WPD 7-76-02
HANDBOOK FOR COORDINATION OF
STATE AND DESIGNATED AREAWIDE WATER
QUALITY MANAGEMENT AGENCIES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
JULY 1976
-------
Page Intentionally Blank
-------
PREFACE
This handbook is one of a series designed to provide State
and areawide agencies with assistance in carrying out water quality
planning and implementation. Designation, Grant Application and
Work Plan, Cost Analysis, Interim Outputs, Management Agencies, State
Continuing Planning Process, and Public Participation handbooks have
already been published. This handbook serves as a supplement to 40 CFR,
Part 130 and 131 which describe the Continuing Planning Process and
the preparation of water quality management plans. It also expands
upon the Draft Guidelines for State and Areawide Water Quality Manage-
ment Program Development (February, 1976).
The purpose of this handbook is to explain more fully and
with the use of examples the specific interactions between State and
the designated areawide planning agencies. These interactions include
the functions of program assistance, technical assistance, and plan
review and certification. The handbook deals specifically with
coordination in basin planning, areawide planning, the NPDES program,
and the facilities planning program.
Other EPA reference documents and previously published handbooks
dealing with the water quality management process include:
• 40 CFR 130 and 131, the Continuing Planning Process
and Preparation of Water Quality Management Plans
(November, 1975).
• Guidelines for Areawide Waste Treatment Management
Planning (August, 1975).
• Draft Guidelines for State and Areawide Water Quality
Management Program Development (February, 1976).
• Cost Analysis Handbook for Section 208 Areawide Waste
Treatment Management Planning, Federal Assistance
Applications (May, 1975).
• Management Agencies Handbook for Section 208 Areawide
Waste Treatment Management (September, 1975).
• Revised Area and Agency Designation Handbook for
Section 208 Areawide Water Quality Management Planning
(November, 1975).
• Revised Grant Application and Work Plan Handbook for
Section 208 Areawide Water Quality Management (December, 1975)
• State Continuing Planning Process Handbook (December, 1975).
-------
• Public Participation Handbook for Water Quality
Management (June, 1976) .
This handbook was prepared under Contract No. 68-01-3195
by Harold F. Wise under subcontract to Centaur Management Consultants,
Inc. with the direction and support of James W. Meek and the Program
Management Branch and James Lund and the Program Development Branch.
Mark A. Pisano
Director, Water Planning Division
Washington, D.C.
11
-------
Table of Contents
Page
PREFACE i
I. INTRODUCTION AND PURPOSE 1
II. CONSISTENCY OF STATE AND DESIGNATED AREAWIDE PLANNING 2
A. Program Relationships 2
B. Planning Relationships 3
C. Consistency of State and Areawide Plans 4
III. STATE RESPONSIBILITIES FOR PLANNING IN DESIGNATED AREAS 6
A. The Basis for Division of Responsibilities 6
B. Categories of Planning Tasks 7
1. Program Assistance
a. State Regulations and Guidelines 7
b. Designated Area Planning Process 10
c. Regulations and Legislation to Implement
Plan 10
2. Technical Assistance 12
a. Revision of Water Quality Standards 12
b. Waste Load Allocations 15
c. Terms and Conditions of NPDES Permits 18
d. Data Collection and Dissemination 20
e. Maximum Daily Loads 21
f. Facilities Planning and Construction Grants. 21
3. Coordination 23
a. Coordination of Water Quality Planning and
Related Programs 23
b. Planning Area Policy Advisory Committees ... 24
4. Review and Certification 29
111
-------
Table of Contents (Continued)
a. Review and Certification of Work Plans 29
b. Review of Progress—Milestones and Interim
Reports 32
c. Review and Approval of Interim Outputs 34
d. Review of Final Areawide Plan 37
IV. PARTICIPANTS IN THE AREAWIDE WATER QUALITY MANAGEMENT PLAN-
NING PROCESS, THEIR ROLES AND EXPERIENCES 39
A. Introduction 39
B. Relationships with EPA Regional Offices 39
C. Established Practices of State Agencies 40
D. The Role and Nature of Areawide Agencies 41
E. Arrangements Between Local Governments 42
F. Conclusion 43
APPENDIX
IV
-------
NOTE
This document is not a replacement to the Act, the Regulations,
or official EPA Policy Statements. It is a supplement to these documents,
showing hypothetical examples to assist State and areawide agencies in
responding to water quality management program requirements. The examples
in this handbook do not constitute a uniform National EPA standard of
acceptability. Any clarification and specific conditions applicable
to a State or areawide agency should be discussed with the EPA Regional
Offices.
v
-------
I. INTRODUCTION AND PURPOSE
The successful development and implementation of water quality
management plans will require a close working relationship between
States and designated areawide agencies as well as local governments.
The purpose of this handbook is to provide guidance concerning those
necessary interrelationships, with particular attention to what States
can do for designated areawide agencies.
The focus of the handbook is on delineation of State and areawide
agency responsibilities, not on planning techniques per se. Respective
responsibilities of the State and the designated areawide planning
agency for accomplishment of the range of major tasks involved in water
quality management planning are described. Where a division of responsi-
bilities is left to the discretion of the participating agencies, sug-
gestions are offered as to how such divisions might be made.
The handbook draws on EPA regulations (including the revised
40 CFR 130-131 regulations), guidelines, program guidance memoranda
and policy directives. It provides simplified examples to illustrate
specific planning tasks to be carried out. Wherever possible, these
examples have been taken from actual cases.
-1-
-------
II. CONSISTENCY OF STATE AND DESIGNATED AREAWIDE PLANNING
A. Program Relationships
The State water quality management planning process provides a
means for integrating designated areawide management planning under
Section 208 with Section 201 facilities planning and construction
grants, the NPDES permit program and Section 303(e) basin planning.
These programs are dealt with in detail in Section III, B, 2 of the
handbook. All of these and other programs operating together constitute
comprehensive water quality management.
It must be recognized, however, that the permit and construction
programs are out of phase with the water quality management planning
process. Since Statewide water quality management plans, once approved,
provide the basis on which future permits and construction grants are
issued, it is the responsibility of the water quality management program,
through State and local cooperation, to guide and coordinate facilities
planning and NPDES permitting.
The NPDES agency, which may be a State agency or EPA, is in
charge of drafting and issuing permits for municipal or public discharges
and industrial and other non-public dischargers. The NPDES agency should
supply State and/or areawide planning agencies with draft permits
affecting dischargers in their planning areas. The State and the area-
wide planning agencies should inform the NPDES agency of conflicts
between draft permits and ongoing planning.
In almost all cases, discharge permits under Section 402 have
been issued prior to the commencement of water quality management plan-
ning. Many first-round municipal permits expire on July 1, 1977,
well before the scheduled completion of most water quality management
plans. Therefore, designated areawide agencies should discuss any
inconsistencies between their water quality management planning and
draft permits with the State and/or EPA. Industrial permits will
generally expire in 1979. Since these permits were also issued prior
to water quality management planning, the State and designated areawide
agencies should become familiar with the conditions set forth in these
permits, determine which conditions conflict with their proposed plans,
and, while in their planning phase,, participate in discussions relating
to subsequent drafts of the permits.
Facilities planning under Section 201 which has been completed
or is currently being done is to be incorporated into statewide water
quality management planning, by both the State and designated areawide
agencies. In addition, the designated areawide planning agencies will
provide the following input to State water quality management plans for
future facilities planning: service areas, capacities and population
served, load reduction or level of treatment, type of treatment, and
preliminary cost estimates.
-2-
-------
Under Section 303(e) basin planning program, the State water
quality management plans, Phase I, completed or near completion by the
States, provide data on wasteload allocations and stream classifications
which may be adequate for areawide planning or may be used as a basis for
more intensive study. Under the new regulations, the State is generally
responsible for: water quality assessments (including nonpoint source
assessment) and segment classifications, inventories and projection of
discharges, revision of water quality standards, total maximum daily
loads, and wasteload allocations and the provision of this information
to designated areawide planning agencies for incorporation into their
plans. The State may reach agreements with designated areawide agencies
to carry out much of this analysis but is ultimately responsible for
providing such information in the State water quality management plan.
For integrating these various programs through the State water
quality management planning process, timing is a key factor. Planning
should generally be completed prior to other actions being taken.
Bringing permitting and construction programs into phase with the overall
water quality management program should be a long-term goal of the State
plan.
B. Planning Relationships
As areawide water quality management planning agencies approach
their assignment, they will find that some of the elements of water
quality management planning required under new regulations will have
been done previously by the State water quality planning agency, and
some will be developed for the first time. Of the former group, some
may be carried over intact, and some may warrant revision.
In the process of transition from the old to the new planning
configuration, State and areawide agencies must determine which planning
elements done previously should be strengthened or revised. Such
determinations will vary from one instance to the next. However, certain
general assumptions can be made as to which elements will usually be
carried over, which will require review and which must be newly developed.
Section 131.10(g) of EPA regulations, 40 CFR Part 130-131,
states that an areawide water quality management plan must include,
but not be limited to, the following elements:
1) planning boundaries
2) water quality assessment and segment classification
3) inventories and projections
4) nonpoint source assessment
-3-
-------
5) water quality standards
6) total maximum daily loads
7) point source load allocations
8) municipal waste treatment systems needs
9) industrial waste treatment system needs
10) nonpoint source control needs
11) residual waste control needs; land disposal needs
12) urban and industrial stormwater needs
13) target abatement dates
14) regulatory programs
15) management agencies
16) environmental, social, and economic impact
The last three elements — regulatory programs, management
agencies and impact analyses — will probably require detailed study
and continuing analysis during plan development, depending on the
complexity of existing institutional arrangements.
While existing regulatory methods and existing management
agencies can be utilized or be adjusted to meet the areawide planning
and management mandate, the comprehensive requirements of the new plan
will necessitate integration of these pieces into a new and broader
scheme.
Additionally, each other element should be reviewed and revised
as necessary. (The ways in which this might be done are discussed in
greater detail in the following section of this handbook.)
It is noted that different States and different areawide agencies
are at different stages in the process of water quality management
planning. Thus, some decisions regarding the use of existing planning
elements and the need for review and revision will have been made, in
many cases, while others remain to be considered.
C. Consistency of State and Areawide Plans
Each areawide water quality management plan when certified by
the Governor becomes a part of the State plan.
-4-
-------
The State planning agency may develop a number of basic plan
elements and will thus assure consistency in these respects. These
include the following:
• Water Quality Standards
• Segment classifications
• Maximum daily loads — point and nonpoint allocations
Other plan elements will be developed by the areawide agencies,
according to criteria developed by the State or to be mutually agreed
upon by the designated agency and the State. These will usually include
the following:
• Municipal waste treatment needs
• Industrial waste treatment needs
• Nonpoint source control needs
• Residual waste control needs
• Stormwater system needs
• Target abatement dates
Consistency in still other plan elements will require special
State areawide coordination. These are elements which may overlap
designated planning areas and State planning areas. These may include
the following:
• Nonpoint source assessment and control
• Regulatory programs
• Management agencies
• Environmental, social and economic impact assessments
-5-
-------
III. STATE RESPONSIBILITIES FOR PLANNING IN DESIGNATED AREAS
A. The Basis for Division of Responsibilities
The basic arrangements for water quality management planning
to be done by the State planning agency and the designated areawide
agencies in the State are determined and explained in the description
of the continuing planning process that is to be submitted by each
Governor to the EPA Regional Administrator (Section 130.10(c), 40 CFR
130) . This description includes provisions for public participation
during the planning process, intergovernmental input in the development
and integration of water quality management plans, and coordination and
integration of water quality planning between the State and areawide
agencies, as well as other related planning activities. In addition,
the State policy on antidegradation, the annual State Strategy, and
the review and certification of designated areawide plans must also be
explained in terms of their achievment in the continuing planning
process description. Finally, the description includes a listing(s)
and map(s) delineating State planning areas and designated areawide
planning areas and showing each segment and its classification, a
description of the State's management program of designated areawide
agencies, and the EPA/State Agreement.
The EPA/State Agreement is the vehicle for establishing specific
division of responsibilities for the various elements of the State
water quality management plan.-1- Since the water quality analysis
elements of the State plan are critical to completing designated area-
wide plans, the EPA/State Agreement should delineate how the State
will ensure completion of these elements in phase with the needs of
designated areawide agencies. The Agreement should further indicate
the milestones that the State will use to monitor the planning progress
of designated areawide agencies. Whatever division of responsibilities
is followed, the State remains in charge of the overall work integration
and coordination.
Since the designated areawide agencies are substantial contributors
to the State plan, they should be consulted in the beginning stages of the
continuing planning process, most particularly in the development of
the State Strategy and EPA/State Agreement. Designated areawide agencies
may find it advantageous to form a council, representative of individual
agencies, to participate in the continuing planning process.
Delegations of responsibilities for specific planning tasks to
other agencies should be based on consultation between the State and the
areawide agencies. The designated areawide agency must know how these
States were to submit their EPA/State Agreement to EPA by April 26,
1976 as part of their continuing planning process submission.
-6-
-------
delegated work tasks will fit into its work program: the specific
amount of work to be completed, the time schedule for completion, and
products to be provided by these other agencies to the areawide agency.
The State is responsible for coordinating interagency work arrangements
at the State level.
B. Categories of Planning Tasks
State responsibilities will be discussed in terms of four
categories of tasks: program assistance, technical assistance,
coordination and review and certification.
Program assistance is that assistance which guides or helps
designated areawide agencies in their efforts to develop the methods
and procedures for water quality management planning and plan imple-
mentation.
Technical assistance pertains to specific planning activities.
Assistance in this category includes both State production of certain-
planning elements for a designated areawide plan, and State cooperation
with a designated agency to accomplish other tasks.
In addition, the State is responsible for general coordination
of the water quality management planning process statewide, and between
the State and its neighbors. This includes coordination both of inter-
governmental inputs to water quality management planning, and of the
water quality management program with other related functional and
planning programs.
Finally, the State must review and certify the various draft
and interim products of the planning process, as well as final plans.
1. Program Assistance
a. State Regulations and Guidelines
The State is responsible for developing and supplying
policy direction. This is best organized in the form of regulations,
guidelines and instructive memoranda which will enable designated area-
wide agencies and other participants in the water quality management
program to accomplish their work in a timely and effective manner. The
State should address this responsibility at an early stage, determining
a general policy with respect to the purposes, format and scheduling
of regulations, guidelines and any other management directives it
proposes to use. Designated areawide planning agencies and other partic-
ipating agencies and groups will want to know what kinds of directives
will be issued, how they will be drafted, what information they will
contain arid when they will be issued.
-7-
-------
By contract with the several designated areawide water quality
management planning agencies in the State, the State Water Pollution
Control Board has agreed to provide a range of services, one of which
is "to review the Agency's planning process and the interim and final
plan outputs to assure consistency with State statutes and policies and
conformance with the State's continuing planning process and the Water
Quality Management Plan".
Certain inadequacies in the procedures being followed by one
designated Agency have come to the attention of the State, and a number
of meetings and exchanges have taken place in an effort by the State to
improve and strengthen the Agency's planning process.
MEMORANDUM:
TO: George Vitale, Chairman,
Johnson County Association of Governments
FROM: Maxwell Clinton, Director
Water Pollution Control Board
SUBJECT: J-CAG WQM Planning Procedures
The memorandum summarizes recent discussions between Board and
Agency representatives regarding improvements to be made in the Agency's
water quality management planning process and assistance to be provided by
the State Board.
The requirements specified by this office refer to EPA regulations
(40 CFR, Part 130.10), and particularly the sections which state that a
designated areawide planning agency must establish a planning process
which:
• Provides for public participation during plan development,
review and adoption.
• Assures adequate intergovernmental input in the development
and implementation of WQM plans.
• Provides for coordination and integration of areawide WQM
planning with related local comprehensive, functional and
other developmental planning activities, including land use
and other natural resources planning activities.
The State Board has determined that J-CAG water quality management
planning procedures, as of this date, do not satisfy these general stan-
dards. This judgement is based on the following major findings:
-8-
-------
• Major tasks relating to WQM planning have been assigned to
the Johnson County Water and Sewer Commission, and are
being conducted without adequate coordination with the J-CAG
planning staff.
• Neither the J-CAG Executive Board, nor any Committee thereof,
has established a regular schedule of meetings for the purpose
of setting policy and guiding the WQM planning effort.
• A number of chief elected officials of cities within the
Agency's designated planning area—all of whom are members
of the J-CAG Executive Board—are not aware of how WQM
planning is to be done or how it will affect their respective
communities.
• No arrangements have been made for participation or represen-
tatives of public interest groups or of the public in general
in the WQM planning process.
In light of these findings, the Board initiated a series of dis-
cussions with the J-CAG Executive Committee. A number bf alternative means
of correcting the inadequacies noted have been suggested. It has been
generally agreed that J-CAG will promptly review this matter, and that
the State Board will provide technical assistance, in line with the State/
J-CAG contract dated August 16, 1975.
The State Board is prepared to negotiate an agreement, supplementing
the State/J-CAG contract, to provide the services of a professional planner
for up to, but not to exceed forty (40) work days, with the cost of these
services to be paid from that portion of the J-CAG WQM planning grant
previously allocated to the State Board for specified services.
For its part, the J-CAG Executive Committee agrees to develop
procedures to satisfy the EPA requirements noted above, and to submit its
proposals for State Board review and approval within sixty (60) days of
the effective-date of the supplemental agreement to be negotiated and with-
in no more than ninety (90) days of the data of this memorandum.
-9-
-------
After making such policy determinations, the State
may establish a mechanism for obtaining prior inputs from all affected
parties — designated planning agencies, local governments, and others.
Such a mechanism will provide for notification of intent to issue a
directive, requests for recommendations, and publication of draft pro-
posals for review and comment prior to issuance.
b. Designated Area Planning Process
The State will provide assistance to a designated
areawide planning agency during the period when it is designing its
planning process, and later when it puts that process to work. The
State will want to make sure that inadequacies and breakdowns in the
planning process are identified and corrected at the earliest possible
time.
When the designated areawide agency is designing
its planning process, the State must determine what elements it will
provide and supply information on standard practices and model pro-
cedures for involving the public; intergovernmental inputs within the
planning area; integrated water quality planning with local compre-
hensive, functional and other developmental planning; and other elements
of the planning process.
The tasks the State will complete for designated
areas (with concurrence at the local decision-making level) will usually
include water quality assessment and segment classification, water
quality standards, total maximum daily loads, and point source load
allocations. These are specific services that the State planning agency
itself provides and should not be confused with responsibilities that
the State delegates to other agencies to do for the designated agencies.
The designated areawide agency should negotiate a formal agreement which
specifies what services will be supplied by the State and in what manner.
Subsequently, the State planning agency should
provide continuing assistance to help areawide agencies produce draft
and interim and final plan elements that will satisfy State and EPA
requirements for quality and timeliness. The State will review and
approve or disapprove interim outputs and the final plan but prior to
that, it will be necessary for the State to provide direct assistance
on a consultative basis.
A limited amount of the designated areawide planning
agency's planning grant (4 to 8 percent of the total) may be passed
through to the State planning agency to pay for program assistance and
general guidance of this type.
c. Regulations and Legislation to Implement Plan
As areawide planning progresses, the need for new and
revised regulations and legislation should be anticipated and identified
in a timely manner. Some will require local action, others will require
action at the State level.
-10-
-------
The Water Resources Division of the State Environmental Protection
Authority has received a significant number of inquires about various State
regulations. Areawide agencies and local governments have asked for samples
of various types of regulations. They have asked about the possibilities
of getting the rules of the State Public Utilities Commission, the State
Department of Health and others modified. Recognizing the need for the
State to provide special assistance in this area, the Division with the
cooperation of the Attorney General's office has set up a new Office of
Legal Assistance, the functions of which are described as follows:
NOTICE
Establishment of Office of Legal Assistance
The Attorney General has assigned James B. Crawford, Jr., a Deputy
Attorney General, who is a water resources specialist, to the Water Resources
Division, State EPA, Mr. Crawford will head a new Office of Legal Assistance
in the Division.
The Office of Legal Assistance will provide information services to
local governments and public organizations and advisory services to local
governments, as follows:
"The Office of Legal Assistance provides a central source of in-
formation and general advisory assistance relating to laws and
regulations affecting water resource management.
"All governmental units within the State, including water and
sewer districts, towns and cities, counties, regional councils
of government, regional planning districts and development districts
may use the services of this Office.
"Assistance will also be provided to public and private organizations
concerned with water quality management, including chambers of
commerce, business and industry associations, environmental organi-
zations, etc. However, assistance to such groups will be on a time
available basis, as the first responsibility of the Office is to
assist governmental units responsible for water quality management
or some related activity.
"The Office will establish a central library of water resource
management laws and regulations, including samples of model regula-
tions, codes, resolutions, laws, etc. Copies of library materials
will be available to government units and others, according to a
fee schedule to be established (or by contractual agreement with
water quality management planning agencies).
"The Office will establish and manage a system to gather reports
on proposed regulatory actions, including drafts of proposed laws
and regulations, from all local and regional agencies responsible
for elements of State water quality management planning."
-11-
-------
The State should provide assistance in the develop-
ment of local rules or ordinances considered necessary for effective
plan implementation. These ordinances and regulations should be analyzed
in terms of long term financing alternatives, annual operating and
maintenance cost estimates, indirect cost impact on current use charge
structures, estimated cost to users, environmental impacts and ability
to meet water quality goals. It will be helpful if the State prepares
a variety of model ordinances for the use of designated areawide agencies
and local governments in resolving general problem areas such as nonpoint
sources of pollution, fiscal or institutional arrangements. One example
would be the modification of construction site practices to better con-
trol or eliminate sediment runoff.
In addition, the implementation of the plan may also
require amendment of State laws or regulations or the drafting of new
ones. At the earliest possible time, it" should be determined whether
or not any such legislative or regulatory actions will be politically
and legally feasible and desirable. Careful attention should be given
to the time constraints involved in the passage of legislation. At the
end of the first year, a special effort will be required to identify
and address problems in implementation.
The State planning agency should prepare and
distribute a summary and brief analysis of all State laws relating to
water quality management. This task could be included in the agreement
with the designated agency as one of the duties performed for receipt
of a percentage of the planning grant. Water quality management regula-
tions, will be distributed as a matter of course, but other related
regulations should also be identified and reported for the use of
designated areawide agencies.
The State may accomplish the task of coordinating
and assisting legislative and regulatory activities in a variety of ways.
A State-level legal office or agency may be delegated responsibility
for coordinating information, furnishing legal advice, and identifying
special problems. The State may devise a system whereby these delegated
agencies can report on what regulation measures are needed to resolve
special problems. As appropriate, conferences of local, areawide, and
State legal advisors might be scheduled, including staff or members of
the State Legislature.
2. Technical Assistance
a. Revision of Water Quality Standards
Water quality standards shall be 'reviewed and revised,
when necessary, by January, 1977 to define, for each waterway, uses and
criteria necessary to achieve national water quality goals. States are
urged to complete standards reviews as soon as possible to provide
designated planning agencies with the information needed to complete
required outputs.
-12-
-------
In April a State announcement of intent to review and revise
water quality standards, beginning on June 1, was published as a legal
notice and distributed to all government agencies, utilities, industry
associations, environmental organizations and other interested parties
throughout the State.
The section of this announcement pertaining to the timetable for
the review and revision process included the following language:
"(1) Notice of intent to review, and where appropriate, revise
water quality standards. All parties proposing to recom-
mend modifications to any water quality standard will submit
formal written notice within thirty (30) days, or on or
before July 1.
"(2) Submittal of recommended revisions. All formal recommendations
for revision of any water quality standard, together with
supporting data and analyses, will be submitted to the State
Department of Natural Resources by no later than August 1
(or within 60 days from beginning of review).
"All local governmental agencies, utilities, industries,
environmental groups and other organizations or members
of the public located within a Designated Planning Area
shall submit proposed revisions to the water qualtiy
planning agency for that area.
"(3) Public notice of propsoed revisions. Each proposed revision
of water quality standards will be summarized by the State
Department of Natural Resources and included on a list to be
published as a legal notice throughout the State, and other-
wise distributed to interested parties, no later than
September 1 (90 days after beginning of review).
"(4) Public hearings on proposed revisions. One public hearing on
all proposed revisions of standards shall be duly advertised
and held in each sub-state planning region no later than
October 1 (120 days after beginning of review).
"Upon the formal request of designated area planning agencies,
additional public hearings will be held in such areas.
"(5) State adoption and approval of water quality standard
revisions. The Governor or appropriate State authority
shall approve revisions, that meet the requirements of PL 92-
500 and EPA policy as stated in 40 CFR 130.17, and refer de-
cisions to the Regional Administrator of EPA on or before
November 30 (180 days from beginning of review)."
-13-
-------
Another section of the announcement pertained to the role and re-
sponsibilities of the local designated planning agencies in the review
.process, and contained the following language:
"Designated areawide planning agencies shall be responsible for
coordinating the review and revision of water quality standards
within their respective planning areas, provided that (a) the
timetable set by the State shall be met, (b) all State guidelines
shall be coordinated with and monitored by the State Department
of Natural Resources.
"To this end, each designated planning agency shall identify one
office within the Agency to coordinate the areawide review and
serve as an information center.
"Local government units, universities, utilities, industries,
environmental organizations and other interested parties will be
consulted by the planning agency, as necessary, and specifically
with respect to the following:
"• Identification of possible revisions.
"• Collection of data, analysis and other documentation
to support each proposed revision, in compliance with
State guidelines."
-14-
-------
Current water quality management is based on water
quality standards as already defined. As planning activities intensify,
planning agencies will provide the State with any new information
suggesting the need for revisions of standards.
Each State is required to submit a schedule for
its standards review as part of the continuing planning process. The
schedule should specify the steps to be taken in the process of review.
It should include a timetable with milestones and deadlines for analysis,
recommendations for any revisions, public hearings, and evaluation and
approval of proposed revisions.
State guidelines shall explain the role of designated
areawide planning agencies and other agencies and organizations in the
review process. Water quality standards are legally adopted by the
State or EPA, and any State revisions must be approved by EPA. Neverthe-
less, designated planning agencies may be delegated responsibility by
the State for circulating proposed revisions and supporting data, col-
lecting comments from all sources and negotiating disagreements, as well
as voicing the agency's own recommendations.
State guidelines and water quality standards should
also restate EPA policy on water quality standards and antidegradation,
adding any supplementary State requirements that may be developed, con-
sistent with EPA's established policy.
b. Waste Load Allocations
Waste load allocations will generally have been
made by the State, as a general rule, based on segment analysis and
classification. These allocations may or may not include assessment
of nonpoint source data.
Within the first nine months of water quality
management planning, designated planning agencies shall review waste
load allocations to understand monitoring and analysis which the State
has done previously. Segment classifications should be included. One
of the interim outputs to be prepared during this period is a report
of this review. (The other interim outputs required at this period
are: service area delineation, existing and projected population and
land use, projected waste loads and flows.)
As planning progresses, it may become necessary
to refine segment classifications and revise waste load allocations.
A definitive classification of stream segments will become possible as
water quality standards are reviewed and revised, and when more complete
data on nonpoint source pollution is obtained. It is the responsibility
of the State planning agency to arrange for review of segment classifica-
tions and waste load allocations, if and when necessary. Designated
planning agencies will often be the first to identify problems with
waste load allocations. The State may delegate responsibility for
review to a designated agency, however the State shall approve all
revisions.
-15-
-------
The State has decided to review and revise water quality standards
to reflect the 1983 goals of the Act. This decision will probably neces-
sitate a waste load allocation review. Designated planning agencies are
to conduct reviews and recommend revisions. Procedures were developed
during the process of revising work plans of FY 1976 and incorporated into
designated agency work programs, as follows:
TASK 23500 - Waste Load Allocation Review
Purpose; This required review of waste load allocations and
supporting elements is to provide (a) a detailed under-
standing of these elements, as they appear in existing State water
quality management plans, and (b) an opportunity for integration of
new data and identification of the need for re-analysis and possible
revision. These data include the introduction of toxic materials to
reflect proposed revisions of State water quality standards.
Subtask 1: Review of basis for waste load allocations
Designated areawide planning agencies shall review data and
analyses on which segment classifications and existing waste load
allocations were based. Materials to be supplied by the State
EPA, if not previously on file.
Each designated agency shall prepare a report—a required
interim output—which includes, as a minimum, the following:
(a) Identification of those water quality assessment data
which will be expanded or updated by the Agency, if
any, with projected dates for completion.
(b) Identification of any new categories of water quality
data to be developed, including nonpoint source data—
i.e., urban stormwater, sedimentation from construction,
agricultural irrigation return flows, etc.
(c) Brief summaries of any problems identified, including
anticipated developments that may affect waste load
allocations.
(d) List of toxic materials, discharged into the area, which
are proposed for inclusion in the water quality stan-
dards .
Subtask 2; Revision of waste load allocations
Designated planning agencies shall determine, on the basis of
their review of waste load allocations, whether revision of allo-
cations, or segment classifications should be considered.
-16-
-------
Each Agency shall file with the State EPA a formal written
notification stating that the agency does, or does not believe such
revisions may be warranted at this time.
If revision is recommended, the agency shall transmit with
this formal notification a brief preliminary summary of reasons,
which identifies the new or changed conditions, projections, data
collected, or other basis for its recommendation.
The State EPA will review each such recommendation and request
additional information, as it deems appropriate. If the State
agrees to consider the proposed revision, the agency may be required
to prepare more detailed supporting analyses.
Relationships with other designated agency planning activity
Revised waste load allocations as agreed upon by the State
and the designated agnecy will be utilized in the designated
areawide planning area as a basis for preparation of the final
areawide point source plan element which addresses industrial,
municipal and all other point sources in the planning region
(See Tasks 2363, 2364, and 2365).
Schedule
Task 23500 is to be initiated during the second week of the
second month of the areawide planning program. Subtask 1 will be
completed during the fifth month and Subtask 2 by the end of the
second week of the ninth month.
-17-
-------
As designated planning agencies proceed to develop
and test alternative sets of waste load reduction and select subplans
of treatment, control, abatement and flow reduction, further adjustments
of waste load allocations may be required.
c. Terms and Conditions of NPDES Permits
Many first-round municipal NPDES permits will expire
on July 1, 1977, well before the scheduled completion of most designated
areawide plans. In these circumstances, second-round municipal permits
should be coordinated with ongoing State and areawide planning.
NPDES agency (State or EPA) shall be responsible
for drafting and issuing permits. In so doing, it shall make certain
that permits are not in conflict with approved areawide plans or
approved interim outputs.
For its part, the designated agency is responsible
for reviewing draft permits and advising the NPDES agency whenever a
draft permit deviates from its planning. When deviations are identified,
EPA, the State and the designated areawide agency will negotiate a
solution to the problem.
As early as possible in the planning period, the
State planning agency, with the cooperation of appropriate areawide
agencies, should give public notice and hold hearings on waste load
allocations and other limits on specific discharges. Unless the State
notifies dischargers and the public on proposed limitations which affect
them, and gives them the opportunity to appeal, subsequent permits may
be delayed by drawn-out litigation.
Also, there should be consistency between permit
compliance schedules and financial planning for treatment works con-
struction. In commenting on draft industrial and municipal permits,
planning agencies should check to see that draft compliance schedules
are realistic in light of available funds. With respect to construction
of publicly owned treatment works, the planning agencies should consider
the position of each project on the State construction priority list
and the availability of Federal, State, and local funds when evaluating
compliance schedules. Planning agencies should also see that local
construction priorities are reflected in the State priority list. Where
conflicts arise on priorities or compliance schedules, EPA, the State,
and the areawide agency should meet to agree on necessary adjustments
before a final NPDES permit is issued.
The areawide agency's permit-related tasks shall be
included in its work plan, and specific resources should be reserved
for the completion of those tasks. In addition, the State and the
designated areawide agency should include their respective roles in
the NPDES program in any formal contractual agreements they may make.
-18-
-------
The State has developed a standard contract to govern the work re-
lationships and responsibilities of the State water quality planning agency
and designated areawide planning agencies. The section of the contractual
agreement relating to the NPDES permit program is as follows:
Section 1; Scope of Work
C. NPDES Permits
Responsibilities of the State—the State, as the NPDES permit
issuing Agency, shall prepare and issue all permits, in accordance
with EPA regulations.
Notwithstanding its authority to issue permits, the State
agrees to cooperate with the designated areawide planning agency
which is a co-signer of this contract as follows:
1. To coordinate all draft permits with the approved water
quality management plan of the designated agency, or
approved portions of said plans, when such permits
are for dischargers located within the boundaries of
the agency's planning area.
2. To deliver copies of all draft permits to the designated
agency, no less than 60 days prior to the proposed
date of issuance, for that agency's review and comment.
3. To duly record and evaluate all agency comments re-
garding a draft permit prior to its issuance.
Responsibilities of the Designated Agency—the designated
areawide water quality planning agency is responsible for review-
ing all draft permits prior to issuance and determining their
consistency with agency planning, plans and portions of plans,
including financial planning.
The designated agency agrees to cooperate with the State,
the NPDES permit agency as follows:
1. To review and comment on all draft permits, .as received
from the State, within 14 days of receipt, said com-
ments to be written and in a format agreed upon by the
State and the agency.
2. At all times to notify the State promptly of all agency
planning activities that affect, or may affect the terms
and conditions of NPDES permits.
3. To inform the State of imminent or existing overloads
of municipal facilities so that the State may issue a
permit in accordance with EPA directives.
-19-
-------
d. Data Collection and Dissemination
The State should provide the areawide agency with all available
water quality data. The base will contain data collected by the
State and others, all of which should be available in usable form
to planning agencies and other interested parties. Designated
agencies may wish to conduct more extensive studies to supplement
the information provided by the State.
The State itself is responsible for water quality monitoring
and surveillance. These activities will provide such information
as wet weather flow conditions, waste discharge from municipal
and industrial sources and will help determine natural background
levels of pollution necessary to establish water quality standards.
EPA has established a computerized water quality information file
(STORET - Storage and Retrieval). This system contains a central
index with data characteristics identified (i.e., topic, detail,
scale, source, currency, etc.), and a set of standard procedures
to be used in assessing data.
Other sources of water quality data will include basin plans,
facilities plans, the NPDES permit program, urban studies by the
U.S. Army Corps of Engineers, flood plain studies by the U.S.
Geological Survey and the Corps of Engineers, and State and local
water supply studies.
General social, economic, and physical data may also be in-
cluded in the data base. This is an optional task for the State
and its inclusion depends primarily upon the State's availability
of manpower or access to such information. Working from this base,
definitive planning at the areawide level and elsewhere can develop
greater detail and more precise analysis. Existing data will be
important to designated areawide agencies during the initial water
quality planning period, when time is short; but new data will be
needed, and if possible, should be added to the base as collected
and collated.
Formats and other guidelines for data reporting and management
by agencies responsible for some portion of water quality management
planning may also be provided by the State. Responsibilities for
collecting data to serve specific special needs should be worked out
by agreement between the State, designated area agencies, and others,
as appropriate.
-20-
-------
e. Maximum Daily Loads
The State should have set maximum daily loads
limit for stream segments classified as water quality limited prior
to the initiation of most areawide water quality planning.
Maximum daily loads indicate the level of pollutant
loading that can be allowed in a given stream segment, under critical
flow conditions, without violating water quality standards. At such
time as water quality standards may be upgrated or otherwise revised,
maximum daily loads may require corresponding revision.
The maximum daily load in a stream segment is
divided between point sources and nonpoint sources, with a total
allocation for point sources and a gross allotment for nonpoint sources.
The point source allocation provides the basis for calculating individual
point source waste load allocations. The nonpoint source allotment
represents a target level for reduction of nonpoint sources. Both of
these allotments are State responsibilities unless delegated to area-
wide planning agencies.
The breakdown into point and nonpoint source allot-
ments should be based on knowledge of the existing proportion of point
and nonpoint loadings in each segment, with allowances for future growth.
These loadings must be reduced to a level consistent with the total
maximum allowable load. A number of tradeoffs may be made between
point and nonpoint sources resulting in a possible change in the ratio
of point to nonpoint loading.
During the course of water quality management
planning, need for adjustment of these proportionate allotments may be
identified particularly as more information is developed as to the
loading contribution made from nonpoint sources.
The categories of nonpoint pollution sources —
i.e., agriculture, silviculture, mining, construction, urban runoff,
hydrologic modifications, groundwater, and residual waste — to be '
considered in the designated area planning must be cited in the State/
EPA agreement and the designated agency's work plan. "Best manage-
ment practices" will be established for each category. Determination
of nonpoint source control needs may be done by the designated areawide
agency or by the State on a statewide basis with assistance from various
agencies, as appropriate.
f. Facilities Planning and Construction Grants
Because of the close relationship between facility
planning and water quality management planning, it is very important
that they be fully coordinated. EPA has developed a policy statement
-21-
-------
The State has established maximum daily loads for 6005 for each
water quality segment including the Smith River within the boundaries of
the designated area. This maximum daily load served as the basis for first-
round point source permits in the area. Preliminary results of an areawide
stormwater study indicate that urban runoff is a larger than expected con-
tributor to the BODs load.
The State and areawide water quality staffs will work together
to construct a set of alternatives for dealing with the allotment between
point (municipal and industrial) sources and nonpoint (urban runoff)
sources of BOD. After public involvement directed by the areawide staff,
the State will assume responsibility for determining the proper mix of
structural and nonstructural controls for stormwater control, as well as
dividing the point source allocation into maximum daily loads to be used
in the subsequent point source permit revisions. Many municipal permits
expire July 1, 1977, while most industrial permits do not expire until 1979.
Preliminary indications are that storage and treatment of runoff
from combined sewered portions of the city will be adequate when supple-
mented by an upgraded street sweeping program in the remaining urban areas.
The unexpectedly large BOD load from sewers may require that point sources
accept slightly more stringent controls in order to avoid the extremely
costly treatment of all urban stormwater.
The State agency, with areawide input, will concentrate initial
efforts on water quality standards revision in the designated area. It
is expected that waste load allocations will be needed for suspended solids,
PCB, and heavy metals to correspond to water quality standard criteria
revised and supplemented to meet the 1983 goal. The areawide agency will
also be responsible for determining NFS controls for these criteria and
waste load allocations based on the State gross allotments, once the water
quality standards are revised.
-22-
-------
on the relationship between facility planning and water quality manage-
ment planning. This policy statement is included in the appendix.
3. Coordination
a. Coordination of Water Quality Planning and Related
Programs
Water quality management planning is to be coordinated
and integrated on a Statewide basis and, as necessary, on an interstate
basis. This should include, as a minimum, the following:
• Water quality planning in designated areas.
• State water quality management planning.
• NPDES permits and facilities planning.
• Federal programs, including those of the
U.S. Army Corps of Engineers, the Soil
Conservation Service, the Agricultrual
Stabilization and Conservation Service, and
the Forest Service.
In addition, water quality planning as a whole is
to be coordinated with related planning activities at all levels —
functional, developmental and comprehensive planning, including land
use and other natural resources planning. These should include, as a
minimum, the following:
• Local and areawide functional, developmental
and comprehensive plans.
• Related planning in contiguous areas.
• State environmental plans, including air,
solid waste, water supply and groundwater.
• Other related State programs such as water
resources, land use, mining, transportation
and comprehensive planning.
• Activities of other States, particularly
in interstate designated areas.
• Federal activities, including regional develop-
ment, coastal zone management, and transportation.
The State is responsible for developing a continuing
planning process that will provide for full coordination, not only of
water quality planning on a Statewide basis, but also of water quality
-23-
-------
planning with other related planning activities. It is essential,
therefore, in the designation process of areawide planning agencies,
that Governors take into consideration other related activities of
the agencies to be designated. Coordination between related programs
can be improved when responsibility for the programs is lodged in the
same agency.
Procedures, planning outputs and elements, staff
assignments and institutional arrangements should all be examined with
an eye to how coordination and integration can best be achieved. The
State/EPA Agreement sets forth specific responsibilities and tasks
needed to carry out the State water quality management plan. Some
of these (e.g., projection of population, land use and economic con-
ditions) will be identical or similar to tasks carried out under other
programs. The Agreement should stipulate what information from other
programs can be utilized for the water quality management plan as well
as what tasks can be carried out jointly in achieving the goals of the
related programs.
The designated areawide planning agency has
responsibility for developing its own work plan and planning process
with particular attention to coordination of the activities of local
agencies and governments. Guidelines and directives issued for water
quality planning tasks should provide for coordination, as appropriate
in each case. Intergovernmental agreements such as contractual relation-
ships, memoranda of understanding and joint exercises of powers may
be made to establish formally specific responsibilities.
It is also important that representatives of the
planning agencies responsible for various related programs be included
in any advisory group which might be created. This will provide a
means for communication and ensure coordination among the planning
agencies. Many of the management strategies which will be adopted as
a result of water quality management planning wall have an impact on
other related programs and vice versa. For this reason, it is essential
for planning agencies to develop a close working relationship with each
other.
b. Planning Area Policy Advisory Committees
A policy advisory committee is to be established
in each designated area to assist the designated planning agency. Each
committee is to serve as an advisory group to the policy-making board
of the designated agency. Advisory committees are to consider how
water quality problems can best be solved within the framework of existing
institutions, critique planning proposals and make recommendations for
new institutional arrangements.
-24-
-------
The State's guidelines include a summary of other plans and plan-
ning activities with which designated areawide agencies must coordinate,
at each stage of work, with the type(s) of required or suggested coordina-
tion.
Stage 1; Work Plan Outline
The following water quality planning elements are to be reviewed
and described—including work done to date and estimated dates for comple-
tion.
Local - 201 facilities planning
State - Phase I WQM plans
- NPDES permits
Level B water resource studies
Stage 2; Work Plan Development
Agencies performing the following types of planning are to be
identified and the jurisdictions and functions of each summarized:
Local - facilities planning
- other functional planning (including developmental)
municipal planning (all types)
Area - land use and resource planning
- environmental planning
other planning (all types)
State - water quality related planning
environmental planning
other planning (all types)
Federal - water quality related planning
- environmental planning
- regional planning (all types)
other planning (all'types)
Stage 3; Water Quality Management Plan Development
Completed plan elements and plans are to be examined and integrated
with water quality plan elements, as appropriate:
Local - facilities planning
development agency plans
transportation agency plans
- other agency and district plans
municipal plans
-25-
-------
Area - area development plans
air quality management plans
- transportation plans
- other functional plans
land use and comprehensive plans
- contiguous area water quality management plans
State - State water quality management plans
- State air quality implementation plan (SIP)
- State solid waste management plan
other water quality related plans
State development plan
State transportation plan
- other functional plans
- State land use or comprehensive plan
Federal - regional development plan
coastal zone management plan
other regional plans
Forest Service program plans
- Soil Conservation Service program plans
agricultural stabilization and conservation program
plan
Army Corps of Engineers program plans
other functional program plans
Coordination Techniques
1. State/EPA Agreement (Stages 1,2,3)
The Agreement outlines State and designated areawide agencies'
responsibilities and provides a timetable for the completion of respective
tasks. The Agreement also identifies State and Federal planning agencies
involved in similar work tasks and specifies what tasks are to be done
by those agencies.
2.
Intergovernmental Agreements (Stages 2,3)
The State will establish work contracts with all designated areawide
agencies through mutual negotiations. The contracts will include a deline-
ation of work tasks to be performed by the appropriate regional councils of
governments, regional basin commissions and local planning agencies that
will be integrated into areawide water quality management planning.
Memoranda of understanding will be drawn up with individual desig-
nated agencies to determine what information already completed by other
planning agencies can be utilized by the designated agencies and what tasks
are to be accomplished jointly. Developing a uniform classification
system so that data collected on population, economic, land use and air
and water quality can be used and transferred among planning agencies, is
one example of a joint effort and one which is enthusiastically promoted
by the State.
-26-
-------
In addition, designated areawide agencies are encouraged to estab-
lish any other formal and/or informal agreements and work arrangements that
are necessary in developing adequate and efficient communication channels
with agencies involved in related work tasks.
3. Representation on Advisory Committees (Stages 2,3)
Designated areawide agencies should include representatives of the
planning agencies responsible for related programs on their policy and/or
technical advisory committees. A suggested list would include public
works directors and planning agency representatives from county and local
jurisdictions, representatives from the State planning office and environ-
mental and/or public health agency and representatives from appropriate
Federal agencies such as Soil Conservation Services and district Army
Corps of Engineers.
4. Reporting Systems (Stages 2,3)
Designated areawide agencies should set up some type of review
and comment system whereby their reports and findings could be circulated
to appropriate agencies and other interested persons for feedback.
-27-
-------
The policy advisory committee should be a
mechanism for coordinating the work of all agencies — local, State
and Federal — engaged in water quality planning and management. It
should also provide the means for coordinating water quality planning
with other related programs, including other environmental programs
being conducted in the area.
Each committee shall include representatives of
chief elected officials of local units of government and representatives
of the State. The Departments of Agriculture, Interior and the Army
(Corps of Engineers) should be invited to participate, under terms of
a standing interagency agreement between EPA and these departments.
(Federal Register, Vol. 38, No. 225, November 23, 1973). Additional
Federal Agencies may be included where it is deemed appropriate. Of
no less importance is the general requirement that representatives
of the general public be named to each advisory committee.
The State is responsible for providing a list of
proposed representatives on each policy advisory committee for State
planning areas in the continuing planning process description submitted
to the Regional EPA Administrator for approval. Such lists will usually
be prepared in consultation with areawide planning agencies and other
local, State, and Federal agencies.
Particular procedures for setting up an advisory
committee are left to the direction of the State water quality plan-
ning agency. Additional criteria for membership may be established.
A formula may be developed for cross-representation between different
areawide advisory committees to permit greater sharing of experience.
Similarly, details of how advisory committees
will function are left to the discretion of the State or, in turn,
to designated areawide agencies and individual committees themselves.
As committees are advisory in nature, areawide planning agencies may
or may not concur with their recommendations. In anticipation of
such occurrences, formal procedures should be set up requiring that
both committee recommendations and agency responses be formally stated
and explained.
In addition to the required policy advisory
committee, other committees may be established either by the State or
the designated areawide agency, or the required policy advisory committee
may be assigned additional responsibilities. A technical advisory
committee composed of planners and other technical personnel from local
units of government may be useful at the area level. In fact, several
technical advisory committees may be set up to study and make recommenda-
tions on specific problems or areas of concern. Areas for study may
include restructuring of user charges, industrial pretreatment standards
or alternative land use management methods.
-28-
-------
4. Review and Certification
a. Review and Certification of Work Plans
Designated areawide planning agencies which have
been awarded EPA planning grants after June 30, 1975, have up to 12
months in which to complete their work plans, beginning from the date
of their designation. The period of time needed for the development
of the work plan and the preparation of the water quality management
plan cannot extend beyond November 1, 1978, the date by which all
water quality management plans are to be completed. During that period
devoted to organization for water quality management planning, they
will prepare drafts for work plan elements, which include the following:
• Description of work performed to date.
• Description of proposed planning process.
• Description of work to be done by other
agencies, with formal agency agreements, as
necessary.
9 Schedule of inter-relationships between
work elements, and projected dates for .
completion.
• Budget showing costs and resources.
• Disbursement schedule, with payments related
to milestones.
The work plan may be regarded as a milestone, in
which case brief progress reports may be required during the period of
its development, with draft work plan elements to be discussed. Copies
will go to the State planning agency, which shall expeditiously review
the report and submit its comments to the designated areawide planning
agency and the EPA Regional Administrator.
Having previously certified the designated areawide
agency's work plan outline — at the time it certified the agency's
original grant application — the State will review work plan elements
to determine if they are sufficient to assure that areawide efforts
will comply with Statewide water quality planning requirements, will
accomplish the required areawide planning, and will not duplicate other
planning activities.
The State is responsible for assuring that all
planning area work plans are consistent with the State water quality
management planning program, and particularly with the continuing
planning process and the State/EPA Agreement on level of detail and
timing, which is part of the continuing planning process.
-29-
-------
The North Central Council of Governments recently submitted to the
State and EPA Regional Administrator its work plan element for preparing
and executing the institutions/management analysis of agencies responsible
for the operation and/or maintenance of wastewater and stormwater collection
and treatment facilities. After reviewing the designated areawide agency's
work plan on this particular element, the State Department of Environmental
Regulation found certain inadequacies in the work design to carry out the
analysis. These are outlined in the following letter:
Mr. Fletcher MacDonald
Project Director, WQM Planning
North Central Council of Governments
Dear Mac:
First of all, let me commend you and your staff for moving
ahead so quickly in the development of the WQM work plan.
After circulating the institutions/management analysis element,
I received mostly favorable comments. The list of critical factors
for determining an agency's ability or inability to function within
the WQM structure is very comprehensive, and I am passing it along
to the other designated agencies in my group of supervision for
their benefit.
Criticism of the element mainly focused on the absence of any
methodology explaining how data will be collected for the analysis.
I am sure both you and your staff realize that an exhaustive in-
stitutional analysis of each agency involved in wastewater/storm-
water collection and treatment is not possible, especially under
the operating time constraints. Therefore, you should develop
criteria to serve as a screening mechanism that will separate
those agencies requiring only a preliminary investigation from
those warranting an in-depth study.
Secondly, you should provide a preliminary list of what in-
formation you will need to collect in order to make an adequate
assessment of each agency's legal, institutional, financial and
performance capabilities. This list may include:
agency responsibilities
legal basis of agency formulation
institutional structure
performance in service delivery and maintenance activities
financial capability—current and project expenditures,
sources of funding, revenues generated, operating cost
rate structures and how they are calculated
potentials for change in functions and activities—expansion
and reduction of authority
special programs—past and present
-30-
-------
Finally, a description of methods for collecting data and
criteria for testing these methods also should be included.
I hope you find these comments constructive as you proceed in
revising your work plan elements.
Sincerely,
Dave Flack
WQM Coordinator for the
Central COGs Group
-31-
-------
The State may, if it chooses, refer to approved
planning area work plans to satisfy the requirement for a State/EPA
Agreement dealing with designated areas. The Agreement is, in effect,
a work program for State water quality management planning. In this
case, the State will take precautions to assure that all designated
area and State planning area work plans are comparable in format and
terms.
When State comments and recommendations have been
considered and work plan revisions made, as appropriate, the work
plan is reviewed by the Regional Administrator. It should be empha-
sized that the plan be submitted to the Regional Administrator after
all problems have been worked out between the State and designated
agencies, in order to expedite plan approval. EPA may require further
modifications by the designated agency before approving the work plan.
This approval is a precondition to the -release of grant funds for further
areawide planning. (Prior to approval, generally no more than five
percent [5%] of the planning grant funds can be released — earmarked
for work plan development.)
b. Review of Progress — Milestones and Interim Reports
The State, as well as the Regional EPA Administrator,
will monitor areawide planning on a continuing basis. Prior to the
completion of specified planning products or outputs, progress will
be measured by milestones — i.e., points along the road that should
be reached at various intervals.
Milestones are set in the designated agency's
approved work plan. Functional activities required to develop the
areawide water quality management plan are identified. Sequence
and timing of tasks — i.e., staffing, data collection and processing,
preliminary analysis, goal setting, etc. — are determined for each
planning activity. Required interrelationships between different
activities are described, and work is scheduled accordingly.
The designated areawide planning agency is required
to submit interim progress reports, generally on a quarterly basis be-
ginning on the effective date of the agency's grant. These brief reports
addressing the milestones in the work plan are submitted within 30 days
following the end of each quarter, unless the Regional EPA Administrator
has determined that semi-annual reports will suffice.
Interim reports are submitted to EPA, with copies
to the State planning agency. The State should review each report and
submit comments to EPA in an expeditious manner.
To keep abreast of planning and, when appropriate,
to assist designated planning agencies to resolve problems and overcome
difficulties, the State may also develop other reporting and consulting
procedures. (See Section l.b.)
-32-
-------
MEMORANDUM
TO: George Ripley, Director, CENCOG
FROM: John Blakely, Director, Department of Natural Resources
SUBJECT: Review of Fourth Quarter Progress Report, Central Council
of Governments
We have the following comments on the urban stormwater section of your
Fourth Quarter Interim Progress report:
We agree with your analysis of the urban stormwater problem. In particular
we have noted the relationship between the DO sag after rainfall and urban
stormwater runoff in the developed and the developing watersheds.
With reference to the proposed management measures, we would like to make
a number of points. First new legislation or revision of existing laws
at both the State and local levels may be appropriate. Specifically, the
State building code may require amendment to facilitate rooftop storage,
and your local sedimentation and erosion ordinance may need strengthening
to ensure that natural drainage patterns are maintained.. In addition,
performance standards relating to development features that affect con-
struction and urban stormwater runoff might be incorporated into your
Planned Unit Development zoning category.
Second there needs to be more examination of the following management
practices:
- buffer zones
- vegetative cover
temporary grassing of slopes
on-site sedimentation ponds
- street sweeping
- catch basin cleaning
Third, it is important to keep in mind that the effectiveness of these
management practices usually increases' when several are used in combin-
ation. Often each individual practice addresses a specific part of the
runoff problem, and a comprehensive approach to nonpoint source control
requires the application of a range of measures.
cc: Ralph Corning
Regional Administrator, EPA
-33-
-------
c. Review and Approval of Interim Outputs
Within the first nine months after a designated
planning process begins, an initial set of interim outputs are to be
completed. Among these are the outputs on which subsequent facilities
planning should be based — service areas, population and land use
analyses and projections, projected waste loads by service area, and
any suggested revision of waste load allocations. Additional interim
outputs needed to support further related areawide activities may also
be identified by the State planning agency or the designated areawide
agency.
The State is responsible for review and approval
of interim outputs, and for transmitting them to the Regional EPA
Administrator for concurrence. These outputs, as portions of the area-
wide water quality management plan, should be submitted to the Governor
for formal adoption and certification, and then to EPA for approval,
in the same manner as the final plan will be processed (See 4.d.,
following).
Further areawide planning may reveal that the
designated agency should modify certain previously submitted and
approved interim outputs. All such modifications should be promptly
brought to the attention of the State and affected facilities plan-
ning agencies. Modifications would then be reviewed, approved by the
State and transmitted to the Regional Administrator for concurrence,
just as were the original outputs.
Any recommendations from the designated areawide
planning agency for revision of water quality standards, maximum
allowable pollutants loads, waste load allocations, and terms for
NPDES permits must also be reviewed and approved by the State. (See
2.a., b., c., e.) .
In keeping with its broad responsibility for
coordination of water quality planning statewide, the State may
establish special procedures for review of some or all interim outputs.
The State will often find it beneficial to involve a variety of Federal,
State and sub-state agencies in the review process, by circulating
copies of interim outputs for comments, by convening special review
panels, or by other means.
It is a major responsibility of the State to
assure that the general public and interested public organizations
have been provided an opportunity to review and comment on interim
outputs.
-34-
-------
The State has prepared a set of questions and factors to be con-
sidered by the designated agencies in determining information that will
aid in the completion of interim outputs. The following refers to land
use analysis and projections.
Considerations for Land Use Interim Output
Are land use planning aspects for WQM consistent with land
use elements developed under the HUD-701 program? With
land use provisions of air quality maintenance planning,
transportation.planning, etc.?
Are land use plans compatible with local land use and growth
policies?
Are land use plans compatible with local and/or State pro-
grams for floodplain management?
Are land use and development regulations affecting waste-
water and land use impact data properly documented?
Are all geographic areas located in designated planning boun-
dary that affect or are affected by water quality included
in land use analysis?
Does the inventory include all significant land use cate-
gories as well as any others which considerably contribute
to pollution locally? ;
I
Have alternatives for areawide growth and development been
carefully and comprehensively analyzed in the determination
of land use projections?
Are land use projections consistent with interim output
population and employment projections?
Are land use plans compatible with the State's approved
Coastal Zone Management Plan (if applicable)?
Are land use scales and classification systems consistent
with each other? Are they consistent with other regional
plans?
Are land use scales and levels of detail adequate for identi-
fying location, volume and nature of wastewater flows?
Is level of detail adequate for displaying the relation of
wastewater flows to projected land uses?
-35-
-------
Has the land use plan been staged, indicated phased develop-
ment and have the public facilities that will be necessary
been programmed? In this connection, has a capital require-
ments program been accomplished and sources indicated.
What is the legal status of the land use plan? What actions
have local governments taken, if any? What is the status
of land use controls and practices?
Depending upon specific conditions and problems of individual
designated area, it may be necessary to include an inventory and/or
projection of any of the following factors:
Topography and soil conditions of the designated area;
Bodies of water and related lands that would be beneficially
or adversely affected by a change in water quality;
Water supply, treatment, and distribution systems;
Existing waste treatment and collection systems, including
interim facilities and major urban storm drainage facilities;
Solid waste disposal sites;
Areas presently served by septic tanks and the suitability
of other undeveloped areas for septic tanks at specified
densities;
Environmentally sensitive areas such as wetlands, aquifer
recharge areas, steep slopes, wildlife habitat.
Culturally sensitive areas such as historic sites, archeo-
logically significant areas, recreation (active and passive)
areas, performing arts location, museums, etc.
-36-
-------
d. Review of Final Areawide Plan
When completed, areawide water quality management
plans shall be submitted to the State for preliminary review and comment,
then modified, as appropriate, and resubmitted for final review and
adoption and certification by the Governor. The Governor in turn will
submit adopted plans to the Regional EPA Administrator for final approval.
Prior to its submission to the State, the areawide
plan must be publicized and comments and recommendations invited from
public interest organizations and the public at large. As a minimum,
public meetings or hearings will normally be scheduled at times and in
locations convenient to the public. (Public participation in, and review
of planning is required at earlier stages, as well.)
Preadoption Review: Prior to formal submission of
the areawide plan for the Governor's certification, it must be sent to
the Governor or his designee for review and recommendations, and at
the same time, to chief elected officials of local units of government
that have responsibility for implementing elements of the plan, or
are otherwise directly affected by the plan. The Governor should review
the plan.without delay and prepare comments, including possible objections.
Local government officials shall do the same within 30 days.
At this time, the State may also submit the plan
to the Regional EPA Administrator for his preliminary review and comment.
If this is done, EPA's response should be relayed to the areawide
planning agency.
Final State Review and Certification: After receiving
all comments and recommendations, the designated areawide planning
agency shall make any necessary modifications and submit the plan to the
Governor for final review and formal adoption and certification. Recom-
mendations from local units of government, whether favorable or unfavor-
able, are to be forwarded to the Governor at this time as well.
The Governor shall then review the plan, determining
whether or not it meets the following criteria:
• Conforms with provisions of the State planning
process, including existing State water quality
management plans, and will be accepted as a
detailed portion of the State plan;
• Is consistent with the water quality management
needs of the designated area;
• Conforms with all State and local legislation,
regulations, or other requirements or plans
regarding land use and protection of the
-37-
-------
environment (unless the plan calls for
changing such laws, regulations and require-
ments) ; and
• Provides for adequate management of water
quality programs.
The Governor will then certify that the plan
meets these criteria and has been adopted, or, if he determines that
the plan does not meet criteria, will either not certify the plan or
certify it on a conditional basis.
The Governor shall notify the Regional Administrator
of his action, specifying the revisions necessary to obtain approval
and full certification and the time period for the designated areawide
agency to prepare and submit such revisions.
EPA Review and Approval: The Governor shall submit
adopted areawide plans to the Regional Administrator for final approval.
Areawide plans shall be submitted no later than two years after the
designated agency's planning process began, and, in any case, no later
than November 1, 1978.
Within 120 days the Regional Administrator shall
either approve, disapprove or conditionally approve the plan. In the
event the plan is conditionally approved, the Regional Administrator
will specify what revisions are required, and in what time period, in
order for the plan to be approved. Approval of the plan is based on
its conformity with the requirements of the Act, Part 131 of EPA regula-
tions and the approved continuing planning process and is consistent
with contiguous water quality management plans including those of
neighboring states.
-38-
-------
IV. PARTICIPANTS IN THE AREAWIDE WATER QUALITY MANAGEMENT
PLANNING PROCESS, THEIR ROLES AND EXPERIENCES
A. Introduction
Water quality management under P.L. 92-500 and EPA regulations
calls for a complete set of institutional relationships among actors
who have had broad previous experience but who have not before been
closely interrelated — as they work toward the achievement of the goal
of clean water.
The U.S. Environmental Protection Agency, the State governments,
areawide councils of governments and regional planning agencies, as
well as local units of general government have all addressed the manage-
ment of water pollution. Nevertheless, there has been little previous
experience in which all levels of government have been tied together
as closely as they are and will be during the course of areawide water
quality management planning.
The purpose of this final section of this handbook is to
generally examine past experiences of the principle participants in
this major new water planning undertaking to better understand the
roles each has played and the roles each will be called upon to play.
B. Relationships with EPA Regional Offices
EPA Regional Offices have the ultimate responsibility for ensuring
that the. requirements of the Act and EPA regulations are met. Regional
Administrators must approve the areawide water quality management plans,
construction grants and permits necessary to implement those plans.
New areawide planning agencies have been and will be designated
at the same time that State pollution control agencies are reorienting
their planning programs, not only to deal with new areawide planning,
but to accomplish the planning themselves in those areas of the State
not covered by designated areawide planning agencies. These activities
are being accomplished in spite of a shortage of trained manpower
available to take on these new assignments at the Federal, State and
local areawide levels.
EPA regional offices will have assigned project officers to
each designated and funded areawide planning agency. States will,
in most cases, do the same. It is essential that the work of State
and EPA field representatives be carefully coordinated. Joint review
meetings can often be arranged and are desirable in the interests of
maintaining clear channels of communication and coordination.
-39-
-------
Both EPA and State coordination efforts have much in common.
Both are aimed at the assurance of high quality.management planning.
The State will look to consistency with State policy and past plan-
ning, particularly basin planning accomplished under the requirements
of 303(e) of the Act as well as facilities planning done under 201-
Step 1 regulations. EPA will be concerned that both the State and
the designated areawide agency conform to Federal law and regulations
issued under that law. Both the State and EPA can offer technical
assistance to the areawide water quality management planning agency.
In addition to policy advisory committees, there might be
developed structured workshops dealing with specific aspects of water
quality management planning. Either the State or EPA could play the
lead role. In some cases, it might be a joint effort. The important
thing is to conduct joint training efforts involving EPA, State and
local agency people to develop a higher capability and understanding
at the staff level. It would be useful if these sessions were to
involve all of the local designated areawide planning agencies in any
given State.
C. Established Practices of State Agencies
While there are no absolute norms, for the most part, State
water pollution control agencies have largely been regulatory agencies
with powers stemming historically from their earlier location in
state public health departments. As such, their relationships have
been with the regulation of individual pollutant dischargers.
Until quite recently (the last six months) State water pollution
control agencies accomplished such water quality planning as there
was — largely basin planning — and worked directly with individual
municipalities and sanitary districts on construction projects to meet
water quality standards. Under P.L. 92-500 many States were also
delegated responsibility for administering the NPDES discharge permit
system. This delegation, again, put them in direct contact with
individual dischargers of water pollutants.
As a result of this experience with construction and permitting
of individual point source dischargers, State staffs have been engineering-
oriented, addressing individual problems on a one-by-one basis. By and
large they have not faced the kind of political problems associated
with the development of areawide (intergovernmental) solutions to water
quality management, including areawide financing, land use planning
and regulation. In addition, of course, to these questions of building
areawide solutions, state water pollution control agencies must now add
nonpoint source analysis to their previously developed approaches to
water quality management.
-40-
-------
With regard to nonpoint source analysis and control, State
water pollution control agencies will have to develop expertise in
new areas and build new channels of communication with agencies they
have not usually worked with in the past. Under P.L. 92-500, the
decision of the U.S. District Court and the new 40 CFR 130-131
regulations issued by EPA on November 28, 1975, traditional engineering
approaches to point source management will not.be sufficient. The
dimensions of the overall water quality planning assignment have
broadened considerably — including political decision-making arrange-
ments at the local government (areawide) level, as well.
New legislative initiatives will be called for in many States.
The question then is how to build capability in these areas of vital
concern. Several states have found it valuable to draw upon the
Governor's Office of State Planning or its counterpart for expertise
on the overall State approach to areawide planning and local-intergovern-
mental political decision-making.
Working committees composed of State Water Pollution Control,
Air Pollution Control, State Planning and areawide water quality
management planning agencies can help to formulate and identify the
need for new legislative approaches and thereby expand the present
capabilities of State water pollution control agencies to deal with
these matters. These representatives are, of course, in addition to
those governmental and private sector special functions or interest
groups identified above.
D. The Role and Nature of Areawide Agencies
Almost all areawide planning agencies that are regional councils
which have been funded by the Department of Housing and Urban Development's
Planning Assistance Program (701) have met previously established HUD
requirements to develop a water and sewer element of their regional
general planning. The areawide water quality management planning
requirements under P.L. 92-500 are viewed by many State water pollution
control agencies as a wholly new program, and indeed the State-areawide
agency relationship is new. The fact remains, however, that locally
based regional planning agencies and councils of governments have
engaged in areawide water sewer planning before. In fact, some of them
were EPA funded under the old 3C program — pre-P.L. 92-500. These
local agencies were largely meeting HUD requirements and were not,
therefore, necessarily responsive to, or a part of, a State water quality
planning and decision-making mechanism.
The challenge now is to build upon previous areawide water planning
experience in meeting the broadened requirements of P.L. 92-500 and to
integrate this experience into a Statewide water quality management
planning program.
-41-
-------
E. Arrangements Between Local Governments
The real business of regional councils and councils of governments
is to facilitate the making of arrangements between local governments,
largely in response to Federal and State law and policy. Of the
initially designated and funded planning agencies, 117 out of 149, or
about 80 percent, are regional councils which were in existence prior
to being designated as areawide water quality management planning
agencies.
The continuing regional planning process involves monitoring
of the actions and evaluating results as against goals. This is part
of the continuous recycling of the planning process — with the
addition of new knowledge of conditions, technology and political
factors.
Recognition of the need for planning for management and for
improved institutional arrangements between units of local government
is illustrated, in a report entitled, "Water and Waste Management
Plan and Program", adopted and published in March, 1974, by the Com-
missioners of the Sacramento (California) Regional Area Planning
Commission (a Council of Governments representing six counties and
seventeen units of local general governments):
"Since the early development of the Sacremento
Regional Area, small water resource agencies have
been created to meet specific localized needs.
Local control and ease of administration have been
the principal reasons favoring the growth of such
agencies.
"Today, with over three hundred agencies involved
in the provision of water, sewer, and drainage
services, a reassessment appears in order. While
the majority of these agencies are providing
effective and efficient service, the concept of con-
solidation has much to offer. First, there are
the economies of scale that are available from combined
operation of water resource systems. These economies
include joint utilization of personnel and equipment
engaged in operation and maintenance functions.
Finally, consolidation can provide for coordinated
regional water resource planning on a scale not
previously realized.
"The recognition of alternative governmental organiza-
tions to provide water resource services is essential
to the long term implementation of the Regional Water
and Waste Management Plan. The Commission is currently
investigating alternative governmental forms as part
-42-
-------
of a contract with the State Water Resources Control
Board. The purpose of the project is to recommend
new governmental forms that could provide for more
effective and efficient use of water supply in the
SRAPC area."
In this instance, a State Water Resources Control Agency
(responsible for the implementation of P.L. 92-500) contracted with
a local consortium of governments through their regional planning
commission (all Commissioners are elected officials) to look at the
existing operating and decision-making structure providing water,
sewer and drainage services. Preliminary studies had indicated
there were some 300 agencies in these interrelated fields serving
the needs of the six counties and seventeen local general governments
in the region.
(NOTE: At the time of the report cited above, SRAPC
was not a designated areawide water quality manage-
ment planning agency but was cooperating with the
State Water Resources Control Board in their planning.)
F. Conclusion
The general problems outlined above really have a single
generic root: they all stem from the fact that a variety of new
actors, and a series of older actors are entering into the areawide
water quality management planning process under new rules.
There are differences in experience, background and loyalties.
There are techniques and policy approaches that will encourage all
participants to interact constructively and to work toward the clean
water goals in a mutually reinforcing manner. There must be a con-
scious effort at all levels, to discover and to apply these techniques
and approaches.
P.L. 92-500, and the required areawide water quality management
planning under that law, however, really adds a whole new dimension
to previous water planning. That new dimension is the requirement for
planning for areawide management that is explicitly spelled out.
Planning for management will necessitate close and understanding working
relationships between designated areawide water quality management
planning agencies and the local governments in the planning area, on
the one hand, and agencies of state government on the other hand.
Changes in institutional relationships for more effective pollution
control management are called for.
-43-
-------
APPENDIX
-------
-------
- 2 -
approved WQM plan or approved interim outputs produced by the WQM
planning process, the facility plan must contain the following
elements:
1. Description of the planning area.
2. Selection of service areas.
3. Selection of overall treatment systems, including location,
capacity and configuration of all facilities, treatment
levels, and preliminary identification of type of treatment
and method of disposal of residual wastes.
4. Analysis supporting the selections in 2 and 3 based on
identification, evaluation and cost-effective comparison
of alternatives.
5. Preliminary designs and studies related to the selected
wastewater treatment systems, including sewer evaluation
surveys, surface and subsurface investigations of sites
for proposed facilities, preliminary designs and detailed
cost-effectiveness assessment, and other requirements set
forth in Section 35.917-1 of the Title II regulations.
WQM Planning under Section 208
WQM planning sets forth a comprehensive management program for
collection and treatment of wastes and controlling pollution from all
point and non-point sources. Control measures for abating pollution
from these sources utilize a combination of traditional structural
measures together with land-use or land management practices and regu-
latory programs. These measures are implemented by a management agency
or agencies designated in the plan. An initial WQM plan is developed
over a prescribed planning period and, thereafter, updated and approved
annually.
POLICY: RELATIONSHIP BETWEEN 201 FACILITY PLANNING AND WQM PLANNING
I. THE RELATIONSHIPS BETWEEN 201 AND WQM PLANNING IN THE SAME
GEOGRAPHIC AREA DURING THE PERIOD BEFORE FINAL EPA APPROVAL OF
A WQM PLAN ARE AS FOLLOWS:
A. 201 Planning
All 201 plans underway and on current or subsequent approved
priority lists should proceed expeditiously through to completion,
State certification and approval by EPA. The scope of 201 planning
approved before the final WQM work plan is approved by EPA should
be at a level necessary to complete all required elements of the
facility plan. The scope of 201 planning approved after the final
WQM work plan is approved by EPA should be at a level necessary to
-------
- 3 -
supplement work assigned to and within the capability of the respon-
sible WQM planning agency to accomplish expeditiously so that a
complete facility plan can be provided with minimal delay.
The WQM planning agency's review of ongoing facility plans
will generally be handled in accordance with procedures for the
A-95 review process.
B. Minimum Requirements for Facility Planning by WQM
Planning Agencies
During the initial planning period/ WQM planning agencies
must produce the interim outputs specified in Program Guidance
Memorandum AM-2; generally, for designated areawide agencies,
these interim outputs will be completed within 9 months of the
date upon which the planning process becomes operational as
selected by the Regional Administrator. States conducting the
planning in non-designated areas may elect to place a lower
priority on facilities planning outputs, and, with the approval
of the Regional Administrator, may provide alternative schedules
to satisfy this interim output requirement.
For those municipal facilities within the WQM planning area
expected to receive a construction grant award during the five
years following initial WQM plan approval, the initial WQM plan
will include the facility planning information listed below. In
most cases, 201-funded facilities planning is either ongoing or
scheduled in the near term to support facilities construction over
the next several years. Thus, WQM planning agencies are expected
during this period to utilize and incorporate (not duplicate) the
201-funded planning information, supplementing the 201-funded or
programmed activities whenever deemed necessary by the Regional
Administrator.
Minimum requirements for facility planning to be summarized in
initial WQM plans for any facilities expected to receive a construc-
tion grant award during the five years following initial WQM plan
approval:
1. Selection of service areas
2. Preliminary estimate of municipal wastewater flows to be
generated during a 20 year planning period based on economic
and population projections for the WQM planning area.
3. Preliminary identification and comparison of the cost of
alternative treatment systems needed to handle projected
municipal wastewater flows, and to meet the requirements of
BPWTT or any more stringent discharge limitation necessitated
under the Act. Cost estimates may be based on streamlined
cost-estimating systems such as those prepared by Bechtel,
Black and Veatch, and ICARUS.
-------
- 4 -
4. Preliminary comparison of the cost of alternative general
configurations for needed wastewater collection at the
trunk line level.
5. Overall summary of environmental impacts of alternative
treatment and wastewater collection configurations.
6. Preliminary determinations, based on the above analysis,
of which municipal treatment systems and conveyance
configurations are likely to be most cost-effective.
7. Estimate of the land area required and possible financial
arrangements which could be utilized to construct these
facilities.
The terms "preliminary", "summary" and "estimate" in this
description are used to emphasize that the WQM plan will satisfy
these requirements by brief, general analysis and conclusions which
are much shorter and less detailed than those in a facility plan.
As such, these conclusions may be modified as a result of 201-funded
facility planning conducted in accordance with policies and procedures
described in Section II (see p. 5).
WQM planning agencies are also required to meet statutory require-
ments which are normally not considered a part of the facility planning
process but which, after approval of the WQM plan, will affect facility
planning. Such requirements include establishment of priorities and
time schedules for completion of treatment works, estimation of municipal
waste treatment system needs, identification of agencies necessary to
construct, operate and maintain treatment works, and establishment of a
regulatory program that can affect facilities in the area (example -
stormwater or pretreatment controls).
C. Detailed Facility Planning in WQM planning Work Plans
New WQM planning work plans shall not be approved by the
Regional Administrator when they provide for detailed facility
planning beyond the minimum requirements in section B, above.
This detailed facility planning shall be handled by existing and
subsequent 201 facility planning grants.
Existing approved work plans for FY 74 and 75 designated 208
areawide agencies which provide for facility planning beyond the
minimum requirements should be amended to eliminate such detailed
planning, except where designated WQM planning agencies have already
contracted to conduct detailed facility planning and the contractor
has started the work and is too far along for the contract to be
revised or terminated as determined by the Regional Administrator.
If work plans are revised to eliminate detailed facility planning,
Section 201 planning grants should be quickly provided in these areas
in accordance with paragraph A above.
-------
- 5 -
D. Interim 208 Outputs
After interim outputs (AM-2) are approved by the State and
EPA for a WQM planning area, the relationship between 201 and WQM
planning in that area will be the same as described above except
that planning under any 201 grant awarded after the approval of
the interim outputs must be consistent with these interim WQM
outputs. The scope and funding of new 201 planning should not
extend to developing a justification for the interim outputs,
as this will have been produced by the WQM planning process.
E. Coordination Between Concurrent 201 and WQM Planning
All WQM planning must be coordinated with facility planning
and other construction grant activity so that the final WQM plan
will facilitate needed construction in the area. Each State,
working with the Regional office must assure that effective coor-
dination between concurrent 201 and WQM planning does occur, and
that relationships between the two planning efforts are consistent
with this policy statement. The procedures for securing agreement
on relationships and responsibilities between concurrent 201 and
WQM planning efforts are at the discretion of the State. Conflicts
in approaches between concurrent 201 and WQM planning should be
resolved between the 201 and WQM planning agencies and concerned
State and local officials.
F. Transition to New WQM Requirements Affecting Facility
Planning'
Any WQM plan which proposes a significant change in either
management or approach affecting construction grant awards must
allow adequate time and establish detailed procedures for transi-
tion to the new approach or management once the WQM plan is approved
by EPA.
II. THE FOLLOWING SPECIFIES THE RELATIONSHIPS BETWEEN 201 AND WQM
PLANNING AFTER THE WQM PLAN HAS BEEN COMPLETED, AND THE MANAGEMENT
AGENCY OR AGENCIES IDENTIFIED BY THE PLAN ARE APPROVED BY THE STATE
AND EPA.
A. Facility Plans Underway
All facility plans underway at the time of approval will be
completed by the agency which received the Step 1 grant. The
planning effort will continue expeditiously through to State
certification and EPA approval unless the approved WQM plan
clearly justifies a change in required treatment levels or alter-
native approach on the basis of substantially lower costs or major
changes in projected environmental impacts.
-------
- 6 -
B. New Facility Plans; Role of Designated Management
Agency(s)
New grants for 201 plans will be made to the management
agency(s) designated in the approved WQM plan. New facility
planning will be consistent with the approved WQM plan.
Hie scope and funding of new facility planning starts
should be sufficient to supplement the data and analysis in
the WQM plan to the extent necessary to provide a complete
facility plan as required by Section 35.917 of the Title II
regulations.
Where future 201 planning results in recommended projects
not in general conformance with the recommendations of an
approved WQM plan, review of the proposed change must be made
by the designated agency responsible for operating the continuing
WQM planning process. If the proposed change is accepted by the
WQM planning agency, the WQM plan is to be revised. (Revisions
will then proceed through the normal State certification and EPA
approval process.) If the proposed change is unacceptable, the
approved WQM plan is controlling.
Review of WDM Plans
Regional municipal construction grants personnel should review
sections of the work plans for WQM planning and draft WQM plans
focusing on facility planning elements to assure coordination between
WQM planning and the municipal facilities grant program consistent
with this guidance. State construction grants personnel should be
encouraged to do the same.
<3PO 907-208
------- |