent transportation and econ-
omic factors. Along with this study is a parallel effort to determine the
capacity of the land to support various land uses. A study of the soils,
geology and vegetation of the region constitutes a major part of the analy-
sis.
The third technical sub-plan focuses on the issue of waste reduction with a
particular emphasis on point source problems. The agency is emphasizing
point sources because it is viewed as a requirement of the WQM program, be-
cause the current local system for dealing with point source issues is under-
managed and the area is facing a critical decision of whether to undertake
large-scale sewering of lakeshore areas.
The;sub-plan is geared toward:
o Delineation of service areas for treatment facilities;
o Projection of waste loads and flows for each area;
o Determination of the adequacy of operating and proposed
facilities and the degree of treatment necessary to meet
water quality standards; and
o Identification and prioritization of needs for collection
systems, urban storm water runoff, systems and new facili-
ites over the next 20 years.
Since many of the area's pollution problems cannot be remedied by structural
solutions, the study is also examining nonpoint sources and controls, partic-
ularly agriculture, silviculture and rural housing. All technical planning
efforts will result in the development of maps, aerial photos and reports
on a regional and sub-regional basis. These products will be of use to other
planning efforts beyond the WQM projram.
C. Management Planning
The WQM agency's management planning efforts are strongly colored by the
staff's understanding of the local preference for maintaining local control.
The agency's orientation is toward combining existing units into more ef-
fective mechanisms and supplementing them, where necessary, with additional
SKV-7
-------
powers or authority. Management planning is being conducted by a consor-
tium of planning consultants, the Executive Director and WQM staff.
The management sub-plan began with an inventory and analysis of existing
laws, regulations, institutions and financial mechanisms relating to water
quality and waste management at the Federal, State and municipal level.
The WQM study will develop alternative management plans for implementing
the technical control plan suggested in the Waste Reduction Analysis.
The approach to management planning basically is to bring together local
and State decision-makers and present then with results of existing programs.
The political actors will then hash out what they feel is the best set of
alternatives. The underlying objective is to determine what is most effect-
ive and implementable so as to ensure success and foster a regional approach
to planning and management.
D. Public Involvement Program
The WQM public involvement program is the responsibility of the Executive
Director. Based on the agency's prior experience in conducting public in-
volvement programs, the Executive Director chose to concentrate public in-
volvement efforts on local decision-makers and public interest groups (par-
ticularly lake associations) rather than the general public.
The general public is notified of WQM activities through:
o Press releases and occasional mailings;
o Program reports made available by the WQM agency upon
request; and
o Regular meetings and communications with public interest groups,
groups.
Citizens were invited to share their views early in the planning process at
individually sponsored town meetings. But the most significant avenues for
public involvement are still the advisory committees and direct WQM staff
contact with local elected and appointed officials.
In structuring its committee format, the WQM program utilized the RPC's stand-
ing committees for recommendations and plan approval functions, and then created
its own WQM special committees for sub-plan reviews and technical recommendations.
The SKVRPC Board of Directors serves in a policy advisory capacity to the WQM
program and is responsible for final plan approval. Other standing RPC groups
participating in the process are the:
o Water and Sewer Subcommittee;
o Land Use Subcommittee,"
SKV-S
-------
o Solid Waste Subcommittee; and
o Open Space Subcommittee.
Members of RPC committees are usually Selectmen, Sanitary District Commis-
sioners, planning board members or other local officials in elected or ap-
pointed positions. The Executive Director feels that contact with local
decision-makers through these committees and one-to-one discussions is the
best way to get their involvement throughout plan development and to ensure
their support at the time of p]an approval and implementation.
The subcommittees for technical review include the following:
o Trunk Sewer;
o District and Cities without Districts;
o Nonpoint Sources;
o Water Quality,'
o Public Works Department,"
o Technical Advisory Committee; and
o Economic Development.
Committee membership includes technical staff persons from State agencies
such as the Department of Environmental Protection and local offices such
as municipal engineering departments. WQM staff and consultants also feed
into the technical review process at this level.
Citizens, special interest groups and industrial representatives are be-
ginning to take a more active part in the WQM planning process through the
Goals and Objectives Committee. This committee was established during the
late months of the first year of planning. Its purpose is to redefine local
perceptions of water quality management goals and objectives vis-a-vis infor-
mation gathered in first year overview studies. According to the Executive
Director, the chief function of this committee is to provide a forum for
discussion among polluters, environmentalists and regulators.
With the exception of the recently established Goals and Objectives Committee,
the committees have met regularly as subplan elements and reports have been
completed. Full copies of reports and accompanying executive summaries are
always sent out in advance of meetings so as to facilitate meaningful discus-
sion among committee members.
SKV-9
-------
E. State and Federal Involvement
The State of Maine has actively supported statewide water quality programs
for many years and, indeed, played an instrumental role in helping local
areas become designated as WQM agencies. Maine had already prepared its
303(e) plans and collected substantial data on the Kennebec River before
the start of Augusta's VJQM program. The early and strong technical and
programmatic assistance from the State Department of Environmental Pro-
tection (DEP) has continued into the planning period. Each designated
agency has been assigned a liaison to provide technical assistance and
facilitate data exchange wherever possible. Augusta's WQM staff maintains
frequent contact with the State, particularly since the DEP is located in
the same city. The liaison attends all joint staff meetings and most
advisory committee meetings. Now that the State has begun WQM planning for
non-designated areas, the Augusta WQM program feels a particular need for
the State to move beyond technical assistance to actual program coordination.
This element, however, still remains undeveloped.
The Executive Director's assessment of the Federal Role in WQM planning
is somewhat less laudatory. He is unclear as to where the WQM program
fits into EPA's total concept of water planning and is unsure of their
commitment to continued WQM planning. He has characterized Augusta's re-
lationship with EPA as two thirds cooperative and one third advisory.
Although the EPA Regional Office has not hampered program operation, he
feels it has failed to offer the kinds of technical and management assis-
tance the agency has needed. In some cases, the EPA Regional Office has
not been sensitive to local problems. In the area of public involvement,
for example, the Executive Director feels that the approach commonly es-
poused by EPA is ill-suited to the designated area. He has had to con-
vince the regional staff that his notion of "co-opting" Augusta's public
is far more effective that EPA's idealized approach.
F. Scheduled Outputs
The following is a list of Augusta's scheduled WQM program outputs:
o Water Resources Data Availability;
o Land Use Trends and Projections;
o Demographic Trends and Projections;
o Existing Publicly Owned Facilities;
o Regional Facilities Overview,'
o Planned facilities;
o Non-sewer Areas Fevi.ew;
SKV-10
-------
o Industrial Waste Overview;
o Preliminary Report on Nonpoint Sources of Pollution/
o Nonpoint Sources - Detailed Analysis of Land Management
Areas;
o Nonpoint Sources - Waste Projections/
o Final Waste Sources Summary/
o Preliminary Waste Reduction Sub-plan,-
o Regional Management Study,"
o Management Alternatvies/
o Alternative Regional Water Quality Management Plans ;
o Environmental Assessment; and
o Final Plan.
The WQM program is on schedule, having completed most of its technical
studies, and is now moving into development and analysis of alternative
plan recommendations. The Schedule has undergone only minor revisions
since its initial writing — principally in the form of combining related
•program sub-tasks and allowing slightly more time to develop recommendations
for non-sewered areas. The staff does not anticipate any problems in com-
pleting the plan on time.
G. Achievements to Date
The WQM staff feel that the program has contributed to the region's planning
capacity by assembling water quality and land use data into a form which can
be used by'the RPC and local planning agencies. The staff has assisted
one town in developing a zoning code and will soon do the same for another.
It will also help two municipalities in their comprehensive planning efforts.
The Executive Director was also pleased to report that the WQM study will
save a considerable amount of money for some lakeshore communities which con-
templated sewering but have now learned that their lake eutrophication problem
stems more from feedlot runoff than from septic system leachate. Land manage-
ment procedures are far less costly and, in this case, will produce more
effective results than sewering.
A number of local officials reported that the WQM project has caused more
communities to acknowledge their need for regional cooperation. One indus-
trial representative was particularly elated that a forum for rational discus-
sion between manufacturers and regulatory agencies had finally been provided.
SKV-H
-------
III. EXPECTATIONS
A. Water Quality
\ The general consensus was that the quality of the Kennebec River will improve
11 as a result of WQM efforts, but that the water will never improve beyond a
1 "C" classification, nor should it, considering its functional economic uses,
i I According to the WQM Staff Engineer, making the river suitable for swimming
||or fishing would necessitate banning all industrial activity along its
' shanks. Since industry is an important element in the local economy, and since
|the lakes are the focus of regional recreational activity, the cost of clean-
jing up the river would far outweigh the benefits. This attitude is vividly
jreflected in the pattern of Augusta's historical development.
-The general attitude toward the lakes, on the other hand, is very different.
:The Executive Director anticipates a noticeable improvement in currently
polluted lakes once existing was~e collection and treatment systems are up-
graded and nonpoint source controls are adopted. The State Liaison and cit-
izens also noted optimism about preservation and protection of currently
pristine lake waters. One citizen felt that shoreline landholders will be
willing to accept inconveniences in the use of their land as long as improve-
ment in water quality of the lakes continues to hold high local priority,
and the land owner can clearly see benefits from these controls. His optimism
j\ was sparked by preliminary reports which suggest that much of the lakes' prob-
I lem is caused by agricultural runoff rather than septic tank leachate. Re-
quiring farmers and dairymen to adopt better land management practices would
financially affect fewer people than would massive sewering proposals.
B. Plan Approval and Implementation
Although the prognosis for plan approval varied among persons interivewedf
most were cautiously optimistic about approval on the local level. Two
local officials explained their optimism i.n terms of the level of water
quality awareness prevalent among local communities. They felt this aware-
ness will render decision-makers more receptive to suggestions for im-
p-roved water quality management. Two of the three citizens interviewed
shared this optimism. Both felt that the public involvement program was es-
pecially helpful in providing timely information, thereby "selling the pro-
gram" to the decision-makers. A third citizen was far more skeptical on the
basis of possible costs of management and the burden placed by these costs
on local governments. In her opinion, most local communities will promptly
reject any plan which requires locals to raise more revenue.
The Executive Director was somewhat hesitant to speculate on the likelihood
of plan approval. He felt that,although the area is currently receptive to
regionalizing wastewater collection and treatment systems, towns may react
negatively to individual elements of the plan, therefore,making it difficult
to secure overall plan approval. For example, many landowners are opposed
to increased land use controls and most local elected officials feel that
storm water management is too costly to consider at this time. The Executive
SKV-12
-------
Director feels that local officials consider plan approval a commitment to
plan implementation. Thus, if they disagree with some elements of the plan,
they may reject the whole.
When pressed for an overall assessment, the Executive Director finally specu-
lated on the possibility of a 60 percent chance of securing local communities'
approval of the WQM plan. Unlike the local elected officials and citizens
interviewed, he felt that local decision-makers have not been sufficiently
involved in WQM planning to date. He hoped to improve this situation, however,
during the second year of planning.
All persons interviewed were more confident about State than about local ap-
proval ot the plan. As noted earlier, Maine has actively supported ehe water
quality management cause in recent years throughout the State and been
closely involved with the Augusta-Cobbossee WQM project since its -inception.
No conflicts have surfaced to date between the State and the designated agency,
and none are anticipated by the State Liaison or the SKVRPC staff.
All persons interviewed were asked to comment upon the likelihood of plan
implementation. Most found it difficult to respond since the plan had not
materialized and since political attitudes varied considerably among towns.
Most finally gave the plan a 50 percent chance of being implemented across
the region. Among the constraints they felt might hinder implementation were
the following:
o Two citizens, a local elected official, a State Legislator,
and the Executive Director felt that local funding require-
ments might present a major problem from small communities
whose budgets are already strained by existing municipal
services.
o One citizen felt that if the plan called for a regional solu-
tion, local officials might wrangle over selection of a local
agency, thereby destroying any spirit of cooperation currently
existing among towns.
o Several people felt that traditionally hostile attitudes toward
land use control, regionalism and Federal intervention might be
too deeply rooted to be overcome, especially given the short
time frame for the study.
The Executive Director felt that, where it occurs, implementation will take
place slowly, over a period of 10 to 20 years. Many of the recommendations to
be made in the final plan have long-term horizons and will not be fully realized
in the first few years after plan approval. The continuation of interest
in water quality concerns, the reaction to initial land use controls and the
cost of management will greatly determine how many towns implement the plan
and to what degree. Expectations for typical management agencies of the
future focused on a strong preference for maintaining local control rather
SKV-13
-------
than establishing new regional agencies. Most communities in the designated
area already belong to sanitary districts which are empowered to undertake
facilities programs. The WQM Executive Director, local elected officials
and the appointed official interviewed envision an improvement in point source
control through greater coordination among these separate authorities. The
interviewees were confident that arguments for the economic efficiency of
cooperative action will convince local communities to work together. In
the area of nonpoint source pollution control, most persons interviewed
looked to the enhancement of local zoning and subdivision controls. The
WQM staff engineer also suggested that better land management practices fos-
tered by the RPC on local farms and dairylands would help overcome some of
the area's most severe nonpoint source problems.
None of the persons interviewed felt that the approval or implementation
would be hindered by legal constraints. All indicated that there are suf-
ficient State laws and local ordinances to implement the plan, at least
during the first year or two after approval. The Executive Director noted
that State laws in the areas of stormwater management, residual waste
management, agriculture, silviculture and soil conservation may be needed
in the future, as the continuing planning process and the WQM management
agency pursue further WQM issues and needs. More enabling legislation for
regulatory authority in particular may be needed as the program evolves.
C. Continuing Planning Process
All persons interviewed hoped that WQM planning would continue beyond its
scheduled two-year lifetime, but a few citizens and local elected officials
in particular felt that continuation will depend on the availability of Fed-
eral funds. Since Maine's economy has been depressed in recent years, locals
do not feel that the towns or State alone can support a continued program
at any kind of meaningful level.
In the opinion of the Executive Director, continued planning should concern
itself with refining the framework for comprehensively analyzing water quality
problems and their causes. It should also involve improving existing WQM
techniques and institutions in rhe areas of both structural and nonstructural
controls. One citizen felt that continued planning should focus on experi-
mental programs to test less expensive ways of dealing with water quality
problems. Most interviewees felt that the continuing planning agency should
act in a general technical advisory capacity to the management agencies.
With the exception of two citizens, the majority of interviewees felt that
the RPC would be responsible for continued planning. They considered it the
most logical choice because of its experience in regional and water quality
planning and because it is generally accepted as a local spokesman by communi-
ties in the area. Two citizens indicated that the State might assume the
planning function in the future, especially if the RPC failed in any way during
the course of the two-year WQM planning effort. However, other respondents,
SKV-14
-------
including the State Liaison, Executive Director and a local elected official
dismissed this possibility on the basis of current local support of the WQM
program, local hostility toward "outside interference" and the inability of
the State budget to accomodate such responsibility.
The need for continued Federal support of the program was voiced as a matter
of course by all interviewees. The Executive Director was quite hopeful of
continued Federal financing but also realized that the local communities
would have to bear part of the cost, probably on a 75/25, Federal to local
ratio. He felt confident that local communities would contribute to con-
tinued planning once they witnessed the benefits of the WQM approach. He
has not yet considered ways to raise the money, however, nor has he approached
local officials with the issue. He appears to be awaiting guidance or a fund-
ing commitment from EPA before taking any action. Presently, he estimates
that the first year of continued planning will cost 50 percent of the current
budget. Thereafter, the figure will drop to about 30 to 35 percent of
original funding levels.
D. Relation to Other Water Quality Programs
The State Water Quality Liaison sees a cooperative working arrangement de-
veloping between the RPC and the State on 201-related issues. In his opinion,
the State will come to rely more and more heavily on the WQM agency's advice
since the latter will have developed a greater expertise in local natural
conditions, political scenarios and facilities needs. The Executive Director
felt that the WQM program will primarily affect management issues since he
feels confident in the State's well-defined set of needs. Currently, the
WQM staff engineer is providing technical assistance on matters relating to
both the existing facilities and the proposed expansion of collector systems.
The Executive Director foresees a continuation of this advisory role. He
also hopes to put a cap on future facilities needs by promoting appropriate
nonstructural solutions such as land use controls, sub-division regulations
and improved septic system codes. One citizen felt that the WQM program's
role in determining where and what kinds of facilities should be built will
be so pivotal that continued WQM planning will be partially financed through
201 funds.
As to the NPDES program, the Executive Director hoped that the WQM program
will help build the RPC's technical capacity to comment on permit discussions
made by the State. This issue was of particular concern to an industrial
representative who feels that a forum is needed for discussing industrial
needs with environmentalists and regulators. Since the WQM program is sen-
sitive to local needs, he feels it should be the prime mover in making NPDES
standards which represent a compromise between economic and environmental
concerns, and constitute a major advance over current practices.
SKV-15
-------
E.
Local Definition of Success
Most interviewees ranked water quality concerns among their foremost
community goals and defined WQM "success" in terms of how it would help
towns meet their general goals.
Among the ways interviewees hoped to benefit from the WQM program are
the following:
o Several people indicated that they felt the need to control
growth to preserve the town's quality of life and protect its
water resources. These people hoped that the WQM study would
give them grounds to establish zoning and land use controls
to offset threats to their drinking water supply and to pre-
serve the quality of life.
o Another town hoped the WQM study would produce the evidence
they needed to protect a rare bank of sand formed over centur-
ies of natural water movement.
o One local elected official identified historic preservation
as the only way to keeping his city viable. He felt that
implementation of the WQM plan would mean a cleaner river
and therefore increased desireability of downtown property.
Increased land values, in his thinkiny, would encourage re-
vitalization.
o An industrial spokesman summed up the region's goal as one
of striking a balance between envirinmental and economic
concerns. The WQM program is tailor-made to this need.
SKV-16
-------
IV. VARYING PERSPECTIVES OF WQM
A. WQM Staff
As noted earlier, Augusta's small WQM staff consisted of only the RPC
Executive Director, an Engineer, a Regional Planner and a Cartographer.
The Executive Director views his role as one of facilitating cooperative
action among towns and ensuring timely flow of information, both in-house
and to the public and other decision-makers. He was attempting
to co-opt local officials into participating in the program and deciding
in favor of the final plan.
The Project Engineer was formerly with the Maine DEP and had assisted in
securing areawide designations early in the history of the WQM program.
He was very familiar with the intent of the national program and sensitive
to the State's perspective. He viewed his role as one of providing and
interpreting technical information to substantiate reasonable arguments for
a regional approach to wastewater collection and treatment. The Regional
Planner was involved with the social and economic impacts of various planning
alternatives.
The staff was very excited about its work and was optimistic about the like-
lihood of plan approval and implementation. Their optimism was based on the
compact size of the designated area which makes the study manageable and al-
lows most people to feel a personal stake in the decisions at hand. The
WQM staff has established a good working relationship with the local sewage
authority and with local communities which have sought the RPC's advice on
•local planning decisions. Although the Executive Director feels that not
all local elected officials are sufficiently involved in the WQM process,
he has personally established contact with most of the key officials and hopes
to arouse further support as the plan nears its final review.
B. Citizens
Three citizens were interviewed in the Augusta area. One is a realtor and
member of a local planning board. Another is an officer of a lake associa-
tion. The third is the official representative of Augusta's major manufac-
turing firm. All three are members of the WQM Goals and Objectives Committee
which is responsible for striking a balance between local economic and environ-
mental concerns.
Each person felt that he had a personal stake in the WQM program outcome.
Two were particularly interested in preserving the "quality of life," re-
creational amenities and property values in their lakeshore communities.
The industrial representative was concerned about keeping expectations
about upgrading the Kennebec River within a range which will allow continued
operation of the plant.
SKV-17
-------
The interviewees felt that their input into the WQM planning process had
been meaningful to date. They were not particularly concerned that the
general public is not more actively involved in the process. Rather, they
shared the Executive Director's opinion on public involvement, i.e., that
the most effective way to reach the public is through public interest
groups and local elected officials. They were optimistic about the likeli-
hood of plan approval and implementation despite local Communities' tradition-
al stand against land use controls, regionalism and any program associated
with a Federal label.
C. Local Elected Officials
Two local elected officials were interviewed. One is the Chairman of a Town
Council/ the other is a Town Selectman. Both are members of the SKVRPC
Sewer and Water Subcommittee.
The first local elected official was primarily concerned with preservation
of the lakes as they relate to his community's water supply. He viewed the
WQM program as a framework for discussion and a means of identfying the most
efficient and effective approaches to local water pollution, tie voiced
no criticism of the program and envisioned it continuing in an advisory
capacity.
The second official has been an advocate of cooperative community action
long before the WQM program came into existence. Although he recognized the
advantages of working together as "a community of communities," he feared
that some Councilmen are still unaware of the WQM program. He was partic-
ularly concerned about those towns which will not receive immediate, visible
benefits from the plan and therefore will find it difficult to transcend
their parochial outlook. Despite this concern, the Selectman was general-
ly satisfied with the way the WQM program was operating and blamed any fail-
ure to involve local officials on the apathy of non-participating local of-
ficials .
D. Appointed Official
The appointed official interviewed was Superintendent of a local sanitary
district. The Superintendent was a member of the Technical Advisory Com-
mittee and also served on the Management Subcommittee. In addition to at-
tending formal meetings, he was in frequent contact with the WQM staff engin-
eer with whom he exchanged technical data and advice. The Superintendent
was not only pleased with the day-to-day advice he received from the WQM
but also with the changes in management which it proposed. He was confident
that the local communities would approve the final plan because he anticipated
that it would suggest extended services which he felt communities wanted.
E. State Legislators
Two State Legislators were interviewed. One also served as a mayor of a
local community. The State Senator was not active in the WQM program and
SKV-18
-------
was quite unaware of its developments to date. He felt, however, that the
existence of the legislative committee structure eliminated a personal obli-
gation to get involved in the program. His area of concern was education.
He concentrates his efforts and attention in this area and relies on the
Natural Resources Committee to advise him on environmental issues.
Unlike the State Senator, the Mayor/Assemblyman was attuned to Augusta's
WQM program and its potential effects on his community. His direct line
to the WQM program is through his town's representative on the RPC Sewer
and Water Subcommittee. He also relied on the Natural Resources Committee
for a State perspective on water issues. The Mayor/Assemblyman felt that
the Committee is probably aware of Section 208 but was not sure how closely
they followed it on the regional level. He indicated that the Legislature
was currently receptive to providing money for environmental causes-, bur
that any action on their part would have to overcome the Governor's general
reluctance toward increased State spending.
F. State Water Quality Personnel
The official State liaison duties were delegated by the Governor to the
Department of Environmental Protection. The DEP was very active in en-
couraging RPCs to seek areawide designation when Federal money was-first
made available in 1974. After designations were made, the DEP assigned a
liaison to each of the areawide WQM agencies. These liaisons were charged
with the responsibility of offering technical assistance where requested,
reviewing project outputs, circulating reports among related State de-
partments and ensuring consistency between areawide programs and State
policies.
Augusta's Liaison found no problems in his relationship with the WQM agency.
Coordination with Augusta has been particularly facilitated by the presence
of a former State Liaison on the areawide WQM staff. The former Liaison is,
of course, very familiar with the State's perspective.
According to the State spokesman, the DEP plans to incorporate the Augusta
and other designated area WQM plans directly into the statewide plan. He
could not identify any areas where, with the benefit of hindsight, he
would suggest changes in Augusta's program. His one complaint was on the
short time span for planning. Given more time, he felt that the WQM agency
could assemble a more complete data base to design and support their manage-
ment suggestions. He was generally optimistic, however, about the likeli-
hood of plan approval and implementation.
SKV-19
-------
IV. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
It appears quite certain that the Augusta-Cobbossee WQM plan will be com-
pleted within the study's two year time-frame. With about nine months of
planning remaining at the time of the interviews, the staff had completed
most of its technical studies and was organizing an outline for final plan
preparation.
There appear to be several reasons why the WQM agency is on schedule.
Among these are:
o Reasonable expectations about what can be accomplished in
two years;
o Utilizing experts familiar with the area, i.e., local Lakes
Associations and engineering firms currently engaged in local
201 planning, to conduct most of the technical studies/
o Experiencing few delays in data collection/
o Receiving good cooperation and active support from the State
DEP f
o Knowing the public and the most efficient ways to reach them,
and,'
o Using the existing Sewer and Water Subcommittee of the SKVEPC
in the advisory committee structure.
Much of the WQM agency's good sense alluded to in the above list is attributed
to the Executive Director. His experience with the SKVRPC and his sensitivity
to the area's political climate have played a large part in shaping the pro-
gram. The schedule he has set should provided ample time for refining plan
alternatives, involving the public in review of alternatives and communicating
the plan to local elected officials.
The probability of plan approval is very difficult to assess, given the strong
independence and unique character of each individual community involved. One
hopeful sign is that none of the towns have voiced opposition to the study,
nor have any dissenting interest groups arisen. By now, the study is suf-
ficiently visible to have elicited overt displays of opposition if such senti-
ments did indeed exist. Most local officials appear very concerned abouc the
area's water quality and at least the few interviewed were optimistic about
the potential success of the WQM program. Also, in the compact study area,
almost every individual involved in the WOM program has a personal stake in
water quality management decisions.
SKV-20
-------
Part of the optimism about approval stems from the political acumen of the
WQM study management. Keeping the program at a low profile and working
within the framework of existing management systems has presented an un-
threatening image to the towns. The WQM program has attempted to involve
all groups which promote or hinder plan approval so as to "co-opt" them
into supporting the outcome. Offering technical assistance to individual
towns and sanitary districts has also helped gain visibility and credibility
for the study which should prove helpful at the time of final plan review.
The political climate itself should also contribute to the likelihood of
approval. For at least half the towns, the following, are strong incentives for
supporting a WQM which addresses both point and nonpoint problems and stresses
cost effective non-structural solutions wherever possible:
o Recent precedents of State Water Studies,-
o Growing public awareness of pollution problems ,•
o Increasing local desire to coordinate 201 activities; and
o Depressed economy.
.Once the hurdle of plan approval is passed, implementation should follow al-
most automatically (though not necessarily immediately), unless extensive
amounts of local funding are required. For most towns, plan approval ap-
pears to be a sign of commitment to action. In fact, the reason why some
towns may not approve the plan may be that they cannot abide by selected
portions of it, and,therefore, refuse the whole. The WQM staff will have
to conduct a good selling job to assuage the towns' fears of regionalism
and Federal intervention. The key items to watch are:
o Whether the program can effectively reach LEO's;
o Whether any opposition groups develop, or alternatives are
refined; and
o Whether any of the later stages of analysis will result in
changes in and/or support of staff recommendations.
B. Public Involvement
The public involvement effort is geared almost exclusively toward Lakes As-
sociations, industries and local elected officials rather than toward the
general public. Some public education work is taking place through the
general mailings and speaking engagements at Community or interest group
gatherings. But past experience has shown that efforts to reach the general
public in the Augusta area are not only costly, but are not all that meaningful.
The first meaningful public involvement has occurred recently through the
Goals and Objectives Committee. Unlike many other WQM agencies which get
SKV-21
-------
public interest groups, industries, etc., involved early in the process and
then lose their interest by the time meaningful input can be made, the Augus-
ta study waited until they had concrete issues to which the public could react.
As a result, members of the Committee feel that they have an important and
influential role to play in plan development. Their enthusiasm should carry
through to the end of the planning phase.
The key people to actual plan approval and implementation are Town Select-
men, local Sanitary District Commissioners and Lakes Associations which will
probably be the most vocal supporters of the plan. With the exception of
several Sewer and Water Subcommittee members who have been actively involved
in the review of planning outputs, few local elected officials actually have
been involved in the WQM process. The Executive Director has tried to keep
the latter groups aware of the program by maintaining phone and mail contact
with them. This has been sufficient during the first year of planning when
the program was concentrating on technical studies, but now that alternatives
are being developed and refined, local elected officials' involvement is
crucial and should be stepped up. Again, with about nine months remaining,
there should be.sufficient time to make a meaningful impact if their involve-
ment can be facilitated.
C. Current Planning Process
The WQM plan will address some site-specific facilities problems but, in
general, seems geared toward comprehensive, areawide coverage of water
pollution issues. In taking a comprehensive approach, the Executive Director
appears to be responding to what he perceives as EPA's directive to address
the full range of possible v/ater quality issues. The broad scope of study
has precluded in-depth analysis of all problems. But even identification
of existing and potential problems and their most probable causes should be
useful in future management planning. For example, determining that
natural and rural runoff contributes more to lake eutrophicat.ion than does
septic leachate wil] redirect control efforts away from massive, sewering
programs and toward more effective land use and land management practices.
The Executive Director has been able to avoid becoming overwhelmed by con-
centrating on developing a process for management decision-making rather
than trying to find all the technical answers within two years. He has
stressed the development of forums for discussion among industrialists,
lake associations, sanitary districts and local officials while still
producing some products (land use, lake sampling, etc.) necessary to
formulate recommendations and gain credibility for the SKVRPC. This approach
is probably most reasonable for the area, given the existence of under-
managed water and sanitary districts and the currently high visibility of
lake problems. The value of this approach is largely contingent, however,
upon the continuation of planning beyond the initial two year period.
Whether or not the full benefits can be reaped depends on whether or not the
WQM agency can convince the local communities to continue the efforts and
implement the planning.
SKV-22
-------
At no point in the process has the agency invoked the threat of Federal
sanctions as an incentive to plan or implement recommendations. Such action
would only alienate local communities which already fear Federal inter-
vention. Instead, the agency needs to plod along gently as it has been
doing, constantly demonstrating the need for action and the value of the
plans the agency recommends.
D. Continuing Planning Process
Despite the fact that all interviewees expressed a desire to see WQM
planning continue beyond two years, the prospect of continuation appears
to hinge on local decision-makers' reaction to the final plan and the
availability of Federal funds. Presently, most towns in the area are
hesitant if not opposed to the concept of regionalism. Whether or not
the WQM process can change this opinion remains to be seen. A good indicator
will be the degree of plan approval and implementation. As to funding,
neither the towns nor the State have the resources to support anything but
the most minimal of planning efforts unless they are supported by Federal
funds. It appears unlikely that Maine's financial problems will change
significantly in the. next few years, so the Federal response will be quite
crucial.
If planning does continue, it will probably involve some added data gathering
efforts and technical analysis, especially on the lakes. The SKVRPC's role
will be to provide technical advice and management assistance to the
individual towns, sanitary districts and/or other regional management agencie
to be created in the future. The RPC is beginning to cultivate the trust
of local communities. If it can continue to do so, it probably will.be
quite influential in future WQM decisions.
G. Significance of Local Elected Officials' Involvement
As noted earlier, local elected officials have not participated actively
in the WQM process to date. However, Sewer and Water Sub-Committee members
have played an important role in review of interim outputs throughout the
process. ¦ The WQM staff has relied on them to act as spokesmen for sanitary
districts and local communities. Without becoming subservient to the Sub-
committee's reviews, the staff has incorporated their comments and concerns
into plan development. The Sub-Committee members, in turn, seem pleased
with the responsiveness of the staff and may be helpful alli.es at the time
of final p]an approval.
SKV-23
-------
AGENCY: SOUTHWEST FLORIDA REGIONAL PLANNING COUNCIL (SFRPC)
REGION: IV - (Atlanta)
GRANT RECEIPT: June 1975
GRANT AMOUNT: $949,000
STARTING DATE: July 1976
STATUS AT TIME OF INTERVIEWS: Are awaiting approval of revised work plan
for State and EPA. Committees have been
organized since September 1975.
REASON FOR INCLUSION IN SAMPLE: This is a coastal area.
SF-1
-------
I. BACKGROUND1
A. Area Description
The Southwest Florida designated area consists of 6021 square miles of
relatively flat land located on the coast of the Gulf of Mexico between
Tampa and the Everglades. Much of the developed portions are located
along a north-south interstate highway. Tourism construction and agri-
culture (sugar cane, cattle and citrus) are the main employers, as there
is little industry.
The designated area consists of the six counties — Sarasota, Charlotte,
Lee, Collier, Hendry and Glades — which make up the Florida State
Planning District #9. Within this area there are seventeen local govern-
ments, nine of which are located in the two SMSA's of Sarasota and Ft.
Meyers. This area is considered cne of the fastest growing in the country.
In 1970 there were 306,756 inhabitants. By 1975, the University of Florida
estimated population at 4 35,000 and by 1995,population is expected to be
700,000.
There are other related projects underway which will be coordinated with
the VJQM Study. One of these is the Coastal Zone Management program. Both
projects, for example, try to avoid duplication in data collection. This
area was also designated a Flood Control District by H.U.D.
This area experienced a tremendous amount of residential growth over the
last two decades. There are large numbers of condominium developments and
•trailer parks throughout, often catering to retired persons. For many large
sections, the land has been platted, streets built, and lots sold (often to
persons out of state) , but no or.e has yet built any homes. This presents
a curious sight, and a potential headache.
There is no overall set of community objectives in this area within which
the WQM can function. In general, there is a realization that "biggest is
not best", growing out of a negative reaction to the rapid and uncontrolled
growth of the past.
The counties and cities are all at different stages of being able to ccpe
with the growth. One county was zoned and platted for one million people,
although they now have only 45,000. They are searching for methods to
make sure that the growth, when it occurs, is slow and orderly. The county
adjacent to it has no land use plan and no idea of what they want. Indi-
vidual communities are adopting their own land use plans, including one
Information in this Chapter was taken from the SPRPC work - plan;and
from interviews.
SF-2
-------
which has set a population limit. Zoning, where it occurs, serves mainly
to keep out heavy industry.
B. Water Quality Problem
Within this area there are four watersheds, two major river basins, thirty
minor rivers and creeks, 220 miles of coast, more than seventeen estuarine
bodies, and numerous canals (many of them man-made). In addition, the
area covers one-third of Lake Okeechobee, a water supply source, and Charlotte
Harbor, a popular recreational fishing area. All waters in the area are
classified WQL by the State, pending reclassification.
The first step in program design was an inventory of all water quality data
available, including NPDES permit information and STORET file data. From
this, all waters and their problems were evaluated, and the most critical
were prioritized. Severity rankings were matched with importance of the
water body as a natural resource and suspected cause of the problem. All
of this information was then given to the 208 Advisory Committee to come up
with a final list of highest priority segments, which were used to develop
the five critical areas for study.
Water quality problems are associated with a number of sources. In many cases
they are from point sources, in other areas it is due to urban runoff, sep-
tic tank leakages, and'livestock and agricultural runoff. Another major
problem is that most of the area is a drained wetland with man-made canals
which intercept the natural flow of waters subsequently, and, the ecosystem.
'C. Designated Agency
The designated agency is a regional planning council. It was established in
1973 and staffed in 1975. Although WOM is the first major effort for the
agency, it has complementary responsibility for coastal zone management
program and for the State Development of Regional Impact (DRI) Process. The
agency also does DOT, HUD 701 and LEAA planning.
The State of Florida recently has enacted a lot of legislation related to
the environmental, land use and planning issues. One lav;, for example, re-
quires land use plans by 1978. Another, the Environmental and Land Management
Act (ELMS) established a state EIS process known as DRI. This process es-
tablishes and provides funding for regional planning commissions to make
fiscal, economic and environmental impact assessment of major private
development projects and all government facilities. It also establishes a
State purchasing program for areas of "critical State concern". The
designated agency recently has completed a major DRI on a proposed estuary
development scheme.
Although the RPC has no land use sowers, it has considerable influence over
the urban infrastructure. Through DRI, they impact transmission lines, and with
SF-3
-------
WQM,they hope to expand their sphere of influence to include sewer systems.
Full time staff working on the WQM study include the Project Manager, one
person responsible for monitoring technical contracts, and one person respon-
sible for the contracts on facilities planning. Two-thirds of the grant
will be used to hire consultants for certain v/ork eJements. Initially, a
consultant was hired to write the work plan, but it was considered un-
satisfactory and rewritten. The same consultant was hired to do engineering,
management and public participation, but has since had the management and
public participation.sections taken away. Another engineering consultant
was hired to do problem identification and probably will be used for making
impact assessment also. Most of the sampling, monitoring and analysis will
be done by this consultant.
In addition to the private consultants, the WQM agency has entered con-
tractural arrangements with some public agencies. Lee County is doing the
water quality analysis for the Caloosa Latehie River. New College is con-
ducting the septic tank analysis of Lemon Bay, and the University of Florida
Law School will examine the legal basis for controlling runoff.
SF-4
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The overall objective of the WQM project is the achievement or maintenance
of water quality standards "suitable for the protection and propagation
of fish, shellfish, and wildlife and recreation". Because the grant was
not sufficiently large to complete studies in all parts of the designated
area, the work program was designed to accomplish two things:
o Identify, prioritize and schedule public wastewater
treatment facilities eligible for 201 funding. To
encourage and assist those agencies which will be
responsible for construction and operation of treat-
ment facilities;
o Analysis and alternative solution selection for priority
problems in each of five critical areas. These problems
include a mix of point and nonpoint source concerns.
B. Technical Component
Technical portions of the plan are divided among the five critical areas
selected by the Advisory Committee. Predominantly, work will involve
monitoring to determine where problems lie and development of regulatory
controls, where indicated.
The first critical area covers Phillippi Creek, Roberts and South Sarasota
Bays, and Little Sarasota Bay. There are at least six point dischargers
into these water bodies, but the primary focus will be upon nonpoint sources.
In the eastern portion of the area, problems come from crop and livestock
production; problems in the western portion come from urbanized land uses.
The study will begin with a survey of existing land use, topography and
hydrology. A sampling program will be designed, specifically to measure
urban runoff from particular uses and to find their impact on receiving
waters. This study also will involve a hydrodynamic sampling program tracking-
tracers. Data from the hydrodynamic study and pollutant loadings will be
used together to determine allowable waste load levels for attaining stan-
dards. Outputs from this critical area study will include: sub-plans for
urban runoff and for agricultural runoff; and a program of treatment facility
construction; and regulatory actions to control pollution of the area.
The second critical area is Lemon Bay, the non-urban coastal basin near the
barrier islands, and an area popular for shellfishing. The focus of this study-
is on whether septic tanks are causing coliform and nutrient pollution of
the Bay. The study consists primarily of a sampling program and a tracer
study. If septic tanks are found to be a problem, a regulatory program
SF-5
-------
will be designed.
The third critical area is Charlotte Harbor, one of the largest estuaries
in the State and an important natural resource. The objective of the study
is to determine the spatial and temporal distribution of contanimants coming
into the estuary as well as an assessment of total pollutant loadings. Again,
the study will rely heavily upon a sampling program. Specific sites for
monitoring will be selected following a review of land use data. Specifi-
cally, urban (commercial and residential), pasture, open spaces and canals
(hydrographic modifications) will be studied. The final outputs will be
a series of alternate controls for both point and nonpoint source pollution.
The fourth critical area is two segments of the Caloosahatchee River. In one,
there are problems from agriculture and livestock operations; in the other
a drinking water supply source (Lake Okeechobee) must be preserved. Again,
a sampling program will be used to provide baseline water quality data as
well as quantification of loadings from livestock and cropland runoff and
from urban runoff. Storm sampling, baseline and flow data will be used to
relate pollutant loadings to water quality. Projections of future loadings
will be made and control techniques will bQ developed.
The fifth critical area is the Big Cypress Basin, another extremely compli-
cated estuarine complex that consists of a series of coastal streams, bays,
marshes, islands and hammocks. The primary objective of this study is to
conduct sufficient sampling to recommend a water quality monitoring pro-
gram to the local government.
C. Management Planning
Management planning will consist primarily of the institutional analysis and
the analysis of implementation mechanisms found in the third and fourth task
elements. Management planning will be completed by one of the staff members
with the Project Manager. It is scheduled to start in September 1977. One
of the first priorities for management planning is to change the existing
structure as little as possible. Beyond that, management studies will ex-
amine the political base, financial support and legal power of potential,
management agencies.
D. Public Involvement Program
The public involvement program was designed around two principles. First,
it seeks to involve primarily the representatives of local government who
will be responsible for making recommendations. Accordingly, each local
government was asked to submit the names of a planner, an engineer, and a
leader of environmental interest groups as delegates to the WQM committees.
The second principle followed in designing the public involvement program was
that committees should be divided according to major drainage basin. In this
SF-6
-------
way, committee members would have a common interest and frame of reference.
Consequently, four advisory committees were created, one for each basin.
Advisory committees have been involved in the study design since its in-
ception. During the data assessment stage, for example, they reviewed
consultant reports and made priority recommendations. They were also given
briefing sessions by USGS and SCS representatives to increase their techni-
cal knowledge of the areas. All four advisory committees are expected to
continue having input into management, regulatory and impact stages of the
study plans.
The work program indicates that most of the resources for public participa-
tion will be used after alternatives have been developed and impacts deter-
mined. If necessary, a full-time staff member will be assigned to coordinate
efforts which will include presentations, information depositories, public
service broadcasts, and newspaper supplements. The final plan will go through
formal public hearings.
Advisory committees have been meeting since September 1975. At the first series
cf meetings, an orientation handbook was presented, and at the second series,
guest speakers outlined local problems. .In the third series of meetings/ pre-
liminary goals and objectives of the study were set. Committees did not meet
from mid-October until March, the time during which consultants were being
selected and contracts arranged. During March and April the advisory com-
mittees met with the staff and consultants to discuss work program priorities.
In the future, it is intended that committees will meet in order to hear
progress reports.
E. State and Federal Involvement
The Project Manager described his relationship with the Regional Office as
"very good". He feels he has been given a lot of guidance and was particular-
ly grateful for their guidance in how to let contracts. The Project Manager ...
has found that the gui.dance from EPA Headquarters is__^^ficjiJLtwito__ unde_r~i..
stand and often waffles. He is particularly bothered by the guidance on WQM/
201 coordination and the guidance that outlines State involvement.
The Project Manager feels they have a "neutral" relationship with the State
Department of Environmental Regulation, although, up to this point, it has
been "hostile". He believes that their comments on the work plan were not
helpful, and has so far, has refused to pay the State the money they want for
their review services. The State, in turn, has refused to approve the work
plan except with a series of conditions, including a requirement, to pay the
$29,580. Other than to review the work plan, the State has not been particu-
lar] y involved thus far.
The Department of Environmental Regulation i.s also having trouble gettiny
the money from the other twelve Florida designated areas!
SF-7
-------
F.
Scheduled Outputs
The first work task deals with identification, prioritization and scheduling
construction of treatment facilities for a 20 year period. There are cur-
rently nine 201 designated areas." Five of them (four counties and one city)
have received Step I grants. Activities under this task include:
o A 201 workshop to disseminate information about
facility planning;
o Concentrated efforts working with the inactive
areas to encourage their participation in 201;
o For those areas that will receive construction
grants— select service areas, estimate flows, cost
estimates of alternative treatment systems;
o Analyze the requirements necessary to control urban
stormwater runoff in Phillippi Creek, Charl^+"t'°
Harbor and the Caloosahatchec River;
o Review of Step I plans for conformance with EPA
guideline AM-II;
o Prioritize needed facilities for five years based on
severity of pollution, population affected, need to
preserve high qualify waters and national priorities;
o Scheduling of facility construction for 20 years.
The second work task involves establishment of regulatory programs in the
^ive critical areas, and one task which is a generalized regulatory pro-
gram for control of pollution in the "non-critical" areas. The task was
divided in this way because lack of funding did not permit examination of
all problems. It is believed that the major source of pollution in these
areas is domestic waste, which can be handled through creation of areawide
waste treatment systems. Programs for the five critical areas are described
in Section IIB. They consist predominantly of sampling programs designed to
yield sufficient information to develop a regulatory control program.
The third task in the work plan involves an institutional analysis of agencies
which will be responsible for construction and operation of treatment facili-
ties and analysis of agencies which can implement the regulatory programs
called for in each of the five critical areas. Finally, agencies will be
identified whose responsibility will bo to oversee overall implementation and
to perform continuing planning analysis. This task will include legal au-
thorities, administrative capabilities and financial support. Institutional.
SF-8
-------
alternatives will be presented to advisory committees and to Southwest
Florida Regional Planning Council for approval.
The fourth task of the program involves four sub-tasks. These are:
o Identification of measures needed by the manage-
ment agencies for implementation;
o Establishment of an appropriate timeframe for
implementation;
o Determination of cost of implementation;
o Assessment of environmental, economic and social
impacts.
Monitoring in the five critical areas, which is a large part of the work
program, will take place for one year from July 1976 to July 1977. The
analysis of regional programs (land use, etc.) will be done between January
and July 1977; so will the 20], work leading up to a prioritization of needed
facilities. Management planning, including identification of management
agencies, necessary authorities, and impact assessment will be done between
July and October 1977.
G. Achievements to Date
It took several months for this agency's project to get underway. Because
it was the agency's first major program, an Accounting Procurement System
had to be established. The EPA Regional Office helped with this and with a
consultant selection procedure, which the Executive Director feels is a
"model". 1
Phase I of the project has been completed for some time. Basically, this
involved a compilation of all existing water data in order to define, prior-
itize and select those problems to be treated in the initial workplan. Con-
sultants were selected in early Spring for the technical water quality por-
tions of the plan. In the meantime, the WQM is concentrating on following
the 201 planning presently underway. In the fall they will hold a 201 work-
shop to try to get other eligible communities interested in pursuing a grant
Committees organized along river basin lines have been established. They do
not, however, meet regularly. Rather, they meet when the WQM agency feels
Basically, consultants were invited to submit ci statement of qualifica-
tions. The agency then did a written analysis of each consultant according
to their own guidelines. Three consultants for each contract to be let
were then asked to submit a proposal. The Agency Council made the final
decision within each seL of three.
SF-9
-------
there is something to be reported or, when an approval is needed. Between
meetings, members receive a newsletter which reports happenings and activi-
ties .
The Project Director described three changes in the area that he fe]t were
WOM project accomplishments. Fcr the first time in the history of southwest
Florida, governments are working together cn a regionwide basis to try an3
solve their water quality problems. The second achievement is that WQM has
shown several local area governments, especially counties, where they can
get money for facilities projects. The third accomplishment cited was a
belief that WQM agencies helped bring about a restructuring of the State
bureaucracy responsible for coordinating WQM plans. The Project Manager
was hopeful that the new structure would be more responsive to the needs of
the designated areas.
SF-10
-------
III. EXPECTATIONS
A.
Water Quality
There were a variety of opinions about whether the area would meet the 1983
goals of fishable, swirnmable waters, and how, if at all, the WQM plan would
help achieve improved water quality. The Executive Director of the RPC said
it was a question of funds; adding that if they continued to receive 201
monies, if a solid waste program could be started, and if the work of the
WQM continued that yes, water quality would improve.
Most interviewees discussed meeting the goals vis-a-vis point source problems.
The appointed official .ji.a id he was_j3ptimisti_c_ that point source problems could
be solved by 198 3. One citizen fe]t the area bare]y met the standards now.
He was outraged as to EPA effluent limitations, calling them "secret", "out-
rageous", and "counterproductive to meeting the goals". The Project Director
said that the area's major point source problem is sewage which should be
improved by the WQM study. He said the area, for the most part, meets the
goals except in worst case conditions.
B. Plan Approval and Implementation
Almost everyone interviewed gave high marks (9 or 10 of 10) to the likelihood
of plan approval and .plan implementation. The WQM Project Director explained
that this is because they designed the work plan by working backwards from the
goals they considered attainable. Some of the other comments given i.ere:
o
State Liaison said it is his job to make sure that
the plan is approvable;
o
One city engineer gave a "9 or 1" for implementation
depending on whether money is available. He added
that in Lee County, one Commissioner is against all
Federally-funded projects;
o
The Ft. Meyers Director of Community Development said
the city surely would approve and implement the plan
so long as they don't have to give up control of their
treatment 'facilities;
o
One citizen said the plan had zero change of either
approval or implementation. He thought beginning
201 type work was a mistake;
o
One local elected official said he gave high ratings
(9.5 on both) because lie believes this eirea is very
planning-minded. The other local official agreed,
but added that implementation would dej^end on funding;
SF-11
-------
o The RPC Executive Director was less sure about
implementation (he said 7) because he is unsure
what the agency's future personnel picture will
be and, therefore, is unsure about their ability
to oversee implementation.
No one seemed to know what the cost of implementation would be, or where
the funds would come from. The Project Director explained that determining
cost of implementation was one of the sub-tasks at the end of planning. He
believed that quality of the product is the key to getting money for imple-
mentation — "if people like it, we'll get money." Most everyone agreed
that there were no local funds for implementation. Only the City Director
of Community Development was not considering asking for more Federal money.
He commented, "There's still plenty we can do at the county and city level
even if there is no Federal money."
The county official responsible for 201 planning sees the area working toward
a regional management system. This is somewhat contrary to the opinions of
some city officials who feel the city will never give up control of its
facilities. One County Commissioner, concurred with the city view. His view
was that the best management level is the county. He thought that the RPC
thinks in terms of regions, but that, "It would be foolish to recommend any-
thing that can't be implemented", which is what regional management would be.
One of the County Commissioners commented on the climate for making changes.
He felt that Florida is moving away from their former position of a restrictive
planning philosophy to one that allows laws to take effect before passing moire.
"After all," he continued, "the environmental appetite is insatiable." The
second County Commissioner felt that the Florida Water Management Districts^
were the most logical implementation authorities. They already have both en-
forcement powers and taxing authority.
C. Continuing Planning Process
There were very few specific comments made about continuing planning. The
RPC Executive Director called WQM "planning in action". He forsees an overall,
program to control wastes with WQM policing 208 and 201, and expects it
probably will be funded through Federal grants. One of the County Commissioners
said he, "hopes the plan is valid for a number of years", and that all they will
need to do is continue testing. The other County Commissioner felt that plan-
ning will continue, although some people always think planning is a waste.
One citizen and the State Liaison both said that continuing planning should be
used to update the plan, and that this definitely should be done at the local
Some people thought the Water Management Districts were the most appro-
priate agency to perform WQM planning. They are governed, however, by
an appointed board and, therefore, are ineligible by EPA's designation
criteria.
SF-12
-------
level. Finally, the Project Director sees continued planning as a moni-
toring process. He says there is no local source for this money and be-
lieves that, "the Feds will be sued," if they don't proyide_ additional
planni ng ^money.
D. Relation to Other Water Quality Programs
One of the most important objectives of this WQM project is to try and get
as many eligible governments as possible into the 201 program. In speaking
with counties and cities, the WQM agency found that these areas do not under-
stand the 201 program, particularly the requirements for a user charge and an
industrial cost recovery program, and, therefore, there have been difficulties
getting projects adopted locally. The agency intends to hold a seminar in
the fall to explain the requirements of the 201 grant program. The agency also
has offered to do Step 1 planning for three of the areas.
Besides trying to get communities involved in 201, the agency intends to play
a large role in the facilities program. For example, they will prioritize
facilities needed in the area and pass these recommendations on to the State.
The agency alr.o will review 201 plans (although not the technical parts) .
The appointed official interviewed expects WQM will be involved in"future
changes. One citizen was pessimistic about the future facilities picture.
He felt the 201's underway were probably a waste because construction money
would not be available. He thought priorities were, "determined by the local
newspaper, and they're anti-regional."
\ The Project Director thought that the greatest WQM impact on the permit pro-
gram would come from the five critical area studies. Because they will be
calculating wasteloads, the WQM will be in a position to recommend changes
in allocations which would change permits. For this State, EPA controls the
permit process. One of the citizens was outraged because EPA had recently
published effluent limitations that were less strict than those already in
effect. He added, "WQM can't save that."
E. Local Definition of Success
Interviewees produced a series of definitions for success, mostly centered
around a better understanding of what the problems are and possibilities for
solving these problems. Specific answers included:
o Clean up the nonpoint source problems that are
practical (e.g. agriculture) (citizen);
o Achieving the water quality goals of PI. 92.500
(citizen);
SF-13
-------
o
A comprehensive evaluation of potential problems
so that preventive, not corrective, actions may
be taken (County Commissioner);
o
A political process for solving water quality
problems (State Liaison);
o
Answer questions about the river condition
(Appointed Official);
o
Maintain some waters and improve others. Set
up an institutional process to keep good water
quality (WQM Project Director);
o
A reasonably approved waste disposal plan that
is implemented and eventual solution to existing
point source problems (RPC Executive Director).
Responses to a question about expected benefits from W2M planning were very
similar to these difinitions of success: "developing baseline data"; "know-
ing if there is a septic tank problem"; "for once we'll be able to compre-
hend our problems"; "we'll have an awareness of where the problems lie and
what controls might be available"; "basic research for future years." Since
these answers were repeated twice at different points in the interview, and
in response to slightly different questions, two things might be inferred:
either people in this area define success in terms of what they expect will
happen; or, people are expecting to know more about their water quality
problems as a result of WQM planning, and this is what they feel is a success.
SF-14
-------
IV.
VARYING PERSPECTIVES OF WQM
A. WQM Staff
The WQM staff .is well-integrated into the full RPC. For example, several of
the WQM staff did work on a recent "DRI" and DRI staff works on parts of the
WQM study. In this way, WQM becomes part of a larger framework of analyzing
regional impacts of proposed development projects. This ability to be flexi-
ble with staff is seen as a strength for the WQM project.
The DRI and WQM programs together are building the reputation of this new
agency. So far, everyone seemed to agree that they are establishing a posi-
tive impression about what can be accomplished through the RPC. The assess-
ments of the WQM staff by citizens, appointed officials and local elected
officials were consistently favorable.
Thie RPC Executive Director and WQM staff alike are enthusiastic about the
future role for the WQM project. They have purposely selected a strategy
that they believe will gain them the support of local officials (by bringing
in money for 201 projects) and that will be implementable (by selecting only
those water quality problems that they know in advance will be implementable).
The desire is to create a waste management control system, and they are already
planning to expand WQM into solid waste management planning. Any expansion of
the program will come because Federal funds .are available. There are no plans
to seek local sources of funds.
.B. Citizens
^Only one citizen was interviewed.^ This citizen is retired and spends much of
his time studying water issues and serving on committees. He is on his Neigh-
borhood Association, a 201 Citizen Advisory Committee and one of the WQM ad-
visory committees. He had hoped WQM would be more of an action program and
wrote to the Commissioners recommending a ground water study. He was not
successful.
This citizen feels WQM is following the act, but feels it won't make much
difference. First, because the 201 program will .hav.e many problems. He did
not think that any one of the 201s in this area were regional in concept, so
he doubts that they will ever be funded. Second, he feels that EPA effluent
limitations relax the previous standards, particularly for the phosphate in-
dustry. In effect, the area (in his opinion) has failed in the two areas
where they could have exercised the most control; namely municipal and indus-
trial point sources.
The agency scheduled interviews with three advisory committee members.
Two, however, were public employees and, therefore, are discussed under
Section IVD, Appointed Officials.
SF-15.
-------
C. Local Elected Officials
Both local elected officials interviewed are County Commissioners (different
counties) and members of the RPC Board (one is Chairman). In general, they
were much more know]edgeable about and interested in their respective 201
studies.
The first Commissioner feels water quality has a high ranking among community
goals, and that water supply is a major determinant of growth. He had hoped the
WQM study would consider the effect of phosphate on the area's water quality,
but it will not.-*- Other than that, he feels his input has been well received.
The Commissioner felt strongly that all data gathered by the WQM study should
be widely disseminated and he would like to see more frequent and timely re-
ports from the WQM study about their progress. The Commissioner favors having
the existing Water Management Districts becoming the implementing agencies.
He believes funding should come from Federal grants programs.
The second County Commissioner said his biggest goal is to " keep Charlotte
Harbor clean", and he would like to see 2 2,000 acres of the mangrove area
put into a State Wildlife Preserve. Although his county has fairly high water
quality, recent tests show they are on the verge of problems. He hoped the WQM
will result in a comprehensive evaluation of those potential problems so that
preventive actions can be taken.
The Commissioner felt it was tco early to predict how the planning process would
fare in the political setting, but added that he thought they had a good project
and a good staff. Although the Commissioner understood that WQM is a regional
concept, in reality he felt that they have separate studies and that the best
strategy is to recommend the Ccunty for management purposes. He added that if
the existing institutional structure is maintained, implementation would not
be difficult.
D. Appointed Officials
Three appointed officials were interviewed; the Director of Community Planning
for the City of Ft. Meyers, the Engineer for the City of Sanibel, and the
Director of Environmental Protection for Lee County. The WQM agency has chosen
to concentrate its efforts on "agency-type" people in the belief that they will
be responsible for actual implementation of the eventual plan. Each of these
persons, therefore, was familiar with the project through their committee
membership.
The City Director of Community Development felt that the WQM study is important
because they will, for the first time, be looking at their water problems,
particularly those caused by nonpoir.t source problems such as agriculture and
^ This was decided against because CEQ has funded a major study on phosphate
in this area.
SF-1G
-------
dredging operations. The Director believed that local officials do not
understand WQM and are particularly unaware of the cost. He thought some
local officials were afraid that WQM v/ill take away their authority. In
this political context, he thought it was possible that the WQM study would
be "just a plan". In particular, he felt there was a lot of concern that
regional government is "unrepresentative", an image the RPC would have to
fight if it is to succeed. At the time of the interview, the Director re-
ported the committee he served on was "in limbo".
The City Engineer (another city) also found interest dragging in the committee.
He thought some members see the committee as just, "one big rubber stamp".
Because the members are all very busy, and they see no immediate benefit from
the WQM project, attendance has been declining.
The Engineer does not find WQM particularly useful for his area. First, his
city is not in one of the critical areas. Second, their 201 work was fairly
well progressed, which has a goal of eliminating all septic tanks. The En-
gineer felt his city's citizens and local officials are environmentally at-
tuned and would be supportive of the WQM plan.
The third appointed official interviewed is Director of Environmental Pro-
tection for Lee County. They had recently completed a Step I study and had
completed two Step II applications. The Department is particularly interested
in the Caloosahatchee study because the County is dependent on the river for
its water supply. The Director finds the County Commissioners are supportive
of the water programs, although at times they can be unpredictable. He thought
they understand 201 is domestic waste, and WQM is "everything else".
E. State Legislators
No State legislators were interviewed.
F. State Water Quality Personnel
The Chief of the Bureau of Water Quality Management for the Florida Department
of Environmental Regulation, and the WQM Agency Coordinator (hereinafter, State
Liaison) were both interviewed. The Bureau Chief's comments related mostly
to the State program and to their relation with EPA. The Liaison's comments
were specifically directed at the work program.
The Bureau Chief was critical of the WQM program because it meant EPA was
"circumventing" the State authority. At the same time, the State was being
asked to review WQM projects and was not given any money for the necessary
staffing. He did not feel the EPA Headquarters was supportive of the State's
position. The Bureau Chief explained that, because of its regulation respon-
sibilities, the State lias the prime responsibility for making projections,
SF-17
-------
allocations, classifications, etc., although he said the WQM agencies will
be asked to comment on all of these.
According to the State Liaison, the Department has a "strong" attitude
about WQM — they want input ard control to make sure plans can be imple-
mented. It was known in advance that there was not enough money to complete
outputs in all 16 recommended.ereas, so the designated agencies were allowed
to set their own priorities. The State of Florida finds that this increases
the difficulty in controlling the projects.-'- The Liaison added that some of
the difficulty comes directly from EPA --- Is WQM to be nohpoint or point source
management? He feels that sometimes they emphasize drinking water, sometimes
phosphate pollution, now residuals. What, he wondered, will be next?
The State Liaison had a number of concerns about the Southwest Florida revised
work plan. Specifically, he felt there should be better documentation of what
they intend to do. He felt they may be trying to do too much and wanted to
make sure there was no duplication between this and other State programs. The
\Liaison felt that the biggest problem in all the designated areas is a lack of
yater quality experience. He felt that EPA used its money to train managers,
and it was necessary for the State to do much of this training.
The State Liaison expected to see the Water Districts as major management
authorities, possibly by giving them permit authority for nonpoint sources.
He felt the State will probably oversee the management agencies. The Liaison
also expected to see the State pass new lav;s and develop best management prac-
tices as a last resort if they were not done at the local level.
There are 12 designated areas in Florida,
?F-1Q
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
There are two parts to this project. The first is work-related to 201 pro-
jects in the area. The second is the detailed studies of the five critical
areas. There is little reason to doubt that the 201 related work will be
completed well before the two year period has ended. Facilities will be
prioritized and recommendations sent to the State. "Implementation" will
depend on whether funds are available and whether EPA funding criteria are
met. Assisting the cities and counties with their facilities work will
remain an on-going function.
Technical work (i.e. monitoring) in the five critical areas will most likely
be completed on _sichedul^.^_It_is_ less certain whetjher regulatory controls
will be developed. The work plan is not very specific as to what "regulatory
controls" will ^Include, and work is not scheduled to begin until September
1977. This_sch_eduie__ma.y_ leave too little time to realistically obtain finan-
cial support and legal powers or to solve institutional disagreements which
are sure to arise.
.There seemed to be conflicting views about regionalism. At least one county
official and the Project Manager said they are working towards a regional
management system. At least one other county official and a city official said
regionalism was foolish. Previous efforts to pass annexation laws in order
to achieve metropolitan government have not been successful.
There had been little thought about how implementation would be financed, be-
yond a determination that it would not be-local. This raises obvious doubts
about the sincerity to implement. There is even some doubt whether the -RPC,
on its own, could support a staff to oversee implementation of the plan. With
this unclear funding picture, it is possib2e that implementation could be taken
over by either the Florida Department of Environmental Control or by the Water
Management Districts, each of which have both enforcement powers and funding
sources.
B. Public Involvement
The public participation program has two positive features. First, it organ-
izes committees according to river basin. Theoretically, everyone on a com-
mittee is interested in the same issues. Furthermore, none of the committee
members have to travel very far in order to attend a meeting. The second
positive feature of the program is that each county selects three members,
a planner, an engineer and an environmentalist. Thus, the people who even-
tually will be responsible for implementation on a day-to-day basis are in-
volved from the outset.
SF-19
-------
Committees have been in existence since September 1975. They do not, however,
meet on a regular basis, but it is their responsibility to stay informed of
the issues rather than to direct the project. Meetings are called only when
the staff feels they have something to report. Thus, the first round of
meetings was held in the fall to inform people about the project. The next
set of meetings was held arounc March to select work programs and consultants.
No meetings have been held in the meantime, although members are kept informed
through newsletters. Unforbuxiately, many of the members are losing interest,
believing they only serve as a rubber stamp.
Another unfortunate aspect is that the general citizens are never reached.
There is no attempt at getting citizens on committees, distributing the news-
letter, or even writing newspaper artic3.es. The Project Director does not
intend to do any of this, although he has reserved money in the budget for a
full-time Public Participation Coordinator "'in case things get hot in the last
six months" of the project. County Commissioners are contacted because they
are on the Regional Planning Council and because their staffs are on the com-
mittees, but other local elected officials are only contacted if they are in-
volved in the 201 portion of the project.
C. Current Planning Process
The work program is more a consortium of water projects than a comprehensive
areawide study. The five critical areas portion of the study, in particular,
encourages committee members and staff to look at their problems by river basin,
and not for the area as a whole. Although this strategy provided a certain
kind of geographic coverage and permitted a reasonable formula for distributing
the funds when it was known that there were not enough funds to examine all the
area's water quality problems, ~he strategy also may make it difficult for parti-
cipants to take an areawide approach in their management studies and when de-
veloping regulatory controls.
The first phase of planning was "problem selection". This process got a number
of agencies and individuals involved in the project, and it helped narrow
the field of study. However, there was a heavy _weigh.ting.._towards selecting_
problems whose solutions were expected to be "implementable". _ ^gafg f _ this
may assist the agency in gaining some legitimacy, but the more difficult
problems will still have' to be Taced^a±~'some' "lateF date, and there is no
strategy for that.
At the time of the interview, the five critical areas studied were in the early
stages of water quality sampling. The sampling is being done to decide whether
or not there is a water quality problem. Managemer^^anning will not begin
until this determination is made. As stated earlier, _jThas_prpl3ably leaves
too little time to adequately analyze legal, financial and political strategies
for regulatory controls. The agency might do well to consider overlapping the
two tasks, once preliminary data begins to indicate problem sources.
3F-20
-------
Finally, the 201 strategy attempts to get as many counties and cities as
possible involved in the program and in receiving grant money. The incentive
is the availability of large amounts of Federal funds, and the agency hopes
to get the areas involved in the rest of the project as a corollary. There
exists the possibility, however, that this strategy could backfire.
Both the State and EPA are involved in funding decisions. Many of the local
agencies do not understand funding processes (which is why they have not been
involved in the past), and they stand to be further alienated if their ex-
pectations are raised and then not realized.
D. Continuing Planning Process
There has not been much thought about the continuing planning process. As
one citizen said, "The plan will need constant modification, but the committee
is not talking about what to do next." Interviewees had vague notions that
something would continue, but they did not know what continuing planning would
cover, or how it would be financed. In fact, the RPC Executive Director com-
mented at one point that the future personnel picture was very unclear.
Realistically, continuing planning is a very relevant topic. First, it is
highly unlikely that funding commitments for 201 grants will all be made in
the next year. (The question is, who wj 1.1 continue to guide local agencies
through the process after the initial planning period is over?) Second, there
needs to be a strategy to determine whether problems (and controls) examined
in the five critical areas studied have relevancy to other parts of the area,
and if so, how can they be transferred? Third, even within the critical areas,
comprehensive studies are not being made. Some thought must be given to how
other problems will be studied and eventually treated.
E. Significance of Local Elected Officials' Involvement
Local officials have not been particularly involved so far. County Commission-
ers are members of the Regional Planning Council. City and town elected offi-
cials are not involved except through their technical staff members who may
sit on committees.
Local officials appear much more interested in their 201 projects than in the
JWQM study. The implication is that they see domestic waste, point sources as
the major water quality problem. Further, local officials do not appear to
favor regional management systems, ei'thST"for^p^iWt!~o?^noripo"irit source problems.
So far, they do not expect any change in the institutional structures or change
in the status quo for regulatory powers.
SF-21
-------
AGENCY:
SUSSEX COUNTY COUNCIL (SCC)
REGION: III - (Philadelphia)
GRANT AMOUNT: $633,089
GRANT RECEIPT: June 1975
STARTING DATE: February 1, 1976
STATUS AT TIME OP INTERVIEWS: Approved workplan. Two to four months
behind on most tasks. Basically are
at data gathering stage.
REASON FOR INCLUSION IN SAMPLE: This is a coastal area. Also designation
was made to the County Council, which is
a non-COG Agency.
SC-1
-------
I. BACKGROUND1
A. Area Description
The designated area is located in southeastern Delaware and includes the
drainage basins of the Broadkill River, the Indian River, Rehobeth Bay and
Little Assawoman Bay. This is a low-lying coastal area consisting of 120
miles along the Atlantic Ocean. The chief water quality problems are as-
sociated primarily with coastal development but are also attributable to
agriculture, canning and poultry processing.
Major jurisdictions include Rehobeth Beach and Bethany Beach, Georgetown,
and about seven smaller municipalities.
Permanent resident population of the entire area is under 40,000. The
area in general is economically depressed and there is a large number of
migrant farm workers.
During the summer, the population rises to 70,000 and climbs even higher when
day-users are counted, and on weekends when the area is inundated with Washing
tonians escaping the city. The Coastal areas are popular for their good
fishing and shellfishing. The bays have sandy beaches for excellent swimming
pleasure boating, and water skiing.
The coastal area and inland bays have experienced heavy development demands
for mobile home parks built on artificial lagoons, high-rise condominiums
and vacation homes. This pressure appears to be increasing and threatens to
destroy those amenities that attract both tourist and resident. The area's
most serious problem^seems to be an ^inadequate method for dealing with the
. projected population Jlncreases.
B. Water Quality Problem
There have not been a lot of studies on water quality in this area, but coasta
development and agriculture are believed to be the sources of existing surfac
and groundwater pollution. Segments with problems include the Broadkill
Creek whose problems come from point sources (food processing and a municipal
sewage treatment plant which needs upgrading); the Indian River which has
high coliform counts from point sources and high phosphorous and nitrate
concentrations; and the Buntings and Cypress Branches which also have high
coliform counts. Supporting data for these problems have been collected and
analyzed allowing development of a comprehensive program to adequately deal
with projected future problems. The area is dependent on groundwater for
water supply and most of the area is dependent on on-site sewage disposal
which increases the urgency for developing a water quality management plan
as soon as possible.
Information for this Chapter was taken from the SCC Designation Package,
1975; SCC Work Plan, 1975; and interviews.
SC-2
-------
The area contains five storm and sanitary sewer collection systems and
treatment plants (Milton, Georgetown, Millsboro, Selbyville, and Rehobeth
Beach). All except Mi]ton are at secondary treatment or are presently being
upgraded. A sixth, in Lewes, consists of a combined sewer system and a prim-
ary treatment plant. The South Coastal Regional Tertiary Treatment Plant is
completed, but not yet open due to a controversy over where effluent should
go. Three other plants for the area are in design stages.
In the past 35 years, dramatic man-made changes have been made to the bay
areas. Miles of lagoons have been dredged and hundreds of acres of marsh
have been filled. Wooded areas have been denuded for mobile home parks
and marsh bottoms dredged for marinas. The resulting effects on bottom mud
and sands have altered estuary ecology and the population of finfish and
shellfish. On the sandy areas of the coast, barrier beaches and dunes have
been damaged and sometimes destroyed by cottages, marinas, campgrounds and
park uses. As a result, storm tides continually wash across and erode the
land, further aggrevating problems.
Known nonpoint sources include septic tank seepage, landfill leachate,
construction and agriculture sedimentation, and some saltwater intrusion
of coastal aguifers, although little is known about the extent of these
causes. Natural background levels of pollution from wildlife are considered
high in several parts of the area. A 303(e) plan has been developed by the
State Department of Natural Resources and Environmental Control.
The Project Director listed the area's problems in the following order of
priority:
o Rehobeth Bay is polluted by Lewes and Rehobeth municipal sewage
plants, by a man-made canal, by mobile home parks built on creeks,
and by the fact that it is a trapped lagoon with very little
flushing action;
o Little Assawoman Bay is polluted by mobile home development;
o Indian River has infiltration from septic tanks; and
' o Broadkill River has pollution from cattle runoff.
Others interviewed did not have a clear view of areawide water quality prob-
lems and generally described isolated problems near their home.
C. Designated Agency
The Sussex County Council was formed in 1970 by the General Assembly of
Delaware. It was given far-reaching powers including all powers not specifically
SC-3
-------
denied to it by State statutes. In addition, the county was specifically
granted authority for sewer and water system construction and operation, com-
prehensive planning and zoning, and solid waste disposal planning and manage-
ment. The County Council consists of five elected offiicals, and its day to
day operations are seen by a County Administrator.
The WQM grant award was made through the County Engineer's Office. This of-
fice has performed extensive WQM facility planning in the past. After re-
ceipt of the grant, a WQM Program Director and staff were hired who are res-
ponsible to the County Adminstrator and the County Council. Staff consists
of a Director who is a professional engineer, and Environmental Planner,
a Public Participation Coordinator who is a former Mayor, and a Graphic Tech-
nician. They are about to hire a fifth professional. This additional person,
who will be paid by shifting seme consultant time, will be used in an assist-
ance manner to free up time so that the Environmental Planner can spend more
time on an impact assessment of offshore oil development.
jconsultants are conducting nearly half the work program. The University
of Delaware, College of Marine Studies, is doing modeling and waste loadings
of nonpoint sources. The University of Delaware, Department of Urban Affairs
is doing population, economic, employment and land use projections. An engi-
neering consultant has been hired to do a study of industrial problems, and
another consultant has been hired to conduct a survey of alternatives to
effluent disposal. An RFP for a consultant to do management planning was
about to be published.
SC-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
This area doesnot have a working set of regional goals. A county compre-
hensive plan was written by the State and a South Coastal Zone Land Use
Plan was recently approved by the County Council, but these are considered
limited tools. When asked, none of those interviewed (including the two
elected officials) could cite any regional or community goals. Goals des-
cribed seem to be those of particular individuals, and very often this meant
development. A previous moratorium on high rise apartments, for example,
was recently lifted. One citizen feared that WQM would be used destructively
as a tool to stop growth. The growth has brought some conflict between goals
of newcomers and those of the old time residents. In general, the coastal
area is recreation oriented, and there is a mix of views over whether single
family homes, high rise dwellings or parks are preferred land uses. Inland,
concerns shift from recreation to industry but, in both coastal and inland
areas, environmental quality is a much lower priority goal than economics.^
The Project Director noted that helping existing industry and stimulating
new industry are primary local goals. Because the WQM project wishes to mesh
its program with local objectives, focus is being placed on identifying (and
correcting) problems industries are having in meeting water quality standards
and developing "affordable alternatives for industrial pollution."
The work plan describes local goals as efficiency, cost-effectiveness,
equity, local determination of priorities, and compatability with other
programs. With the exception of local determination of priorities,
however, few of these goals were explicitly or implicitly discussed by any
of the interviewers. Efficiency was designed into the program in the form of
program coordination to avoid duplication of efforts. The WQM is coordinating
with the Sussex County Planning and Zoning Office on land use planning, and
with the State CZM program in developing population projections (through a
joint contract with the University of Delaware). One elected official felt
that WQM (which he did not distinguish from PL 92-500 or from EPA) was extremely
inequitable in its requirements for secondary treatment which his community
could not afford. He implied that WQM objectives were not consistent with his
own. The Project Manager tells one of his major obligations was to raise
alternative nonstructural solutions ("cost-effectiveness") and has focused on
encouraging discussions over alternatives to an ocean outlet and also on
promoting consideration as land application.
First priority goals for the WQM program, as identified in the work plan,
include 20-year municipal facility planning; permitting planning; assessment
and control of nonpoint pollution including recreation and tourism, agricul-
ture, septic tanks; and development of a management, program. It should be
noted that detailed identification of WQM program goals is Task 2311 of the
"^The Delaware State Planning Office is currently developing a plan under
the Coastal Zone Management Program (CZM):
SC-5
-------
workplan and identification of regional and local goals is Task 2312. These
are scheduled for completion in Month 2.
B. Technical Component
Task 2.0 of the Work Plan describes all technical water quality planning and
it is dependent, in part, on results of preliminary studies of what are the
major problems. Task 2.0 is divided into "series" and includes three major
sub-plans as final outputs: a point source plan; a nonpoint source plan;
and a residual management plan.
The first series outputs of this task involve program sketch plans; reports
of local and regional goals; reports cf existing resource management pro-
grams; and coordinating mechanisms with local planning agencies, state
agencies, the river basin plan, NPDES Permit system, and 201 planning. This
work is considered preliminary and introductory for the staff.
The second series outputs are baseline inventories relating water resources
and human activity. This work will be conducted by the county and individual
cities. Areas of data collection include: cultural environment, natural en-
vironment, water uses, land use, and groundwater quality.
The third series involves water quality data collection. Outputs include
a hydrodynamic model (of Indian River and Rehobeth Bay), water quality
monitoring data (both point and nonpoint source), and industrial facilities
report, a municipal waste water collection systems report, a private waste
treatment systems report, and a residuals disposal report.
A fourth series outputs include estimations of nonpoint source waste
loadings detailed by Background level and loadings by land use categories,
a report of point source waste loadings, identification of existing service
areas, a report on land use/water quality relationships, delineation of future
service areas, a residuals disposal alternatives report, a future residual
production report and a segment analysis report.
The fifth series formulates alternative subplans for point, nonpoint residuals,
and management elements. This series alsc involves an environmental assessment.
C. Management Planning
Task 3.0 of the work plan provides for establishment of a management program
including facilities planning, regulatory programs, financial management and
institutional arrangements conducted concurrently with Task 2 0 (the Water
Quality Program). Outputs will include a management program < oals and com-
ponents report; existing management and local programs inventory; a report
on management system deficiencies and necessary changes; and i set of manage-
ment alternatives.
SC--6
-------
Management planning has not yet begun, but it will principally involve the
Project Director, Environmental Planner and a consultant (yet unhired). It
is expected that the consultant will be hired in August. The Project Director
listed a series of areas where management plans are needed. These include:
nonpoint source, new sewer districts, sewer collection and regional plants,
industry, land disposal (probably irrigation), dune irrigation, and under-
ground water table. The staff has identified three possible management agencies.
Subject to future investigation, these are: as a wing of the engineer's
office, as part of the planning and zoning office, or as a separate agency.
D. Public Involvement Program
The work plan calls for a public participation program that includes a
committee structure, public awareness campaign, omsbudsman, public work-
shops and public hearings. So far, very little of this has been accomplished
and getting people involved is considered by eVeryone as one of t_he program's
biggest problems. Most people have not heard of WQM and those who have do
not understand what it is. There is very little experience in this area
with public participation in other programs and people do not like to go
to meetings. The elected officials, who are usually unpaid, also do not
understand WQM or why they have been asked to a meeting? There are very
few organized interest groups in the area and none are involved in WQM.
The first committee formed was the Policy Advisory Board. It is made up
of 18 elected officials but has suffered from pQor_attendance .The official
number for a..quorum had to be dropped in order to conduct,.business.. Many
of the officials send alternates. Some of the jurisdictions never attend.
The most active have been the representatives from Lewes and from Bethany
Beach. To further complicate problems, several elected officials were
changed in the spring, making it necessary to educate the new members.
A staff member has been hired to spend his full time on public participation.
He has made approximately eight presentations about the program to local groups.
He is also starting a slide library for public presentations. There has been
some interest on the part of the local newspapers, but the majority of the
effort is on informal "contacts.
Much advice has been offered to the Public Participation Coordinator, but
none of it was considered helpful. He initially spoke to the staff at
New Castle County WQM but did not find their methods transferrable. He
attended the Synergy meeting, but found it too urban oriented. He felt
neither the State nor EPA has been of much assistance.
E. State and Federal Involvement
EPA has a very bad name in this area. The agency is seen as arbitrary, ig-
SC-7
-------
norant of local conditions and insensitive ~o local financial problems. The
WQM agency is trying to overcome some of this feeling by proving that they
can help everyone, starting with industry. By developing a complete data
base on water quality problems, the WOM agency hopes to be able to prove what
should be done and what effect each charge will have.
The Project Director feels they are getting low priority from EPA Region III.
The Regional Office has attended two TAC meetings and has visited about four
other times. The Project Director feels he is considered a nuisance and finds
the Regional Office directors unwilling tc meet on policy issues. He feels
EPA has given the WQM agency a tremendous volume of literature and opportun-
ities to attend the meetings, but he wants more guidance on policy matters.
Again, he is speaking particularly ol his wish to expand the work program to
include a study of land application. Region III, so far, has been unsupportive
of this change.
As with EPA Regional Office, the Project Director feels the State policy
level has been unsupportive, particularly over the land application issue.
In other relations, he has found the assigend coordinator cordial, helpful
and active and feels that mechanics and procedures in general have been smooth
The State Coordinator attends most of the TAC and PAB meetings.
F. Scheduled Outputs
The first phase of the program involves data collection and analysis. Much
of this is being conducted by consultants. Developing a good data base on
.existing problems is considered one of the chief outputs. The focus of the
rest of the work plan will depend in large measure on what is found in this
phase. The staff feels it is essential to get a grasp of the magnitude and
gravity of the problems, including background levels.
A detail of sub-task outputs for both technical water quality and management
planning is described in Chapters 2B and' 2C above. Final outputs will include
o A point source plan,
o A nonpoint source plan, and
o A residuals management plan to deal with municipal and in-
dustrial solid waste and with sludge disposal.
The likely final output will be a series of recommendations for institu-
tional arrangements for nonpoint. sources, septic tanks and industrial pol-
lution.
The work schedule officially began on February 1, 1976. According to the
work plan, data collection and analysis of growth is scheduled for completion
SC-8
-------
in month 4 (June). The third series, data collection and analysis of water
quality, should be partially completed by month 8 (October) and fully com-
pleted by month 14 (April, 1977). The fourth series, growth accommodation
planning, should be completed in month 8. The fifth series, water quality
considerations, should be completed by month 14. The sixth series, plan form-
ulation, should be completed by month 18 and the seventh series, plan review
and approval, is scheduled for months 14-24. The management program is
scheduled to begin in month 2 and be completed by month 11.
G. Achievements to Date
WQM's biggest achievement so far is that it has begun to change attitudes
about what can be accomplished. The County Administrator, for example,
said that originally he was opposed to WQM planning because he saw it as
"a two-year job, with lots of consultant work and pretty little reports".
The vote to accept the grant passed by only 3-2 because of a feeling that
it was a waste of money in an area where sewer lines were already in the
ground. Soon after getting started, however, the WQM staff was instrumental
in convincing EPA not to go ahead with an unpopular Lecato ocean outfall.
The Policy Board was pleased with the way ^QM handled the situation and un-
animously endorsed the staff to continue. The County Administrator now sees
WQM as action-oriented and receiving growing support. He considers:- it an
arm of the County government and has asked them to take on certain other
projects. The WQM Project Director agreed that an increased public interest
is the greatest achievement so far. He felt this was accomplished in spite
of tremendous skepticism about the project and it would help contribute more
good will towards EPA in general.
The staff feels they are out of phase by two months because they were
bogged down in the letting of contracts. Most of the consulting work is
being done in the first phase. Therefore, the population and land use
data base and projections (being compiled by the University of Delaware)
have not been completed and interim outputs have not be submitted.
Also, most of the inventory tasks (cultural environment, natural environment,
groundwater, water resources uses) and the water quality tasks (municipal
treatment, industrial discharges, land uses, water resources) are behind
schedule. This will probably mean less time spent to complete the task or
less time on formulation of alternatives. In the area of nonpoint source
work, not enough work has been done in order to establish the priority
problems, although this is one of the main areas of concern for manangement
planning. There is no specific mention of how anti-degradation will be
handled.
The Project Director feels that one of the chief purposes of the WQM is to
propose alternatives to structural solutions. Early in the project, he was
successful in halting a proposed ocean outfall. He is now trying to change
the workscope to include a study of land based alternatives. In particular,
he would like to examine whether land application is feasible and whether
SC-9
-------
groundwater can take some of the pollution, lightening the burden on sur-
face waters. This idea has met with considerable opposition, particularly
at the state level, in part^because the area depends so heavily on ground-
water for its water supply. The director is also trying to get approval and
additional funding for studying dune irrigation.
A second possible PCP revision would require the addition of a new staff
person (paid for by a shift ir. consultant time) . The purpose for this
shift is to free up some time to conduct an impact assessment of proposed
offshore oil drilling. The state and county have recently changed their
position on offshore drilling and have decided to actively court it. Con-
sistent with his views of WQM as an action agency, the County Administrator
has asked that they conduct the assessment.
The Director explained that land application is supposed to be studied
under the law, but feels that, because it wasn't in the original workplan,
no one wants to talk about it now.
SC-jLO
-------
III. EXPECTATIONS
A. Water Quality
Very few of those interviewed had any opinion on whether water quality
problems would be solved. The staff felt solutions could be achieved,
mostly because a management agency would be established. Most felt that
background levels would make improvement imperceptible, and that the comp-
lexity of nonpoint source problems further complicated meaningful solution.
The County Engineer felt there would be improvement, but that this was due
to actions already underway. There was general agreement that water quality
planning should be integrated with water supply.
Although waters wojald be_improved, no one felt the area would, "meet the_
1983 fishable, swimmable goal. In the Broadkill River area this is due to
high background levels from wildlife. Where the goal will be met, this is
considered due to programs previous to WQM, although WQM is considered to
enhance those actions. For those areas which would be sewered, they expected
to meet the goal, but not necessarily by 1983. The coastal shellfish and
swimming problems were expected to be resolved by 1980. One citizen felt
that the area may get worse before it gets better. Another hesitated to
speculate on results until plans started coming in.
B. Plan Approval and Implementation
Again, most persons interviewed either did not know enough about the program
to answer or were hesitant to answer without having seen the plan. Approval
by the State was considered very likely (8) and by the local communities,
to vary widely (4 or 5). Short sighted local interests, particularly by
farmers, were blamed as the reason why plan approval would not be achieved.
The Planning Policy Board, made up of affected municipalities and county
council members, were considered most essential in achieving approval.
At this point in time, local elected officials do not understand WQM and,
i therefore, cannot be considered committed to it. Consequently, they are not
facing the issue o_f Implementation. It is unlikely that this issue will
be faced this year because it is an election year for County offices. It
is believed that the area is already implementing much of what is needed
for municipal treatment plant control. But the hard issues of nonpoint
source controls will not be faced until 1977. The staff is aware of the
need for elected official involvment and has contracted with the county
and municipalities for some of the data collection work. In general,
however, they have not tried to involve elected officials except through the
PAC. Implementation is generally_seen as_an area of local concern subject
to the avialability of funds.
SC-U
-------
Implementation would depend on how well the PAC is sold on the plan and
this likelihood was generally rated low (around 4). One local elected
official said he would not go along with anything unless he knows the
cost. The other said she would go along with anything recommended by the
County Engineer. In general, the County Council is believed most essential
to implementation. It is beleived that to implement, there must be in-
creased education of industries and agriculture in order to overcome emo-
tionalism.
The Project Director did not know what State laws or County ordinances
would be needed to implement the plan. They are considering hiring the
consultant who conducted legal work for New Castle County WQM and having him
adapt it for Sussex County.
C. Continuing Planning Process
Most of those least involved in the program (citizens, local elected of-
ficials) thought that it might not continue after two years, especially if
there is no follow-up money. No one expected the state would take, it over.
One citizen felt it could only be a Federal program because it was so big
and because local and State governments are too easily subject to pressure
from industry. The two local elected officials seemed to think it should
go back to the County Engineer's office. The County Engineer thought the
project would be smaller but remain in order to maintain and update the plan.
The Project Director saw the agency's role as ensuring implementation of
controls for nonpoint sources, septic tanks, industry and other identified
problems.
The County Adminstrator saw the possiblity of the WQM staff becoming
a County Planning Ager.cy. Although there would be less money, he felt the
staff had developed expertise at no cost to the county ajid he sees the
county playing a more dominant planning role in the future. ¦He felt growth
and land use planning would be less helter-skelter, but that the area
would still be subject to development pressures. He did not estimate what
continuing planning would cost.
D. Relation to Other Water Quality Programs
Most people did not know the expected effect WQM would have on 201 and
NPDES programs. One industrial engineer expected 1977 permits to be
stricter (closer to zero discharge) but did not know what would be WQM's
role in this. The Project Director saw the WQM role in 201 planning to
be an advocate role for non-structural alternatives. The County Engineer,
whose office writes 201 applications, expected WQM to provide population
and other data where service areas are being delineated. He also thought
it possible 1 that they might review preliminary designs. The County Admin-
SC-12
-------
istrator identified an existing conflict between WQM and 201 based on per-
sonalities, but said it was being resolved.
The County Administrator and the Project Director both saw a role for
WQM in the permit program. WQM is expected to provide the data needed to
do permit revisions. One of the first efforts of WQM is to help industry
resolve its permit problems. Towards this end, a consultant is doing an in-
dustry-by-industry contact survey to determine how WQM can help them. This
effort will hopefully result in more widespread support for the WQM project.
E. Local Definition of Success
The Project Director said success for the WQM project would be if they can
get a grasp on the magnitude and seriousness of their problems, so that when
it is necessary to tell someone not to pollute that they can prove that
action will actually clean up the waters. Furthermore, he believed success
requires a plan for all problems and not a piecemeal approach. This regard
for credibility seems necessary since representatives of government, industry
and individual citizens all expressed concerns that they were the only ones
being regulated and it wasn't making any difference. One local elected of-
ficial said there could be no success because WQM is a waste of time and money.
Success, therefore, might in part include overcoming such attitudes.
The County Engineer said there would be success if WQM provided sufficient
data to adequately do 201 planning and if it established a better inter-
agency review process. The County Administrator felt success would be if
the county estabi.lished a planning department that faces all aspects of
life and if pollution is controlled so it stays controlled for a number
o'f years. Finally, one of the citizens said there would be a success if
they provided a way for people to give their input.
Interviewees listed a number of expected benefits from the WQM program.
Cleaner water was considered both a direct benefit and an indirect one.
For example, it was expected that shellfish would return to most areas.
The project director explained that clean water is essential to the econ-
omic health of the county because of its dependence on tourism. Other
indirect benefits included better education on water quality, and free
planning experience for the staff that could later be .used by the County.
SC-13
-------
IV. VARYING PERSPECTIVES Or WQM
A. WQM Staff
According to the staff, the greatest constraints so far have been in getting
consultant contracts approved. This has held up most of the work. They also
"feel they have had little success coordinating with municipalities on pro-
jections. The staff did not specifically feel they had been limited by either
EPA or the state, with the exception of the complaint by the Project Director
that neither were considering his request to study land application altern-
atives .
B. Citizens
Since no meetings of the CAC had been held before the citizen interviews,
none of the citizens interviewed were particularly familiar with WQM pro-
gram. They did, however, have varying degrees of knowledge about water
quality in the area. Invitees zo the first CAC meeting were heavily rep-
resentative of industry and the question period centered around a concern
that all problems would be attacked, that the goals would be set locally,
and that they would be sure of not "over-extending". That is, doing things
that they later might find were not necessary.
The first citizen interviewed was the plant engineer at Townsend, Incorp-
orated, a poultry processing plant, who is responsible for making sure the
plant complies with standards. His plant has two permits, one for temper-
ature and one for waste water. He feels he knows nothing about the WQM
so far, but did attend the organizational CAC meeting. He also feels that
in addition to making sure industry complies, they should look at pollution
coming from mobile home parks, particularly those near streams. He was con-
cerned that small areas such as theirs could not afford the measures being
required, and that WQM would only be a benefit if it provided Federal and
State money for treatment. For the company, he doubted whether WQM would
be of any benefit.
The second citizen interviewed is owner of a water supply company. He
has been involved in a number of community efforts such as schools and
highways and sees them as all interrelated. He attended the first CAC
meeting and is a member of the Policy Advisory Board. Ke feels the PAB mem-
bers all come from a "different scope of things" and they attend meetings
to find out how WQM will affect them. This man's concern was that the State
and EPA are getting outside of their expertise when they come into a local
area. He felt it is essential to take a more local viewpoint, arid he felt
WQM should provide a vehicle for this local input. Alternatives to the ocean
outfall were discussed at the last PAB meeting.
The third citizen interviewed became involved through his activity in a
mobile home community. He is head of a local committee that took over
SC-14
-------
a mobile home park which had been abandoned by the developer. Sewer and
water facilities had not been maintained, only two of nine aerator tanks
worked, and a storage pond was leaking. He is now President of the Community
Association. When a County referendum established a sanitary sewer districtf
he was appointed as a member of the Advisory Committee. He has been at-
tending PAB meetings (ex officio) and feels that his input was received
during the formative meetings. He is particularly concerned that people
must be educated in ways to prevent pollution, and is concerned with the
tremendous growth in the area which simultaneously brings more waste and
more''demand for water. He feels the WQM project was slow in getting started
and the committees were not well instructed in the beginning. He feels they
are now moving and are attempting to make up for lost time. Finally, this
citizen's greatest concern was for implementation. He believed the local
municipalities were too weak and too opposed to anything that will cost
money. He feels that strong federal regulations are necessary to attain
clean water.
C. Local Elected Officials
The local elected officials interviewed kn^w very little about WQM,
'TlTey^iiad attended PAB meetings, but were most concerned ,about their local
interests?" They were not at all committed tb-Tmple~menting"~WQM", particu™"
"larly if it would cost money which they felt they did not have.
The first official interviewed is a Councilwoman in a small resort town.
She has gone to PAB meetings, read the materials, and feels it is a good
idea to have the information. She is particularly concerned with how the
ocean will be affected. In general, however, she feels WQM is a waste of
time and money. She feels that the County Engineer had already developed
plans for the area and that "they should just leave it to him". Bringing
in a consultant from California was considered a particular waste. She
hoped the program would go away in two years and go back to the County
Engineer.
I The second official interviewed was a Mayor of a small town that had been
1 told it must upgrade its treatment plant to the secondary level. He had the
town Treasurer with him, and they both felt that this requirement was tot-
ally unequitable - that .areas with no plant were not being forced to build
one, so in effect, ;they were being punished for having done something a few
years ago. The Mayor lias attended the WQM PAB meetings, but seems only
concerned with what his town has to do and what it will cost. He does not
feel anyone, including the WQM planners, are answering his questions. This
official said his town is constantly being told what to do, and then told to
pay for it themselves, then told a few years later to do more. His town al-
ready has a sewer user charge and a front footage charge. Bonds on the primary
system are not due until 1990 - "Where," he asks, "can he get more money?"
He needs to know a per person cost for any actions. Furthermore, he does not
feel they are polluting the creeks anymore than anybody else. Industry is
SC-15
-------
constantly dumping in, and some towns are totally unsewered. Farmers and
cattle owners are polluting, but he does not see WQM going after them. He
also feels that his town is in limbo regarding whether or not they can (or
should) hook into one of the treatment plants.
D. Appointed Officials
The official interviewed was the County Engineer. His office directed the
initial WQM application and he now attends both TAC and PAC meetings. His
office is also responsibile for 201 application writing and operation of
sewer treatment plants. The County Engineer feels WQM is important to his
work and wishes it had been done several years ago. For example, in plan-
ning the Lecato plant, they needed long range growth projections, but the
data were not aviolable. In the future, he hopes this data will be collected
in an on-going way so that it does not have to be done .on a project-by-pro-
ject basis. He sees WQM's problem in getting the attention of local elected
officials as due to several things:
o WQM is not a tangible thing that produces something now,
o Local areas are protective of their sovereignty, and
o Water quality is not a high priority in this area.
The County Engineer's office has fairly wide authority and it is likely
that they will have some management responsibilities for implementing the
plan. He expects WQM to provide 201 planning guidance and to serve as a
review agency for preliminary design and that the plan will need constant
updates and revisions.
There is currently a difference of opinion between the County Engineer and
the Project Director over suitability of land application. The County En-
gineer feels it is not needed to recharge the groundwater nor, in most years,
is it needed for irrigation.
E. -State Legislators
No State legislators were avialable for interview at the time of the site-
visit.
F. State Water Quality Personnel
No State water quality personnel were available for interview at the time of
the site-visit
SC-16
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
This agency has taken on 5 very ambitious work program. ..and._is_fair.ly-
dependent on consultants in all tasks. The population and economic
data collection tasks were scheduled to_be completed in time, but wer.e_
late~"in getting'~s"'tar^B^ An August completion djitj^has. been^predicted.,
for this data. Several other tasks build on__this__dat.a.,. which, automatic-
ally puts them behind^also. _ This time can be made up during alternative
formulation, assuming that the tasks fall no farther behind. Management
planning, which is not dependent on data collection tasks, is also behind
by about two months and the contract is just being let.
The WQM agency is concentrating some of its early efforts in two areas.
First, they are conducting a survey of industry permitting problems. If this
is completed, and the WQM is able to be of some assistance, they will gain
invaluable support for the WQM program. Because the inland area is part-
icularly concerned about its economy, and EPA regulations are seen as an
irrational threat to industry with very ]ittle clean-up value, it is nec-
essary that WQM serve a difficult balancing function. The second early
effort has been to argue for non-structural effluent disposal alternatives.
This problem is of particular concern to the coastal areas, heavily depen-
dent on recreation and tourism, where a proposed o.cean outfall was to be
located. Again, this approach has won respect and support for the WQM by
local governments. The land application alternative, however, has some
powerful opponents including the EPA Regional office, the State and the
County Engineer. WQM must_be careful notto^be too closely identified with'
any one alternative, or they risk losing much of their support.
1 Despite the growing support for the program, very few citizens and local
|elected officials have ever heard of WQM. Of those who have, it is generally
lnot understood or thought of as a sewer program. This will be an obstacle
|to plan approval and implementation, particularly if implementation is to
take place at the local level. The County seems to be the most involved
level of government. The County Administrator is supportive of WQM and sees
it possibly turning into a County Planning Agency. The County Engineer has
been fully involved in WQM since its inception. This closeness of the WQM
to an operational level is a hopeful sign for implementation at the County
level. A considerable amount of person-to-person contact and involvement
would be necessary to achieve any implementation at the local level.
B. Public Involvement
The public participation program should be stepped up and broadened. Thi.s
i/i.s very difficult because public participation is new to this area, and
SC-17
-------
there are no identified citizen leaders on which to build. 1'n general,
citizens do not understand WQM, water quality issues, planning or their
role in decision-making.
It is clear that WQM is either not known or not understood at all levels.
At the general public level, leaflets or brochures describing the WQM pro-
ject should be distributed and more public presentations should be made.
Also, the staff might spend some time with local newspapers making sure that
reporters understand the meaning and usefulness of the program.
The first meeting of the CAC was held during the period of the interviews.
Of nearly twenty people invited, only five or six attended the meeting. The
program was explained and a Chairman was elected. The tone of questioning
was skeptical and most people seemed to be attending to find out if WQM
would be worthwhile. It will be necessary to hold additional meetings scon
and to make sure there is a meaningful role for the committee or else the
mai.'ginal attention they have now will be lost. The same may hold true to
a lesser extent in the PAB. In order to increase involvement, it probably
will be necessary to seek out key individuals more aggressively, to individ-
ually brief them on the program, and to personally solicit their participa-
tion. It probably will be necessary for the entire staff to do this kind
of one-on-one contact.
At the interest group level, the staff has done a good job of identifying
the aEfected industries. The staff should also identify other groups (such
as conservation and farmers), and invite them to select representatives to
serve on committees. In addition, the WQM Agency must deci.de if it wants
committees to serve any function besides review. So far, the PAB has suf-
fered from poor attendance. This might be because they either do not
understand their role or because there is no meaningful role for them.
Committee members should be notified by telephone and mail to explain
agendas prior to the meetings.
C. Current Planning Process
The agency is at the data gathering stage in the planning process. Except
for having written a workplan (which was done by a consultant) , J:he_jagenqy
has not developed a set of goals and objectives.
In one area of study, they are at the point of alternative formulation. Thi
is about the alternatives to the Lecato ocean outfall. The alternatives,
which were developed by a firm from California, were presented at the last
PAB meeting. There has been considerable reaction to these alternatives,
ranging from total opposition because they were done by an outside firm who
"couldn't possibly understand conditions in Delaware", to advocacy support
for particular alternatives. All other areas of study are at the stage of
SC-1S
-------
data gathering and should be into problem analysis by the end of August.
D. Continuing Planning Process
If WQM Planning continues it probably will be because the county has created
a planning agency. This is possible if, when WQM is comp]eted, it is
considered comprehensive, accurate, equitable and not very costly. Local
governments, .are^,sq__oy_erb.urdened,.__un,convinced that, WQM is,needed, or workable,
and unconcerned about their water quality that^J:he.r^_j.£>^pr.^c.t^^J.y_no)
chance of their agreeing to pay_for continued planning. A tremendous
public relations promotion v:ill be needed to keep WQM.
E. Significance of Local Elected Officials' Involvement
Local elected officials interviewed did not understand WOM's function.
or why it was needed. The County Council members know little more than
its expense, and that it involves consultants. There is little or no
commitment to either implementation or continuing planning.
In order to make any change in this condition, the efforts of all members
of the staff will be needed. So far, efforts to get involvement have
suffered because of turnover in officials. Whereas this is unavoidable,
the staff still must carefully guide the elected officials toward under-
standing their role in implementation. It will also be necessary to elicit
the support of people such as the County Engineer and the County Adminis-
trator.
SC-19
-------
AGENCY: TETON COUNTY 208 PLANNING AGENCY (TCPA)
REGION: VIII - (Denver)
GRANT AMOUNT: .$370,000
GRANT RECEIPT: July 1, 1975
STARTING DATE: July 1, 1975
STATUS AT TIME OF INTERVIEWS: Work plan is approved. Water quality
inventories and constraints analysis
are complete. Water quality monitoring
will continue throughout the study period.
REASON FOR INCLUSION IN SAMPLE: This is a new agency, specially created
to conduct WQM planning. The agency is
in an area with presently high water
quality conditions, but is subject to sub-
stantial tourism-related development pre-
sure. Finally, over 75% of the area is
under Federal management.
TC-1
-------
I. BACKGROUND1
A. Area Description
Teton County, Wyoming is located in the heart of an area of senic grandeur
and high environmental value. Most of the County is located in the
Grand Teton National Park, a mountain range known world-wide for its
dramatic beauty. Two National Forests (Bridger-Teton and Targhee),
the National Fish Hatchery and the National Elk Refuge are located in the
area. Yellowstone National Park is located directly north of the area.
Most of the land in Teton County is publicly owned. Only 75,000 acres,
or 3 percent is privately owned. Eighty-six percent of the private land
is held by 139 large land owners having 100 acres or more. Of the pub-
licly owned lands, 77 percent is U.S. Forest Service land, 16.5 percent
is controlled by the National Park Service, and the remainder comes
under the jurisdiction of the Bureau of Land Management, the Bureau of
Reclamation, the Fish and Wildlife Service and the State of Wyoming.
Grand Teton National Park and the National Forests receive nearly 4
million visitors each year. In the winter, visitors are attracted to
the three ski areas of Tetor. Village, Grand Targhee and Snow King
Mountain. Much of the area's problems, both water-related and other, are
derived fron this tremendous volume of visitors to the area.
The National Park Service recently has prepared a Master Plan for Grand
Teton which would limit the number of public concessionaires and camping
units, which would probably increase the demand on privately owned
facilities. The Park Service also is considering expansion of the park
through purchases of additional lands and possible acquisition of "scenic
casements" and "development rights."
The 1975 population of the area was 7,300. Approximately sixty percent
of the area residents live in the town of Jackson, which is the only in-
corporated municipality in Teton County. Growth (basically in Jackson
County) has occurred at an annual rate of 4.7 percent. By 1990,
the County is expected to grow to approximately 12,900 full time resi-
dents .
Currently, over half of the county's 4,300 jobs are tourism-related and
many are seasonal in nature. Most of the remaining employment relates
Information in this section comes from the TCPA grant application;
memos in WQM files; Teton County Growth and Development Alternatives
and Summary Citizen Report and Questionnaires, 1976; and from inter-
views .
TC-2
-------
to farming and/or cattle ranching. It would be difficult to alter the
area's economy significantly by introducing new industries (for example,
lumber, livestock processing, or oil and gas production), without causing
severe conflicts such as air and water pollution that would affect the
tourism-related economy adversely.
In relation to the WQM study and a related Comprehensive Plan effort,
the County conducted a survey on attitudes toward growth and development.
Results of the survey indicate an overwhelming sentiment in favor of
limiting development of private lands when there are natural hazards;
when the land is unsuitable for septic tanks; or when the terrain or
scenic values are being protected. Large land owners (100 acres or more)
who might be expected to have the greatest influence on County develop-
ment agreed with these sentiments to a lesser degree. Long-term residents
of the area generally followed the majority views but residents of one
unincorporated area, Wilson, strongly favored limitations on development.
In response to water quality-related problems, 24 percent were not aware of any
problems. Others were eventlv divided as to.their awareness of particular
"problems.. Eigfvty-one p"ercent~Cf—the—re-sporrdentrs--s"ai"d—Oiey would "support
enactment and enforcement of water quality regulations even if they
affected their business, ranching operation, or their li'fe style"; only
7 percent said they would not support, such regulation.
B. Water Quality Problem
The main thrust of this WQM planning effort is toward anti-degradation
and identification of potential problems. The County includes nearly
70 square miles of surface water, all of which have been given the highest
quality classification.
The major water body is the Snake River and its tributaries; Pacific
Creek, Buffalo Fork and Cache Creek. The USGS operates seven major
guaging stations and 90 stream monitoring stations. In addition, the
U.S. Forest Service, State Game and Fish Department and State Department
of Environmental Quality operate 17 others. , „ \
There are three known present or potential* water quality problems in the
area. The first relates to the unregulated diversion of Gros Ventre
River for irrigation which has caused some downstream segments to go
completely dry. Late summer water releases from Jackson Lake diminish
the scenic and recreational value of the lake and affect important
trout spawning areas. The second water quality problem is caused by
effluent discharge from the Jackson sewage treatn>3nt plant which has .
resulted in high TDS, BOD, fecal coliform, phosphate and nitrate levels \
in Flat Creek. The source of the problem is due probably to extensive . j
infiltration. Teton Village and Aspen treatment systems have periodic
malfunctions due to abrupt changes in waste loads. The third water
quality problem is well pollution. Although only a few cases arc
known," they are important because of the area's reliance on wells for
its water supply.
TC-3
-------
In addition, there are potential problems from increased urbanization,
road runoff and road construction, as well as from larger amounts of
effluent discharges. Further, there has been some concern about possible
run-off from the Elk Refuge. (This is being studied by the WQM agency,
but so far it does not appear to be a problem).
C. Designated Agency
The TCPA was created specifically to conduct the WQM study. Although
the County has given the WQM agency office space and equipment, the WQM
agency is not a part of the County government. The agency was created
in 1974 v;hen a University of Wyoming survey of community attitudes
toward land use, planning, and regulaticn showed that people felt such
a plan was needed. At about the same time, the State passed its Land
Use Planning law which required a comprehensive plan in each county.
A California consultant subsequently met with representatives of the
County Forest Service, National Park Service and U.S. Fish and Wildlife
Service, and prepared an application for designation. At the same time,
the consultant began work on the County Comprehensive Plan and Imple-
mentation project.
The Comprehensive Plan project started in spring 1975, and is being con-
tinued at a cost of $262,500; of this, S60,000 comes from a grant from
the Nature Conservancy and 599,500 from EPA WQM funds. The first'phase
of work, which included compiling environmental studies, was completed
in December, 1975. The second phase, completed in May, 1976, included
a summary and a full technical report on growth and Development alter-
natives. In conjunction wi~h this phase, a survey was made of all
County households and non-resident property owners. The questionnaire
was accompanied by a lengthy and detailed analysis but, due to the
complexity of the issues and the confusing format of the questionnaire,
a less than desirable response rate was achieved. A second survey will
be conducted covering the Comprehensive Plan and alternative means of
implementation.
The County has enacted Interim Development Regulations which require per-
mits for all new development during the period that the Comprehensive
Plan is being prepared. Th^se regulations mandate positive findings
on 25 factors such as environmental and visual impacts, water supply,
and waste disposal. The County and Town of Jackson recently hired
an Administrator of Planning Services who will prepare reports of his
findings.
There are several other relevant planning studies going on in this area.
These include: a scenic rivers study; and airport study; a transportation
study; a HUD floodplain mapping study; and an EIS for a sewage treatment
plant. Although these are being conducted by a range of Federal, State
and county agencies, they demonstrate the depth of development pressures
the area is currently experiencing and which will continue to dominate
the County's future.
TC-4
-------
II. PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The objectives stated in the original applications were written by the
consultants and representatives of the Forest Service and the National
Park Service. Objectives included:
o Preservation of existing water quality and protection
from possible degradation;
o ' Provision of land and water resources for area residents
and tourists;
o Preservation of the County wildlife resources;
o Provisions for orderly economic growth and development
of the County;
o Providing a means for achieving the Federal 1983
goals;
o Establishment of priorities for the solution of point
and nonpoint pollution problems, with particular
emphasis on non-structural measures; and
o Cooperation with the State in setting waste load
allocations for the Snake River Basin.
B. Technical Component
Several special water quality monitoring programs have been initiated
to improve the available data on nonpoint sources:
o Montana State University has agreed to monitor the
effects of elk and cattle on the quality of Flat
Creek. Sampling and tests will be conducted for a
year, concentrating on the Spring runoff period.
o USGS will be studying the effects of recreation and con-
cessionnaire activity in Grand Teton National Park on
the Snake River.
o The Forest Service will test water over a two year
period for lumbering sites, recreational areas, a dredge
operation on Cottonwood Creek, some controlled burning
areas, and a herbicide spray area.
TC-5
-------
o The Town Engineer and County Sanitarian will conduct
an urban runoff study of Flat Creek near the down-
town area.
o The WQM agency staff is monitoring water in areas
closest to population concentrations.
C. Management Planning
Substantial management planning has not been previously conducted in
the TCPA area due to a lack of preliminary technical planning. Technical
plans were necessary in order to define work tasks and increase general
public awareness. When the results of the second survey and corresponding
public meetings are gathered, (sometime in September or October, 1976)
TCPA will begin to formulate alternatives.
Recently, a joint county/town planning office was formed and it is
possible that this office could serve to oversee implementation of the
plan. Other possibilities are to increase the responsibilities of the
County Engineer or alternatively/additionally, to maintain a technical
person on the County payroll to specialize in managing water quality.
D. Public Involvement Program
Twelve organizations such as civic groups, professional clubs, the League
of Women Voters, environmentalists and cattle and horse associations
were asked to select a representative for the Citizen Advisory Committee.
The Project Director sends written notices followed by phone calls to
these representatives and invites them to attend the monthly meetings.
Attendance has been improving noticeably, although it definitely drops
when notices are not followed up with phone callu.
In addition to the CAC, the general public has been kept informed in several
ways. The Project Director has been on radio and T.V. and several news-
paper articles have appeared. Also, there have been a series of surveys
and public meetings concerning the comprehensive plan, of which water
quality is one element. There has been significant response to an
input from these presentations.
The County Council, Planning Board and Town Council were most directly
involved in the original application stages, most likely because they
perceived WQM as a vehicle for getting more money for the comprehensive
planning program. Most individuals had difficulty in understanding
the significance of the .issues, however, due to their complicated,
technical nature. Also, because of the many other demands on the
officials' time (most are unpaid and have businesses in town), the elected
officials are not as involved as the staff would like.
TC-6
-------
An Agency Board which advises the project consists of two County
Commissioners, two Town Councilmen, two County Planning Commissioners
and a Citizens Representative. The Forest Service, National Park
Service, and Fish and Wildlife Service are non-voting members.
Although they have been__in_volved in many issues, it was necessary
£o reduce the Agency Board quorum from seven to four\'
E. State and Federal Involvement
Several Federal agencies (Forest Service, National Park Service, Soil
Conservation Service, Bureau of Land Management, Bureau of Reclamation,
Corps of Engineers) are members of the Technical Advisory Committee
and, as noted above, also have work task responsibilities. This in-
volvement is essential because so many of the problems originate on
Federally-owned lands.
j The Project Manager feels they have an excellent relationship with
the EPA Regional Office. He feels EPA has been helpful in both admini-
strative and technical matters, (The Regional office even loaned a per-
son to give technical assistance for agriculture work).
The biggest involvement from the State comes from the WQM agency which
hired a State employee for 21 months of the study period. He is coordi-
nating State activites, performing certain monitoring and assisting in
nearly all aspects of the project. This arrangement has been praised
by both the Project Manager and the State agency.
F. Scheduled Outputs
The current work plan was not changed from the original plan prepared
by the consultant and the Forest Service. A full-time Project Director
and staff on loan from the State began in August of 1975. Although
there is some feeling that the staff would have done things a "little
differently," they agree that, by accepting the plan, they saved four
to six months time. It also means, however, that most of the work will
be done by the consultant and the Federal agencies while the
staff plays merely a coordinating and oversight role. The State agency
was worried that these would limit the in-house capability, and the
program would disappear after two years.
The planning consultant received $94,500 of the $370,000 grant. In turn,
they are responsible for tasks in four phases. (A detailed description
that shows the combined work program for the comprehensive plan and
WQM plan is shown in Exhibit 1)
o The first phase, July, 1975 to December, 1975
involved compilation and mapping of environmental
data (water, soil survey, geologic, groundwater,
etc.).
TC-7
-------
¦-"rO>: COUNTY COMPREHENSIVE PLAN AND IMPLEMENTATION PROGRAM: WORK PROGRAM (Including Shared Section 20S Planning Studies)
"uly Aurruct Sept
Oct. Nov. Dec.
10 7 G
January February March April May June July August Sept. Oct.
1077
Nov, Dec. Jnn, I'cb." March April
•vironmkntal studies
"Va'.cr Quality , Wustov/uter Treatment,
Sc'.id M'r.'s'.e Disposal
Soils , Vegetation, Climate
V.'ildlife Management
Outdoor Recreation
Ge olegy
Surface and Groundwater Hydrology,
Flood i^zard
Visual Surveys (U.S.F.S.)
Public P.GVIC
SYNTHESIS . INTERPRETATION,
AND PROJECTIONS
o Synthesis and Interpretation
of Environmental Studies
o Visitation, Employment, Popu-
lation, and Mousing' Needs
Projections
o Critical Issues
i c Grny.-th end Development
Alternatives
— Summary Report and
Questionnaire
— Full Report
? Public Review
THE COMPREHENSIVE PLAN AND
IMPLEMENTATION ALTERNATIVES
o Preliminary Comprehensive Plan
— Land Use
— Housing
— Densities
— Visitor Accommodations
— Recreation
— Traffic Circulation
— Airport
— Open Space Preservation
o Implementation and Financing
Alternatives
o The Proposed Comprehensive Plan
ar.d Implementation Alternatives
— Summary Report and Question-
naire
— Full Report
FINAL REPORT AND IMPLEMENTATION
ORDINANCES AND PROGRAMS
» Comprehensive Plan and Ir.plenc.'-
tfition Program Final Report
o Lurid Use and Development Regulri'
o Capita! Improvement Programs
o Other Implementation Programs
c> Public Hearings
-------
o The second phase identified development constraints im-
posed by water quality factors and was conducted from
January to April, 1976.
o The third phase, to be completed by September, 1976,
involves an analysis of point and nonpoint source
impacts of the comprehensive plan proposals and ex-
amines the technical and regulatory management
alternatives for pollution control. Outputs of this
phase include a report on alternative management solu-
tions to be incorporated in the summary report as well
as a questionnaire on the proposed comprehensive plan
which will be mailed to all households. A second
section will incorporate the responses to the question-
naire .
o The fourth and final phase of work for the planning
consultant calls for an analysis of WQM alternatives
and selection of a final plan. The output will be a
document that will be included in the comprehensive
plan and implementation program.
U.S. Forest Service received $99,000 of the $370,000 grant. This
money is for monitoring point and nonpoint pollution on forest lands:
and will be carried out over the full two year period (July 1975 to
June 1977). Types of pollutant sources will include: six timber sales
(three active, the others for baseline data); three recreation complexes;
two grazing allotments; two burning and two herbicide spraying projects;
and one elk feedground. In addition, testing will be done on waters
draining from a mining operation and an oil drilling site (both of which
pass near a reservior); waters near a construction project; waters
near a naturally occuring landslide; and a town water supply. The
Forest Service will also prepare orthophotoguad maps and will operate
a computer terminal facility for storage and retrieval of accumulated
data.
Other work elements are primarily technical in nature and are described
in the next Chapter. Their outputs are generally data from monitoring.
The engineering consultant will prepare alternatives for wastewater and
and stormwater facilites in developing portions of the County.
G. Achievements to Date
Several things have been learned from the technical monitoring programs.
It now appears that the Elk Refuge is not the major problem it was
once believed to be. Baseline data is available for all major rivers,
some for the first time. Thev have not begun to monitor stormwater run-
off in Jackson because the equipment has not arrived yet. ' ¦
TC-9
-------
Inventory of existing conditions and analysis of constraints have been
fully completed. This work went quickly in order to be ready for
the timetable of the comprehensive plan program. All households have
received environmental information knowr. about the area and have been
given a series of growth alternatives in conjunction with the compre-
hensive plan.
The agency has requested and received an extension for completing its
interim outputs until the comprehensive planning effort is firmly estab-
lished. It is expected, for example, that preliminary population
projections will have to be modified.
The Project Director listed three things he considers as achievements:
o The several agencies involved (Federal, State, County
and town) have been coordinated so that they are all
working together. The staff was involved in bringing
together several agencies charged with responsibility
for settling a dispute over location of the treatment
plant.
o The program is becoming better known to the public.
At.the Decembar meeting there were only 10-15 peo-
ple; only one who was not directly connected to the
program. At the last meeting, there were 35 persons
not connected.
o Baseline data needed for such tasks as making the
decision about regional wastewater facility have
been collected and analyzed.
TC-10
-------
III. EXPECTATIONS
A. V7ater Quality
Water quality problems in this area center around preserving and
maintaining the existing quality of the waters. Most area water
quality is considerably higher than State standards. Two persons
(a citizen and the town administrator) indicated that Fish Creek
may not be able to meet the standard. A second citizen expressed
concerned that, although the area currently has high water quality,
people do not realize how fragile the area climate is. If certain
practices continue (e.g., plowing winter manure into the creek),
several of the creeks such as Fall, Flat and Catch will not meet the
standards.
B. Plan Approval and Implementation
There was general agreement that there is a very good chance the
plan will be approved both locally (most answer 8 or 9 of 10) and
by the State (most said 10 of 10). Most everyone recognized that
approval depends on whether it fits community objectives and the WQM
project seems to be working in that direction.
The Project Director said that the plan wculd be effectvely be im-
plemented (seven out of ten). He felt that the Federal agencies,
county commissioners and town council members would be most essential
and that the Federal agencies, particularly the Forest Service, could
most easily implement their portions of the plan.
One of the citizens said that, to be implemented, the plan must enter
at a "fundable level." A second citizen was more specific. She
said likelihood of implementation was only five of ten because money
is involved. She said this area, more than others, is greatly affected
by national politics. She said that whoever is elected President will
determine what funds are available to aid small communities.
Both the State Liaison and a local official mentioned that new septic
tank restrictions probably will be needed. The State Liaison said
that Soil and Water Conservation Districts have much of the authority
'needed to implement plans, but theirs was often a cumbersome process,
so it probably would not be relied upon. The recently enacted State
Land Use Planning Act assumes that implementation authorities will re-
main local.
One of the citizens noted that being so closely associated with the
comprehensive planning program may jeopardize implementation of the WQM
plan. She said there is an active anti-planning faction in the comrnuni
which intends to make the land use studies backfire and use the data
as arguments against planning. Certain candidates running for local
offices are known to be against the planning, and the. WQM may "go along
with it," (terminating the plan). She is concerned because the plan is
only as good as its enforcement.
TC-11
-------
c.
Continuing Planning Process
The Project Director said that most of the necessary planning would.be
completed within the_in-i^>a'l""two years. He believed management would
stay with the existing controlling agencies (i.e., the Town, County,
and Forest Service). He felt that the Agency Board would stay on in
a coordinating role. He hoped that a technical expert would be retained
to be responsible for inspection and monitoring. He believed this per-
son would cost $25,000 per year and the monitoring costing an additional
$25 - $50,000. He did not believe the County would pay this kind of
money on its own. He felt the State might come up with 25% if they
were convinced it is to their advantage, but the rest of the money would
have to be Federally funded-
Others interviewed gave various statements supporing the description
outlined by the Project Director. The State Liaison said plans would
be updated by the County. A County official felt continuation should
be County funded and operated. He hoped to see a monitoring system,
probably in the County Planner's office. A local official said there
would not be local money. The Town Administrater felt there is no
need for personnel beyond the Planner ar.d Engineer and he saw "no
practical reason to update something as stable as geology."
The State legislator felt continued work should be done by State and
local agencies and not by Federal agencies. He thougt the legislature
might be willing to give money to study nonpoint source problems but
not money to regulate. He noted that last session was not generous
in providing money for enforcement personnel.
D. Relation to Other Water Quality Programs
Because the WQM project is so closely connected with the comprehensive
planning program, they will clearly impact each other. The three citizens
each expressed hopes that the WQM would be a major determinant in decisions
for placement of sewer infrastructure. The Project Director noted that
facility planning is a priority item that dovetails with discussion
over where growth will take place. There is currently a controversy
over the growth consequences of building a new sewer treatment plant
versus expanding the exising one. The WQM staff will be deeply involved
in this issue.
Permitting is almost entirely handled by the State. There are five per-
mits, in the WQM area: the U.S. Fishery; the Jackson treatment plant;
I1 two for subdivisions and one for a ski area. Data from WQM project
monitoring will be made available to the State.
TC-12
-------
E.
Local Definition of Success
Responses to the question, "what is your definition of success?"
ranged from the generalized hope for a better environment to special
desires for elimination of septic tanks in a particular community.
The full responses are listed below:
o Project Director- A good set of implementation re-
gulations, the resolution of the 201 controvercy,
and the hiring of a technical staff person.
o State Liaison- They can't do everything in the "regs",
but what they do should be reflected in the County land
use plan. They should identify the problems on
Federal lands.
o Town Administrator- 100 percent clean water in the entire
county.
o County Commissioner- A complete in-depth analysis of
water quality in the area showing where the problems
are, and giving recommendations for solving them.
o Town Councilman- Helping to improve the sewer system
and passage of some zoning or control ordinances that
do some good.
o Citizen- Enabling the sewage plant to handle the summer
people and setting definite standards (for density, septic
tanks) for unincorporated communities.
o Citizen- Stopping and rectifying point and nonpoint
problems and bringing human problems under control.
o Citizen- Sewering the town of Wilson so it doesn't
affect the water system
In addition to their definitions of success, interviewees talked about
benefits from WQM planning. The County Commissioner hoped it would in-
still better confidence in the political structure by getting the planning
started. One of the citizens thought that it brought needed expertise
to the staff iwhile another citizen hoped it would stabilize growth.
One citizen and the Project Director both saw increased public-awareness
as a benefit of the planning. The Project Director added that he hoped
an improvement in the Forest Service's methods would be a benefit.
TC-13
-------
IV. VARING PERSPECTIVES OF WQM
A. WQM Staff
The Project Manager felt that the project's greatest strengths were
reflected by more x>eople's increased awareness of water quality and that
WQM staff are developing rapport with agencies, elected officials and
the general public, resulting in a spirit of cooperation. He believed
one factor in this rapport is that the two staff members are both living
in the Community rather than serving as outside consultants. • Because
outsiders are viewed with suspicion and disdain by members of this
tight knit community, the WQM staff has had to gain acceptance both as
individuals and as members of a Federally-owned program. The Project
Manager feels it is important that "a technically qualified person
monitors water quality and that he should remain on the County payroll.
The Town Administrator is adamently and somewhat hostiley opposed to
this idea. He thinks there is enough in-huuse expertise to answer any
questions which may arise.
The Project Manager feels the biggest problems so far have been keeping
tabs on everyone. The Forest Service acts automonously and the WQM staff
does not always follow them as closely as they would like. Likewise,
the planning contractor, because of the dual position lie holds, has his
own set of ideas about the way things should be done. For example, at
first, he would not do the agriculture element of the plan and now he
claims the environmental assessment is not part of his contract. The
WQM staff has had to gear its outputs to the timebable of the comprehen-
sive planning program.
The Town Administrator's bicgest compliant is that the entire process
goes to slowly. He feels the WQM plan snould have been done before, so
it is known where density can and cannot occur. He sees WQM as a one
time collection of information of water in the area "that can then be
used by those who must make decisions for the town.
B. Citizens
Three members of the Citizer Advisory Committe were interviewed. Each
appeared very knowledgeable about the WQM project and about citizen
opinions in the community. None felt that their own views were a re-
flection of the typical attitudes. Rather, each believed themselves
to be more in favor of planning and control than might generally be the
case.
TC-14
-------
Many citizen views were presented at a joint County Commission/County
Planning Board Meeting held during the time of the interviews.1 In par-
ticular there is one element totally opposed to any planning. The op-
position sees growth as a threat to their present lifestyles and they
associate planning with promoting growth rather than stopping it or mini-
mizing its impacts.
One of the most threatened groups is the ranchers. Fewer acres are de-
voted to ranching each year and the ranchers fear the comprehensive
plan will result in further regulations that will accelerate the loss.
The first citizen interviewed represents the League of Women Voters on
the CAC. She, like others is most concerned with understanding how measures
to clean the waters will affect development and limit growth. She be-
lieves that something must be done and feels that the County Council is
committed to carrying out both plans. She also feels that most of the
public does not understand the issues and, therefore, will look for the
"cheapest way" to solve water quality problems. (She noted the out-
right opposition from cattlemen,) For these reasons, the representative
felt it would take an "outsider" to get the plan implemented.
The second citizen interviewed represents the cattlemen on the CAC
and represents citizens on the Agency Board. He indicated that citizens
don't understand the project and that there is natural opposition to any
Federal program. This individual believes the WOM agency should concen-
trate on collecting statistical data (not on decision-making) so that
the problems are documented before solutions are tried or before there
are any plans for growth. He feels that, at present, the County's
development and environmental goals are in conflict. But he added that
the decisions should be made by the politicians while the WQM planners
should act merely as researchers.
The third citizen interviewed feared that the WQM project was too closely
tied to the comprehensive planning project and, specifically, to the
issue of density. She felt people were rejecting sewers even in areas
where they are badly needed becauce they will promote additional develop-
ment. She feels this area, like most of the State, is "90 years behind
the rest of th County," adding that this planning should have been done
in the '50's. She looks toward the local and national elections, as
an indicator of what the future will be like. Local elections will show
how much support there will be for further planning and control regulations,
national elections will show how much money is available for expenses
1
The Comprehensive Planning Program holds periodic meetings in the
community to present their findings. This meeting (attended by one
field team member) was a preliminary presentation to the joint boards.
Because it was an open meeting, citizens were allowed to give comments
and ask questions at the end.
TC-15
-------
such as sewer treatment plants.
This citizen felt that, although local officials are not opposed to the
WQM project, support has not been as strong as potentially possible.
She said there is a danger that if WQM is locally administered, it will
be subject to the whims of whoever is'elected and, therefore, subject
to preseures form the anti-planning element. She favors a commission
consisting of the Town, County, State, National Park Service and Forest
Service.
C. Local Elected Officials
The first elected official interviewed is Chairman of the County Com-
mission and Chairman of the WQM Agency Board. He said that the County
became involved in WQM because it complements the comprehensive planning
process and because it was financially advantageous to do both at the
same time. He was pleased that the project is being efficiently ad-
ministered and on schedule. He hoped that one result of the effort
will be establishment of a monitoring system that can be carried on by
the City/County Planner but he does not want the system to be tied to
an extensive financial commitment. Because of its importance as a
national tourism area, the Commissioner feels that the Federal govern-
ment and Federal agencies have special responsibilities.
The second elected official interviewed is a Town Councilman who serves
on the Agency Board. He doubted the project's value and expects that
no one will listen anyway. The Councilman said no EPA or WQM office
can tell them what to do and that the key is self-government.
D. Appointed Officials
An ETS on whether to expand the present sewer treatment plant or to build
a new one has recently been started. Many of the growth implications
are being studied under the comprehensive planning program. The inter-
view with the Town Administrator, who is the ranking appointed official,
is discussed in Section IVA.
E. S^ate Legislators
The State Senator from Laramie, Wyoming was interviewed. He was not
aware of the Teton County WQM Project although he was familiar with the
comprehensive planning effort as established by the State Law.-*- The
Senator felt that environmental issues he]d a high priority with the
legislature and the governor, but they seem more inclined to providing
1
Another interviewee explained that commercially and otherwise, Teton
County is "in Idaho". Laramie is located in the southeast corner of
Wyoming, oyer 300 miles from Jackson.
TC-16
-------
planning money rather than enforcement money. He noted that ranchers
have a particularly difficult problem with water but this has not been
discussed by the legislature.
F. State Water Quality Personnel
The State Liaison is coordinating with the WQM agency to make sure it
is consistent with the State program, but so far he has not been di-
rectly involved except to review the workplan.l The three Wyomining
WQM agencies have met to discuss common issues such as suggesting
best management practices for the Highway Department.
The State has permit responsibility, but this is not much of an issue
in Teton County since all streams are classified effluent limited.
303(e) plans are complete for all areas in the State and the data is
available to the WQM agencies. The Liaison was hoping for guidance
from EPA concerning how the State is expected to combine basin plans
and WQM plans into a statewide Strategy.
The Liaison believed that Teton County has a better chance of "success"
than the others in the State becuase it is so closely tied to the local
government.2
He added that, in the other two areas, WQM will have to be "sold" to
the counties. In those areas, the problems are more widespread. There
is tremendous area development and energy-related pressures and employ
ment is tied to those who must be regulated. For these, he saw no
guarantee that they would exist beyond the first two years, whereas in
Teton County, he felt the County could continue WQM related work.
1
The Liaison is an IPA from Region VIII. He works most closely with
the State person who has been loaned to Teton County for the WQM pro-
ject.
2
The Liaison felt that all funds should have passed through the State
because the counties and cities as well as the State agencies and Con
servation Districts can become involved to a greater degree. This
was not a problem in Teton County, but it was in the other two areas.
TC-17-
-------
V.
A.
ANALYSIS AMD CONCLUSIONS
Likelihood of Plan Completion, Approval and Implementation
There is little reason to doubt that the plan will be completed on time,
iAll of the initial data gathering is already completed and has been
Imailed to households. Management and facility alternatives are tied to
[the comprehensive planning program which js proceeding on schedule.
^Monitoring will continue throughout the next year.
I Plan approval and implementation are unpredictable. County officials
Hthe Commission, Planning Board and Town Administrator) seem genuinely
committed to doing something. As indicated in all the surveys con-
ducted, citizens have shown both an interest in what is happening and
a desire to prevent degradation of the: r environment. The issues, how-
ever, can be very complex-' and citizens are often unable to understand
the consequences of certain alternatives. Within this atmosphere, an
anti-planning group is able to capitalize on people's fears. Several
of the candidates for local office are vocal opponents of the compre-
hensive planning program and, by association, of the WQM project. This
attitude also capitalizes on anti-Federal sentiments which are prevalant
throughout the area.
Thus, the close association between the comprehensive planning and the
WQM planning projects is both a help and a hinderance. It is likely
that the two either will be carried out or defeated together. The
greatest support for implementation will occur at the County level.
Town officials, however, do not understand the purpose and scope of the
project as well as County officials and are totally opposed to the ex-
penditure of funds. County officials expect that planning will be com-
pleted within the two years and that appropriate monitoring can be con-
ducted by the Town Engineer and the City/Council Planner. Of course, all
this pertains only to the privately owned lands. The lands controlled
by the Federal agencies are of even greater consequence, particularly
to the Forest Service. There is no way to predict how much of the plan
they will implement at this time.
B. Public Involvement
There is a very high level of interest in the combined planning programs.
Meetings of the public boards are as crowded as the community meetings.
1
For example, they are considering the possibility of transfer cf de-
velopment rights based on carrying capacity, a highly specialized
planning tool. At the same time, the National Park Service is consi-
dering the purchase of scenic easeinents. What can be accomplished
under these programs is vague and often misunderstood.
TC-J8
-------
Most everyone seems to understand that they are discussing the area's
future outlook, even if they do not understand all the technical issues.
Most individuals - whether it is the lady worried about unsecured Wilson,
or the gentlemen who owns hundreds of acres - perceive a high personal
stake in WQM. All meetings are covered in depth by the newspapers and
reported on T.V. and radio news.
In addition to the multiple rounds of community meetings, all house-
holds received a summary of the technical reports which include a survey
of alternative growth preferences. A number of the most active citizens
were concerned that the first survey may have been too difficult for
most people to understand. They have since formed an ad hoc committee
to assist in preparation of the next survey. There seems to be general
agreement that conducting the survey is the "right way" to go about
things. In addition to the general survey, the planning consultant
completed a confidential survey of the large land owners (100 acres or
more) to discover what plans, if any, were being made for development.
Members of the CAC seemed satisfied with the way their input had been
utilized. The addition of a citizen to the Agency Board seemed to
please those who felt that "the politics must be watched."
C. Current Planning Process
The WQM planning is inextricably linked to the comprehensive planning
program. This means that WQM work tasks and schedules were designed
to meet the needs of the comprehensive plan (with greatest emphasis on
land use). Given the fact that the County is not zoned, the town has
a weak zoning law based on septic tank suitability. It is probably
appropriate that the emphasis is greatest on the comprehensive planning
program, since existing waters are of high quality and since future de-
velopment presents the greatest threat to water quality.
So far, planning has consisted of technical water quality studies
for input into land use planning. Monitoring is progressing which will
lead to a more complete :data base and specific analysis of several
nonpoint source problems.
Currently, very little management planning has taken place, but this
seems appropriate given the kind of opposition that can be anticipated.
Any management alternative can be expected to have serious economic im-
plications and, unless there is sufficient proof that a problem exists,
there will be no support, which may lead to a defeat of the entire plan.
D. Continuing Planning Process
The most likely scenario following the intial two year period will be
a monitoring of known problem sources by either the County Engineer, the
City/County Planner, or both. It is doubtful that a staff solely respon-
sible for water-related issues will continue. Whatever staffing structure
TC-19
-------
exists, it will definitely be scaled down from the present effort and
it will exist as the County, not the Town level.
E. Significance of Local Elected Official's Involvement
There are not a large number of local elected officials. Only one
town (Jackson) is incorporated. Two of three County Commissioners,
two of three town Councilman, and two of five County Planning Commissioners
make up the VJQM Agency Board. Thus, over half the elected officials
have a direct link to the project. Because the comprehensive planning
project has such major implications for the County, virtually every
official is aware of what is happening even if they do not always under-
stand the technical issues. Future area development and planning programs
are issues in the upcoming local elections.
Elected officials will be rost influential in creating a management
system and the Planning would never have been successful without their
involvement. Nevertheless, they have a difficult and sometimes impossible
task in trying to satisfy all the competing interests. Any regulations
or controls will be unpopular with certain elements. County officials
will have to perservere to see the two projects through to completion.
Election of unsupportive officials could destroy any "chances of imple-
mentation.
TC-20
-------
AGENCY: VENTURA REGIONAL COUNTY SANITATION DISTRICT (VRCSD)
REGION: IX - (San Francisco)
GRANT AMOUNT: $928,000'
GRANT RECEIPT: June, 1975
STARTING DATE: June, 1976
STATUS AT TIME OF INTERVIEW: VRCSD had entered its third month of official
WQM planning. For a year prior to that time,
VRCSD had been engaged in work plan development
and helping to establish a framework for
actually conducting planning.
REASON FOR INCLUSION IN SAMPLE: The WQM planning agency is a single purpose,
wastewater treatment planning and management
agency.
VCrl
-------
I. BACKGROUND1
A. Area Description
The Ventura County WQM study encompasses the lower portion of the Santa
Clara River Basin which lies northwest of the Los Angeles metropolitan
area. The designated area coincides with both the County's jurisdictional
boundaries and the Ventura-Oxnard SMSA. It includes both sparsely settled,
highly ercdable mountain areas in and near the Los Padres National Forest
and increasingly urbanized areas in the valleys, the Oxnard plain and along
35 miles of Pacific coastline. A large naval complex and several industrial
centers and oil processing plants are located along the coast but agricultural
activity, particularly citrus and truck farrring, remain a vital part of the
economy. Parts of Ventura County also serve as bedroom communities for
greater Los Angeles.
The 1970 U.S. Census population for the WQM area was 450,000. The area
recently has experienced substantial growth which is anticipated to continue
with increasing pressures from Los Angeles. Population projections for
1990 range from 605,000 to 878,000 according to the State Department of
Finance. In anticipation of further development, two of the area's foremost
goals are to javoid annexation by Los Angeles and to retain Ventura County's
rural atmosphere with green belts separating individual cities. Environmental
c^cern runs^J^gf^airojng the general public and local officials of Ventura
County, because .of„ their familiarity.. with Los Angeles '..air quality,, coastal zone
and water^supplyLgroblems.
The profile of government in the designated area is characterized by a
variety of local. County and State authorities. There are only nine
incorporated cities throughout.Ventura County; eight of_them are in the
low.er^.S.an ara..basin,and, therefqr_e.,__are_ included__in the J/entura County
WQM study area. The majority of land is still unincorporated and exists
under the auspices of the County Board of Supervisors. Both the cities and
\ the unincorporated areas are within the jurisdictional control of special
purpose bodies including the Regional Water Quality Control Board (RWQCB),
the Regional Water Resource Board (RWRB) , the Air Pol 1 ution Control District
(APCD), the Flood'Control District (FCD) anc the Ventura Regional County
Sanitary District Commission (VRCSD) . The RWQC.B was created by the State
/for the purpose of monitoring local water pollution problems and recommending
punitive and/or remedial action where needed. The RWRB is concerned with
regulating and ensuring adequate water supply. _The_APCD and the FCD have
been involved primarily in planning.^activ.ities but do have latent regulatory
powers. The VRCSD is responsible for wastewater treatment and disposal and
has the authority to control the types of wastes entering the systems.
B. Water Quality Problem
The lower Santa Clara River Basin includes the Santa Clara River and its
tributaries, the Ventura River and its tributaries, and the Calleguas-Conejo
Information for this Chapter was taken from the Ventura County Areawide
Waste Treatment Management Planning Work Program, VRCSD, April, 1976;
and various interviews.
VC-2
-------
system of creeks. Although the area's natural geological conditions historically
have contributed to poor water quality, sufficient water for irrigation and
fishing purposes existed before the turn of the century. Intensification of
agriculture, industry and associated urban expansion, however, have led to
further quality degradation and dewatering. Today, surface water problems
include high salinity from irrigation runoff, irrigation.water recycling and
fertilizer applications. Erosion from the coastal hills contribute to the
river and bay siltation. A variety of other problems, including low dissolved
oxygen levels from sewage discharges and other point sources are also common
to the area. Groundwater problems center around saltwater intrusion from over-
draft and insufficient recharge while increasing mineralization can be attributed
to downward percolation of irrigation return flown.
Parts of th^.County^now rely on the Feather River for their water supply but
the area's primary source is marginal quality groundwater. _ Each .year,the
quality of this water suffers as aresult of ever-increasing consumptive
uses^ The absolute necessity of protecting the remaining supply is an obvious
priority. .
The State of California has been aware of water supply problems in southern
California for many years and created Regional Water Resources Board and
Regional Water Quality Boards in response to these situations. The Ventura
County RWRB and RWQB have been involved in several county-wide planning
efforts. In particular, both were responsible for the Santa Clara 303(e)
basin plan which generated water supply, groundwater, wastewater and water
reclamation data now being used in the WQM project.
The Ventura County WQM study also benefits from a number of regional studies ¦
completed by the VRCSD. In the course of developing a masterplan for a
regional system of wastewater treatment and disposal in 1974, the VRCSD
developed information requiring future wastewater treatment needs, current
design deficiencies and cost and construction priorities. The VRCSD
also completed a master plan of water reclamation and reuse in 1974 and a
solid waste plan in 1972. Information from these studies will be useful
particularly in WQM nonpoint source studies. A number of other reports
prepared by State and local agencies have generated data on solid waste
management, transportation, population, land use and air quality.
C. Designated Agency
The_Ventura Regional County Sanitation District is the official WQM planning
agency for the Ventura area. The District was formed six years ago for the
purpose of providing county-wide coordination and management of wastewater
planning, treatment and disposal, and water reclamation activities. The
District boundaries include all of Ventura County and the submerged
land extending three miles from the County's shoreline. Each of the nine
member cities entered the District on a contractual basis and send their
mayors (or representatives) to serve on the Board of Directors. There are
sixteen special sewage districts within the VRCSD.
VC-3
-------
As a wastewater treatment management agency, the VRCSD was a rather unique
applicant for WQM planning. Although the area was designated early in
1975, the program did not begin planning officially until a year later,
partly because of delays in work plan approval but also because of con-
troversy over the nature of the VRCSD.
Generally speaking, VRCSD is respected by local communities for its efficient
handling of wastewater treatment systems. The nation of regionalism is
common to southern California, especially in matters related to water
supply. Some local residents expressed fears that unnecessary regional.ization
would destroy the unique character of individual communities and might
possibly result in extensive urbanization similar to Los Angeles. Regionalism
as represented by VRCSD is, therefore, accepted but only in moderation.
Although the VRCSD is concerned primarily with 201 facilities planning and
management, it is also currently involved in solid waste planning and a
residuals study on agriculture liquid and waste. The WQM project holds
medium priority among VRCSD planning activities which are a]1 related through
the use of common staff and shared technical information.
Only 8 percent of VRCSD1s total WQM|grant is being used in-house to salary
¦ the Project Manager and the Assistant Project
. ,1
€ r
two full-time positions
Manager. The WQM staff is responsible for overall program management,
development of work plan, development of scope of contracts, technical
vrork on sewage systems and sonie public involvement, particularly for conducting
general public meetings. The remaining 92 percent of Ventura's WQM grant
is divided among:
o Ventura County Planning Commission;
o Ventura County Air Pollution Control District;
o Ventura County Association of Governments;
o State Department of Water Resources;
o State Water Quality Control Board;
o Ventura County Flood Control; and
o 8 participating municipalities.
portion of its study because the consulting
V?
The VRCSD chose to contract a 1
agencies already had in-house expertise and/or because they were already in
the process of collecting data needed by the WQM program. Most importantly,
however, VRCSD recognized the need to coordinate its activities with other
agencies which may have an indirect effect on water quality or may play a
role in WQM implementation. For these reasons, the OWR was selected for
modeling cause and effects of groundwater mineralization; the V.'QCB for some
technical work and State policy interpretation on NPDES; the Flood Control
Commission for a saltwater intrusion study; and the eight cities for
VC-4
-------
individual land use and population projections. The most significant
relationship, however, is between the VRCSD and the Ventura County Association
of Governments (VCAG), the Air Pollution Control District (APCD) and the
Local Agency Formation Commission (LAFCO) through the Regional Land Use
Program (RLUP).
RLUP is a cooperative planning effort among the four participating agencies
conducting concurrent county-wide programs. All four programs require similar
methodologies, land use and growth management data, liaison and coordination
functions, project management systems and public involvement processes.
RLUP was designed to increase the effectiveness of each individual program,
achieve coordination among plans and avoid duplication of effort. Under
the orchestration of the County Planning Commission, common data collection
tasks, analysis and committees structures are jointly funded by all four
agenices. Tasks are then delegated to the individual agencies according to
their qualifications and previous experience in related areas. In the.end,
each agency will have its own individual plan. The County Planning Commission
also hopes to coordinate the land use elements into a comprehensive land use
plan which addresses the concerns and constraints of the individual programs,
i.e., water, air, transportation and annexation.
Although the VRCSD is contributing over half of the funds for RLUP, the VRCSD
actually is doing.,_of-JSgSggo^.wgjjji; The County Planning
Commission is responsible for, among other things, identifying the potentials
and constraints for growth and development, and assessing social and economic
impacts of various land use schemes. VCAG is chiefly responsible for
committee management, APCD for coordinating air quality concerns with water
quality concerns, and VRCSD for point source investigation, delineation of
sewage service areas and development of management planning alternatives.
Common analysis and integration of planning elements provide coordination
necessary for a comprehensive areawide perspective.
Overall coordination and communication among the four programs occur through
the RLUP Steering Committee which consists of an elected official from each
of the four participating agency policy boards. The RLUP Steering Committee
is responsible for policy level contact between RLUP and the respective
participating agencies. Similar to the Steering Committee is the RLUP
Staff Advisory Committee consisting of the chief officer of each of the four
RLUP programs. Acting as staff to the Steering Committee, the Staff Advisory
Committee's responsibilities are to coordinate staff services, resolve inter-
agency staff matters, and answer policy-makers' questions. The RLUP program
also has established a Citizens' Advisory Committee which is, basically, an
extension and modification of VCAG's committee structure and a Technical
Advisory Committee consisting of representatives of all participating cities,
agencies, selective special districts and extra-county entities. These
four RLUP committees basically fulfill the WQM committee structure require-
ments.
VC-5
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
The overall goals of the Ventura County WQM Study are to complement county-
wide planning efforts of RLUP, zo enable achievement of 1983 goals of PL 92-500
and to meet the water quality objectives identified in the State 303(e)
basin plan. The goals of the RLUP program¦were established by advisory com-
mittees before the WQM program ioegan and served as guidance for VRCSD in
setting EQM goals. The 1983 water quality goals purposely were left for
local definition and, therefore, only served as broad indicators for the WQM
project. The 303(e) plan, on the other hand, specifically identified a
number of water quality problems in Ventura County, established beneficial
uses, and proposed structural systems to meet 1977 goals. Non-structural
alternatives were touched upon only in the 303(e) plan, thereby leaving mcst
of this work to the WQM program.
The specific objectives of Ventura's WQM project are:
To identify all nonpoint source pollution on a sub-area, and
land use basis, and to test out several land use/population
alternatives;
To test the' ability of existing and proposed treatment
facilities to meet 1983 goals;
To develop detailed financing and implementation arrangements
for the areawide treatment system suggested in the 303(e)
plan;
To detail finances for a brine line proposed in the 303(e) plan;
To devise an impact assessment procedure for structural and
nonstructural alternatives which is consistent with the Air
Quality Management Plan for Ventura County;
To develop local support for WQM plan implementation; and
To develop objectives and controls for storm runoff.
According to the Project Director, VRCSD1s priorities were to develop
an environmentally and economically acceptable program to deal with
agricultural problems and to determine the most efficient type of regional
sewage system to be developed. Although the Director felt the project would
have more than enough work to keep it busy for two years, he recognized the
need to conduct more technical studies, especially in nonpoint source areas.
The Project Director also thought it necessary to conduct more extensive
financial and institutional planning than could or would be handled during
the course of the project.
o
o
o
o
o
o
VC-6
-------
B.
Technical Component
The technical planning component was designed to examine the area's major
water quality problems, the constraints in dealing with these problems and
alternatives to achieve water quality goals. Sampling, modeling and analysis
focus on the saltwater intrusion problem, the causes and effects of ground-
water mineralization, NPDES and municipal as well as industrial point source
problems. While attempting to identify various methods of land use controls
which local governments can utilize to control pollution, the relationship
between land uses and water quality will be determined, as well as conversion
factors developed. Existing and proposed land use plans will then be analyzed
for their projected effect on water quality and their consistency with other
program goals.
The WQM study will consider treatment requirements beyond best practicable
levels where necessary and will develop plans for abatement of separate
industrial discharges. Other considerations include flow and waste reduction
measures, sludge generation and potential growth inducement. Since the
area needed so much sampling, modeling and analysis of nonpoint source problems,
VRCSD limited its point source studies to a reassessment of data collected
previously through the 303(e) study.
C. Management Planning
Management planning was recognized by VRCSD as an essential part of WQM
planning and, therefore, scheduled it to take place concurrently with technical
planning. Management planning was designed to include development of regula-
tory and fiscal controls, institutional arrangements and financial programs
If or an approval and implementable WQM plan. A regulatory program was anticipated
•for local agencies to administer and enforce land use and pollution control
'measures recommended in the technical component of the study. More specifically,
institutional planning aspects outlined include:
o A description of existing legal authorities and suggestions
for additional powers where necessary;
o An evaluation of each technical-management plan in terms of
operational effectiveness, practicability, coordinative
capacity and public acceptability;
o The development of the recommended final institutional plan; and
o The financial arrangements necessary to carry out the plan.
An evaluation of social, economic and environmental impacts of the plan was
anticipated throughout the planning process as .alternative management schemes
are developed and analyzed.
The bulk of management planning will be done by VRCSD but in cooperation with
the RLUP program. Since CRCCD already has a legal foundation for county-wide
wastewater treatment planning, it will concentrate on encouraging non-
participating areas of the County to join the system and focus on improving
VC-7
-------
the current system's financial and management practices. Much of the manage-
ment work related to non-structural solutions, particularly land use controls,
will be handled through RLUP.
A Program Review Board has been established in order to avoid major disagree-
ments and misunderstandings between the WQM plan and policies of concerned
State and Federal agencies. The Program Review Board is composed of policy-
level personnel from the State and Regional Water Resources Control Boards,
the Air Resources Board, the State Ofiice of. Planning and Research and EPA
Regional Office. The Board is responsible for reviewing program outputs
throughout the course of the study.
D. Public Involvement Program
The WQM public involvement process was designed to facilitate continuous
public input throughout the plan's development. The VRCSD chose to rely
on the RLUP Citizens Advisory Committee in addition to its own WQM Citizen
Advisory Committee as the primary vehicles for public involvement. The
RLUP committee basically was an expansion and modification of an existing
VCAQ Transportation Planning Advisory Committee composed of various
geographic and public interest representatives. The Committee was
scheduled to review and evaluate the progress and all output of the RLUP
program including those specifically related to the WQM study. The WQM
Citizens Advisory Committee was similar in function to the RLUP Committee,
however, the focus of its attention specifically was on the WQM study and
concerns. Its membership consisted of representatives from environmental
organizations, civic groups and various economic interests such as agriculture
and industry. At the time of the interviews, the WQM Citizens Advisory
Committee was beginning discussions on overall program goals and objectives.
'With the exception.of public hearings anticipated at the time of final plan
approval, the advisory committee was the only formalized avenue for general
public and interest group involvement in the WQM process. The Project Director
voiced some frustration over the WQM project's low public involvement budget
which did not direct more attention to the general public. He also felt that
dispersing the committee efforts between RLUP and WQM reduced the effective-
ness of the public participation staff's efforts and that the WQM program
needed a coordinator to integrate the two communities.
Local elected officials were to be informed of the WQM program through work-
shops on plan alternatives as they develop and through the RLUP Technical
Advisory Committee. The Executive Director of VRCSD was certain that local
elected officials would be involved sufficiently throughout the WQM program
if for no other reason than because they had contracted VRCSD to participate
in data collection efforts. The Executive Director was relying on frequent
contact on the work task to ensure local officials' awareness of, and input
into, the process.
E. State and Federal Involvement
The Ventura WQM study's staff contact with the State occurred through a
liaison from the California Water Resources Control Board and throuyh the'
VC-8
-------
Program Review Board, 'me wyw agency contracted tne state lor a naison to
overview and monitor the program so as to eliminate conflicts between WQM
and the 303(e) plan and/or State regulations. According to the Project
Director, the State has acted chiefly as a watch-dog to date, making sure that
State policies are not contradicted. The most recently assigned liaison,
however, has also provided technical assistance when requested and has
attended all CAC meetings to answer citizens' questions. Nevertheless, the
Project Director still felt there was room for improvement in intra-State
WQM coordination planning effort, thereby contributing more positively to
the WQM. The Executive Director felt that State involvement through the
Program Review Board would ensure State approval at the time of final plan
approval.
As to the Federal relationship with EPA, the Project Director noted that the
Regional Office Personnel were very helpful during the designation and work
plan preparation stage. However, he did find that EPA's guidance on overall
program policy and direction was vague, thereby causing' some concern in
the Ventura program about the area's compliance with national expectations.
F. Scheduled Outputs
It is anticipated that the major outputs of the plan will be:
1. Land Use (task elements 3, 4, 5, and 7)-
o Tables showing population projections for the
planning period (output of subtasks 3.2C, 3.8, 5.10.1);
o Working maps showing residential, commercial,
industrial, and other land uses (output of subtasks 3.2.B,
3.2.C, 3.8, 5.10.1);
o Working maps showing critical water quality/environmental
aieas (partial output from subtasks 3.2.2, 3.4.2, 3.3,
3.4.3, 4.12, 5.4.1, 5.4.2, 4.4, 4.8, 4.7) (complete
output of subtask 4.9);
o Working maps depicting the type, pattern, amount,
and location of growth (output of subtask 3.1);
o Identification of land use regulatory controls to
meet water quality objectives with and without structural
solutions (output of subtask 7.4.2).
2. Point Sources"1"
o Definition of municipal service areas which consider
topography, drainage, political boundaries, and LAFCO
spheres of influence (output from subtask 5.4.1);
The basis for this point source work has been provided during the 303(e)
planning process. This effort would provide more local input (population
projections, local industrial surveys, local land use) and the additional
detail needed in the 208 planning process.
VC-9
-------
o Residual waste disposal needs (subtask 5.6);
o Inventory of point source dischargers (output from
subtask 5.4.2, 5.5.1);
o Wasteload projections for each service area and
industrial dischargers which include constituents
limited by 1983 goals (output from subtask 5.4.2,
5.5.2, 5.5.3);
o A detailed cost estimate for point source facilities
needed over a 20-year period to meet the 1983 goals and
known wasteload constraints (partial output of subtask
5.6) ;
o Establishment of construction priorities for municipal
treatment works and the time schedule for their
initiation and completion (partial output of subtask
5.6) ;
o Identification of industrial treatment works construction
and schedule of discharges from such works to receiving
waters or to municipal treatment works (partial output
of subtask 5.6);
o Industrial pretreatment requirements and ordinances
(output of subtask 4.5);
o Urban runoff control requirements (subtask 5.14).
3. Nonpoint Source
o Identification of major nonpoint pollution sources
and their impact on water quality (partial output of
subtask 4.3.1, 4.3.2, 4.7);
o Identification of those nonpoint source problems compatible
to solution (partial output of subtask 4.3.1, 4.3.2, 4.7);
o Specification of nonpoint source control mechanisms
(partial output of subtask 5.12.1, 5.12.2, 5.12.3, 5.13).
4. Regulatory-Institutional Recommendations
o Identification of management, agency (s) to carry out
the plan (subtask 7.4.3*;
o Description of management agency(s)1 authorities needed
to carry out the plan (subtask 7.4.2);
VC-10
-------
o Certification that the management agency (s) have
the authority to carry out the plan (subtask 7.4.2);
o Specification of land use controls to carry out
the plan (subtask 7.4.2);
o Existing
o Needed
o Specification of nonpoint source controls to carry
out the plan (subtask 7.4.2);
o Existing
o Needed
o Examples
o Specification of the institutional arrangements
to carry out the plan. For example:
o Description of the relationship between the
management agency(s) and other agencies whose
actions will significantly affect plan implementa-
tion (subtask 7.4.2);
o Identification of the agencies responsible for
(subtask 7.4.2);
o Facilities construction
o Regulatory control
o Wastewater treatment
o Planning
o Monitoring and enforcement
o Interagency mechanisms such as contracts or
joint powers agreements;
o Target abatement dates.
5. Financial Program (subtask 5.17)
Legal authority to finance;
Industrial cost recovery provisions;
User charges provisions;
Provisions that participating communities pay a
proportionate share of treatment costs;
o
o
o
o
VC-11
-------
o Projection of financial means to provide wastewater
treatment works over 20-year period, with detailed
projections for first five years;
o Provisions for funding and continuing planning process.
6. Environmental, social and economic impacts of the recommended
plan (subtask 6) .
Every attempt will be made during the WQK process to include all pertinent
work done during the 303(e) process, and avoid duplication of effort. Current
and proposed 201 planning efforts will be coordinated with the WQM planning
process to assure maximum water pollution control results.
Since the program had been engaged only in official WQM planning for three
months (at the time of interviews),1 it vas too early to evidence any problems
in meeting the program's schedule. The program has had to make one adjust-
ment already, however, in response to the Flood Control District's decision
not to conduct groundwater samplinc and modeling. In order-to compensate for
the time lost in renegotiating these services, the VRCSD reduced some of its
sampling tasks, thereby averting other scheduling problems. The Project Director
predicted, however, that the WQM's overall tight schedule and limited staff
probably would necessitate further reductions in order to complete a final
plan on time. Schedule breakdowns could cause major problems in the end because
of the highly integrated nature of the program's work elements.
G. Achievements to Date
Again, due to the early phase of official WQM planning, the VRCSD had few
achievements to report. The Project Director did feel, however, that
assembling and establishing the RLUP structure was itself a major achieve-
ment which the WQM project helped to realize. In his opinion, the RLUP
program had already heightened local political awareness of the need for
regional approaches to problem solving. The RLUP and WAM committees had
also been organized and were meeting regularly at the time of interviews.
Most of the technical studies v;ere also underway.
VRCSD was designated for WQM planning in 1974. After some EPA disagree-
ment over designating a single purpose, management agency, VRCSD began
WQM planning in 197 5. However, not until a year later when its work plan
was approved, did the agency begin officially.
VC-12
-------
III.
EXPECTATIONS
A. Water Quality
All persons interviewed anticipated an improvement in water quality as a
result of the WQM program. The Project Director looked forward to improved
groundwater resources and a halt to further degradation as a result of
aquifer recharge systems, brine lines and more rational land use controls
proposed through the WQM program. The State Water Quality Liaison added
the possibility of water importation to the Executive Director's list.
All of these measures were expected to contribute to higher quality drinking
supplies without necessitating a reduction in agricultural use. One citizen
felt that improvements were inevitable since the WQM plan would prove to
local officials that these actions were both environmentally necessary and
economically efficient.
The 1983 water quality goals had not been identified yet by Ventura County.
According to the State Water Quality Liaison, EPA Region IX is waiting for
,local definition which it has promised to support and uphold. The VRCSD
Executive Director was confident that the WQM plan would help the area meet
these 1983 goals as they are determined throughout the designated area.
An appointed official, on the other hand, felt that the County would need
more time to achieve reasonable goals. The State Liaison and another local
official felt that, even if all communities support cooperative efforts
toward 1983 goals achievement, financing these activities would most likely
present a problem to local communities and, therefore, impede complete success.
The local official predicted that the high cost of recharge wells in
particular would force the County to ask for a waiver on compliance in order
to prevent bankrupcy of local agricultural interests. One citizen felt that
all water quality goals which related to health issues would be met on time
but that others may go unfulfilled. Only one citizen anticipated complete
improvement and antidegradation of all County water:-.
B. Plan Approval and Implementation
Optimism concerning plan approval at both the local and State levels ran high
among all interviewees. Their positive outlooks stemmed from what they
perceived as an admirable public involvement process which provided effective
ways to resolve differences of opinion. The VRCSD Executive Director felt
that the WQM program had engendered local support because of its reasonable
approach to problem solving and because of the respect VRCSD had earned from
past planning and management efforts. The Project Director felt that the
FLUP Technical Advisory Committee structure was particularly helpful since
it provided a way for program information to filter up from the staff to local
elected officials. lie hoped that keeping local officials informed throughout
the process would facilitate plan approval. He also felt that local communities'
direct involvement in the WQM project through contracts for land use and
population projections was a clear sign of their support.
VC-13
-------
One citizen interpreted local support of the plan in a very different
manner. In her opinion, cities agreed to formulate projections for the
WQM plan because the task had tc be undertaken, even if the WQM program
had not materialized. Rather than finance projections themselves, the
cities chose to avail themselves of WQM funds. The interviewee felt that
the cities would become trapped into accepting the management scheme
proposed by the WQM plan and would probably approve the plan since, from
all recent indications, none were carefully examining its financial rami-
fications .
Interviewees, including the State Liaison, felt that the Ventura WQM program
provided excellent opportunities for State involvement in the local
process, particularly through the Program Review Board. Active interchange
with the State throughout the planning process was interpreted as insurance
for plan approval.
The prospects for plan implementation were more uncertain than those for plan
approval. According to the Project Director, WQM recommendations related
to sewage collection and treatment probably would be implemented because of
substantiating information in tne 303(e) plan and the WQM plan itself.
However, he expected nonpoint source controls to arouse a fair amount of
controversy as rivalries among existing agencies began to surface. Several
persons interviewed, including local officials and citizens, noted that,
if implementation required substantial outlays of local funds, only parts of
the plan would be realized no matter how much support it received at the
time of approval. One citizen suggested that the communities cou]d meet
their financial responsibilities only if local funds could be collected in
a non-obtrusive way. Anti-regionalism sentiments presnet an impediment to
plan implementation. Some special interest groups, particularly farmers
concerned about agricultural trade-offs, feel threatened by areawide
decisions.
VRCSD was most often cited as the group to become the WQM management agency.
The Executive Director explained that the VRCSD probably would assume expanded
regional responsibility for wastewater treatment, planning and management
while the local units of government, the County and most special purpose
districts, would be responsible for non-structural controls. All interviewees
felt that sufficient State and local legal foundations for plan implementation
were already in place. They felt, however, that many statutes were not
consistently operative or enforced.
C. Continuing Planning Process
Most interviewees expected WQM planning to continue beyond the initial two
year time-frame. As one local official stated, "The plan will be most
relevant at the time immediately following its completion". In order to
maintain this relevancy it will need constant updating. The State Liaison
implied that the State would rely on WQM data to update 303(e) plans. Another
local official noted that the County government's support of the plan would
help ensure continued planning efforts without Federal funds.
VC-14
-------
The Project Director's picture of continuing planning implied that this was
considered a vital part of the WQM project from its inception. In his
opinion, continuing planning will be concerned with:
o Political decisions surrounding division of management
and enforcement responsibilities;
o Financial arrangements to pay for planning and management;
and
o Additional work on nonpoint sources.
The Executive Director noted that he had no desire for VRCSD to conduct any
continuing WQM planning beyond 201 related issues. He hoped that VCAG would
do the bu]k of the remaining planning in the future since it was the only
organization which was not a single-purpose agency and, therefore, the best
candidate for a comprehensive perspective. VCAG had not been designated
the WQM planning agency originally because, at that time, VCAG was just
beginning to get local approval and support. Two of the citizens interviewed
assumed VRCSD would be the prime contracting agency and that they would
sub-contract planning work to other agencies.
The Project Director estimated the cost of continuing planning to be between
$25,000 and $50,000. He felt that each of the agencies involved in WQM
management would be responsible for part of the planning responsibilities.
A variety of suggestions for financing continuing planning were expressed.
The Executive Director immediately discounted the possibility of increased
local property taxes or Federal subsidy. Instead, he suggested some kind
of local tax thet would create the least burden on local residents, e.g., a
tax on property exchange, a sewer fee, or a service connection charge. A
local appointed official expressed a similar sentiment, stressing the equity
of taxing those who benefit most from the WQM program. As the program was
just entering its fourth month of planning, none of these suggestions had
been presented to the public.
D. Relation to Water Quality Programs
Clearly, all persons interviewed considered selecting and promoting cost
effective regional approaches to wastewater treatment, one of the most
important functions of WQM planning. This is understandable in view of
national legislation, and the VRCSD's function as a single purpose agency
specifically designed to deal with this issue. It is understandable that all
interviewees felt the WQM plan would be the basis for future 201 planning
and, that through the plan's land use element, the WQM process would
determine future needs.
The WQM plan was viewed similar as a basis for action in the NPDES program.
One local elected official noted that the WQM plan would help give the
NPDES program a perspective that would reach beyond individual communities'
boundaries. The State Liaison felt that this relationship between WQM
VC-15
-------
planning and the NPDES process was somewhat guaranteed since the State's
WRCB which administers the NPDES program was working with VRCSD on the
day-to-day project level.
E. Local Definition of Success
All local definitions of success centered on establishing a cooperative
working relationship among cities and areawide planning agencies, and
enforcing incremental steps toward water quality improvement. Among the
particular responses given by interviewees were the following:
o The State Liaison felt the Ventura WQM program was already a
success since it established a system for communication and
coordination among various environmental groups and areawide
planning programs:
o The Project Director and Executive Director defined success
in terms of convincing all local elected officials to
recognize the area's water quality problems and to use the
plan as a guide when dealing with these problems;
o Ail appointed official defined success in terms of enforcement.
(He did not want to see the plan shelved as a useful but
inappropriate docjment for his men.) A citizen shared the
latter point of view indicating a hope that the WQM conclusions
would be so attractive that local communiti.ws logically would
.tend to follow the plan's recommendations; and
o Two other citizens felt tha~ the WQM would be a success only
if it solves one of the area's water quality problems without
destroying the agriculture industry or introducing degrada-
tion in other areas (e.g., promoting rapid growth in currently
undeveloped areas).
VC-1S
-------
IV.
varying perspectives of wqm
A. WQM Staff
VRCSD's in-house WQM staff was concerned primarily with point source problems
and structural solutions proposed in the 303(e) plan. Such concentration is
clearly understandable given the orientation and expertise of the District,
i.e., wastewater treatment, planning and operation. Coordination with non-
point source and lans use studies through RLUP is an organizational factor
which distinguishes. 2.01 planning from the WQM project. The staff noted that,
for the first time, they were able to take a comprehensive look at the
County's water quality problems and to have an impact on future land use
decisions as they relate to facilities' needs. The Project Director felt that
this approach would be particularly useful in providing economic and environ-
mental justifications for stronger regional approaches to wastewater treatment
problems.
The staff was somewhat worried, however, that limited time and manpower
restrictions, and insufficient coordination with the State and EPA might
lead to problems in final plan completion and approval by the State and EPA.
Some staff members felt that VRCSD had accepted too much work considering the
size and duration of the project; especially in view of the fact that VRCSD
did not intend to be the continuing planning agency. They also were unsure
as to how well the Ventura County WQM program complied with State and Federal
program expectations. They anticipated little time for adjustments in latter
stages of planning due to the tight work schedule.
Generally, the VRCSD staff was pleased with the working relationship established
with RLUP. They were relatively optimistic about RLUP's ulitmate contribu-
tion to water quality if for no other reason than that they expected RLUP to
heighten public's awareness of water quality problems, thus making the public
more sympathetic to VRCSD suggestions.
Whether or not WQM project would result in substantial non-structural changes,
however, was still questioned by these individuals. The outlook on further
regionalization of facilities planning and management was much brighter.
B. Citizens
Two members of the WQM Citizen Advisory Committee and the Chairperson of the
RLUP Citizen Advisory Committee were interviewed during the site visits.
One member was invited to participate in the committee because of his
association with agricultural interests in the County. Others were asked
because of their involvement with environmental groups. All three, inter-
viewees felt that committee effectiveness was somewhat limited during the
early stages of the program because some committee members were not well
attuned to water quality problems and concerns. However, they did feel that
meetings had become more productive over time, and that the proqram staff
generally were receptive to citizen input. One rather strong exception was
VC-17
-------
registered by a VRCSD CAC member who was annoyed that citizens were consulted
on program goals and objectives after they had already been set and in opera-
tion by the VRCSD. She felt that more citizen input would have resulted in
stronger emphasis on non-structural solutions.
Two of the three interviewees noted that local elected officials were not
sufficiently involved in the WQM,process. Although they did not expect
local officials to participate directly ii; advisory meetings due to their
other political duties and responsibilities, citizens felt that the WQM staff
should have made a more concerted effort to keep decision-makers informed of
the program's concerns and developments. Unlike the VRCSD Executive Director,
one interviewee interpreted municipal contracts for population and land use
projections as more a matter of reluctantly accepting the "coopting" of
VRCSD than enthusiastically supporting the WQM effort.
One member of the CAC indicated that their participants primarily represented
environmentalist organizations, with only a few people; taking agriculture
and industry perspective. The interviewee felt that, since the committee
structures were almost the sole- avenue for public education and involvement,
more diversified groups should have been included in the committee roles.
As it stood, environmentalists were already in support of the WQM program
while the general public was almost totally unaware of it.
Despite these program shortcomings, all three interviewees anticipated that
improvements in water quality wc-uld occur as a result of the WQM plan.
They felt that communities were beginning to recognize the connection between
local environmental goals and growth goals, especially since preservation of
agricultural land is such an important issue in Ventura County. Therefore,
they felt the time was ripe for WQM planning.
C. Local Elected Officials
Two elected officials were interviewed. One was involved in county government
and is a member of both the RLUF Steering Committee and the VRCSD Board of
Directors. The other official is a selectman, a member of the RLUP Technical
Advisory Committee and also is cn the VRCSD Board of Directors. Both people
were, therefore, well-informed about both the RLUP and WQM programs. Since
the local communities and the County as a 'whole are concerned with balanced
growth, efficient delivery of services, protection of water supply and
preservation of agricultural land, the interviewees felt that the WQM
program in conjunction with the RLUP program was just what the area needed.
Unlike the interviewees, however, most local elected officials in the County
were not involved sufficiently in either program. According to the interviewees,
this situation might contribute to plan approval problems since decision-
makers might not be aware of the overall tnrust and long-term benefits of the
program. They also felt that the WQM program may be too comprehensive to be
completed within two years; and definitely is too broad to receive quick approval
from all communities potentially effected by it. The fact that elected officials
VC-18
-------
who are aware of the program may leave office before the end of two years was
another problem that the interviewees recognized. Interviewees, however,
felt the WQM staff may have overlooked this fact. Interviewees suggested
that the WQM program spend more time and money reaching the general public and
public interest groups to ensure that the staff will have public lobbying
support when the plan is presented to local officials.
D. Appointed Officials
The appointed official interviewed was serving in a non-salaried County
position and as representative of her organization on the WQM Program Review
Board. The interviewee was pleased with her role in the WQM process. She
felt that it offered an excellent opportunity to ensure that her Board's
concerns were incorporated in the WQM plan. She also felt that the WQM
program had a good chance of being implemented because of the relating compact
nature of the designated area and because of the immediate importance of
water supply issues in Ventura County. Her one complaint was that the general
public was not aware of WQM planning. She felt that this oversight would
lower the likelihood of widespread plan acceptance and enforcement.
E. State Legislators
The State Legislator interviewed was only ±nformed indirectly about the WQM
program through the legislative Committee on Natural Resources. In his
opinion, WQM planning is just another unnecessary drain on tax revenues.
The Assemblyman hinted that work being done under the VJQM could have been
done as easily by existing planning organizations and staff without duplicating
efforts of common elements.
F. State Water Quality Personnel
The State Liaison to Ventura's WQM project was a staff member of the State
Water Quality Control Board. He was quite pleased with the VRCSD's activities
to date and, unlike some persons interviewed, was not distrubed to see that
the program was slightly off schedule since he anticipated corrections for
minor shortcomings during continuing planning. He did not anticipate any
problems with plan approval from the State level since the State has been
working so closely with VRCSD throughout the process. He felt that, if any
problems arise, they will come from local communities themselves.
VC-19
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
Unlike most WQM agencies, the Ventura Regional County Sanitation District
(VRCSD) is a single purpose agency created for wastewater treatment planning
and management. It is, therefore, understandable that the agency's first and
foremost concern was with point source pollution and structural solutions
—its area of expertise. Ventura's WQM plan was not restricted to 201
related issues but was designed to address a wide range of items including
saltwater intrusion, groundwater mineralization, protection of water supply
and preservation of agricultural land.
The Ventura County WQM program was entering its third official month of
planning at the time of the site visit but some indicators of the future could
be seen already in the structure of the program. The bulk of WQM planning
was not being done by VRCSD alone but in conjunction with a consortium of
planning agenices working in the Regional Land Use Program (RLUP). RLUP is
a cooperative planning effort sponsored by four regional planning agencies
(including VRCSD) which are engaged in concurrent county-wide planning efforts.
Its purpose is to conduct common planning elements, particularly land use,
in order to eliminate duplication of effort and to ensure coordination among
the final individual plans of the participants.
What appears to be Ventura's strength, however, may also be its weakness.
Should coordination and cooperation among the participants break down, the
land use component may be produced too late to be of use in the final WQM -
plan, or may be lost altogether. There was no indiciation of any problems
at the time of the site visit, however, whether or not RLUP will be as
effective as it promises remains to be seen.
All of the sampling, modeling and nonpoint source analysis in the WQM program
is being done by the Ventura County Flood Control District and the State
Water Resources Board. The problem of relying heavily on consultants has
already arisen. After agreeing to undertake modeling tasks, the VCFCD
changed its mind, thereby necessitating a renegotiation with the State
WRB. This, in turn, caused a further delay in the schedule.
Given the ambitious WQM work plan, it is very likely that some downward
adjustments in expectations will have to take place as these and other delays
occur. Indeed, the Project Director has already admitted that a truly effective
public involvement program will need more staff and time than originally
was budgeted.
Despite the existing and potential problems, the commitment, of the Executive
Director to the WQM program and, particularly to further regionalization of
wastewater treatment planning and operation, suggests that the VRCSD will
complete a plan at the end of the WQM project. The plan may not include
as much as originally desired, but it will most certainly address 201 issues
delineated in the State's 303(e) plan. Pre-existing data on those issues
and the VRCSD's experience in this field will help make this possible.
VC-20
-------
Given the early phase of the WQM program it is difficult to speculate on
plan approval. Most people agree that local elected officials have not been
involved sufficiently in the WQM process to date. Meanwhile, the concept of
iregionalism is not popular among local communities even though it is an
accepted practice throughout the County. VRCSD has tried to allay locals'
fears by involving local communities directly in the WQM planning process.
From all indications it appears that this type of "coopting" will work
if only because the local communitities will feel they have no choice but
to abide by WQM plans, especially since water supply and preservation of
agricultural land is at stake.
Plan approval by the State and EPA appears far more certain. According to
all parties involved, the Program Review Board has provided adequate
opportunities for input and review throughout the WQM process. Any differences
will have been resolved before the plan is completed.
Speculation on implementation is even more difficult since the WQM plan has
not yet materialized. The management powers of the VRCSD, however, should
work to the program's advantage. The VRCSD is already in place and more
than willing to assume more responsibility. Implementation of non-structural
recommendations is somewhat more uncertain because:
o Some local communities will be hard pressed to raise the
revenue if the plan calls for local expenditures;
/
o The VRCSD does not anticipate, nor does it seem to want,
responsibility for nonpoint source pollution. These
responsibilities will have to be divided among existing or
newly created bodies;
o Rivalries among existing agencies may surface as the division
of responsibilities for non-structural solutions takes place.
Since the political climate appears ripe for approval and implementation of
any plan that proposes to clean up and protect the water, it is very
reasonable to expect that something will actually be implemented.
B. Public Involvement
The Ventura County WQM program has concentrated its public involvement efforts
on reaching public interest groups and representatives from various economic
fields through the formal committee structures of both the RLUP and WQM
program. Representation on these committees was quite diversified and
attendance rather high for several reasons.
o RLUP's Citizen Advisory Committee structure was borrowed from
the Ventura County Association of Governments which meant that
the committee members were familiar with procedures at meetings
as well as with discussions related to regional concerns.
o Reliance upon existing committees meant that the interest of
active citizens was not lost by dilution throughout many groups.
Rather, citizens' interest in regionalization was fortified
by awareness of similar concerns among other planning programs.
VC-21
-------
o The WQM Citizens Advisory Committee had been organized only a
short time before the site visit. Interest was naturally high
at that time but it was too early to determine whether this
would continue.
Despite the apparent merits of committee structures, some problems were
evident in the WQM committee. The most obvious problem was that citizens
were asked to participate in setting program goals and objectives long after
work schedule decisions were made by the WQM staff. Some citizens had taken
their role very seriously and were disturbed when they realized their input
would have little effect on planning. Such untimely requests for input not
only decreased citizens' interest in communities, but also tended to lower
the WOM staff's credibility in the eyes of committee members. Since the
WQM program in Ventura is relying heavily on committees, it should devote
careful attention to ensure their support. The Project Director indicated
that the program has insufficient time and staff to conduct an effective
public involvement program. If such was the case, perhaps the WQM staff
should heed the citizens' advise and eliminate some scheduled work tasks in
order to ensure completion and approval of the most crucial elements of the
program.
In addition to committees, the WQM program was relying on newsletters,
bulletins, press releases, etc., from RL'JP to the general public. Some
public hearings related to the WQM program were held but no comments on
them were made. Some WQM committee members complained that information was
not reaching all members of the public. Obviously, the existing committees
could not be expanded since their broad representation already makes
decision-making somewhat unwieldy. However, greater efforts to keep the
general public informed about the WQM program perhaps should be made in order
to allay local fears of being coerced into something about which they know
little or nothing.
C. Current Planning Process
The Ventura County WQM planning strategy revolves around the use of RLCJP,
the VCFCD and the SWRB to supplement VRCSD's work in 201 related areas.
Working through PJ.UP's cooperative arrangement and with State-established
planning bodies rather thai; building up VRCSD's in-house expertise or rather
than relying on private consultants, was a wise decision by Ventura for several
reasons.
o Addressing nonpoir.t sources, water supply, land use, etc.,
should quell fear that the VRCSD simply is promoting
regionalization to aggrandise itself. Demonstrating that
regional approaches are needed in other aspects of water
planning and management should give more credibility to
VRCSD's position.
o Working with other respected agencies should also contribute
to the final WQM plan's cridibility.
VC-22
-------
o Since VRCSD had no intention or interest in planning or
I management outside of wastewater treatment, it probably
J was wise to invovle other agenices which appeared to be likely
candidates for those duties. This arrangement may contribute
to smooth transition from planning to management.
A few problems may arise with this arrangement. The primary problem
involves information flow both among participating agencies and from
agencies to local communities. As the number of actors increase, the focus
of attention is distorted and the chance that communications will flounder
also increases. As to the substance of the planning efforts, a great deal of
water sampling and modeling was designed into the program. The models may
be calibrated but as one interviewee stated, there might not be enough data
to make the models useful. Again, the scope of the program should have
been trimmed back to address a few problems in-depth rather than a large
scale superfically.
One of VRCSD's primary concerns in the WQM program are management issues,
since the 303(e) plan already identified needs and because the VRCSD already
has planning and management authorities. As mentioned earlier, the Executive
Director's primary goal appears to be the promotion of further local coopera-
tion in the regional wastewater treatment system.
Unlike many WQM agencies, VRCSD has scheduled specific time in its work plan
for the financial planning of continuing WQM activities. Fiscal planning is
scheduled, however, at the end of the process where it is likely to feel
the pressures of earlier delays in work plan elements. Whether or not there
will be sufficient time for fiscal planning remains to be seen.
D. Continuing Planning Process
VRCSD's interest in continuing planning centered on 201 issues which the
agency expected to carry out as part of its legally mandated functions. The
Project Director considered continuing planning in both nonpoint source areas
and land use as equally important. However, since VRCSD had no interest in
conducting such activities, it had given much less time to developing an
overall scheme for continuing planning. The Executive Director hoped that the
Ventura County Association of Governments would use its experience with RLUP
to strengthen its credibility, thereby making it the most likely candidate
for continuing non-structural planning and nonpoint source management. It
appeared that continuing WQM planning generally would involve refining
selected alternatives and continuing technical studies where needed.
E. Significance of Local Elected Officials Involvement
Local elected officials were not invited to join the Citizens Advisory Committees
of WQM or RLUP, however, they were given an active role in determining policy
through the RLUP Steering Committee. The Steering Committee is responsible for
review of all program outputs as they develop. Th.is arrangement should provide
reasonably adequate time to resolve any disagreements before the end of the
planning process; at least for those officials who are involved and arc aware
of the program. Local officials also had access to program information through
RLUP's Technical. Advisory Committee composed of technical staffs of State
agencies, EPA and local communities.
VC-23
-------
The Executive Director was pleased with local communities 1 direct involverrent
in the WQM process through contracts for population and land use projections.
He thought that this participation indicated local willingness to cooperate
with the program. One would tend to agree with the Executive Director if
for no other reason than contracting was a clever way to "coopt" locals into
the process. However, according to some citizens, communities primarily
agreed to participate because they lelt WQM was a good source of revenue
to cover a necessary task with or without EPA support. Therefore, local
official support of the program through contracting arrangements must not
be taken for granted. Now that the WOM program has their attention, it
must work at getting local officials directly interested and more active
in the program.
VC-24
-------
AGENCY: YELLOWSTONE-TONGUE AREAWIDE PLANNING ORGANIZATION (YTAPO)
REGION: VIII - (Denver)
GRANT AMOUNT: $540,000
GRANT RECEIPT: June 4, 1975
STARTING DATE: November 15, 1975
STATUS AT TIME OF INTERVIEWS: YTAPO data collection activities and
facility planning subcontracts are
currently underway.
REASON FOR INCLUSION IN THE SAMPLE:
The semi-rural area is susceptible
to rapid growth induced by energy
extraction and conversion projects.
YT-1
-------
1
I. BACKGROUND
A. ¦ Area Description
The Yellowstone-Tongue area covers a vast, semi-rural section of
Southeastern Montana. It stretches for 18,300 square miles across
six counties (Custer, Powder River, Carter, Fallon, Rosebud and
Treasure) and the Northern Cheyenne Reservation, comprised of
portions of Rosebud and Big Horn counties. Over 75 percent of the
area is grazing land with irrigated and dry land farming increasing.
Although the largest designated WQM planning area, the population
served by the YTAPO numbers only about 30,000. Sixty-eight percent
of the area's towns have fewer than 100 residents.
Trends in the area population have been changing in recent years.
Previously showing a 5.3 percent decrease in population between
1960 and 1970, energy development has caused a significant
population increases. One town was noted to have grown 1400
percent since 1970. Future population estimates relate directly
to existing and proposed coal gasification, mine-mouth power
plant, oil field and uranium mining projects. However, the
Director of the Yellowstone-Tongue Areawide Planning Organization
(YTAPO), which serves the area as the WQM planning agency, noted that
the timing and extent of future energy-related activity remains
-uncertain. He indicated that, although the area received WQM
designation in anticipation of immediate energy development, it
now appears that impacts may not be realized until 1990.
Accordingly, this uncertainty complicates WQM designation and
planning for secondary impacts as it has thwarted YTAPO1s attempts
to project future population. The YTAPO Director also commented
that the Northern Cheyenne Reservation was seeking designation
as a Class I Air Quality Region which would inhibit mine-mouth
operations and affect development potential.
B. Water Quality Problem
The three rivers comprising the major focus of the WQM effort are
the Tongue, Powder and Yellowstone. The Tongue River has reasonably
good quality. The YTAPO Director noted that area adjacent to the
Tongue River will be a site of extensive road and soil construction
1
Information in this Chapter was taken from the Region VIII Review o
Yellowstone-Tongue 208 Designation, the Final Work Plan (November,
1975), the Semi-Annual Report (May, 1976) and interviews.
YT-2
-------
related to energy development. The Powder River has poor quality
water due to natural and man-made sedimentation. According to the
YTAPO Director, the "man-aggravated" contribution is difficult to
define as it is relative to some reference point. The Yellowstone
and Powder Rivers both have high saline content which are of area
concern particularly because of the potential long-term impacts of
oversalting soils and the impact of irrigation return flows on
the Rivers. The Yellowstone River also shows sizable sediment
loads, although less than the Powder River, and some minor impact
of substandard municipal facilities. As existing water quality is
fairly good, the YTAPO staff as well as other interviewees were
concerned primarily with preserving water quality and somewhat re-
cognized the need to plan in advance of energy development.
Consequently, most foresaw the need to upgrade municipal facilities
in preparation for future population influxes. Most non-staff
interviewees did not believe nonpoint sources to be a significant
problem, although a county official expressed concern that mining
activities may contaminate groundwater supplies. Although one effect
of future power plant cooling or coal gasification projects is
dewatering, the YTAPO Director believed dewatering the Powder River
may be beneficial insofar as it.s poor quality impacts on the
Yellowstone River would be reduced.
C. Designated Agency
The Yellowstone-Tongue Areawide Planning Organization was formed
for the sole purpose of undertaking WQM planning. The State Water
Quality Bureau initiated the development of the areawide effort
and, in concert with local officials, applied for WQM funding.
Subsequent to funding, local officials selected the YTAPO Director.
He is assisted by an urban Planner in charge of public participation
and portions of the sampling program,, and a temporary full-time
Groundwater Analyst. The State provided a Water Quality Specialist
who has technical responsibilities in surface water sampling and
coordinating the YTAPO project with the State.
The YTAPO project boundaries intentionally align with the sub-state
areas defined by the State Department of Community Affairs. The
YTAPO Director commented that these boundaries were not logical for
the WQM effort as they exclude a considerable portion of the coal
fields which is the site of two of the larger operations.
The YTAPO area boundaries are also coterminous with the Air Quality
Maintenance Region, currently a Class II'Region. However, the
YT-3
-------
YTAPO Director noted that, within the region, the Northern Cheyenne
Reservation was seeking Class I designation which, if achieved,
would have some inhibitive impacts on energy development.
For assistance in conpleting plan components, YTAPO has awarded
a number of subcontracts which total 75 percent of their allocated
WQM funds. Four sewage system plans are being conducted by various
private consultants. Groundwater quality interpretation is the
subcontracted responsibility of another private firm. Various
public agencies are also committed by contract to providing planning
assistance. The Montana Testing Laboratory is analyzing nonpoint
source data collected by the Conservation Districts. Mapping
activities include the Conservation District and the EPA-EPIC.
Groundwater data will be completed by the Montana Bureau of Mines and
Geology. Finally, the Montana Water Quality Bureau is receiving
$40,000 for water quality assistance, which includes the full-time
services of the Water Qiiality Specialist loaned to YTAPO by the
State.
The Northern Cheyenne Tribal Council received $50,000 for developing
the WQM sub-plan for the Reservation. Although the Tribal research
staff will proceed fairly autonamously with plan development and
implementation will be directed by -he Tribal Council, the Northern
Cheyenne WQM plan is being coordinated with YTAPO's efforts and will
be included in the overall plan.
YT-4
-------
II.
PLANNING STRATEGY AND RESULTS TO DATE
A. Agency Objectives
Because YTAPO determined that a formalized planning process was
politically unacceptable to the area, the YTAPO WQM project was
designed to respond to local interests. Accordingly, the YTAPO
Director indicated that developing a data base was the WQM project
priority. He and other interviewees emphasized the data base
as providing support to future local planning efforts preparatory
to the secondary impacts of energy development. For example, a
data base, including land use mapping and land capability analysis,
available to counties as well as developers might assist siting
decisions either in an informal advisory capacity or perhaps more
formally through performance standard techniques. In addition to
developing a data base and land use mapping, YTAPO is also
emphasizing municipal facilities planning in light of local needs
for upgrading facilities and expanding their capacity to meet
future growth demands. Further, the YTAPO Director noted that
the YTAPO staff responds to short-term problems, e.g., well
disinfection assistance, so that people associate YTAPO action
with the overall WQM planning effort.
Overall, the YTAPO Director noted that their efforts were constrained
by several aspects of the WQM program. First, he believed greater
program flexibility was necessary to attend to the more critical
areawide issues of water supply and quantity of stormwater drainage.
Second, he believed an overall watershed management approach was
preferable to limited areawide water quality management. Third,
he noted that belatedly issued EPA guidelines commonly followed
critical decisions.
B. Technical Components
According to the YTAPO Director, technical planning emphasizes
the development of a data base and basic mechanisms for adapting
technical analytic tools to future local uses. " Existing surface
water quality is being supplemented by sampling efforts of the USGS
and YTAPO in cooperation with the State of Montana. Groundwater
quality data is being compiled by the Montana Bureau of Mines and
Geology while YTAPO conducts checks of well log data and samples
approximately 200 additional wells. The nonpoint source consultant
has been active since April, 1976 in establishing an irrigation
return flow sampling program and coordination with the Conservation
Districts. The land use mapping phase of the nonpoint program
YT- 5
-------
is a major interest of the area, as heretofore, no basic land use
inventories have been compiled. The land use maps as well as the
groundwater data base will be available in both a computerized form
and a lay interpretation.
;As discussed in Section I A, YTAPO efforts to project future popu-
lation are frustrated by the uncertain timing and extent of potential
energy development. To plan in the face of uncertainty, YTAPO
has assumed no major charge in Federal energy policy and the
YTAPO Director observed that a change in Federal policy would be
detrimental to their WQM planning efforts. He a]so noted that
the uncertainty surrounding future population rendered municipal
facilities planning efforts somewhat tenuous.
Under YTAPO WQM-funded subcontracts, wastewater treatment facility
plans, equivalent to Step I of the construction grants program,
are underway in five comir.unities. Completion of one of the facility
plans was expected June 20, 1976.
Under subcontract to the YTAPO, the Northern Cheyenne Research
Project staff is conducting an analysis of the Reservation's water-
quality problems. The Water Management Coordinator of the Northern
Cheyenne Research Project indicated that the information collected
would provide a basis for determining the compatability of future
coal mining activities and related development with Tribal objectives.
The Research staff is examining the water quality problems caused
by sediment, irrigation return flow, septic tanks and sewage lagoons.
C. Management Planning
The YTAPO Director indicated that management planning began early
in an informal manner with YTAPO staff taking a "seat of the pants"
approach to assessing likely management agencies and mechanisms. On
YTAPO's draft interim report, alternative implementing agencies,
their authority, staff and funding resources were postulated.
YTAPO staff assessment of management agencies has input to the
technical alternatives developed along with a legal capability
analysis. Under subcontract to YTAPO, a Montana attorney is
reviewing relevant legislation and existing authority for implementing
WQM plan recommendations.
D. Public Involvement Program
The most structured aspect of the YTAPO public involvement program
is the manner in which agency representatives and local elected
officials are involved in the WQM planning project. Initially,
local elected officials responded to the State Water Quality
YT-6
-------
Bureau's initiative to form an areawide WQM planning body. Coming
together as the YTAPO Board of Directors were the elected county and
municipal officials, with the exception of two towns which chose
.not to participate. A Technical Advisory Committee of 30 members
¦includes 13 elected officials with the remainder of representatives
from public agencies.
To date, the YTAPO staff believed the ranching season and the great
travelling distances involved in attending meetings inhibited the
involvement of officials. Two County Planners noted that the
technical information was difficult for officials to absorb and,
further, they believed officials did not fully understand the
potential value of the information generated by the WQM project.
Other YTAPO efforts to reach the public include news releases, a
newsletter, and conducting irrigation water sample analyses at
county fairs. In addition, YTAPO has held three informational
meetings regarding nonpoint sources and has visited various
organizational meetings to present the WQM program and its objectives.
YTAPO staff tentatively plans to develop a slide presentation,
conduct surveys and develop a citizens advisory group.
Although the YTAPO staff believed that people were beginning to
recognize YTAPO as a resource for short-term problem-solving,
'they felt that people were not particularly aware of the rami-
fications of future energy development, e.g., potential incompata-
bility of strip mining and agricultural activities. The YTAPO
Director noted that reaching the public would be attempted but
he was not sure it was practical considering the limitations of
YTAPO resources.
E. State and Federal Involvement
The YTAPO Director commented on the assistance provided by the EPA
Regional Office. Contact is maintained somewhat consistently by
telephone and mail, and EPA Regional Office staff have visited
the YTAPO area twice since its inception. The YTAPO Director felt
guidance from the EPA Regional Office was "fairly good" but also
noted that the EPA Regional Offd ce staff "did not seem to know
what they want", (e.g., procedural details).
The YTAPO Director noted that lie appreciated the limited EPA
guidelines but also added that most EPA guidelines had been
received after contracts had already been signed. The YTAPO
Director was also concerned that dupJication of efforts would
occur because the timing of the various studies would preclude
coordination. He also desired more and better indexed information
from EPA's energy offices and suggested EPA use library techniques
or microfiche documents to reduce storage and mailing.
YT-7
-------
Two State Water Quality Eureau staff members outlined the State's
involvement in designated WQM planning areas. Initially, State
involvement was considerable as Water Quality Bureau staff wrote
all of the work plans for the designated areas. Following funding,
YTAPO proceeded fairly autonomously, with the State only moderately
involved through contract approvals, occasional meetings among the
areawide projects, and general technical assistance. A large
portion of the State's $40,000 contract for coordinative services
and technical assistance was allocated to providing a full-time
engineer to YTAPO. Coordination of State WQM planning efforts
which are just beginning, and the YTAPO and other designated WQM
plan, is of greatest concern to State Water Quality Board staff
members. They indicated that the Board has not had sufficient re-
sources to enable adequate, ongoing coordination, and believed
more State involvement was desirable. However, in light of the
limited resources, the State Water Quality Board staff members
noted that the State was more active in other designated WQM projects
having greater difficulties. They believed the YTAPO project was
proceeding relatively well and required less State attention.
F. Scheduled Outputs
YTAPO expects to produce five to seven facility plans and various
interim reports, land use mapping and groundwater data base
collections in computerized form, and a final plan which includes
the Northern Cheyenne Reservation Sub-plan. Although YTAPO has
experienced seme delays in regard tc land use mapping and nonpoint
source project phases, the YTAPO Director expects plan completion
within the time allotted. He believed interim reports provided
useful information for areawide distribution.
G. Achievements to Date
YTAPO has already achieved a number of results in keeping with
YTAPO's intent to focus on short-term problems of immediate concern
to its constituents. Facility planning efforts are well underway
with one community's plan completed in July, 1976.
o YTAPO's analysis of a community's water supply
has expanded upon the previous limited assessment.
o The YTAPO staff has responded to specific requests
for well disinfection measures.
o YTAPO has conducted limited analysis of saline and
sodium content of irrigation water at county fairs
and distributed information regarding impacts of
sprinkler irrigation systems.
o As part of its interim report, YTAPO has proffered
a set of tentative recommendations relative to im-
plementing "a practical water quality management
plan" with the purpose of soliciting comments on
their desirability.
YT-8
-------
III. EXPECTATIONS
A. Water Quality
Most interviewees did not expect significant improvement in water quality.
Rather, they believed that further degradation of water quality would
be prevented. The YTAPO Director expected some minor improvement, but
noted natural pollutants precluded achieving 1983 swimmable goals. He
also expressed greater concern for irrigation use of the highly saline
streams than for achieving recreational uses. A facility operator be-
lieved upgrading municipal facilities would contribute to water quality
improvement. Two State Water Quality Bureau officials emphasized non-
degradation and better information available for decision-making as
.their expectations for water quality impacts and noted that, to date,
the State has not enforced its nondegradation policy. They also believed
1983 goals could not be reached due to sediment loads but that streams
¦would be "suitable for present beneficial uses".
B. Plan Approval and Implementation
At this stage of the planning process, several interviewees expected
the plan to be approved. Their expectations for plan acceptability
were couched in terms of anticipating the plan's role as only advisory,
to local actions, and that the plan would recommend a locally controlled
management arrangement. The State Water Quality Board staff members
expected State approval of the plan provided that ongoing coordination
of State and designated area planning assess the compatibility of the
two processes.
The outlook for plan implementation according to most interviewees
depended on local action in response to plan recommendations. Most
believed that the plan should be only a suggestive guideline or informa-
tion base and that a stronger plan would be locally opposed, particularly
in light of prevalent attitudes hostile to "too much goveriiment", and
overall planning and land use controls - all of which are perceived to
threaten locally independent action.
Accordingly, the YTAPO Director believed implementation would occur through
existing local units of government with technical assistance provided by
a locally supported and controlled "Technical Support Project". As
stated in YTAPO1s Tentative Recommendations, the Technical Support Project
would be formed by counties in the energy impacted area and would provide
environmental, engineering and related assistance to local units of
government.
YT-9
-------
YTAPO's Tentative Recommendations for plan implementation include 24
items. In addition,to the Technical Support Project, YTAPO has pro-
posed specific WQM action in the below listed areas.
o Establish a high quality data base for the entire
energy development area which is accessible to
all private and governmental agencies.
o Require industry and mines to provide adequate mobile
home sites for construction workers.
o Develop a service center to serve the coal development
projects, (i.e., "new towns", including appropriate
facilities and bus access to sites).
o Modify enabling legislation for county zoning to allow
uniform county control over buildings and roads accessory
to the mines.
o . Enforce existing county wastewater regulations and
State household waste disposal guidelines for flexible
incorporation into cour.ty regulations.
o Tie petroleum and uranium mining techniques to deep
well wastewater "injection permitting system.
o Expand the role of the Soil Conservation Service to
include monitoring and assistance to local governments
and private developers.
o Investigate irrigation projects in terms of poor
water quality impacts on soil productivity prior to
investment.
o Streamline and coordinate State and local water quality
monitoring systems, including municipal self-monitoring
procedures.
o Classify rivers and streams to reflect saline and sediment
limitations on consumptive and irrigation uses and
restrict further saline discharges.
In the case of the Yellowstone and Tongue River and reservior sites, strict
effluent restrictions would be designed to assure nondegradation.
The YTAPO Director expressed concern that implementation may be affected
by the lag in energy development. With a lack of development pressure;
YTt10
-------
he believed area awareness and support of the WQM planning effort may
wane, such that ongoing activities preparatory to secondary impact plan-
ning may be hindered. He believed updating information in the context
of the rapidly changing area to be the most critical aspect of providing
a readily usable tool.
Nevertheless, the YTAPO Director believed the people essential to plan
implementation had been involved in the WQM project from the outset. He
felt local elected officials' awareness and support of the project had
been achieved because of YTAPO's immediate response to'officials' con-
cerns. YTAPO staff reported that elected officials were attending meet-
ings about fifty percent of the time, but were satisfied with this atten-
dance record considering the great distances involved. YTAPO staff have
an ongoing working relationship with local agencies including County Plan-
ners. The conservation districts are working with YTAPO under subcontract
for nonpoint source data collection and soils mapping.
Two State Water Quality Board staff members commented on YTAPO plan
implementaion. Both indicated that YTAPO would provide valuable data
to the State in terms of nonpoint source problems which the State
could potentially utilize in agricultural regulations. They did not
expect any areawide or new authorities to be established, but rather
anticipated exising agencies with their basic authority clarified and
strengthened to provide a vehicle for local implementation. They
also noted that the State could assume some implementing responsibi-
lities in the event that a local effort is not instituted.
The YTAPO Director indicated that YTAPO has not made any direct attempt
to establish legislative contacts. As the Montana Legislature convenes
biennially, he noted that the Fall, 1977 session would offer the first
opportunity for such contact. Primarily, he believed legislative
action may be necessary to clarify existing county authority. Two
State Water Quality Board staff members concurred with this view of
legislative needs as they believed basic Authority essential to plan
implementation, including sediment"and erosion controls, currently exists.
C. Continuing Planning Process
Following the initial planning period, the YTAPO Director did not anti-
cipate that a centralized areawide office of the Council of Governments
would continue. Rather, he believed the continuing planning function would
more likely be in the form of a technical planning staff or "pool."
available to assist county planning board and conservation district acti-
vities. He expected possible funding support to depend on local sources,
YT-11
-------
coal tax monies available for such purposes1, and federal grants.
Other interviewees commented on the likelihood of a continuing planning
function. A county official believed there would be a local support
for further data analysis and technical assistance functions of a cen-
tralized planning staff. Another county official believed the planning
period was sufficient for problem identification and wanted continued plan-
ning only if focused on assisting local problem-solving actions. Two
other interviewees, a County Planner and operating facility manager,
were skeptical that continued planning would receive local funding support
due to other priorities competing for local resources. Generally, two
State Water Quality Board staff members did not expect continuation
of areawide WQM planning despite their hopes for the regional function.
They indicated that the State retains responsibility for continuing
planning and, in the event that areawide efforts do not continue, the
State Water Quality Board would perform the ongoing planning function.
D. Relation to Other Water Quality Programs
The YTAPO Director did not expect substantial interaction between the
WQM planning effort and construction grants program. He indicated
that the plans equivalent to Step I of the contruction grants program
were being completed for fivs to seven communities under YTAPO WQM
funding. He also noted that future facilities would not be significantly
affected as regionalized waste treatment was not generally feasible in the
semi-rural area. A county official hoped the WQM plan would indicate
priority facility needs in tr.e area. A State official hoped that the
area would recognize the State/EPA priority system for awarding con-
struction grants. Another State official simply stated that through
YTAPO WQM funding, facility jlans for communities could be developed pre-
paratory to construction funding.
Regarding the NPDES permit program, the YTAPO Director noted that no
critical permits were locate-?, currently within the area and the YTAPO's
WQM plan is accordingly designed for zero discharge. State water
Quality Bureau staff member expected the YTAPO project to generate data
for input to establishing effluent limits.
E. Local Definition of Success
Most interviewees were asked to define what they would consider a success
for the WQM planning project. The local non-staff interviewees generally
considered success to be a response to the concerns of the WQM planning
participants which include facility planning, identifying contaminating
1
The Gross Proceeds Coal Tax is assessed on the mine-mouth price of
subbituminors and legnite coal and the revenues are portioned to local
areas impacted by energy development activities.
1TT-12
-------
sources of groundwater, air interior census for Rosebud County and land
use mapping. A County Planner also desired some mechanism, (e.g., land
development permitting system) for siting future development and a
county official wanted guidance for future local actions. The YTAPO
Director believed success would constitute "no major future impacts on
water quality" and "pressure to maintain high water quality standards".
One State Water Quality Bureau staff member believed that a successful
outcome comprised an overall plan for local decision-making, while
another desired coordination of studies in the energy development areas
and local education regarding the agriculturally induced water quality
problem and overall land use-water quality relationships.
All interviewees expected the WQM planning project to generate area
benefits. Expected benefits centered on the informational support to
county planning activities and public education regarding existing
and potential problems related to growth. A State official hoped informa-
tion would stimulate local action to correct and/or prevent water quality
problems.
YT-13
-------
IV. VARYING PERSPECTIVES OF WQM
A. VJQM Staff
According to the YTAPO Director, YTAPO's role is to serve the immediate
concerns of local officials ^hich includes developing a data base, land
use mapping, and municipal facilities planning. All of their activities
are preparatory to planning for the secondary impacts of energy develop-
ment in the area. In addition, YTAPO has responded to local problems
such as disinfecting wells.
The YTAPO Director emphasized the technical planning role of the YTAPO staff
in the current planning period. He believed data gathering and analysis
were YTAPO tasks endorsed by local officials, whereas areawide planning
per se was not. Hence, YTAPO is providing tools for future local effcrts
.and decision-making, and making suggestions for local action. A continu-
ing role for YTAPO may evolve into a technical support staff or "pool"
to provide ongoing data analysis and technical assistance to local units
of governments.
B. Citizens
Two interviewees were County Planners who had ongoing contact with YTAPO
and were involved in various sub-elements of the WQM planning process,
(e.g., interim census for or_e community and land use mapping) . Both felt
that YTAPO suffered from a lack of public and officials' understanding
of the project's value. They anticipated some opposition due to a per-
ception that local control is being pre-empted or otherwise interfered
with by Federal regulations. Both believed planning was "unpopular"
in the area. One County Planner felt nonpoint source control imple-
mentation would best occur through county agents of the SCS.
The third interviewee was the Water Management Coordinator for the
Northern Cheyenne Research Project. He explained that the Tribal Council
had not been eligible for WQM program funding and consequently approached
YTAPO for assistance. Originally, the Northern Cheyenne had subcontracted
for specific elements of the YTAPO project, but ultimately EPA directed
that a WQM plan for the Reservation be developed. The Research project
staff is establishing baseline data to determine the relationship of
water quality to potential coal mining activities and related development,
and will feed into a larger ongoing research effort regarding coal
development. Although the Northern Cheyenne Sub-plan will be incorporated
in the overall YTAPO plan, the Tribal Council has implementing authority
within the Reservation.
YT-3,4
-------
c.
Local Elected Officials
Two County Commissioners were interviewed, both of whom were active on
the YTAPO Board of Directors. Both believed the YTAPO project provided
a means for preparing for the future impacts of coal development. How-
ever, obtaining baseline data for impact assessment and planning was
secondary to one official who was more immediately concerned with sewage
disposal. The other official stated that he was primarily concerned with
water supply.
Both officials strongly believed that the WQM plan should be advisory to
local actions. While one official supported the idea of continuing
areawide planning and a technical support staff, the other official was
more reticent to support continued planning until the value of the YTAPO
project could be determined.
D. Appointed Officials
The appointed official interviewed headed an operating facility which is
being studied for upgrading under YTAPO WQM funding. He noted that the
community was too small to receive construction grants funding and the
oxidation project would likely be funded through the Farmers Home Admini-
stration, the State Coal Board and/or local sources. He believed the
community had been "dormant" in correcting municipal facility problems
until Federal regualtions forced compliance with discharge permit require-
ments .
Although his role in the WOM planning effort is largely limited to manage-
ing the operating facility, he commented on the overall YTAPO project.
He felt the main problem to be a local concern tnat the YTAPO program
threatens Federal interference with traditionally independent actions of
ranchers and local governments. He also believed WQM funding sources to
be uncertain; especially questionable was the availability of coal tax
revenues to the area as well as the ability of the WQM project to compete
with local priorities for use of those revenues.
F. State Legislators
One State Representative to the Montana Legislature was interviewed. He
served in the State Environmental Quality Council which is an interim
legislative Committee examining uniform permitting. His awareness of
the WQM program was limited to committee briefings and he had not been
contacted by any WQM agencies.
YT-15
-------
The State Representative commented on the legislative climate for environ-
mental issues. Ee believed that utility plant siting, strip mine recla-
mation, groundwater protection and stream preservation numbered among
priority environmental concerns in the Montana legislature. He also cited
water quality as a great concern, especially where potential conflicts
may occur between users for agricultural and energy development purposes,
j Although he permally favored land use legislation, he expected the rather
f conservative legislature to oppose land use control measures.
F. State Water Quality Personnel
Two staff members of the Montana Mater Quality Board were interviewed.
One staff member had written the YTAPO work plan which was the basis for
YTAPO's designation.' The water quality specialist on loan to YTAPO from
the State is the primary vehicle for State participation.
'Generally, they believed the State had not been involved as much as it
'should to assure coordination of State and designated area WQM planning.
II Because the State did not have the resources to become extensively involved
a in each of the four designated WQM planning areas, the State Water Quality
| Bureau attended to the other WQM planning areas having greater difficulties
and left the relatively successful YTAPO project alone. Overall, they
expected the YTAPO effort to have some impact, and emphasized their con-
fidence in the YTAPO staff as a primary reason for the expected success.
YT-16
-------
V. ANALYSIS AND CONCLUSIONS
A. Likelihood of Plan Completion, Approval and Implementation
At this point, YTAPO is reportedly on schedule for meeting the plan
completion date, and will likely achieve its objective of developing a
data base, providing the area with good quality land use maps, and com-
pleting five to seven facility plans. Because of the apparent confidence
of local and State interviewees in YTAPO efforts, gaining plan approval
seems likely. YTAPO is also understood to be serving local concerns and to
be generating recommendations which are only advisory to local actions.
Hence, YTAPO actions, in themselves, do not seem to arouse local opposition.
However, with the WQM program hinting at Federal interference, plan approval
may be hindered by the frequently mentioned attitudes of "anti-big govern-
ment" .
The current outlook for plan implementation is not clear. As noted by the
YTAPO Director, a lag in area energy development would allow awareness of
the effort to subside. The plan would then only become advisory to local
governments. Implementation would potentially occur as local actions are
deemed timely and appropriate. Considering the anti-planning attitudes
in the area, local actions could arise as a reaction to development, rather
than in anticipation thereof. Although energy development may not be
realized for five years or more, maintaining a current data base and viable
processing mechanism would seem desirable- to ensure a dynamic adaptability
to the rapidly changing area. A reactive response would be insufficient
to the task.
YTAPO is currently proposing tentative recommendations for plan implementation,
Although less than one year into its planning period, the tentative recom-
mendations circulated for areawide comment should provide a milestone indica-
tor to local governments and other interest groups of the project's progress
to date, as well as its future direction. YTAPO may obtain indicators of
the local receptivity to the WQM project with responses to these recommendations.
One of the most important aspects of plan implementation is the proposed
Technical Support Project. A staff of Technical Analysts would provide
ongoing technical assistance to local governments and provide a means for
maintaining an up-to-date information system available to local decision-
makers. Local officials may keep well appraised of the needs for local
action by relying on the technical staff to provide indicators and analysis
of development trends in the future. Further, the technical staff could
work with the SCS County agents in a variety of educational efforts to reach
the ranching and farming groups, (e.g., information regarding impacts of
irrigation water with high saline content). However, at this stage of the
planning process, it is not clear what actual local support exists for the
establishment of a technical services pool.
YT-17
-------
B.
Public Involvement
Aside from YTAPO contacts with officials through the Board of Directors
and informal liaison with county planners and SCS agents, no extensive
public involvement effort has commenced. To date, a few activities have
been aimed at disseminating information and heightening local awareness
of the YTAPO effort and its objectives, "e.g., informational meetings,
newsletters, news releases, and conducting irrigation water sample analysis
at county fairs). However, public involvement per se is yet to be evidenced
and may not occur. The YTAPO Director had noted that reaching the public
may not be practical given the limited YTAPO resources and the vast
distances involved.
Considering the objectives of the YTAPC project, public involvement at
this stage of the WQM planning process may not be practical. Developing
a data base, land use inventories, and itunicipal facilities plans are not
controversial activities in generating technical products. More important
for public review is the manner in which these tools will be used at the
local level. As YTAPO has not assumed a stance of effecting local action
other than in air advisory capacity, public comment may be more essential
in determining the appropriate direction of future local actions. In
essence, YTAFO is not telling communities how they should grow, but only
advising them on the base of analytical results as to what changes are
presently occuring and will potentially occur in the course of growth.
Nevertheless, through information dissenination efforts, YTAPO may stimulate
local interest in preparing for growth and enhance the prospects for local
action.
C. Current Planning Process
From the outset, YTAPO was directed by local officials who form the areawide
organization, to devote attention to specific concerns. By focusing on
the local interests in municipal facilities, data gathering and land use
mapping, YTAPO assumed the role of technical advisors to local governments.
This has resulted in a straight forward technical approach to the WQM plan-
ning task which is manageable within the planning period and resources
available.
Enhancing the project's manageability is the object of YTAPO as a single
purpose, short-term agency, unencumbered by predecessor, concurrent activities
or complex institutional arrangements. The management question is answered
by the few municipal and county authorities presently operating. For
example, regionalized facilities in this sparsely populated area do not
emerge as a management complexity and, consequently, municipalities will
retain control over their operating facilities. Moreover, the YTAPO area
is not suffering from degraded water quality due to heavy urban and
industrial activity. Rather, its relatively good quality waters are
contaminated primarily by natural man-aggravated sources of pollution (e.g.,
high sediment and saline content).
YT-1S
-------
Hence, the water quality issue is one of nondegradation in the context of
an area susceptible to rapid growth induced by energy development.
Probably the most vexing problem for YTAPO planning is the uncertain advent
of energy development. Without explicity knowing the timing and extent
of energy development, determinating population projections became a
difficult task. Municipal facilities plans were seen as particularly
tenuous, as population to be served was a rather gross assumption.
Planning in the fact of uncertainty requires flexibility. The YTAPO staff
recognized the potential for rapid change in the area, and therefore must
be in a state of continual readiness to cope with emerging problems.
Developing tools for decision-making and creating an awareness of the water
quality issues attendant to growth seem appropriate first steps. Applying
those tools in preparation for growth is the second step. The extent and
timing of growth related to energy development remains uncertain, and may
force local governments into a reactive position.
D. Continuing Planning
An ongoing means for providing technical assistance to local actions would
seem critical to plan implementation. The Technical Support Project would
offer that continuing role in specific technical tasks, such as updating
information and advising local governments. However, if development
pressures are not sufficient to cause officials to value the continuing
function, ongoing planning responsibilities may fall to the County Planners
or to the State, neither of which has sufficient staff to thoroughly
attend to the areawide issues. Should coal tax revenues be available for
a continuing planning function, the question remains as to whether local
governments would divert funds from other priorities to support the effort.
E. Significance of Local Elected Officials' Involvement
Clearly, local elected officials are the primary constituents of the YTAPO
project. YTAPO responds to the~immediate concerns of officials and conducts
WQM planning in a manner which seemingly renders YTAPO an extension of local
staff. YTAPO is providing data previously lacking in the area, including
land use mapping and, in one community, an interim census. Both of these
efforts have considerable transfer value to other local activities. Most
interviewees, including two County officials, recognized YTAPO's contribu-
tions to their efforts and expressed appreciation for YTAPO's responsiveness
to their concerns.
In its advisory capacity, YTAPO has seemingly established a rapport and
credibility with local officials which will hopefully enhance their
receptivity to YTAPO recommendations for plan implementation. However,
should local officials balk at under-taking action, the impact of YTAPO's
efforts may be short-lived.
YT-1,9
------- |