LOCAL GOVERNMENT ADVISORY COMMI
Small Communities Report
Small Communities:
The Front Line of
Environmental Protection
PREPARED BY
U.S. Environmental Protection Agency's
Local Government Advisory Committee
Small Community Advisory Subcommittee
United States
Environmental Protection
lAgency
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Letter from the Chairman
The Local Government Advisory Committee appreciates the opportunity to provide
advice to the EPA on issues that are important to local governments and, in particular,
to small communities. Environmental protection doesn't happen just because a law
is passed or amended by legislative bodies. It is also the result of agency rulemaking,
guidance, technical assistance, and financing. Locally, implementation actions resolve
pollution problems. The intergovernmental system in which this occurs should de-
pend upon a firm understanding of those on the front
line - over 74,000 counties, cities, and towns, and
special districts - which are called upon to implement
public policy. When it comes to environmental and
public health protection, they are the ones who "make
it happen." It is essential then that the Environmental
Protection Agency continues to call upon the mem-
bers of the Local Government Advisory Committee
and the Small Communities Advisory Subcommittee
to provide counsel and advice on the shared responsi-
bility of environmental and public health protection.
The LGAC believes that it is critical that a Small Communities Office within the
Agency be established to coordinate regulatory, policy, and financing needs of
small communities.
Chairman Roy Prescott
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LOCAL GOVERNMENT ADVISORY COMMITTEE
Small Communities Report
Small Communities:
The Front Line of
Environmental Protection
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Background
Local Government Advisory Committee (LGAC)
The Local Government Advisory Committee was char-
tered in 1993 under the Federal Advisory Committee
Act. It is composed primarily of elected and appointed
local officials, along with several State representatives,
environmental interest groups, and labor interests.
Committee members come from various EPA Regions
around the country.
The LGAC advises EPA on how to develop a stronger
partnership with local governments delivering envi-
ronmental services and programs. The ultimate goal of
the LGAC is to provide the citizens of the Nation with
more efficient and effective environmental protection at
the community, State and Federal levels.
Small Community Advisory
Subcommittee
The Small Community Advisory Subcommittee (SCAS)
was established by EPA in 1996 to advise the Administra-
tor on environmental issues of concern to the residents
of smaller communities. As a standing subcommittee
of the Local Government Advisory Committee, it was
established in response to recommendations of the Small
Town Environmental Planning Task Force, an earlier
advisory panel created by the Small Town Environmental
Planning Act of 1992 which concluded its work in 1996.
EPA Deputy Administrator Marcus Peacock listens during a
roundtable discussion with members of the LGAC at EPA head-
quarters, Washington DC. (Feb 7, 2008)
The Front Line
Men and women who are elected, appointed, and hired
at the local government level to make decisions and
implement actions are among the unsung heroes of the
environmental movement. Here are some examples:
Ken Fallows -former mayor of Haskins Village in Ohio-
said that his town is the exception and not the rule. He
stated that "most elected officials do not have a clue how
to access resources in dealing with environmental issues
affecting small communities."
Are all these communities the same because they are in-
corporated cities or towns? In Oregon the incorporation
paperwork might be similar for the cities of Portland and
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Ken Fallows- former mayor of
Haskins Village in Ohio says:
"...most elected officials do not
have a clue how to access
resources in dealing with
environmental issues
affecting small communities."
*
OF
HASKINS
I fWN HAI
and n/\ ,
Lonerock. But at a population of 20, Lonerock is a much different
place. Yet both communities share similar responsibilities for compli-
ance with federal and state environmental laws. If local governments
defy comparison within states, imagine how unique local govern-
ments can be, stretched across the vast American landscape from Key
West, Florida to Ketchikan, Alaska and points beyond.
It is essential then that the Environmental Protection Agency con-
tinue to call upon the members of the Local Government Advisory
Committee and the Small Communities Advisory Subcommittee to
provide counsel and advice on the shared responsibility of environ-
mental and public health protection.
It is fair to say that the constant turnover of local officials (and sheer
volume of local government partners) creates a situation where the
local recognition of responsibility in the intergovernmental partner-
ship, the discovery of services and tools, the distribution of informa-
tion and training and the building of relationships with state and
federal regulatory partners is a process that never really ends.
A Small Community Office will ensure that the unique needs of
small communities are not overlooked.
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Challenges Faced by Small Communities
For the Environmental Protection Agency, a small community is de-
fined as a jurisdiction of as few as 2,500 persons. Small communities
have a variety of governmental and quasi-governmental organizational
structures including incorporated and unincorporated communities,
water and or sewer districts, rural areas, homeowners associations,
mobile home parks and colonias. From the perspective of the majority
of local governments, EPAs "small community" definition describes
their larger neighbors. The responsibility for protecting the health of
the public and the environment is not scalable. Small, medium, large,
and larger governments all have virtually the same implementation
requirements.
LGAC member Charles Hafter said "As a city manager of twenty-
nine years experience, I have managed in small communities and
larger cities. Small communities have a much more difficult time
they have the same infrastructure problems as larger cities, except on
a lesser scale , but none of the resources or professional management
needed to efficiently solve these issues."
But, despite the similarity of responsibility, different-sized communi-
ties are different when considering their ability to implement envi-
ronmental protection. Research indicates that there are at least two
major factors that directly impact the ability to implement the regula-
tory requirements of environmental protection; the most important
being fiscal capacity and administrative capacity. The lack of capacity
not only limits their ability to provide adequate infrastructure and
support systems, it can limit their capacity to plan and develop their
communities appropriately. The effect is pernicious, as irresponsible
planning and growth leads to more environmental problems and a
greater need for capacity and costly infrastructure to address those
problems.
LGAC and SCAS member Jerry Johnston said "most small communi-
ties do not understand or know what resources are available to them."
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT 7
LGAC member Charles Hafter says:
"As a city manager of
twenty-nine years experience,
I have managed in small com-
munities and larger cities. Small
communities have a much more
difficult timethey have the
same infrastructure problems as
larger cities, except on a. lesser
scale , but none of the resources
or professional management
needed to efficiently solve
these issues."
southburlington
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LGAC and SCAS member
Jerry Johnston says:
"most small communities do not
understand or know what
resources are available to them."
Small Communities Lack Fiscal Capacity
The smaller the community, the more difficult it is for the citizens to
raise the revenues needed to meet their infrastructure needs. To make
matters more difficult, full-cost pricing of services requires not only
that the operating and capital costs of the system be met, but also that
future replacement of the system be funded as well. A small commu-
nity without sufficient customers to share the cost, and/or com-
munities with lower income customers, often will not have the fiscal
capacity to establish and maintain environmental systems. When one
considers the number of separate environmental systems that maybe
required, the cumulative costs of service may not be affordable. As
requirements expand within each regulatory category (e.g., drinking
water, wastewater treatment, and storm water) any available fiscal
capacity is quickly exhausted.
The perception that significant funding can be provided to local
governments from the federal domestic budget must also be tempered
by the fact that there are numerous priorities seeking funding from
that source. Creative financing and the leveraging of multiple sources
of funding to meet environmental demands are techniques that even
small communities must master in the coming years.
8 LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Small Communities Lack Administrative
Capacity
Another critical capacity that is directly related to the size of a com-
munity is administrative capacity. Some small communities - such as
resort cities - have small permanent populations but significant fiscal
capacity from tourist dollars and high income residents. These com-
munities have the resources to hire professional staff with the high di-
vision of labor needed to adequately administer the particular service
systems to maintain a high quality of life. These communities have
well compensated planning, financial, and public works professionals
that can support their elected officials in making good decisions for
financially and environmentally sustainable communities. Western ski
resort towns such as Sun Valley, Idaho and Park City, Utah, are good
examples to examine when investigating the relationship between size
of community, fiscal capacity and administrative capacity.
LGAC Member Joe Palacioz said: "Small communities will under-
stand and solve environmental issues when there is communications
going both ways between and among local, state and federal govern-
mental officials. It is important to involve such officials to arrive at a
better decision. Such dialogue will make the decision-making process
more difficult, but you will have a better decision".
LGAC Member Joe Palacioz says:
"Small communities will under-
stand and solve environmental
issues when there is communica-
tions going both ways between
and among local, state and
federal governmental officials.
It is important to involve such
officials to arrive at a better
decision. Such dialogue will
make the decision-making pro-
cess more difficult, but you will
have a better decision".
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Growth at the Center of the Issue
Many small communities look to growth and develop-
ment to provide answers to many of their problems, while
others see it as the source of their problems. Growth and
development provide opportunities for additional jobs,
increased local revenue, commercial and retail establish-
ments, and other opportunities like increasing fiscal and
administrative capacity among local leadership and staff.
However, challenges also accrue: the need for additional
infrastructure like roads, sewers, schools and additional
services can have significant impact on the environment.
For example, more parking lots and buildings often mean
additional runoff into nearby streams, triggering new
regulatory requirements and costly measures to address
the pollution. However, if new growth and development
is done well, environmental challenges can be mitigated
and costs can be reduced.
When smart growth strategies are combined with green
building policies, the beneficial environmental outcomes
are aggregated, providing communities with the oppor-
tunity to address critical environmental challenges, often
outside the regulatory framework. New development
within the existing fabric of small communities means
these communities are taking advantage of the infrastruc-
ture that already exists. This adds to the local tax base
with less impact on existing capacity. Incorporating green
building and green infrastructure (such as trees, rain
gardens and other natural elements) in the built environ-
ment will lead to less energy and water use and provide
healthier living environments, leading to significantly
lower overall infrastructure costs.
All of the above solutions need to be tailored to small
communities' unique characteristics. While such com-
munities may point to a less sophisticated workforce, the
lack of green materials and of trained urban planners as
barriers to green building and smart growth, they have
other valuable assets to put to use. For example, small
communities are often in a position to offer a remark-
able level of community collaboration central to effective
community planning. Using locally-sourced products
made by residents offers unique opportunities for innova-
tion while boosting the local job market. Also, taking
advantage of low-cost open space in many of these com-
munities to create natural solutions to problems, such as
creating wetlands to treat waste water relieves some of
the burden to create costly traditional gray infrastructure
and avoid adopting technological solutions that may be
beyond a community's expertise.
10 LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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While it may be attractive for the Agency to seek new approaches to
the intergovernmental challenges, it's good to look at what has already
been developed to determine what works best. For the newly elected
official in Soda Springs, Colorado - everything the Agency and its
partners do is brand new to her. The Local Government Advisory
Committee can assist the Agency in understanding which among the
existing programs and techniques are the most effective from the local
government perspective. The LGAC can also help by discussing how
current technologies can be used to improve communication and the
delivery of technical assistance.
Steve Jenkins, SCAS chair said "I believe in the resiliency of small
communities and their ability to sustain a quality of life for genera-
tions to come."
Stevejenkins, SCAS chair says:
"I believe in the resiliency of
small communities and their
ability to sustain a. quality of life
for generations to come."
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT 11
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Place-Based Program in Region 10
Sue Skinner, the EPA "place based"
person in Pocatello, Idaho says:
"If you listen closely and get
to know the person and their
values and they get to know
yours the "lets do this" moment
often follows."
Lyons Gray, EPA Chief Financial
Officer says:
"Without this tour I don't think
I would have understood the
real needs. We hear about it
but it's nothing like seeing it first
hand and it gives me a better
appreciation of where to
place the money that
Congress gives us."
Sue Skinner, the EPA "place based" person in Pocatello, Idaho said
"If you listen closely and get to know the person and their values and
they get to know yours the "lets do this" moment often follows."
A "place based" approach has led the Portneuf River Watershed to
establish the Portneuf Watershed Partnership. A success of the part-
nership is the installation of a state-of the-art water quality monitor-
ing network that also posts its monitoring results on the internet.
This partnership helps to improve the understanding of the cultural
importance to the Shoshone-Bannock Tribes. With this as the back-
ground, the City of Pocatello now has a Phase II Municipal Separate
Storm Sewer System, an (MS40) permit with goals they can accom-
plish, a newly constructed wetland to treat storm water and additional
plans in the works to protect water quality. Pocatello's ultimate goal is
to bring the Portneuf River back as their community centerpiece.
Idaho Tour Community Profiles
The issues of fiscal and administrative capacity were clearly on display
when the Local Government Advisory Committee visited the Idaho
cities of Dietrich and Castleford in the fall of 2007. These communi-
ties were part of a tour organized by the Boise State University Envi-
ronmental Finance Center when the Environmental Council of the
States and the LGAC convened in Sun Valley, Idaho. The Committee
was joined by state officials, local planners, EPA regional staff, Idaho
legislators, and citizens for the tour. In addition to visiting Dietrich
and Castleford, the tour included stops at a mega-dairy operation, a
cattle ranch and two non-profit community water systems.
Lyons Gray, EPA Chief Financial Officer, says: "Without this tour I
don't think I would have understood the real needs. We hear about it
but it's nothing like seeing it first hand and it gives me a better appre-
ciation of where to place the money that Congress gives us."
12 LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Dietrich, Idaho
The City of Dietrich, Idaho, (population 215 people) incorporated in
1909, is located on the south slope of a sagebrush - covered, extinct
volcano called Crater Butte in rural Lincoln County. It is about 25
miles northeast of the City of Twin Falls. The leading employer is the
school district, with the majority of residents commuting to other
towns for work.
The city was notified in the early 1990s that the septic system drain
field used by their high school was a health hazard and that the high
school would be closed unless a wastewater solution could be ap-
proved by the local health district. "With considerable effort on the
part of Mayor Jeannetta Knowles, the city engaged local funding
agencies and the Department of Environmental Quality in a S elf-
Help project to build a new sewer system. This challenge followed
closely on the heels of the requirement to build a new community
water system in 1992. The water system improvements virtually
exhausted the fiscal capacity of the city. These projects also exhausted
the elected officials, especially Mrs. Knowles. The mayor, who then
was in her 70s, retired in 2007 because her husband could no longer
drive her to meetings.
Due to fiscal constraints, the town functioned as its own contractor
to accomplish the wastewater project. The majority of equipment and
labor was provided on a volunteer basis, including demolition work
required before construction on the lagoon system could begin. The
complexity of managing this project was exacerbated by the need
to blast trenches in the lava rock formations to run the sewer lines
throughout the city, to negotiate an agreement with the Union Pacific
Railroad to run the sewer line underneath their tracks (the city still
cannot afford to employ a city attorney to write such contracts), and
the inability to compel new residents to hook up to the wastewater
facility.
Mayorjeanetta Knowles,
Dietrich, Idaho, says:
"If you have a good program,
stick to it, and don't let people
talk you out of it."
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s
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT 13
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While both projects in the short term were an over-
whelming challenge for the City of Dietrich, many con-
sider these efforts to be a minor miracle. That is because
the entire annual budget for the City of Dietrich is less
than $50,000.
The Leaking Tower of Castleford, Idaho
Rita Ruffing, Mayor of Castleford, Idaho town of 297
people will have to spend approximately $1.6 million
to bring their water tower into compliance. Water rates
in the town have gone from $12.00 to $41.00 and will
increase to $55.00 per month this year. According to
Mayor Ruffing, "a $55.00 water bill puts a lot of hurt on a
lot of people"
Castleford, Idaho
Within the last five years the City of Castleford, Idaho
faced challenges stemming from the change in the
maximum contaminant level for arsenic. Arsenic occurs
naturally throughout this area of Idaho, which is south of
the Snake River. As a result, the existing municipal well
had to be relocated which caused a fiscal chain reaction,
including the cost of relocating City Hall because it was
too close to the new wellhead. The costs involved in relo-
cating and restructuring major components of the water
system nearly crippled this small community. In Decem-
ber 2003, the city requested an exemption (or imple-
mentation delay) from the new arsenic rule. The US EPA
Region 10 Environmental Finance Center at Boise State
University provided a financial analysis to the EPA which
demonstrated the financial hardship the city faced. For
reasons involving the health hazard related to the level
of arsenic contamination, the exemption was not granted.
Mayor Rita Ruffing led the charge to first fight against
the new requirement and then to find the resources
necessary to rebuild the water system. The Mayor was
(and still is) immersed in the effort. As a result the water
rates were increased, and there is still no guarantee that
the new rates will be accepted by the citizens over the
long term. The work is still not done. The distribution
system is in dire need of repair and the water tower is
leaning and will eventually need to be replaced. This city
is strapped financially and had to borrow construction
horses (to cordon off the newly constructed well) from
the neighboring City of Buhl (over 10 miles away). The
City of Castleford does gain an economic advantage on
administrative capacity. Mayor Ruffing is also the city's
certified water system operator. However, she does not
qualify to operate the new system which requires a Class
3 operator. To receive her operator's license in this class
she will need to work under another Class 3 operator.
Unfortunately, there is not another Class 3 operator
within 200 miles of Castleford. Perhaps, facilitating a
system of shared operators on a regional basis would help
small towns in this predicament. Small towns could share
an operator unless treatment is necessary. This would pro-
vide access to a qualified operator and result in potential
cost savings to those towns.
14 LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Regarding fiscal capacity, in 2002 before this new project was built,
Castlefbrd's water fund revenues were $49,084. The expenses were
$61,963.
LGAC Chair Roy Prescott said: "Better communication with each
other is the best way to serve not only local governments but smaller
communities as well. Everyone wins. "
Here is how to get the job done.
The Federal and State governments recognize the challenges faced
by small communities and have created several organizations and
implemented several programs to deliver technical assistance and
education to appointed and elected officials and community leaders.
This helps them deliver the best level of service at the lowest cost. The
direct assistance provided to these communities is invaluable to main-
taining their quality of life and ensuring their continued existence as
environmental laws, rules and regulations continue to change. These
organizations bring administrative and financial expertise to these
communities in an effort to ensure compliance while enhancing the
working relationship with the agencies involved.
LGAC Chair Roy Prescott says:
"Better communication with
each other is the best way
to serve not only local govern-
ments but smaller communities
as well. Everyone wins."
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT 15
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Programs and Resources
EPA's Environmental Finance Program (EFP)
http://www.epa.gov/efinpage/
EPA's Environmental Finance Program (EFP),
evolved from the Public Private Partnership Pro-
gram in 1993, assists public and private sectors
in their search for creative approaches to funding
environmental programs, projects and activities. It
uses leveraging and partnerships to extend the reach
and impact of its activities.
The program has closely related components that
provide financial outreach services to Agency
customers and the regulated community. These
components include:
The Environmental Finance Center
(EFC) Network
http://www.epa.gov/efinpage/efcn.htm
Environmental goals cannot be met without financ-
ing, which is essential to implementing state and
local programs. Knowledge about how to fund these
programs is often limited, especially at the local
level. As a result, there is an unprecedented demand
on the expertise of public officials currently on the
front lines of financing environmental facilities and
services.
The Environmental Finance Center provides state
and local officials and small businesses with advisory
services, education, publications, training, technical
assistance and analyses on financing alternatives. The
Network currently includes centers at universities
all over the U.S. which promote innovative environ-
mental financing techniques. While EPA provides
seed funding for start-up operations, financial inde-
pendence of the centers is a major objective.
The University of North Carolina is designing
a finance training course for Network use and is
completing a report on wastewater and growth is-
sues in the southeast coastal region of the country.
The University of Louisville is providing support
services to many small and medium-sized water and
wastewater facility operators throughout Kentucky.
The University of Southern Maine is currently fo-
cusing on wastewater treatment challenges in coastal
areas of Massachusetts.
Local Government Environmental Assistance
Network (LGEAN)
http://www.lgean.org
The Local Government Environmental Assistance
Network (LGEAN) is a "one-stop shop" providing
environmental management, planning, funding, and
regulatory information for local government elected
and appointed officials, managers and staff. Located
at http://www.lgean.org, LGEAN enables local of-
ficials to interact with their peers and others online.
Peer Center - Public Entity Environmental Man-
agement System Resource Center (PEER)
http://www. peercenter. net/
Welcome to the PEER Center! PEER stands for
Public Entity EMS Resource Center and provides a
broad array of information and tools to help public
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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entities understand and adopt environmental man-
agement systems (EMSs) for their operations. The
PEER Center is a collaboration between the Office
of Water at EPA and the Global Environment &
Technology Foundation (GETF). A number of
organizations around the country called PEER EMS
Local Resource Centers are reaching out to local
governments to help them adopt EMSs.
Small Local Government Compliance
Assistance Policy
http://www.epa.gov/oecaerth/resources/
policies/incentives/smallcommunity/
smalllocalgovca.pdf
The Small Local Governments Compliance As-
sistance Policy promotes comprehensive environ-
mental compliance among small local governments.
Providing conditions and circumstances in which
states may reduce or waive normal noncompliance
is intended to reassure small local governments
that they will not be forced to pay a large penalty if
environmental violations are discovered while they
are participating in compliance assistance activities.
Additional resources can be found on EPA's website:
http: //www.epa.gov/
Smart Growth Technical Assistance
http://www.epa.gov/dced/sgia.htmttcomm
Though communities want to foster economic
growth, protect environmental resources, enhance
public health, and plan for development, they
may lack the tools, resources, and information to
achieve their goals. In response to this demand,
EPA developed the Smart Growth Implementa-
tion Assistance (SGIA) Program. The aim of EPA's
smart growth program is help communities achieve
better environmental, fiscal, community, and public
health outcomes with better development patterns.
Smart growth approaches include increasing walk-
ing, increasing transportation choices and devel-
oping places where infrastructure already exists.
Other strategies include conserving and protecting
farmland, ranges, and environmental sensitive areas,
including stakeholders in development decision
making, and making the development process more
fair and predictable in places where communities
want growth to occur. All of these approaches help
to decrease the environmental footprint of develop-
ment while providing the increased opportunities
that are necessitated by growth.
Green Building
http://www.epa.gov/greenbuilding/
The EPA Green Building Strategy addresses a major
sector of the economy that presents significant op-
portunities for improving environmental and public
health protection. By working with others who
share EPA's interests and by strategically coordinat-
ing the Agency's own building-related programs,
EPA will play an important role in bringing about
the widespread adoption of effective, high-perfor-
mance green buildings for the benefit of future
generations.
LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT 17
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Recommendations
Small communities are the front line of defense when it comes to protecting human health and the envi-
ronment. It is essential that EPA establish a small communities office that will coordinate the unique needs
of small communities, primarily the lack of administrative and fiscal capacity.
The Local Government Advisory Committee would like to thank all the small towns and local govern-
ments in the United States for their effort to protect human health and the environment, and in particular
the people of Castleford, Idaho and Dietrich, Idaho who willingly shared their challenges and accomplish-
ments with the LGAC and the EPA.
Acknowledgements:
Corey Buffo, EPA Smart Growth Program
Darcey Doyle, Environmental Finance Center Boise, Idaho
Pam Grant, EPA Senior Advisor to the Administrator
Lyons Gray, EPA's Chief Financial Officer
Bill Jarocki, Environmental Finance Center Boise, Idaho
Sue Skinner, EPA Region 10 Place Based Person
Local Government Advisory Committee Members
Small Community Advisory Sub-Committee Members
Photos: EPA AO Multimedia Operations and Services Staff
18 LOCAL GOVERNMENT ADVISORY COMMITTEE SMALL COMMUNITIES REPORT
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Disclaimer:
This report is a work product of the Small Community Advisory Subcommittee (SCAS) of the Local Government Advisory
Committee (LGAC), a formal advisory committee chartered under the Federal Advisory Committee Act since 1993. The
committee is composed primarily of elected and appointed local officials, along with several State representatives, environ-
mental interest groups, and labor interests. The LGAC provides advice and recommendations to the Administrator and other
officials of the U.S. Environmental Protection Agency (EPA) to assist EPA in developing a stronger partnership with local
governments and building efficient and effective environmental protection at the community, State and Federal level. This
product has been reviewed by EPA; however, the work product contents and recommendations represent the views of the
Committee, not of EPA. Mention of trade names of commercial products does not constitute a recommendation for use.
Local
November 2008
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