AREAWIDE WATER QUALITY MANAGEMENT
PROGRAM SURVEY (II)
MARCH 1977
PREPARED FOR
WATER PLANNING DIVISION
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
Centaur Management Consultants, Inc.
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PREFACE
This is the second round in a series of surveys of areawide water
quality management (WQM) agencies. These surveys are being conducted
for the Water Planning Division of the Environmental Protection Agency,
Washington, D.C. by Centaur Management Consultants under Contract No.
68-01-3577. The first survey in these series was documented in two
reports: "Areawide Water Quality Management Program Survey Summary"
dated August, 1976; and "Areawide Water Quality Management Program
Survey" dated October, 1976.
This survey was conducted solely by telephone in February of 1977. The
survey format was transmitted to each of the WQM agencies and to the EPA
Regional Offices prior to the telephone contacts. The survey structure
as described below was modified by the unique characteristics of each
agency. The actual questions asked of the various local interviewees
over the telephone reflect our previous understanding of each agency's
achievements, problems, and progress to date. A list of interviewees
is in th'e Appendix.
The theme of this survey is to assess progress toward plan implementation.
In order to assess the sample agencies' performance, the following three
issues were discussed.
1. Nonpoint Source Problems - For each areawide agency, a
specific nonpoint source problem was selected for dis-
cussion. The nonpoint source problem selected was not
necessarily among the reasons cited for initial designa-
tion, however in each case it does represent a priority
concern identified in the agency's profile prepared for
the EPA Water Planning Division. Interviewees were asked
such questions as: How was the issue defined? To what
extent will it be corrected as a result of the WQM pro-
gram? When will plan recommendations be implemented?
2. Facilities-Related Plan Elements - Interviewees were asked
whether WQM interim and final plan outputs influence
current and future wastewater treatment facilities
decisions. And, if so, in what way will this happen?
3. Role of WQM Planning in the NPDES Permit Process -
Interviewees were asked whether WQM interim outputs
as well as the final WQM plan will influence the next
round of NPDES permits . If the WOM plan will not be
ready for the next round, how do interviewees think
it will influence future NPDES permitting activities?
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TABLE OF CONTENTS
Page
PREFACE i
CASE STUDIES
1. Chattanooga Area Regional Council of Governments/
Tennessee Development District CA-1
2. Delaware Valley Regional Planning Commission DV-1
3. East West Gateway Coordinating Council EWG-1
4. Houston-Galveston Area Council HG-1
5. Lower Rio Grande Valley Development Council. LRG-1
6. Martha's Vineyard Commission MV-1
7. Miami Valley Regional Planning Commission MVR-1
8. Mid-America Regional Council ' MA-1
9. Middlesex County Planning Commission MC-1
10. Mid-Willamette Valley Council of Governments MW-1
11. Municipality of Seattle - METRO....- MS-1
121 Ohio-Kentucky-Indiana Council of Governments OKI-1
13. Southeastern Wisconsin Regional Planning
Commission SEW-1
14. Southern Kennebec Valley Regional Planning
Commission SKV-1
15. Southwest Florida Regional Planning Commission SF-1
16. Sussex County Council SC-1
17. Teton County 208 Planning Agency TC-1
18. Ventura Regional County Sanitation District VC-1
19. Yellowstone-Tongue Areawide Planning Organization... YT-1
APPENDIX
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In order to obtain a broad perspective on the WQM program, a variety
of persons were interviewed in each project area. Included among the
interviewees were the WQM Project Director, the EPA Regional Project
Officer, the State water quality agency liaison, local elected officials
and citizens. Whenever possible, the survey team interviewed the same
persons who participated in Centaur's previous WQM survey.
Because this survey was-designed as part of an ongoing WQM program
study, the following case studies should be read with the earlier Centaur
case studies in mind. For the sake of brevity, a full explanation of
facts already presented in earlier reports are not repeated in these
case studies.
This round of the WQM survey was directed by Ms. Jane Nowak. Assisting
her were Cheryl Dinneen, Ann Hoffman, and Constance Castle. Centaur
appreciates the useful guidance provided by Ms. Pat Cohn, the EPA Project
Officer.
Michael L. Frankel
Centaur Management Consultants, Inc.
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1 Chattanooga
Chattanooga Area Regional Council of Governments/
Southeast Tennessee Development District
Chattanooga Area Regional Council of Governments (CARCOG)
started its WQM project in September, 1975 and is scheduled
to complete its final plan in October, 1977. The total
WQM grant amount is $949,000.
The designated area is 2,012 square miles and includes three
counties each in the States of Georgia and Tennessee. The
population is 370,010 according to the U.S. Census of 1970.
The Chattanooga area was designated because of its urban con-
centration and its industrial pollution. However, since¦ much
of its population is concentrated in one country, Chattanooga
also has a large rural area. This area accounts for a number
of nonpoint source problems which are also being studied under
the WQM proiect .
General Nonpoint Source Analysis
Chattanooga Area Regional Council of Governments (CARCOG) is examining a
range of nonpoint pollution sources {e.g., agriculture, mining, silvicul-
ture and construction), and particularly those sources which contribute
sedimentation to the area's waters. Attention is also being directed
toward-combined sewer problems which are causing pollution in some tri-
butaries. All of these problems were identified by the WQM's Technical
Advisory Committee (TAC) but had never been studied before.
A key feature of the nonpoint source WQM study element is that CARCOG
has engaged the services of a Soil Conservation Service (SCS) staff per-
son to conduct the nonpoint source study over the two year study period.
The SCS person has already completed an assessment and evaluation of the
area's nonpoint source problems and is currently monitoring land use
types (industrial, commercial, residential, agricultural, etc.). This
data will be used to determine pollution loadings and finally to develop
land use management practices.
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A sampling program is being completed by the Tennessee Valley Authority
(TVA) in order to calibrate and verify a nonpoint source model. The
sampling program is going slower than expected in part because of co-
ordination problems between CARCOG and the TVA and because there was a
problem with low seasonal rainfall. Only 15-20 percent of the sampling
was finished by February, 1977.whereas they had previously expected to
finish 80 percent by that time. A consultant is using the SWMM model
to do an analysis of urban runoff. At a minimum, the consultant will
quantify the problem and if possible develop, alternatives.
The WQM staff was working on three possible solutions to its nonpoint
source problems. The first is the development of BMPs by the SCS person.
Although this work just started in June, it is ahead of schedule and will
be ready to be presented to the WQM Program Board with alternative re-
commendations, their impacts and costs by the beginning of March. The
second solution being considered is a sediment control regulation for
the three counties in Tennessee. The Georgia counties already have a
regulation that requires a sediment/erosion plan from all potential
polluters1 and a parallel regulation for the Tennessee counties is
believed desirable.
The third solution being developed is the formation of an association
of the five SCS districts in the designated area. The association would
consider-urban and rural runoff problems. The EPA project officer, the
State liaison and the WQM project staff all felt this alternative re-
presented an innovative management approach. Although' historically the
SCS has operated through education and voluntary programs, under the
five district association they might seek some regulatory powers (such
as through an erosion control ordinance). The first steps towards im-
plementation of this solution were taken in late 1976 with formation of
the association.
The EPA Project Officer expects the association will develop and promote
voluntary compliance with BMPs. He feels this is the only acceptable ap-
proach. The Tennessee State liaison is also in favor of the association's
"softer" program with funds and motivation instead of imposed regulations.
He expects eventual abatement of the nonpoint source problems through the
association of SCS districts.
One-of the County Commissioners felt it is necessary to "give it teeth"
before the program will work. He also favored examining a full manage-
ment system before writing regulatory -ordinances rather than trying to
solve problems piecemeal. A city engineer felt that nonpoint sources
were not a significant problem with the exception of combined sewer over-
flow, so he was not particularly interested in this element of the plan.
There isf however, an exemption for agriculture.
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A citizen, who is a representative of the National Association of Home
Builders on the Citizen Advisory Committee felt that the WQM plan was going
too far, too quick. He wondered what the costs would be and how they
would be passed on. He felt that nationwide the WQM program will be a
"blow to the economy" and asked whether anyone had done an economic
impact study on the program. In his opinion they would be "stopping
all coal digging just for a couple of streams that aren't important
anyway". Finally, he said that WQM was contributing to a situation
where no one can afford a single family home. NAHB, though concerned
about the program, has not publicly opposed it, fearing a backlash of
anti-development sentiment would lead others to support WQM.
According to the project staff, the interim outputs are completed but
have not been sent to EPA Regional Office for approval. The projections
and inventories were useful for the nonpoint source work. The State
will do all wasteload allocations under the statewide plan.
The final WQM plan will be completed by the summer or the fall of 1977,
and everyone agreed they would start implementing parts of it even before
the final plan is completed. The final plan must be approved by the
Water Quality Hoard on behalf of the CARCOG Board. Two possible barriers
to implementation cited were qpposition from private industries that stand
to be regulated and lack of implementation funds. The WQM staff thought
that financial problems would arise particularly at the local level.
According to the EPA Project Officer, the problem will be complicated by
the fact that the SCS itself does not have the money and would probably
be looking to Federal sources.
A Citizens Advisory Committee (CAC) was not formed until the fall of 1976,
therefore citizens were not involved in either problem identification or
review of interim outputs. The CAC will review the management alternatives
when they are completed in March. The CAC consists of 30 members selected
to represent a balance of interests and geography. At the time of
the interviews, the CAC had only had one meeting. Attendance was limited
because of bad weather, but those attending were very interested. One of
the citizens attending felt that people were hesistant to speak up
because it was the introductory meeting, but he expects active involve-
ment and participation.
All interviewees agreed that there has been excellent involvement by local
elected officials. The officials' involvement is centered around the Policy
Board, but there is also good direct communication and coordination between
meetings. The WQM staff explained that interest varies according to how
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much the official's area stands to lose or gain. Thus several officals
(especially those in Hamilton County and in Northern Georgia) are
involved on a day-to-day basis. Some of these officials are asking for
a regional management system. The WQM staff noted that any manage-
ment system or any nonpoint source regulations will only have the force
given them by these officials. Many of the key officials, such as the
Mayor of Chattanooga, attend meetings personally (rather than send a
representative) which encourages others involved to believe the elected
officials will follow the program through. The State liaison believed
that the Chattanooga program is the best designated program in Tennessee,
mostly because it has such excellent communication at the local level.
The two states (Georgia and Tennessee) involved in the Chattanooga
study kept informed of project j^iuyress but neither is very active in the
program. Georgia is not involved because it is primarily interested in
201 planning, not areawide WQM planning. Although Tennessee is more
interested, staffing problems have forced them to limit involvement to
reviewing plans and attending TAC meetings. The State of Tennessee has
hired a consultant to coordinate the areawide studies with ,the statewide
WQM study. A few meetings between areawide planning bodies and the State
have been held. It is believed that many legal issues can be solved in
common.
The EPA Regional Office has been actively involved in several elements
of the WQM study. In addition to helping define problems, give support
and guidance, the Regional Office has organized over four joint State/
areawide meetings and a presentation on cost recovery. In addition, the
water lab in Athens used this area for testing certain modeling techniques.
Facilities Planning Related Elements
The WQM study is not doing facilities planning work because they were
told not to by the EPA Regional Office. Most of the 201s in this area
are already complete. The one area not involved has recently started
a 201 plan. These 201 plans are considered adequate and thus not
requiring attention of the WQM staff.
In examining the facilities management system, the WQM staff is trying to
work within the confines of existing agencies. The WQM staff, EPA Project
Officer and State liaison tentatively suggested that there may be a need
for a new regional agency. The EPA Project Officer noted that it certainly
makes more sense for one agency to deal with EPA rather than each local
jurisdiction dealing separately. He also noted that the Chattanooga area
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has successfully tackled other problems - notably health and transit - on
a regional basis. The State liaison, however, .felt that there would be
resistance from many towns who might feel power is being taken away from
them. One County Commissioner felt that any new agency would have to be
large enough to handle all the work. Currently, the only body large
enough to do that would be.the City of Chattanooga. He said he would
support such a system if there is a lot of local input and it is not too
costly.
The City of Chattanooga sewer use ordinance became effective in January
1977. Right now industries are being asked for information on their
discharges in order to develop pretreatment requirements and industrial
cost recovery formulas. The EPA Project Officer also felt that the
information might be used to start an industrial exchange, so that those
who could use a particular discharge as a water supply would be aware of
where it is. So far, the WQM has had little involvement in the ordinance,
.Role of WQM Planning in the NPDES Permit Process
EPA has NPDES permit authority in both Georgia and Tennessee, although
the State of Tennessee is seeking to take over this authority. In
issuing permits, EPA solicits State review and attaches State comments
as integral conditions. The WQM agency is also sent draft permits for
comment, but so far has not made any comments. Citizens and local
elected officials also do not play much of a role in permitting.
The interim outputs were not particularly useful in permitting. The
WQM staff agreed that the State should do the wasteload allocations.
Since this has not happened, the WQM agency feels the State should
either do it, or let it be done under the WQM study. EPA was also
critical of the State for not implementing standards. The State,
in turn, was critical of EPA for not studying the State's problems in-
depth before issuing the permits. Instead NPDES permits were issued
"in bulk", which the State felt was an "inaccurate procedure".
Conclusions
CARCOG is generally believed to have an excellent nonpoint source program
underway. The Soil Conservation Service staff person who is on temporary
assignment to the WQM staff is highly regarded and seems to have
accomplished a great deal of work in a relatively short period of time.
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In addition to completing an inventory and evaluation of the nonpoint
source problems, he has almost completed an evaluation of loadings by
dominant land uses and is about to prepare BMPs for a variety of
potential nonpoint source pollutants. This element of the plan will most'
likely be completed ahead of schedule.
The accomplishment cited by all interviewees is the formation of an
association of the five Soil Conservation Districts in the area. Federal,
State and local officials alike are enthusiastic that the association
will be able to successfully solve the nonpoint source problems of the bi-
State; area. Implementation has already started through formation of the
association. The association will generally work through education and
voluntary programs, ana will also provide regulatory controls such as an
erosion control ordinance which is being considered.
Citizens are just starting to become involved, but there is a fairly high
level of interest because there is so much happening in this program.
Not all the interest,is necessarily favorable; some industries and
developers are concerned about the cost and effects of certain regulations,
but no definite opposition has formulated yet.
Local elected officials have been active for some time. Leadership has
developed among the officials as the mayors of some of the largest areas
have'taken a personal interest in the program. Most officials seem
cautiously interested in looking at new institutional and management
alternatives. They are concerned about the area's problems and agreed
that some corrective actions are needed, but they are unsure what effect
this might have on existing authorities. It seems likely that the
officials will remain involved and possibly might even consider creating a
new regional management authority for treatment facilities.
The WQM staff is presently looking at the existing treatment facilities
management to see what improvements might be made. Many officials in the
area are beginning to think that a regional authority would make sense.
Other officials are jealous of their existing powers and would oppose such
a move. If regionalism is to occur, it will have to come slowly as a
concensus emerges. The WQM staff is sensitive to that fact. The WQM
staff does not become involved in any 201 planning as it is mostly
completed in this designated area.
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NPDES permitting authority rests with EPA in both Georgia and Tennessee.
Neither the States nor the WQM agency get heavily involved, although
they are each given an opportunity to comment on draft permits. Both
EPA and the WQM agency were critical of the State of Tennessee for not
completing some of the work that might have been used in making permit
decisions. For example, wasteload allocations, which were to have
been done by the State, have not yet been started.
Aside from this, however, the WQM agency and the State of Tennessee
are working well together. The State liaison calls Chattanooga the
best areawide program in the State. Georgia has shown little interest
in the program, preferring to spend its time on 201 planning in the
State.
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2 Philadelphia, penn.
Selaware Valley Regional Planning Commission
The Delaware Valley Regional Planning' Commission began actual
WQM planning for the Philadelphia area in January, 1976
and is scheduled to complete a final plan in December, 1977.
The Philadelphia WQM project is one of three WQM projects being
conducted by DVRPC.. Problem definition and data gathering were
completed under the Pennsylvania comprehensive water planning
program (COWAMP) prior to receipt of the Philadelphia WQM grant.
The Philadelphia study area consists of 2200 square miles and
includes 3,865,810 people according to the 1970 U.S. Census.
Eighty-seven percent of the area is in greater metropolitan
Philadelphia, much of which has complex urban and industrial
sources, of water pollution problems. Urban storm runoff is a
major problem in the City of Philadelphia itself and approximately
20 other neighboring urban communities.
Urban Storm Runoff
A study conducted by the Philadelphia Water Department before the WQM
study began confirmed the existence of an urban storm runoff problem
in the Philadelphia metropolitan area. Beginning with this knowledge,
the Delaware Valley Regional Commission (DVRPC) designed its WQM
project:
• To determine the magnitude of the runoff problem
relative to point source pollution problems; and
• To define site specific solutions for problem areas.
The absence of storm conditions during the WQM planning period, however,
has interfered with stream sampling needed to calibrate a new runoff
model being prepared by the Pennsylvania Department of Environmental
Resources (DER). Without this data, the WQM Project Director feels that
DVRPC's quantitative analysis will be severely limited and that the
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final WQM plan can do no more than outline generally appropriate manage-
ment strategies. The Director estimates that a six month time and
funding extension from EPA would enable DVRPC to use the new State model
and thereby develop sound and implementable recommendations.
The State liaison from the DEE. agrees with the WQM Project Director's
opinion. He noted that if DWPC does not receive the requested extension,
the WQM agency will be forced to use existing data in conjunction with'
an old State runoff model. This "primitive" model will only generate
"best guess" estimates, solutions, costs, results, etc. Local communities
are not expected to enthusiastically receive or implement "best guess"
recommendations. The EPA Project Officer sympathizes with the sampling
difficulties but feels that DVRPC may be looking for more data than it
actually needs to reach its desired objectives.
Philadelphia's WQM interim outputs have not been completed yet because of
technical and political problemsi. The WQM Project Director however noted
that the interim outputs will not be directly useful in solving existing
urban storm runoff problems, but may be helpful in projecting possible
pollution from future growth. The population and land use projections in
particular will be used in calibrating the DER runoff model.
The WQM Project Director expects that most recommendations will pursue
a voluntary rather than regulatory approach to problem solving because of
local concerns about autonomy. The EPA Project Officer noted that such
an approach is to be expected since DVRPC has never been involved in
regulatory activities. According to the State liaison, DER is already
prepared to ask all local communities to make their local sewer plans comply
with the WQM plan. One citizen noted that DVRPC has avoided discussions
about voluntary versus regulatory approaches to problem solving since
regulations are such a politically volatile issue in the WQM area. He
feels, however, that DVRPC-will be forced to face these difficult questions
before the final WQM plain is issued for review.
Although the WQM project extension controversy has left the nature of the
final WQM plan recommendations rather uncertain at this time, the WQM
Project Director predicted that recommendations will chiefly emphasize
nonstructural management practices (e.g., street sweeping, sewer maintenance
and cleaning, catch basin cleaning) or semi-structural solutions (e:g.,
use of storm sewers for- retention and delayed treatment of water). In
view of his personal stand on the project's extension, the EPA Project
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Officer; expects DVRPC to rely on literature for guidance in selecting
appropriate recommendations. One citizen noted however that literature-
based recommendations will not be adequate from the local perspective,
especially if communities think that more effective and perhaps more
economical solutions could be developed with just a little more planning
time and money.
Most interviewees feel it is too early to predict the WQM plan's impact
on water quality. Generally, they expect existing problems will not
be completely corrected but that WQM planning will provide tools and
knowledge for avoiding future problems. The key, of course, will be
the degree to which the plan is implemented.
When final WQM plan alternatives are prepared they must be reviewed first
by the public at county forums (i.e., public meetings) and by the Citizens
Advisory Committee. The final plan then moves through the rest of .the
WQM committee structure, i.e., the Technical Advisory Committeethe
Policy Advisory Committee and the Study Advisory Committee. The two
latter committees are composed primarily of county and local officials.
After public hearings are held, the plan is reviewed by the DVRPC Board
of Directors which is composed of eight County Commissioners, representa-
tives from the four largest cities in the WQM area, and three representa-
tives from the State. Local elected officials then have a chance to
review the plan and make comment directly to the Governor before his final
review and transmittal of the plan to EPA. The critical points in the
review procedure, according to the WQM Project Director, are the DVRPC
Board of Directors and the local elected officials.
The WQM Project Director would like to see some implementation of plan
elements before the final plan is approved, but given the uncertainty
of project extension and local communities' aversion to a "piecemeal
approach", it is unlikely that much action will be taken in the immediate
future.
A number of potential barriers to final WQM plan implementation were
mentioned. The WQM Project Director, a citizen and the State liaison noted
that intense home rule preservation sentiments will be the most significant
stumbling block to overcome. Some communities have traditionally dismissed
any plans which even vaguely speak of regionalism or inter-community
cooperation. Since the Philadelphia WQM area has over 350 municipalities,
coordination is essential but will be difficult to achieve. Many local
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officials are still unfamiliar with the rationale behind WQM planning
and the costs and benefits of possible recommendations. The WQM Project
Director feels it may take a good deal of time after the two year period
to convince these officials to accept and implement the plan. Since
involving the myriad of local officials would have made the planning
process totally unwieldy, the WQM staff has geared its program toward
an audience of county level officials to date.
A citizen and local official stressed that local communities are concerned
that the WQM plan will be based on inadequate data. Now that the WQM
Advisory Committees and the general public (through the county forums)
have heard about the data gathering extension controversy, many are
convinced that anything short of using the new State runoff model and
thorough storm sampling data will not suffice. The last thing property
owners want is further control on the use of their land, let alone if
those controls are based on possibly faulty data.
Availability of outside funding is also a major factor in implementing
the WQM plan. The WQM Project Director noted that funding during the
transition period between plan completion and implementation will be
particularly important. DVRPC is presently considering a variety of
transition period funding alternatives including charging a fee for re-
viewing local plans and making them consistent with the WQM plan (as
required by the State). Another alternative is to recruit the coopera-
tion of the Corps of Engineers or the Soil Conservation Service in
coordinating planning efforts with WQM transitions planning and funding.
One local official feels that without Federal sanctions, there is little
hope for plan implementation since water quality management is not a
foremost priority among most local officials. He also noted that
jurisdictional problems can be expected. For example, if one town installs
a culvert to carry away urban storm runoff, the pipe may have to extend
into the neighboring community. Questions about who benefits and who
should pay will surely arise.
To overcome some of these potential barriers, the WQM staff has
tried to reach out to municipal associations with local official member-
ship. There, the WQM staff has tried to explain the WQM project and
solicit local input. DVBPC has also used television and radio public
service announcements to increase the project's visibility and to call
upon concerned citizens to lobby for local officials support of the WQM
program. DVKPC is also still pursuing grant extensions from EPA.
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The quarterly county forums mentioned above are the chief routes for public
input into the WQM program. These forums are jointly sponsored by the
State's comprehensive planning programs (COWAMP). The WQM Project Director
feels that these forums have been very helpful in keeping the public informed.
A citizen interviewee, on the other hand, feels that the forums are only
useful to those who were already interested in water quality and vranted
a platform to voice their parochial point of view. The Citizen Advisory
Committee (CAC) has more direct input into the WQM planning process. The
CAC helped identify nonpoint source problems for study and reprioritize
work elements when the initial petition for project extension was rejected.
The CAC is currently engaged in discussions on management alternatives.
The most active special interest groups are the watershed associations
which, according to the WQM Project Director, promoted more input from
local officials. All interviewees felt that DVRPC has done commendable
work in the area of public involvement. They attribute any shortcomings
to the public1s own apathy.
As noted earlier, local elected officials have not been formally included
in the WQM advisory structure because of the multitude of townships and
cities involved. The WQM Project Director feels that citizens on
adivsory committees and at county forums balance the program with local
input. On the urban storm runoff issue in particular, the EPA Project
Officer noted that only 18 - 20 communities are directly connected to
Philadelphia where the problem is most serious (a great deal of the remaining
WQM area is rural) and therefore active interest from the whole spectrum of
local officials should not be expected. The EPA Project Officer also noted
that since well developed management alternatives have not been formulated
yet, it is too early to even try to reach local officials. The State
liaison shares the opinion and expects to see more direct interest from
local officials when alternatives are presented to them. One local elected
official cautioned however that if DVRPC waits until the end to reach
local officials, those officials will balk at DVRPC's recommendations if they
are perceived as dictates from the county and State level.
The State has actively supported the Philadelphia WQM program which is now
combined with Pennsylvania's COWAMP program. The State co-sponsors county
forums and has assigned a liaison from the DER to attend all WQM committee
meetings and oversee all technical and administrative matters. DER
contracted with DVRPC to subcontract out all technical work elements. The
purpose was to supplement DVRPC's staff with technical expertise for sub-
contract quality control. DER has been less helpful directly in DVRPC's
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storm runoff work than in other parts of WQM planning because the Philadelphia
Water Department is actually doing most of this nonpoint source study. The
State, however, has given informal support to WQM recommendations in the
form of suggestions for statewide stormwater management practices. According
to the WQM Project Director, DER is looking to DVRPC for lead work in
this direction.
The WQM Project Director has been very pleased with DVRPC's working relation-
ship with EPA's Regional Office in Philadelphia. His only complaint
concerned EPA insensitivity to areawide planning constraints (e.g., well
defined local institutional inventories, available technologies, etc.)
which have made WQM planning more difficult than EPA expected.
Facilities-Related Plan Elements
The WQM plan is expected to strongly influence facilities planning decisions
in the Philadelphia area. As a number of interviewees noted, without such
an. effect, the grant money will have been wasted and a foremost purpose
of the program missed.
In Pennsylvania, all local communities are required to develop a sewer,
plan per order of State Act 537. DER's policy is that all 537 plans
will have to be revised to be consistent with the final WQM plan. Not
all grant applications for facilities projects can wait for WQM plan comple-
tion since there is political pressure to spend the money now or lose it.
In the interim, the State is working closely with the WQM staff in review
of facilities plans and ongoing 537 plan updates. DVRPC will continue
influencing future decisions through its role in the A-95 review process.
One citizen warned that the full possible effect of WQM planning on facilities
planning would depend on' how' well DVRPC could educate local officials to the
range of wastewater treatment alternatives open to them. This citizen was
particularly concerned about promoting nonstructural alternatives wherever
possible.
In the area of management planning, DVRPC has just completed its inventory
of existing wastewater treatment management authorities. The inventory
identified over 500 agencies with some pertinent management-related powers.
The WQM Project Director noted that eliminating all or even a great deal
of these powers is politically impossible, but that DVRPC is trying to
develop a scheme to simplify and coordinate their activities. The question
of regionalization has not been raised yet. The EPA Project Officer feels
that DVRPC may be ignoring management discussions on purpose since they
will inevitably arouse major controversy. A cit-izen explained that some
communities fear regionalization will automatically mean higher taxes for a
program they feel they can handle adequately on a municipal basis.
DV-6
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Since facilities related plan elements are a major concern in the
Philadelphia WQM study, DVRPC has stressed related plan elements in
public forums and CAC meetings. There is mixed reaction to DVRPC's
efforts, however. One citizen feels the WQM staff has been extremely
open and receptive to public input. Another citizen feels that this
public input is of limited value since those who speak out at public
meetings are only representing their veify parochial concerns. Although
the WQM staff has tried to elicit local official's output into the
planning process, only a few have become interested at this point.
Role of WQM Planning in the NPDES Permit Process
EPA Regional III is responsible for NPDES permitting in Pennsylvania.
According to the WQM Project Director and the EPA Project Officer, EPA
will depend heavily on WQM wasteload allocations in issuing future permits.
However, the EPA Project Officer noted that DVRPC will have to prove it
used a good model in order -to defend the wasteload allocations it projects.
This statement focuses back on stream sampling problems and the question-
nable use of an updated State model. Whether or not WQM input will be
exercised in the next round of Pennsylvania permits depends on the
resolution to these questions.
NPDES permitting has been discussed extensively by citizens and special
interest groups in the WQM municipal and industrial discharge subcommittee
of the WQM Study Committee. Since the subcommittee has had difficulty
in becoming focused in its discussions, specific recommendations (e.g.,
identification of new permit needs or changes in permit requirements) have
not been made. Local elected officials have not been active in this area.
Conclusions
The lack of sampling data due to weather conditions and the delay in the
development of a State model have led to a steadfast call from the Delaware
Valley Regional Planning Commission WQM staff for a time and funding.,
extension for the Philadelphia WQM project. This request has filtered
out to local officials who are also beginning to pick up the call in fear
that they may be burdened with an inadequate plan. Since the data to be
generated through the State model will affect many components of the final
WQM plan, the question of extending the WQM project may have far-reaching
consequences in terms of plan implementation.
DV-7
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The lack of active involvement of local elected officials in the WQM
planning process may also create a problem at the time of final plan
review. Local governments are not going to accept something which, to
their eyes, even vaguely resembles a regional dictate. Yet, DVRPC1s
decision not to attempt to direct local officials involvement in.WQM
planning was probably reasonable given the multitude of numbers involved.
But DVRPC must make a concerted effort between now and the time of plan
approval to communicate to local officials the costs and.benefits of the
WQM.plan. Even after approval (which should not be too difficult to
secure), DVRPC must work hard to convince these local officials to act
on plan suggestions. Finally, DVRPC must hope that local communities
will rely on the WQM plan as good technical advice that is worth taking.
Affiliation of the WQM project with Pennsylvania's COWAMP planning program
should also work to the benefit of the WQM plan. COWAMP has strong
State support and has gained the respect of many municipalities.
This factor in particular makes the outlook for implementation of at least
the planning recommendations of the WQM plan look bright, especially in
facilities-related work where the State has already required all local
sewer plans to be consistent with the final WQM plan. EPA has also
offered support in this area in that it is delaying some facilities grant
decisions until the WQM plan recommendations can be taken into consideration.
In the areas of urban storm runoff, it appears that most of the plan
recommendations will involve non-structural voluntary approaches to problem
solving. How effective these solutions will be remains to be seen.
Funding, as usual, will be crucial to all implementation.
DV-8
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3 st. Souis
East-West Gateway Coordinating Council
East-Nest Gateway Coordinating Council began its WQM planning in
January of 1976, and is scheduled to complete its final plan in
December of 1977. The total grant amount for this project is
$2,243,000. The designated planning area encompasses 2,713 square
miles, and according to the 1970 Census, has a population of
1,827,635 people. This area was selected for study because of
its complex urban-industrial pollution problems.
Urban Storm Runoff
Studies of the Merimac River (conducted prior to the WQM project) identified
urban storm runoff as a major source of water pollution in the St. Louis
region. The existence of this problem is widely recognized by communities
throughout the WQM designated area. The State liaison from the Missouri
Department of Natural Resources and the EPA Regional Project Officer felt
that the two year WQM planning period provided sufficient time for the East-
West Gateway Coordinating Council to define the extent of pollution caused
by urban storm runoff. None of the interviewees felt that the WQM planning
agency has enough time to thoroughly define appropriate solutions and
ensure their complete implementation. The WQM Project Director thought it
was only enough time to "scratch the surface" of the problem.
EWG-1
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Data collection efforts by the St. Louis WQM agency should provide the neces-
sary data for determining initial alternative solutions to the problem. Addi-
tionally, the St. Louis Metropolitan Sewer District (MSD) which serves all
of the City of St. Louis and portions of St. Louis County, is concurrently
conducting a one-half million dollar study (independent of WQM planning) of
urban storm runoff in its service area. This study will assess the cost of a
computerized stormwater storage system which retains high stormwater flow
within the pipes for later treatment rather than discharging untreated
overcapacity flows. The interim outputs were considered only peripherally
useful in identifying the urban stormwater runoff problem. Population and
land use projections and required treatment levels provided a base from
which to judge future impacts, however, they did not contribute to actual
identification of the problem. This work should provide useful information
in terms of alternative methods and costs of decreasing pollution from
urban storm runoff for selected areas of the WQM study.
The solutions to the urban storm runoff problem however are expected to
come in the form of locally regulated practices such as street sweeping,
construction practices and pesticide/herbicide controls, especially in
priority areas where the WQM study shows the problem is most serious. One
citizen commented -that enforcement of existing ordinances in certain areas,
would contribute to the elimination of urban stormwater runoff.
All interviewees were uncertain, however, as to how much pollution from
urban stormwater runoff would be eliminated as a result of WQM planning.
This is attributed partially to the early stage of the St. Louis WQM
planning process as well as the state-of-the-art of stormwater management
controls (which is not capable of accurate prediction). An appointed
official added that national coordination among metropolitan areas is needed
in order to expedite the development of solutions to common urban storm
runoff problems. All interviewees looked forward to WQM plan implementation
on a step-by-step basis. Some felt that small parts of the plan (e.g., con-:'
trolling activities on small watersheds or testing a model ordinance) may
materialize before final plan completion.
The interviewees expected a variety of implementation barriers to arise along
the way. The WQM Project Director stated that insufficient data to verify
the nature and extent of local problems and the failure of the state-of-
the arts to provide a sound basis for recommendations would make it difficult
for the WQM agency to promote plan implementation. The State liaison thought
that coordination among the large number of municipalities in the St. Louis
WQM area would complicate WQM implementation. One citizen felt that cost
would be the major barrier, while another thought that acquisition of legal
powers to implement WQM recommendations would be a problem. The appointed
official noted that public education was paramount to facilitate plan
implementation.
EWG-2
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Citizens and local elected officials have been involved in the WQM process
through advisory committee meetings and workshops. The WQM Director
reported that citizen involvement has been somewhat limited but nevertheless,
useful in terms of keeping the WQM staff sensitive to local needs. Citizens
commented on the frustration of no.t being more involved in the early stages
of the decision-making process and of being asked to review alternatives
rather than to help the WQM staff develop them throughout the planning pro-
cess. Some of this frustration appears to be due to the nature and reality
(money and time constraints) of the planning process; however, it continues
to be a source of discontent for the members of the Citizens Advisory Com-
mittees . The citizens requested and will receive more data on the River Des
Peres in order to consider alternative strategies. This appeared to be an
example of the agency's responsiveness to input from citizens in the consider-
ation of additional alternatives even if after initial alternative development.
The degree of local elected officials participation in the WQM project
varies among political jurisdictions. The less active areas (i.e-, St.
Charles, St. Louis County and St. Louis itself) tend to be more urbanized.
An appointed official felt that other interests predominate over water quality
in these areas while water tends to be a more singularly important concern
in less urbanized places.
In addition to St. Louis's ongoing coordination with the Missouri DNR, the
WQM agency has established contact with the State Water Pollution Control
Board on a monthly basis. This Board will be providing major input to the
Governor on WQM plan approval or disapproval. Both avenues of coordination
with the State should facilitate plan approval at that level.
The State role has been primarily one of technical assistance, review and
coordination among designated WQMarea.s. The State has developed an
interdepartmental committee at the State level which reviews outputs from
all WQMs in Missouri. The three designated WQM agencies also coordinated
with each other and divided responsibilities for a statewide legislative
review.- At this time, no statewide regulatory program is being developed.
The State and the designated WQM areas appear to favor developing enabling
legislation where needed for local authority to implement the WQM plans.
EPA's role has been primarily administrative, according to the WQM Project
Director. Relations appear smooth and cooperative.
EWG-3
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Facilities-Related Plan Elements
The interim outputs of the St. Louis WQM project were submitted to EPA
on February 25, 1977. Consequently, most interviewees felt it was too
early to comment on their influence on local facilities planning.
In the future, however, most interviewees expected the WQM plan would guide
facilities construction decisions. WQM planning was already seen to have
made progress in promoting coordination of facilities among communities
previously opposed to cooperation. Although political barriers still
exist in certain areas, most people were confident of making progress
toward achieving WQM objectives because of the increased willingness
to coordinate locally.
The Role of WQM Planning in the NPDES Permit Process
The State of Missouri is responsible for NPDES permitting the St. Louis
area. Although few permits will be reissued in 1977, the State'liaison
noted that most permits will not be reissued until 1979-1980. The WQM
Project Director was uncertain how much the State would use WQM input.
The EPA Project Officer thought the influence of the WQM plan in
permitting would be minimal in 1977, but that the State would probably
consult the plan more directly in reissuing later permits. Most interviewees
had not given much though to this issue.
Conclusions
The St. Louis WQM project is progressing on schedule and appears to have
a variety of active interests involved in the planning process. Many
interviewees also commented on the excellent work done by the two consulting
firms (technical and management) hired for WQM work.
Urban storm runoff is a priority concern in the Merimac and other smaller
streams in the area because of the recreational value of these waters.
Although most people feel that the two year WQM planning period is adequate
to define the urban stormrrunoff problem, some think it is only enough
for a start. Additional work and refinement of solutions will probably
be necessary after the planning period.
A variety of barriers to implementation are expected but according to the
WQM Project Director, all of them normally accompany a planning process
which advocates change on a large scale. The St. Louis WQM staff appears
to have a clear understanding of, and is working to remove the obstacles
to implementation of the WQM plan. The major source of discontent with
EWG-4
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the project was vocalized by citizens who felt that they were not included
in the earliest stages of the development of alternatives. In one way,
this speaks highly for the planning process in that a high level of citizen
participation has been aroused. The frustration of including a variety
of strong interests is being experienced, rather than the difficulties
trying to attract citizens to participate throughout the process. Most
interviewees were hopeful that the WQM plan would guide future facilities
construction decisions. Little thought have been given to the influence
of WQM on the next round of permitting.
EWG-5
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4 houston-gaiveston
Houston-Galveston Area Council
Houston-Galveston began its WQM project in June of 1975 and is
scheduled to complete its final plan in June of 1977. The
total• grant amount of this project is $1,798,300. The desig-
nated planning area encompasses 2,450 square miles and, accord-
int to the 1970 Census, has a population of 1,905,961 people.
This area was selected for study because of a unique combination
of urban industrial problems. Greater Houston is experiencing
intense and rapid growth in a political climate which has been
traditionally apposed to planning and land use controls.
Urban Runoff
Water studies conducted prior to the WQM program in the Houston-Galveston
area suggested that urban runoff was a major problem in the region. Since
a thorough assessment of the problem was lacking, the Houston-Galveston
Area Council (H-GAC) made urban runoff the first priority in its WQM
project. The WQM Project Managers,^ an EPA Region VI official and a State
water quality agency official feel however that the two year period for
the study will be inadequate to complete a comprehensive study of urban
runoff. First, available data was inadequate, thereby forcing H-GAC's
current analysis to essentially "begin from scratch". Second, no money
was approved for sampling. Thus, H-GAC has had to depend on literature
coefficients for an analytical basis. The WQM Project Managers expect
the final plan to generally indicate problem areas and show the need for
data verification after the initial planning period terminates. The State
water quality official interviewed concurred on this viewpoint.
H-GAC has two Project Managers. One is primarily concerned with technical
elements of the project, the other with overall project administration.
Although the latter assumes lead responsibility, the two Managers work
together closely on all project matters.
HGrl
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Currently, the H-GAC is at the stage of identifying the urban runoff problem.
The nonpoint source consultant is just completing a first-cut assessment
of urban runoff loads on a watershed by watershed basis. All persons
interviewed felt that the population projections and land use maps prepared
as part of H-GAC1s interim reports were most valuable to the urban runoff
study. Also included among H-GAC's interim reports is a catalog of avail-
able nonpoint source strategies and their unit costs. Since this catalog
represents a general listing of available technologies rather than a
list of site-specific alternatives, local elected officials and citizen
interviewees criticized EPA and the State for wasting Houston's WQM money
on a state-of-the-arts inventory that could have been sponsored by Texas
WQM programs on a statewide basis or by EPA itself on a nationwide basis.
In conducting its urban runoff study, the WQM Project Managers are attempting
to provide local decision-makers with all the costs and benefits of plan
alternatives. In this way, the WQM project hopes to help local communities
determine the value of tradeoffs to be made within the context of certain
parameters (e.g., water quality standards) set by the State and EPA.
Because of limited water quality data and analysis, the WQM Project Managers
anticipate that few new controls or management arrangements will be
instituted at the local level. Without verified data to demonstrate water
quality improvement benefits and support recommended strategies, the WQM
Project Managers see the need for a more thorough study before implementa-
tion can begin. They believe less than fully documented measures would be
premature and potentially hazardous to the political acceptability of the
entire WQM plan. Hence, they expect the two-year WQM study to provide
some incentives toward utilizing existing but currently unexercised authority.
For example, county erosion controls have yet to be fully implemented.
Interviewees at the local level had mixed expectations about the form
recommended solutions may take. Most believed that regulations would be
necessary (e.g., development controls) but doubted that any regulatory
program would be acceptable to area officials. A citizen noted that only
EPA or State enforcement would constitute the authority sufficient to
overcome local political forces which favor uncontrolled development.
As the H-GAC is only beginning to define the problem, the various advisory
committees have not been discussing the urban runoff problem except in
general terms. Most persons interviewed believed the committee structure
(e.g., the Citizens Advisory Group with its nonpoint source subcommittee,
HG-2
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the Technical Advisory Committee and Planning Advisory Committee) would
provide a mechanism for their participation once alternative corrective
measures are formulated. Similarly, although local elected officials
currently were not believed to be sufficiently active, H-GAC hopes to
stimulate their increased.interest and involvement through discussions with
officials serving on the Planning Advisory Committee and the H-GAC Executive
Board. The WQM Project Managers noted that H-GAC has been working closely
with other local water-related planning programs. In the case of flood
plains, the WQM Managers are channeling available water quality data into
the flood plains study in order to effect water-related elements of that
plan. The WQM Managers feel that even though WQM data does not constitute
a sufficiently refined basis for drawing WQM suggestions, it is valuable
for related planning efforts. Using it in such studies may give credibility
to the WQM study and further promote interest in the plan.
The State's participation in the H-GAC WQM study has consisted largely of
providing technical assistance in program development, coordination of H-GAC
efforts with State WQM planning in non-designated areas, and a methodology
for examining the impacts of urban runoff loads. The State also received
funds from H-GAC for developing the urban runoff models. Although data
generated by the State model will be of use to the Houston WQM study,
the WQM Project Managers believed the state model could have been more
useful if H-GAC had been given an opportunity to adjust the model to
specific needs and conditions in the greater Houston area.
A State water quality official expected the State's future role in correcting
the urban runoff problem would depend upon the as yet undefined nature
and extent of the problem. Currently a team of three State agencies are
involved with WQM planning: the Texas Water Quality Board (TWQB), the
Texas State Soil and Water Conservation Board (SWCB),•and¦the Office of
Special Advisor to the Governor on Natural Resources. The SWCB is concerned
with nonpoint source planning in non-designated areas and overall coordina-
tion while the Governor's Special Advisor is primarily concerned with coordin-
ation. The TWQB has lead responsibility for monitoring and reviewing WQM
planning in designated areas. This arrangement appears to have worked well
and is' expected to continue in the future.
By agreement between the TWQB and EPA, the TWQB was named the lead agency
for reviewing and monitoring WQM planning in designated areas. As a result,
the EPA Regional Office has assumed a somewhat more passive role in con-
ducting secondary reviews of the WQM project.
HG-3
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Facilities - Related Plan Elements
A great deal of wastewater treatment facilities planning was initiated in
the Houston-Galveston area prior to the beginning of the WQM project.
The H-GAC will have little if any effect on these plans which it is
basically incorporating without revision into the WQM plan. On the other hand
hand, the WQM plan is expected to have some effect on future facilities
planning through the H-GAC1s role in the A-95 review process. In re-
viewing facilities grant applications, the H-GAC will consult the interim
population and land use reports and eventually the completed WQM plan
for consistency. A State water quality official noted furthermore that
the State will also review construction grant applicants according to
criteria developed by the H-GAC WQM study. The final weight of WQM plan
recommendations, however, is still expected to be overshadowed by
the power of local wastewater treatment management agencies which are
already firmly entrenched in most areas.
Since management analysis has begun only recently, interviewees could
speculate only about potential management systems. The WQM Project
Managers believed several alternatives would be explored including
the possibe allocation of management responsibility to existing local
grant recipients with some potential areawide overview provided by an
appropriate form of the H-GAC Technical Advisory Committee.
Local elected officials, citizens and WQM Project Managers noted that
developing an acceptable management scheme for wastewater treatment will
be difficult. Because the interviewees anticipate opposition to creation
of a new management agency, they expect the WQM plan will recommend that
a consortium of existing local management agencies be developed. Even in
a consortium arrangement however, local interagency politics and self-
interests are expected to limit the effectiveness of a regional approach
to management.
To date input of officials and citizens to facilities related plan elements
has been limited to discussions of population and land use projections.
This participation has been through the Advisory Committee structure.
A Citizen Advisory Group (CAG) member noted that the relationship between
the CAG and the H-GAC has improved, greatly with each understanding its
role in relation to the other. He also believed the H-GAC Executive Board
and Planning Advisory Committee have recognized the responsible commitment __
of the CAG and in that light value CAG input. As with citizens, elected
and appointed officials have discussed the facilities related plan elements
(e.g., population and land use projections). Eventually their A-95 review
activities will rely on the approved WQM plan.
HG-4
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Role of WQM Planning in the NPDES Permit Process
Although the H-GAC wanted to have input to NPDES permitting, EPA Region VI
did not consider H-GAC's review of permit applications as an allowable cost
under WQM funding. Consequently, as of last year, H-GAC is no longer re-
viewing permit applications. The WQM Project Managers noted that H-GAC
was submitting a proposal to EPA for funding NPDES permit reviews. Even
without H-GAC's review of permits, the WQM Project Managers believed the
approved WQM plan would be considered by the State and EPA in future permits.
There is a duplicative permitting system in the State of Texas. Each permit
requires separate reporting applications and hearings and each is based on
a separate set of criteria. State issued permits are based on stream
standards which reflect present use classifications. EPA issued permits
disregard stream standards and are based on "Best Available Technology". The
EPA approach is considered more stringent by local interviewees.
An appointed official, an industrial engineer, a citizen.interviewee and
an elected official voiced common criticism of this duplicative system.
They were hopeful that the WQM plan would influence the situation. In
particular, they hoped EPA would incorporate stream standard considerations
in its permitting system. They cited some of the following arguments:
• The cost of meeting BAT requirements is not justified where
uses preclude the possibility of achieving clean water
(e.g., in the Houston Ship Channel).
s It would be more equitable to include local opinions and
values in the permitting process.
Conclusions
Defining the urban runoff problem will consume most of H-GAC's allotted
resources within the planning period. The lack of available data, the
problem's analytical complexity and the use of literature coefficients
rather than actual sampling data comprise the major reasons for expecting
H-GAC's analysis to achieve only general indicators of the problem's
magnitude. Based on the general assessments, H-GAC may push for some minor
action but will not propose major implementing measures within the planning
period. Both the State and H-GAC agree that verifying data and developing
appropriate strategies will be tasks following the initial planning period.
It is not determined how these activities will be funded.
HG-5
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It is the intention of the H-GAC's WQM planning effort to establish an open
process which flexibly adapts to changing conditions, new information and
perhaps most importantly, to the preferences of local decision-makers.
With such a WQM planning process, H-GAC has committed itself to thorough
study of the urban runoff problem prior to proffering alternative imple-
menting measures. Although this is a cautious approach to problem cor-
rection, the planning strategy may constitute the most politically sensitive
and pragmatic approach given the area's traditional opposition to imposed
controls and general anti-planning attitudes. By basing recommendations
on well-documented information, H-GAC hopes to maintain a level of credibility
essential to gaining areawide confidence in and support of their planning
efforts.
The emphasis on gaining credible data prior to developing alternatives
somewhat precludes the more active involvement of area officials since it is
difficult to gain the attention of officials in the data analysis phases
of the process. Although the highly active Technical Advisory Committee
members recognize the massive scale of the area's urban runoff problem,
at this stage the local decision-makers are not believed to appreciate the
value of problem correction. To gain local support for continued planning,
H-GAC is attempting .to channel information toward more visible implementing
measures.
The WQM project will not have sufficient data and analysis ready in time
to develop detailed recommendations in the final plan. The WQM plan
therefore will be limited chiefly to general proposals for future action.
However the WQM Project Director feels that the project will produce some
useful data which should be used to influence water quality even before the
final WQM plan is completed. The project staff is therefore making WQM
data available to a concurrent flood plains project being conducted in the
area. In this way, the WQM project is influencing water quality and gaining
credibility for the WQM planning effort at the same time.
It is highly unlikely that the WQM plan will effect current facilities planning.
Since strong management arrangements are already established at the local
level where facilities planning is not underway, it is also unlikely that
the WQM plan will significantly effect future planning decisions. Despite
the validity of a regional overview for management purposes, the self-
interests of the several existing authorities may work against an effective
consortium arrangement and even more so against a single regional entity
with enforcement powers. The feasibility of a regional management forum
would depend seemingly on the sanctions provided by EPA and State regulations.
HG-6
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It is not clear what impact the H-GAC WQM study will have on NPDES permitting.
Without ongoing input by reviewing NPDES permits, H-GAC's impact likely
will be delayed until the WQM plan is approved. By the time the plan is
approved, the second rounds of permits which will be effective into the
early 1980's will have been issued. Although State permits may be modified
to accommodate H-GAC final recommendations regarding stream standards,
the independent EPA permits currently have no such provision. Consequently
the dischargers will have to meet the more stringent effluent limitations
which in some cases may mean "cleaning up too much", in local opinion.
In addition, EPA and State officials should be encouraged to explore and
negotiate with H-GAC the available options for H-GAC1s ongoing input to
reviews of NPDES permits to foster consistency and development of the most
efficient and equitable approach.
HG-7
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ower rio
Lower Rio Grande -Valley Development Council
The Lower Rio Grande Valley began its WQM project in June of
1975 and is scheduled to complete its final plan in June of
1977. The total grant amount for this project is $775,000.
The designated planning area encompasses 2,515 miles and,, ac~.
cording to the 1970 Census, has a population of 283,025 people.
This area was selected for study because of its extensive
agricultural activities and because it supports a wide mix
of economic activities which affect water quality.
Irrigated Agriculture
The economy in the Lower Rio Grande Valley is dominated by irrigated agriculture.
The area is, therefore, interested both in water quality and water quantity for con-
tinued irrigation use. The local residents were aware of a local water pollu-
tion problem, but until the advent of the WQM project, the extent of
irrigated agriculture's effect on water quality in the Lower Rio Grande
Valley had not been measured. A WQM consultant began such a study with a
sampling program in November 1976. Although the Lower Rio Grande Valley
Development Council (LRGVDC) expects to complete an analysis of the problem
within the two-year planning period, the WQM Project Director, the EPA
Regional Project Officer and the State water quality agency liaison all feel
that time and funding constraints will necessarily limit the study effort.
The WQM study will supply initial data but verification and control strategies
will be needed beyond the present planning phase. The State liaison added
that responsibility and resources for carrying on future study needs
have not been determined. Determination of the problem will depend on
what stream standards are set. If locals determine stream standards, it
is likely that standards will allow for the continuation of irrigated agri-
culture practices. If the State disagrees on this input, a conflict may arise.
LRG—1
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The interim outputs have been useful to the study of irrigated agriculture.
In particular, population projections and distributions have been used
with land use projections to estimate the future expansion of cities and
the conversion of prime agriculture land for development purposes. These
land use projections will be coupled with water quality data to estimate
the wasteload contribution by irrigated agriculture. Because of agri-
culture' s importance to the Valley's economy, the Policy Advisory Committee
is particularly concerned with this aspect of the WQM study. The State
Soil and Water Conservation Board also is carefully reviewing LRGVDC's
outputs to ensure that pollution loadings attributed to agriculture are
well-documented. Recognizing these local concerns, the WQM Project Director_
noted the difficulties of accurately projecting migrant worker and winter
resident populations.
As the nonpoint source analysis is just getting underway, interviewees
could only speculate on likely plan recommendations. The WQM Director
and other local interviewees noted that, if irrigated agriculture proves
to be a significant water quality problem, it will be' difficult to find,
locally acceptable solutions. Many of the local interviewees felt that
the Valley historically has practiced careful irrigation practices due
to the area's shortage of water. They were doubtful that' the WQM study
would significantly affect agricultural practice although they could:
® Identify problem areas;
e Investigate practical techniques for improved irrigation
management;
• Provide information/education regarding conservation of
irrigation water (e.g., applying the minimum amount of
irrigation water results in a lower volume of runoff);
• Promote a better understanding and tolerance of the respective
problems of the cities and rural areas.
Two most frequently mentioned obstacles to plan implementation are local
opposition to land use controls and potentially adverse economic impacts
of controls on agricultural productivity. One local official was particu-
larly concerned about controlling the use of pesticides and insecticides
for water quality'purposes. He explained that such controls might decrease
yield per acre but that yield per acre must increase as development pressures
compete for the Valley's prime agricultural land. Hence, controls affecting
yields per acre have community-wide as well as individual impacts and
necessitate a cautious approach.
LRG-2
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Where the WQM study indicates that some action must be taken, the interviewees
felt, that the locally most acceptable approach would be a voluntary/educational
one. The EPA Project Officer and State Water quality official also expected
that follow-up regulatory practices might be needed in the future. These
would come about only if the State or EPA impose such a program.
Implementation of plan elements related to irrigated agriculture is not
expected until the final plan is completed and approved. Generally, all
interviewees agree that more time is needed to verify data, develop ,
appropriate techniques, institute educational programs and, finally, to
gain public acceptance.
The citizens' role in the WQM process takes place through the Policy Advisory
Committee (PAC). Although local interviewees feel that the discussion of
irrigated agriculture has been of a cursory and general nature to date, they
believe the PAC will become more focused on the issue when the nonpoint
source report is completed. At that time the WQM Director expects to involve
agricultural interests more heavily in the WQM program. At the present,
however, the ,most active PAC members are the municipal appointed officials-
and water district representatives.
The primary avenue for participation of local elected officials is the
LRGVDC Executive Board. At this level, elected officials review technical
¦reports and hear PAC and WQM staff presentations. Local interviewees
believe that local elected officials have generally given little attention
to the WQM project. The level of interest is expected to rise, however,
when the nonpoint source report is issued.
State participation in the WQM program involves a team of three agencies:
the Texas Water Quality Board (TWQB), the State Soil and Water Conservation
Board and the Office of Special'Advisor to the Governor on Natural Resources.
The TWQB has assumed responsibility for overseeing designated WQM planning.
According to a TWQB official, TWQB's role is to ensure that State.water
quality objectives are met and to assist with development of studies to
adequately define the area's water quality problems. The State Soil and
Water Conservation Board has primary responsibility for reviewing nonpoint
source-related planning elements. Because the irrigated agriculture issue
is somewhat unique to the Valley, coordination with the other designated
WQM projects has not been appropriate.
LRG-3
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EPA participation in LRGVDC efforts consists largely of precedural review,
some technical assistance and PAC representation. EPA, through a formal
arrangement with the TWQB, follows the TWQB's lead in reviewing and monitor-
ing WQM planning.
Facilities-Related Plan Elements
All interviewees expected the completed and approved WQM plan to be useful
in future facilities planning decisions. The population projections gen-
erated by the WQM effort are expected to be helpful to local governments,
particularly in providing a common data base. A State water quality official
noted that the projections would be used to verify local applications for
construction grant funds.
WQM population projections and distributions were approved only after some
controversies among agencies which will be using these figures in facilities
•planning. The cities were concerned that the WQM population projections/
distributions to be used in facility planning be based on the cities'
expressed growth policies and preferences. Otherwise, facilities decisions
could rigidly commit the cities to incompatible and inflexible .land use
patterns. Further difficulties had emerged in projecting the winter resident
and migrant worker populations and in questioning the 'assumption about
the maintenance or growth of the substandard settlements ("colonias")
of poor migrant workers.
Since the LRGVDC has only recently begun management planning, interviewees
could speculate only about likely approaches. Although a number of options,
including regional, sub-regional, and local management will be explored,
all interviewees expected stiff resistance to regional management systems
in favor of retaining local control. All interviewees expected the
Valley's prevalent attitude for local autonomy to work against regional
efforts even if regional system should emerge as more efficient and less
costly options.
Role of WQM Planning in the NPDES Permi *¦ ProceW
The interrelationship of the WQM plan and NPDES permits has not been defined.
The WQM Director hopes the WQM plan will influence future permits, particularly
by basing permit conditions on locally established stream standards. The
TWQB, however, has final authority over stream standards and, according to
an EPA Region VI official, the extent to which the WQM plan will affect those
standards is an issue not yet resolved. A TWQB official expected the WQM
LRG-4
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plan to have some influence and noted that the State is currently developing
a strategy for considering WQM plans in the KPDES permitting procedure.
To date, there has been no discussion among local officials or citizens
regarding NPDES permitting. One official and two citizens expected the
WQM plan to exert only limited incluence. They also noted that officials
did not seem to regard permitting as an area of great concern. No one
expected the WQM plan to have any impact on permitting at least until
after the plan is completed and approved.
Conclusions
LRGVDC's approach to the WQM problems related to irrigated agriculture is
a cautious one. Until the magnitude of pollution contributed by irrigated
agriculture is documented, LRGVDC does not expect the issue to attract
substantial local concern. To prematurely arouse local interest groups
with only a speculative assumption of an undocumented problem could work
against the credibility of LRGVDC and the overall WQM plan. With the
completion of the nonpoint source analysis, the irrigated.agriculture
problem can be the subject of well-focused discussion among interest groups
and officals. Even at that stage, LRGVDC recognizes that the initial
analysis will require data verification prior to considering appropriate
corrective measures.
Both LRGVDC and the State expect data verification and development of
alternatives will occur after the initial funding period. Funding for such
activities is still uncertain. Since local officials apparently have not
recognized the value of an ongoing WQM planning process yet, they appear
unwilling to make local funding commitments at this time. In addition,
local resources in this economically depressed area are limited and other
competing concerns may have a higher priority. It would seem that Federal
funds are essential to carrying the local WQM planning process to some
fruition; alternatively the State may assume responsibility for the tasks
of the ongoing planning period.
The greatest achievements of LRGVDC's irrigated agricultural study will
probably be found in the increased data base and educational programs.
By highlighting the economic advantages of better irrigation management,
LRGVDC is helping to realize the area's water quality objectives and the
valley's efforts to conserve its limited water supply.
LRG-5
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LRGVDC planning efforts related to facilities planning already have a
locally acknowledged value in providing a common data base to the valley.
By working through the somewhat controversial population projections and
allocations, LRGVDC has achieved local consensus and State concurrence re-
garding growth expectations related to facilities planning. In the manage-
ment planning area, LRGVDC will have to contend with local resistance to
regional or sub-regional systems. It is doubtful that local officials
would accept any proposals for regionalization due to traditionally held
attitudes of local autonomy.
It is not clear how the LRGVDC WQM plan will receive State consideration
in future NPDES permits. As the plan will not be completed until 1978,
the State permitting process will be affected only after that time and
only to the extent LRGVDC data is believed sufficiently documented.
LRG-6
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6 martha's vineyard
Martha's Vineyard Commission
Martha's Vineyard began its WQM project in June, 1975 and is
scheduled to complete its final plan in September, 1977. Be-
cause of an EPA Region I requirement to conduct an Environ-
mental Impact Statement on the final plan and because of the
time needed for review of the EIS, it. is anticipated that the
WQM planning project will not end officially until December,
1977. The designated area, encompassing the entire Island
(approximately 100 square miles), has a year-round population
of 7,500 people which swells six to. ten times in peak summer
tourist months. The total grant amount"is $216,000. The
Island was designated for WQM planning because of a concern
for preserving the present water quality and to provide water
quality planning inputs into decisions of the Martha's Vine-
yard Commission (a unique regional land use authority) . On-
lot disposal is the Island's major threat to water quality.
On-Lot Disposal
All of Martha's Vineyard waters currently are classified "A" by the State
of Massachusetts. For some time, however, conservationists have suspected
that on-lot disposal systems were threatening the Island's groundwater
drinking supply. Approximately 90 percent of the Island depends on septic
systems yet most of the Island's soil is too sandy for proper percolation.
Continued high density growth and development without improved wastewater
disposal practices could jeopardize the Island's future.
The Martha's Vineyard WQM project chose to concentrate its energies on
nonstructural solutions to the on-lot disposal problem because:
• WQM water quality sampling showed septic systems were
already causing abnormally high nitrate levels in local
groundwater;
MV-1
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© On-lot disposal is the only source of water pollution
on the Island not mitigated by natural processes (e.g.,
flushing of harbors, etc.); and
• An environmental impact assessment process on proposed
expansion of the Edgartown wastewater- treatment system
(the only facility on the Island) was already underway,
but no concerted efforts were being made to investigate
nonstructural options.
The WQM Project Director had hoped to test alternative on-lot disposal
designs and maintenance systems over the two year period, but time and
budget constraints forced him to rely more heavily on existing literature
and partial testing on location. Although the existing data provides
sufficient information for initial plan recommendations, the Project
Director still feels there is a need to continue the study beyond the
two year timeframe to locate faulty systems, to identify appropriate
remedial actions (e.g., pumping, rehabilitation, replacement, etc.),
to select best design specifications for new systems, and to develop
detailed maintenance programs for all current and future systems. The
EPA Project Officer agreed with the Project Director, especially in
regard to the need to locate faulty systems and secure implementation
of proposed solutions.
Part of Martha's Vineyard's data problem stems from unsatisfactory popu-
lation and land use projections prepared to meet EPA interim output re-
quirements. The WQM agency contracted with the State for population pro-
jections, but both the MVC and the State, found these projections unsatis-
factory. The State is still in the process of revising its projections.
The absence of this essential base data has severly limited the detail
of any project recommendations the WQM agency can develop.
The MVC has had problems with other interim outputs as well. In the area of
land use projections, the MVC has very little existing mapped data with
which to work. As a result, MVC was limited to making only descriptive
forecasts of future land use patterns. Due to incomplete population pro-
jections and generalized land use projections, the MVC has had difficulty in
completing its wasteload allocations interim output. The WQM Project Director
expects the recommendations on sewer priorities will only be expressed
verbaily.
MV-2
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Despite these problems, the EPA Regional Office has not shown dissatisfac-
tion with the MVC's performance. As far as the WQM Project Director knows,
EPA has accepted the interim outputs and will not require revisions or
additions. The State reviewed the interim outputs and offered some sug-
gestions for revision but made no mention of a need for official State
approval. Since the Citizen Advisory Committee was abandoned, the public
was never asked to review and/or approve the EPA required interim outputs
(see Areawide Water Quality Management Survey, October, 1976, pp. MV7-8
for discussion on CAC).
Based on information currently available, the WQM project is suggesting a
three part management plan for on-lot disposal practices. The proposed
plan includes:
• Stricter health codes regulating design and maintenance
of septic systems;
9 A regional inspector to oversee all new installations and
monitor maintenance of those areas which could be a problem
because of density, soil type or depth to water table; and
• Additional soil surveys to guide development of future'
zoning and subdivision ordinances as well as local Board
of Health codes.
These suggestions were first raised in one of the WQM project's interim re-
ports and then developed more fully throughout the course of the project.
According to the EPA Project Officer, the interim reports allowed the staff
to focus their efforts and lay a groundwork for implementation by preparing
communities to hear substantiated recommendations in the final plan.
Most of the Island's attention is now focused on the wastewater treatment
plant proposal being discussed in the EIS process. According to the Pro-
ject Director, however, Boards of Health have been contacted directly by
the WQM agency and have been receptive to the WQM staff's suggestions.
Similarly, local planning boards are now looking to the WQM plan for guid-
ance on controlling future density and locating new development, assuming
that septic systems will continue as the primary method of wastewater ids-
posal.
MV-3
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The Project Director is condifent that the nonstructural approach is the
answer to the Island's pollution problems. Many Islanders feel that
extending sewer lines and expanding current wastewater treatment plants
to meet peak summer toi^rists demand is not economically feasible for the
Island's economy. Thus, more local residents are beginning to support
nonstructural alternatives. The EPA Project Officer agrees with this
sentiment, especially since he views the sewering alternative as an open
invitation to indiscriminate development and subsequent destruction of
the Island's character and natural charm. Citizens interviewed generally
were hopeful about the effectiveness of nonstructural solutions, but added
that.supplementary structural solutions or improvements would be needed in
highly developed areas where stricter septic codes alone will not suffice.
The WQM staff has not waited for the final plan before seeking implementation.
Rather, it has sought to promote implementation whenever staff time and
substantiating evidence permit. On the basis of WQM findings, the Martha's
Vineyard Commission (the regional land use authority and official WQM
designee) issued a series of suggested septic system regulations for new
development in areas of critical environmental concern. These areas in-
clude all land within 500 feet of ocean shoreline and shores of great ponds.
Most towns with critical zones already have reviewed the Commission's
suggestions and have developed their own version of the regulatory tools
recommended, where these regulations involve a change in town bylaws,
public approval at town meetings must be obtained. Where simple changes
in planning tools or health codes are involved, action by the local planning
authority or Board of Health will suffice. If towns within the jurisdiction
of the MVC do not respond to the Commission's suggestions, the Commission
has the authority to impose its recommendations under its regional land
use authority.
Four local Boards of Health already have adopted stricter codes related
to the siting and maintenance of on-lot disposal systems. A number of
towns have shown an interest in the maintenance program suggestions, but
implementation is contingent upon the availability of a receiving disposal .
facility which can treat the septage waste. The Edgartown plant already
has excess treatment capacity except in high demand months, i.e., the summer.
The WQM Project Director mentioned the possibility of adapting the plant
to receive pumped septage wastes thus eliminating the need to invest in
a new system.
Several possible sources of local opposition to the plan were identified.
First, Island .residents on limited incomes may find it difficult to
afford the additional cost of system cleaning. Developers and builders
who profit from high density development also are expected to oppose non-
MV-4
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structural solutions since sewering would allow more development at a
lower cost to the builder. The Project Director is also expecting some
opposition to the recommendation concerning an inspector hired jointly
to service the region. There is already a fair degree of opposition to
the MVC on the grounds of losing local autonomy. One local elected official
interviewed suggested that the WQM staff must convince the Island towns
that better septic system practices are cheaper than sewering. Also, he
felt that sewering-threatens .the Island's character and the continued
prosperity of its tourist economy.
To date, the public has not been involved in the WQM program except through
participation of interested individuals in MVC meetings or through direct
assistance from the WQM staff on septic system questions. Most people,
including the Project Director, recognize the need for Advisory Committees
to help overcome expected opposition. The Project Director called atten-
tion to the fact that the MVC had just hired a new staff person to assume
responsibility for the previously.neglected public participation program.
The Director was very, optimistic about this person's effectiveness and of
scheduled public workshops which the Director hoped to use as forums for
selecting plan alternatives and for generating public advocacy in support
of plan implementation.
Similar to the general public, local elected officials have not been involved
actively in the WQM program at Martha's Vineyard. All persons interviewed
excused this lack of participation by local officials due to competing
demands on officials' time. With the exception of Board of Health officials
(most of whom are appointed locally) who are directly involved with issues
under WQM discussion, most local officials appear to be more interested in
economic development than in water quality per se. In order to reach these
officials, the Project Director has made regular personal contacts with
town councils and individual selectmen to keep them informed of the project's
developments. Some officials are also members of the MVC and can be kept
apprised of new developments through regular progress reports at each meet-
ting. The Project Director is hopeful that these contacts will be suffici-
ent until the final stages of the program when workshops on selection of
plan alternatives will begin. Although workshops are open to the public,
particular emphasis is on attendance by local elected officials. The Pro-
ject Director believes that local officials by the will take a "more
active role in the program. He also expects local officials will continue
to rely on the expert advice of Boards of Health which have been well in-
formed throughout the program.
MV-5
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According to the WQM Project Director and the EPA Project Officer, the
"coordination role of the Massachusetts Division of Environmental Quality
Engineering (the official State liaison to the areawide designated agencies)
is just now beginning to develop. Until now, the State DEQE has not
supported staff recommendations actively nor has the DEQE clarified what
it will require of the program for final plan approval. Recently, the DEQE
notified the areawide agencies that it expects a paper on growth as a
prerequisite to approval of plan elements. The MVC WQM staff was disturbed
by this requirement because it was issued after the agency's first set of .
population projections were completed and the WQM workplan was approved.
Despite these shortcomings, the WQM Project Director hoped the State's
role would be more clearly defined and more helpful in the final stages
of the process.
The Project Director found the regional EPA office, on the other hand, to
be extremely helpful to Martha's Vineyard's WQM program. In particular,
he praised the Region's prompt response to requests for information or
technical assistance as well as their thorough comments in reviewing out-
puts and activities.
Facilities - Related Plan Elements
As mentioned earlier, most facilities-related work at Martha's Vineyard
presently is occurring through an EIS process focusing on the proposed
expansion of the Edgartown wastewater treatment plant and its connecting
sewer system. Only a few areas on the Island are of sufficiently high
density to make a central collection system financially feasible. These
towns are principally those neighboring Edgartown. The EIS process, there-
fore, is nearly comprehensive in its coverage of facilities planning — at
least in the near future.
To date, cooperation and exchange of information between the consulting
engineers conducting the EIS process and the WQM staff has been limited.
Though the engineer did use some WQM suggestions on well locations, the
WQM Project Director was uncertain whether or not other relevant informa-
tion and projections prepared by the WQM staff were used. The WQM Project
Director gave no indication that he expects the role of the WQM project
in the Edgartown planning process to change in the future, but he noted that
his schedule, of nonstructural work leaves him little time or resources to
expand on facilities planning directly. The WQM project is directing its
attention toward promoting nonstructural solutions (e.g., better septic
system siting practices) wherever possible. Should the local communities
choose to support expanded sewer lines, the WQM Project Director suggested
that the WQM plan will encourage a regional approach to management.
MV-6
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Citizens have been more active in the facilities planning process on the
Island than they have been in the past. This has not occurred as a result
of the WQM planning process, however, but rather as a result of the EIS
process and its requirements for public participation. The same is true
for local elected officials who have taken an active interest in the EIS.
The State has not given the WQM agency any indication on how it intends
to use the WQM input in present or future facilities construction decisions.
The WQM Project Director suspects that the plan will have very.little
effect. The EPA Project Officer had a similar impression based on the
traditional lack of active coordination between the DEQE and the WQM agency.
Role of WQM Planning in the NPDES Permit Process
The EPA and the State share responsibilities for NPDES permitting in
Massachusetts. Currently, there are only two industries operating under
NPDES permits at Martha's Vineyard. The WQM planning process did uncover
the need for permitting another point source discharger and presently is
trying to bring this need to the attention of EPA and the State. The WQM
plan will also recommend that the State examine a number of MVC permits
for land disposal operations to determine whether additional NPDES
permitting is required. The WQM Project Director expects the EPA Regional
Office to be receptive to WQM recommendations.
The WQM Project Director views the role of the WQM program, in NPDES permit-
ting primarily as a matter of educating the public about the existence
of the permitting system and identifying the need for additional permitting
where appropriate. At the time of interviews, none of the citizens or
local elected officials were aware of the NPDES permitting process.
Conclusions
The Martha's Vineyard WQM project has made noteworthy progress in dealing
with the Island's existing and potential on-lot disposal problem. The
project staff has assembled base data on water quality, soils, etc.,
which were sorely lacking until the project began. This base data will
be helpful not only in identifying and remedying current groundwater pro-
blems but also in planning for environmentally sound growth in the future.
The WQM project has already convinced several local Boards of Health to
adopt stricter septic system codes. A number of towns are also considering
MV-7
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a septic system maintenance program which the WQM staff is espousing.
These achievements have been accomplished despite a limited public edu-
cation program, the absence of an active Citizens Advisory Committee and
a lack of State support for nonstructural solutions to wastewater disposal.
Although the WQM Project Director has been effective through reliance on
personal contacts with local elected and appointed officials, the absence
of a meaningful public participation program may hurt the WOM program in
the long run. .Successful continuation of the WQM process will depend on
active local interest and support. This support will be difficult to
muster if the WOM program does not increase its public education efforts
soon, and if it does not bring the public and local elected officials
actively into the process. Water quality concerns are already in com-
petition with economic development interests. There is a need to convince
Islanders that economic prosperity is directly tied to preservation of
water quality and that action must be taken now to insure that the water
can be protected. Furthermore, the Island towns are strongly opposed to
perceived threats on local autonomy. Some towns are already dissatisfied
with the MVC's regional approach in designating "critical districts" which
are subject to special MVC authority. The association of the WQM plan with
the MVC may hurt the plan's chances for local approval. Unless these com-
munities become actively involved in formulating plan recommendations,
implementation of plan elements will be delayed and possibly rejected,
especially if the Project Director leaves for any reason, taking with him
the personal trust and credence he has instilled in the program.
The Martha's Vineyard WQM project has recognized these problems and,
despite a limited budget, has hired a full-time public participation
staff person to reactivate the WQM Citizens Advisory Committee and to
coordinate more public education programs (e.g., workshops, news releases,
etc.). How effective these efforts will be within the remaining few
months of the WQM project remains to be seen.
As to the likelihood of State approval of the final plan, the MVC has al-
ready encountered-problems. The State is demanding that, before plan
approval, the WQM program produce a paper analyzing the factors affecting
growth. The growth paper was not a part of MVC's initial contract with the
State nor was the paper included in MVC's workplan. Given the project's
limited budget and timeframe it will be difficult for the WQM project to
meet this requirement and to obtain State approval. Approval from EPA is
more likely since the WQM Project Director has received few indications of
dissatisfaction to date.
MV-8
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As to the relationship between current and future facilities construction
decisions and WQM plan recommendations, the WOM staff has already made
informal input into a current construction decision on the Island in the
form of information exchange between the WOM staff and the engineering con-
sultants conducting an environmental impact assessment on the proposed
expansion of the Edgartown wastewater treatment system. The value of
this information exchange is questionable, however, since the WQM Project
Director could offer no proof that the WQM data actually was used by the
consultant. As to future decisions, the Project Director and EPA Project
Officer believe that WQM projections and suggestions would not be heeded
unless they agreed with State projections. Since the State has not act-
ively supported nonstructural approaches to date, the WQM project will
have to work at convincing local communities that septic systems can be
as effective and more economical than sewering.
The NPDES system is not a significant issue on the Island since there are only
two active permits at this time and little foreseeable need for more per-
mitting in the near future.
MV-9
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7 clayton
Miami Valley Regional Planning Commission
The Miami Valley Regional Planning Commission began its
WQM project in June of 1974 and is scheduled to complete
its final plan in June of 1977 . The total grant amount
is $1.5 million. The Miami Valley area encompasses 2,300
miles and, according to the 1970 Census, has 901,672 people.
This area was selected for study because it is a complex
urban and industrial area reported having a "pro growth"
climate.
Urban Runoff
The Miami Valley Regional Planning Commission (MVRPC) has encountered
difficulties in its analysis of the area's urban runoff problem. All
interviewees expect these difficulties will limit the comprehensiveness
of the study. According to the EPA Region V Project Officer, the WQM
Director and other local interviewees, the reports submitted by the sub-
contractor - the Miami Conservancy District (MCD) were not acceptable.
The sampling and modeling-, as designed and executed, were considered un-
realistic and inadequate to define the runoff problem. Consequently,
MURPC recently terminated the contract with the MCD and will attempt to
put the useable information into a more acceptable form. Nonetheless,
all interviewees believed the considerable informational gaps in the
analysis may remain unfilled due to the rapidly approaching end of the
planning period.
MVR-1
-------
As an early WQM designee, the MVRPC's planning period was to have termi-
nated at the end of January, 1977. Although funds did expire as of that
date, MVRPC will continue WQM planning under an EPA-granted time extension
to June 25, 1977. The WQM Director noted that MVRPC is committed to complet-
ing the WQM plan and has re-allocated various resources to allow the plan-
ning effort to continue until June. The remaining funds from the MCD
contract are partially supporting a skeleton staff at MVRPC. Funds from
the management planning subcontract, which was terminated because of in-
adequate technical analysis, also were reallocated to MVRPC. An additional
funding commitment of $25,000 from Montgomery County will enable MVRPC to
complete WQM planning elements related to the County.
The WQM Director outlined MVRPC's strategy for completing the study's
urban runoff components. In each of the 31 watersheds (or WQM areas),
available nonpoint source information will be integrated with the point
source analysis. (Among the most useful data in the.-urban runoff study are
the population and land use elements prepared as part of the interim out-
puts.) Proposals for alternative corrective measures for both point and non-
point problems will be included in each area report. One of the WQM area
reports has been completed already. Now that a format has been developed,
the WQM Director expects the remaining 30 reports to consume less time.
He considers it likely, however, that the planning period will expire
-before all of the WQM area reports are completed.
Although the WQM Director and other interviewees did not expect to have
well-documented recommendations ready, even with the extended planning
period, the MVRPC recently began to supplement sampling and modeling
efforts to fill the biggest informational gaps. According to the WQM
Project Director, extensive data verification will still be needed before
any structural solutions can be feasibly proffered. The WQM will there-
for, concentrate primarily on improved management practices.
To date, nonstructural approaches to the area's urban runoff problem have
been discussed only in general terms. For example, the advisory committees
have considered the applicability of a proposed State sediment control
legislation but because the bill is only applicable in unincorporated areas
and has weak enforcement powers further action on this possible alternative
was curtailed. Furthermore, all discussions are colored somewhat by the
fact that most local citizens and officals are assuming a runoff problem
does not exist until it is carefully demonstrated.
MVR-2
-------
Interviewees1 expectations for correcting an urban runoff problem focused
on several unresolved and somewhat intermeshed concerns:
• the need for more complete data to document a
problem;
• the availability of funding for continued planning;
• the need to gain local acceptance and support.
All interviewees doubted that corrective measures would be undertaken
until the analysis substantiates the urban runoff problem. They feel that
continuation of the study will depend on gaining Federal and local support
for an ongoing analysis. The WQM Director noted that, although EPA Region V
had initially raised MVRPC's hopes for supplemental funding of a "transition
phase", no additional EPA funds have materialized. Local resources for con-
tinuing the analytic effort have not been committed, yet, and interviewees
were uncertain whether local support ever would be committed. Two citizens
expected costs of the effort as well as "pro-growth" interest groups to
inhibit any possible local support. Even if local moneies were committed,
interviewees did not feel such funds would be adequate.
«
All interviewees believed that local elected and appointed officials are quite
aware of the urban runoff problem and generally attend meetings, although, two
citizen interviewees felt only a few local elected officials were devoting
sufficient attention to their review and comment responsibilities. A local
elected official was pleased with the MVRPC's public participation progress,
and noted that the MVRPC had achieved a close working relationship with the
community leaders, local elected and appointed officials. According to one
citizen, the WQM agency had reached those "who form the nucleus of opinion
regarding plan implementation", even though neither farmers, builders nor
developers were involved in the advisory committees. Yet despite the overall
success of MVRPC's public involvement efforts, the lack of runoff data on
that issue has confined discussion on this issue to a cursory level.
The Ohio Envrionmental Protection Agency (OEPA) has participated minimally
in MVRPC WQM efforts. OEPA became involved in the MVRPC project one year
after MVRPC was designated, as soon as funds for State involvement were
made available to them. The WQM Director noted that OEPA has not provided
guidance but instead has focused on a liaison role to ensure coordination.
MVR-3
-------
OEPA circulates MVRPC reports to 26 State offices for review and comment.
During the course of the OEPA-MVRPC contractual arrangement, MVRPC has
had four different liaison officers, and this has hindered continuity
somewhat.
Local and State interviewees commented on the uncertainty of gaining State
certification for the WQM plan. The OEPA proposed certification process is in
an unofficial draft form. The original draft would have required designated
WQM agencies to obtain resolutions of intent to implement the WQM plan from
every governmental unit. According to the WQM Director, this requirement
translates into an extensive and costly review process which will overload
the resources presently available to MVRPC.
The original draft certification process has undergone revision and although
two OEPA staff members noted that revision was being aimed toward a more
flexible strategy, neither could outline the specific stance OEPA ultimately
would adopt. One OEPA staff member noted that the original conservative
approach to evincing local support was considered vital to gaining Guber-
natorial certification over the Governor's expressed "pro-development"
policy. This is expected to hinder plan certification.
The WQM Project Director praised EPA Region V personnel for their responsive-
ness to MVRPC requests for technical assistance. He also was grateful that
Region V was promoting MVRPC's request for additional funding assistance.
In contrast, the Director viewed EPA Headquarters personnel as inconsistent
and contradictory in their responses to MVRPC, indicating that they seemingly
were unconcerned with the problems of the early designated WQM agencies.
He also believed EPA was reserving judgement in matters most appropriately
determined by the Region V office. The WQM Director criticized EPA Head-
quarter general programmatic management of the early designated WQM projects.
He feels that the lack of continuity Headquarters has generated has adversely
affected the planning process. For example, each time MVRPC has had to re-
program its workplan, delays and additional expenses have occurred.
Facilities - Related Plan Elements
The WQM Director outlined several ways in which the WQM planning process is
interrelating with the numerous ongoing facilities planning efforts in the
area. Although not formally adopted as interim outputs (as was required of
later WQM agencies), MRVPC land use and population projections are being
used in facilities plans. MVRPC meets with every consultant and agency
MVR-4
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undertaking a facilities study in the area to ensure MVRPC's early involve-
ment. MVRPC staff closely reviews the facilities plans for conformity with
the WQM plan elements while summaries of the plans are scrutinized by the
advisory committees. Upon favorable review, by the WQM committees, the
facilities plan is formally adopted as part of the WQM plan.
The WQM Director noted good cooperation with OEPA regarding facility area
delineations and alternatives. At one point, the OEPA had supported higher
population projections and larger facilities, but the WQM Director believed
the difference of opinion was being resolved in the direction of WQM re-
commendations. The State as well as EPA Region V consults MVRPC interim
outputs in reviewing facilities plans.
All local interviewees agreed that the WQM plan will continue to influence
future facilities planning decisions by narrowing the options for local
agencies, providing an information base for local management agencies and
consultants and by reviewing facilities proposals through the A-95 review
process.
All local interviewees expected the proposed management system to include
a range of alternatives including some subregional activities and consortia
of existing agencies. No one expected extensive changes in existing manage-
ment arrangements and most local interviewees saw this as a politically
wise option. A local elected official believed that a new interrelation-
ship of agencies was necessary to escape the historical conflicts among
local political units.
All local interviewees noted that the A-95 review process provides for
advisory committee involvement in detailed review of facilities plans.
The Technical Advisory Committe has a large number of appointed officials
and the Water Resources Committee is attended actively by local elected
officials.
Role of WQM Planning in the NPDES Permit Process
The WQM Director hopes the WQM plan will influence future NPDES permits and
that MVRPC will have the technical capability and resources (e.g., staff and
funding for continuing planning) to comment on future permits. The waste-
.load allocations prepared by the subcontractor were unacceptable for use
in identifying inconsistencies between existing permits and the WQM plan.
Wherever data is available, NPDES considerations will be built into each
of the 31 WQM area plans.
MVR-5
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The WQM Director and other local interviewees noted that officals and in-
dustries were questioning effluent limitations and were concerned that
the costly treatment required may be unnecessary. A citizen noted that,
considering the weakness of the data, any proposed wasteload allocations
may be challenged.
Several interviewees were concerned with the uncertainty of State certifi-
cation of. the WQM plan, which is a formal prerequisite to basing NPDES per-
mits on the plan. They are also concerned about how the WQM information
will be considered in the interim. According to the OEPA staff, the State
has not determined if and how designated WQM agencies will have input to
the forthcoming round of permits. Presently the State is revising its water
quality standards, but these will not be completed until after that next
round of permits is issued. An OEPA staff member indicated that the June,
1977 round of permits could be based on existing or proposed standards or
some combination considered to be a "best judgement".
Conclusions
The results of an urban runoff analysis, in the form of documented in-
formation and fully developed alternatives for implementation, will not
be realized during MVRPC's initial planning period. Given the data in-
adequacies of the subcontractor's analysis, MVRPC can hope, at best, to
channel the useable information, as well as MVRPC's supplemental sampling
into further study of the urban runoff problem.
MVRPC's attempts to complete even this limited analysis are hindered by
inadequate staff and funding resources. As the WQM funds were exhausted
as of January, 1977, MVRPC is able to continue WQM planning only by re-
allocating the remaining funds from the terminated subcontracts.
Consequently, the WQM staff has been reduced to a skeleton crew which is
greatly overloaded with the tasks required to meet a June 25, 1977 com-
pletion date.
Bringing the analysis to fruition depends on the availability of funding
support for continuing the WQM planning effort. Although MVRPC, with the
support of EPA Region V, is actively seeking EPA "transition phase" fund-
ing, the present indicators are that EPA Headquarters has little interest
in MVRPC's concerns. If Federal funding is not given to MVRPC for con-
tinuation, WQM planning may come to a halt. It is questionable whether or
MVR-6
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not MVRPC could obtain sufficient local resources to continue an extensive
analytical effort. Montgomery County's financial contribution to help com-
plete the initial program requirements by June, 1977, however, does present
some hopeful signs of" local commitment to the WQM effort.
One of the major accomplishments of the MVRPC effort is that the program
has established a planning process with open dialogue among the area's
public agencies and interest groups. MVRPC has achieved the active partici-
pation and interest of local elected and appointed officials and citizen
representatives by encouraging their contributions and responding to their
concerns. Although the urban runoff study has not yet reached the stage
of alternatives discussion, the advisory committee structure is well-
established to provide an appropriate forum when alternatives are ready.
MVRPC, however, may do well to include builders, developers, and agricul-
tural interests in the advisory committees.
•MVRPC's best efforts are in facilities related planning elements. MVRPC
has established a process for ensuring the compatibility of the WQM plan
and facilities planning efforts starting from the earliest phases of
facilities planning on through to plan implementation. The Technical
Advisory Committee, the Water Resources Advisory Committee, and ultimately
the MVRPC Commissioners are all involved in the review and approval of
proposals and plans. In this way, MVRPC is providing a framework, for
meaningful areawide input into facilities planning decisions.
MVRPC has chosen, a rather conservative approach to wastewater facilities
management since many local management agencies are already entrenched.
For that reason, they may have little significant impact on present waste-
water facilities management arrangements.
The interaction of the MVRPC plan and future NPDES permits probably will
be minimal in the short-term. MVRPC's limited data can substantiate neither
wasteload allocations nor recommendations for revising the State's water
quality standards. Even if MVRPC could make solid recommendations re-
garding NPDES permits, it is not clear how the State would consider them.
OEPA has no strategy for incorporating areawide WQM recommendations into
future permits and yet has to define a process for State certification of
.the plan. The sluggishness of OEPA may be attributed to the State admini-
stration's expressed policy of promoting economic growth at the expense of
environmental prgrams. Until the WQM plan achieves certification - which
could be procedurally delayed - there is no certainty the WQM recommenda-
tions would be considered in the permitting process.
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8 kansas city
Mid-America Regional Council
Mid-America Regional Council (MARC) began its WQM
project in July of 1976 after a year's start-up
delay due to refinement in the WQM workplan. The
final WQM plan is due in June, 1978. The total grant
amount for this project is $1,400,000. The designated
planning area encompasses approximately 3,800 square
miles in the States of Kansas and Missouri. According
to the 1970 Census, the total population of the region
is 1,327,266. This area was selected for study because
of the unique problems of a bi-state WQM planning effort.
Combined Sewer Overflow
In the Kansas City area, agricultural nonpoint sources of water pollution
are being studied by Kansas and Missouri in their statewide WQM programs.
Urban nonpoint source problems are being studied on an areawide basis
by the Mid-America Regional Council (MARC). According to MARC's WQM
Project Director, MARC is concentrating its nonpoint source study on
combined sewer overflow because a 1973 3(C) study indicated these
overflows may be contributing more pollution, especially in smaller
tributaries, than direct municipal discharges. Since no efforts were
ever made to test the 3(C) suspicions, MARC felt it was important
to define the magnitude and location of the combined sewer overflow
problem. MARC's objective is to determine whether it would be more cost
effective for Kansas City to shift attention away from traditional waste-
water treatment planning and toward combined sewer overflow solutions.
The Missouri State liaison, on the other hand, feels that MARC's interest
in combined sewers stems less frorrf MARC_'_s own interest in the subject and
more from EPA's requirement to examine the issue.
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The WQM Project Director acknowledges that a thorough study of the
combined sewer overflow problem in the Kansas City area will require
more than two years, however, he feels that the agency's workplan will
allow MARC to gain a better understanding of the problem and to offer
some preliminary recommendations for problem solution. Other interviewees
were less optimistic about the final WQM plan outcomes. Not only is
MARC faced with the problem of sketchy data, but at this time, even
MARC's limited data collection efforts are in jeopardy because of a
delayed major WQM engineering contract. The Kansas and Missouri
liaisons fear that if the delay persists much longer, MARC will be
unable to recoup lost time to salvage the study. The State liaisons
blame EPA bureaucracy for the delay but the EPA Project Officer justify
close contract scrutiny on the basis of the study's complicated nature
and the WQM staff's complex coordination role.
MARC's interim outputs are not expected to be of much direct use in
the combined sewer overflow study. Combined sewer overflow problems
chiefly exist in older, fully developed urban areas where population
and land use changes are unlikely to occur in sufficient measure to
alter the problem significantly. On the other haiTd, should EPA
shift its policy and allow construction of combined sewers in the future,
the EPA Project Officer noted that the interim outputs could be used
to predict the type and strength of combined sewer overflow loadings
from future growth.
Since MARC had not yet begun its major data collection and analysis
contract, it was difficult for interviewees to speculate on the nature
of final plan recommendations. However, the WQM Project Director
was certain that MARC's study would not make any breakthroughs in
current technology, but rather would probably opt for one of the solu-'-
tions currently espoused by EPA (e.g., holding basins and delayed
treatment). He felt MARC's contribution would be in determining the
location, cost and schedule for implementing appropriate solutions.
The Missouri State liaison expects that because of political and
financial constraints, MARC will concentrate on indirect, nonstructural
solutions such as street sweeping practices. A more pessimistic local
elected official felt that the most one could expect from the WQM plan
is a suggestion for further sampling and analysis in the future. The
EPA Project Officer was skeptical about the very magnitude of the problem
MA-2
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and suspects that the WQM study may find combined sewer overflow is
not deserving of major attention and financing.
With,the exception of one local official, none of the interviewees
expected WQM's combined sewer overflow study to produce noticeable
improvements in water quality. A citizen interviewee felt that even
if data collection was on schedule, the complicated political setting
would make it nearly impossible to devise politically acceptable and
financially feasible solutions within two years. The Kansas City
study area is characterized by an intense desire to maintain local
autonomy and by a long history of interstate rivalry and suspicion.
Furthermore, most combined sewer overflow solutions involve extremely
expensive structural solutions. All three of these considerations
will take a long time to settle. A local elected official and a
citizen interviewee noted that the WQM project generally is not giving
sufficient attention to legal groundwork necessary for implementation of
plan recommendations. The local official also- noted that operating and
maintenance costs are usually ignored in such planning programs, yet
local communities have come to realize that these costs are as important
in decisions as capital investment costs.
Despite these pessimistic prognoses for plan implementation, little
opposition is expected at the time of final WQM plan approval. This
is partially explained by the ongoing review and approval of WQM plan
outputs by local elected officials and their representatives on the
policy subcommittee of the Mid-America Regional Council and the Technical
Advisory Committee. To reach other officials not directly involved,
MARC has prepared a slide show and brochures which it has circulated
among local communities. All interviewees felt that MARC's attempts
to reach local officials were effective especially since MARC itself
is composed of elected persons from each of the communities in the
designated WQM area. According to one citizen however, MARC has
failed to use this contact with local elected officials as effectively
as it could. Rather than giving directional lead to these officials,
MARC's WQM staff has assumed a low profile, only responding to current
local preferences and stressing the WQM program as a planning study rather
than an action plan. To date, no local officials have become excited
about combined sewer overflow problems because the issue has not yet
been defined in terms of immediate needs. Only those officials who
MA-3
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perceive combined sewers as an important problem in their communities
are really interested.
Probably of more significance to plan approval is the fact that, according
to the Kansas State liaison, locals expect the WQM plan will be "just
another study". The Missouri State liaison noted that since most local
communities in his State will have developed their budgets for fiscal
year 1980 before the WQM plan is completed, they will be reluctant to
seek any kind of plan implementation and therefore will not arouse
any opposition.
Citizen involvement in water quality programs has been traditionally
minimal in the Kansas City area because of the low priority of such
programs relative to other community concerns. All interviewees felt
MARC had done the most it could to stimulate citizen interest and
involvement by establishing broad based Citizen Advisory Committees
and public education programs, however, none of these have been
particularly successful. Citizens involved in-the WQM program were
interested in water quality issues long before the WQM program began.
Those who are involved in the WQM committee structure review and
comment on program outputs as they materialize. As mentioned earlier,
citizens were not involved in the selection of combined sewer overflow
for WQM study. This decision was dictated to MARC by EPA, according to
the WQM Project Director.
MARC has contracted with Kansas and Missouri for full-time liaisons who
are engaged in monitoring MARC's progress and ensuring coordination
between the areawide and statewide WQM plans. The WQM Project Director
has found the States generally supportive in MARC's activities to date.
As to EPA Regional Office involvement, the WQM Project Director noted
that EPA has been very active in monitoring grant administration and in
transmitting some technical assistance upon MARC's request. The Kansas
State liaison took a much harder view of EPA. In this opinion, EPA
is sabotaging MARC's study by delaying contracts. He feels that EPA
has no commitment to the combined sewer overflow plan elements but
rather is only interested in building bureaucracies by regionalizing
wastewater treatment. The Missouri liaison took a softer line but
did call attention to changing EPA policies and delays in- transmitting
guidance which have caused delays in MARC's WQM planning process.
MA-4
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Facilities-Related Plan Elements
Although MARC has not been directly involved in facilities planning,
it has participated in the planning process through its A-95 review
role. The WQM Project Director hopes that the WQM plan will give
MARC greater influence on the location, timing and capacity of new
facilities through the use of WQM population projections, service
area delineations, etc. in planning decisions. The Director expects
EPA will accept and abide by WQM suggestions and that the States
in turn will follow EPA's lead on penalty of Federal sanctions. One
citizen, in fact, believes that EPA is already withholding construction
funds until locals can take the WQM plan into consideration.
The EPA Project Officer felt that the WQM Project Directorls prognosis
would probably materialize but added that WQM information would be
used only when approved by the States. Although no formal agreement
on the use of WQM interim outputs has been made between MARC and the
States, the State liaisons also anticipated required compatibility
between the WQM plan and future facilities plans. No effect on ongoing
plans, however, is expected. Two local officials suggested the pos-
sibility that the WQM program through MARC would have primary control
over construction money. Neither official was able to define exactly
what effect this would have.
MARC's major effort in relation to wastewater treatment is in the area
of management planning. Even before the WQM project began, MARC was
engaged in an effort to consolidate the many wastewater treatment agencies
in the Kansas City area for reasons of cost efficiency and more sensible
planning. One local elected official praised MARC's efforts toward
regionalization but none of the interviewees anticipated great progress
in ther.near future. The most commonly cited reason was local opposition
from communities that feared loss of local control or that expected
regionalization to cost them more than present independent management
systems.
Any proposal to form a regional management arrangement across State lines
is sure to cause great controversy especially among Kansas residents
who fear they will be overshadowed by Missouri interests. One local
elected official felt that the WQM plan was not giving sufficient
attention to the legal groundwork necessary for management changes.
Any interstate pact, for example, would need Federal approval through an
act of Congress,
MA-5
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Since MARC has not progressed very far in facilities-related plan
elements to date, citizens have not been active in this area as yet.
However, the WQM Project Director hopes to present the public
with a clear analysis of regionalization1s costs and benefits in the
near future. Through the public participation process (i.e., CAC,
brochures, public meetings), citizens will be given the opportunity
to review WQM alternatives and voice their preferences in selecting
plan alternatives.
Local elected officials will be involved in facilities-related
discussions principally through the WQM policy subcommittee of MARC's
standing committee structure. As mentioned earlier, those com-
munities who stand to be affected most directly by the plan are
likely to participate in discussions. It is questionnable how active
others will be.
According to the Kansas State .liaison and several other interviewees,
consolidation of local management agencies into regional systems is
the foremost interest of EPA. As such, the interviewees feel that EPA
is trying to minimize other parts of the Kansas City WQM plan. The
one benefit local and State interviewees look forward to is strong
support for WQM influence in future facilities work.
The Role of WQM Planning in the NPDES Permit Process
Kansas andMissouri State governments are responsible for NPDES
permitting in the Kansas City area. The WQM Project Director is
certain that any applicable data generated by the WQM study will
be used by both States in their permitting functions. The Director
expects the most likely WQM plan input will come in the form of
suggestions for new industrial permits; however, he does not anti-
cipate many such occassions will arise.
The Kansas State liaison felt there was little MARC could add to the
State's program since Kansas is technically far superior to MARC in
the area of permit analysis. The Missouri State liaison, on the
other hand, noted that all permits issued after the WQM plan would
be issued in conformance with the WQM plan.
Since the issue of permitting had not arisen in committee meetings,
neither citizens nor local elected officials had made input on these,
nor did they understand exactly what kind of input they could or would
have.
MA-6
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Conclusions
Despite the good intentions of the Mid-America Regional Planning Council
and its WQM staff, it appears that the Kansas City WQM plan will have
limited effects on the area's combined sewer overflow problems. MARC
hopes the WQM study will provide a better understanding of the combined
sewer overflow problem relative to other planning concerns. The object
is to enable the region to utilize available construction money in the
most cost effective way possible, perhaps by diverting some facilities
grants toward combined sewer overflow programs. MARC1s problem is that
the complexity of the problem, the absence of an adequate data base and the
current delay in a major engineering contract have severely limited the
WQM project's potential effectiveness even at this early date. Probably
the most the WQM plan can do is suggest a few, broadly outlined solutions
and then recommend that additional studies be conducted in the future.
Even if MARC had sufficient data, the structural solutions which would
probably be recommended are beyond .the current financial means of most
participating communities. Changing Federal grant regulations to allow
facilities money to be used on combined sewer problems will not take a
long time to accomplish. Recognizing these facts, several interviewees
have become disillusioned and referred to the WQM plain as "''just another
study" that will sit on planner's bookshelves.
Yet the Kansas City WQM program is not entirely bleak. In the face of
strong interstate rivalry, home rule supremacy and anti-regionalism
sentiments, MARC has made some noteworthy progress in establishing
communications among communities with common or interrelated problems.
Furthermore, MARC has at least begun the long needed look at combined
sewer problems.
It also appears that the WQM interim outputs will have considerable
influence on future facilities construction decisions since both States
and EPA appear to be waiting for WQM data before committing any further
construction funds. Efforts are reorganizing the current pattern of
wastewater treatment management agencies, on the other hand, will
probably be less effective. MARC may be a bit too intimidated by local
sentiments opposing regionalization. It is almost as though, resigning
itself to the locals' steadfast position on regionalization, MARC has
decided not to bother investigating legal groundwork for implementing
new arrangements. Neither is MARC examining operating costs in which
local communities are really interested. Such positions almost ensure
that no change will take place.
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The WQM's role in NPDES permitting is uncertain at this time, however
the State of Missouri has come out strongly in favor using any applicable
data that the WQM plan may generate.
The outlook for plan approval appears quite bright on the local level
partly because of relatively good involvement of local officials in the
WQM program through MARC's Board and subcommittees and partly because no
one expects the WQM plan to propose any revolutionary ideas. Approval
from the States may be more difficult to secure because of traditional
rivalries between Kansas and Missouri.
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9 middlesex county, n.j.
Middlesex County Board of Freeholders
Middlesex County began its WQM project in May, 1975 and is
scheduled to complete its final plan in September, 1977.
The designated area is 380 square miles large and includes
approximately 731,330 people according to the 1970 U.S.
Census. The total grant amount is $1,420,000. The Middle-
sex area was designated for WQM planning because of its •
complex, urban and industrial pollution problems. Urban
runoff is considered on of the area's most serious sources
of pollution.
Urban Runoff
Water quality sampling and analyses by the Middlesex County Planning Board
have identified urban runoff as a major source of pollution in the Middlesex
County WQM study area. Urban runoff is considered a priority problem
because:
New development is anticipated in key watersheds with
potable water resources and high recreational value;
Patterns of high intensity growth and development are
expected to continue throughout the designated area
further threatening water quality; and
No State agency currently is engaged in the study of
urban runoff as a nonpoint source problem.
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Recently, emphasis in Middlesex has shifted away from urban runoff. The
closing of 100 private wells last year alone has forced the WQM program
to spend more time studying groundwater problems. Nevertheless, according
to the WQM Project Director, urban runoff still remains an important
concern in the study, especially in view of anticipated development's
increased demand on water supply. The Project Director feels that a
comprehensive analysis of the urban runoff problem must extend beyond
the two year study timeframe because sufficient data to get a complete
understanding of problems and to make detailed recommendations has not
materialized as planned. Limited financial resources and inappropriate
weather conditions frustrated attempts to carefully sample and accurately
quantify the extent of the problem. Existing literature provided suffi-
cient supplementary data to suggest a range of outcomes in some development
decisions, but when large scale projects and expenditures with potentially
large water quality effects arise, more detailed information will be
needed. The WQM Project Director hopes to pursue this work earnestly
in continuing planning.
The interim outputs were helpful in understanding the existing urban
runoff problem. Since land use categories used in interim output
projections were developed specifically for the runoff/water quality
relationship analysis, they should be particularly useful in estimating
nonpoint source wasteloads and water quality impacts of future development.
It should be noted, however, that only the Policy Advisory Committee (PAC)
had adopted the interim outputs. Further approval is now pending from
the State Department of Environmental Protection (DEP) and Regional EPA
Office.
At the time of interviews, Middlesex was just beginning to discuss alterna-
tive solutions to the urban runoff problem. The PAC was scheduled to be
subdivided along subject lines (including urban runoff) and was given
two months to develop and review alternatives. The WQM Project Director
hoped to have at least general solution proposals ready for cities at
the end of the project. More time and data will be needed for detailed
recommendations. The EPA Regional Project Officer expected both non-
structural solutions (such as street sweeping programs) and structural
solutions (such as stormwater collection basins) to be proposed in the
final plan.
All persons interviewed anticipate a need for regulatory programs but
feel that these should function through existing legal and institutional
frameworks. Private citizens, in particular, expect local communities
to adopt regulatory measures where they are deemed necessary. They are
MC-2
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optimistic about change though none is expected in the immediate future.
The State DEP spokesman is less certain about plan recommendations and
implementation in the near future. In his opinion, insufficient data may
be insufficient grounds for action and may cause the PAC to decide
against implementation action until more specific information is assembled
and analyzed. Although he views this reaction as less than immediately
satisfying, he considers it to be a legitimate response and a positive
step toward dealing with urban runoff.
Before Plan recommendations can be incorporated into the final plan they
must be approved by the PAC. The Plan then must be approved by the
County Board of Chosen Freeholders (the official WQM designee), the
Governor's Office (through the State DEP), and the EPA Regional Administra-
tor. Implementation will depend on approval by implementing agents which,
as mentioned above, probably will be local municipalities in most cases.
Municipal approval is subject to acceptance by individual City Councils
and, in the case of by-law changes, public hearings review.
The WQM Project Director hopes to promote local adoption of recommendations
as they emerge. Given his tight project schedule, however, the Project
Director does not expect much implementation at the end of the two years.
This issue is corroborated by several interviewees, particularly private
citizens who feel that the urban runoff problem is not recognized as a
problem sufficiently urgent to command immediate action and attention.
Opposition to structural solutions is expected from cities where local
expenditures are involved. Nonstructural solutions, such as land use
controls'and zoning will meet with less opposition if strong empirical
evidence is provided. In either case, however, the generally depressed
state of New Jersey's economy has predisposed some cities to oppose any
solutions which appear to hinder economic development. The WQM Project
Director hopes to overcome these sentiments by mobilizing citizen advocacy
groups and by promoting urban runoff controls on the basis of recreational
benefits and protection of water supplies. At least one citizen, however,
feels that such environmental protection arguments are unlikely to outweigh
interest in economic development.
To date, citizen and special interest groups have played a key role in
setting priorities, directing efforts and reviewing interim outputs
related to urban runoff. These interest groups will begin to develop
and select management alternatives through the PAC structure. Citizen
participation in the PAC generally has been well sustained since the
MC-3
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project's inception. Attendance at meetings had diminished slightly,
but according to one citizen, attendance is expected to pick up again
as management alternatives are developed and discussed. The WQM
Project Director is hoping that citizen advocacy groups will help
supplement the staff's contact with local elected officials.
Local elected official participation which was minimal in the beginning
of the program has not improved over the course of the project. Housing,
transportation and other compelling programs which offer direct subsidy
are expected to command foremost attention among mayors and town select-
ment. The WQM staff still keeps officials informed through brochures,
newsletters and sometimes through delegates such as town engineers who
represent elected officials at PAC meetings. Direct participation or
advocacy by local elected officials, however, is almost non-existent
at this time. One citizen interviewed was concerned because he feels
that direct participation of local elected officials is crucial to plan
implementation. Most other interviewees including the Project Director
and EPA Project Officer take a more lenient viewpoint noting that
competing demands for time and attention make it impossible for local
officials to participate actively in the WQM program. These interviewees
were confident that local elected officials' interest will increase as
concrete recommendations materialize. Interviewees also felt that these
officials will take positive action where strong empirical data inter-
preted by their technical staff (e.g., planning boards, conservation
commissions, town engineers, etc.) supports such action.
Although the State Department of Environmental Protection (DEP) always
has sent a representative to PAC meetings to respond to technical
questions, the WQM Project Director noted that the State has offered
little other direct support for the urban runoff problem. As mentioned
earlier, the State has no ongoing program related to urban runoff as a
nonpoint source problem and, therefore, had little technical
assistance to offer. The DEP did review and comment on urban runoff
data analysis techniques where it felt it could be useful. It also
provided early coordination among neighboring interstate and intrastate
WQM agencies, however, these arrangements broke down because of time
constraints on the WQM agencies. Both the Middlesex WQM Project Director
and the EPA Regional Project Officer concurred that there is room for
improving the State's role through renewed efforts to cpordinate and
support ongoing monitoring. There was no indication from the State
liaison that coordination and monitoring efforts definitely would increase
in the near future.
MC-4
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According to the WQM Project Director, EPA's role in the Middlesex WQM
project has been, to date, more administrative than technical. The
Regional Office has made its expertise on urban runoff available to
Middlesex upon their request but has not assumed a visible advocacy
role in support of local plan implementation,, a function which citizen
interviewees, in particular, feel EPA should serve in order to help
convince local communities to take action.
Facilities - Related Plan Elements
Most of the designated WQM area lies within the service area of the
Middlesex County Sewerage Authority (the regional wastewater collection
and treatment management agency) and is either serviced already or
currently is undergoing planning for future service by the MSCA.
Because there appeared to be little opportunity to influence ongoing
planning and because the County generally is pleased with MCSA's
performance to date, a decision was made at the outset of the Middlesex
WQM project to concentrate attention on nonpoint source problems which
had been, somewhat neglected until then. Middlesex, however, did
prepare population and wasteload projections as part of their interim
outputs. Although these projections differed from those being used by
MCSA, the WQM Project Director could not explain how or if EPA would
resolve these differences; nor was he particularly disturbed by the
situation because of his general confidence in the MCSA.
Unlike the WQM Project Director, the State DEP spokesman foresees the
possibility of a more active WQM role in facilities decisions^particularly
in those areas where facilities planning have been delayed and where
outputs in construction planning have not been developed. The DEP spokes-
man cautioned that the WQM projections are not sufficient grounds for
decisions since they do not entail socioeconomic impact assessment and do
not necessarily reflect growth patterns preferred by the State and
individual communities. The EPA Project Officer suggested that the WQM
plan may be used in assessing environmental impacts of any proposed
facilities construction decision since the WQM projections are based on
the premise of achieving desired water quality standards. He also feels
that the planning process may encourage better coordination between the
MCSA and local land use authorities on the scheduling of local sewer
hook-ups. Along these same lines, one citizen added that the WQM program
be used to guide the location on placement of two proposed trunklines.
The WQM project staff already has cautioned that, if the pipes are laid
too deep, they may break through an important aquifer and promote salt-
water intrusion.
MC-5
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Citizens and delegates of local elected officials had been involved
with facilities decisions only in their review of WQM interim outputs.
According to the EPA Project Officer, local elected officials are
concerned chiefly with economic factors and are trying to temper the
use of environmental concerns alone to guide decisions.
Role of WQM Planning in the NPDES Permit Process
The EPA has responsibility for NPDES permitting in New Jersey until the
State is prepared to assume this function. The WQM Project Director feels
that the WQM project should have influence over permitting because this
affects local water quality and. is important to WQM modeling. Given the
amount and type of data that the WQM project has collected, the DEP
spokesman feels that there are few ways in which the WQM agency can
influence the next round of permitting. The WQM agency was unable to do
a complete review of State wasteload allocations for point sources because
these allocations were not completed by the State and because of the time
and cost involved in preparing this information.
Several persons interviewed, including a citizen and a local official felt
the WQM agency should influence permitting because it has the most com-
prehensive information on quality of local receiving waters. So far,
however, no formal arrangements for permitting input have been made
between the WQM staff and EPA or the State. Even in those areas where
the State has provided information for WQM review, models needed for
WQM review purposes may not be ready in time to influence the next
round of permits.
Conclusions
Middlesex's progress in the area of urban runoff points to some basic
weakness in its WQM project. The first stems from insufficient substan-
tiating data which has made it difficult to convince local communities
that urban runoff poses a crisis in need of immediate action. The
agency has been unable to broaden its constituency since the early
stages of the WQM project. The only citizens, special interest groups
and local elected officials to have sustained an active interest
(e.g., attend advisory committee meetings, etc.) in the project are
those who were advocates for cleaner water before the program began and
those who probably would have continued their interest even without
the WQM project.
MC-6
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The second project shortcoming stems from inadequate coordination among
the Middlesex WQM project and neighboring WQM projects. Since urban
runoff is not a self-contained problem but, rather, crosses political
and project boundary lines, Middlesex communities are reluctant to
commit themselves to corrective action without some assurance that
other contributing communities will do likewise. The State has not
provided active support in the form of statewide programs so far.
The third problem can be attributed to the somewhat depressed state
of New Jersey's economy. When it comes to tradeoffs between the
environment and the economy, the latter almost always holds greater
weight among local decision-makers. This economic situation may indeed
be the greatest barrier of all to implementation. Having failed to
convince local communities that environmental quality is as important
as economic activity, the WQM project may be unable to effect much change
in the near future.
The Middlesex WQM process may not be a total loss, however. Should the
State choose to take a strong stand on water quality, data generated
by the Middlesex project could be used to develop a State-mandated
regulatory program in the area. Also, although the project failed to
build a broader constituency, it may have more firmly entrenched the
existing constituency supporting cleaner water. This constituency may
be important in promoting continued planning and action in the future.
Much is contingent, however, on continued funding and State programmatic
support.
It is also encouraging to see the WQM agency shifting its attemtion away
from the urban runoff problem and toward groundwater contamination by
industrial and municipal land disposal practices. Unlike urban runoff,
the groundwater problem is more self-contained within the study area, is more
easily recognized as a crisis (i.e., a threat to drinking water supplies)
and is more tangible to the public because of public health implications.
As a result, the Middlesex project may be able to generate more publicity
and support for the groundwater issue. Later this support can be
channeled into solving other water quality problems including urban runoff.
The key will be the agency's flexibility and the degree of support it
can raise from the State and EPA. Needless to saypartial continuing
funding from an outside source is also crucial to final plan implementation.
MC-7
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Because the Middlesex County Sewerage Authority is so well respected and
because most of the county is already sewered or undergoing plans for
sewering, the Middlesex WQM project has not played a major role in
facilities construction decisions? nor does it plan to assume a more
active role in the future. This situation has allowed the WQM agency
to concentrate more fully on nonpoint source problems. The WQM plan,
however, may serve to prompt the MCSA and the State to take a more
comprehensive look at the environmental impacts of future facilities
decisions.
The NPDES program is massive in Middlesex because of the great number of
large industries located there. The WQM project could not afford to
become deeply involved in the permitting process because of limited
existing data and limited financial resources to produce the missing
information. Had the WQM agency tried to do more, it probably would
have had little effect on the permits but would have crippled its
efforts in other areas.
MC-8
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10 salem
Mid-Willamette Valley Council of Governments
Mid-Willamette began its WQM project in November, 1975
and is scheduled to complete its final plan in September
of 1977. The designated area is 2,613 square miles
large and includes approximately 226,900 persons according
to the 1970 U.S. Census. The total grant amount is $446,300.
The area was designated because of the high urban concentra-
tion in Marion County (metropolitan Salem) and also because
of agricultural activity in the rural portions of the area.
Among the major water pollution problems in the rural portion
of the area is septic tank failure.
Septic Tank Failure
Septic tank failure is commonly known to be a problem in the rural parts
of greater Salem. A 3C River Study confirmed the problem's existence,
but no one has ever studied it in detail. In terms of the number of
people affected, septic tank failure is not the area's worst problem
(urban runoff or sludge disposal would come first), but the problem has
a sense of urgency because the failures that have occurred were massive.
If these problems continue, the cumulative impacts will be great.
One of the areas where massive failures have occurred is Grand Ronde, an
unincorporated area in northern Polk County and Yamhill County. Because
this is considered a "worst case" situation (a State survey showed 90 per-
cent failure during a drought period!), the WQM agency selected Grand
Ronde as a pilot test area to investigate possible technical, financial
and political solutions. The pilot study will also be used to develop a
model methodology for solving problems and preventing failures from re-
occurring in other problem areas.
MW-1
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The first draft of the WQM project septic tank report is already finished.
It includes problem definition, geology and soils data, and remedial
alternatives and costs. The EPA Project Officer expected that the Mid-
Willamette Valley Council of Governments (COG) would adopt the recommenda-
tions no later than September. Of three effected counties, at least
one (mostly likely Polk) would adopt the needed regulations.
According to the WQM Project Director, the State Department of Environ-
mental Quality (DEQ) is responsible for installation of septic tanks but
DEQ contracts this work out to County Sanitation Departments. While
this aspect of the regulations (i.e., site selection and construction)
is considered adequate, there is no provision for periodic inspection
after installation. Most interviewees expected an inspection system
will be recommended:
According to the EPA Project Officer, any inspection recommendation is
likely to be regulatory because previous experience shows that people •
do not-pump out their systems until they fail. The State liaison,
however, disagreed with this alternative. He felt that the problem is not
maintenance, but poor soils and therefore requires a structural solution.
He suggested replacing or repairing the drain system and constructing a
treatment plant with a summer and winter system.
Other proposed solutions mentioned include mounding (a form of above ground
septic tanks); composting toilets, and pumping effluent to a large sewage
treatment plant. According to the WQM Project Director, however, it is
still uncertain whether the WQM plan will recommend countywide solutions
or restrict its recommendations to special critical areas. In either
case, there will have to be additional studies made on the septic tank
problems of other parts of the area.
The WQM interim outputs will be completed in early March. The three
participating counties each received contracts:
a To take population projections developed by Portland
State University and allocate them to their county;
• To gather land use data; and
© To delineate urban areas (i.e., service areas).
MW-2
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Salem had already set its urban boundary; all other areas were required
by State law to set boundaries within an established compliance period.
This period, however, was shortened to fit the WQM plan schedule.
Of 32 boundaries needed approximately one-third are "tentative", one-
third are "proposed" and one-third "adopted". Wasteload allocations
will be done by the State. The WQM interim outputs will be reviewed
by the State and EPA, and will be particularly useful for facilities
planning.
The WQM Project Director explained that plan approval measures would start
with the Technical Advisory Committee (TAC) and the Regional Planning
Committee of the COG. Next the COG Board itself will adopt the plan.
He did not feel it will be necessary to get the approval of each
individual jurisdiction. DEQ (field office and headquarters) will
review the plan for final certification by the Governor. The WQM
Project Director felt there was an excellent chance for implementation.
The only problems he anticipated were money and an anti-regulation sentiment.
A local elected official was more specific. He felt that the anti-
regulation feeling was most prevalent among farmers and that the plan
would be most successful if the farming community were the ones to
propose the needed regulations. Although an important element, the
anti-regulation faction is not widespread. Anti-COG and anti-land
use referenda were both soundly defeated in the November election.
In reference to the problem of raising funds to pay for septic tank
improvements, the EPA Project Officer suggested that construction grant
regulations be changed so that municipally owned septic tanks are made
eligible for funding. He said this issue is of concern to much of
Region X, and that a National Conference is being held on this issue.
According to the WQM Project Director, there are several Areawide
Technical Advisory Committees (ATAC) which include technical advisors,
and some citizens and elected officials, but there is no officially -
organized Citizen Advisory Committee. The WQM staff has a slide presenta-
tion on the program which has been shown to over 700 persons. Although
the WQM staff has met with farmers and county planners, according to the
EPA Project Officer, they have no definite strategy to identify and
involve key persons. Three elected officials and a citizen all explained
that the Soil and Water Conservation and Agriculture Extension Service
have been active in the Grand Ronde problem and that they will most likely
be key to implementing any solution. Public hearings were held in Grand
Ronde about the septic tank problem and there was good attendance.
MW-3
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County councilmen are the most actively involved elected officials in the
project. A few councilmen are very active in the ATACs and in the Grand
Ronde project. One County Commissioner who was formerly opposed to the
WQM study was made a Committee Chairman and now is a supporter. Several
City of Salem elected officials are active, but most other local elected
officials have not been deeply1involved. They do, however, keep informed
through the COG Regional Planning Committee.
Interviewees gave several interpretations on the State's involvement. The
WQM Project Director and one elected official felt there was little State
involvement in the WQM study. The elected official added that DEQ had
little funding, was involved in other programs and had "little commitment"
to the areawide studies. The EPA Project Officer and another elected
official said that the State had kept close touch with the septic tank
and sludge elements of the WQM study.
The State liaison felt that the WQM staff is working hard, but that the
EPA schedule asks too much. He feels the program came fast "with too
little thought and that a year was lost by "stumbling" in the beginning.
One of the citizens involved also felt the study is being rushed. He
feels it is a fractured program, with too little money and direction
from DSQ and SPA.
One county councilman who has been very active in the WQM study feared
that since the WQM agency has made no provisions for an ongoing role,
that the State would take over WQM planning. He felt this would be a
serious setback since the State is much more involved in point source
problems. The EPA Project Officer also worried that if ongoing funding
decisions are not made quickly, the staff involved will leave for more
secure positions.
The EPA Regional Office influence has been mostly felt through their
requirement for implementation of "hard outputs" within two years. One
elected official felt that this had alienated some people involved. Most
others, however, felt it gave the project a needed push. One citizen
credited the implementation requirement for precipitating a decision to
pursue the septic tank failure problem. At the time it seemed easier
to get a septic tank ordinance approved than other nonpoint source
regulations. The elected officials were particularly pleased with the
EPA Project Officer who they considered an "advocate" for their point
of view.
MW-4
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Facilities-Related Plan Elements
The WQM agency originally intended to develop an areawide Master Sewer Plan.
The schedule was revised, however, to shift emphasis towards "hard outputs".
According to the State liaison there are over fifteen Step 1 and 2 facilities
plans; only one of which is nearly completed. Four or five facilities plans
are about to be undertaken. The State liaison felt that facilities work
will be based on WQM planning data (particularly the interim outputs), but
he felt that so far the WQM staff has been too busy to get very involved
in this area.
As mentioned, the WQM interim outputs are usefun in facilities work. The
WQM Project Director expected the service area delineations (urban boundaries)
will be most useful for facilities planning. Total population projections
are completed, and the detailed wasteload allocation at a detail needed for
facilities planning is now being done. According to an official of the
Salem Utilities Department this is key. Ee said the Utilities Department
is currently updating its own comprehensive plan and is re-studying the urban
growth boundaries. The Salem Utilities Department has met with the WQM staff
several times to discuss planning problems and ways to coordinate the two studies.
The City is particularly concerned about expansion of a part of the City that
lies in a different drainage basin. Possibilities include building a new
treatment plant there or pumping wastes back into the existing system.
The WQM study is looking at the certain management questions related to
facilities. The study consultant has already looked at the sludge
management question in particular. Salem currently uses land applica-
tion to dispose of its sludge, and consideration is being made to do this
regionally. Concerning other management questions, the WQM Project
Director and one elected official felt the study would recommend building
of existing institutions and against creating a new regional agency.
The EPA Project Officer, however, said no agency has the needed powers and
a regional agency was certainly a possible alternative. The State liaison
also felt a regional agency was possible if it were shown to be a cheaper
solution. A management system will be recommended in August;
Role of WQM Planning in the NPDES Permit Process
The Oregon Department of Environmental Quality has NPDES permit authority.
The WQM Project Director, citizens and elected officials interviewed all
MW-5
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said they do not get involved in permit decisions because it is "totally
a State function". The State liaison said that the DEQ works directly
with the cities and industries involved, therefore he does not expect the
WQM agency to become involved.
One elected official expressed some criticism of the State for not seeking
more involvement. He said that recently the State had issued its basin
plans but had not allowed sufficient time for the public to comment.
DEQ was severely criticized at the public hearing and given one year to
incorporate public comments.
Conclusions
The Grand Ronde pilot study of septic tank failures is likely to have
several results. Because of extraneous circumstances (i.e., poverty) in
Grand Ronde itself, there may be a relocation program to move residents
out of the area where the greatest number of failures occur. As far as
other parts of the county, a periodic inspection system (and possibly
permitting) will probably he recommended.
The county officials are actively involved in the septic tank study. They
are committed to finding -and implementing a solution. Likewise, the Soil
and Water Conservation Service and Agricultural Extension Service who will
be key to encouraging involvement by farmers have been actively involved.
Officials and the WQM staff are working with other programs in the Region
and in the Nation in hopes that regulations for construction grants might
be changed to make municipally-owned septic tanks eligible for funds.
All of this adds up to a reasonably bright outlook for further planning
and implementation.
The Region X edict that all WQM programs must implement four "hard outputs"
within the two year planning period appears to have been beneficial to the
Salem project. First, it has shifted focus away from some of the more
general planning efforts (e.g., Master Sewer Plan) and from those that
would be most difficult to gain approval (e.g., some nonpoint source
regulations). Instead, the study has focused on well defined problems
with clear cut solutions. Concentrating in such areas has made it easier
to secure implementation and hopefully to start a "snowball" effect toward
further implementation of the final WQM plan.
MW-6
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Although the WQM staff has been too busy with other plan elements to become
heavily involved in facilities related work, it appears that WQM data will
still influence future decisions since county and local planning agencies
are already turning to the WQM project for data. The WQM planning agency
therefore was probably wise to make the tradeoff between involvement in
facilities questions and concentration on "hard outputs" in other areas
where concerted planning may not have been taking place.
The role for ongoing WQM planning is questionable because the funding
picture is so unclear. If the present staff continues to leave, transition
period work may be in jeopardy. However, the involvement and concern
of local officials and county officials presents some encouragement
for the future of WQM planning. These officials are too committed to the
program to see the whole effort collapse at the end of two years.
MW-7
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11 seattSe
Municipality of Seattle - METRO
Seattle-METRO started its WQM project in January, 1976
and is scheduled to complete its final plan in January
of 1978. The designated area is 1,160 square miles and
has a population of approximately 1.1 million according to
the U.S. Census of 1970. The total grant amount is
$850,000. The metropolitan Seattle area was designated
because of its growing urban concentration. One of the
primary pollution problems being studied is urban storm
runoff.
Urban Storm Runoff
Citizens in the Seattle area are concerned about a general loss of natural
resources in lakes and streams. For some time, metropolitan area officials
were aware that urban storm runoff was causing significant problems.
Previous studies and most recently the RIBCO study^ and plan pointed out
the need for drainage controls. The RIBCO study indicated that the least
costly alternative in undeveloped areas would be maintenance of natural
streams while in developed areas, storm sewers would be necessary.
Because point source problems are already being dealt with under a con-
current facilities study, urban storm runoff is considered the major
problem of this area.
An in-depth study of the area's water quality problems and alternative
solutions. RIBCO completed detailed water quality analysis for most
of the designated area.
MS-1
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The RIBCO study showed the analysis and costs of the urban runoff problem
for 25 sub-basins. The next step in treating the problem is to complete
comprehensive sub-basin plans. To do this, the WQM study effort of METRO
focuses on two demonstration studies, Juanita Creek basin and Thornton
Creek/Lake Union. The Juanita Creek portion of the study is being con-
ducted by the King County Public Works Department. The Thornton Creek
portion of the study is being prepared by the City of Seattle Engineering
Department. Finally, METRO itself will prioritize the next sub-basins to
be studied in detail.
Because the Thornton Creek/Lake Union demonstration study deals primarily
with a weed control problem, the Juanita Creek demonstration is the focus
of attention for this report. The Juanita Creek basin study focuses on a
seven square mile sub-basin in a rapidly developing portion of the County.
It spans parts of the cities of Bothell and Kirkland and some unincorporated
lands which are under the jurisdiction of King County. King County has
had a runoff ordinance (No. 2281) since 1974 which requires all new develop-
ments to control runoff so there is no more runoff after construction than
before. The limitations of this ordinance, however, are that it only
applies to new construction and it only applies in unincorporated areas
of the county. Another problem with the ordinance is that the County
assumes operation and maintenance costs of holding ponds after three years
which could become a very costly responsibility in the future.
In developing an overall county program for controlling runoff, King-
County hopes to avoid costly structural solutions. Any solution, however,
is costly. Although the cost would differ from basin to basin, Green River
basin might be considered typical. These costs for purchasing rights
of way and for constructing channels was $l,500/acre. The County, there-
fore is looking closely at funding alternatives. So far, recommendations
have included:
o Requesting EPA to allow surface runoff treatment costs
to be eligible for facilities construction funds.
o Requesting EPA to start a block grant program similar to
that carried out by the Department of Housing and Urban
Development,
• Using the River Improvement Fund. (This is not a good
source.of money, however, because it was intended for
flood control.)
MS-2
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• Using State road funds. (Since they are already required
to build retention ponds, the County hopes to convince
the State to change pond locations so that they can also
be used for a regional facility.)
The King County administrator has publicly stated that he thinks funding
should come from the general budget, not from user charges.
So far, the Juanita Creek basin study has concentrated on calibrating an
EPA runoff simulation model so it can be used to identify and analyze
drainage alternatives. The Public Works Department (PWD) hoped to have
this capability in the County so that they could use it to encourage
other jurisdictions to enter inter-governmental agreements to solve
basin-wide problems. (The County only has jurisdiction in the unincorporated
areas). The PWD also intended to develop a handbook on use of the model.
The model-related elements of the WQM study, however, have not been success-
ful so far. The engineers are unsure how applicable the model is to their
area, and feel it needs many revisions. Some parts of the model, especially
the transportation element, are considered too costly to use.
Nevertheless, the County Public Work£ Department hopes to accomplish some
things as a result of the WQM project. First, they hope to develop alterna-
tives for Juanita Creek basin and select one that is most cost effective.
Second, they hope to execute a management agreement between Bothell and
Kirkiand and King County (the three relevant jurisdictions) over allowable
land uses in Juanita Creek area. Third, they hope to develop a series
of alternatives for funding of urban runoff "solutions".
One funding alternative being proposed for both Thornton Creek (which is
in the City of Seattle) and Juanita Creek is the creation of Draining
Utility Districts. By doing this the City could sell bonds and assess
charges to residents of the districts. The district approach was
tried in the City of Bellevue which is also part of the Seattle metropolitan
area. After much opposition, that program was scheduled to go into effect
in March of 1977. Because of the relevancy to its own activities, METRO
funded a political case study of Bellevue as part of the WQM study.^
Partly based on this experience, there is some doubt by citizens and
officials alike whether utility districts would be politically acceptable.
Hall and Corwin Associates, The Bellevue Experience, November, 1976.
MS—3
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The King County Public Works Department hopes it can construct a "blue/
green" detention pond (wet during rainy periods; dry at other times) as
part of a County Park. They have also prepared a leaflet, "Home Tips for
Clean Streams" to encourage public behavior to reduce pollution. Ironically,
however, some county officials are beginning to feel that a more regional
(versus sub-basin) approach is needed. Specifically, the area needs to
conserve wetlands and make certain stream bank improvements. Funding for
a regional approach, however, is even more uncertain that for a sub-basin
program.
In the two year planning period it will not be possible to solve the
structural and technical needs even in the demonstration basins.
Nonetheless, partly at the urging of the EPA Regional Office, some things
will bee implemented. This includes putting in place institutional arrange-
ments (e.g., inter-governmental agreements), financing and management
structures. There is a decided emphasis on a regulatory approach because
it is believed most feasible for the long term. The WQM Project Director
predicted that controls would be implemented by June, 1977.
The WQM Project uxrector, iixe tne county engineers, noted the lack of
federal monetary incentives to get too deeply involved in runoff controls.
To date, all costs must be incurred locally. The Project Director is
meeting with other WQM Project Directors in the West to help formulate
strategies for seeking funds to continue their studies.
One local elected official mentioned another possible barrier to imple-
mentation. Several years ago the Corps of Engineers authorized the Soil
Conservation Service to dump into the Green River as a flood control
measure. It may be necessary for them to withdraw this authorization.
If this occurs, the County will have to ease up on some of its own regula-
tions .
The population projections in the interim outputs were prepared by the
Puget Sound Council of Governments (PSCOG),-'- but it was not directly
useful for the urban runoff analyses. Wasteload projections have not
been completed. Wasteload allocations will not be done by METRO. The
State will decide whether allocations are needed, and if so, the State" will
do them.
This inter-agency agreement was a condition of designation.
MS-4
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Formal steps for approval of the WQM plan will include community hearings,
adoption by the METRO Council, review by the State Department of Ecology,
and Certification by the Governor. Washington has a new Governor and her
administration is currently being brought up to date on a number of
issues. The State, so far, has somewhat left the areawide agencies on
their own and concentrated on its statewide WQM planning.
METRO has a water quality Citizens Advisory Committee which considers both
facilities construction and WQM planning issues. According to one of the
citizen members, the CAC received a briefing on the demonstration projects,
but has not heard anything since then. Although EPA Project Officer,
the State liaison and one local official interviewed all thought citizen
involvement was good, it was necessary to replace almost half the members
in the fall' because of poor attendance. CAC members tend to be activists
and seem to function best at the task force level. Task forces to consider
sludge and combined sewer overflow were considered helpful, and active.
A task force on areawide issues has also been formed. According to its
Chairman, the study group will discuss sewer extension issues and review
reports from the City of Seattle and King County which are due in April and
"May. A second citizen, however, found the concept of areawide planning
difficult to comprehend because it "has so many loose ends, its hard to
get your teeth into it". He added that the area for study is so large,
that its often difficult in meetings to get everyone down to specifics.
Beyond the advisory committee, METRO uses several other means to involve
citizens.. A monthly newsletter which reports on WQM activities and gives
"anti-pollution plugs" for stopping pollution at home is mailed to over
20,000 residents. The Division of Community Involvement at METRO is about
to undertake four demonstration projects to involve citizens in water
quality-related activities. These will be selected from a pool of ten
suggestions, each designed to "get quick results". One of the ten is a
tree-planting program designed to lower stream temperature (higher
temperatures were preventing fish from swimming upstream to spawn).
Weyerhauser would donate the trees, and labor would be volunteered by
interested private citizens.
Local elected officials have been involved through a number of means.
According to the EPA Project Officer, the METRO staff ".takes pains :to! keep
them personally involved often on a one-to-one basis". Some officials
are also kept informed through activities of the Water Quality Committee
of the METRO Council and through the METRO Council itself which has 30
members, all elected officials. Finally, a highly successful workshop for
elected officials was held in the fall. Forty persons attended and
discussed the area's problems, regulatory approaches and financing
possibilities.
MS-5
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One of the county officials who is on the METRO council agreed that
officials are very involved, but a citizen said he-has not seen much
involvement so far. The State liaison said that involvement is
excellent from those areas most directly affected; others put water
quality at a somewhat lower priority.
The State has not become heavily involved in the areawide programs. (There
are three in the State of Washington). It has primarily played a
review and reactionary role, providing information whenever possible.
The EPA Regional office has played a much more active role. EPA
Representatives attended committee meetings and the Regional administra-
tor spoke at the elected officials workshop. The EPA Project Officer
holds monthly progress meetings and also has day-to-day telephone contact.
Facilities-Related Plan Elements
Currently, a separate staff, within METRO is preparing a wastewater
treatment facilities plan. In this plan, the staff are analyzing
alternatives for meeting the secondary treatment goal of P.L. 92-500.
METRO as well as most citizens and elected officials are not in favor
of upgrading existing plants to';the secondary level. They argue that
given the tidal action of the sound, that existing treatment is'equivalent
to secondary. Furthermore they argue that upgrading is expensive
with little or no benefits. EPA and the State have not accepted this
argument which has caused some strain between METRO and EPA. While
still arguing against upgrading, METRO is proceeding with its facilities
plan. This is due in August with hearings due in October and final
action due in November.
The WQM study has been coordinated with the facilities study in several
important ways:
0 Population projections and land use studies were
prepared by PSCOG (under joing funding) for use of
both the WQM and the facilities planning efforts.
• Both the WQM and the facility plans addressed the
question of which level of treatment is needed. The
WQM plan is looking at urban storm runoff solutions
that, if successful, might further decrease the need
for secondary treatment.
• The WQM plan will include sewer extension guidelines after
examining the role of sewers in growth management.
MS-6
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Because METED is already a metropolitan sewer agency, there is no
need to create a new management system. There is"no intention for
METRO to take on more management authority (e.g., land use controls)
than it already has. As local and EPA officials.alike noted,
"the system is in place", it is more a matter of exercising existing
powers. Previous studies have recommended a merger of METRO with
King County. Although the WQM study will support the merger as a
concept, it has less impact for water quality, so will not be
emphasized.
Role of WQM Planning in the NPDES Permit Process
The State of Washington has NPDES permitting authority, however, it
has delegated this authority to METRO for those industries which discharge
into the METRO system. Permitting, therefore, is more related to
METRO'S facilities study than the WQM study.
Conclusions
The METRO WQM study focuses primarily on the two demonstration projects
in Juanita Creek and in Thornton CrSek/Lake Union. Beyond that the
study will consider sewer line extension policies and will prioritize
areas that need detailed plans for urban storm runoff.
There seems to be an excellent chance that WQM plan, recommendations will
be implemented in the demonstration areas. King County is committed to
signing an inter-local agreement with Bothell and Kirkland to control
land uses in the sub-basin area. The County also hopes to construct a
detention pond in a park. The County's original desire for a county-wide
program, however, will be limited because they are experiencing problems
with the EPA runoff model. The County had hoped to use availability of
the model as an inducement to incorporated areas to enter inter-local
agreements.
Another limitation to county-wide implementation is funding. Most solutions
to runoff, but especially structural solutions, are very costly. Most
officials hope to convince EPA to make runoff control costs eligible for
facilities construction grant funds. Another widely mentioned alternative
is creating utility districts. This was tried in Bellevue and their
experience is being closely watched.
MS-7
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Many locally elected:.officials are involved in this effort. Nearly 40
attended a workshop held in the fall. This demonstrates at least
their interest in learning about problems and possible solutions.
Again, their commitment to doing something will probably be limited
by the cost involved.
The quality of citizen involvement is high. They have input into
discussions on sludge and combined sewer overflow, and certainly seem
capable of tackling issues such as sewer line extension and prioritization
of areas to be studied for urban runoff. Beyond the most active
participants (i.e., those on committees), 20,000 people receive a monthly
newsletter and many more will become involved through the four citizen
involvement demonstration projects that will be conducted by the University
of Washington.
MS-8
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12 Cincinnati
Ohio-Kentucky-Indiana Council of Governments
The Ohio-Kentucky-Indiana Council of Governments (OKI)
began WQM planning in January, 1975 and was' officially
scheduled to end planning in December, 1976. OKI ob-
tained an EPA time extension to complete final plan re-
view, revision and adoption as well as preparation of
continuing planning. Due to frugal budgeting through-
out the two years, OKI was able to conserve enough grant
funds to continue WQM planning for the additional six
months.
The ten-county OKI region includes areas in three states
around the Cincinnati and Hamilton-Middleton SMSAs. The
total WQM designated area consists of 3,117 square miles.
According to the 1970 U.S. Census, these are 1.65 million
people i'n the designated area. Approximately 1.2 million
of these reside in Ohio.
As a trirState area and an early designant, OKI did not
operate under the EPA guidelines which directed later
WQM projects. OKI has received national attention for
its technological approach to nonpoint sources of water
pollution.
Combined Sever Overflow
The Ohio-Kentucky-Indiana Council of Governments' (OKI) analysis of
stream segments clearly identified combined sewer overflow as a sub-
stantial water quality problem. Although no studies pre-dated the OKI
analysis, Cincinnati's totally combined sewer system and other smaller
combined systems had been considered obvious pollutant sources for a
long time. By applying a model in each of the four basins comprising
the WQM study area, the present OKI analysis calculated the magnitude
of the problem and the water quality benefits to be derived from cor-
rective measures. The OKI model, endorsed by EPA, relied on literature
coefficients rather than actual sampling. Nonetheless, the WQM Director
believe this initial analysis sufficiently documents OKI recommenda-
tions for steps toward problem resolution.
According to the WQM Director, the analysis identifies immediate needs
for action while proposing other short-term and long-term alternatives
contingent upon further study prior to implementing action (e.g.,
OKI-1
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structural investments). OKI recommendations recognize the need for
relatively low-cost interim solutions (e.g., storage and pumping of
storm water into treatment plants) while longer-term solutions requiring
substantial monetary investments aire analyzed. Both phased short-term
and long-term approaches are designed to be flexible and adaptable to new
information. In the ongoing planning phase, OKI intends to verify data
through sampling, isolating the costs of corrective measures and by con-
ducting demonstration projects. For example, OKI will be testing a
low-maintenance gravity device for potential application to the combined
sewer overflow problems.
As an early designated WQM agency, OKI was not required to produce in-
terim reports. OKI did develop population projections and land use
elements which were reviewed by the WQM planning process. All inter-
viewees believed these reports to be valuable to the study as well as to
other related planning efforts in the area.
Although most interviewees were confident of OKI's technical analysis and
overall planning process, they believed that implementation toward pro-
blem correction depended on the availability of Federal funds. As cor-
recting even the smallest combined sewer system's overflow problem en-
tails 42 million dollars, citizens and local elected officials expected
little public support for the implied skyrocketing of sewer rates. With-
out substantial Federal funds, no one believed longer-term structural
solutions would be acceptable. In some areas, less expensive partial
solutions were believed likely and, in a few critical areas, short-term
approaches are already being adopted.
An area of concern to local interviewees was the State of Ohio's position
regarding WQM plan approval and certification.-*- All interviewees noted
the present State administration's attitude of "pro-development" and ex-
pected the State to disapprove of those WQM plans with potentially adverse
impacts on economic development. Most interviewees believed that the
State of Ohio would like to delay certification until 1978, commensurate
with the completion of the statewide WQM plan. They also felt that a
draft document of the State certification process, if approved, could have
the effect of "killing" the OKI plan.
1
Although three States - Ohio, Kentucky and Indiana - are involved in
the OKI WQM study area, only Ohio was discussed in these interviews.
OKI-2
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According to citizens and local officials, the State may require OKI to
obtain a "resolution of intent to implement" the WQM plan from each govern-
mental unit prior to submitting the plan to the Governor for certification.
No local interviewee believed OKI could master these resolutions, and the
extensive public hearings required within the planning period.
This local perspective of the State's position regarding plan approval/
certification does not mesh with statements obtained from the Ohio Environ-
mental Protection Agency's (OEPA) staff. According to two OEPA staff
members, OEPA has been aware of the Governor's anti-regional and pro-
development positions and consequently OEPA had originally proposed local
resolutions of intent to implement as documentation of local support for
expediting the certification process. However, in response to WQM agencies
concern, the draft certification document recently has been unofficially
revised to reflect a more flexible stance. Although still an unofficial
position, an OEPA staff member expected the OKI plan will be reviewed
and approved by OEPA as soon'as possible with OEPA recommending immediate
certification to the Governor. The two OEPA staff interviewees anticipated
some form of local "resolutions of intent to implement" would be required
within a given time period following certification.
All local non-staff interviewees commended OKI staff for their thorough
technical analysis and sensitivity to the needs to respond to local offi-
cials and citizens. The OKI Citizen Participation Committee and Water
Quality Advisory•Committee have been actively reviewing interim reports.
A local elected official commented that officials are active on the ad-
visory committees and seemingly well-informed. Some local elected offi-
cials have attended national workshops and conferences. Further, OKI
staff have maintained informal contact with officials in the course of
plan development. The WQM Director noted that appointed officials of
the large Metropolitan Sewer District have formed a Technical Steering
Committee to work with OKI on the combined sewer overflow problem.
Consultants to the District work with OKI on an ongoing basis. With
the forthcoming hearings regarding the WQM plan, all interviewees ex-
pected a thorough discussion of alternatives. However, most were aware
that the high costs of correcting the combined sewer overflow problem
(e.g., increased sewer rates) would effect a conservative stance from
elected officials.
The OEPA initially was not involved in OKI WQM efforts until the 1975
programmativ provision allowed funding for State participation. Since
then, a State liaison officer has been provided to OKI for coordinative
purposes. OEPA reviews all OKI reports and distributes copies for
review and comment to various State agencies.
OKI-3
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In the area of combined sewer overflow, the OKI WQM Director believed ¦
the State was not actively promoting correction of combined sewer over-
flow problems, but rather focused on facilities construction grants as
a priority.
According to the WQM Director, EPA Region V has not been involved in the
specific area of combined sewer overflow. EPA involvement has been limit-
ed to review of reports and•attendance at meetings.
Facilities - Related Plan Elements
A major focus of the OKI WQM study has been facilities planning. As an
early WQM designee, OKI had the program flexibility to utilize WQM funds,
for facilities plans. , OKI is developing 22 facilities plans; two of these
plans have already progressed to Step II phases. OKI also has attempted
to work with the U.S. Corps of Engineers in a dam construction project.
Although unsuccessful, OKI had sought low flow augmentation measures to
prevent the need for costly treatment facilities downstream.
Citizens and local officials commended OKI staff for their approach to facilities
planning. OKI has involved officials in developing feasible and locally
acceptable plans and instituting a planning process which ensures tech-
nical assistance and OKI review for local-regional compatibility at the
earliest stages of planning. The WQM Director noted that local consul-
tants and local officials now come to OKI for information and assistance.
In only one case, did interviewees note some resistance to OKI recommenda-
tions. As OKI recommendations may limit the capacity of facilities
for expansion, there is concern that growth may be inhibited.
A State water quality official and the Region V Project Officer noted
that their respective reviews of facilities construction grant applica-
tions already rely on OKI interim reports. The WQM Director noted that
OKI and OEPA have a good working relationship regarding facilities plans.
OEPA reviews applications in light of comments provided by OKI.
No one believed management of facilities to pose insurmountable problems.
The WQM Director attributed the ease of the management question to the
already existing, well-regionalized systems in the area. He noted that
about 80% of the population is served by well-staffed and efficient
operating agencies. Consequently OKI has focused management concerns
on the smaller, unstaffed areas. Certain small operations will be con-
solidated and merged with adjacent entities. These recommendations are
OKI-4
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found in the 22 OKI facilities plans and in county composite reports¦
which coordinate OKI plans with the other 35 existing or ongoing facili-
ties planning efforts in the area. OKI sees itself as appropriately
continuing its technical advisory services to local agencies.
The WQM Director believed OKI's public involvement efforts regarding
facilities plans have been very successful. Through local presentation
and discussion of the facilities plans with citizens and officials, the
WQM Director believed the facilities plans have served as a vehicle for
arousing enthusiasm for and interest in the WQM planning effort. He
felt local people gained a perspective on the overall basin plan through
its link with the more tangible facilities plans. In other areas where
the urgency of sewer needs and concerns was not felt, the WQM Director
noted less active interest and participation. Citizens and local offi-
cials agreed that, at the advisory committee level, they were well-
informed and active in discussing facilities-related plan elements.
Role of WQM Planning in the NPDES. Permit Process
The relationship between the OKI WQM plan and future rounds of NPDES
permits is not clear. In two completed basin plans, OKI has proposed
wasteload allocations and expects that the OKI plan will serve as a
basis for future NPDES permits if the plan gets State approval and
certification. However, the WQM Director, the EPA Region V Project
Officer and local interviewees believed that attaining State certi-
fication will be difficult. As discussed earlier, the State has not
yet clarified the conditions for certification, but at present could
conceivably delay certification by requiring local "resolutions of
intent to implement" the OKI plan from every local governmental unit.
An OEPA staff member noted that currently the State is revising water
quality standards and may extend permits until the revision is com-
pleted. No State official would specify, at this juncture, how OKI
recommendations would be Incorporated into the NPDES permitting system.
The OKI WQM Director believed local officials and citizens were concerned
with permitting from the standpoint of equity. Other local interviewees,,
however, felt that citizens and local officials were not well aware of
concerns related to NPDES permits.
Conclusions
OKI's approach to the combined sewer overflow problem clearly demonstrates
a well defined hierarchy of priorities. The OKI analysis both documents
OKI-5
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immediate needs for problem correction and identifies areas requiring
further study prior to specific investments. Even while analyzing
longer-term corrective measures, OKI is recommending interim solutions
to mitigate the combined sewer overflow problem. OKI's incremental
approach is necessitated by local economic and political conditions
which preempt the feasibility of costly structural solutions.. OKI
recognizes the need for a practical alternative to large-scale struc-
tural investments and recently hag undertaken a demonstration project
testing a low-maintenance gravity device.
A strength of the OKI effort is the ongoing working relationship OKI
has maintained with local elected and appointed officials. Although a.
lack of large-scale Federal financing may defeat immediate resolution of
the combined sewer overflow problem, OKI's analysis already has enjoyed
considerable success in its application to local planning. OKI has
established itself as a leading technical consultant to projects related
to combined sewer overflow' issues. The OKI data base is locally acknow-
ledged as a credible resource for local planning efforts.
There are two possible obstacles to OKI WQM plan implementation: public
acceptance and State certification. Because solutions to combined sewer
overflow imply large increases in local sewer rates, local citizens and
officials will closely examine OKI recommendations for the most economical-
ly practical solution. OKI seems, however, to have incorporated the neces-
sary flexibility into its planning process to allow for partial solutions'
while other alternatives are analyzed for their costs and benefits. Al-
though the official procedure for gaining State certification remains to
be delineated, the present Ohio administration's "pro-development" and
anti-regional planning posture is an undercurrent threatening the pros-
pects for certifying designated WQM plans. A costly local WQM plan re-
view procedure unnecessarily duplicates the earlier outreach efforts of
designated agencies and would delay certification if not totally exhaust-
ing the resources of the WQM planning agencies. The State believes it
can argue for this conservative approach toward assuring gubernatorial
certification by showing solid local support for the,WQM plan recommenda-
tions. Whether or not the State will become more flexible and reasonable
in its certification process seems to rest with the resolution of a politi-
cal question which is perhaps beyond the influence of the designated WQM
agencies.
OKI's involvement in facilities planning has lent the overall WQM project
a heightened areawide visibility. OKI has affecttsd facilities planning
directly by developing 22 facilities plans and coordinating them
OKI-6
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with other existing and ongoing facility planning efforts. In developing
the facilities plans, OKI has involved local elected and appointed offi- ¦
cials and in some areas held numerous public meetings. OKI interim re-
ports have also been the basis for regional A-95 review, State and EPA
review of applications for construction grants. These review procedures
ensure a compatibility among concurrent regional and local projects.
The major question surrounding the interaction of NPDES permitting and
the OKI WQM plan is again State certification of thie plan. The State
is not required to consider the WQM plans in NPDES permitting until the
plan is approved and certified.
OKI-7
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13 southeastern Wisconsin
Southeastern Wisconsin Regional Planning Commission
The Southeastern Wisconsin Regional Planning Commission
(SEWRPC) began its WQM project in June of 1975 and is
scheduled to complete its final plan in November of 1977.
The total grant amount for this project is $2,607,000.
The designated planning area encompasses 2,689 square
miles and has a population of 1,798,781 people, accord-
ing to SEWRPC statistics. This area was selected for
study because of a unique combination of agricultural
and industrial problems.
Agricultural Nonpoint Sources
Ongoing watershed studies conducted by the Southeastern Wisconsin Regional
Planning Commission (SEWRPC) in Southeastern Wisconsin revealed that
pollution from agricultural lands is a significant problem in the region.
SEWRPC recently completed a 10-year study of water quality sampling data
which further identified the nature and extent of the problem. The WQM
staff felt that the WQM planning period was sufficient to establish al-
ternative solutions to agricultural pollution problems; however, continued
planning will still be needed for ongoing refinements of solutions.
Most others interviewed felt that two years was too short since this
year's drought prevented the collection of data on average conditions
and since solutions to the problem were too elusive to identify within
the two year period. One year was generally considered a sufficient
addition to the planning period.
In the course of its water quality planning efforts, SEWRPC has prepared
a volume entitled Rural Stormwater Runoff. This report lists various
technical solutions along with the cost and projected effectiveness of
SEW—1
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each solution. The State through its regional planning commissions has
been actively promoting agricultural pollution control practices (e.g.,
manure spreading, soil and water conservation practices, etc.) over the
past 20 years.
The WQM staff hopes to bring about,a new emphasis on those practices
which are most beneficial to water quality by working closely with the
Soil and Water Conservation Boards, which are composed of elected
officials in each county.
The WQM interim outputs were not considered particularly useful in iden-
tifying agricultural nonpoint source problems. Most interviewees felt
that the interim outputs were more closely related to the point source
problems, although the land use and population elements (identified under
701) were considered a fundamental prerequisite to identification of non-
point source agricultural pollution.
Interviewees were uncertain about the extent to which agricultural non-
point sources of pollution would be corrected as a result of the WQM plan.
The likelihood of improving water quality will depend on:
• kinds of solutions chosen for implementation;
e , availability of money to assist farmers in implementing
conservation techniques;
• specificity of problem definition as a result of the WQM
plan; and
e degree of Federal support (i.e., funds and sanctions) for
the implementation of WQM plans.
The SEWRPC staff and a local elected official consider voluntary solutions
to the water quality problem most politically feasible since adverse re-
actions to regulations in the past have thwarted previous attempts at en-
forcement. Most other interviewees felt that regulations would be neces-
sary, but that monies (i.e., matching funds, incentives or grants) to im-
plement practices would be a necessary adjunct to regulations. Currently
there are efforts to study the regulatory approach. For example, Washington
County is presently conducting a study to develop a model ordinance for sedi-
ment control under a separate EPA grant.
SEW-2
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All interviewees felt that WQM planning was another step in the ongoing
water quality programs in Southeastern Wisconsin. Consequently, they were
not waiting for a completed plan to begin implementation. Potential areas
where the influence of WQM planning will be felt before plan completion are
in current decisions concerning sewerage extensions, in the nature of pro-
grams supported by the Soil and Water Conservation Boards and in the type of
materials presented in public education programs.
The only barriers to implementation anticipated are those which normally
surface during planning periods. Lack of money and time were specifically
mentioned along with the inherent difficulties of coordinating a variety
of agencies and interests in a diverse metropolitan area.
Preliminary contact with the Governor's office has been established, but
most interviewees expected an increase in the importance of that relation-
ship later in the process. Until that time, a close working relationship
with DNR suffices for State-level coordination.
All interviewees felt that citizens, local elected and appointed officials,
the State DNR, and Regional EPA had the opportunity and were contributing
to decision-making in the WQM process. Citizen and local elected officials
attendance has increased in the meetings held in each county. SEWRPC has
established ongoing contact over the years with the variety of technical
people in the region. This includes representatives of local elected
officials, sewer district officials, and Soil and Water Conservation Board
groups.
The Wisconsin DNR and SEWRPC work closely together, frequently exchanging
information. Examples include SEWRPC's contribution to the development
of the water quality standards, and DNR's disapproval of sewer extensions
that do not conform to the WQM service area delineation. Some coordination
has occurred with other WQM programs in Wisconsin and with a contiguous WQM
program in Illinois (NIPC). Coordination within the State has occurred
on the issues of water quality standards, nonpoint sources, and population
projections. Some consideration is being given to a Statewide regulatory
program, however, it is unclear at this time whether that would be the
best approach.
The WQM staff reported that EPA's primary role to date has been in monitor-
ing the project and providing technical data. Communications were reported
to be open and smooth.
SEW-3
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Facilities - Related Plan Elements
SEWRPC was engaged in facilities planning in the designated area long
before the WQM project began. SEWRPC therefore adopted its WQM facilities-
related plan elements from its other ongoing facilities work.
SEWRPC's plans and projections presently guide all decisions for plant
construction and sewerage extensions in the region. Both EPA and the
State are providing strong support for the present plans, by requiring
local resolution of conflicts before approval of any future monies. In
one conflict which has arisen, the State is presently withholding approval
of a sewer trunk extension that does not conform to the facilities plan.
Little public involvement in facilities planning elements occurred during
WQM planning because a comprehensive regional sewerage plan was completed in
1974, prior to the WQM study. Under WQM, the technical and citizens commit-
tees reviewed the delineation of service areas; however, most of the public
input was gathered in the development of the comprehensive facilities plan.
Some responses indicated that the major vehicle for input into facilities
related decisions is in the community-level committee structures., rather
than a regional forum.
Role of WQM Planning in the NPDES Permit Process
The interim outputs were completed by SEWRPC in time to influence the
next round of permitting. EPA officials stated that the drafting of per-
mits was to begin soon. All interviewees were confident that the present
channels of communication between DNR, SEWRPC and local communities would
enable a variety of actors to influence future permitting. These actors
include SEWRPC itself and citizens groups such as the Milwaukee River
Restoration Council The DNR official also referenced a State law which
requires all permits to be in compliance with WQM plans.
Conclusions,
The study of agricultural nonpoint sources of pollution is generally considered
an important aspect of Southeastern Wisconsin's comprehensive study of land
use and water quality relationships. The importance of agricultural non-
point sources of pollution relative to other plan elements, however, depends
on the perspective (i.e., location) of the interviewees. Combined sewer
overflow problems are considered more important in urban areas, while smaller
communities are more interested in facilities construction. The more rural
counties are naturally very interested in the agricultural elements of the
WQM plan.
SEW-4
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WQM planning has however, made significant progress toward identifying pro-
blems and outlining possible solutions for water pollution in agricultural
areas. A 10 year study of regional water quality, vegetative cover and animal
inventories, and a catalogue of techniques for reducing agricultural sources
of water pollution will contribute to the development of sound alternative
solutions under the WQM project. The SEWRPC staff sees public education
as a crucial aspect of successful plan implementation, and looks to" volun-
tary solutions as the best approach to plan implementation (i.e., those
with the most chance for success). Money to implement selected agricul-
tural practices is also seen as a crucial aspect for achieving water quality.
All interviewees felt that it was clear that farmers could not absorb the
entire cost of eliminating agricultural sources of water pollution. SEWRPC
has been working closely with the county Soil and Water Conservation Boards
who have been very supportive of SEWRPC's activities. This connection is
apparently invaluable in efforts toward solving agricultural nonpoint
sources of pollution.
The WQM plan is perceived as part of an ongoing water quality planning pro- •
cess in the region. SEWRPC has a 15—year history of water quality planning
experience, and is conducting studies for the region on a watershed basis.
Consequently, it is often difficult for participants to separate single
grants (e.g., WQM planning) from the total planning process. Good communi-
cations have been established between SEWRPC and the various communities in
the region. This is often accomplished by SEWRPC staff attending the com-
munity meetings.
SEWRPC completed a comprehensive sewerage plan for the region in 1974.
This document provided a basis for the interim outputs, and is generally
being followed throughout the region. EPA and Wisconsin DNR are both
requiring all future facilities plans to conform to the present facili-
ties service area. plan.
Interim outputs have been completed and should be considered in the next
round of permitting. All interviewees were confident that SEWRPC would
¦review the permits and consequently be able to ensure conformance with
WQM plans. An additional incentive for this review exists in a Wisconsin
State Law which requires all permits to comply with WQM activities.
At this time, it appears that SEWRPC's strong history of water quality
planning and the sound technical base from which the WQM plan began, bode
well for plan completion and adoption. The region-wide support for SEWRPC
and its planning activities should facilitate the WQM project's contribu-
tion to Southeastern Wisconsin's ongoing water quality planning programs.
SEW-5
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14 augusta
Southern Kennebec Valley Regional Planning Commission
The Augusta WQM project began in June, 1975 and is scheduled
for final plan completion in July, 1977. The designated area
is approximately 500 square miles with a population of.
about 55,000 people according to the 1970 U.S. Census. The
total grant amount is $380,000. The Augusta area was desig-
nated for WQM planning for a combination of reasons. The
area's lakes (essential to the region's economy) were suf-
fering from unaccountable eutrophication, some of its ground-
water was showing signs of contamination and a number of local
industries dispose large amounts of waste into the region's
major river.
Agricultural Runoff
The Augusta WQM area is dotted with a series of fresh water likes and
ponds which are key to the area's recreation industry and water supply.
In recent years, the nutrient concentration in these waters has been rising
causing several lakes to suffer from advanced eutrophication. Initially,the
Southern Kennebec Valley Regional Planning Commission (SKVRC) assumed
that septic leachate from lakeside cottages was the source of pollution.
However, water sampling sponsored through the WQM project showed that the
major source of nutrient loading is actually uncontrolled agricultural
runoff particularly from poor retention and disposal of dairy cattle
manure. Because the lakes are so important to the region's economy and
because agriculture is the second largest land use in the area, agri-
cultural runoff automatically became a priority issue in the Augusta
WQM project.
SKV-1
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According to the WQM Project Director, the two year WQM study timeframe,
will not provide sufficient time to deal with the agricultural runoff
problem in its entirety. The State Department of Environmental Protection
(DEP) spokesman agreed that further study is needed on agricultural
practices (other than the dairy industry). The EPA Project Officer
stressed, however that the two year period should be sufficient to
deal with the major agricultural problems, although he too foresees the
need for additional time to implement WQM recommendations.
Although the EPA required interim outputs were not particularly helpful
in the study of agriculture, the WQM Project Director found the interim
reporting process useful in formulating management alternatives. A
citizen and local elected official noted that the interim outputs made
them aware of the agricultural runoff problem and demonstrated that
cooperative effort among area communities would be needed in order to
deal with the existing situation.
At this time, the WQM staff was preparing to present alternative manage-
ment schemes to the public through an Environmental Impact Statement
review process on the WQM plan.^ Selection of final plan recommendations
will depend on the outcome of this process. At this time; however, it
appears that the final WQM plan will call for construction of better
manure retention pits and disposal practices to prevent runoff to lakes
during heavy rains and spring thaws. According to the WQM Project Direc-
tor, the WQM agency is presently emphasizing voluntary compliance with
plan recommendations because regulatory measures do not appear politically
feasible at this time. The Project Director is aware of general local
opposition to regulations of any kind and recognizes that these farmers can
can wield considerable influence on local politics.
Preliminary discussion with farmers has revealed that their main obstacle
to implementing WQM recommendations is the cost of building retention
facilities. In order to relieve the fanners of this economic burden,
the WQM agency is currently attempting to convince the Agricultural
Stabilization and Conservation Service (ASCS) to allow farmers to receive
up to ten yearly grant allotments in one lump sum. This would make a
All WQM agencies in Region I are required to submit EISs on their WQM
plans. The EIS requirement appeared in all Region I WQM workplans, but
only SKVRPC took this requirement seriously and has completed the EIS
as scheduled.
SKV-2
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sufficiently large sum (approximately $25,000) available for construction
purposes. It is believed that too few farmers would accumulate yearly
grants over the ten year period until they had sufficient capital to make
the investment. Furthermore, receiving the money immediately would
avoid further degradation of area waters. Individual farmers would
still have to make the independent decision to commit all their ASCS
payments for the next ten years. Some farmers apparently feel that
since the ASCS grants are more or less guaranteed for a number of other
needs (e.g., purchase of fertilizers, etc.), some other source of
funding (possibly EPA) should be sought for construction of manure pits.
These farmers are reluctant to forego the insurance of the yearly ASCS
grants.
If the voluntary approach fails, the WQM Project Director suggested that
the WQM plan will probably recommend a contingency plan for local
regulation of agricultural (particularly dairy cattle) activities. The
local regulatory program most likely would entail enforcement of a local
plan prepared with the help of the Soil Conservation Service. The Project
Director gave no indication however on the details of such a regulatory
program or the time when such a program may be expected.
As another contingency to the voluntary approach, the State DEP is
currently consulting with designated WQM agencies on the desirability
of statewide agricultural controls. In the case of manure retention and
disposal, for example, farmers complying with an SCS management plan
would be exempt from State permit and inspection requirements. All
others would have to undergo inspection for a permit in order to continue
operation. Should the designated WQM agencies support such a permitting
process, the DEP is prepared to submit a legislative package to the
Governor's office with their support.
The general public and special interest groups have played a minor role in
the WQM process to date. A Citizens Advisory Committee was formed early
in the project but disbanded soon after when the WQM staff found that the
membership on the CAC was identical to membership on the Technical
Advisory Committee or the Management Committee. The WQM Project Director
expects public involvement to occur through the EIS process at which time ¦
final plan recommendations will be selected. The EPA Project Officer
feels that the EIS process may be too late for meaningful public input
since all of the alternatives will have already been formulated and most
citizens will not be familiar with background or the detailed implications
of alternative recommendations. In the Project Officer's opinion, the
Augusta WQM program should have sought more public input and provided
more public education from the project's onset.
SKV-3
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In contrast to the general public, local elected officials and their
delegates have played a relatively active role in the WQM process.
According to most interviewees, regular attendance of some officials
at advisory meetings and frequent, informal contacts with the WQM staff
have kept them generally well informed of the project's-progress. This
situation did not evolve haphazardly but rather reflects the WQM Project
Director's philosophy on public participation. In the Director's
opinion, elected officials are the best spokesmen for the general public
and as decision-makers, local officials are the most efficient target
for education and persuasion. Despite the relatively active participation
of elected officials, however, the WQM Director noted that public
participation is the major weakness in the Augusta project. Other competing
interests and concerns outweigh interest in water quality. Yet the WQM
Director felt that this situation did not present an insurmountable
problem. He hopes that a subtle approach in an ongoing manner will
convince local officials to support the WQM plan. The EPA Project
Officer's only complaint was that local officials were not being con-
fronted directly with alternatives and implications of possible recom-
mendations. Since officials often do not become involved with an issue
until it becomes a crisis or until it takes the form of a discernible
course of action, the Project Officer feels the Augusta WQM project
could benefit from a more comprehensive and open treatment of possible
plan recommendations while there is still time to come to an agreeable
arrangement in the.final plan.
The State has actively supported the Augusta WQM project with technical
-assistance, coordination with other designated WQM agencies and the
promise of legislative support should the latter be requested by the
WQM agencies. The presence of the State has been highly visible and has
added credence to the WQM suggestions both with the public and the
Governor's office.
Facilities-Related Plan Elements
The Southern Kennebec Valley Regional Planning Commission was involved
in wastewater treatment planning activities before the advent of the
WQM project. Each town assigned a member of the agency's permanent
Sewer and Water Committee to the WQM committee structure which provided
the WQM study with a well-informed and concerned advisory panel. With
SKV-4
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the use of WQM population and land use projections prepared as part of
the project's interim ouputs, the WQM Project Director hopes to
promote nonstructural approaches to wastewater treatment needs. En-
couraging signs in this direction can be seen already. The WQM staff
and advisory committee have reviewed all existing and proposed facilities
plan3. The WQM committee is now considering a recommendation to cancel
an inter-community trunkline extension project in favor of on-site
disposal systems. The WQM Project Director's supporting rationale is that
it is more environmentally sound to treat and dispose of wastewater on
site than to collect it all and dispose concentrated effluent into the
Kennebec River. Additionally, curtailing sewer line extension is the most
effective local growth control tool available. A number of communities
are already removing their support for the trunkline due to these WQM
discussions.
The State DEP is actively supporting the Augusta WQM project's nonstructural
emphasis. The DEP is preparing a State legislative proposal to set aside
5-10 percent of construction grant funds for septic systems, agricultural
management programs, etc. Such an arrangement would be far more cost
effective than sewer systems for rural Maine communities.
The WQM Project Director is expanding and promoting a pre-WQM recommenda-
tion to increase regionalization of future wastewater treatment activities
under the Augusta Regional Sanitation District System. ' Augusta already
has enabling legislative authority to assume such responsibility. Whether
or not the final plan recommends such action depends on the reaction of
local communities during final plan review.
Although the public has not been involved in developing facilities related
plan elements, local elected officials have begun to have input through
the WQM Management Subcommittee. Livelier discussions are expected as
plan alternatives are more thoroughly defined and presented.
The State DEP has reviewed and approved WQM interim outputs. The DEP
spokesman expects these outputs and final plan recommendations will
strongly color all future facilities decisions in the Augusta area.
Role of WQM Planning in the NPDES Permit Process
EPA has responsibility for NPDES permitting in Maine. The State, which
currently operates a separate system of permitting, will eventually
assume responsibility for the national system permits.
SKV-5
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The WQM Project Director noted that NPDES permitting is not a major
issue in Wie Augusta area since currently only a handful of permits
are issued there. As a result, there is little discussion of the WQM
plan's role in NPDES permitting among the public or in WQM committees.
Apparently, few citizens or local elected officials are aware of the
process.
The State is planning to consult the WQM plan in its next round of
permitting even though no formal arrangements for coordination have
been made. The EPA Project Officer also stated that EPA will ensure
that NPDES permits are consistent with the WQM plan although he too
was uncertain how this would be accomplished.
Conclusions
The Augusta WOM project has identified a rather straightforward
explanation of one of the area's major water quality problems. In
uncovering the relationship between manure runoff and lake eutrophica-
tion, it has helped the area avoid expensive sewering in lieu of
relatively inexpensive structural solutions (i.e., manure retention
pits) and better management practices. Despite a clear definition of
problem and solution, however, the WQM project may encounter some
difficulties in securing implementation.
The WQM Project Director chose to concentrate on a voluntary approach
to problem solution because of the area's traditional opposition to
interference in local autonomy. The WQM project has recently begun
concerted efforts to reach farmers and acquaint them with the problem
and available solutions. WQM efforts to prompt construction of manure
pits by making ten-year Agricultural Stabilization and Conservation
Service grant funds available in one lump sum however may not be as
much incentive as the WQM agency once hoped. Many farmers feel that
using the available money all at once is too risky in view of unpredict-
able expenses that may arise over the next ten years. Furthermore,
since they are not faced with regulations, farmers stand to lose little
by not taking action. . Without an active public participation/education
program, the Augusta projects cannot depend on grass roots pressure for
local regulations should farmers fail to take action. Perhaps the WQM
project should have been less cautious with local'elected officials
themselves. If the WQM staff had been more persistent in promoting the
need for action, local elected officials may now be more receptive to
suggestions for local regulations.
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But the prospects for implementation are not all dim. Active State
cooperation and potential incentives in the form of statewide regulations
hold a promise for remedial action. Also, nurturing local trust in WQM
findings and assuaging local fears about outside influence may yet
translate into local action in the towns' own good time. The WQM
planning process has gathered data and stirred new interest where it
never existed before. The WQM Project Director is optimistic about
gradual change and plan implementation but only if Federal and/or
State funds for continuing activities and staff maintenance are provided.
One area where WQM's effect will be felt in the future is future facilities
planning. Because the SKVRPC's permanent Sewer and Water Committee has
been directly involved in the WQM process, it has been exposed to .the
development of plan's findings, alternatives and recommendations. Since
the State DEP plans to utilize WQM interim outputs in its funding
decisions, the WQM plan's influence is doubly assured.
NPDES permitting is not a major factor in the Augusta area. Most of the
point source dischargers on the Kennebec are. located up-river from the
Augusta WQM area.
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15 ft. meyers
Southwest Florida Regional Planning Council
Southwest Florida began its WQM project in July, 1976 and
is scheduled to complete the final plan in July, 1978. The
designated area is 6,021 square miles. According to the 1970
U.S. Census it has a population of 306, 756 and has two of the
fastest growing SMSAs in the county. This growth rate was
one of the primary reasons for designation. The area also
has some unique natural resources and, therefore, has a
large tourist population. The total grant amount is
$949,000. One of the area's most serious problems being
studied is urban storm runoff.
Urban Storm Runoff
Urban storm runoff was identified as a problem in a previous EPA-sponsored
study prepared by the Tampa Bay Regional Planning Council.1 A model of
point sources showed that, even if all point sources received advanced
waste treatment, the area's waters still would not comply with standards.
When it came time to define what problems WQM would evaluate, the agency
decided to select key problems in each of four drainage basins. In the
Phillip! Creek basin, the Technical Advisory Committee recommended examin-
ing urban storm runoff. The three other basin committees selected other
problems.
TB-RPC planned for tJae Southwest Florida area until 1973 when the
Southwest Florida Regional Planning Council (SWF-KPC) came into
existence.
SF-1
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Subsequent water quality data has verified that there is a pollution
problem. Althoughtwaste loadings have not been done, it appears that
there are multiple sources of this pollution. The waters contain large
amounts of nutrients, toxics, and heavy metals (lead, mercury, copper),
which appear to vary with the water flow. Traces of pesticides have
been found and this indicates that either residues are present in the
soil or that someone is illegally using certain pesticides.
The WQM Project Director expects that the study can be completed within
the two years. After that point, there are "diminishing returns"; that
is, further study would reveal little. Region IV has required that, for
all water quality problems, WQM agencies must indicate whether problems
will be identified and quantified, whether a solution will be proposed,
or if the problem can be solved. The EPA Project Officer expected that
Southwest Florida could propose solutions to urban storm runoff and
possibly implement them, but that solving the problems in two years
would be beyond expectations.
Currently SWF-PRC is conducting the first stage of sampling. Interpre-
tations of the sampling from the consultant are due at the end of February,
1977. Possible solutions will not be proposed until November, 1977. Al-
though interviewees were cautious to explain that actual sources and,
therefore, solutions are unknown at this time, they did speculate as to
possible actions. The EPA Project Officer suggested that county ordinances
requiring review of construction plans might help control sedimentation.
One citizen felt that regulations for commercial parking lots would con-
trol some of the toxics. A local elected official felt that better en-
forcement of controls over a trailer camp might reduce the high coliform
count.
One County Commissioner admitted that the county does not have appro-
priate regulations to deal with urban runoff at this time. He feels the
WQM study has forced county officials to talk more about the issues, but
he is unsure what type of regulation might be adopted. A commissioner of
another county feels county officials are taking a preventative approach,
correcting problems as soon as they learn about them. One citizen, a long
time activist in water related issues, is too impatient to wait for the
WQM project to complete its studies and make recommendations ("confirming
the invention of the wheel"). He has obtained a sample urban storm runoff
'ordinance from Orange County and is asking the Sarasota County Commission
to adopt it.
SF-2
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Everyone agreed that proposed solutions to urban runoff problems will
most likely be regulatory. The EPA Project Officer explained that,
because this is such a fast growing area, a strong approach is needed.
The Project Director explained that the WQM plan is looking for inex- '
pensive, politically acceptable solutions so that proposals will be
implemented quickly to alleviate the pollution problems. The Commis-
sioners of two counties also agreed that proposed solutions would be
regulatory, but they were indifinite as to the content or timing of
such regulations.
According to the WQM Project Director, the interim outputs were completed
several months ago but, because they were not specific enough, he did not
consider them particularly useful for the urban storm runoff portion of the
study. The agency is not preparing to re-work the interim outputs so that
the information is useable, particularly for the point source work.
Although the Project Director felt that plan implementation could begin
before approval, both the State liaison and the EPA Project Officer felt
this to be unrealistic. The EPA Project Officer cautioned that the tech-
nical work will not be substantial enough to prove a definitive cause and
effect relationship. He felt the WQM agency should not try to develop a
full range of specific recommendations at this time, but rather should con-
centrate on involving policy people. The State liaison felt that more study
is needed in the area to find out which areas are favorable for development.
Then ordinances can be prepared to control development there. Because of the
rapid growth in the area, the citizen interviewed felt that the biggest barrier
to implementation would be from the construction industry. The interviewee was
confident that more active involvement from environmental groups could offset
opposition.
The steps for plan approval have been fairly well set. First, plan approval
is recommended by the Policy Advisory Committee (five elected officials).
Next, the plan is approved by the Regional Planning Council which includes
elected officials from all local jurisdictions. Next, the plan is reviewed
by the State Department of Environmental Regulation and is certified by
the Governor. Finally, the plan is approved by EPA.
The State of Florida has suggested a plan format to each WQM agency as well
as specific problems that each chapter should address. In part this was
done to improve consistency among the WQM plans so they can be easily in-
corporated into the statewide plan. Agencies have been told that they
can submit chapters in advance of the full plan and receive sign-off on
those portions.
SF-3
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It still does not appear that citizens are becoming actively involved
in the WQM effort despite the fact that, as several interviewees noted,
the area is environmentally-oriented. The Project Director noted that
citizens through the WQM committee structure eventually will review the plan.
Local elected officials, though aware of the WQM study through their contact
with the Policy Board, are not heavily involved^ The Project Director explained
that it was hard to maintain officials' interests during sampling. During
problem identification some elected officals were very active, and it is
expected that they will become involved again. The two elected officials
interviewed feel they have an excellent program which is meeting its
schedule. Thus, they feel no additional need to become more involved
at this .time.
rhe State Department of Environmental Regulation has an areawide co-
ordinator for general coordination and review role. The State liaison
felt the Southwest Florida program is "moving along well", (especially
relative to other programs in the State) and that they have a "good
handle on what they're doing".
The State has proposed an anti-degradation ordinance that would impact
all areawide agencies. At one time the State was preparing nutrient,
standards which would have related to runoff, but lately they have
not been supported actively. Most State activity has centered on re-
organization of the Department of Environmental Regulation. The
eleven areawide agencies in Florida have formed a coalition, organized
initially in opposition to the mandate demanding that a certain per-
centage of each WQM grant be given to the State for review and coordi-
nation. Subsequently, the group has yet to exchange data, technical
information and strategies for solving common problems.
EPA Regional Office has not been heavily involved in the WQM study. In
part this is due to understaffing, but it is also because SWF-EPC is
independent and does not request much assistance or involvement.
Facilities - Related Plan Elements
Nine facilities plans are now underway in this region. One of the largest
cities, Ft. Meyers, filed its completed 201 plain in the fall of 1976.
The City Council approved the recommended sewer districts and applied
for Step II funds to plan for an additional, facility. In another service
district, plans are being made for sewer hook-ups. The city is now look-
ing at its infiltration problem. Clearly, there is little the WQM agency
can or should do to get involved in a planning process so well advanced.
SF-4
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The WQM interim outputs, however, may be used in future planning.
Other jurisdictions in the designated area,have been moving more slowly
and a couple of the smaller towns have done no facilities planning. The
WQM planning agency has held one workshop to explain facilities planning
and another regarding user changes and industrial cost recovery. Initi-
ally, the WQM agency thought it could write 201 plans for those areas
not yet involved, but they have since decided that their proper role is
to offer assistance.
Citizens and local elected officials alike believed that it was necessary
to have an approved WQM plan in order to receive 201 funds. In fact, to
some, this was the only reason for producing a WQM plan.
Two counties are starting new wastewater treatment related projects in
addition to their general 201 planning. One County Commissioner explained
his area is just starting a pilot project on salt water intrusion . Another
county is starting to buy small wastewater treatment franchises. This
is a costly undertaking in part because the franchises recently were
upgraded and, thus, are worth more. The county, however, feels they
can make wastewater treatment into a money-making proposition. The
WQM is not involved in these activities. Rather they concentrate their
efforts on guiding jurisdictions that need help through 201 planning.
The WQM agency is just starting to look at the existing facilities
management system and to see which agencies would qualify for a lead
management role. The Project Director said they most likely would not
create any new agencies. As the management analysis is just starting,
none of the other interviewees knew what would be included. One citizen
and one county commissioner each felt the most likely choice for a manage-
ment agency would be the Utility District. The Commissioner from another
county expected they might establish a cooperative city/county manage-
ment program by joint agreement. The Ft. Meyers Director of Community
Affairs pointed out that a previous study had recommended creating a
utility authority. The City, which felt it had effectively managed its
treatment facilities for several years, refused to accept the recom-
mendation. The WQM planning process will have little effect here.
Each of the nine -201s .has its own citizens committee. Some citizens are
on both 201 and WQM committees, so there is effective communication.
Local elected officials rarely are involved, although their representa-
tives (who are technical people, planners, engineers, etc.) are very
involved. Beyond funding the projects, neither the State nor EPA seem
to be heavily involved in the actual facilities planning in this area.
SF-5
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Role of WQM Planning in the NPDES Permit Process
EPA has the permitting authority in Florida, although the State eventu-
ally may have an approved program and assume responsibility for it. There
is a separate State permit required. There are few industrial dischargers
in the two county area and most permits are for municipal treatment facili-
ties.
The WQM agency receives permit applications for review, but so far they
have not become very involved in permitting. The citizen interviewed
was critical of the WQM effort for not being more interested in permitting.
Recently this citizen challenged the EPA permits because they failed to
incorporate the State standards, for discharge into salt waters of
Tampa Bay.^ EPA subsequently has agreed to re-issue the permits. The
citizen felt that this is the kind of activity the WQM Agency should be involved
in, yet so far they have showed no interest, despite this person's promptings.
Conclusions
It is difficult to predict the outcome of the urban storm runoff plan ele-
ment because the WQM project is still at the sampling stage.- Possible solu-
tions will not be proposed until November, 1977. Most everyone involved is
thinking in terms of regulatory programs in the form of county ordinances
to control the several nonpoint sources of pollution. Everyone interviewed
cited a different example of the kind of source problems that must be
regulated, which may indicate that the study is not yet narrowing and em-
phasizing particular problems. The activist citizen clearly was impatient
with the WQM program and already was starting to suggest ordinances to
commissioners of the county in which he lives.
Neither citizens nor elected officials are deeply involved in the project.
This does not appear to concern the WQM agency because the technical re-
presentatives such as most directly responsible for implementation are actively
involved. This lack of interest also may be due to the lack of controversy
in the program. The WQM agency did not explain how they expect to win
approval of their plan if citizens and elected officials are not involved.
1
The Wilson-Grizzle Act (1972) requires advanced wastewater treatment
for discharges into Tampa Bay. This State law is mere restrictive than
the secondary standard of PL 92-500.
SF-6
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The WQM agency, with the encouragement of the EPA Regional Office, has
spent much of its energy guiding the local jurisdictions through their 201
planning. The agency is just starting to look at the existing facilities
management system in order to evaluate the powers of each one. Most likely,
there will be a mixture of management authorities and powers in the differ-
ent counties. It is unlikely that there will be many changes from existing
authorities in any of the counties.
There are very few industrial permits in the area, so the WQM planning
agency has taken little interest in NPDES permitting procedures. A least
one citizen, however, is critical of this stand and feels the permits
must be reviewed to ensure that they comply with all pertinent water
quality standards.
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16 sussex county, del
Sussex County Council
Sussex County began its WQM project in February of
1976 and is scheduled to complete its final plan in
January, 1978. The designated area consists of over
350¦ square miles with 24 miles of ocean frontage.
Resident population is approximately 40,000, but
this rises to well over 70,000 during summertime and
on certain other weekends according to County estimates.
The total grant amount is $633,089. The Sussex County
WQM project was awarded to the Sussex County Council,
rather than to a regional planning council or council
of governments as most other designations. The area
was designated because of agricultural activity inland
and because of recreation uses along the coast.
On-Lot Disposal
Residents of the area have known for some time that there was a water
quality problem due to on-lot disposal, particularly along the shoreline.
Septic tanks are generally unsatisfactory because of poor soil drainage
and a high water table. Much of the area around the bays has'been
ditched in order to create usable land, but those areas are also not
suitable for septic tanks. The WQM study is the first serious attempt
to find alternative measures to deal with the problem.1 Further com-
plicating the problem, the beachlands along the eastern shore attract
large numbers of visitors on weekends and summer vacations.
A full description of the on-lot disposal study as well as dune irriga- •
tion and spray irrigation elements of the WQM study can be found in
the Sussex County application for a National Association of Counties
Achievement Award
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During the early stages of the WQM study, preliminary analyses showed
particularly serious water quality problems in heavily populated areas.
The Friends of Herring Creek, a conservation group in the area, also
asked the WQM study staff to look more closely at Herring Creek and its
problems. This led the WQM staff into a close working relationship
with the Coastal Zone Management (CZM) staff of the State planning office.
The WQM study thus slowly developed a planning framework focused on
general shoreline development and seasonal population flux. The strategy
is to possibly .replace on-lot disposal with a pumping system to a disposal
facility.
During the compilation of a land use inventory, the WQM agency noted an
unexpectedly large number of campgrounds mostly along the shore and bays.
These campgrounds contain 4,000 - 4,200 campsite units servicing 30 - 40,000
campers yearly. All of the campsites have on-lot disposal which presents
a tremendous potential problem of contamination. Although they have
been unable to definitely prove there is a problem, the WQM staff will
most likely recommend new and revised regulations for wastewater
practices at campgrounds.
The EPA Proj ect Officer suggested that one possible solution might be
creation of a "buffer zone" in which effluent disposal would be prohibited
or restricted. Because septic tanks are currently regulated by the State
Department of Natural Resources and Environmental Control, he expected
the WQM plan would recommend changes to more closely relate State regula-
tions to subdivision regulations at the County level.
The WQM Project Director described a number of alternative solutions that
might be proposed. These include:
a Better enforcement of existing State regulations, particularly
through a more active inspection system;
• Requiring that percolation tests be done by a licensed
contractor
• Review of all subdivision permit applications by the
Technical Advisory Committee (TAC). (The WQM study has
examined soils and elevations and now knows land use
capabilities and septic tank suitabilities.)
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• Requiring mound units for septic tanks;
• Requiring all subdivisions to hook into subregional
facilities;
• Creating sanitary districts.
'There was no local planning or zoning in this area until around 1970.'
Since many regulations and procedures are still being developed, water
quality criteria probably can be worked in fairly easily at this time.
One citizen noted that zoning regulations for camping originally were
based on tent camping, yet now most camping is done by vehicle, which
permits more campers and creates'more wastes. This citizen also mentioned
that stricter development regulations are needed to protect water supplies.
He cited a University of Delaware study of 850 wells that showed salt-
water intrusion and the presence of nitrates.
Two citizens, the State liaison and a town administrator all mentioned
the possibility of mounding. One of the citizens, however, pointed out
that it is not enough to suggest the best available technology, such
techniques should be tried on a demonstration basis first. Yet he felt
that the WQM study timetable leaves no time for such a demonstration,
and further that the grant conditions did not allow for "research" type
activity. Although most of the interviewees cited a central treatment
plant as an alternative, they noted its high cost, particularly in such
rural (and often unincorporated) areas.
Correction of septic tank problems will require the combination of
structural, regulatory and voluntary approaches. Prevention of problems
from future campgrounds can be handled through regulations. Correction
of existing problems is more difficult. The State liaison noted that
neighboring New Castle County retracted local inspection authority. This
could also happen in Sussex if the County could find the money to hire a
trained engineer. The WQM Project Director hoped to achieve voluntary
compliance by convincing individuals that it is cheaper to change or clean
out their septic tanks than to pay for a sewer hook-up. One citizen
suggested it may be necessary to. establish a loan program to carry out
the program.
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The WQM interim outputs are currently being completed. Population pro-
jections were done by the University of Delaware, Division of Urban
Affairs, and presented to the Policy Planning Board and the Citizens
Advisory Committee. Citizens, a town Mayor, a town administrator and
the State liaison all pointed out that there is some disagreement
about the number of weekend and vacation visitors to the area. Most
felt the projections were too low (trailer parks were omitted and some
noted occupancy rates were too low). The University has been asked
to recalculate these figures before formal adoption. The service area
delineations show 30 - 40 percent of the population will be on the
regional system leaving the balance in need of additional planning.
Wasteload allocations will be done by the State. Perhaps the most
useful interim output to the on-lot disposal study was the land use
output which, as noted above, pointed out the potential problem of
campsites.
The Sussex County WQM project is somewhat unique in that it is organized
under both the County•Council and the County Engineer's Office. According
to the WQM Project Director, this unique situation presents an excellent
opportunity for implementing solutions immediately rather than waiting
for the full plan to be completed and approved. Furthermore, upon the
recent resignation of the County Engineer, the WQM Project Director was
appointed acting County Engineer. Although this may mean that he must
spend more time,on facilities planning and less time on areawide WQM issues,
it also means he will have intimate understanding of the implementation
needs of WQM alternatives. Several interviewees cited this appointment
as evidence that the county officials have growing confidence in and
support for the WQM effort.
The WQM plan will have to be approved first by the WQM Planning Policy
Board which is composed of elected officials. The Board has had some
trouble maintaining attendance at meetings, but the EPA Project Officer
pointed out that the most crucial issues concern development in areas under
county jurisdiction. Since these areas are of less concern to already
developed towns, he feels it may not be so important to get full approval
of all elected official's in order to implement the plan. After the
Planning Policy Board, the plan must be accepted by the individual members
of the County Council.
After local approval, the Delaware Department of Natural Resources and
Environmental Control will review the plan. The WQM Project Director and
RPA Project Officer both noted that fiscal problems in the State could
SC-4
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limit the amount of personnel time that can be spent on plan review.
The new Governor has shown concern for environmental issues in the past,
but must spend much of his time on the State's financial troubles.
The New Castle County plan will have been approved previous to Sussex
County's so the Governor will at least be familiar with the need for
his certification of the plan.
Cost seems to be the greatest barrier to full implementation of the' plan.
The EPA Project Officer suggested they might devise a system whereby those
who benefit pay, such as through a camp tax. The State liaison
speculated about the possibility of Federal money since he doubted that
local governments could pay for new authorities. The State liaison also
cited a conservative attitude of anti-regulation which could limit the
strength of regulations adopted.
Citizen involvement has been somewhat limited to a small hard-core group
of 5-10, but as the State liaison noted, they are earnest, concerned and
raising good questions. Two interest groups — Save our Seashores, Friends
of Herring Creek — have been involved in different parts of the study.
The EPA Project Officer pointed out that the population in this area does
not generally get involved in anything on an ongoing basis unless there
is a crisis. One of the involved citizens speculated that others are not
more involved either because they fear it is too technical for their
comprehension or because they are confident that someone else will
represent their interests.
Another involved citizen explained that the CAC role is pretty well defined,
and it includes responding to presentations by the staff. He expected
their role to be more interesting and that there would be more opportunity
for involvement as more reports are completed. A town administrator who
is Chairman of the CAC felt there is growing interest by the public. He
said most did not see their problems until the WQM study came along. He
added that most of the interests of the area — canning, cattle, agriculture,
tourism — are involved in some part of the study.
Although supportive of the Sussex County project, the citizens interviewed
had some general criticisms of the national program. One felt that
EPA had included too many planning requirements. He felt many of these
were'not needed in all areas, yet they were still required. To get their
money's worth, he felt EPA should sharpen their requirements to fit the
needs of each area. A second citizen felt that there is a national lack
of public understanding of the purpose and scope of the program. In turn,
he felt this makes it difficult for locals to arouse interest in their own
project.
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Local elected officials are involved through the Planning Policy Board.
According to the EPA Project Officer, the Board will make suggestions,
but generally does not give too much direction to the staff. Some
elected officials (particularly from the coastal parts of the County
which stands to be effected most) are very active in the WQM program.
The Councy Council stays informed, mostly because the County Administra-
tor has remained interested and involved in the project. The WQM
Project Director, EPA Project Officer and the two citizens both expected'
interest to pick up as the study becomes "less abstract and more
decisions are made".
Two State agencies are actively involved in the WQM study, the State
Planning Office (which has coastal zone management responsibility) and
the Department of Natural Resources and Environmental Control. A recent
turnover in administrations has brought several personnel changes. The
new State liaison formerly worked in State Planning, and has brought some
knowledge of their programs with him. One citizen described him as an
"instant entree" to State programs.
The WQM Project Director was very complimentary in his comments about EPA
involvement. He feels they have sent good technical informaticpn and have
recommended attending outside conferences on subjects related to work
being done in Sussex County. The EPA Project Officer described his own
role as primarily supervisory.
Facilities-Related Plan Elements
Early in the WQM study, the WQM agency became involved in seeking alterna-
tives to an ocean outfall for the Locato treatment plant. The WQM staff
recommendation for spray irrigation of the effluent was adopted by the
County Council. The WQM agency held four workshops to explain the process
and several farmers and canners have shown an interest in participating.
The alternative has gained widespread praise because according to the WQM
Project Director, it saved the area $10 million in construction costs.
Early analyses also show that irrigation of the effluent may increase
agricultural productivity of the land.
Another alternative considered was dune irrigation. The State, however,
opposed this alternative so the topic has been turned over to the University
of Delaware for furthur study. Aside from the work on alternatives to the
ocean outfall, however, the WQM has not been particularly involved in
facility planning activities. Seeing that point sources were already
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adequately handled, the WQM study focused more on nonpoint source problems.
As part of the WQM study, a consultant studied existing facilities, but
no significant recommendations for change were made.
Facilities planning is handled directly in the County Engineer's office
and the two staffs have worked freely with each other. As noted above,
the WQM Project Director has recently been named acting County Engineer,
so it is possible that the two programs could work even more closely
together.
The population and service area delineation in the interim outputs will
be useful for facilities planning work. The EPA Project Officer explained
that the population projections will also be useful, but they are not
yet at the necessary level of detail. The WQM study will eventually
detail the population distribution. The EPA Project Officer also felt
that the elected officials most.interested in facilities work are those
whose areas are most likely to eventually hook into the Locato system.
There is less interest from these officials and from citizens in general.
The Role.of WQM Planning in the NPDES Permit Process
There are approximately 15 NPDES permits in this area. The State of
Delaware has the permit authority and the State liaison said that there
has been good enforcement and compliance from industries in Sussex County.
He added that the State will use WQM information in making permit decisions,
but there is no formal means for their input besides posting legal notices
on permit issuance.
The WQM Project Director did not feel it was the WQM project's role to
become invovled in permit decisions although the WQM staff have spoken
with permitted industries, and offered WQM assistance in ways to comply with
permit restrictions. Spray irrigation was a solution for some of the inr
dustries. The EPA Project Officer suggested that the WQM study might
indicate that much of the area's pollution is coming from nonpoint sources,
If ways could be found to control these sources, he reasoned, it would
lessen the pressure to clean up point sources.
Conclusions
The Sussex County WQM project has already had a major success by con-
vincing the County Council to adopt a spray irrigation program for their
effluents. Advantages include:
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t> Abandoning the ocean outfall which was controversial
and divisive;
o Cost saving of $10 million;
e Providing effluent to farmers for improved productivity.
Having been credited with finding this mutually agreeable solution, the
WQM study has gained the respect and support of most locally elected
officials and citizens. Recently the WQM Project Director was appointed
acting County Engineer. Most everyone took this as a sign of support
that the County Council and County Administrator agreed with his
performance to date.
After dealing with the effluent disposal question, and seeing facilities
planning work already adequately handled, the WQM staff decided to con-
centrate its efforts on nonpoint source problems. Early land use analysis
showed a large number of campsites in the area, all using on-site disposal.
Consequently, the WQM study extended its septic tank regulations to include
campground regulations. A full program of inspection, design criteria,
and conditions for installation (via zoning and subdivision regulations)
will most likely be recommended.
The Sussex County WQM plan has an excellent chance of being adopted and
implemented. The WQM staff's position in relation to both the County
Council and the County Engineer's office puts them in direct communica-
tion with potential implementors. Although the State is in a fiscal
crisis, they have lent support to the project whenever possible. Sussex
has also been able to learn from the experiences of New Castle County
which is approximately one year ahead in schedule.
As with other areas, the principal limitation to implementation will be
monetary. The WQM Project Director, however, is hopeful that voluntary
approaches will be successful. Steps are being taken to create utility
districts as a means for raising revenues.
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17 teton county
Teton County 208 Aqencv
Teton County began its WQM project in July, 1975 and is
scheduled.to complete the final plan in July, 1977. The
desgnated area is over 3,500 square miles large, 97% of
which is publicly owned, mostly by the Park Service. The
resident population is 7,300 people according to 1975
estimates, but in the summer months the area has nearly
3 million visitors annually, an equivalent summer month
population of 12,000. The total'.grant amount is $37,000.
The Teton County area was designated because of its tourism
and recreation value and as a preservation area. Septic
tank seepage is one element of the WQM study.
Septic Tank Seepage
Three major, related planning studies are being conducted simultaneously
in Teton County. These include:
e The WQM study which is being prepared by a specially created
agency whose Board is made up of two county and two town
officials.
« The comprehensive land use plan which is being prepared for
adoption by the Teton County Planning Agency and the County
Commission.
• An EIS which is being prepared for the Town of Jackson
sewer treatment plan to deternine whether to expand
and upgrade the plant or build a second plant.
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Most of the WQM planning is actually a subpart of the comprehensive land
use planning and is being conducted for Teton County by the same consultant.
All of the WQM work being done on private lands relates to the land use
planning. Other parts of the WQM study including monitoring and develop-
ment of BMPs for activities on Federal lands will be done by the National
Park Service.
Several reports prior to the WQM study indicated there was a septic tank
problem, and there was a suspicion that wells were being contaminated
from seepage. Residents of Wilson specifically requested that a study be
made of their area. So far, however, the WQM study has been monitoring
thirty wells and found no contamination. They will continue monitoring
in the spring when water levels are high. The Project Director feels
it is important that this type of monitoring continue indefinitely,
possibly combined with some studies of groundwater movement.
Despite the findings that there does not appear to be a problem, the WQM
agency is submitting a report to the County Council that calls for design
changes in septic tanks, tighter monitoring and stricter State controls.
In a related action, the comprehensive plan recommends "Environmental
Protection Districts", some of them based on groundwater conditions. These
districts would require:
o Separation of leach fields and minimum distance between
tanks.
• An evaporation rate loss design factor 7.1 (versus .17).
o Septic tank inspection every three years.
• Delineation of an alternative leach field in case of
malfunction. This would be indicated on the development
application.
Under the proposed solution, authority for inspection and monitoring would
rest with the county engineer. The WQM Project Director expected it would
be necessary to hire a water quality specialist to assist the county
engineer with this and other problems. Up to this point the State has
been largely responsible for supervision of septic tanks. The State is
interested in delegating this authority to county engineers and so has
encouraged the WQM agency to recommend inspection by local officials.
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Citizens and local elected officials are aware of the WQM Project recom-
mendations for septic tank regulations and are in support of them. . The
interviewees felt that nearly everyone agrees that even though there is
not an immediate problem, some kind of regulatory program along with
inspection is a good idea.
The WQM agency will present its technical report to the County Council
in February. After the Town Council and County Commission have made
their comments, there will be a formal public hearing (probably in
mid-March). The final plan will incorporate comments made, be adopted
by the WQM agency board, and then sent to the State. At the State level,
the.plan will be reviewed by the Department of Environmental Quality,
the State Technical Advisory Committee, A-95 Clearinghouse, the Water
Quality Advisory Board (all Governor's appointees) and Water Division
Citizen Committee. After their review, the Teton County WQM Agency
Board will officially adopt the plan and it will be sent for Governor's
certification and EPA approval.'
Neither local, State nor EPA officials expected many problems in the
plan being adopted and implemented. At the local level, there was
expected opposition from certain large workable solutions. Some problems
were expected with BMPs written by a local agency for use on Federal
lands, but these were expected to be minimal. The State, if not always
active, is at•least always aware of the WQM activities. EPA Regional
Office had assisted technically by inspecting grazing practices and by
flying remote sensing units to provide pictures for forestry elements
of the plan.
Because the comprehensive plan schedule is ahead of the WQM schedule,
certain portions of the WQM plan will be implemented ahead of the full
plan. The complete WQM plan which includes the technical work,
recommendations for BMPs on Federal lands, and proposed regulations on
private lands will appear as a separate document for approval by citizens,
local agenices, the State and EPA.
While there is mixed support for the comprehensive planning effort, there
is . broader support for the WQM portions of the plan. Citizens seem
impressed that it is analytical and proposals are based on facts. One
citizen who has come to oppose the comprehensive plan (because it is
"rotten politics" and "destructive") claims he will support only the
WQM portions of the plan because they are based on facts and made sense.
Elected officials claim they are impressed with the WQM presentations on
runoff, septic tank problems, and findings that little pollution is
being generated from the Elk Refuge located within the designated area.
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While all three planning efforts deal with issues of growth, the
comprehensive planning effort is most controversial because it deals
with these issues most directly. Some opponents accuse the con-
sultant of trying to create "suburbia in the mountains" and thereby
destroying their ranching lifestyle. Other residents see planning
as the only way to prevent total destruction of the area. In the
most recent town and county elections (Fall 1976), the need for plan- .
ning and land use controls and location of the sewer plant were the
most talked about issues. Pro-planning candidates won both town
and county offices. Another important sign of support occurred at.-,
a recent workshop on the EIS for the treatment plant. Citizens opposed
those alternatives which they believed were inconsistent with the
comprehensive plan and the WQM plan.
Facilities-Related Plan Elements
The Town of Jackson is currently preparing an EIS for its treatment plant.
Although the plant is owned and operated by the town, the decisions have
impact on the entire county. The WQM plan and the comprehensive plan
must consider the whole country and recommend whether unincorporated
portions should hook into the town plant, continue on septic tanks, or
build their own plant. Some management relationship must be agreed upon.
Most likely there will be a joint town/county memorandum of understanding
either for annexation or for the town to accept, county wastes in exchange
for a tap fee or a service charge. It is unlikely that there will be a
new agency.
The WQM agency is aware, of the EIS activities, but has interpreted their
role to be strictly review (because the construction grant was awarded
ahead of the WQM plan). Thus, the WQM agency is waiting for the final
EIS before discussing a management system, at which time they will
respond to the EIS and make recommendations for management.
The interim outputs prepared by the WQM agency were used in the EIS to
develop alternatives. Originally there were 12 alternatives which have
now been narrowed down to five. These include alternatives'for three
new sites, upgrading the existing facility to 1977 standards, and expanding
the existing plant to accommodate 1995 capacity. Each alternative has been
evaluated against land use projections and goals of the comprehensive
plan.' The population projections were considered less useful than some
of the other interim outputs, in part because the county intends to find
ways to manipulate its population size. The WQM Project Director said
there is no need in this area for the wasteload allocations identified
in the EPA interim.-,output guidelines.
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The town has earmarked $550,000 for construction of the facility. This
project is number five on the state priority list, but because numbers
two through four are completed, it is number two in line for existing
funds. Because the State is short of construction grant funds, they
favor the interim upgrading alternative.
Both citizens and local officials are actively involved in the EIS
process. Workshops are well attended and there will be a formal hearing.
Interestingly, some of the most active involvement comes from county
not town residents, although it is the Town Council that will make the
final decision. This shows that county residents clearly see the potential
impact of the treatment plant.
Role of WQM Planning in the NPDES Permit Process
The State of Wyoming has permitting authority in this az'ea. However,
this is not a particularly large issue.as there are only five permits.
Four of the permits are for wastewater treatment plants (Town of Jackson,
Teton Village, Grand Targhee Ski Area and Jackson Hold Golf Course).
The fifth is issued to the Jackson National Fish Hatchery. Recently, a
laundromat in Jackson applied for a discharge permit and the State asked
the WQM agency for comments, but most citizens and local officials know
little if anything about permitting. It is too soon to know how the
WQM agency comments will be used.
According to the State water quality liaison, permits are based on effluent
limited classification. The statewide WQM plan is reviewing standards,
looking at water uses and criteria.
Conclusions
The Teton County WQM plan seems well on its way to completion and imple-
mentation. It has the respect and support of citizens, local officials,
the State and EPA. Excellent coordination among the comprehensive land
use, EIS and WQM planning processes, is probably the single most encouraging
sign of potential success. The WQM plan appears technically sound and
holds a promise of implementation through the land use controls being
proposed by the comprehensive plan.
Obtaining local WQM plan approval, however, will not be easy. "Zoning"
and similar regulations have connotations threatening to local autonomy
and are therefore generally opposed by nearly all residents of the area.
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Although much controversy still surrounds portions of the land use plan,
there appears to be general agreement and support of both the intent
and specifics of WQM portions. Residents are willing to support controls
where they recognize an existing' or potential problem. For this reason,
it is -very likely that some kind of land use controls (whether they take
the form of "Environmental Protection Districts" or some other scheme)
recommended by the WQM plan will be implemented. For example, despite
the fact that the WQM agency monitoring showed no existing problem of
septic tank seepage into wells, people understand the value of tightened
controls and a regular inspection program. The county will most likely
adopt this WQM recommended program.
The WQM agency has not been deeply involved in the EIS for the town treat-
ment plant. The interim outputs, however, have proved useful for developing
alternatives.to those preparing the EIS and to town and county officials
who are reviewing it. Citizens involved in both efforts have understood
the potential relationships between the WQM study (and comprehensive plan)
and the EIS. They have insisted that the studies be consistent with
each other, and that the EIS not select a treatment plant location that
would allow development in areas not recommended under the comprehensive
plan. Some of the same town and county officials will approve, adopt
and implement both plans.
Because this is a single county area whose problems are somewhat self-
contained and which is simultaneously facing several issues on its future,
this was a timely period in which to do a WQM study. It is respected
for gathering monitoring data about the area before developing recom-
mendations. Being such a small area (population-wise), it may be
difficult to fund additional positions needed for ongoing inspection
but because there is general agreement on the need, there is an excellent
prospect for this occurring.
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18 ventura
Ventura Regional Sanitation District
The Ventura County Regional Sanitation District was designated
for WQM planning in June, 1975, and began its project in
June, 1976. The final WQM plan is scheduled for completion
in June, 1978. The total grant amount is $928,000. The WQM
area coincides with the County's jurisdictional boundaries
and the Ventura-Oxnard SMSA and had a 1970 population of
450,000 according to the U.S. Census. The area has recently
experienced substantial growth which is expected to continue
with increasing pressure from Los Angeles. This rapid growth
along with groundwater pollution and mineralization from
agricultural runoff and irrigation practices led to the
County's designation for WQM planning. Since water supplies
are limited in the area, protecting the current supply is of
primary importance.
Irrigated Agriculture
Ventura County has some of the richest agricultural land in the country.
For some time however, the County has suspected that prevalent agricultural
practices and high volume water demand were contributing to degradation
of limited groundwater supplies by building up salt concentrations and
promoting saltwater intrusion.• The WQM project investigated these
suspicions and focused local environmental and.economic interests
on the subject. Although the WQM agency would like the luxury or more
time to study the problem, the Project Director along with most other
interviewees agree that the two-year study timeframe will provide sufficient
opportunity to assess the situation and develop appropriate recommendations
for action.
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Although Ventura is still in the data gathering and analysis stage,
the WQM Project Director offered a list of plan alternatives to be
considered. Among these were:
e Continuing present irrigation practices, but importing
better quality water for irrigation and recharge
purposes;
o Changing patterns of water use by tapping deeper
aquifers or limiting the amount of watering to avoid
excess runoff;
® Controlling the amount of pumping to avoid overdraft;
« Constructing a brine line to channel water with heavy
concentrations of natural salts and fertilizers out to
sea rather than to the local groundwater; and
® Changing crop rotation patterns.
Eafih alternative will be examined in terms of tradeoffs among air, water,
transportation and economic concerns. The channel for reaching a con-
census on these tradeoffs is the Regional Land Use planning program which
is a conglomerate of concurrent air, water, transportation and com-
prehensive land use planning efforts. (For a detailed discussion of the
RLUP program, see Centaur's "Areawide Water Quality Management Program
Survey" of October, 1976.) All interviewees were confident that the
WQM study would generate technically sound solutions for improving or
at least preserving present water quality without sacrificing continued
agricultural production.
The interim outputs are expected to contribute to the likelihood of plan
approval because, unlike summary reports issued to date, the interim
outputs will require approval from each of the nine participating cities
and the County. According to the State liaison from the California
Water Resource Control Board, the approval requirement will necessitate
attention from local decision-makers and should generate active interest
on their part. Little opposition to the interim outputs is expected
since the Ventura County Regional Sanitation Commission (the WQM agency),
contracted with each of the local communities for population and land
use projections.
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The final plan solutions are expected to consist of a combination of
voluntary and/or educational and regulatory programs. The WQM Project
Director expects a heavier emphasis on regulations due to the extent
and severity of the problems at hand, although he did note that the
decision to adopt regulations will be left to the discretion of local
communities unless otherwise mandated by State law. The State spokes-
man corroborated on the possibility of statewide regulations but only
if absolutely necessitated by the lack of local initiative or by local
jurisdictional disputes. A citizen interviewee and the EPA Project
Officer felt that the WQM agency would probably explore educational
and voluntary approaches before suggesting regulations since the former
are easier to accept and make the latter more palatable when necessary.
All interviewees were quick to add that no matter which approach was
selected, every attempt would be made to stay within the confines of
existing institutions. New arrangements between or among institutions
might be approved but no one favors creating completely 'new entities given
the existing multitude of local, county, and State management and
regulatory agencies.
All interviewees were remarkably optimistic about the likelihood of
plan approval and implementation. The WQM staff is already laying a
groundwork for plan approval by contacting local and county officials
on an individualized workshop basis. The purpose of these early contacts
is to bring as much information as possible before decision-makers while
there is time to discover possible problems or disagreements and make:,
adjustments where necessary. Requesting local approval of plan elements
along the way will make final plan approval much easier at the end of
the planning period. The WQM Project Director will advocate implementa-
tion of some land use elements of the WQM plan even before it is com-
pleted. However, he noted that the WQM project will tread softly in
this direction. According to a county official, the participating cities
aire approaching implementation cautiously. They appear willing to act
but not in a piecemeal fashion before all the facts and plan elements
are brought into focus. The WQM Project Director is avoiding the "hard
sell" approach so as not to produce a threat of outside interference in
local decision-making.
The final WQM plan is scheduled to go through a complicated set of approval
steps before it is adopted. Although it may appear somewhat tedious,
this procedure almost guarantees implementation in that all implementa-
tion actors will be involved and all possible bases of coordination will
be touched. The plan will first undergo review by the nine municipalities1
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technical staffs and the staff advisory committees of the four participating
RLUP programs. Next, it will go before the RLUP Steering Committee which
is composed of local elected officials representing each of the four
individual program committees and then to the Ventura County Association
of Governments (VCAG) Executive Committee. This Committee is composed
of one representative from each participating city and one county official
representing unincorporated areas. Finally, the plan must be approved by
the City Councils of each participating municipality and by the County
Board of Supervisors. According to one county official, the Board of
Supervisors is strongly in favor of the WQM plan and is planning to take
a lead in approving so as to convince local communities to do the same.
No organized opposition to plan approval is anticipated at this time.
All interviewees were hopeful that the WQM staff will be successful
in convincing local communities that failure to take immediate action
may herald the end of agriculture in the county. One citizen felt that
the current West Coast drought will work to the benefit of the WQM
project by causing water prices to rise thereby highlighting the imminent
crisis. The only possible opposition anticipated is from builders and
other pro-growth proponents who are expected to view the WQM as a method to
frustrate new development. A local official also noted that should the
plan necessitate local funds for structural solutions to irrigated
agriculture problems, some citizens may find it difficult to translate
preservation of agricultural land into preservation of open space and
local character. The official was hopeful, however, that public
education programs sponsored through RLUP would help eliminate this
problem.
The public has participated in the Ventura WQM process through two channels:
the Citizen.Adivosry Committee (CAC) and a series of public forums.
Membership on the CAC consists of a broad spectrum of special interest
groups (e.g., industrial representatives, environmentalists, the League
of Women Voters, etc.) who are extremely well informed and very active
in the WOM program. The CAC (and the self-created CAC task forces in
particular) reviews all activities and outputs of the project: and submits
comments and suggestions to the staff, A member of the committee noted
that the CAC is pleased with the responsiveness of the WQM staff. The
WQM'Project Director commented that although CAC involvement sometimes
slows down the planning process, citizens' input is nonetheless respected
and heeded for its value in the long run. Only one interviewee noted
some disappointment with the CAC since she had hoped the WQM program
would cultivate active participation of groups outside of those already
VC-4'
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concerned about water quality before the WQM project began. Despite
this fact, she too was pleased with the broad opportunity for citizen
participation in the program. A county official suggested that the
momentum of the four individual programs cooperating in the KLUP program
has helped generate active involvement of citizen groups in the WQM
project.
The second mechanism for public input is a series of forums sponsored
jointly by KLUP and private groups including the League of Women Voters.
Although the forums are not specifically designed to address WQM issues,
water quality and planning in general are among the topics discussed.
The forums are viewed by the WQM Project Director as channels for
public education and information dissemination. A forthcoming forum
focusing specifically on irrigated agriculture is anticipated to
cultivate public receptivity to WQM plan recommendations. Attendance
at these forums has. not been overwhelming to date but interest and
¦attendance is expected to rise as the series continues and as more
critical issues are raised.
The WQM project was designed to keep local elected officials informed of
WQM developments through municipal staff representation on the Technical
Advisory Committee (TAC). The WQM Project Director has been somewhat
disappointed that this system of information flow has not worked as
smoothly as hoped. Only in the few cases where local officials them-
selves attend -TAC meetings do officials actually remain aware of program
developments. Most local officials are too busy with other interests
to keep apprised of TAC meetings. These officials appear to be waiting
for actual decisions to arise before they give the WQM project their
attention. To correct for this situation, the WQM staff" has begun
making direct contact with City Councils and is now requiring local
approval on plan outputs as discussed earlier. Input of local communities
comes through local officials' membership on the WQM Steering Committee
and through local contracts for population and land use plan elements.
Most interviewees anticipate increased interest and involvement of local
officials as plan alternatives begin to emerge.
The State Water Quality Control Board entered a contractual agreement
with the WQM agency to offer technical assistance to the WQM staff but
according to the WQM Project Director, the State has mainly assumed a
"watchdog role" in tracking and reviewing WQM project progress. The
State liaison, on the other hand, feels he has contributed to the Ventura
program by facilitating coordination with the Los Angeles WQM program
on bordering areas and common concerns. The State liaison is an official
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member of the Ventura WQM Committee structure and regularly attends all
WQM meetings. The liaison explained that the State is assuming a
low profile because it does not want to dictate to the local planning
program. .On the other hand, it is ready to offer assistance upon request
and is in general support and agreement with the Ventura program. The
EPA Project Officer feels that although the State has been very
cooperative to date, it could be of greater assistance by acting on its
own initiative.
The EPA Regional Office has also assumed a somewhat passive administrative
role in tracking and monitoring program progress. The EPA Project Officer
is very enthusiastic about the potential success of the program.
Facilities^Related Plan Elements
The parent WQM agency, VCRSD, has been directly engaged in facilities
planning and management for some time. VCESD expects to utilize data
generated through the WQM project in facilities planning activities
where it has primary responsibility (i.e., unincorporated areas). The
WQM, Project Director also expects that the WQM plan will help bring about
coordination between plans in neighboring basins - something that has not
happened in the past. Although most facilities planning will be completed'
before the WQM plan is finished, the Project Director noted'that the
advisory committees are considering a suggestion for coordination between
those plans and the WQM plan even before the latter is finalized.
As to the future, the State liaison expects that all facilities plans
will have to be consistent with WQM population and land use'projections.
The Governor's office is apparently supporting WQM data since they
express local growth and economic preferences. A county official noted
that the effect of the WQM plan on future facilities planning will not
occur in isolation but through the combined effect of the RLUP program
on future land use patterns, A citizen interviewee expected that the
WQM plan's areawide perspective would contribute to a more efficient
distribution of wastewater treatment capacity.
The'WQI^ Project Director does not expect that the WQM plan will suggest
significant changes in wastewater treatment management arrangements.
The area already has a regional management authority Cthe VCESD) in
operation. Expanding the VCPSD's active jurisdiction depends on
voluntary decisions of local communities, but neither the WQM Project
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Director, the EPA Project Officer nor the State liaison anticipate that
the WQM plan will promote further expansion at this time since c'ounty-
wide support is not strong at this time.
The only area in which new management arrangements may be necessary is
in the sale of recycled water for irrigation purposes. This issue will
only arise, however, if and when such a recycling program is instituted.
Citizens will be involved in facilities-related discussions through the
CAC. Although there has not been much discussion in the area to date,
the EPA Project Officer and State liaison expect more citizen input
when the WQM land use plan elements and their implications are
more clearly focused upon and/or when specific facilities suggestions
arise. The same remarks are true for local elected officials, particularly
those whose cities and towns will be directly affected.
Role of WQM Planning in the NPDES Permit Process
The State is responsible for NPDES permitting in California. The WQM
project has an agreement with the State Water Quality Control Board
whereby technical data prepared for the WQM plan will also be used in the
permitting process. The net effect is that all permits will have to
be in coordination with the WQM plan. The State liaison expects that the
WQM plan may lead to the expansion of the permit process by suggesting
permitting of nonpoint sources. In the area of agriculture, for example,
tilled irrigation fields would require permits in the future. In order
to deal with the saltwater intrusion problem, the WQM plan may suggest
combining runoff drains and rechanneling this water to compensate for
overdraft. In this case, runoff drains may need NPDES permits.
Although NPDES permitting has not been discussed directly at CAC meetings
to date, the permitting issue is scheduled for thorough.committee
discussions later in the project. One local elected official was
looking forward to these discussions as an opportunity for local communities
to define their priorities and desired tradeoffs. Since the-next
round of permits is scheduled for 1983, the WQM Project Director noted
that there will be plenty of time and data to use in permitting.
.Conclusions
According to the EPA Project Officer and the California State liaison,
the Ventura WQM project is the best in the State. A combination of factors
including well defined problems, a compact study area, a one-county
political jurisdiction, rising no-growth sentiments and the current drought
have given the WQM study focus and impetus.
VC-7
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The problems of irrigated agriculture were generally known before the
WQM project began, but it took the WQM project in conjunction with the
KLUP program to provide a cooperative mechanism for regional problem
solving. The WQM project has made considerable progress over the
past year. Through active committees, contracts with local governments
(i.e., for population'and land use projections), and direct contact with
City Councils, the WQM project has provided a successful framework
for education, communication and input of potential plan implementors.
Association with KLUP has given the WQM project publicity and promises to
strengthen WQM recommendations through coordination with other ongoing
planning programs (i.e., air, transportation and annexation). Through
RLUP, intermedia coordination and regional cooperation appears to be
working.
Because the designated area has witnessed problems that result from rampart
growth, most local communities are receptive to growth- controls and land
use regulations. Even agricultural interests appear to realize that
immediate action is needed to stave off regional demise of agriculture.
The only thing locals will not tolerate is interference in local autonomy.
Recognizing this, the WQM project has assumed a profile of assisting
local communities develop their own regional solutions rather than
imposing WQM staff suggestions on them. WQM staff receptivity to local
preferences has been returned with the respect and active partcipation;of
citizens, special interest groups and a number of local and county officials.
The WQM staff has identified decision-makers who will be responsible for
approving and implementing the plan and has actively sought out their direct
involvement.
Given present regional interest and State support for the plan, imple-
mentation appears likely even if it should take more than two years
to materialize. If the project continues on its present path, the WQM
planning process will probably be evidenced in the future since the
procedures are well developed and firmly established and since the
State will probably require local compliance with the'final plan as a
contingency for funding related activities.
In the area of facilities planning, "WQM interim outputs are expected to
influence all future facilities decisions. This is partly explained by
the fact that unlike most incorporated areas which already have sufficient
treatment capacities, unincorporated areas still have unanswered waste-
water treatment needs. Planning for the latter areas is -he responsibility
of the VCRSD, the WQM parent agency. It is unlikely that the VCRSD will
VC-8
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disregard WQM data especially since that data reflects regional concerns
and perspectives which will help VCRSD avoid inappropriate distributions
of treatment capacities that occurred in the past. The State recognizes
this and is supportive of the WQM plan's regional perspective. It is
too early to predict change in current management arrangements although
given the legislative authority and public acceptability of the current
system, it is unlikely that radical changes will occur.
NPDES permitting is not a major issue in the Ventura area at this time since
only a fair number of permits are currently issued and since local com-
munities appear satisfied with the State's permitting decisions. However,
permitting may become a more important issue later in the WQM planning
period if the final WQM plan recommends that some nonpoint source pollution
controls necessitate permit control.
VC-9
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19 yellowstone tongue
Yellowstone-Tongu§ Areawide Planning Organization (YTAPO)
The Yellowstone-Tongue Areawide Planning Organization (YTAPO)
is a single purpose planning body specially created for
WQM planning in southeastern Montana. YTAPO began its
WQM project in November of 1975 and is scheduled to complete
its final plan in January of 1978. The total grant amount
is $540,000. The southeastern Montana is the most
sparsely settled- WQM area in the country. It encompasses 18,300
square miles andf has approximately 23,000 people according to
the 1970 Census. This semi-rural area was chosen for
study because it is susceptible to rapid growth induced by
energy extraction and conversion projects. Because the
area now enjoys relatively good water quality, an attempt is
being made to ensure preservation.
Water Quality Preservation
The focus of the Yellowstone-Tongue Areawide Planning Organization (YTAPO)
WQM effort is preservation of existing water quality. In view of the
fact that local waters are already subject to relatively high concentra-
tions of salinity from natural sources of pollution, YTAPO is concerned
that other potential polluters that can be controlled (e.g., agriculture
and secondary impacts of energy development) not be allowed to aggrevate
the problem. Preservation is especially important in southeastern
Montana because of anticipated energy development and extensive
agricultural operations in the area.
In order to develop recommendations for the preservation of .existing
water quality, basic water data had to be compiled. The level of detail
achievable within the two year planning period is necessarily limited,
but the YTAPO Director, EPA Project Officer and State water quality
officials are confident that the WQM data will provide a satisfactory
basis from which to draw indications of potential problem areas.
YT-1
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In addition to inventorying existing water quality, YTAPO is involved in
studies related to energy-development activities. More specifically,
YTAPO is providing data for an Environmental Impact Study on two
proposed nuclear power projects at Colstrip and the North Powder River.
Such demands for YTAPO participation have emerged and probably will
continue to emerge as plans for energy development unfold. EPA
Region VIII recognizes outside factors (e.g., Federal energy policy)
influencing the scope of YTAPO's WQM efforts and has already granted a
two-month extension to allow YTAPO participation in environmental impact
assessments related to energy development.
YTAPO completed its interim outputs as scheduled. These were well
received by the EPA Regional Office. Similarly, the Montana Water
Quality Bureau (the official State liaison office) reviewed the
interim,.outputs favorably and is already using the data where relevant
in their own planning activities.
In a semi-annual report completed in the Fall of 1976, YTAPO outlined
tentative recommendations based on preliminary data to implement and
augment preservation efforts. The majority of these recommendations
are. listed in the "Areawide Water Quality Management Program Survey".!
They include such items as a proposal to restrict saline discharges of
agricultural water users and to reclassify water uses of streams taking
saline discharge restrictions into account. The State water quality
official noted that the State previously had not been aware of the
salinity issue and would consider this and other tentative recommendations
as potential areas for State action. A citizen interviewee and two
local elected officials noted that the tenative recommendations have
provided starting points for discussion by the YTAPO Board of Directors.
Generally they believed the recommendations are reasonable, offering a
number of alternatives.
At this juncture, all interviewees expected the WQM project to contribute
to better management and planning decisions. This will be particularly
true as development pressures related to mining activities are realized
even though the EPA Region VIII Project Officer noted that the level of
Federal or local control overrsecondary impacts of energy development
has not been clearly defined yet. Optimistic expectation for local
plan support is based on the WQM Project Director's direct contact with
local elected officials and his responsiveness to their interests and
priorities. Both of these activities have stimulated local trust in
WQM recommendations. However, none of the interviewees expect unanimous
local support for the plan, especially since locals are very skeptical
Centaur Management Consultants, Inc., "Areawide Water Quality Manage-
ment Program Survey", October, .1976, p. YT-10.
YT-2
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of land use controls. Furthermore, if energy development does not
materialize as anticipated, the WQM Project Director believes that
interest in the WQM project will wane quickly. Data collected
through the WQM program will then be left for use by other ongoing
State planning agencies.
A voluntary approach to preserving or improving'water quality with
respect to agricultural practices is preferred by the YTAPO Director
and two local elected officials. The YTAPO Director intends to stimulate
better management techniques through a public education program
emphasizing the economic advantages of appropriate irrigation practices,.
The advent of a new regulatory institutional arrangement, however, is
possible. For example, the WQM project is currently considering
investing the conservation districts with authority to regulate the
salinity of irrigation return flows. However, the YTAPO Director
and local interviewees believe that minimizing regulatory alternatives
is essential, given the area's general animosity toward imposed controls.
Although a State water quality staff member and EPA Project official
considered a voluntary approach most appropriate to the area, they
also recognized that supplemental regulatory action may be necessary.
The YTAPO Director outlined the current status of efforts to implement
the WQM plan. The U.S. Agricultural Extension Service "and a nonpoint
source consultant are developing case studies on soil types, salinity
of the soil, irrigation techniques, salinity of irrigation water and
the resulting impacts on crop yield. Workshops to present the findings
to agricultural interests are planned. YTAPO is also conferring with
the conservation districts regarding their involvement in promoting
better management practices. A State water quality official noted that
YTAPO's interim recommendations would be considered in the revision
of water quality standards which will occur prior to September, 1977.
Participants in the YTAPO WQM project have been limited largely to the
YTAPO Board of Directors who meet regularly and to local agency
technical staffs who are contacted informally by the WQM staff. A
formal Citizens Advisory Group has not been organized due to sparse
settlement patterns and the great distances involved in commuting to
areawide meetings. YTAPO generally prefers to reach the public by
vising local organizational meetings and holding WQM-related workshops
throughout the area.
YT-3
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Local elected officials have been reasonably active in the YTAPO
project despite commuting problems. This interest can be explained
in part by the imminent threat energy development poses to most
farmers and ranchers and to the fact that the WQM project provides
a focus for their concerns. The YTAPO Director also maintains
informal contact with both elected and appointed officials. The
draft nonpoint-source report will be presented in March along with
proposed alternatives for implementation. From that point on, the
YTAPO Director expects local elected officials to become more actively
interested in the discussion of appropriate implementation measures.
Throughout the planning period, the State has made available a full-
time engineer for on-site services to YTAPO. The State coordinates
directly with YTAPO and also promotes intrastate coordination among
Montana's four WQM projects. Representatives of the four WQM projects
meet monthly and jointly have retained an attorney to develop and
promote legislative proposals. The State expects ongoing coordination
"with YTAPO and other WQM agencies to result in compatible implementa-
tion programs. The State is already revising its water quality
standards on the basis of.YTAPO's WQM data and recommendations.
The YTAPO Director*reported that EPA energy-related staff have become
more active in assisting YTAPO recently. He stressed the importance
of their involvement in considering the conflicting objectives of
energy development and nondegradation of the area's water quality.
Resolution of the conflict could involve a number of options which
would require Federal support and WQM programmatic fle'xibility.
For example, the Tongue River is being polluted currently by: natural
causes. Rather than attempt to clean up the Tongue River (which
for all intents and purposes will continue to suffer from natural
causes), the WQM plan might suggest that energy developers concentrate
their wastes in this river rather than spread pollution to other
rivers. The WQM plan would include measures to compensate farmers
who might otherwise rely on the Tongue River for irrigation water.
Facilities-Related Plan Elements
•YTAPO's WQM efforts have had significant influence on current facilities
planning. Under WQM-funded subcontracts, facility plans (equivalent
to Step I of the construction grant program) are underway iri five small
communities. One of these communities has already moved to Step II
of the construction grants program. The State has supported this
YT-4
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action by promising higher priority ratings to projects conducted
through the WQM program.
Local officials consider YTAPO's population projections to be
.the best approximations for the area. The uncertain timing and
magnitude of energy-related development, however, make .the validity
of any projections somewhat tenuous.
In the YTAPO area, no regional: management of facilities is believed
feasible due to low density settlement patterns. Management
authority will most likely remain with individual cities.
In communities with ongoing WQM-funded facility planning projects,
citizens, local elected and appointed officials have been fairly
active in the WQM planning process.
The State and EPA regional offices are involved in the WQM project
through routine procedures for review of WQM outputs. The YTAPO
Director noted that incorporating future facilities needs (as
identified by the WQM project) into the State priority system may
present a complex problem. State priorities are based on development
trends derived from 1972 population figures. Such projections do not
accommodate the projected energy-related influx of population.
Therefore, construction grant funds will cover projected 1972 needs but
not actual needs; a supplementary funding source (e.g., coal tax
funds)' must be found..
Role of WQM Planning in the NPDES Permit Process
YTAPO interest in the NPDES permitting process has, for two reasons,
been very limited. First, there are currently only three industrial
and one municipal permits in the area; and secondly, private energy
development operations have adopted "zero discharge" philosophies
for primary waste elimination. YTAPO did review the existing permits
and made relatively minor recommendations which the State is con-
sidering. YTAPO also requested and received EPA permission to conduct
instream monitoring of dissolved oxygen in the area of Colstrip, the
major site of current energy development"activities. Because there are
so few dischargers in the-area, the YTAPO Director stated that no
citizens or officials have shown considerable concern with NPDES
permits.
YT-5
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Conclusions
The YTAPO staff seems to have a clear sense of the technical and
political limitations shaping their expected achievements within the
planning period. As water quality preservation efforts must emmanate
from a baseline of documented data, YTAPO is focusing its efforts
appropriately on assembling a water data base. Concurrently, YTAPO
is working with local elected and appointed officials to acquaint them
with the emerging issues attendant to the area's energy development
activities. At this early stage of its planning process, YTAPO has
developed tentative recommendations which will focus the discussion of
alternatives among local officials.
Among YTAPO recommendations are practical and innovative considerations
in the face of conflicting pressures for energy development and
environmental preservation. For example, in proposing the "sacrifice"
to development of one river of marginal quality, YTAPO has recognized
the local preference for (if not necessity of) balancing economic
and environmental considerations—particularly in the face of a
national energy crisis.
The strength of the YTAPO effort is the effectiveness of YTAPO staff
in building support for the project among local officials. While
commuting distances inhibit regular meeting attendance, YTAPO staff
ensure ongoing communication and coordination among local officials
through informal personal contacts. YTAPO's responsiveness with
technical assistance to immediate local needs has enhanced the Agency's
credibility and visibility as a valuable resource for local govern-
mental units. In an area which is traditionally opposed to intervention
into local autonomy, YTAPO has promoted itself as an aide to local
efforts rather than as an outside force seeking to pre-empt local
control. Local decision-makers believe that their prerogatives will
prevail but accept the informational input of YTAPO to their efforts.
In a similar fashion, YTAPO will be providing assistance to agricultural
interests by demonstrating the benefits of irrigation practices which
limit the adverse effects of salinity on agricultural lands and crop
yield. As the U.S. Agricultural Extension Service has an existing
working relationship to agricultural interests, YTAPO is coordinating
with them to develop appropriate educational workshops.
YT-6
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Although the timing of the WQM study is appropriate to planning
in advance of energy development impacts, the lack of immediately
felt development pressures may allow local support and interest
in continuing technical analyses (e.g., updating water data) and
coordinating with energy development-related projects to wane.
With the heavy involvement of many Federal agencies in the area
and the resulting panoply of studies, it is difficult for the
contribution of the YTAPO effort to stand out as exceptionally
useful to local governments. Should YTAPO or an alternative
technical support pool not continue due to insufficient local or
Federal funding support, it is questionablecwhether.rthe local
governments with their limited staff and other resources have the
capability to adequately confront the energy-development issues
when they emerge.
YTAPO is already affecting planning for needed facilities in the
area which will have a direct impact on eliminating: municipal
discharges as pollutant sources. Because of the very few'dis-
chargers in the area, NPDES permits are a relatively minor concern
to YTAPO.
YT-7
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APPENDIX
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INTERVIEWEES
WQM Study Area
WQM Project
Directors
EPA Regional
Project Officers
State Liaisons
Local Officials
Citizens
1. Chattanooga
2. Philadelphia
3. St. Louis
4. Houston-
Galveston
5. Lower Rio
Grande
6., Martha1 s
Vineyard
7. Daytoij
8. Kansas city
Gordon Mellancamp Steve Sandler
Tom Walton
Larry Zensinger
Nick Aschlimann
Charles Savino
John Janak-
Bill Wilcox
Bert Middlebrook
Tom Neal
9- Middlesex County, William Krause
New Jersey
10. Salem
Curt Smelzer
Glen Witmer
Lee Duvall
Sam Nott
Martha Seymour
Charles Conway
Elaine Greening
Larry Sheridan
John Wodkowski
Cecil Qullette
Kirk Mayes
Steve Anderson
Sedwick Karper
Earl Holtgraeve
Dr. Peggy Glass
Dr. Peggy Glass
Susan Wilkes
A1 Buoni
Roy Parrish
Ellis Spenser
Robert Struble
Tom Fulweiler
Kaiser
Judge Steinberg
Judge Oscar Nelson
Dee Brune
Bill Meyers
Juanita Brodecky
Ronnie Schultz
Ron Schmidt
Gene Cronk*
Robert Hart
James Farley
Ben Williamson
(Kansas)
Ed Knight
John Schondelmeyer
Joseph Fitzpatrick
(Missouri)
William Minervini Richard Naberezny
John Runyon
P,uss JFetrow
Herb Arnold
Ted Lopuscynski
Ellen Lowe
Alan Miller
James Barnett
Richard Cormack
Barbara Paul
William Martin
Steven Banton
Suzanne Pogell
Ken Kramer
W.W. Wright
William Parish
Ersel Lantz
Robert Woodruff
Marguerite Bergstron
Madline Lokman
Chris Carolson
Richard Baldouf
Roberta Chittendon
E.I. Rumrill
Joan Ryan
Caroline Neuwijrth
County engineer interviewed as substitute for local Mayor who was unavailable for interview.
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WQM Study Area
11. Seattle
12. Cincinnati
13. Southeastern
Wisconsin
14. Augusta
15. Ft. Meyers
16. Sussex County,
Delaware
17. Teton County
18. Ventura
19. Yellowstone-
Tongue
WQM Project
Directors
Rod Stroupe
Dory Montezumi
Bill McElwee
Larry Wyble
John Forster
Larry Pearson
William Pleasants
Eugene Zeizel
Joe Borgerding
Mike Williams
(Assistant)
Clark Judy
EPA Regional
Project Officers
Al' Ev4ng
Elaine Greening
Bruce Baker
Ed Woo
Steve Sandler
Larry Maxwell
Bruce Zanders
Mary Ann Grasser
Roger Dean
State Liaisons
Local Officials
Citizens
Chuck Clairk
Debbie
Gross-Sidlow
Randy Wade
Bill Stoddard
Bill Busig
Rudolph Jass
Larry Robinson
Jim Haupt
Steve Pilcher
Dcwe Mooney
Brad Gillespie
Donovan Treacey
Kim Saunders
Bob Turner
R.J. Borchart
Norbert Dettmann
Paul Vrakas
Robert Stubbs
Scott Higgings
Beverly Clay
Richard Hallam
Robert H. Shedd
A1 Stango
Byard Coulter
Paul Bruin
Muffy Moore
Ted Grandsen
L.H. Maland
Floyd Iron
Art Kamhoot
Scoot Smith
Bob Copernoll
Jack Kleymeyeo
Joan Hammond
Helen Jacobs
William Murphy
Janet Rizi
Joe Roach
John Farrow
Joseph Skelly
Skip Wright-Clark
Janet Beymer
Walter Archer
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