RELATIONSHIP OF LEVEL B PLANNING
AND WATER QUALITY MANAGEMENT PLANNING
U.S. ENVIRONMENTAL PROTECTION AGENCY
WATER PLANNING DIVISION
WASHINGTON, D.C. 20460
NOVEMBER 1976
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EPA REVIEW NOTICE
This report has been reviewed by the Environmental
Protection Agency and approved for publication.
Approval does not signify that the contents, conclusions
or reconuendations of the report necessarily reflect
the views and policies of the Environmental Protection
Agency, nor does mention of trademarks or commercial
products constitute endorsement or recommendation for
use.
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RELATIONSHIP
OF
LEVEL B PLANNING PROCESSES AND PLANS
TO
WATER QUALITY MANAGEMENT PLANNING
WATER PLANNING DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY
Contract No. 68-01-1961
George Fleming, Project Officer
September 1976
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TECHNICAL REPORT DATA
(Please read Jp tsu tiong on the reverse before completing)
1. REPORT NO. 2.
3. RECIPIENTS ACCESSIOPNO.
4. TITLE AND SUBTITLE
RELATIONSHIP OF LEVEL B PLANNING PROCESSES AND Pr. ANs
TO WATER QUALITY MANAGEMENT PLANNING
5. REPORT DATE
September 1976, date submitted
6. PERFORMING ORGAt .LIZATION CODE
7. AUTHOR(S)
Banks, H.O; N.J. Owen; N.E. Schwarz Wendell Associates
I. PERFORMING ORGANIZATION REPORT NO.
. PERFORMING ORGANIZATION NAME AND ADDRESS
Harvey 0. Banks, Consulting Engineer, Inc.
#3 Kittie Lane
Belmont, CA 94002
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68—01—1961
12. SPONSORING AGENCY NAME AND ADDRESS
Water Planning Division
U.S. Environmental Protection Agency
401 M Street Washington, DC 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
lb. Ab I MACI
The study reported was commissioned by the Environmental Protection Agency (EPA)
to identify and improve relationships between planning conducted pursuant to Sec-
tions 208 and 209 (Level B) of PL 92—500. Case studies were conducted in the Central
Snake Basin, Idaho, and Monongahela River Basin Pennsylvania, West Virginia and Mary-
land, where both Level B and 208 programs are underway. The case studies revealed
neither program effectively used information developed in the other. Level B plans
were found to have special value in interstate aspects of water quality; in assessipg
effects on quality of projected water uses; and of basinwide water resource manage-
ment measures. Level B and 208 planners must understand the relationship of the two
planning processes. The WRC and the EPA must require full consideration of the other’
planning prograxqs. The report recommends that the WRC promulgate regulations ex-
plicitly identifying water quality management elements in Level B plans; modify pre-
sent constraints on Level B planning to allow collection of new data where necessary
to give adequate consideration to quality; and increase efforts to resolve interstate
problems. The report recommends that the EPA modify regulations for 208 planning to
require consideration of Level B plans and inclusion of personnel with water resource
planning expertise on 208 planning staffs. Both EPA and WRC should assure full under-
standing in. planning of the interdependences of water quality management with other
asnects of water and rel - d
- - — L b UL m n g m nr
7. KEY WORDS AND DOCUMENT ANALYSIS
I. DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
C. COSATI Field/Group
Planning
Regional planning
River basin
River basin development
Water quality
Water resource
Planning
Regional planning
Water quality management
River basin development
)50l Administra-
tion and
management
.
.302 Civil Engi-
neering
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Reporitf
21. No. OF PAGES
163
20. SECURITY CLASS (Thi. ,page)
22. PRICE
EPA Form 2220-1 p.73)
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TABLE OF CONTENTS
Page
PREFACE .
CHAPTER 1 - INTRODUCTION 1-1
Purpose and Scope of Study 1-6
Conduct of the Study 1—7
References Chapter 1 1—10
CHAPTER 2 - CONCLUSIONS AND RECOMMENDATIONS 2-1
conclusions 2—2
General 2—2
Central Snake Case Study 2-3
Monongahela Case Study 2-4
Level B Planning 2—5
Water Quality Management Planning 2—7
Summary Conclusions 2—7
ReconmiendationS 2—11
Central Snake Case Study 2—11
Monongahela River Basin 2-12
Water Resources Council 2—13
Environmental Protection Agency 2-15
General 2—15
CHAPTER 3 - WATER QUALITY MANAGEMENT/LEVEL B
3-1
Water Quality Management Planning 3—1
Background 3—1
Planning Objectives
Plan Content
Coordination with Other Planning Programs 3—7
Use of Level B Plans 3—13
Implementation 3-15
Plan content Requirements 3—15
Regional or River Basin Planning, Level B 3-16
Legislative History of Sec. 209, PL 92—500 3- 16
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TABLE OF CONTENTS (cont ‘d)
Page
Level B Planning Process and Plans 3-19
Comparison of Water Quality Management Planning
and Level B Planning Programs 3-27
Entities Involved 3-28
Planning and Implementation Processe 3-31
Types and Detail of Study Products 3-33
Urban Studies Program, Corps of Engineers 3-34
State, Regional and Local Water Plans 3-36
Literature I eview 3-36
References Chapter 3 3-38
CHAPTER 4 - CASE STUDIES 4-1
Central Snake River Basin 4—3
overview 4-3
Description of the Case Study Area 4-3
Description of the Central Snake Level B Study 4-6
Description of Water Quality Management Planning
Programs 4-10
Interpretations of Interrelationships Between the
State’s Continuing PLanning Process, Level B and
Urban Studies Planning Programs 4-15
Coordination Arrangements 4-22
Level B Inputs to Water Quality Management Planning 4-23
Implementation of Plans 4-24
Monongahela River Basin 4-25
Level B Plan 4-27
SillilnarY
Pittsburgh 208 Area Planning 4-40
Pennsylvania - Water Quality Management Planning 4-43
Pennsylvania - State Water Plan (SWP) 4-47
West Virginia 4-50
Environmental Protection Agency, Region III 4-52
Other Agency Staff Comments 4-53
References Chapter 4
CHAPTER 5 - PLAN INTERRELATIONSHIPS .5-1
Data Base
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TABLE OF CONTENTS (cont’d)
Page
Air Quality 53
Water Quality Standards 5-3
Demographic and Economic Projections 5-4
Land Use
Hydrologic and Hydraulic Effects 5-4
Water Rights 5—6
Social Impacts 5—7
Energy Impacts 5-7
Planning Under Uncertainty 5-8
summary 5—8
APPENDIX A - DESCRIPTION OF POTENTIAL CASE STUDIES A-i
Yakima River Basin A—2
Hawaii (statewide) A—2
Maumee River Basin A2
Minneapolis-St Paul (Lower Minnesota and Upper Mississippi
Rivers A3
Central Snake River Basin.. ..
Monongahela River Basin A4
summary A—4
APPENDIX B - COMPARISON OF PLANNING REGULATIONS AND GUIDELINES B-i
LIST OF TABLES
1. COMPARISON OF WATER QUALITY MANAGEMENT PLAN CONTENTS
REQUIRED UNDER 40 CFR 131 WITH POSSIBLE OUTPUT OF
LEVEL B STUDY 3-8
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PREFACE
Sections 208 and 303(e) of the Federal Water Pollution Control Act
Amendments of 1972 (Public Law 92—500), and the implementing regulations
(40 CFR Parts 330 and 131) mandate areawide and statewide approaches to
water quality management planning. Plans prepared pursuant to these man-
dates are to emphasize implementation of waste treatment works and regu-
latory and control programs to attain the specific statutory objectives.
The nationwide coverage of the Sec. 208 program, its broad consideration
of both point and nonpoint sources of pollution, and the emphasis on
implementation make it one of the most important sections of PL 92-500.
Full realization of the objectives of Sec. 208 and other water quality
management programs requires comprehensive consideration of related pro-
grams for water and land resource management to assure complementaritY
of objectives as well as efficiency in planning and implementation. Fed-
eral and federally assisted planning programs dealing with water and re-
lated land resource development, use and management are coordinated through
the U.S. Water Resources Council (WRC) of which the u.s. Environmental
Protection Agency (EPA) is a member (Public Law 89-80, as amended). Plan-
ninq carried out under the Council’s aegis includes regional or river basin
planning (Level B). The potential interrelationships between Level B plan-
ning and areawide and statewide water quality management planning have not
been adequately defined previously. Exposition of the more significant
of these interrelationships is one of the objectives of this report.
This report describes results of a study commissioned by EPA to
identify and describe relationships which should exist between Level B
and water quality management planning processes and plans. it addresses
the divergencies presently existing between the programs and how the two
planning efforts could be made more mutually supportive and useful to
one another. The study, conducted by Harvey 0. Banks, Consulting Engineer,
Inc., (Contract 68—01—1961), was initiated on January 15, 1976. Joint
EPA—WRC management of the study was provided by a Project Advisory Committee.
Other members of the study team were: H. James Owen, Mitchell Wendell, and
Harry E. Schwarz.
Field investigations were conducted of two case study areas involving
both Level B planning and areawide water quality management planning, the
Central Snake River Basin in Idaho and Monongahela River Basin which in-
cludes parts of Pennsylvania, West Virginia and Maryland. These areas
were approved by the Project Advisory Committee and EPA Project Officer
on recommendation by the Contractor.
Staff members of federal, state and local agencies in each case
study area providing special assistance for the case studies include the
following:
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Central Snake Case Study Area
Lawrence V. Armacost, chief, Basin and Urban Studies Section,
Wa].la Walla District, Corps of Engineers;
Lynn McKee, Idaho Operations Office, U.S. Environmental Pro-
tection Agency;
E.J. Gullidge, Planning Director, Pacific Northwest River
Basins commission;
Warren Reynolds, State Study Team Leader, Idaho Department
of Water Resources;
Donel Lane, chairman, Pacific Northwest River Basins Commission;
Henry Stuart, Assistant Study Manager, Pacific Northwest River
Basins Commission;
C. Stephen Alired, Administrator,Planning Division, Idaho
Department of Water Resources;
James Runsvold, Water Quality Bureau, Idaho Department of
Health and Welfare;
Robert F. Minter, 208 Program Manager, Ada/Canyon Areawide
Waste Treatment Management Committee;
Peter Gowen, Environmental Planner, Ada/Canyon Areawide Waste
Treatment Management Committee;
David Fortier, Engineer, Ada/Canyon Areawide Waste Treatment
Management Committee;
Robert Wise, thief, Bureau of Planning, Division of Budget,
Policy Planning and Coordination, Office of the Governor,
Idaho.
Monongahe].a Case Study Area
Claude A. Rays, Executive Director, Ohio River Basin Com-
mission;
Stephen Thrasher, Assistant Director, Planning, Ohio River
Basin Commission;
George White, Director, Monongahela Level B Study, Ohio River
Basin CommIssion;
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E. Anthony Joering, Director, Ohio River Main Stem Level B
Study, Ohio River Basin Commission;
Leo Weaver, Executive Director, Ohio River Valley Water Sani-
tation Commission;
Charles R. Ownbey, Ohio River Basin Coordinator, Environmental
Protection Agency;
Edward V. Geismar, Basin Commission Coordinator, Environmental
Protection Agency, Region III;
Dale Wismer, Water Programs, Environmental Protection Agency,
Region III;
Robert A. LaMacchia, Administrator, 208/COWAMP Progra!n South-
western Pennsylvania Regional Planning Commission;
James DeAnglis, Chief, Advance Planning, Southwestern Pennsyl—
vani.a Regional Planning Commission;
Walter Lyon, chief, Bureau of Water Quality Management,Depart-
ment of Environmental Resources, State of Pennsylvania;
Richard H. Boardman, Chief, Division of Water Quality, Bureau
of Water Quality Management, Department of Environmental
Resources, State of Pennsylvania;
William M. Frazier, Bureau of Resources Programming, Department
of Environmental Resources, State of Pennsylvania;
John E. McSparran, Bureau of Resources Programming, Department
of Environmental Resources, State of Pennsylvania;
Teh Shee Lee, Bureau of Resources Programming, Department of
Environmental Resources, State of Pennsylvania;
Dr. Brooks F. McCabe, Jr., Research Analyst and Assistant
for Planning, Office of Federal—State Relations, Resource
Development Support Division, Office of the Governor, State
of West Virginia;
James Lloyd Harris, Environmental Specialist, Office of Federal—
State Relations, Resource Development Support Division, Of fic
of the Governor, State of West Virginia;
Edward Y. Long, Land Use Specialist, Office of Federal—State
Relations, Resource Development Support Division, Office of
the Governor, State of West Virginia;
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Earl P. Bisher, Chief, Planning Branch, Division of Water Re-
sources, Department of Natural Resources, State of West Virginia;
James Adkins, Planner 1, Water Resource Planning, Division of
Water Resources, Department of Natural Resources, State of
West Virginia;
Col. Janairo, District Engineer, Pittsburgh District, Corps
of Engineers, United States Army;
James Purdy, Chief, Environmental Planning Section, Pittsburgh
District, Corps of Engineers, United States Army;
Michael Koryak, Hydrology Branch, Pittsburgh District, Corps
of Engineers, United States Army;
James Mershimer, Urban Studies Unit, Pittsburgh District,
Corps of Engineers, United States Army;
F. De? rio, Formulation Section, Pittsburgh District, Corps
of Engineers, United States Army.
The assistance given by these individuals and numerous others is
greatly appreciated.
Mr. George Fleming was Project Officer for the U.S. Environmental
Protection Agency. Mr. Albert Erickson, U.S. Environmental Protection
Agency, and Mr. Wayne Haas, U.S. Water Resources Council, served as members
of the Project Advisory Committee. Their efforts in furnishing information
and assistance were extremely helpful and are deeply appreciated.
iv
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CHAPTER 1
INTRODUCTION
The Nation’s extensive surface and underground water resource con-
stitutes one of its major economic and environmental assets. Management
of this resource for multiple purposes is an important activIty at all
governmental levels and in the private sector. The Water Resources
Planning Act of 1965, Public Law 89—80, established the U.S. Water Re-
sources Council (WRC) to encourage the conservation, development and
utilization of the Nationts water and related land resources on a compre-
hensive basis through coordinated planning by the Federal Government,
States, local governments and private enterprise. among its other
duties, WRC is directed to:
Maintain a continuing study of the relation of regional
or river basin plans and- programs to the requirements of
larger regions of the Nation and of the adequacy of ad-
ministrative and statutory means for the coordination of
the water and related land resources policies and programs
of the several Federal agencies; it shall appraise the
adequacy of existing and proposed policies and programs
to meet such requirements; and it shall make recommendations
to the President with respect to Federal policies and pro-
grams [ 1, Sec. l02(b)J.
The Water Resources Planning Act provided for formation of river basin
commissions. These commissions are directed to [ 1, Sec. 201(b)]:
(1) serve as the principal agency for the coordination
of Federal, State, interstate, local and nongovernmental
plans for the development of water and related land re-
sources in its area, river basin, or group of river basins;
(2) prepare and keep up to date, to the extent practicable,
a comprehensive, coordinated, joint plan for Federal, State,
interstate, local and nongovernmental development of water
and related resources: provided, that the plan shall include
an evaluation of all reasonable alternative means of achiev-
ing optimum development of water and related land resources
of the basin or basins, and it may be prepared in stages,
including recoimnendations with respect to individual pro-
jects;
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(3) recommend long-range schedules of priorities for the
collection and analysis of basic data and for the investi-
gations, planning, and construction of projects; and
(4) foster and undertake such studies of water and related
land resources problems in its area, river basin; or group
of river basins as are necessary in the preparation of the
plan described in clause (2) of this subsection.
Six river basin commissions are presently organized and operating:
New England River Basins Commissions;
Ohio River Basin Commission;
Great Lakes Basin Commission;
Upper Mississippi River Basin Commission;
Missouri River Basin Commission;
Pacific Northwest River Basin Commission.
In an effort to organize the large number of planning efforts under-
way, WRC has specificed three levels of planning (2) including:
Level A: Framework Studies and Assessments;
Level B: Regional or River Basin Plans; and
Level C. Implementation Studies.
Definitions of these levels of study are provided by W1 ’s Principles
and Standards for Planning Water and Related Land Resources (3) promul-
gated pursuant to Section 103 of the Water Resources Planning Act (1).
Section I.C. of the Standards states:
Framework studies and assessments are the evaluation or
appraisal on a broad basis of the needs and desires of
people for the conservation, development and utilization
of water and land resources and will identify regions or
basins with complex problems which require more detailed
investigations arid analysis and may recommend specific
implementation plans and programs in areas not requiring
further study. They will consider Federal, State, and
local means and will ecinsider both national economic
development and environmental quality objectives.
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Regional or river basin plans are reconnaissance—level
evaluation of water and land resources for a selected
area. They are prepared to resolve complex long—range
problems identified by framework studies and assess—
rnents and will vary widely in scope and detail; will
involve Federal, State, and local interests in plan
formulation; and will identify and recommend action
plans and programs to be pursued by individual Federal,
State, and local entities. They will consider both
national economic development and environmental qual-
ity objectives.
Implementation studies are program or project feasibility
studies generally undertaken by a single Federal, State
or local entity for th purpose of authorization or develop-
ment of plan implementation. These studies are conducted
to implement findings, conclusions, and recommendations
of framework studies and assessments and regional or river
basin studies which are found to be needed in the next
10 to 15 years. As with framework studies and regional
or river basin plans, they will consider both national
economic development and environmental quality objectives.
At the present time, Level A studies have been completed or are
approaching completion for most areas of the Nation. Numerous Level C
studies are underway by the U.S. Army Corps of Engineers (USCE), Bureau
of Reclamation (USBR), Soil Conservation (SCS) and other agencies.
Section 209 of Public Law 92—500 states (4):
(a) The President, acting through the Water Resources
Council, shall, as soon as practicable, prepare a Level
B plan under the Water Resources Planning Act for ll
basins in the United States. All such plans shall be
completed not later than January 1, 1980, except that
priority in the preparation of such plans shall be given
to those basins and portions thereof which are within
areas designated under paragraph (2), and (4) of sub-
section (a) of section 208 of this Act.
(b) The President, acting through the Water Resources
Council, shall report annually to Congress on progress
being made in carrying out this section. The first
such report shall be submitted not later than January
31, 1973.
(c) There is authorized to be appropriated to carry out
this section not to exceed $200,000,000.
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Congress clearly intended that Level B planning processes and plans
complement water quality management planning.
Level B studies are designed to result in reconnaissance level plans
for water and related land resources of selected regions or river basins.
They are to resolve complex near-term and mid—term problems identified in
Level A (or their precursor Type 1) studies. Level B studies generally
are directed toward solving problems requiring an interdisciplinary
approach. The complexity of such problems may require additional planning
for final solution. The Water Resources Council has defined a “New Approach”
to Level B planning (5) emphasizing strong central management and centralized
funding of studies, limitation of studies to two years, and use of
judgmental planning. Proposed Guidelines for Level B planning using
the “New Approach” have been prepared for field evaluation (6).
A Level B study is intended by WRC to provide an important step in
an orderly sequence of water and related land resources planning and
management activities for a particular region or river basin. As multi—
agency planning efforts, Level B studies are designed to provide a forum
for the incorporation and reconciliation of plans and objectives related
to specific functions and specific areas.
WRC proposed Guidelines state the intended relationship of Level B
studies to other studies (6, II.C.):
Level B planning is a means to resolve critical near
term (next 5 years) mid-term (15-25 years) issues and
problems identified primarily in Level A studies. This
requires integration of problems associated with water
quality, water supply, flood damage reduction, and other
relevant water and related land resource programs, as
well as institutional coordination at all governmental
and private levels. The process requires the structuring
of alternative strategies as an aid to decision—makers in
arriving at agreement on implementation. Whenever prac-
tical, Level B planning precedes project-type planning
(Level C) and major cormnitment of substantial funds for
program implementation.
Level B studies help place water and land resources needs
and problems into proper perspective and provide a basis
for the orderly development of coordinated implementation
plans for resource conservation, preservation, management
and development. The Level B planning process identifies
the various contributions to national economic developnent
(NED) and environmental quality (EQ) objectives. It also
provides decision—makers with alternative plans supported
by information on tradeoffs and choices in areas where
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significant conflicts in use and management of natural
resources exist. Thus, management strategies integrating
the appropriate natural resources programs, and considering
institutional and other policy issues, are selected to best
reflect the overall priorities and preferences of the public.
The integration should be two-fold: First, other studies
can provide input (data, problem identification, alterna-
tives etc.) to the Level B and assist in implementing
Level B recotiunendations. Second, the Level B provides a
broader perspective upon which other studies and programs
can build.-——
Heavy reliance hasbeen placed by the Congress and U.S. Environ-
mental Protection Agency (EPA) on planning to provide the basis for
achieving the goals and objectives of Public Law 92-500, namely, to
achieve fishable, swimmable waters wherever attainable by 1983 and
elimination of discharge of pollutants to navigable waters by 1935.
Two major water quality management planning programs, areawide and
statewide pursuant to Sec. 208 and Sec. 303(e), respectively, and
facilities planning under Sec. 201 of the Act, are authorized.
EPA has entered into agreements with other federal agen .’ es with
resource planning programs——Department of Housing and Urban Development,
Department of Commerce and Bureau of Land Management for exaxnp1€ —for
coordination of the related planning programs. EPA and WRC ‘ e yet
to work out arrangements for coordination of their respecti planning
programs although there is recognition of the need.
In some respects bilateral agreements are analogous to the planning
procedures developed by Federal agencies in accordance with Section 1.D.
of the Standards (3). The procedures are to provii e f r consistency in
the application of the Standards and are reviewed by the Water Resources
Council prior to promulgation by the agency. The bilateral agreements
also strive to provide for coordination of the planning prccesses. It
is possible that the mechanism set forth in Section l.D. of the Standards
to coordinate and attain consistency in the planning process might be
used rather than multi—bilateral agreements.
Regulations implementing the continuing planning process have been
promulgated by EPA including those pertaining to grants to states and
designated areawide planning agencies (7), policies and procedures for the
state continuing planning process (8), and requirements for preparation
of water quality management plans (9). EPA has supplemented the regulations
with both guidelines for planning (10) and a handbook concerning the con-
tinuing planning process (11). These guidelines were developed prior to
enactment of the amendment of Public Law 89-80 which designated EPA as a
member of WRC. The guidelines, therefore, were not reviewed by the Council
for consistency with WRC’s Principles and Standards. Whether there will
be a subsequent review has not been determined.
Planning pursuant to Section 208 is in its initial stages.. No initial
plans have yet been submitted to EPA for those areas first designated for
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planning by local agencies. For non—designated areas, few states have yet
made significant progress toward meeting the requirements of EPA regu-
lations (8,9). However, funds are already committed to this latter
activity and a vastly increased level of effort is expected.
Difficulties have been experienced in integrating water quality
management consideration——especially non-point source control problems——
and other aspects of water resource planning and management, which are
neither unusual or unexpected. A major problem is the dispersion of
responsibilities for water and related land resources planning and manage-
ment among several agencies at both Federal and State levels, each acting
under different statutory authority. Similar problems have been encountered
with respect to recreation, protection and propagation of fish and wild-
life, arid other functions. However, the large public and private invest-
ments being made for water quality management purposes and the mandated
achievement of clean water goals in the future wherever attainable, have
made the problem more obvious and the need for resolution more urgent.
Direction for coordinating the several water resource programs has been
lacking in Congressional program authorizations. These authorizations
have not reflected consideration of the interrelationships of the plan-
ning processes involved, objectives and nature of the resultant plans
and programs, or of the differing procedures and levels for the decisions
necessary for implementation.
PurpoSe and Scope of Study
This study was undertaken to evaluate current perceptions, interactions
and coordination between Level B planning and water quality management
planning programs, both as expressed in the several relevant statutes, regu-
lations and guid 1.ines, and as practiced, and to recommend actions that would
result in improve iients in conduct of the programs. The findings and recom
mendations resulting from the study are intended to be useful to those now
engaged in Level B and water quality management planning, and to EPA and
WRC in guiding future planning.
The study included the following:
o Survey of available information on Level B planning
under the Water Resources Planning Act (1) and on
water quality management planning under PL 92-500,
(4) and implementing regulations (8,9) and guide-
lines (6,10,11);
o Conduct of two case studies including both water
quality management and Level B planning and their
analysis with respect to:
a) usefulness of Level B planning processes
and plans to areawide and statewide water
quality management planning processes and
plans;
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b) divergence of actual Level B planning pro-
cesses and plans from the requirements of
the relevant regulations and guidelines
and the causes of such divergence; and
c) possible strategies for overcoming weaknesses
in present processes for relating Level B
planning and water quality management plan-
fling;
the preparation of substantive recommendations such
as:
a) interrelationships which should exist between
Level B planning processes and plans and those
for water quality management;
b) potential utility of Level B planning products
for water quality management planning particu-
larly for the development of water quality
management plans which will fulfill EPA re-
quirements;
c) modifications to Level X and water quality
management planning processes and products
which would facilitate water quality manage-
ment planning in accord with Sec. 208 of
PL 92-500, and which would provide for
greater water quality input to Level B plan-
ning;
d) water quality management planning procedures
that would take maximum advantage of comple-
ted Level B plans or Level B planning in
process; and
e) institutional, financial and other implica-
tions of the coordination of Level B plan-
fling with water quality management planning.
Conduct of the Study
The investigation was approached through five related tasks including:
o Detailed study design;
o Review and analysis of relevant statutes, regulations,
guidelines, reports and other documents and literature;
Conduct of case study investigations;
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o Analysis of the case studies; and
o Preparation of recommendations and reports.
During the detailed study design period, criteria were established
for selecting the case studies and information was collected concerning
all candidate Level B planning activities. Six potentially useful case
studies were considered by the project Officer, Project Advisory Committee
and contractor (Appendix A). The Central Snake and Monongahela Level B
planning programs were selected for investigation.
Review and analysis of the statutes, regulations, guidelines, reports
and other documents and literature was largely completed prior to beginning
the case studies. Later in the study, some further review and analysis of
literature was undertaken to investigate particular points which arose during
analysis of the case studies. The initial comparison of regulations and
guidelines for Level B and water quality management planning was suc-
cessively refined as continuing project study provided additional infor—
ination and insights on important points. Conduct and analysis of the
case studies emphasized the planning processes as well as the plans which
were in varying stages of completion. Preparation for each of the case
studies included review of the extensive information available concerning
the areas and the studies underway in each. This varied in each case but
generally included correspondence, Type I and other prior studies, and
documentation of the Level B,208 and other studies underway.
Visits were made to each of the case study areas to interview repre-
sentatives of agencies conducting the principal studies underway in each
area. Level B and 208 study managers, representatives of state water re-
sources and water quality control agencies, staff members of EPA and other
federal agencies, and representatives of river basin coimnissions were
interviewed.
Following on—site visits, brief analyses of the findings in each
case study were presented to the Project Officer and Project Advisory
Committee. Each case study was then analyzed in detail with respect to:
o Interrelationships and coordination, or lack thereof
between Level B planning and water quality management
planning;
o Beneficial mechanisms for coordination;
o Impediments to coordination, including attitudes;
and
o Values of Level B planning to the water quality manage-
ment planning in progress or to be undertaken.
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Recommendations have been based upon the information gained from
review of the literature, analysis of findings of the case studies, and
experience of the investigators. The recommendations include some perti-
nent to planning organizations in the case study areas and some directed
to the Water Resources Council and Environmental Protection Agency. The
latter are of general application to all organizations undertaking Level
B or water quality management planning.
Conclusions and recommendations are presented in chapter 2. The
water quality management and Level B planning programs are described and
compared in Chapter 3. The two case studies are discussed in Chapter 4.
Certain interrelationships between water quality management and overall
water resource management that should be taken into account in planning
are briefly discussed in chapter 5.
A list of references is given at the end of Chapters Three and Four. Numbers
in parentheses in the text refer to the numbers in the list.
1—9
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CHAPTER 1
REFERENCES
1. U.S. Congress. Water Rescnlrces Planning Act . Public Law 89-80,
89th Congress. July 22, 1965.
2. U.S. Water Resources Council. WaterResourCeS Council Policy State-
ment No. 1, water and Related Land Resources Planning . Washington,
D.C. July 22, 1970.
3. Principles and Standards forPlanning Water and Related Land Re—
sources . 38 FR 24778.
4. U.s. Congress. Federa1 Water Pollution Control Act, as amended , Public
Law 92—500, 92nd Congress. October 18, 1972.
5. U.S. Water Resources Council. Second Annual Report to the Congress
of the United States on Level B (Section 209) Planning . Washing-
ton, D.C., 1974.
6. U.S. Water Resources Council. Proposed Guidelines for Regional or
River Basin Planning (Level B) ; Proposed for Field evaluation,
subject to revision. Washington, D.C., March 1976.
7. Grants to State and Designated Areawide Planning Agencies—Conditions,
Policies and Procedures , 40 CFR Part 35, Subpart A, Section 35.200
through 35.240 (40 FR 55321). November 28, 1975.
8. Policies and Procedures for Continuing Planning Process , 40 CFR
Part 130 (40 FR 55334). November 28, 1975.
9. Preparation of Water Quality Management Plans , 40 CFR Part 131 (40
FR 55343). November 28, 1975.
1.0. U.S. Environmental Protection Agency. Guidelines for Areawide Waste
Treatment Management Planning . Washington, D.C.,, August, 1975.
ii. U.S. Environmental Protection Agency. State Continuing Planning
Process Handbook . Washington, D.C., December 1975.
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CHAPTER 2
CONCLUSIONS AND RECOMMENDATIONS
The conclusions and recommendations presented here are based on re-
view of (a) WRC’s “new approach”, the Proposed Guidelines for Regional
or River Basin Planning (Level ), March 1976, and the Principles and
Standards for Planning Water and Related Land Resources, (b) review of
EPA’s latest regulations for water quality management planning (40 CFR
130 and 131), and Guidelines for Areawide Waste Treatment Management Plan-
ning and the States Continuing Planning Process (c) review of the stat-
utes and legislative history, Cd) review of literature relevant to Leve)
B and water quality management planning, (e) information obtained from
discussions with staff and officials of organizations participating in
Level B, Sec. 208, Sec. 303(e), Urban Studies and other planning activi-
ties in the Central Snake River Basin and Monongahela River Basin case
study areas, (f) review of documents pertaining to the case studies, and
(g) experience of the investigators.
The Level B study was completed or nearing completion for each of the
two cases studies. Sec. 208 planning was underway by the Ada/Canyon Area-
wide Wa te Treatment Management Committee for the designated Ada/Canyon
counties 208 area in the Central Snake River Basin Level B study area,
Idaho. The six county Pittsburgh 208 area had been designated and the
Southwestern Pennsylvania Regional Planning Commission had been designated
as the areawide planning agency for part of the area covered by the Mon—
ongahela Level B Study, but an approved work plan had not yet been de-
veloped; this was known at the time the case study was selected. The
States’ continuing planning processes for water quality management in
accord with the latest EPA regulations (40 CFR 130 and 131) were in the
process of development. The USCE Urban Studies program at Boise was near
its m.id-point. The status of planning provided ample information regarding
the respective Level B studies and the Boise Urban Study but required some
postulation as to the expected conduct of the water quality management
planning programs.
While the conclusions and recommendations presented pertain to diverse
aspects of the case studies, WRC’s Proposed Guidelines for Regional and
River Basin Planning and EPA’s regulations for water quality management,
five questions are basic to the purpose of the study. They are:
(1) What is the existing use of the Level B studies in water
quality management planning?
(2) What is the usefulness of existing Level B studies in water
quality management planning?
(3) What is the potential usefulness of future Level B planning in
water quality management planning?
(4) What are the reasons for the divergence between (1) and
(2), and between (2) and (3)?
(5) What three or four main actions are necessary to attain
the potential usefulness?
2—1
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Conclusions especially formulated in response to questions one through
four are entitled Summary Conclusions and appear beginning on page 2-7.
Recommendations 11,12,13,14, and 15 are particularly responsive to the
fifth question.
Page numbers in parentheses in the following Conclusions and Recom-
mendations refer to the pages in this report where supporting material
is to be found.
Conclusions
General
fulfill the Congressional intent, water quality management
planning and Level B planning must be conducted in a compatible
manner, and to the extent possible, be mutually complementary
and supportive (3—16). Congress has established, through en-
actment of PL 92-5007 ertain goals and objectives respecting
the quality of the Nations’ s water resources and has provided
for certain programs to achieve those goals and objectives.
These programs include water quality management planning pur-
suant to Section 208 and 303(e) and Level B planning directed
by Section 209 of the Act. The goals, objectives and programs
are matters of national policy and effort and must be so con-
sidered in all planning activities.
2.lj iere are certain inherent difficulties in achieving full com-
patibility between water quality management planning conducted
pursuant to PL 92-500 and EPA implementing regulations (40 CFR
130 and 131) and Level B planning accomplished in accordance
with the “new approach”, the WRC Proposed Guidelines and the
Principles and Standards for Planning Water and Related Land
Resources. Water quality management planning essentially has
the single objective of meeting approved water quality stand-
ards through facilities and regulatory programs to control
the discharge of pollutants from point and non-point sources.
The only economic criterion is that of cost—effectiveness (3—33).
On the other hand, Level B planning is niultiobjéctive, to en-
hance National Economic Development and Environmental Quality
in accordance with the Principles and Standards for Planning
Water and Related Land Resources, and multi-functional to meet
needs and solve problems. Alternatives are evaluated in terms
of the beneficial and adverse impacts on national economic de-
velopment, environmental quality, regional development and social
well-being. Implementation of water quality management plans
must be assured prior to final approval. In general, implemen-
tation of Level B plans depends upon further actions and de-
cisions (3—33).
2-2
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Central Snake Case Study
3. The Central Snake River Basin Level B Study was initiated prior
to WRC’s adoption of the “new approach” or development of the
Proposed Guidelines. However, the Study has been carried out
in general accord with the Proposed Guidelines and the “new
approach” except that additional information for fish and wild-
life was collected and the study period was extended beyond
two years (4-7).
4. Conjunctive consideration of water quantity and water quality
management was an important purpose for undertaking the Central
Snake Level B Study (4—6) but water quality aspects are not
treated in the study report except to assume that the goals
expressed in Pt 92—500 will be met (4-8). Neither EPA nor
the Idaho Department of Health and Welfare made significant
inputs of information to the Study or participated in formu-
lation of recommendations (4—15,17) although both were members
of the State-Federal Study Team.
5. Lack of knowledge on the part of the water quality management
agencies with respect to the Principles and Standards, WRC’s
Proposed Guidelines, and of EPA regulations for the State’s
continuing planning process by the Level B planners was a
serious impediment to effective coordination of programs (4—18,
21,23).
6. Adequate formal and informal mechani ms exist for coordination
of the Central Snake Level B Study with water quality manage-
ment planning. They have not been used effectively to make
Level B and water quality management planning mutually suppor-
tive (4-22). Significant amounts of useful information pre-
pared in the Level B Study may not be used as a result (4-11,
17) contrary to EPA requirements for use of Level B Study re-
sults (40 CFR 130.34(c)] and to the detriment of achieving a
practical plan for water quality management in the Central Snake
River Basin (4-9). Adverse effects of the lack of coordination
on water quality management planning in the Ada/Canyon Counties
designated area are mitigated by its upstream location in the
Boise River watershed.
7. Failure to incorporate water quality considerations in the
Central Snake Level B Study has jeopardized the overall use-
fulness of that study (4-9) and the potential for compatible
inclusion in the Coordinated Comprehensive Joint Plan of both
Level B and water quality management plans (4-10).
8. The ongoing US cE Boise Valley Study has had no discernable effect
on the coordination of the Level B Study and water quality management
planning conducted by others for the Central Snake River Basin
but has itself included some integration of quality and quantity
considerations (4—15).
2—3
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Monongahela Case Study
9. The Monongahela River Basin Level B Study by the Ohio River
Basin Commission (ORBC) was conducted in accordance with the
“new approach” and generally followed WRC’s Proposed Guidelines,
and the Principles and Standards (4-30). The Study did not adequately
address all of the important aspects of water quality discussed
hereinafter in chapter 5. This was due in part to lack of input
information concerning water quality problems from water quality
management agencies. Consideration of quality problems was limited
to domestic sewage, industrial wastes, acid mine drainage particu-
larly from abandoned or orphan mines, and sediment. Pollution
from other important non—point sources such as urban runoff was
not considered (4-33).
10. Overall, input to and participation in the Level B Study from
Federal and State water quality management agencies was minimal,
although it varied among agencies. Opportunity for participation
was afforded (4-30). Effective coordination of water quality
management and Level B planning was generally lacking (4-39) and
made more difficult by the limited participation.
11. Water quality in the Monongahela River Basin near Pittsburgh
is poor (4—27) for a variety of reasons. Potential streamfiow
depletions resulting from upstream water uses in the three States
involved have major impacts on low flows and consequently on
water quality in the vicinity of Pittsburgh unless ameliorative
actions are taken. One option would be additional water supply
storage as proposed in the Level B plan (4—42). The Level B Study
did not resolve certain interstate issues relating to repayment for
provisions of storage and streamfiow augmentation which would
ameliorate the problem (4—36).
12. The principal values of the Level B Plan as regards future water
quality management planning are that it:
A. Points up the interstate nature of the water quality
problems in the Basin and the necessity for coordi-
nated interstate actions to solve those problems (4-36,
39);
B. Demonstrates the significant adverse impact on critical
flows that would be caused by future increases in water
use for municipal, industrial, agricultural and power
generation purposes, unless additional storage is pro-
vided to meet those increased demands (4-28,35); and
C. Recommends priorities for implementation of water re-
sources management measures including water quality,
on a basinwide basis in the context of overall needs
for water resource management funding and actions (4—52, 53).
13. Some interviewers in water quality management planning agencies saw
little value in the Level B Plan since the information provided was
considered to be readily available from other sources (4—42).
2—4
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14. Except for ORBC staff, staffs of the agencies interviewed were
not familiar with WRC Proposed Guidelines or Principles and
Standards (4—42,47,49,51,52).
15. Water quality management planning by Southwestern Pennslyvania
Regional Planning Commission (SPRPC) must proceed under con-
ditions of uncertainty as regards implementation, or lack
thereof, of interstate water quality management measures par-
ticularly as regards provision of additional storage, recommended
in the Level B Plan (4-42). Unless those recommendations are
carried to fruition, it may be impossible to achieve the national
goal of “fishable, swimmable” waters within the designated area
even though all point and nonpoint pollutant sources therein are
fully controlled. The result would be highly inequitable to those
within the designated area who had made heavy investments for
pollution control but whose efforts to fully achieve “clean water”
would be frustrated by lack of action upstream. The Level B Plan
does not, of course, resolve these uncertainties but does serve
to identify them and their significance. It points up the neces-
sity for actions by others besides• water quality managinent
agencies in order that water quality may be maintained and im-
proved.
16. Similarly, the uncertainty concerning future critical low flows
could lead to serious mis-investments (4—42). Facilities planned
and designed on the basis of current critical flow magnitudes
might become inadequate in a relatively short time if upstream
storage were not provided in time to meet increased upstream
water demands. Conversely, planning and design now on the basis
of possible reduced critical flows in the future would involve
additional investments that need not have been made if upstream
storage should be provided and the reduction not occur.
17. The Statewide Comprehensive Water Quality Management Planning
Program (COWAMP) and the State Water Planning Program (SW ?)
being conducted by the Pennsylvania Department of Environmental
Resources appear to be well conceived and executed, and fully
coordinated (4—50).
18. The present division of responsibilities for water quality
management planning and water resources planning among state
agencies in West Virginia may make the requisite degree of co-
ordination difficult (4-51).
Level B Planning
19. Level B planning is intended by Congress to be one means by which
• water quality and developmental considerations related to water
and related land resources are to be reconciled to provide a
coherent basis for resource management (1—4, 3—18). It is re—
quired for all parts of the Nation to achieve that purpose (1-3,
3-19) with priority for areas with substantial water quality
2—5
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problems (1—3, 3-19). Water quality and solutions to the quality
problems that may be involved must therefore be considered to the
requisite degree in each Level B study. Resolution of conflicts
between water quality and other considerations must take place
within the mandates and framework of pi 92-500 through the com-
prehensive coordinated joint planning required by PL 89-80 (3-15).
20. Widespread and uniform understanding of the purpose and processes
for Level B planning, including its relationship to water quality
management planning does not exist (4-17,47,50). Achieving such
understanding and the development of procedures to make Level B
planning and water quality management planning mutually supportive
are seriously hampered by the lack of any definition of the Level
B planning products to result. WRC’s Proposed Guidelines do not
overcome this deficiency. They are procedural in nature. (B—2).
The opportunities for improving understanding of Level B planning
and clarifying its relation to water quality management planning
would be improved greatly if certain essential parts of the Pro-
posed Guidelines dealing with bothplanning procedures and products
were made more specific and were promulgated as regulations for
planning by Federal agencies and under federally assisted pro-
grams, leaving only such matters to the Guidelines as are properly
discretionary, with recognition of the need for full coordination
with water quality management and other planning programs.
21. The Principles and Standards for Planning Water and Related Land
Resources only recognize the national water quality goals estab-
lished in PL 92-500 and encourage their consideration (3—23).
Planning pursuant to the Principles and Standards is not ex-
plicitly required to comply with water quality standards and
time frames for their accomplishment established in accordance
with statutory directives. No base is established or guidance
provided for the measurement of water quality related impacts on
national economic development or regional development (3-23).
22. WRC’S Guidelines do not insure full consideration of water quality
management in Level B planning. Water quality management is not
specified as one of the focusses to be considered in all Level B
studies and evaluation of water quality impacts of proposed pro-
jects and programs is not expressly required (3-28). The Guide-
lines do not specify how water quality management plans and pro-
cedures such as water quality standards, effluent limitations,
NPDES permit conditions, and plans developed by the State’ s con-
tinuing planning process are to be taken into account in Level B
planning (3—23).
23. WRC’s Proposed Guidelines are generally compatible with EPA’s
regulations for the State’ s continuing water quality management
planning process and would neither exacerbate nor improve the
interrelationships except fhat the Guidelines’.:
2—6
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A. Restriction on development of new information may frus-
trate adequate consideration of water quality and other
environmental concerns for which presently available
data are limited in many areas (3-27);
B. Flexibility in the selection of study focusses by the
study team may permit omitting water quality as a sig-
nificant concern (3—27); and
C. Procedures for evaluation and selection of the recom-
mended plan which properly encourage consideration of
tradeoffs among objectives do not require compliance
with approved water quality standards (3-28).
Water Quality Management Planning
24. EPA regulations (40 CFR 130.34] require the consideration of
some types of information expected to result from Level B plan-
ning, and development of certain of that information in the
event Level B planning has not been initiated (3-13), but do
not require full consideration of quality/quantity interrelation-
ships as described in cthapter 5, or specify how integration of
Level B outputs with water quality management is to be achieved.
Neither EPA’s Guidelines for Areawide Waste Treatment Management
nor the State Continuing Planning Process Handbook provide elabor-
ation on relationships between water quality management and Level
B planning or how Level B study products are to be used.
25. EPA regulations on intergovernmental cooperation and coordination
[ 40 FR 130.16] place responsibility for coordination of water
quality management planning with other activities on the States
(3—12) and only require representatives of the State and public
on policy advisory committees (3-30). Provisions are not suf-
ficient to assure that mechanisms for coordination of Level. B
and other types of water and land resources planning by river
basin commissions and the Water Resources Council are used ef-
fectively.
Summary Conclusions
26. At the time of interviews (March 1976), the water quality manage-
ment planning agencies had made little use of the Level B planning
studies, and the staffs:of those agencies saw comparatively little
value in the Level B studies and plans. Participation and input
by the water quality management agencies in the Level B planning
activities had been minimal In the Central Snake River Basin,
some use had been made in water quality management planning of
2—7
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basic data collected in the course of the Level B study and
comon use was made of certain projections. For the Monon—
gahela River Basin, some value was attributed to the Level B
Plan for water quality management planning because of its
interstate coverage.
27. The Level B studies and plans for the two river basins can be
of value in water quality management planning. The values
encompass:
A. Availability of compiled data on geology, hydrology,
climatology, soils, land and water uses, demography,
economic and cultural development and related matters;
B. Identification and description of the major water and
related land resources problems, needs and opportunities
for development in the basins which should be considered
in developing water quality management plans and programs;
C. Projections of types, locations, and amounts of future
demands on the water resources of the basins for the
several purposes to be served;
D. Identification, analysis, evaluation and screening of
the several plans and programs that have been proposed
by various entities for control, conservation, pro-
tection, development and use of the water resources;
E. Formulation and evaluation of alternative plans to
satisfy projected demands for water and their probable
effects on stream flows, particularly critical low flow
rates;
F. Identification and evaluation of certain tradeoffs
involved in developing comprehensive basinwide plans
for water resources management and in decisions con-
cerning such management;
G. cost estimates for projected future water develop-
ments in the basins, useful in allocating and scheduling
funding for comprehensive water resources management;
H. For the Monongahela River Basin, identification of
actions and decisions by entities other than water
quality management agencies which will be needed to
complement the waste treatment facilities and regula-
tory programs;
I. For the Monongahela River Basin, identification of the
interstate nature of both developmental and water quality
management problems, and the need for coordinated inter-
state actions to solve those problems; and
2—8
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• For the Central Snake River Basin, information on ground-
water and groundwater—surface water relationships, prior
studies and ongoing resource related investigations, inter-
state considerations, and energy.
28.. Properly conducted with due regard for the mandates of PL 92-500
and the water quality management planning programs conducted in
accordance therewith, Level B planning should provide the basis
for comprehensive management, including water quality management,
of the water and related land resources of a particular river
basin or region. Level B planning should identify and evaluate
both the factors and significant tradeoffs that need con-
sidered in developing complementary water quality management plans
and development plans. In addition to the information of value
for water quality management planning listed in item 27 above,
Level B planning should:
A. Identify and evaluate the quantity/quality interre-
lationships involved in proposed water and related
land resource developments and uses;
B. Evaluate the waste loads that would be generated by
proposed developments and use of water and related
land resources and estimate the cost of waste treat-
ment facilities and regulatory programs needed to
protect receiving waters in accordance with approved
water quality standards, in the evaluation of alterna-
tives;
C. Provide information on the economic values of water
quality in relation to the uses being made or due to
be made of the waters involved;
D. Provide information as to the need for any revision
of water quality standards and justification therefor,
pursuant to 40 FR 130.17, in the interest of compre-
hensive management of the water and related land re-
sources concerned;
E. Provide the basis for proper allocation and scheduling
of funding among the several programs for overall water
and related land resource management including water
quality management;
F. Provide the mechanism for coordination and harmonizing
the programs of water quality management agencies and
of developmental agencies with the objective of best
resource management within the framework of national
and statutory policies; and
2—9
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G. Provide information concerning energy development
and production related factors involved in compre-
hensive, basinwide resource management.
29. The reasons for the difference between the expected use and
the possible usefulness of the existing Level B plans for the
two river basins in the current water quality management
planning programs may be categorized as follows:
A. Lack of knowledge and understanding on the part of
water quality management planning agencies of the
present Level B planning program and the potential
usefulness of Level B planning results in water quality
management;
B. Lack of knowledge and understanding by Level B plan-
ning agencies of PL 92—500 and its import, and of EPA
regulations and guidelines for water quality manage-
ment planning;
C. Lack of understanding by water quality management
planning staffs of the quantity/quality interre-
lationships;
D. Reluctance by water quality management planning
agencies to participate fully in the Level B
planning programs;
E. Differences in agency philosophy, objectives and
interests;
F. Conflicts among agencies;
G. Ladc of reciprocal expertise on the staffs of Level
B and water quality management planning agencies,
and lack of adequate reciprocal representation on the
respective advisory coninittees.
30. The potential usefulness of Level B planning is not being realized
for the following additional reasons:
A. Lack of knowledge and understanding by all concerned
of the intent of Congress in enactment of Section 209
of PL 92—500;
B. Reluctance on the part of Level B planning agencies and
staffs to accept and integrate into their planning the
goals, objectives and procedures mandated by PL 92-500,
the implementing regulations, and the water quality stan-
dards and pollution control measures established in
accordance therewith;
2—10
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C. The indefiniteness of WRC’s Proposed Guidelines for
River Basin or Regional Planning (Level B) as to its
objectives and expected results, and lack of specificity
as to consideration to be given to water quality prob-
lems and to coordination with water quality management
planning programs;
D. The limitations on timing, funding and collection of
additional data imposed by WRC’s Proposed Guidelines;
E. The lack of specificity in the Principles and Standards
for Planning Water and Related Land Resources as to
the consideration to be given water quality management
in the formulation and evaluation of alternative plans,
and in selection of a recommended plan;
0
F. Lack of clear direction in EPA’s regulations (40 FR
130 and 131) and guidelines for water quality manage-
ment planning as to coordination with and participation
in Level B planning activities, and as to the need for
and use of Level B planning products; and
G. The fact that the Level B planning program and the water
quality management planning program are generally out
of phase on a nationwide basis.
Recommendations
Central Snake River Basin
1. The Central Snake Level B Study should be supplemented to in-
clude more specific consideration of water quality, particu—
larly analysis of the impacts of the Study’s recommended allo-
cations of water on meeting national goals established in Sec.
101(a) of PL 92-500. WRC, EPA and the Pacific Northwest River
Basins Commission should encourage active participation by the
Idaho Department of Health and Welfare in the further consider-
ation of water quality and in preparation of the analysis. EPA
should also provide technical assistance including consideration
of any interstate impacts.
The costs for controlling new point and non—point sources of pol-
lutants from new developments considered in Level B planning
should be included in economic evaluations. Other beneficial
and adverse quality—related impacts such as those resulting
from changes in low flows shou]d be evaluated.
2—11
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2. Pacific Northwest River Basins Commission and Idaho Division
of Budget, Policy Planning and Coordination, Office of the
Governor, should assume major responsibility for securing
greater coordination of water quantity and water quality
management planning in the Central Snake River Basin. EPA
Region X should provide technical and policy assistance to the
Commission in this effort. WRC should closely monitor all re-
lated activities and member agencies should aid the Commission
in its efforts to achieve coordination by directing the appro-
priate participation of field staff.
3. Ada/Canyon Waste Treatment Management Committee should request
the Idaho Department of Water Resources to provide specific
data and information from the Central Snake Level B Study
useful for water quality management planning in the Ada/Canyon
County designated area and for analysis of the effects of Level B
Study recommendations on water quality management requirements
in the Boise River Basin near Boise. The two agencies should
work together in evaluating the potential effects of water
quality management alternatives on recommended Level B Study water
allocations. Particular attention should be given to the poten-
tial effect of regulatory programs for control of agriculturally
related nonpoint sources of pollution on water requirements.
EPA’S Idaho Operations Office and the Idaho Department of Health
and Welfare should assist in the required analyses.
Monongahela River Basin
4. Ohio River Basin CommissiOn (ORBC) should give greater con-
sideration to quantity/quality relationships and to.evaluation
of potential quality impacts of projects and programs under
consideration in its ongoing comprehensive coordinated joint
planning. Water quality management agencies should provide
the necessary input concerning quality.
5. Region III of EPA, the designated State water quality manage-
ment planning agencies of Pennsylvania, West Virginia and Mary-
land, Southwestern Pennsylvania Regional Planning Commission
and other designated areawide planning agencies, and the Ohio
River Valley Water Sanitation Conuniss ion should actively par-
ticipate with ORBC in the continuing comprehensive coordinated
joint planning to assure full and coordinated consideration of
quality problems.
6. Southwestern Pennsylvania Regional Planning Commission should
make full use of tbe Level B plan information and recommend-
ations.
7. Aggressive joint action should be taken by all agencies con-
cerned to iu lement the Level B plan recommendations concerning
control of acid mine drainage and sediment.
2—12
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8. ORBC should actively promote joint interstate action to control
acid mine drainage.
9. In developing the areawide water quality management plan for the
designated Pittsburgh 208 area, and the schedule for implemen-
tation, Southwestern Pennsylvania Regional Planning Commission
should give full consideration to the time that may be required
to effect full control of acid mine drainage and sediment in the
Monongahela River Basin upstream of the designated area. Like
wise, the Commission should give full consideration to potential
depletions of minimum stream flows due to upstream water resource
development and utilization.
10. Level B plan recommendations for determination of minimum low
stream flow requirements for aquatic life and for detailed
studies of potential water supply reservoirs to provide for
future water uses should be implemented as rapidly as possible.
Water Resources Council
11. Instructions for Level B planning should be revised and sup-
plemented to:
A. Limit content of the Level B Guidelines to information
and instructions concerning discretionary procedures
and products;
B. Expand the Principles and Standards, or promulgate
separate regulations, to set forth those required
aspects of the Level B planning program which are
necessary to achieve complementarity with water quality
management planning. Regulations should:
a. require maintenance or improvement pf water
quality to be appropriately considered in
each study;
b. provide that the agreements between states
and EPA concerning water quality management
planning pursuant to 40 CFR 130.11 shall be
taken into account in Level B planning;
c. require that established water quality
standards and other limitations prescribed
or established pursuant to PL 92—500 be
considered as baseline conditions for Level
B planning, and that any changes in quality
that would result from implementation of
recommendations be evaluated against those
baseline conditions;
2—13
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d. require evaluation of the effects, including eco-
nomic evaluation wherever possible, of alternative
resource development plans on achieving, main-
taining or otherwise affecting water quality stand-
ards, stream segment classifications, waste load
allocations, water quality management plans, non—
point source controls and other water quality ele-
ments developed and adopted pursuant to PL 92-500,
including justification of any recommended plan
features which may adversely affect such elements;
e. require assurances that EPA and state water quality
management agencies will participate in Level B
studies;
f. require Proposals to Study to include assurances
by water quality management agencies that necessary
water quality inputs will be provided;
g. require interim reports on conduct of Level B
studies and provide for their review by appro-
priate interstate agencies, state water resource
and water quality management agencies, and desig-
nated local water quality management agencies;
h. require certification by Governors of affected
states that recommended Level B plans are con-
sistent with the State’s program for water
quality management and other relevant plans;
i. define the specific contents of Level B plans
relevant to water quality management.
C. Increase emphasis in Level B Guidelines on consideration of
specific arrangements for implementing water quality manage-
ment plans.
12. The Water Resources Council should make, or seek necessary funds
and/or authority to make modifications in the Level B planning
program, including:
A. Funding and scheduling of studies on an individualized
basis in accordance with the study requirements for the
particular situation in lieu of the study and time linii—
tations now prescribed in “new approach”;
B. Providing for collection of new data and information
where essential for resolution of critical problems;
C. Maintaining and updating Level B studies on a frequent
basis, particularly for areas with significant quantity/
quality problems;
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D. Assumption of major responsibility by WRC for coordi—
nation and management of Level B studies unless iver
basin commissions control study funds or other effective
mechanism for assuring coordination is to be utilized.
Environmental Protection Agency
13. Regulations for the State continuing planning process should be
modified including:
A. Expansion of 40 CFR 130.34(c) and (d) to include con-
sideration of additional relationships between water
quality and water quantity management as described in
Chapter 5.
B. Inclusion in 40 CFR 130.16(d) of requirements to in-
clude representatives of ongoing Level B study organi-
zations on policy advisory committees.
14. EPA should ensure that completed and ongoing Level B studies are
recognized and appropriate provisions made for coordination
in requests for designations, grant applications, work plans
and other documents prepared prior to undertaking development
of water quality management plans. Monitoring of ongoing
water quality management planning should assure coordination
procedures are adequate and successful.
15. EPA should place heavy emphasis on use of river basin com-
missions or similar entities where they exist to coordinate
water quality management planning activities with other water
and related land resources planning. EPA should contribute to
strengthening the capability of commissions and other similar
entities by participation in planning activities and by joint
development of specific coordination procedures.
General
16. EPA and W1 should jointly work to assure that State and local
water quality management agencies are adequately funded for
appropriate participation in Level B studies.
17. EPA and WRC should assure that all key participants in planning
under their supervision, including those responsible for mcmi—
toring ongoing studies, are fully cognizant of Level B and water
quality management planning processes including relevant statu-
tory and regulatory requirements and the need for considering
quality/quantity relationships. A jointly sponsored series
of training sessions should be considered for this purpose.
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18. A technical manual should be jointly prepared by EPA and W
to provide guidance on quantity/quality relationships and how
these are to be considered and evaluated in the several planning
programs, and on the economic evaluation under the Principles
and Standards of quality changes.
19. The staffs of water quality management planning agencies and of
Level B agencies should have expertise in water resource de-
velopmental planning and in water quality management, respectively.
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CHAPTER 3
WATER QUALITY MANAGEMENT/LEVEL B
PLANNING PROGRAMS
This chapter presents a comparison of water quality management
planning as prescribed by PL 92-500 (1) and the implementing regulations
(2,3,4) and guidelines (5), with Level B planning as directed by WRC Pro-
posed Guidelines (7) and Principles and Standards for Planning Water and
Related Land Resources (8).
Water Quality Management Planning
Water quality management planning — by both areawide planning agencies
designated pursuant to Sec. 208(a) (2), (3) or (4) of PL 92—500 for desig-
nated areas, and state planning agencies designated in accordance with
Sec. 208(a) (6) to conduct planning for non-designated areas — is now to
be conducted under provisions of 40 cFR Part 130, Policies and Procedures
for the State Continuing Planning Process, and 40 CFR Part 131, Preparation
of Water Quality Management Plans, effective November 28, 1975. Planning
under these new regulations is significantly different in some respects
from what was previously termed “areawide waste treatment management
planning.”
Background
Prior to promulgation of the new regulations, the Sec. 303(e)--
state continuing planning process——, Sec. 305--annual reporting and
analysis--, and Sec. 106--state and interstate agency program grants--
provisions of PL 92—500 were interpreted as being largely separate each
from the other. The decision of the United States District Court for
the District of Columbia on June 5, 1975 in Natural Resources Defense
Council (NRDC) ‘V. Train, 396 F. Supp. 1386 (1975), precipitated a sub-
stantial change in water quality management planning for both designated
and non—designated areas. Previously, the state responsibility for plan-
ning for non—designated areas had generally been considered to be less
than that for designated areas. The NRDC decision set forth the principle
that the level of planning by the State for non—designated areas must be
equivalent to that of designated areawide planning agencies in designated
areas. The Court ordered EPA to issue a revised set of regulations em-
bodying this principle.
In the course of doing so, EPA has also made several other changes.
Before the NRDC decision, it was considered that planning by the
State pursuant to Sec. 303 (e) of PL 92—500 was broader and less detailed
than areawide planning under Section 208. State planning for non-designated
areas under Sec. 208 was expected to be little if any more than what was
required to satisfy the maintenance of a “continuing state planning pro-
cess” under Section 303(e). The new regulations, promulgated in accord
with the Court’s decision that water quality management planning for both
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designated and non—designated areas should be conducted at equivalent
levels of detail for the same types of water quality problems, are sig-
nificantly different from earlier EPA regulations.
The u st significant change has been to blend and coordinate the
several planning activities prescribed by PL 92-500. In so doing, the
effect of the regulations is to merge areawide waste treatment management
planning with planning by the State pursuant to Section 303 (e) as well as
with that to be accomplished by the State under Sec. 208. The only real
differences now appear to be:
A. Whether the planning is done by a designated re-
gional agency of essentially interlocal character
such as a council of governments or a regional
planning commission, or whether it is done by a
designated state agency; and
B. Full recognition that certain elements of the plan-
ning for water quality management as a whole may be
reserved for state performance, either because of
the nature of the authority involved or because uni-
formity on a statewide basis is desired (e.g. 40 cFR
131.ll(f)(4), 131.11(g) (4), and 131.ll(j)(3)(vii)).
Thus, 208 planning is to be done for all areas having water quality prob-
lems and the delineation of designated area boundaries is primarily sig-
nificant in identifying the planner to be either an areawide planning
agency or a state planning agency.
The (burt precipitated revision took effect on November 28, 1975.
This was relatively early in the work of the first group of 208 planning
projects which had been initiated prior to the decision, but late enough
to have come after the pre-approval work related to the designation of
planning areas and their agencies. In many cases, it has also come after
oon’pletion of work plans. Consequently, it should be anticipated that
there may be some differences in emphasis as between planning processes
for 208 plans commenced on or shortly after July 1, 1975 and those
carried forward entirely after the appearance of the revised regulations.
However, it is likely that, as a practical matter and at least so far as
designated areawide planning agencies are concerned, any differences will
probably be minor. Water quality management planning by the States may
be much re affected.
The current regulations provide that conduct of 208 planning by a
state agency is to be governed by an EPA-State Agreement (40 CFR Sec.
130.11). While this permits EPA to assure itself concerning the coverage
of the work, it also is intended to provide a means of determining whether
and at what level of detail, water quality management planning is justi-
fiable and practicable. For example, the regulations specificalLy provide
that if the State can show that there are no significant water quality
problems in a particular area, water quality management planning need
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not be done there (40 CFR 130.11(b)). Further, an EPA-State agreement
may determine a level of detail or the selection and measure of concen-
tration to be applied in a given part of the State’s non—designated
areas (40 CFR 130.11(a)).
Thus, water quality management planning for every square mile of
land area in a state is not necessarily required at the same intensity
and for the same gamut of subject matter. This suggests an important
contrast between designated and some non—designated areas. The former
are by definition areas in which the State and EPA have officially found
significant water quality problems to exist. Accordingly, the statutory
list of matters to be considered in the planning, to the extent applicable
to the economic, physical and social environment of the particular area,
must figure in the planning process. The work plan submitted for approval
by EPA must spell out the activities which will be performed. It may
emphasize, de—emphasize or even neglect one or more items . important
to planning for other areas.
Consolidation of the several planning and allied processes called
for by PL 92-500 has resulted in some shift in concept. Section 208,
according to the unaided statutory language, deals primarily with “area-
wide waste treatment management planning”. It may be argued that because
Section 208 specifically mandates consideration of such matters as land
use and social and economic setting, the title of “waste treatment management
planning” was a misnomer and far too narrow for what was actually intended
by Congress. Nevertheless, even waste treatment management broadly
interpreted would not necessarily or customarily have been thought to in-
clude all aspects of water quality management. Such planning must include
consideration of the ‘hatural” condition of streams, subsurface waters,
and their environments when free of some or all wastes and of other factors
such as water uses which are only partially and sometimes tangentially
concerned with wastes.
In brief, in the contemplated content and procedures for conduct of
planning, the new regulations replace “waste treatment management plan—
fling” with “water quality management planning” in a much broader context.
The intent as stated in 40 CFR 130.1(b) is:
—-to unify and, integrate the State and areawide water
quality management planning and implementation require-
ments of section 208 and other provisions of the Act.
Combining the processes into “water quality management planning”, should
result in more systematic and integrated planning, especially with respect.
to the interrelationships between designated areas and contiguous non—desig-
nated areas. When a single state agency is the planner, it also results
in submerging the separate requirements and procedures of individual parts
of PL 92-500 in favor of a process which includes waste treatment manage-
ment planning, standards setting from Sec. 303(c) and (d), and the several
surveys and inventories of needs and conditions required by Sec. 305 and
516 (b).
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When the planning agency is a designated areawide agency, the plan-
ning process which emerges from the regulations needs to be understood
somewhat more narrowly. A substate regional agency is not responsible
for the section 303(e) state continuing planning process, for the sub-
mission of water quality standards to EPA, or for the furnishing of reports
on water quality conditions and on state needs for treatii ent works. This
is true even though much of the information concerning designated areas
ultimately submitted by state agencies to EPA may come from regional or
local governments and their planning agencies.
When viewed from the standpoint of a designated areawide planning
agency, the process should still be considered as much the same as the
previously conceived “areawide waste treatment management planning” under
Section 208. The main caveat to this statement is that some items of
content which were previously implicit in the concept of comprehensive-
ness may now be explicit. For example, 208 planning is to take account
of energy production processes and energy requirements in the area pur-
suant to 40 CFR 130.34(c)(d).
The pdpose of water quality management planning is implementation of
the water quality objectives of PL 92—500 through achievement of water
quality standards made pursuant to it by reduction or elimination of point
and non-point pollutant discharges to the extent necessary to comply with
applicable laws and regulations. Consequently, the regulations prominently
include the necessity for plans to contain schedules for facilities con-
struction as well as the priorities which one would expect to have identi-
fied and analyzed in any plan.
Section 208 and the regulations spell out the mandatory elements
of the areawide waste treatment management plan (water quality management
plan) in detail and with reliance on specific lists of component items.
Thus, the planning process can be described as comprising data collection
and analysis, identification of problems and needs, establishing priorities,
development and analysis of alternatives, defining necessary regulatory
programs, defining the management structure, scheduling actions for imple-
mentation, and selection of recommendations necessary to encompass each of
the items (40 CFR 131.1). The planning process should make the relationships
among these many component items clear and demonstrate how their implemen-
tation will advance achievement of water quality management objectives.
Planning Objective
The primary objective of water quality management plans is stated in
40 .CFR 131.10(a) to be:
to define the programs necessary to achieve the 1983
national water quality goal established in Sec. 101 (a) (2)
of the Act. The plans shall identify the controls, regu-
latory programs, and management agencies necessary to obtain
the water quality goals and the established state water
quality standards.
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(2) it is the national goal that wherever attainable an
interim goal of water quality which provides for the
protection and propagation of fish, shellfish and wild-
life and provides for recreation in and on the water to
be achieved by July 1, 1983 (Sec. 101 (a) (2), PL 92-500).
Plan Content
Sec. 208(b) (2), PL 92-500, specifies the matters to be included in
an areawide waste treatment management plan, namely:
(2) any plan prepared under such process shall include,
but not be limited to:
(A) the identification of treatment works necessary
to meet the anticipated municipal and industrial
waste treatment needs of the area over a twenty—
year period, annually updated (including an
analysis of alternative waste treatment systems),
including any requirements for acquisition of
land for treatment purposes: the necessary waste
water collection and urban storm water runoff
systems: and a program to provide the necessary
financial arrangements for the development of such
treatment works;
(B) the establishment of construction priorities for
such treatment works and time schedules for the
initiation and completion of all treatment works;
(C) the establishment of a regulatory program to--
(i) implement the waste treatment manage-
ment requirements of Section 201 (c),
(ii) regulate the location, and construction
of any facilities within such area which
may result in any discharge in such area,
and
(iii) assure that any industrial or commercial
wastes discharged into any treatment
works in such area meet applicable pre—
treatment requirements.
(D) the iaentification of those agencies necessary to
construct, operate, and maintain all facilities
required by the plan and otherwise to carry out
the plan;
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(E) the identification of the measures necessary to
carry out the plan (including financing), the
period of tine necessary to carry out the plan,
the costs of carrying out the plan within such
time, and the economic, social, and envi ronmen—
tal impact of carrying out the plan within such
time;
(F) a process to (i) identify, if appropriate, agri-
culturally and silviculturally related nonpoint
sources of pollution, including runoff from
manure disposal areas, and from land used for
livestock and crop production, and (ii) set
forth procedures and methods (including land
use requirements) to control to the extent
feasible such sources;
(G) a process to (1) identify, if appropriate,
mine—related sources of pollution including
new, current, and abandoned surface and under-
ground mine runoff, and (ii) set forth pro-
cedures and methods (including land use re-
quirements) to control to the extent feasible
such sources;
(H) a process to (i) identify construction activity
related sources of pollution, and (ii) set forth
procedures and methods (including land use re-
quirements) to control to the extent feasible
such sources;
(I) a process to (i) identify, if appropriate, salt
water intrusion into rivers, lakes, and estuaries
resulting from reduction of fresh water flow from
any cause, including irrigation, obstruction,
ground water extraction, and diversion, and (ii)
set forth procedures and methods to control such
intrusion to the extent feasible where such pro-
cedures and methods are otherwise a part of the
waste treatment management plan;
(J) a process to control the disposition of all re-
sidual waste generated in such area which could
affect water quality; and
(K) a process to control the disposal of pollutants
on land or in subsurface excavations within such
area to protect ground and surface water quality.
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Planning elements to be included in water quality management plans
as specified in 40 CFR 131.10(g) and 131.11 are listed in Table 1,
which also lists possible Level B planning outputs for comparison.
Coordination with Other Planning Programs
Coordination is required by 40 CFR 130.34(a) with other applicable.
resource and development planning, including as listed in the regulation:
1. State and local land use and development programs;
2. Activities stemming from applicable Federal resource
and developmental programs including:
(i) The Solid Waste Disposal Act, as amended
(Pub. L. 91—512);
(ii) The Safe Drinking Water Act. (Pub. L. 93-523);
(iii) The Clean Air Act, as amended (Pub. L. 91—604);
(iv) The Coastal Zone Management Act (Pub. L. 92-583);
(v) The Watershed Protection and Flood Protection
Act (Pub. L. 83—566);
(vi) The Rural Development Act of 1972 (Pub. L.
92-419);
(vii) The Land and Water Conservation Fund Act, as
amended (Pub. L. 88-578);
(viii) The National Historic Preservation Act (Pub.
L. 89—665);
(ix) The Fish Restoration Act (Pub. L. 81-681) and
the Federal Aid to Wildlife Restoration Act
(Pub. L. 75—415);
(x) The Endangered Species Act (Pub. L. 93-205);
(xi) Wastewater Management Urban Studies Programs
administered by the U.S. Army Corps of Engi-
neers (Pub. L. 685, 1938, Pub. L. 429, 1913);
(xii) Transportation Planning administered by the
Department of Transportation (Pub. L. 87-866,
Pub. L. 93—366, Pub. L. 93—503);
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TABLE 1
COMPARISON OF WATER QUALITY MANAGEMENT PLAN
CONTENTS REQUIRED UNDER 40 CFR 131 WITH
POSSIBLE OUTPUT OF LEVEL B STUDY
40 cFR 131.10(g) and 131.11
Requirements for Water Quality
Management Plan Contents
Possible Level B Study
Outputs
1. delineation of planning boundaries
— maps of state planning areas,
designated planning areas, areas
where facilities planning is neces-
sary, location of identified water
quality and effluent limitation
segments, significant dischargers,
and fixed monitoring stations.
2. water quality assessment and segment
classifications
- identification of type and degree
of existing and potential problems
and point and nonpoint sources of
pollution; classification of seg—
ments based on cocmon hydrologic
characteristics, flow regulation
patterns, physical and other charac-
teristics, present and future compliance
with water quality standards, adjacent
land areas and upstream conditions.
3. inventories and projections
— municipal and industrial sources of
pollutants including description of
waste discharge characteristics,
ranking of municipal sources, s sn—
mation of existing land use patterns,
demographic and economic proj ections,
projected municipal and industrial
wasteloads and projected land use
patterns.
4. nonpoint source assessment
- description of problems caused by
nonpoint sources of pollution in-
cluding type of problem, identifi-
cation of waters affected, serious-
ness and identification of sources
by category.
— base maps of stream networks,
social and cultural features,
existing land use, project de-
velopments and data collection
networks.
— sunmaries of existing ground
and surface water quality; as-
sembly and interpretation of
hydrologic information; pro-
jections of future land use;
information on present and
planned flow regulation.
— demographic and economic pro-
jections, existing land use and
projections of future land use,
water quality impacts of pro-
posed developments, and water
use and water supply information.
— identification of water quality
problems, groundwater/surface
water relationships, runoff
characteristics, existing and
projected activities.
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TABLE 1 CCont’d)
COMPARISON OF WATER QUALITY MANGEMENT PLAN
CONTENTS REQUIRED UNDER 40 CFR 131 WITH
POSSIBLE OUTPUT OF LEVEL B STUDY
40 CRR 131.10(g) and 131.11
Requirements for Water Quality
Management Plan Contents
Possible Level B Study
Outputs
5. water quality standards
— specify uses to be achieved and pro-
tected, and criteria necessary to sup-
port uses take into account use and
value for public water supplies, propa-
gation of fish, shellfish and wildlife,
recreation purposes, agricultural in-
dustrial and navigation purposes.
6. total maximum daily loads
- determine total allowable maximum
daily load of relevant pollutants
for critical flow periods considering
seasonal variations, margin of safety,
thermal loads, allowance for growth
and effluent limitation standards.
7. point source load allocations
— five year individual load allocation
for point sources considering thermal
loads, overall load allocation, growth,
NPDES permits, and margin for safety.
8. municipal waste treatment system needs
— analysis of alternative systems,
land requirements, capital funding
requirements and program for financing
arrangements considering water quality
standards and effluent standards, ex-
isting and future population equivalents
served, facilities planning, and alterna-
tives of connecting industrial sources
to system.
9. industrial waste treatment system needs
- identification of load reductions re-
quired to meet water quality standards
and effluent limitations; specify cost
recovery provisions.
— identify minimum water quality
requirements for Level B plan
for periodic revision of stand-
ards; aid in determining water
uses and value; identifying and
resolving conflicts among uses;
identify planned or anticipated
resource developments that would
impact uses, including changes
in flow regimes.
— identification of critical
flows, seasonal variations in
quality, existing and projected
water supply and waste loads.
— economic and demographic pro-
jections, projected energy de-
velopments (thermal), and data
for model calibration and
verification.
- availability and suitability
of lands and soils, total resource
related financial requirements. Popu-
lation projections and inventories
of existing facilities.
— existing and projected private
industrial water supplies and use
rates and industrial growth fore-
casts.
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TABLE 1 (cont’d)
COMPARISON OF WATER QUALITY MANAGEMENT PLAN
CONTENTS REQUIRED UNDER 40 CFR 131 WITH
POSSIBLE OUTPUTS OF LEV B STUDY
40 cFR 131.10(g) and 131.11
Requirements for Water Qualtiy
Manacement Plan Contents
Possible Level B Study
Outputs
10. nonpoint source control needs
— alternatives and measures chosen for
reducing pollutants from existing non-
point sources to a level consistent
with the gross allotment established
for such sources; alternative land
measures chosen for new or potential
nonpoint sources so as to maintain ex-
isting water quality; agency(s) to super-
vise implementation; adequacy of regulatory
program to implement measures.
11. residual waste control needs
— identify needed controls over residual
waste disposal affecting ground and sur-
face water quality and describe procedures
to achieve controls; identify controls
over land and subsurface disposal.
12. urban and industrial stormwater needs
- identify new systems and improvements
to existing systems needed to a hieve
water quality standards emphasizing
land use management and other nonstruc—
tural techniques; provide estimates of
capital and operating costs.
13. target abatement dates
— establish schedules for abatement or
compliance for all dischargers, nonpoint
source control measures, facilities and
other programs.
14. regulatory programs
— description of existing and
needed State and local regulatory
programs for plan implementation in-
cluding approach, statutory basis
and financial aspects; demonstration
that recomiiended programs are adequate
and that pretreatment requirements will
be met.
— identification of existing and
probable future problems, sources
of authority, agencies to imple-
ment, etc.; examine potential
solutions and recommend an approach
consistent among affected States.
for interstate problems and areas.
— soil characteristics; ground
water characteristics, location
and depth; projected future rural
housing and private waste dis—
posal; integration of land use
plans for functional purposes.
— climatology, rainfall and run-
off data; information on existing
urban drainage, flooding, and
use of land use management and
other nonstructural measures for
flood damage reduction.
- coordination of water quality
management program schedule with
implementation of recommended
Level B plan.
— inventory of resources—related
statutes and regulatory programs;
assessment of non—federal fi-
nancial needs for resource develop-
ment and management; coordination
of institutional arrangements for
water quality management with
other water related programs.
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TABLE 1 (cont’d)
COMPARISON OF WATER QUALITY MANAGEMENT PLAN
CONTENTS REQUIRED UNDER 40 CFR 13]. WITH
POSSIBLE OUTPUT OF LEVEL B STUDY
40 CFR 131.10(g) and 131.11
Requirements for Water Quality
Management Plan Contents.
Possible Level B Study
Outputs
15. management agencies
— recommendation of agencies to be desig-
nated for implementing, operating and
maintaining the plan considering mini-
nrnm required authorities specified in
Act; describe authorities and budgets.
16. environmental, social and economic impact
— assessment of carrying out the plan
considering schedule, effectiveness
in meeting goals, costs, and impacts.
— relationships between implemen-
tation and operation of water
quality management programs and
water rights administration,
water resources data collection,
state and regional planning and
project dev€ lopment and np1emen—
tation.
— summary of other 1atod impact
appraisals; deve1 pn nt of broad
assessment of r iQ rCe m mnagement
impacts.
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(xiii) The Housing and Community Development Act of
1974 (Pub. L. 93-383);
(xiv) Other Federal assisted planning and management
programs.
Other relevant planning programs and plans include among others:
1. Comprehensive, coordinated joint planning authorized
by the Water Resources Planning Act of 1965;
2. Reclamation planning by the U.S. Bureau of Reclamation
pursuant to the Reclamation Act of 1902 and acts amenda-
tory thereof and supplementary thereto;
3. Comprehensive planning by the u.s. Corps of Engineers;
4. Planning by interstate agencies; and
5. State water resource management plans.
While the regulations cite a number of Federal and State programs
with which water quality management planning is to be coordinated, the co-
ordination procedures are left to the initiative of the areawide planning
agency under the leadership of the State planning agency designated by
the Governor (40 CFR 130.12(a)).
Areawide water quality management plans, the proposals for their imple-
mentation, and the work conducted by the State in the nondesignated areas,
must recognize and be integrated with the public health planning and en-
forcement activities encompassed in the Safe Drinking Water Act of 1974
(PL 92—523), and EPA’S regulations promulgated pursuant thereto (40 R
Part 142). %‘ hie the necessity for coordination is obvious, guidance for
assuring that it does in fact take place is left with the States.
Coordination of the water quality management planning program with
the Comprehensive Planning Assistance Program (701) of the Department
of Housing and Urban Development (HUD) has been formalized in instruc-
tions to regional administrators for implementing an agreement reached
between HUD and EPA (March 24, 1975, EPA-IAG-P5-0662,). The memorandum
of instructions identifies 208 as an abbreviated reference to all related
requirements of water quality management planning incorporated in PL 92-500.
In the designated areas for 208 planning, an exchange of Overall Program
Design (OPD) documents (701 work outlines) and 208 work programs is
reccounended in 24 CFR Sec. 600.170 (a). For non-designated areas, the
State and EPA must agree on a work program and reach agreements on 208—701
coordination in accordance with 24 CFR Sec. 600.105(b) (2) and Sec. 600.115
(d)(3) and (4). The State OPD submitted for 701 financial assistance must,
‘under these provisions, provide assurances that there are no overlaps or
inconsistencies, and make provision for effective and continuing 701—EPA
• coordination.
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Coordination between water quality management planning and resource
management planning by the States in the coastal areas pursuant to the
Coastal Zone Management Act, PL 92-583, is required by EPA in 40 CFR
Sec. 130.34, but without procedural requirements. To a substantial
though indirect extent, this coordination is guided by an agreement between
BUD and the Department of Commerce with respect to coordination of the 701
program and coastal zone management planning. This agreement, dated February
19, 1975, parallels the BUD-EPA agreement cited above. By taking these
agreements together in the context of 40 CFR Sec. 130.34, and the imple-
mentation memoranda dated March 10, 1976, that BUD has transmitted to the
regions, the coordinating link between the 701, 208, and coastal zone
management planning progams is to a substantial extent clarified.
The regulations for the Urban Studies Program of Corps of Engineers
(33 CFR 264.14(c)) cite the responsibility of EPA for areawide waste
treatment management and facilities planning, and the need for “close
cooperation” between the Corps’ program and EPA field personnel.
The Clean Air Act as amended, Federal solid waste disposal programs,
and the Federal Flood Insurance program are linked to the water quality
management planning process through the implicit or explicit land use
aspects of the several acts and Federal agency programs. Placing re-
sponsibility for clean air enforcement and solid waste management in
designated areawide management entities has been proposed in legislation
before Congress. EPA Guidelines establish minimum requirements for con-
sideration by 208 planners of clean air and solid waste elements (Sec.
2.3, A and B) under present law.
The land use elements of 208, 701 and coastal zone management plan-
ning are a matter of explicit Federal interagency coordination, through
the agreements cited above.
Use of Level B Plans
The uses to be made of Level B plans in water quality management
planning, where they exist, are stated in 40 CFR 130.34(c). A list of
Level B outputs to be en ployed in water quality management planning is
presented and followed in 40 CFR 130.34(d) by a shorter list of items to
be produced in the water quality management planning process if there is
no Level 8 plan for the area in question. The two lists are quoted because
it is particularly useful for this report to reflect on the differences:
40 CFR 130.34(c) In the event that a Level B study (as
required under Section 209 of the Act) is underway or has
been completed, the State or designated areawide planning
agency shah consider the following outputs of the study,
and where appropriate, provide for integration of the out-
puts with the water quality management plan(s):
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(1) Existing and projected future water with-
drawals and consumptive demand over a 20
year period;
(2) Facilities and management measures to be under-
taken to meet demands on the water supply pro-
gram;
(3) The effects of the water supply program on water
quality;
(4) Impact of authorized water development measures;
(5) Identification of proposed or designated wild and
scenic stream reaches;
(6) Watershed management and land treatment measures;
(7) Energy development and production related factors.
(d) In the event that a “Level B” plan has not been initi-
ated, the State or designated areawide planning agency shall
identify the appropriate constraints on water quality manage-
ment which would be brought about by:
(1) Current and projected future (20-year period)
water demands;
(2) Designated and desired wild and scenic river
segments;
(3) Energy development and production factors.
No explanation for the difference is offered in the regulations, nor is
it easy to discern why the items on the second list are so necessary that
they must be produced, whether or not there is a Level B while the others
are to be used only if provided by a Level B.
However, both lists are important because they represent a recognition
that other aspects of water and related land management must be taken into
account in water quality management planning. A basic difference between
Level B planning and water quality management planning under PL 92-500 must,
however, be kept in mind. The former can have a variety of emphases. Tha—
ditionally, it has been oriented toward water resource development. Water
quality has been only one of the full range of considerations to be taken
into account. As discussed hereinafter, the appearance of Section 209
(regional or river basin planning) in PL 92-500 makes it apparent that Con-
gress now intends that planning of the Level B concept be conducted in a
manner that will serve water quality management needs as well as the previously
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recognized Level B purposes. Nevertheless, it is generally not the prac-
tice in Level B planning to subordinate other water and related land re-
source management interests to water quality. On the other hand, water
quality management plans under PL 92-500 are intended to further the water
quality goals and objectives explicitly stated in that Act. Other aspects
of water and related land resource planning would thus appear to be sub-
ordinate in congressional priorities to water quality management objectives.
If there are legitimate inconsistencies between the results of water
quality management planning under PL 92-500 and plans produced for other
purposes or under other auspices, they can only be reconciled within the
statutory policy framework of PL 92—500 and relevant regulations, par—
tictilarly as regards the setting of water quality standards and revisions
thereof as specified in 40 CFR 130.17.
Implementation
The water quality management plan must identify those agencies recom-
mended for designation by the Governor as responsible for implementing the
several elements of the plan, including those agencies which will construct,
operate and maintain all treatment works recommended in the plan and those
which will carry out the recommended regulatory programs (40 CFR 131.11(0)).
Procedures for designation of these management agencies by the Governor and
approved by the Regional Administrator, EPA, are prescribed by 40 FR 130.15.
The Regional Administrator must:
.accept and approve all designated management agency (ies)
unless, within 120 days of a designation, he finds that,
the agency(ies) does not have adequate authority, including
the requirement that statutory and regulatory provisions
required to implement the plan be adopted by the date of
plan approval by the Regional Administrator, and capability
( including financial ) .. . to accomplish its assigned re—
sporisibilities under the plan. (40 CFR 130.15(d). (In-
sertions supplied).
Plan Content Requirements
An approvable water quality management plan must have 13 principal
components to accord with the provision of 40 CFR 131.10 and 131.11,
namely:
o municipal and industrial treatment works program;
o residual waste management program;
o urban stormwater management program;
o non—point source management program;
o regulatory programs necessary for implementation;
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o financial management program;
o institutional management program;
o schedules and priorities for implementation;
o environmental, social and economic impact assessment;
o local government’s recommendations with respect to
state certification and EPA approval of the plan;
o certification of consistency of the plan with other
relevant plans;
o designation of agencies to implement the plan;
o certification and description of the public partici-
pation program.
Some flexibility exists as to how these 13 principal components may be
organized and presented as outputs of the planning process. However, the
minimum outputs which are to result, are explicitly identified in Sec. 208(b)
of PL 92—500 and regulations (40 CFR 130 and 131) promulgated pursuant to
that Act.
Water quality management planning is essentially single purpose in
nature, that is, to achieve the mandated national water quality goal. The
only economic constraint required to be considered in achieving the goal
is cost effectiveness for facilities. It is emphasized that a most sig-
nificant aspect of water quality management planning is that the plan or
portions thereof must be implementable by designated management agencies
when finally approved by the Regional Administrator, EPA.
Regional or River Basin Planning
Level B
Planning under the aegis of the Water Resources Council was originally
authorized by the Water Resources Planning Act of 1965, PL 89-80. Pur-
suant to Sec. 209 of PL 92-500, Level B plans are to be completed for all
river basins in the United States no later than Janyary 1, -1980. Priority
in developing such plans is to be given to those basins and portions
thereof Which have been designated under Sec. 208 as a result of having
substantial water quality control problems.
Legislative History of Sec. 209, PL 92—500
Water quality management- -planning as authorized and synthesized-from
Sections 208 and 303 (e) of PL 92-500 has a set of attributes that can be
extracted from the statutory provisions and the implementing regulatipns.
In contrast, Level B planning is a concept mentioned in PL 92-500 but not
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defined or explained there, perhaps because Level B is neither a new term
nor a new idea although not specifically defined in PL 89-80. The in-
tensity or depth of detail of planning defined as Level B has been tra-
ditionally referred to as “reconnaissance level” planning. That term does
not, however, give a clue to subject matter or procedures for the conduct
of the planning involved.
The Level B planning concept expressed in Sec. 209 of PL 92-500
appears to have been intended to be a departure from the type of planning
of the same name as previously practiced. Although Congress did not spend
many words on the subject, the committee reports do shed important light
on the meaning of Level B planning in the context of the water quality
management planning programs authorized by PL 92—500. Some inferences can
also be drawn from the position of the Level B provision in the Act and
from its very appearance there. However, since the term “Level B” had
an established meaning prior to the enactment of the Act, it is desirable
to set forth the longer known concept first.
Level B plans have generally identified programs and projects which
would develop the water resources of a particular area or basin for a
variety of purposes. Other objectives have been to gather data, and per-
form analyses which would identify needs and show how projects would meet
them, thereby contributing to economic development, environmental improve-
ment and general welfare. Such plans have generally been development
oriented and have often given water quality either peripheral attention
or none at all.
The legislative history of PL 92—500 gives important clues as to the
coverage of future Level B plans prepared pursuant to Section 209 under
directions developed by the Water Resources Council, as intended by Congress.
However, neither the statute nor the committee reports contain any real
detail. The principal aid to understanding provided by the history is in
terms of the general objectives and value of the expected planning process
and indication of those who should participate.
The Senate Committee Report (No. 92-414) is not informative because
the Senate Bill (S.2770) did not contain any provision comparable to Sec.
209 of the present statute. Accordingly, only the House Committee Report
(No. 92—911) and the Conference Committee Reports (No. 92-1236 and No.
92—1465) are informative. Both are consistent, but the former is longer
and so offers a little more of the flavor from which the intended planning
approach can be interpreted.
Report No. 92—911 states:
The time has long passed when this Nation can afford to
consider each problem on an ad hoc basis. We can no longer
act as if one environmental issue is not related to any
other; after all, the pretense that industrial growth is
unrelated to environmental quality has brought: us to where
we are today. Even an issue so pressing as water quality
cannot be considered or resolved without concurrent con-
sideration of water quantity problems. The Committee
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recognizes that comprehensive planning programs have been
underway for the past 50 years and that they are now under
the aegis of the Water Resources Council.
The Environmental Protection Agency and the Corps of Engi-
neers, along with all other Federal agencies, participate
in the activities of the Council and follow the Council ‘s
directions with respect to comprehensive planning. In
its statement of July 27, 1970, ‘Water and Related Land
Resources Planning,’ the Council provides for develop-
ment of regional and river basin plans (Level B) in co-
operation with State and local interests--such planning
considers both quantity and quality problems, Federal
and non—Federal alternatives in solving those problems,
and is focused on the next 15 to 25 years.. A Level (B)
plan for a basin identifies each water resource project
and each water quality program that should be author-
ized and implemented to attain the water quantity and
water quality objectives extablished for the river basin
plan. Only through such a rational, comprehensive plan-
ning process can we provide a program to cope, on a
sound priority basis, with our water quality problems
(page 97).
Report No. 92-911 also notes that no comprehensive plans for river
basins had been completed since WRC began operations because funds were
lacking, and points to the $200 million:to be authorized under Section
209. In this connection, it is declared that the Level B planning will be
done pursuant to the directions of WRC but that the bulk of the funds are
expected to be transferred to agencies such as EPA, the Corps, and others
to do the actual work on the plans.
EPA was not a member of WRC at the time PL 92-500 was under consider-
ation.
Planning for water quality management is explicitly to be a purpose of
Level B planning which is to take full account of both quality and quantity
considerations. Level B plans are now supposed to emphasize and integrate
both the previous developmental aspects of Level B planning and the en-
vjronmenta]. concerns associated with achievement and maintenance of water
quality to the standards and requirements in effect pursuant to PL 92-500.
Accordingly, it is reasonable to conclude that Level B plans were
conceived by Congress as vehicles for reconciling development and quality
issues in a basin or area, or at least for pointing out divergences or
conflicts that need to be resolved and the alternatives available for
doing so.
Some significance should be given to the appearance of Section 209
in the statute. To do water quality planning of the conventional kind,
including the “comprehensive” water quality planning authorized by Sec. 3(c)
3—18
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of the predecessor Act (70 Stat. 498), it was not necessary to deal ex-
plicitly with the concept and procedures of Level B plans completed or
concurrently under development. Consequently, inclusion of a statutory
provision in the basic federal water pollution control law argues that
henceforth comprehensive water and related land resources plans and com-
prehensive water quality management plans are expected to reflect exami-
nation of both quantity and quality issues.
The legislative history of Sec. 209 could be interpreted to mean
that Congress intended the Level B planning process to provide a frame-
work within which water quality management planning would proceed. However,
it is clear that Congress expected the two planning programs to be carried
out more or less concurrently in areas with significant water quality prob—
leins. Completion of initial plans by designated areawide waste treatment
management planning agencies was scheduled some years before 1980, the
statutory time limit for completion of Level B plans for all river basins
in the Nation. Congress appears to have envisioned that Level B planning
could and should complement the process by which water quality would be
improved and maintained and that the two planning programs should be fully
coordinated.
Level B Planning Process and Plans
The purpose of Level B planning conducted in fulfillment of the mandate
of Sec. 209 must be to provide a comprehensive, interagency and intergovern-
mental process for integrating the planning conducted pursuant to other
sections of PL 92-500, notably Sec. 208, and the several other water and
related land resource planning programs conducted by Federal agencies,
regional entities, the states, and local entities, into a comprehensive
management strategy that would resolve “critical mid-term (15—25 years)
issues and problems” (WRC Proposed Guidelines for Regional or River Basin
Planning [ Level B] March 1976, II,C). The integrated planning would, as
envisioned in the Guidelines “reflect the overall priorities and preferences
of the interested public”.
The language of Sec. 209 establishes the priorities to be observed
by WRC in conducting Level B planning by relating its mandate to the
identification of areas for conducting Sec. 208 planning.:
Sec. 209(a). The President, acting through the Water
Resources Council, shall, as soon as practicable, prepare
a Level B plan under the Water Resources Planning Act for
all basins in the United States. All such plans shall be
completed not later than January 1, 1980, except that pri-
ority in the preparation of such plans shall be given to
those basins and portions thereof which are within those
areas designated under pare graph (2), (3) and (4) of sub-
section (a) of Section 208 of this Act (emphasis supplied).
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WRC’s Proposed Guidelines describe the principal features of the
planning process in these tents:
III. Level B Processes
The Level B process is designed to provide basic data,
inforrna tion, concepts, projections, and comprehensive
water and related land resource plans and decisions for
specific study areas. The Council’s Level B planning
approach includes the following major features:
- proposals to study (PTS) developed for use in
determining merit to commitment of planning
funds (Section III.A. and B.);
- plans of study (Pas) at the beginning of planning
(Section III.D.);
- strong central management (Section III. P.);
- centralized funding (Section III .E.l);
- a first-cut plan published early in the study
for review and feedback (Section III .F .2);
- two—year study effort (Section III.F.2);
- costs reduced by emphasis on judgmental planning
and use of available data (Section III.F.3)
(references added).
The Proposed Guidelines are designed to carry out the “new approach”
to Level B planning which was set forth in WRC’s Second annual Report to
the Congress of the United States on Level B (Section 209) Planning in 1974,
in order to reduce the time and expense required to produce usable Level B
plans. The “new approach” emphasizes reliance on available data and on plans
and programs already developed or under consideration.
The Proposed Guidelines are to undergo a one-year field test. This
will assist in identifying strengths and weaknesses.
Leadership by WRC in conducting and/or sponsoring Level B planning
stems directly from the Congressional mandate. This authority and re-
sponsibility is sunmarized in the Proposed Guidelines in II.A:
II Role of Level B Studies
A. Authority
Multiagency water and related land resources planning
is performed under the guidanöe of the Water Resources Coun-
cil (WRC) by virtue of the 1965 Water Resources Planning Act
(PL 89—80).———
-------
Further specific Congressional direction in water and
land resources planning has been provided in PL 92-500,
Federal Water Pollution Control Act Amendments of 1972,
October 1972. Section 209 of PL 92-500 calls for the
President, acting through the Water Resources Council
(WRC), to prepare Level B plans for all basins in the
United States by January 1, 1980.
The Level B planning process is designed to build a management strategy
to resolve the problems identified in Level A studies, and, presumptively,
to precede and provide the basis for prioritizing project—type implementation
planning (Level C). The Level B plan, thus, is regional in scope, as opposed
to the problem—specific, site-specific Level C plan.
Level B (regional or river basin) planning is directly linked to
the application of the Principles arid Standards for PLanning Water arid
Related Land Resource (s) as a guide to conduct and product of planning
ifl I.B. 1 Activities Covered, of the Standards, as follows:
1. Comprehensive plar4ning. These standards apply to
Federal participation in comprehensive framework
studies and assessments and regional or river
basin planning of water and land resources whether
carried out———
a, by river basin commissions established under
the Water Resources Planning Act;
b. by entities performing the functions of a
river basin commission, including, but not
limited to, such entites as:
(1) Federal—interstate compact commissions;
(2) Federal-interstate interagency cormnittees;
(3) Federal—State coordinating committees;
(4) Federal -State development commissions;
(5) Lead Federal agency with special authori-
zation for comprehensive planning;
(6) Other entities designated by the Council
engaged in comprehensive water and land
resource planning with coordinated Federal
technical or financial assistance.
In formulating plans to meet the multiobjectiveS all al-
ternative means shall be considered, including, but not
limited to, water and land programs to be carried out
directly by the Federal Government, Federal financial
and technical participation in water and land programs
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to be carried out by State or other non—Federal entities,
and Federal licensing activities that affect the develop-
ment, conservation, and utilization of water and land
resources.
WRC Proposed Guidelines are intended to provide a process through which
the national economic development and environmental quality objectives
planning concept of the Principles and Standards can be implemented on a
multifunctional basis under the “new approach”. Under the Principles,
Part V.C., Formulation of Alternative Plans, multiobjective planning is
a key element in the Level B planning process:
Based upon identified needs and problems, alternative plans
( including both structural and nonstructural measures ) will
be prepared and evaluated in the context of their contribu-
tions to the multiobjectives. This involves comparisons
among objectives, and it will be necessary to formulate
alternative plans that reflect different relative emphasis
among the objectives for the planning setting.
The number of alternative plans to be developed for each
planning effort will depend upon complementarities or con-
flicts among specified components of the objectives, resource
capabilities, technical possibilities, and the extent to which
the design of additional alternative plans can be expected to
contribute significantly to the choice of a recommended plan.
Because planning staffs are limited, emphasis should be placed
on examination of those waters and land use plans which may
have appreciable effects on objectives.
With respect to the number of alternative plans there will
be a continuing dialog among the Water Resources Council,
river basin commissions, and other planning groups, em—
phasizing on the one hand the need for national guidelines
and overview of objectives for which alternative plans are
formulated, and on the other the special insights into
local planning situations that field level teams may develop.
Appropriate methods and techniques for estimating beneficial
and adverse effects will be used to provide reliable esti-
mates of the consequences and feasibility of each alterna-
tive plan.
In the cases where the trade offs among objectives are judged
to be significant in the context of either national priorities
or more localized priorities, an alternative plan will be
formulated to emphasize the contributions to each such ob-
jective. One such alternative plan will be formulated in
which optimum contributions are made to the nations economic
3—22
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development objective. Additionally, during the planning
process at least one alternative plan will be formulated
which emphasizes the contributions to the environmental
quality objective. Other alternative plans reflecting
significant trade offs among the national economic de-
velopment arid environmental quality objectives may be
formulated so as not to overlook a best overall plan.
Alternative plans emphasizing contributions to specified
components of the regional development objectives will be
prepared only with advance approval (insertion added).
Under II.B., Objectives, of the Standards, the Water Quality Act of
1965, PL 89—234, the Clean Water Restoration Act of 1966, PL 89-753,
and the water quality goals established by PL 92-500, among other statutes,
are listed as “Major Congressional Directives”. But the Principles and
Standards provide no guidance as to the manner in which the goals and
objectives of PL 92—500 are to be considered in Level B planning. Like-
wise, the Principles and Standards do not indicate how the water quality
standards, effluent limitations, and non—point source controls established
pursuant to the mandates of PL 92-500 and EPA implementing regulations,
40 CFR 130 and 131, are to be treated in the Level B planning process.
The Standards provide, in II.D., Objectives, that:
a. Enhancement of quality aspects of water, land, and
air by control of pollution or prevention of erosion
and restoration of eroded areas embracing the need to
harmonize land use objectives in terms of productivity
for economic use arid development with conservation of
the resources———
is to be considered as a component of the national economic development ob-
jective. As stated in II.F.2.a., “—-an improvement in water quality,
and improvement in the reliability of both quantity and quality--” are to
be evaluated as contributions to that objective. However, the Principles
and Standards are silent as to the base from which an improvement in quality
is to be measured.
WRC’s Proposed Guidelines describe the end products of the Level B
planning process (III. G. 1,2, 3). The minimal information requirements
are:
1. A concise (approximately 100 pages) report for use by the
Congress. As a minimum, the Level B study report must in-
clude the information described below for the nationwide
evaluation process to be carried out by the Water Resources
Council (WRC) and local, State, and Federal participants
as required in Section 102 of PL 89-80.
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a. critical issues, problems,and needs of the
study area;
b. the recoranended plan and alternatives with an
explanation of the selection process;
c. an abbreviated four-account (National Economic
Development F Environmental Quality (EQ)
Social Well—Being (SWB), and Re ional Develop-
ment (RD)) display of the effects of the recom-
mended plan and alternatives;
d. a discussion of the assignments and the time-
table for implementation of program, project,
and management proposals of the study area plan,
thereby setting priorities for the study area;
e. major gaps in data and technology in planning
for study area needs;
f. reconinendations for Level C, special or other
studies necessary that should be undertaken
under separate follow—up authority;
g. a comparison of any alternative economic and
demographic projections used in the Level B
study with the OBERS baseline projections;
h. suirinary of plan formulation rationale and
methodology;
i. an Environmental Impact Statement (EIS) dis-
playing the overall effects of the plan. The
five major requirements of Section 102(2) (c)
of the National Environmental Policy Act (NEPA)
should be addressed in one section with referen-
ces to other parts of the report to avoid dupli-
cation thus making the Environmental Impact
Statement (BIS) an integral part of the report.
2. An executive sumary containing at least the following
parts:
a • a complete concise picture of study effort,
alternative plans treated, and the recom-
mended plan;
b. conclusions and step—by—step actions to
accomplish the reconunended plan;
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C. summary of beneficial and adverse effects
(an abbreviated four-account display) of
implementing the plan;
d. location of additional information and backup
data.
2. Supporting documents or technical papers will be:
a. referenced in the report but will be pro-
vided only with technical review copies
of the study report;
b. maintained for in—office public review
by the river basin commission (RBC) and/or
study participant;
c. available to public at cost, possibly through
National Technical Information Service (NTIS).
WRC Proposed Guidelines offer some generalized direction as to the
relationship of Level B planning with other plans and programs in II.C.
by citing “examples” of other programs that should be integrated into a
Level B study. Use of the term example implies that all relevant plans
and programs are to be used as input to the Level B planning process. The
specific examples cited are:
1. Housing and Urban Development (HUD)--7Ol Studies,
Flood Insurance, Federal Disaster Assistance;
2. Environmental Protection Agency (EPA)--Water Quality
Studies, i.e., Sec. 208 and 303(e);
3. Federal Energy Administration (FEA)--Project Inde-
pendenóe;
4. Interior--Land Use, Fish and Wildlife, Recreation
Special Studies, i.e., Total Water Management, Out-
door Recreation, Endangered Species;
5. Commerce——Coastal Zone, Commercial Fisheries, Weather
Modifications;
6. corps of Engineers (COE)—-Urbafl Studies, Basin Studies,
Flood Plain Management Services;
7. United States Department of Agriculture (USDA)--Small
watershed, Resource Conservation and Development, Rural
• Development, Type IV River Basin, National Forests;
8. Energy Research and Development Administration (ERDA);
3—25
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9. Nuclear Regulatory Commission (NRC);
10. Department of Transportation--Water Transportation.
The outputs of Level B planning to be considered in water quality manage-
ment planning are identified in 40 CFR 130.34 (c) and were discussed pre-
viously (pages 3—13).
WRC Guidelines (13) for conducting Phase II, Specific Problem na1ysis,
of the 1975 National Assessment, September 1974, relate the Assessment pro-
gram to Level B planning under activity Three and Four and in subactivities
12,13,14,15,16, and 17, and graphically in Figure 2 of the Phase II Guide-
lines. The National Assessment is not of Level B scope or necessarily
comparable with a Level B study.
Briefly, the Assessment is to identify problem areas and issues, re-
late these areas and issues regionally as a predicate to evaluation of the
need for Level B planning, and prioritize recommendations for Level B
planning based on the urgency and/or severity of identified problems It
may also serve to identify needed Level C or special studies.
As identified in Section 208 of PL 92-500, the objective of water
quality management planning is to encourage and facilitate “--development
and implementation of areawide waste treatment management plans--” in
areas having substantial water quality control problems as the result of
“——urban—industrual concentrations or other factors——”. In this sense,
208 planning might be considered as a means of solving problems envisioned
in the National Assessment Guidelines definition of “problem areas”.
Under the Assessment Guidelines, it is envisioned that several such “prob-
lem areas” might appropriately be joined in a Level B planning area recom-
mendation. This relationship is somewhat modified by the judicial require-
ment that 208 planning be conducted in non-designated areas to achieve a
management plan for water quality control but the conceptual relationship
in geographic scope seems clear.
Scheduling of water quality management planning follows a process
established in PL 92—500, for the various steps of designation, inter-
action between State, EPA and planning entities, and plan formulation,
review and approval. These specifications in the Act are amplified and
reinforced in the EPA regulations.
WRC Proposed Guidelines for Level B planning are much n re generalized,
with the only requirement in Section 209 of the Act being ccmpletion of Level
B planning for the entire United States by January 1, 1980, a deadline which
seems wholly unrealistic, in view of the limited funding so far provided.
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Comparison of Water Quality Management
Planning and Level B Planning ‘Programs
The Proposed Guidelines which have been prepared by WRC for field evalu-
‘ation in the Level B planning program and the EPA regulations and guide-
lines relating to the continuing planning process in state and designated
planning areas differ in substantial respects. As shown in Appendix B
the two sets of Guidelines are not parallel documents and deal only with a
few common points. The comparison has been performed by careful examin-
ation of the Level B Proposed Guidelines to identify any instructions
contained therein which would cause Level B planning to complement or to
conflict with state and areawide water quality management planning and i m-
plementation carried out pursuant to 40 CFR 130 and 131. The following
are specific points of possible incompatibility:
A. Reliance on available information and hasis on
judgmental planning — Water quality management ac-
tivities, including planning and permitting programs,
are heavily oriented toward implementation. Pro-
grams are dependent upon precise and complete listing
of discharges, detailed analyses of water quality and
extensive management investigations. The Level B Pro-
posed Guidelines emphasize and encourage the use of
judgmental planning to minimize costs and study time
(Sec. 111(F) (2)). Level B plans are to be based on
review and use of available material accepting any
gaps in information and data. Detailed studies such
as are necessary for “implementation studies” are
specifically described as “inappropriate for studies
of Level B intensity.”
Data and information available for use in Level B
planning may be insufficient to provide the types,
amount, and detail of information on which water
quality planning and implementation decisions must
be based. As constrained by the WRC Proposed Guide-
lines, Level B studies in some cases might be unable
to consider the full range of present and potential
water quality problems, their ramifications with re-
spect to the management of water and related land
resources for other purposes or all of the potential
trade—offs, because of lack of immediately available
information.
B. Selection of Level B focusses — The Proposed Level B
Guidelines describe the other programs which should be
“integrated into a Level B study including many which
are linked through various interagency agreements pro-
viding for coordination of planning, particularly with
respect to land use (Sec. 11(c)).
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The Guidelines leave great flexibility to the Level B
study team in selecting what will, in fact, be considered.
The instructions provided with respect to selection of
Level B study focusses make no mention of how other pro—
grains are to be considered nor identify any minimum points
which Level B studies will address (Sec. II (A) (2), Sec.
P1(D) (5)). This omission could result in Level B plan-
ning not considering water quality except as an incidental
issue. Contrarywise, PL 92—500 and EPA regulations and
guidelines are specific as regards problems that water
quality management planning must address.
C. Selection of the recommended plan — The Proposed Level
B Guidelines (Sec. 11(C)) state:
Thus, management strategies integrating the
appropriate natural resources programs, and
considering institutional and other policy
issues, are selected to best reflect the
overall priorities and preferences of the
public.
This approach to selection of management strategies does
not give specific direction to the Level B planner as to
other programs that are to be maintained whole to the
extent that they exist at the time of Level B planning,
or that requirements of other important programs are to
to be considered explicitly. The direction to select
management strategies which “best reflect” overall public
priorities suggests a high degree of flexibility for the
planner to decide the relative merits of differing pro-
grams.
Regulations and guidelines affecting the formulation of
water quality management plans are much more specific
than those for Level B studies. Plan formulation must
address at least those point and non—point sources of
pollutants specified in Sec. 208(b), provide cost—ef-
fective sblutions meeting 1983 goals, and be demon-
strably effective. Trade-offs in the plan formulation
process do not consider what is to be accomplished but
rather the priority, method and responsibility for ac-
complishment to meet established water quality standards.
Entities Involved
Both Level B pl ning and water quality management planning and imple-
mentation involve significant numbers of persons respresenting various in-
terests and sources of information. Participants can be generally divided
into entities responsible for planning and implementation and those which
assist in the activities.
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The variation of the key participants in the planning process has
import with respect to coordination of the several programs. Only EPA
and the State water quality control agencies provide the across-the-board
participation in all water quality management programs. Yet, neither is
always included in the management structure for Level B studies. Of equal
significance, State agencies responsible for water resoui ce planning and
development and for allocation of water resources are not always included
in the management structure for water quality management planning. Par-
ticipation by all responsible state agencies in both planning programs
is necessary to obtain the requisite degree of coordination.
EPA regulations (40 CFR 130.13(c) (1) through 15)) require that the
agency designated by the Governor of a state to develop an areawide water
quality management plan for a designated area shall:
1. be a representative organization whose membership
shall include, but need not be limited to, elected
officials of local governments or their designees
having jurisdiction in the designated areawide plan-
ning area;
2. have waste treatment planning jurisdiction in the
entire designated areawide planning area;
3. have the capability to have the water quality manage-
ment planning process fully underway no later than
one year after approval of the designation;
4. have the capability to complete the initial water
quality management plan no later than two years
after the planning process is in operation; and
5. have established procedures for adoption, review,
and revision of plans and resolution of major is-
sues, including procedures for public participation
in the planning process.
For the non—designated geographic areas of the State, the Act requires
the State to undertake water quality management planning (Sec. 208 (a) (6)).
The Governor is required to designate the State planning agency to be re-
sponsible for the conduct and coordination of the required planning in both
the designated and non-designated planning areas (40 CFR 130.12).
In contrast, the number and interests of participants in Level B plan-
ning is much more fluid. WRC Proposed Guidelines anticipate that a river
basin commission would take the lead in Level B study management. A plan-
ning board or coordinating committee is “usually” established, chaired by
the study manager, and composed of representatives from “those Federal
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and State agencies involved with major water and related land programs in
the study area” (Guidelines, I II .D.). Presumptively, agency representation
will be the same as or compatible with the interagency groups created to
conduct the National Assessment activities.
The planning board or coordinating committee is responsible for:
developing study policies, and schedules; resolving plan-
fling issues; and directing plan formulation. •Each member
is responsible for the quantity, quality, and timing of
his respective agency ‘s technical inputs in accordance
with the Plan of Study. The group meets periodically in
formal sessions and at other times as determined by the
study manager.
This group traditionally employs a concensus rule to make
decisions. The State and agencies should be represented
by individua k knowledgeable about the study area and capa-
ble of representing State or agency policy - (Sec. 111.2. a.)
The study manager is selected by and is responsbile to the river basin
commission where one exists or to WRC. In areas where no river basin com-
mission has been formed, the WRC consults with the states involved prior to
selection and appointment of the study manager.
Although WRC Proposed Guidelines provide for creation, optionally, of
a Citizens Advisory Committee to provide input to Level B studies (Guide-
lines III.D.2.), no representation of local elected officials is required
in contrast to the EPA regulations which stipulate representation in desig-
nated areawide planning entities.
Similarly, the policy advisory committee described in the EPA regulations
(40 CFR 130.16(b) and Cc)) is mandatory, and, further, must include a
majority membership of local elected officials:
(b) Local governments within the State are to be en-
couraged to utilize existing, or develop, appropriate
institutional or other arrangements with local govern-
ments in the same State in the development and imple-
mentation of water quality management plans, or portions
thereof.
(C) The State shall provide a mechanism for meaningful and
significant results from local, State, interstate, and
Federal units of government. As an element of this
mechanism, a policy advisory committee(s) shall be
established to advise the responsible planning or im-
plementing agency during the development and implemen-
tation of the plan on broad policy matters, including
the fiscal, economic and social impacts of the plan.
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Use of existing policy advisory committees is encouraged;
however as a minimum, this policy advisory committee
shall include a majority membership of representatives
of chief elected officials of local units of government.
The planning organization for Level B planning, including the study
manager, is appointed for the two-year period during which the plan is to
be developed. Interagency task forces are envisioned by WRC Proposed Guide-
lines as the mechanism for carrying out specific tasks not within the capa-
bility of the planning staff.(Guide].jnes, III.2.d.).
The planning entity designated by a Governor for 208 planning, on
the other hand, is to be in place with an existing planning capability.
This capability is supplemented by funding consultant contracts as a means
of accomplishing the work laid out in the work plan. Consultant contracts
can likewise be funded under Level B studies.
Planning and Implementation Processes
The processes for conducting Level B and water quality management planning
and implementation vary considerably.
Study Initiation - Level B studies are initiated subject to petition
by interested states, river basin commissions and others. Requests for
studies generally exceed the funds available and WRC screens requests and
selects those to be undertaken; EPA is involved in the screening and
selection process. In contrast, water quality management studies are
mandated and the principal question involves identification and designatton
of the agency(s) to be responsible for conduct.
Study Definition - The nature of a Level B study is determined
in the field subject to broad guidance from WRC. Outputs are not speci-
fied. Water quality management planning is defined with respect to content
and outputs and specific guidance is provided with respect to each. Both
types of studies proceed through a progressive refinement of the description
of work prior to beginning extensive planning efforts.
Study Objectives — Objectives relevant to all water resources planning
undertaken by WRC, river basin commissions and certain other organizations
are stated in the Objectives portion (Part II) of the Principles and Standards
for Planning Water and Related Land Resources as follows:
The overall purpose of water and land resource planning
is to promote the quality of life, by reflecting society’s
preferences for attainment of the objectives defined below:
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A. To enhance national economic development by
increasing the value of the Nation’s output
of goods and services arid improving national
economic efficiency.
B. To enhance the quality of the environment by
the management, conservation, preservation,
creation, restoration, or improvement of the
quality of certain natural and cultural re-
sources and ecological systems.
The definition of Level B studies provided in the Levels of Planning
portion (Part C) of the Principles and Standards for Planning Water and
Related Resources makes clear that Level B studies are intended to “re-
solve complex long—range problems”, “involve Federal, State, and local
interests in plan formulation” and “identify and recommend action plans
and programs to be pursued by individual Federal, State, and local
entities”. Section IV of the Proposed Guidelines, Relationship of Level
B Studies to Other Studies adds to the range of Level B study objectives.
It implies the objectives of resolving “near—term” and “mid—term” issues
and problems.
Objectives of the continuing planning process for water quality manage-
znent are to:
40 CFR 130.1(c). ..assure that necessary institutional
arrangements and management programs are established
to make and implement coordinated decisions, designed
to achieve water quality goals and standards; to de-
velop a Statewide (State and areawide) water quality
assessment, and to establish water quality goals and
water quality standards which take into account over-
all State and local policies and programs, including
those for management of land and other natural resources ;
and to develop the strategic guidance for preparing the
annual State program plan required under Section 106 of
the Act (emphasis supplied).
Water quality management planning objectives are described with re-
spect to the objectives of the plans which are to result. Regulations
for the preparation of water quality management plans state:
40 CFR 131.10(a).. .the primary objective of the water
quality management plans shall be to define the pro-
grams necessary to achieve the 1983 national water
quality goal established in Section 101(a) of the
Act.
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Whereas Level B planning objectives include a concurrent consideration
of multi—functional problems over several time frames to formulate a
plan, water quality management planning is directed specifically to a short-
term, single function objective.
Study Conduct - Both types of studies are conducted by a number of
participants structured as work groups or task forces with a single agency
responsible for supervision. Level B studies are based on available infor-
mation, emphasize breadth of study and stress multi-objective and multi—func-
tional solutions. Water quality management studies require detailed investi-
gations, emphasize the depth of investigation for a single objective and
stress single purpose solutions, i.e. to meet effluent limitations and
water quality standards.
Evaluation Procedures — Alternative Level B plans are evaluated on the
basis of trade—off s among their effects on national economic development
and environmental quality with regard also for regional economic develop-
ment and social well being. Water quality management plans are evaluated
on the basis of cost—effectiveness in meeting established objectives and
consideration of the social, economic and environmental impacts of alterna-
tive plans.
Plan Approval - Level B plans are approved by planning participants,
river basin commissions and/or states, depending on the existing insti-
tutional structure. Water quality management plans are approved by Gover-
nors and Regional Administrators, EPA.
Plan Implementation — No specific process for implementation is re-
quired for Level B plans. However, a priority list of projects recommended
in the Level B plan must be submitted with later agency requests for study
or project funding to follow. Approved water quality management plans become
a part of the State’s plan for water quality management, influence availa-
bility of funding and have other facets mandating implementation. Imple-
mentation is also backed by Federal control of the NPDES program. The
essential difference is that a water quality management plan must be imple-
mentable by the designated management agencies once it is finally approved
by Regional Administrator, EPJ ,whereas implementation of a Level B plan may
be dependent on subsequent decisions.
Plan Updating — Level B plans are updated as required. Water quality
management plans are part of a continuing planning process providing at
least annual updates of important parts of the plan.
Types and Detail of Study products
Many of the products of water quality management planning are mandated
by statute. Others are specified in regulations and administrative memoranda.
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The categories of products include lists, program descriptions, analyses,
and agencies and measures available for implementation. They have been
identified in detail on pages 3-5 and in Table 1.
A comparison of required water quality management plan contents with
possible Level B planning outputs is presented in Table 1.
Level B study products include a brief (100 page) report for use by
Congress, an executive suimnary and supporting documents or technical papers
(Sec. 111(G)). In addition, various reports containing backup data are
usually prepared.
The outputs of the Level B and water quality management planning
programs as described in the several regulations arid guidelines have no
inherent conflict with one another. Water quality management planning
product descriptions are much more explicit and detailed. However, the
general character of the Proposed Level B Guidelines does not prohibit
their interpretation in a way compatible with water quality management
planning. As an example, the “assignment of implementation authority”
to emerge from Level B planning could be envisioned to include the infor-
mation on legal authority, financial capability and other points required
in water quality management plans. Likewise, the “further studies” element
of Level B plans could be comparable in detail to the continuing planning
program to be established in water quality management planning. In fact,
this may not happen for several reasons including:
A.. lack of resources in Level B planning to work in
detail over a large geographic area;
B. lack of resources in Level B planning to address
several functional areas in detail;
C. specific provision of the Level B Guidelines that
plans are to be based on readily available data
(Sec. 111(F) (2)), which may be grossly deficient
as regards certain quality aspects.
Urban Studies Program Corps of Engineers
The Urban Studies Program (12) of the Corps of Engineers (COE) provides
a range of urban water resources plans compatible with the comprehensive
urban development goals of the study region. Flood control, flood plain
management, municipal and industrial water supply, wastewater management,
bank and channel stabilization, lake, estuarine and ocean restoration and
protection, recreation, and regional harbors and waterways in an integrated
metropolitan setting are included in these studies where applicable. The
program initiated in 1972 was the Corps’ response to the need for relevance
of its programs in the context of urban America. Plans developed under this
program were to be conceived in a manner to meet applicable Federal, State
and local requirements for implementation.
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The wastewater management portion of the Urban Studies Program was
formalized by an EPA-COE agreement first entered into in November 1974,
and published in an extended version in the Federal Register Vol.
40 No. 11, January 16, 1975). This agreement defines the relationship
between areawide waste treatment management planning conducted by both
agencies, sets forth coordination and funding procedures for Corps Urban
Studies in areas designated for areawide planning, and provides for Corps
of Engineers technical assistance in areawide planning outside the Urban
Studies Program.
Major points made in this agreement are:
Planning by the Corps of Engineers under the provisions
of section 208 will be to the level of precision required
by the Administrator for approval of any plan certified
and submitted to him by any Gove!rnor under Section 208.
The existence of an urban study resolution shall not
preclude approval of a 208 designation for an area,
nor shall approval of a 208 designation for an area
preclude funding for an urban study.
In no case shall there be a duplication of Environmental
Protection Agency and Corps of Engineers funding for the
same specific task in development of a wastewater manage-
ment plan or planning process under Title II of the Federal
Water Pollution Control Act Amendments of 1972.
All section 208 planning activities undertaken by the Corps
of Engineers will be set forth. in a plan of study approved
by the designated local planning agency, the State and the
Environmental Protection Agency Regional Administrator.
Such planning will be in accordance with all applicable
laws, Environmental Protection Agency guidelines, criteria,
and regulations, as well as applicable State and local laws
and regulations.
Technical assistance provided by the Corps of Engineers may
include the development of alternative plans or portions of
plans for meeting the provisions of section 208(h ). The de-
cision to adopt or implement specific alternatives or pro-
posals generated by this planning is the responsibility of
the designated planning and the designated management
agency (ies).
The outputs of the Urban Study Program are sets of alternative urban
water resources plans, priced and evaluated sections of each plan to meet
short range (20 years) needs, phased early action programs and if appro-
priate, proposals for Congressional authorization of selected pro)eCts
within that early program publicly selected “best”.
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State, Regional and Local Water Plans
In addition to the aforementioned Federal programs, states, regional
authorities and local entities, large and small, are engaged in water and
related land resources planning. State water plans range from framework
type plans like those in North Carolina to detailed water plans as developed
in Texas or California. While greatly varying in detail and scope, most
state water planning is comprehensive in the sense of looking at most if
not all of the facets of water planning simultaneously. Much regional and
local water planning is single purpose such as planning by irrigation or
drainage districts or water supply planning by metropolitan authorities
or towns.
Coordination of these planning programs with water quality management
planning under Sec. 208 is needed if these state, regional or local plans
have effects on the water quality directly through discharges or indirectly
through changes in flow volumes or discharge locations, or if these plans
are based on assumptions of existence and implementation of 208 plans.
There is such a wide range in state, regional and local water planning
that general rules of coordination and cooperation cannot be established.
Each situation must be treated as unique and coordinating mechanisms
developed for each specific case.
Literature Review
Water Policies for the Future , National Water Commission, June 1973.
The report recommends that an expanded program of planning for regional
water quality management (208) should be accomplished for the entire country
coordinated with planning under the Water Resources Planning Act (Level B)
(p. 84 and p. 107). Further, the report recommends amending the FWPCAA of
1972 with respect to regional or metropolitan waste management agencies
to give the states authority for decisions regarding the form of local govern-
ments (p. 108). The report recommends encouragement of coordinating mechan—
isnis such as Title II river basin commissions in relating water and land use
planning (Recommendation No. 10—1, p. 369). The emerging 208 program is
described in the report on page 453.
Report to the Congress by the National Commission on Water Quality , March 1976.
The Commission recommended (VI, p.lO) that areawide waste management
plans include an acceptable strategy for mitigating effects of discharges
from irrigated agriculture. The report cites the reliance on planning as
the strategy tool for relating the various programs under PL 92-500 but
finds that it has not functioned in that manner (p. 29).
State and Areawide Management (SAM) Guidance Memos , Environmental Protection
Agency, various dates by subject (March 1975 to April 1976)
The memos provide guidance by EPA on the entire spectrum of the 208
planning process including relationships of 208 with other programs, defi-
nition of state roles, technical planning input, interagency coordination,
and procedures for 208 planning in Indian reservations.
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Alternative Institutional and Financial Arrangements for Areawide Waste
Treatment Management , Harvey 0. Banks, Consulting Engineer, Inc., and H.
James Owen, Consulting Engineer, January 1974.
The report describes the institutional and financial approaches to 208
planning in selected case study areas, and recommends actions by EPA to
assist local and state governments conducting areawide planning.
208 Areawide Waste Treatment Management Seminar , Personal notes, November 6,
7, 1975 and February 2, 3, 1976. Jointly sponsored by the Environmental
Protection Agency, Region VI, and the University of Texas at Dallas.
The seminars were conducted by selected faculty and EPA representatives
to provide direction to formulation of 208 planning in designated areas.
Presentations included technical discussions of source and nonpoint source
pollutant control, and analyses of legal and institutional factors.
Areawide Water Quality Planning and Management, A Proposal for Texas, yexas
Texas Advisory Commission on Intergovernmental Relations, September 1974.
The Texas Advisory Commission on Intergovernmental Relations was cre-
ated to provide research, advisory, and information capability in support
of public officials arid private citizens for the purpose of improving
cooperation between state and local governments and between the state and
federal governments. This report was prepared in this context to provide
a detailed analysis of Section 208 and federal regulations promulgated
pursuant thereto, and to propose a coordinated state—regional—local program
for implementing areawide planning in Texas.
Urban Stormwater Management and Technology: An Assessment , Metcalf arid Eddy,
Inc.,Western Regional Office. Study sponsored by the Environmental Pro-
tection Agency, December 1973.
The report details an investigation and assessment of promising,
completed, and ongoing urban stormwater projects, representing state—of—
the-art in abatement theory and technology. Although not exclusively pre-
pared for areawide planning, the study was designed to provide planning
input on control of stormwater pollution in planning and in the construc-
tion grant program.
A Method for Assessing Rural Non-point Sources and its Application in Water
Quality Management , Ohio-Kentucky-Indiana Regional Councils of Governments,
September 1975.
The report presents a model to estimate quantity and quality of runoff
from predominantly rural watersheds for use by planners/engineers. The model
is used to compute land surface erosion and to provide load estimates of
sediment, biochemical oxygen demand, total nitrogen, and total phosphorus.
The model can be used to select alternative cropping and management combi-
nations to limit erosion and nutrient locations within acceptable, levels.
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REFERENCES
1. U.S. Congress. Federal Water Pollution Control Act , as amended,
Public Law 92—500, 92nd Congress. October 18, 1972.
2. Grants to State and Designated Areawide Planning Agencies - Con-
ditions, Policies and Procedures . 40 FR Part 35, Subpart A,
Section 35.200 through 35.240 (40 FR 55321). November 28, 1975.
3. Policies and Procedures for Continuing Planning Process . 40 CFR Part
130 (40 FR 55334). November 28, 1975.
• ! reParation of Water Quality Management Plans . 40 CFR Part 131 (40
FR 55343). November 28, 1975.
5. U.S. Environmental Protection Agency. Guidelines for Areawide Waste
Treatment Management Planning . Washington, DC. August, 1975.
6. U.S. Congress. Water Resources Planning Act . Public Law 89-80,89th
congress. July 22, 1965.
7. U.S. Water Resources Council. Proposed Guidelines for Regional or
River Basin Planning (Level B) ; for field evaluation; subject
to revision. Washington, DC. March 1976.
8. principles and Standards for Planning Water and Related Land Resources .
38 FR 24778.
9. U.S. Environmental Protection Agency. State Continuing Planning Pro-
cess Handbook . Washington, DC. December 1975.
10. U.S. Water Resources Council. Second Annual Report to the Congress
of the United States on Level B (Section 209) Planning . Wash$ng-
ton, DC. 1974.
11. U.S. Water Resources Council. Water Resources Council Policy State-
ment No. 1, Water and Related Land Resources Planning . Washington,
DC. July 22, 1970.
12. U.S. Department of Defense, Corps of Engineers, Department of the Army.
Urban Studies Program . 33 FR Part 264 (39 FR 24754). July 5, 1974.
13. U.S. Water Resources Council. 1975 Assessment of Water and Related
Land Resources; Guidelines for Conducting Phase II Specific Prob-
lent Analysis . September 1974.
14. Senate Report (Public Works Committee) No. 92—414, October 28, 1971
[ to accompany S. 2770].
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15. House Report (Public Works Committee) No. 92-911, March 11, 1972
(to accompany H.R. 11896].
16. Senate Conference Report No. 92-1236, September 28, 1972 (to accompany
S. 2770].
17. House Conference Report No. 92—1465, September 28, 1972 [ to accompany
S. 27701.
18. U.S. Congress. Safe Drinking Water Act . Public Law 93-523, 93rd con-
gress. 1974.
19. Drinking Water Standards Implementation . 40 cFR Part 142 (40 FR 33232).
August 7, 1975.
20. U.S. Environmental Protection Agency, Draft Guidelines for State and
Areawide Water Quality Management Program Development . February 1976.
3-39
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CHAPTER 4
CASE STUDIES
The conclusions and observations resulting from thi study are based
in large measure upon investigations of two case studies. Criteria for
selection of the case studies were:
A. Relative completeness and availability of a Level B
product prepared under the “New Approach”;
B. Likelihood of access to the principal participants
in the Level B study;
C. Existence within the Level B study area of a desig—
nated 208 area and areawide planning organization,
preferably one which had at least completed a plan
of study;
D. Representativeness, to the extent possible, of other
areas for which Level B studies have been or may be
undertaken;
E. Diversity with respect to character and interests of
the area, hydrologic characteristics, and types of
problems related to water quality and water use.
Six possible case studies were evaluated. These are listed and briefly
described in terms of the above criteria in Appendix A. The two case studies
selected with approval of the Project Officer and Project Advisory Committee,
were:
Central Snake River Basin, Idaho, with the designated
Boise 208 area; and
Monongahela River Basin, West Virginia, Maryland and
Pennsylvania, with the designated Pittsburg 208 area.
Representatives of the staffs of federal, state and areawide agencies
engaged in water and related land resource planning for each case study area
were interviewed to elicit information concerning:
A. Perceptions of the objectives, scope, level of detail
and values of the several types of planning under
consideration and the reasons therefor, particularly:
Sec. 303(e), PL 92—500;
Sec. 208, PL 92-500, for both designated and non—
designated areas;
Level B;
USCE Urban or other studies (where applicable);
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B. Perceptions of the types, significance and extent of
the interrelationships and interdependencies between
water quality management planning under Sec. 303 (e)
and Sec. 208, and Level B planning and other water
resources planning activities; perceptions of the
differences between these several types of planning
and their results, and reasons therefor;
C. Extent to which and the manner in which established
water quality standards and the objectives and
mandates of PL 92-500 are being or should be taken
into account in water resources “quality” planning;
D. Status of planning activities;
E. Knowledge of WRC proposed Guidelines for Regional or
River Basin Planning (Level B) and their significance;
F. Knowledge of EPA Water Quality Management Planning
Regulations and Guidelines and their significance;
G. Compatibility of Level B Guidelines and EPA Regu-
lations and Guidelines; and, if considered incom-
patible, what changes might be made to improve
compatibility;
H. Value of Level B planning to water quality management
planning;
I. Desirable or necessary inputs from Level B planning to
208 planning (designated and non-designated area), and
vice versa;
J. Coordination among the several planning agencies, present
effectiveness and possible improvements;
K. Use of common data base, projections and assumptions;
L. Perceptions of differences in requirements for imple-
mentation of Level B and 208 plans and their signif i-
cance;
14. Extent to which nonpoint pollution sources could or
should be taken into account in Level B planning;
N. The desirable sequence of Level B v. 208 planning;
0. Public participation in planning;
P. Availability of additional reference materials (and
acquistion).
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CENTRAL SNAKE RIVER BASIN
Overview
Contrary to expectations when the Central Snake Case Study was
selected for analysis, coordination between the several planning programs
underway there was less than the good exan ple desired. Particularly,
interagency relations appeared poor between the Department of Water
Resources which is providing leadership for the Level B study and the
Department of Health and Welfare which has water quality planning and
management responsibilities.
Information derived from the interviews conducted indicate that
inadequate coordination of programs between the agencies has adversely
affected planning done to date. The Level B study was undertaken in
substantial part on account of water quality problems but does not
address water quality for the apparent reason that the anticipat:ed
input on this topic by the Department of Health and Welfare was iot
provided, notwithstanding that the latter was a member of the Level B
Study Team.
Description of the Case Study Area
The Snake River is the largest tributary to the Columbi River. It
rises in Wyoming at Jackson Lake, within the boundaries of ( rand Teton
National Park. The river winds west for a thousand miles, n ostly through
Idaho, until joining the Columbia River in southwestern Washington. The
Snake River Basin encozr asses an area of 108,000 square r len, including
about 90 percent of Idaho’s total area. The Basin has vast resources of
land and water and relatively small population.
Considerable development has taken place in the Snake River Basin
for hydroelectric power and irrigation. Flows are heavily appropriated.
The Basin includes national parks, wilderness and primitive areas, and
wild rivers which make it a nationally significant recreational area.
It is also one of the few phosphate producing areas in the United States.
The Snake River Basin includes parts of Wyoming, Utah, Nevada, Oregon
and Washington, giving rise to interstate considerations in the manage-
ment of the Basin’s resources. The principal issues in interstate
management are the control of water levels in Jackson Lake to meet recre-
ational needs in Grand Teton National Park and irrigation needs in Idaho,
consideration of recreational opportunities in the Hell’s Canyon area along
Idaho’s western border, and provision of minimum streamfiows at the
Washington border. Intrastate issues pertinent to Idaho include manage-
ment of the Snake River Plain which is a major aquifer, and allocation
of river flows between instream and other uses (1?).
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The Snake River Basin has been divided for water resources planning
purposes into three parts identified as the Upper, Central and Lower Snake
Subareas (River Basins). The Central Snake River Basin encompasses the
southwestern portion of Idaho and extends from near Twin Falls to below
the confluence of the Snake and Powder Rivers. The Boise River is one
of the principal tributaries to the Snake River in that reach.
The economy of the Central Snake River Basin is largely based on agri-
culture although Boise is a regional center for commerce and manufacturing.
about a third of a million acres are presently irrigated within the area
and additional large amounts of land are suitable for irrigation develop-
ment if provided with a dependable water supply. Idaho’s most heavily
urbanized area lies within the Boise River Basin. Larger communities
there include Boise, Nampa and Caidwell which, in 1970, had populations
respectively of 97,393, 20,786 and 14,219. Ada and Canyon ( unties,
which include those communities, had populations respectively in 1970
of 112,000 and 61,288.
The Type I Columbia-North Pacific Region Comprehensive Framework Study
which was completed in 1972 under the auspices of the Pacific Northwest River
Basins Commission (PNRBC) pointed out the hydrologic complexity of the
Snake River and the difficulties in water resources management due to the
number of storage reservoirs and other developments as well as the extensive
opportunities and needs for both consumptive and non—consumptive water use
(9E ,F). It also noted the need for an integrated study of the Boise River
to determine the adequacy and optimum use of water resources and control
facilities.
Water quality problems in the Central Snake River Basin identified in
the Type I Study (lE,M) included the following:
— potential for dritical low flow conditions brought
about by ground water withdrawals;
— critical seasonal oxygen problems in the Snake and
Boise River Basins;
— settling and floating solids below the mouth of the
Boise River;
— serious bacteriological pollution of the Snake River
upstream from Payette, Idaho, particularly during
summer months;
— excessive aquatic growth caused by natural and man-
made sources of nutrients;
- need for updating water quality standards;
- conflicts between water quality and developments for
power, irrigation, and flood control;
— erosion and sedimentation;
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— anaerobic decomposition of settled organic materials
in Brownlee Reservoir;
— logging practices;
— mining practices;
— heavy waste loads from Boise;
— feedlot drainage in the Boise area;
— irrigation return flows; and
— critical low flows due to flow stoppages for
maintenance work on the Lucky Peak Dam outlet.
Large portions of the streams in the study area are water quality limited
(3C). Major sources of pollution according to EPA (2T) include incomplete
waste treatment by municipalities and industries, agricultural practices,
livestock, and erosion caused by excessive irrigation. Storm water runoff
is also a source of problems in the urbanized areas in and around Boise,
Naxnpa and Caidwell. The most serious pollutants resulting from these
sources are suspended solids, phosphorus, coliforms, and pesticides (3S).
In spite of these conditions, EPA interpreted the water quality conditions
in the Snake River Basin as near optimum level, given existing development
and technology (lN).
Contractor’s Observation No 1 .
Serious problems exist in the Central Snake River Basin with
respect to water quality, irrigation and other functions. The
available water resources are insufficient to take advantage
of opportunities for economic development and still meet water
quality and other environmental objectives. Further irrigation
development will deplete flows and simultaneously spur secondary
economic activities and population increases. A significant
portion of food processing, transportation and other indus-
trial, commercial, and population growth stemming from new
irrigation developments is likely to take place in the Boise
area. Increased waste production from these added sources and
increased water supply requirements would exacerbate water
quality problems.
Since waters of the Basin are largely water quality limited,
any further development of irrigation would probably need to be
accompanied with stringent regulatory controls to limit increases
in nutrients, fertilizers, pesticides, sediment and other pol-
lutants. At the minimum, proposals for development should
give careful consideration to water quality impacts.
Water quality management problems in the area are also re-
lated to considerations of ground water management, use of
available storage, and numerous aspects of water use both up-
stream and downstream of the Central Snake River Basin.
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Several planning programs relevant to the purposes of the case study
are now underway in or affecting the Central Snake River Basin including:
o Central Snake Level B study;
o Water quality management planning in nondesignated
areas pursuant to the State Continuing Planning
Process;
o Water quality management planning in the designated
area of Ma and Canyon Counties;
o Boise Valley Study, a Corps of Engineers’ Urban
Studies project;
o State Water Plan; and
o State Water Permit Administration.
Description of the Central Snake Level B Study
The Central Snake Level B Study had its genesis in the Type I study
completed earlier. That study found that water pollution control needed
an effective and coordinated regionwide program for waste control and
treatment, flow regulation, and land use management (iF).
Pursuant to the findings of the Type I Study, the PNRBC adopted a
Plan of Study for preparing a Coordinated Comprehensive Joint Plan for the
Pacific Northwest (CCJP) (11). The CCJP was intended to be a supplement to
the Western U.S. Water Plan which was being prepared by the U.S. Department
of the Interior. It was also intended to provide a basis for the preparation
of schedules of priority by the PNRBC and as a guide for implementation
by the Commission’s member agencies. Level B studies were to be performed
under the Plan of Study for a number of areas including the Central Snake
River Basin. The Level B studies were to be conducted by federal-state
study teams, organized on a state basis with state leadership, under the
general management of the Pacific Northwest River Basins Commissions.
The Pacific Northwest River Basins Commission’s adopted Plan of Study
for the Comprehensive Joint Plan identified the key points to be addressed
in the several Level B planning programs. For the Central Snake, the
Level B Study was to address instream uses, system effects of varying
water uses, effect of improved water management on other water use functions,
and water quality including the possibility of additional releases from
storage for water quality purposes. Legal and institutional restraints
on implementation of recommendations were to be considered (1M). The Plan
of Study for the CCJP was modified by the PNRBC in 1973 due to funding
limitations. However, the Central Snake Level B Study was continued
with “...emphasis on natural environment, related lands, water quality,
fish and wildlife, recreation, and irrigation” (1K).
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The Level B Study of the Central Snake is being performed by a
federal-state study team chaired by a representative of the Idaho Depart-
ment of Water Resources. The study team includes representatives of seven
Idaho state agencies, eighteen federal agencies arid five other organi-
zations. Included among these in addition to the Department of Water
Resources are the Idaho Department of Health and Welfare; Idaho Division
of Budget, Policy Planning and Coordination; Corps of Engineers; U.S.
Environmenta]. Protection Agency and PNRBC.
Work on the Level B Study began in 1973. That year was devoted pri-
marily to study organization. The major effort of planning and analysis
took place in 1974. In 1975, effort was devoted largely to public par-
ticipation and to the formulation of decisions based on the results of
the public participation program. Because the study revealed resources
were inadequate to meet the needs of the area, an interim report was pre-
pared in February 1976 as the basis for an additional set of public hearings.
At the time of the case study investigation, it was expected that the study
would result in adoption of a plan for the Central Snake by the Idaho
Water Resources Board on or about September 1976.
The Central Snake River Basin Level B Study was well advanced at the
time the case study investigation was performed. Technical studies and
formulations of alternative plans were completed and the study report was
being drafted. The major portions of the study effort remaining prior to
its expected adoption by the Idaho Water Resources Board were a program
of public hearings and revision of the plan as appropriate based on the
hearings.
The study has identified nearly one million acres of irrigable land
in southwest Idaho as well as additional development opportunities for
various purposes. Recommendations have been prepared concerning allo-
cation of flows between instrearn and consumptive uses and with respect to
various research, policy arid other actions.
The Summary Report (1A) evidences the approach taken to water quality
effects and the degree of specificity with which water quality consider-
ations were treated. Recommendation No.4 of the Summary Report reflects
awareness of the close relationship between water quality and water quan-
tity. It states:
Amend the Idaho Code to combine the programs of water
quantity and water quality planning and administration
into a single agency, except with respect to public
health aspects of water quality.
In support of the recommendation, the report’s discussion of its basis
notes that:
Separate planning and administration of water quantity
and water quality ignores the fact that they are two
directly interrelated physical properties of the same
resource. They are so interrelated that actions in-
volving one have direct effects upon the other. To
attempt to solve problems involving either property
4—7
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of the water resource without considering the other,
compounds problems. Different levels of funding and
different planning schedules have not permitted water
quantity planning and water quality planning to be
fully integrated in the State Water Plan.
Despite recognition of the close relationship between the quality
and quantity of water which is required in planning either aspect, no
explicit attention was given water quality in establishing allocations of
quantity for various purposes. In explaining the recommended allocations
of water for irrigation, municipal and industrial, and thermal uses, the
Summary Report notes:
No water allocation is made specifically for pollution
control. Other recommendations in the water plan are
based upon the assumption that the water quality goals
of PL 92-500, the Federal Water Pollution Control Act
Amendments of 1972, will be met in Idaho.
The Summary Report does not examine the validity of assuming water
quality goals will be met concurrent with implementation of the recommended
Level B plan. Identification of the water quality impact of the recommended
plan is largely limited to a brief notation in a table of the Summary Report
regarding general environmental effects that the recommended plan:
Will probably decrease water quality some on Snake
River because of river flow depletions. Any stream
where instreain flows are provided, quality would be
improved.
Other mentions of water quality in the Summary Report include concern
over radioactive contamination of the Snake River Aquifer; recognition
that land use, mining, forestry and recreation have water quality aspects,
and the need for general environmental protection. Brief mention is made
of activities under Public Law 93-523, the Safe Drinking Water Act. The
Summary Report does not present existing water quality standards, discuss
present water quality, nor identify the types of water quality management
programs needed to maintain and enhance water quality as economic de-
velopmerit proceeds.
Contractor’s Observation No. 2
The resolution of complex problems involving water quality
was an important purpose for undertaking the Level B study.
As conducted thus far, the Level B study does not treat water
quality objectives or assess the potential extent and magni-
tude of impacts on water quality from future resource developments.
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While the identification of developments and programs provided
by the Summary Report are useful for water quality management
planning, it is insufficient to assure coordinated plans can
be developed. Either the water allocations of the Summary
Report are taken as given, assuming whatever water quality
treatment facilities and regulatory programs are necessary
will be forthcoming regardless of cost, or water quality
planning will identify constraints on development which will
require modification of the Level B plan. In either event
investments in both water quality control measures and water
resources development will proceed without.integration of water
quality and water quantity considerations.
The serious nature of water quality problems identified in
the Type I Study and their complex interrelationship to over-
all water resources management was recognized by both the
Pacific Northwest River Basins Commission and the Idaho De-
partment of Water Resources. In view ofthis, the failure to
deal explicitly with water quality jeopardizes the credibility
of the recommended plan as an acceptable pattern for managing
the land and water resources of the study area. This is not
to say that the proposed developments will be incompatible
with water quality goals within the limitations of social and
economic impacts, but only that the report does not show such
compatibility exists or can be achieved.
Subsequent to its adoption by the Idaho Water Resources Board as a
part of Idaho’s state water plan, the plan for the Central Snake will
be considered by the Pacific Northwest River Basins CommIsssIon for in-
clusion in the CCJP. The interests of federal agencies and those of
adjacent states are expected to result in efforts to modify portions of
the plan having interstate implications prior to its adoption by the Pacific
Northwest River Basins Commission. The presence of interstate consider-
ations is acknowledged in the Summary Report with the following brief
statement:
The Snake River Compact, enacted in 1949, establishes the
allocation of water between Idaho and Wyoming. No other
compacts exist with regard to the allocation of the Snake
River flows. The State of Washington has previously ex-
pressed its desire to see a minimum flow of 22,000 cfs at
the Idaho—Washington boundary on the Snake River. The
recommended plan does not provide any minimum flow except
that required under the provisions of the Federal Power
Commission License for Hells Canyon Dam of 5000 cfs at
Johnson’s Bar. Flows at the Idaho-WashingtO”l border
will be less than 22,000 cfs at times.
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Contractor’s Observation No. 3
Plan formulations to be considered by the Pacific Northwest
River Basins Commission will consist of elements wholly in-
ternal to the State of Idaho, the management of which is of
little interest to other states, and elements of an interstate
nature significantly affecting adjacent areas in other states.
Intrastate elements may be thought suitable for incorporation
in the CCJP without more than casual concern on the part of
federal agencies or other states. However, elements which
affect economic and environmental interests of other areas,
such as major depletions in streamf low or developments which
create or worsen water quality problems in downsream areas
are likely to be contested and may require modification before
incorporation in the CCJP.
Operation of river basin commissions on the basis of con—
census provides no way for authoritatively resolving differences
between states. Long periods of negotiation between Idaho and
its neighboring states will be necessary to arrive at mutually
agreeable development plans, water quality standards or other
common approaches to resource management.
This impediment to early resolution of interstate issues
results in part from the institutional nature of river basin
commissions and in part from the encouragement which the use of
state led Level B study teams gives to development of plans
biased toward interests of the sponsoring state.
Failure to resolve interstate issues prevents the availability
of a firm plan for development of the entire basin and results
in the forwarding to Congress of unresolved issues. Studies
led by Federal agencies or by river basin commissions may
find a lack of state participation which leads to similar prob-
lems.
Description of Water Quality Management Planning Programs
There are several specific water quality management planning efforts
underway in the Central Snake Level B study area including facilities
planning, the Ada/Canyon water quality management planning program, the
State’s continuing planning process, and the water quality portion of the
Boise Valley Study.
Facilities planning in Nampa has been completed with support from a
Sec. 20]. grant and in Boise through Ma Council of Government’s 3c grant
planning program. Planning supported by Sec. 201 grants was underway in
the area for the cities of Caidwel]. and Meridian at the time of investigation
(2N).
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The Ada Council of Governments and the Canyon Development Council
jointly requested designation as a Section 208 water quality management
planning agency in January 1975(2F). The designation was made by Governor
Andrus on January 17, 1975(2H), and approved by EPA on April 2, 1975(2Q,R).
A planning grant in the amount of $414,300 was awarded on June 9, 1975.
The Ada/Canyon Areawide Waste Treatment Management Committee submitted
its Project Control Program in August 1975(28). Planning commenced upon
EPA’s approval of the Project Control Program.
The principal problems identified in the Project Control Program to
be addressed in the study include, in order of priority, the following:
— municipal treatment facilities;
— major irrigation return drains;
— instream flow maintenance;
— individual waste disposal systems;
- feedlots and dairies;
— urban runoff; and
— erosion control.
The Technical Advisory Committee for the Ada/Canyon 208 study was formed
in November 1975. It included representatives of the Idaho Department of
Water Resources, Idaho Department of Health and Welfare, Idaho Department
of Budget, Policy Planning and Coordination and Corps of Engineers as
well as numerous other federal, state and local agencies. EPA is not a
member of the Technical Advisory Committee.
The Ada/Canyon water quality management planning program was still
in its initial stages at the time the case study investigation was con-
ducted. The technical products of the program at that time were limited
to draft memoranda concerning the identification of major natural streams
in the study area which may receive waste discharges and economic and
demographic projections and analyses for the study area. Other aspects
of the study underway included identification and analysis of existing
water quality conditions, point source analysis, nonpoint source analysis,
and land use analysis. Management planning tasks had not begun due to
delays in developing suitable contractual arrangements with the agency’s
general consultant.
Contact with the Level B study was limited. Interviewees representing
the Ada/Canyon Waste Treatment Management Committee were aware that water
resources planning was underway by the Idaho Department of Water Resources
but were not familiar with the type or breadth of those studies. Effort
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to collect useful information from the Level B study program was limited
to a request that ment,ers of the Technical Advisory Committee provide
information they thought relevant.
Contractor’s Observation No. 4
Interviewees at the Idaho Department of Water Resources indi-
cated a general willingness existed on the part of the Level B
study team to assist meeting 208 data and information requirements
when and if such requirements are identified. However, Idaho
representatives on the study team are not agressively attempting
to encourage such arrangements.
Several reasons may exist for the absence of more aggressive
efforts to use common data. As noted, staff of the Ada/Canyon
Waste Treatment Management Committee were not fully aware of
the Level B study. They also placed reliance on the Idaho
Department of Health and Welfare to provide such coordination
in accord with their contract for services (2C).
Delaying formation of the Technical Advisory Committee until
after completion of the Project Control Program and its approval
by the State and EPA at least deprived the Ada/Canyon Waste
Treatment Management Committee of whatever inputs the Level B
study team might have made to the organization and approach to
water quality planning. The inference drawn by those on the
Technical Advisory Committee could easily have been that little
value was placed on their potential contributions and that their
role was one of assisting in details and lending authenticity
to the planning effort. Contributions of the Level B study
program to the Ada/Canyon waste treatment management planning
program might have been considerably enhanced if the Idaho
Department of Water Resources had been consulted on design of
the Project Control Program and if the Technical Advisory
Committee had been formed at an earlier date.
Water quality planning at the state level in Idaho is and has been con-
ducted by the Idaho Department of Health and Welfare and its predecessor
agencies. In February 1976, a basinwide report pursuant to Sec. 303(e)
which encompassed the Central Snake River Basin was completed. This report
was not available at the time of the case study interviews. Reportedly,
the document consists mainly of an accumulation of NPDES permit conditions
for the area and provides little of the basis for more detailed planning.
Integrating and coordinating water quality planning processes and
plans with those of the Level B program is complicated by the fact that
the Idaho Department of He lth and Welfare has not yet formulated an approach
to meeting the requirements of the continuing planning process in the non—
designated portions of the State. However, a draft outline ( ) concerning
the water quality management program indicates that a significant portion
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of the proposed effort will be oriented toward the preparation of inven-
tories and development of detailed technical plans. The outline does not
indicate that the continuing planning process will either resolve dif-
ferences which may exist between water quality objectives and the Central
Snake Level B Study or provide another hydrologic framework in lieu of
that to be provided by the Level B Study. Neither does it indicate sig-
nificant reliance on any of the expected products of the Central Snake
Level B Study or other Level B studies underway in Idaho. This raises
the prospect that the required implementation of water quality management
plans may be based on erroneous data with respect to future development,
waste loads and flows.
As noted previously, the Central Snake Level B Study did not investi-
gate whether water quality considerations would or should constrain ex-
ploitation of opportunities or irrigation or other economic development.
A dilemma will be reached if water quality management planning finds the
extent of development proposed in the Level B Study to require exorbitant
costs for treatment facilities or unrealistically stringent regulatory
controls to achieve water quality standards. In that event, either water
quality standards can be lowered in accord with procedures for their
revision (40 FR 130.17] or the proposed extent of water and land re-
sources development can be reduced.
Contractor’s Observation No. 5 .
The responsibility for adoption of the Central Snake Study
as part of Idaho’s State Water Plan is assigned constitutionally
to the Idaho Water Resources Board. Implementation of the plan,
at least insofar as water rights administraticn and certain policy
matters are concerned, rests with the Idaho Department of Water
Resources. It is relatively well assured that the Department
of Water Resources will proceed quickly to reflect any adopted
plan in their activities. Since water quality was not a serious
concern in developing the recommended plan for the Central Snake
River Basin, administration of water rights by the Department of
Water Resources is likely to be similarly deficient of this
concern.
Water quality r anagement planning is performed at the depart-
mental level by the Department of Health and Welfare. However,
the principal responsibility rests upon the Governor for certi-
fication and forwarding of plans approvable by EPA’s Regional
Administrator.
Each of the major departments involved has its historic con-
stituencies with varying interests in irrigation, power, environ-
mental improvement and other areas. The sum effect of the insti-
tutional setting is to create a situation in which it will be
particularly difficult to harmonize the proposed extent of develop-
ment and water quality standards. Still, the dichotomy likely
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to be reached in Idaho does not depend on whether water quantity
or water quality was performed first. It results from the
lack of concurrent and comprehensive consideration, stemming
at least in part from the fact that Level B studies were funded
and staffed prior to beginning major water quality management
planning activities.
Unless reconciliation of all important economic and environ-
mental objectives in water planning is explicitly built into
the planning processes, securing compatible plans may be ex-
tremely difficult due to institutional mechanisms which are
not easily changed. Uncoordinated planning leads to reconcili-
ation of differences in a competitive environment with each
agency principally interested in promoting its own programs.
This approach to reconciliation may have some benefits in theory
to the extent it causes a thorough testing of the assumptions,
procedures and results on either hide. However, from a practical
standpoint the economic and other costs of such an approach may be
large including mis-investments, foregoing of benefits from
earlier use of renewable resources, and others apart from just
planning costs.
Many of the adverse results stemming from the production of
differing plans affecting the same resource can be lessened or
avoided by either carrying on the plans concurrently or elimi-
nating the advocacy relationship through combining the planning
processes. Support for eliminating either water quality manage-
ment planning or Level B planning and expanding the remaining
program was voiced by several of the interviewees.
The Corps of Engineers, Ada Council of Governments and Canyon Develop-
ment Council are jointly conducting a planning program for that portion of
the Boise River drainage area downstream of Lucky Peak Dam as a part of the
Corps of Engineer’s Urban Studies Program. This investigation, identi-
fied as the Boise Valley Study, encompasses an area nearly identical to
that of the Ada/Canyon 208 Study. The Study is oriented primarily toward
water quality, flood control and water supply objectives (2G).
The Boise Valley Study began in 1972. “Support” agencies for the
Study include the Idaho Department of Water Resources; Idaho Department
of Health and Welfare; Idaho Department of Budget, Policy Planning and
Coordination; and EPA as well as other State, federal and local agencies.
The support agencies for the Boise Valley Study are not formed into a
coi m ittee or work group structure or otherwise brought together on any
regular basis. Meetings between study staff and agencies are carried
out on an ad hoc basis as needs arise for coordination.
The Corps’ Boise Valley Study was nearly complete at the time the
case study investigation was conducted. Advance reports had been prepared
and distributed concerning Barber Dam, the impact of subsurface sewage dis-
posal in the Ada/Canyon County area, the effects of on—farm water management
4—14
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practices, selection and management of feedlot sites and land disposal of
manure, and irrigation drain treatment. Alternatives had also been prepared
for a second outlet from Lucky Peak Dam. Substantial progress had been
made on reports concerning wastewater facilities plans for the Nampa—Cald—
well area. Plan formulation was expected to take place in mid-1976.
The products of the Boise Valley Study are considered by the Ada/Can-
yon Waste Treatment Management Committee staff to be key inputs to their
water quality management planning program. Since Ada and Canyon Counties
are guiding and supporting both studies, planning approaches are relatively well
integrated. The Boise Valley Study was particularly looked to for pro-
vision of some facility designs, identification of stormwater treatment
needs, monitoring, information on irrigated agriculture, and assistance
in management planning.
Interviewees representing the Ada/Canyon Waste Treatment Management
Committee cited the flexibility and compatible time frame of the Boise
Valley Study as its principal advantages with respect to their program.
Interpretations of Interrelationships Between the State’s Continuing
Planning Process, Level B and Urban Studies Planning Programs
The agencies responsible for leadership of the studies in the Central
Snake River Basin have varying views regarding the nature and value of the
other studies as reflected in the comments and attitudes of interviewees
and the emphasis placed by each on assuring coordination with the other
planning programs. Each agency views its planning program as being a
significant factor in future resource nanagement decisions. In some
cases, agencies did not view certain of the other programs as either
relevant or important to their own programs.
Idaho Operations Office, EPA, places considerable emphasis on the
State’s continuing planning process for water quality management. Close
relations are maintained with both the Idaho Department of Health and Welfare
and, in EPA’s view, with the Ada/Canyon water quality management planning
program. However, EPA is not a member of the Technical Advisory Committee
for the latter study based on the concept that this constitutes a conflict
with EPA’S responsibility for plan approval. EPA also works closely with
the Corps on the Boise Valley Study which they view as being integrally
related to the Ada/Canyon water quality management planning program.
In contrast to the interest expressed in the specific water quality
studies underway by EPA staff interviewed, EPA participates in the Central
Snake Level B Study only on an occasional basis even though the agency
is a member of the State-Federal study team for that effort. Similarly,
EPA has elected to not be represented on the PNRBC’s Federal Technical
Committee which is assisting in preparation of the CCJP and which provides
much of the coordination among federal agencies involved in the Central
Snake and other Level B Studies and water resource related planning efforts
of other types.
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Staff members of EPA’s Idaho Operations Office viewed the Ada/Canyon
water quality management study and the Boise Valley Study as similar in
nature excepting the broader consideration of the latter for flood control
and other purposes. Similarly, the State’s continuing planning process
was seen as the logical vehicle for preparing the water quality element
of the Central Snake Level B Study subject to constraints on the com-
patibility of the programs. Desirable linkages identified between the
programs included common economic, population and land use projections,
and common goals and objectives. The most important aspects of the Level
B Study were considered to be recommendations concerning minimum stream—
flows and provision of information on land use which would be helpful in
designing measures for control of nonpoint sources of pollution. Although
recognizing these linkages and that they are not being developed, EPA has
made an apparent effort to require water quality management efforts be
more closely aligned with the other programs:
Contractor’s Observation No. 6
Advisory committees required under EPA regulations for guidance
of efforts to prepare water quality management plans are intended
in part to provide “a mechanism for meaningful and significant
results from local, State, intrastate, and Federal units of
government (40 CFR, Part 130, Sec. 130.16(c)]. Designated plan-
ning organizations are required to provide for representation
on the committee of the state [ 40 CFR, Part 130, Sec. 130.16(d)]
which also has responsibility for approval [ 40 cFR, Part 131, Sec.
131.20(f)] of the plan which is to be prepared. States are also
encouraged to submit plans for review by EPA prior to their adoption
to minimize potential objections [ 40 cFR, Part 131, Sec. 131.20(d)].
These regulations indicate that designated planning organi-
zations and states are to seek meaningful inputs from federal
sources and federal review of plans prior to their adoption by
the State. In view of the fact that State participation in both
development and approval of plans from designated areas is re-
quired, EPA’s election not to participate on the advisory com-
mittee for the Ada/Canyon Counties 208 planning effort appears
inconsistent. EPA’s failure to participate aggressively in other
related planning programs deprives the water quality management
planning process of early confrontation of differences between
water quality and water quantity planning which might be pursued
effectively by EPA through their involvement in all of the water
quality planning programs ongoing in the area as well as through
participation in the Central Snake Level B study, Pacific North-
west River Basins Commission, and Water Resources Coui cii.
More broadly, EPA’s lack of substantial participation is in-
dicative of the low priority given planning as opposed to grant
administration, regulation, and other activities.
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The Idaho Department of Health and Welfare places considerable im-
portance on both the designated and non—designated aspects of the con-
tinuing planning process and on the Boise Valley Study. The agency is a
member of the Technical Advisory Committee for the Ada/Canyon water quality
management planning study arid attends on a regular basis. It is also a
support agency for the Boise Valley Study and maintains close coordination
with that effort.
The Central Snake Level B Study is viewed by staff of the Idaho De-
partment of Health and Welfare interviewed as overly oriented toward
irrigation development and largely a presentation of already available
information. It was described as deficient in consideratior of the
economic and environmental consequences of decisions on instreaxn flows.
Because of this, the Level B Study was not described as being either vital
or particularly useful to the programs managed by the Department of THéalth
and Welfare. The Department does not expect to encourage the use of
hydrology or other information developed for the Level B Study in the
Ada/Canyon 208 Study. Little serious consideration has yet been given
by the Department of Health and Welfare as to how the results of the Level
B Study might be useful to the State’s continuing planning process except
as it may provide information on, and inventories of, land use.
Coordination among the several planning programs and agencies was
seen by the Department of Health and Welfare interviewee as important to
avoid duplication in development of the State’s continuing planning process
for water quality management. In lieu of the Department’s participation
in other studies, materials leading to establishment of the State’s con-
tinuing planning process were to be widely distributed to other organi-
zations for their information.
Little concern has been evidenced by the Department of Health and
Welfare with implementation aspects of the Central Snake Level B Study
or the adequacy of the Ada/Canyon waste treatment management plan. Em-
phasis is directed primarily to meeting immediate requirements relating
to permits, grant administration and other matters. The Level B program
was not viewed by the interviewee representing the Department as the
proper forum for the development of implementation arrangements within
which plans meeting Section 208 requirements would be developed.
Overall coordination between the Central Snake Level B Study and
activities of the Department of Health and Welfare is conside ed in-
effective by the latter. However, this is not seen by the Department as
particularly adverse to water quality planning and management activities
since the Central Snake Level B Study does not address water quality
directly and its level of detail is thought to make the study largely ir-
relevant to water quality management planning.
Contractor’s Observation No. 7
The approach taken to coordination by the Department of
Health and Welfare does little to encourage closer integration
of planning processes or resolve differences in the resultant
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plans. Departmental interest, at least on a sustained and
significant basis, is limited to water quality planning, with
little interest in the Central Snake Level B study or concern
with any threat which it might pose to the attainment of water
quality objectives. Apparently, this attitude is based upon
an assumption that the Level B Study plan will not lead to
immediate implementation or be adhered to rigidly ix future
decision-making. As a result, no substantial effort has been
made to influence the Level B Study with regard to its treat-
ment of water quality, to identify useful products of the Level
B Study, or to stimulate coordination between the Ada/canyon
Counties designated planning organization and the Level B
Study. This lack of positive action to encourage coordination
furthers the development of conflicts in water resources manage-
ment planning.
Many reasons doubtless contribute to the position taken by the
Department of Health and Welfare with respect to water quality!
water quantity coordination. Reasons put forth by interviewees
included a shortage of funds and personnel to participate and
the irrelevance of the Level B Study due to its lack of detail
and new information. Other reasons not expressed by inter-
viewees may exist which are more subjective and more complex.
Attitudes toward coordination ar ’ probably affected by the sig-
nificant disparity in size between the Department of Water
Resources and Water Quality Bureau of the Department of Health
and Welfare and the consequent difference in their capability
to undertake and carry out programs. While the Department of
Health and Welfare as a whole is larger than the Department
of Water Resources, the Bureau of Water Quality comprises only
a few professional staff. In addition to a staff of about a
hundred, the Department of Water Resources has extensive back-
ground in water rights administration, state—federal relations
and other relevant areas whereas the State’s water quality
planning program is just being established. In contrast to
their size relationship, the Bureau of Water Quality Manage-
ment has responsibility for the administration of large amounts
of money and for carrying out a planning program with close
ties to local public officials. Given these conditions, the
reconunendation of the Department of Water Resources that water
quality and quantity planning be combined in a single agency
provides a strong stimulus to rivalry and withdrawal.
Attitudes toward coordination are also likely to be influ-
enced by the breadth of understanding of the several involved
programs. In the case of the Idaho Department of Health and
Welfare, this lack of understanding may constitute a signi-
ficant impediment as exhibited by the little concern for im-
plenientability of water quality management plans, unfamiliarity
with the existence of the Principles and Standards, and unaware-
ness of the requirements for coordination with Level B planning
4-18
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explicit in the regulations for the State continuing plan—
fling process.
Whatever the full range of reasons for failure of the
Department of Health and Welfare to participate aggressively
and constructively in the Central Snake Level B Study may be,
any adverse comments by the Department on the failure of the
study to appropriately consider water quality will be rebutted
with a recounting of their lack of participation. The likely
outcome of such an exchange would be a further decline in inter-
agency relations, making reconciliation of program objectives
more difficult.
The Department of Water Resources provides State leadership for the
Central Snake Level B Study and views that program as a principal part of
the Idaho water resources planning program. The Department also partici-
pates in other studies described including attendance at meetings and pro-
vision of some inputs. The Boise Valley Study, for example, is using
hydrologic information prepared by the Department of Water Resources
and the Department of Health and Welfare expects to use population infor-
mation in its continuing planning process which was developed by Boise
State University for the Department of Water Resources. The Department
of Water Resources views the Boise Valley Study as very similar in nature
to the Level B Study excepting the Boise Valley Study’s greater emphasis
on implementation. The Ada/Canyon water quality management planning
study is viewed as important, primarily because of its potential effect
on agriculture.
Information from the Central Snake Level B Study is seen by the De-
partment of Water Resources as useful for water quality management plan-
ning, particularly with respect to water supply, potential agricultural
development, population forecasts, environmental aspects other than water
quality such as instream flows and land use, summarization and comparison
of prior studies, and provision of inventories. In general, the Depart-
ment views the Central Snake Level B Study as providing the overall frame-
work within which water quality and other functional plans will be developed.
Contractor’s Observation No. 8
One of the serious constraints on the mutual exchange of
information and support between Level B and water quality
management planning programs stems from the differing views
of the potential use of the Level B study which are held by
the Departments of Water Resources and Health and Welfare.
Whereas the former sees the Level B study as the broad
framework for n re detailed studies, the latter finds it
largely irrelevant to their objectives. Both views are
probably influenced by the types of subjective considerations
mentioned earlier and not wholly correct.
4-19
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The Central Snake Level B Study is relevant to water quality
planning notwithstanding its scant attention to that topic.
Much of the basic work is useful for other purposes as sug-
gested by the Department of Water Resources. However, the plan
formulated is of lesser value in that it provides only one
interpretation of the basic data on opportunities and needs,
largely uninfluenced by real concern for water quality. To
make the Level B plan wholly usable as a framework requires
subordinating water quality management to other objectives.
In spite of its views as to the value of the Central Snake
Level B Study for water quality planning purposes, the Depart—
merit of Health and Welfare may have little choice in using its
results. Section 130.34(c) of the Policies and Procedures for
Continuing Planning Process [ 40 CFR 1301 require that where a
Level B Study is complete or underway, the State or designated
planning agency provide where appropriate for integrating their
water quality management planning with certain of its outputs
including “existing and projected future water withdrawal arid
consun tive demand over a 20—year period.” As water quality
and water quantity are inextricably related in the Central
Snake River Basin, integration would appear required.
This situation suggests that either Level B studies must give
consideration to water quality when projecting future water
withdrawals or water quality planning must aocommodate whatever
results are obtained. EPA’s instructions in Section 130.34 for
water quality planning to incorporate the development of
projected water demands applies only to cases where no Level
B study has been initiated.
The Corps of Engineers attends and participates in both the Ada/Canyon
water quality management planning study and the Central Snake Level B study
team efforts. The Corps is also represented on PNRBC’s Federal Technical
Committee.
The Level B Study is viewed by the Corps as being related to the Boise
Valley Study through the use of common information on instrealn flow needs
and hydrology. An ecologic model developed under a joint contract for
the Department of Water Resources, Corps and Department of Health and Wel-
fare will also be used in the Boise Valley Study to identify impacts of
alternative potential future conditions. Corps staff view the Ada/Can-
yon water quality management planning study as particularly important
because of its close relationship to the Boise Valley Study. The land
use plans used in the latter are those prepared by Ada Council of Govern—
ments and the Canyon Development Council for their respective areas.
The mechanisms available for coordination among the several agencies and
programs are thought by the Corps to be adequate.
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Contractor’s Observation No. 9
The most effective coordination between the several activi-
ties underway, at least as perceived by the investigators in
this case study, was that achieved by the Corps for the Boise
Valley Study. Interestingly, organization of that study does
not include formal committees or task forces and meetings with
supporting agencies are held on an ad hoc arid “as needed” basis.
This suggests that organizational form may be less important
than other factors in achieving coordination. In the case of
the Boise Valley Study, success in coordination was apparently
achieved because:
A. a conscientious and sustained effort is made
by project staff to effect coordination;
B. related agencies and- local officials view the
study as resulting in near term implementation
and therefore of importance; and
C. project staff have a relatively good under-
standing of each of the other related planning
programs.
Staff members responsible for the Ada/Canyon water quality management
planning study viewed the State’s water resources planning progam as pro-
viding a general guide for their efforts and expect to use information con-
cerning instream flow needs, hydrology, irrigation development and
waste water problems. However, no specific arrangements for obtaining
and applying information from the Level B Study are included in the
project control program or other documents reviewed.
The State’s water quality planning products, mainly the basinwide
plans, were viewed by local planning staff as insufficiently detailed to
be of significant value in their program. The designated area planning
program was expected to provide the major source of information for
development of the Department of Health and Welfare’s statewide program
for management of nonpoint sources of pollution rather than the State
providing leadership to local agencies.
While the project staff considered the nature of the Boise Valley
Study’s final product to be unclear, that study was regarded as an impor-
tant adjunct to the local water quality management planning program.
In view of the project staff, lack of understanding of the water
quality management planning program on the part of others was thought to
be a significant impediment to coordination of planning.
4—21
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Coordination Arrangements
A number of mechanisms exist by which the several studies under-
way in the Central Snake River Basin might be made complementary and
mutually supportive.: among others, these include the sponsorship of the
Pacific Northwest River Basins Commission, cross membership on study
committees, legislatively mandated coordination meetings between Idaho’s
Departments of Water Resources and Health and Welfare, and review processes
maintained by various agencies.
River basin commissions have a significant responsibility to:
Serve as the principal agency for the coordination of
Federal, State, interstate, local and nongovernmental
plans for the development of water and related land
resources in its area, river basin, or group of river
basins (Sec. 201 (b), PL 89—80).
In the case of the Central Snake Level B Study, the Pacific Northwest
River Basins Commission had adopted the !1 ’pe I study which pointed out the
need for investigation, and prepared and adopted the plan of study. The
Commission is chaired by a presidential appointee and provided with pro-
fessional staff. A federal technical committee operating under the aegis
of the Commission and having coordinating responsibilities attended most
or all of the meetings of the State—federal study team for the Central
Snake Level B Study.
Unfortunately, advance budgeting information from federal agencies
which is one of the principal coordinating techniques intended to be used
by the Commission is ineffective insofar as EPA administered programs
are concerned since EPA does not regularly provide budget information to
the Commission. Nevertheless, given the Commission’s keen awareness of
the couplexity of the Central Snake River Basin and close relationship
between water quantity and water quality, effective elimination of water
quality from the Central Snake Level B Study should have been apparent
to the Commission or at least to its professional staff. No documen-
tation collected during the case study investigation indicated any strong
effort by the Commission to reinforce coordination or modify the Level B
Study program so as to include water quality.
As noted in the descriptions of the various studies underway in the
Central Snake River Basin, several agencies were either prime or supporting
participants in each effort excepting the state continuing planning process
which has not depended yet on coordination meetings or inputs from others.
One of the agencies, the Division of Budget, Policy Planning and Coordi-
nation has specific coordination responsibilities.
The Idaho Departments of Water Resources and Health and Welfare are
required by law to meet quarterly for purposes of coordination. Reportedly,
such meetings have not focussed on coordination of the Level B and water
quality management planning programs.
4—22
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Contractor’s Observation No. 10
Representatives of the Ada/Canyon Waste Treatment Management
Committee interviewed were generally acquainted with water
resources planning being performed by the Department of Water
Resouces within the context of a state water planning program.
However, they were unfamiliar with the concept of Level B Plan-
ning. A considerable portion of the first interview was spent
with the interviewees describing the general institutional
framework for water resources planning, the role of the Water
Resources Council and the river basin commissions in that frame-
work, levels of studies, basic concepts of the Principles and Stand-
ards and “old” v. “new” approaches. The lack of background on
the part of the interviewee largely frustrated specific dis-
cussion of opportunities for coordination between the programs
or useful information which Level B studies might provide local
planning efforts. It also apparently reflects a minimal inter-
agency exchange of information and views with respect to plan-
ning.
It is unrealistic to expect effective coordination to be
originated through the local water quality management planning
program staff until they have gained familiarity with the Level
B program and developed a more comprehensive background in
the various related planning programs.
Level B Inputs to Water Quality Management Planning
There are no specific plans to extensively use inputs from the Central
Snake Level B Study in water quality planning and management efforts at
either the local or State level in Idaho. Moreover, interviews disclosed
no strongly expressed desire to identify ways to make the several programs
mutually supportive excepting as the Boise Valley Study is concerned.
Documents preliminary to conduct of the State’s water quality management
program (3B,C) and the Ada/Canyon Counties water quality management plan-
ning program (2A,B,F) are largely devoid of any mention of the Central
Snake Level B planning program. This lack of awareness or coordination
went unchallenged in the review of materials conducted by EPA (2Q,RS,T)
and the Department of Health and Welfare (2H,K,M).
Contractor’s Observation No. 11
Unless EPA is insistent on explicit treatment of the Level
B study outputs, the plan of work for the State’s continuing
planning process is likely to be deficient in that respect.
4—23
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EPA carried out an extensive review of proposals for designation
pursuant to Sec. 208(a) of PL 92—500. In the case of the Ada/Canyon
Counties water quality management planning program, several reviews were
performed of the designation request, the application for planning funds,
the Project Control Plan, and milestone reports. In spite of EPA’s member-
ship on the Pacific Northwest River Basin Conunission and the Central Snake
Level B Study and EPA’s recognition of quantity/quality problems, no ob-
jection was raised to the failure of those documents to comprehend the
Level B Study or specify coordination with that program.
Contractor’s Observation No. 12
The lack of coordination between the Central Snake Level B
Study and the water quality management planning underway at the
State and local level in the Basin cannot be attributed to any
single agency or level of government. The lack of coordination
was apparent at each step and should have been well known at least
to EPA and State personnel with responsibility with water quality
management planning programs, the State-Federal Study Team for
the Level B Study, the Pacific Northwest River Basins Commission
and the Water Resources Council.
Nothing in the Water Resources Council’s proposed guidelines
for Level B planning or EPA’s guidelines and regulatiorLs for
the State’s continuing plannning process prevents such situations
from occuring again with the exception of EPA’S requirements
to use certain outputs of any ongoing or completed Level B
studies. In the case of the Central Snake, even that instruction
has so far been insufficient.
In 1ementation of Plans
Each of the several studies underway addresses implementation to some
extent. However, the Boise Valley Study is addressing implementation in
less detailed fashion than is required for approval of plans in accord
with Section 208 of PL 92-500, and in n re detail than the Level B Study.
The Central Snake Level B Study is unspecific with regard to implementation
other than with respect to the identification of needed legislation and
the activities of the Department of Water Resources. No effort is underway
to coordinate in lementation planning for these and other related activi-
ties in Idaho.
4—24
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Monongahela River Basin
The Monongahela River Basin comprises an area of 7,384 square miles
in northern West Virginia, northwestern Maryland and southwestern Pennsyl-
vania; the drainage area in Maryland is comparatively sn all in comparison
with the portions of the watershed in West Virginia and Pennsylvania.
Monongahela River flows generaly northerly from its headwaters in Randolph,
Upshur and Lewis Counties, West Virginia, joining the Allegheny River at
Pittsburgh to form the main stem of the Ohio River. The Ohio then flows
westerly and southwesterly to its confluence with Mississippi River at Cairo,
Illinois.
Major metropolitan areas are the Pittsburgh and Johnstown Standard
Metropolitan Statistical Areas (SMsA), in Pennsylvania, and Clarksburg,
Fairmont and Morgantown, West Virginia. Population of the Basin, in-
cluding all of the Pittsburgh SMSA and Johnstown SMSA was reported to be
about 3,200,000 in 1970 (4.E., page 22). Both SMSA’s encompass substantial
areas outside the Basin proper; City of Johnstown is located outside the Basin.
The Basin has been described in the following terms (4.E., page 22):
The Monôngahela River Basin is located in the Appalachian
Plateau. The terrain is rugged and valleys are deep and
narrow. Flat areas are limited to narrow flood plains
and some terraces and flattopped hills. Elevations of
the basin range from approximately 4,600 feet above sea
level in the headwaters of the Cheat River to about 700
feet above sea level at Pittsburgh, giving a maximum relief
of nearly 4,000 feet. The climate is temperate, with an
annual precipitation ranging from 36 to 70 inches.
Most of the agriculture, manufacturing, mining, and urban
and industrial centers are located in the western half of
the basin. Forested lands are more concentrated in the
eastern half. Hay and livestock are the chief agricul-
tural products. Much coal mining has occurred in the
basin, and coal extraction continues to be important in
the western third in the general vicinity of the West
Fork River, the main stem of the Mononga.hela River, and
in parts of Preston County, W. Va., and Somerset County,
Pa. Industries are concentrated along the main stem
of the Monongahela River with most of the steel industry
located in the lower reach.
In 1840, private interests began operation of the first
navigable river lock system in continuous use through-
out the country. It was primarily for transport of the
large quantities of whiskey produced in the basin. After
the Whiskey Rebellion (sic) this navigation system provided
easy transport of coal, contributing to the establishment
4-25
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of the steel industry at Pittsburgh. For several decades,
the Monongahela navigation system has carried more coal
tonnage than any other comparable navigation system.
The northerly part of the Basin encompasses the southerly portion of
the designated Pittsburgh 208 areawide planning area which comprises the
Counties of Allegheny, Armstrong, Beaver, Butler, Washington and Westmore—
land including and surrounding the metropolitan area of Pittsburgh, Pen-
nsylvania. The portion of the 208 area within the Basin comprises relatively
small proportions of both the Basin and the 208 area. As of June 1976,
this was the only designated 208 area within the Basin. Southwestern
Pennsylvania Regional Planning Commission has been designated as the
areawide planning agency.
Monongahela River Basin is within the jurisdiction of the Ohio River
Basin Commission (ORBC) which was established by Executive Order 11578 on
January 13, 1971, under the provisions of the Water Resources Planning Act
of 1965, PL 89-80. As described hereinafter, ORBC completed and published,
in July 1975, the “Monongahela River Basin Water and Related Land Resources
Level B Study Report” for submission to Governors and Heads of Federal
agencies for official camnents. The Level B Plan has been incorporated, as
the “First Step”, in ORBC’s Comprehensive Coordinated Joint Plan which ORBC
must prepare and keep current pursuant to the Water Resources Planning
Act of 1965. Level B studies by ORBC are pending for the Allegheny River
Basin and for the Ohio River Main Stem.
Monongahela River Basin is within the area encompassed by the inter-
state compact which created the Ohio River Valley Water Sanitation Com-
mission (ORSANCO). However, the organization has traditionally confined
its interests and activities largely to the Ohio River Main Stem below
Pittsburgh -
For purposes of this report, staffs of the following planning organi-
zation active in Monongahela River Basin were interviewed (interview dates
are given in parentheses):
Ohio River Basin Conunission (March 8, 1976);
Southwestern Pennsylvania Regional Planning Commission
(March 10, 1976);
Conmm nwealth of Pennsylvania, Department of Environ-
mental Resources, Bureau of Water Quality Management
(March 23, 1976, by telephone);
Comonwealth of Pennsylvania, Department of Environ-
mental Resources, Bureau of Resources Prograluning
(March 11, 1976);
State of West Virginia, Department of Natural Resources,
Division of Water Resources (March 9, 1976);
4-26
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State of West Virginia, Office of the Governor, Office
of Federal—State Relations (March 9, 1976);
U.S. Army, Corps of Engineers, Pittsburgh District (March
10, 1976);
Environmental Protection Agency, Region III (March 26, 1976).
In addition, the Ohio River Basin Coordinator, EPA, and the Executive
Director, ORSANCO, were interviewed on March 8, 1976.
Names of the individuals interviewed are listed under acknowledgments
in the Preface.
Level B Plan
The Monongahela River Basin Water and Related Land Resources Level B
Study Report is stated by ORBC to be “. - .the first study completion in the
nation using the ORBC’ s Comprehensive Coordinated Joint Plan (CCJP) method-
ology and Continuous Planning System (CPS) which is completely compatible
with Water ResourCes Council’s New Approach to Level B Planning”. Level B
funding (total amount $261,000) for ORBC management and coordination was
provided in September 1973, the Plan of Study was adopted in January 1974,
and ORBC approved the final report in July 1975, well within the two year
period prescribed by the “new approach”. Nearly all of the contributions
of time, effort, and existing information by governmental organizations,
private industry, and interested citizens were provided without reimburse-
ment from Level B funds. The Level B study did not encompass the develop-
ment or collection of any ftew data.
Prior planning of particular interest is the Ohio River Comprehensive
Survey, Main Report, Volume 1, August 1969, by the Ohio River Basin Compre-
hensive Survey Coordinating Committee. appendix D,Volume V, Ohio River
Comprehensive Survey, Water Supply and Water Pollution Control, June 1967,
was prepared by U.S. Department of the Interior, (then) Federal Water Pol-
lution Control Administration.
The major regional issues are described as follows (4.E. pages 5-6):
The water pollution existing in the i.fonongahela River Basin
is a detriment to current and future economic development.
Improvement will lead to a better overall environmental
quality, cleaner water supplies, and mere recreational
opportunities.
The large amount of coal available in the Monongahela
Basin has been a mixed blessing for the local people.
Appalachian coal has been a major source of income and
employment, and is currently contributing toward making
the United States self-sufficient in energy. Obtaining
this coal from either strip or shaft mines has also
4—27
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resulted in serious environmental damages mostly by
polluting the streams with acid and sediment. Existing
enforcement programs, if sufficiently funded, can con-
trol problems emanating from active mines. However,
abandoned mines are causing major pollution, aesthetic
and other problems, and there is no adequate program for
abatement measures———
In addition to the energy and water quality problems,
other major issues include balancing a recreation de—
mand, heaviest in Pittsburgh, with a supply primarily
available in the upper portion of the basin; eliminating
flood damages in cities such as Pittsburgh, Pa., and Weston,
W.. Va., which have major existing flood plain developments
that would be too costly to relocate; and consideration
of the inundation of environmental and agricultural lands
by the proposed lakes of Rowlesburg, Davis and Stonewall
Jackson. Other needs and problems affecting the liononga-
bela Basin were considered; however, most of these had
solutions which were easily determined, or the problem
was not of a nature considered applicable to a Level B
Stud
The zionongahela River Basin has a large demand for water
supply in the future. The existing 7 day/lO year minimum
low flow was used as a benchmark to maintaining aquatic
life. If this flow is to be maintained, for water quality
and aquatic life purposes, additional storage for low flow
augmentation for water supply will be necessary to meet
increased demands such as municipal, industrial, and
power cooling requirements, and potential coal conversion
facilities. 4 4n estimate of these demands indicates that
if the current trend for development supporting energy re-
quirement continues, the current 7-day/lO year low flow
would be reduced by approximately 40 percent by 2020 at
the mouth of the Monongahela River---
Level B planning Objectives - The Level B Plan report states that
the objectives are (page 20):
1. 2’ provide decision makers at all levels of govern-
ment with that information necessary to clearly
identify problems and offer alternative solutions
to direct, manage, and implement action for the
development or protection of the Monongahela River
Basin’s water and related land resources.
4—28
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2. To develop a plan which will be multipurpose in scope,
considering all facets of resource rnanagenient, and
offering a time phased array of viable alternatives
to delineated resource problems in the basin.
The following two objectives, as stated in the Water
Resources Council’s Principles and Standards for
Planning, were used as primary planning objectives
in the Monongahela effort:
1. To enhance national economic development in in-
creasing the value of the Nation’s output of goods
and services and improving national economic ef-
ficiency.
2. To enhance the quality of the environment by the
management, conservation, preservation, creation,
restoration, or improvement of the quality of cer-
tain natural and cultural resources and ecological
systems.
The specific planning objectives were: (1) to ascer-
tain critical areas of overbank flooding, inadequate
drainage, and soil erosion damages; (2) to assess
present and future needs of municipal, industrial,
and rural water supply deficiency; (3) to assess
eritical reaches of streams which do not conform
to established stream standards and to note areas
of unsuitable groundwater; (4) to assess needs for
water-based recreation facilities; (5) to assess the
need for further investment in water borne transpor-
tation; (6) to assess the needs for fish and wildlife
enhancement and archeological and natural areas pre-
servation; and (7) to assess the current and future
basinwide and transfer needs for power.
Planning Process — This is described in the Level B Plan report as
follows:
The plan formulation process began with the identification
of needs, problems, and potential alternatives using ex-
isting information provided by various planning agencies.
Where gaps or conflicts existed the needs and problems
were estimated or evaluated by the Plan Formulation Com-
mittee. Simultaneously, information was gathered relating
to existing and potential land and water resources. This
resource information was displayed on a series of maps and
overlays.
4—29
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A second step of the plan formulation process was convening
of a Working Board consisting of representatives from the
States of Maryland, Pennsylvania, and West Virginia, the
U.S. Departments of Agriculture, Army and Interior, and
the U.S. Environmental Protection Agency. Planning accom-
plished by this Working Board was based on the accounting
sheets and maps already developed and the Board’s combined
knowledge of the basin’s needs, problems, and potential al-
ternatives (solutions), and the basin’s land and water re-
sources.
Based upon individual State and Federal agency analysis of
the alternatives and their representative’s knowledge of
the area, the Working Board developed a First Cut Plan by
considering approximately 1,000 known alternatives, the
objectives of National Economic Development and Environ-
mental Quality (from the WRC’s Principles and Standards),
and planning objectives previously adopted by the Plan
Formulation Coirnnittee. This analysis proce&ed syste-
matically by functional category within each drainage
basin. Conflicts and complements among functions were
considered during the planning process. The beneficial
and adverse effects in the four Principles and Standards
Accounts were considered.
Following completion of the First Cut Plan Formulation
by the working Board, the full Plan Formulation Committee
continued with the plan formulation process by examining
the interfunctional and interstate requirements, depen-
dencies, and opportunities. Consideration was given to
State planning objectives and to insuring compatibility
with completed or underway state planning efforts. Land
and water resources were examined from the standpoint of
the tradeoffs that could be made by adopting various al-
ternative plans.
The public participation effortr-was intensified follow-
ing the development of the First Cut Plan. Recommendations
from this effort were considered in developing the final
recoimnended plan. The Citizens’s Advisory Task Force pro-
vided input at all phases of the process through review
comments and regular attendance at plan formulation meetings.
During the plannir period, the Study Direction and Plan Formulation
Committee met eight times (4.M.) and the Water Quality Work Group twice
(4.L.). Four planning workshops were held at various locations in the
the Basin (4.K.)
Projects and programs included ir the Recommended Level B Plan repre-
sent a consensus of the Ohio River Basin Commission members.
To assist in applying WRC’ s Principles and Standards to the Level B
Planning Process, ORBC retained the consulting firm of Gannett, Fleming,
4-30
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Corddry and Carpenter, Inc., Engineers (GFCC) of Harrisburg, Pennsylvania,
to develop applicable methodology. The GFCC final report, Monongahela
River Basin Principles and Standards Analysis, was submitted in December
1974 and with some additions and changes, became the Principles and
Standards analysis included in the ORBC Level B report.
The GFCC report was prepared in two parts. Part II describes the
analysis performed during the Monongahela Level B Study and Part I explains
and critiques the analysis. The report states (4.F., p. 1.1) that the
analysis was performed in six steps as follows; comments following the de-
scriptions taken from the GFCC report are by the principal investigators for
this report:
1. Specify components of the objectives relevant to the
planning setting;
Performance of this step assumed that ongoing studies reflected the
existing needs and problems in the Basin. Table Ml (4.F. p. 11.9) pre-
sents a listing of all projects, programs and studies considered for in-
clusion in the plan.
2. Evaluate resource capabilities and expected conditions
without any plan;
Projects which were either existing, underway or already planned were
considere4 to constitute the “without plan conditions.” It is not clear
that Part II contains a description of the “without” conditions.
3. Formulate alternative plans to achieve varying levels of
contributions to the specified components of the ob-
jectives;
Worksheets are presented for description of each project by various
study participants as well as summary sheets for use by the analyst in
standardizing and condensing the detailed descriptions. The critique
points out the need for a more objective basis for characterizing projects.
Step 3 also includes the allocation of projects to the National Eco-
nomic Development (NED) objective, Environmental Quality (EQ) objective,
or both, beginning with single project-single need situations and
progressing through single project—multi need situations and then to more
complex cases. Allocation of the alternative plans was subjective and
based on each project’s general characteristics. All projects or programs
included in the NED and EQ plans were included in each alternative plan
prepared.
4. Analyze the differences among alternative plans which
reflect different emphasis aircng the specified compo-
nents of objectives;
4—31
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This step provides for identifying and comparing the contributions to
each of the four accounts by the projects included in the various alterna-
tive plans.
5. Review and reconsider, if necessary, the specified com-
ponents for the planning setting and formulate additional
alternative plans as appropriate;
This step provides for reviewing the several plans with respect to
the system formed by each and review of the available information for each
included project. The review is to assure no patently unsuitable combi-
nations of projects occur and, to the extent possible, make any modifica-
tions to the plans to improve optimality.
6. Select a recommended plan from among the alternative
plans based upon an evaluation of the trade-offs
between the objectives of national economic develop-
ment and environmental quality and considering, where
appropriate, the effects of the plans or regional
development and social well-being.
The Recommended Alternative(RA) plan was constructed of projects which
appeared in both the NED and EQ plans and others selected by judgeinent which
appeared in one or another of the plans. Where decisions were difficult and
no basis could be found for decision, the plan was left incomplete with the
conflict pointed out.
The critique of the process by GFCC points out problems which were en-
countered and makes recommendations. Problems noted by GFCC with respect
to the Principles and Standards include:
o It is difficult to grasp the distinction between
externalities under the NED Account and the effects
under the Regional Development Account.
° The NED objective does not adequately treat water
quality as an NED component and seems to view water
quality control as a strictly EQ component.
o It is difficult to prepare Table 1 as described in
the Principles and Standards; its purpose is not clear.
o The organization of the Principles and Standards, as
presented in the September 10, 1973, Federal Register,
is confusing; a Table of Contents would be an improve-
ment.
GFCC also noted the variations of level in information available from
agencies concerning projects and programs.
4—32
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Recommendations made by GFCC include provision of the following
guidelines:
o An effort should be made to eliminate weak projects
and programs from consideration as early as possible.
o Many potential projects and programs are not selected
for any plan; the PP1 and PP3 display sheets for these
excluded projects and programs nee& not be reproduced,
although this may tend to conceal a valid part of the
analysis.
o Some attempt should be made to list directly certain
beneficial and adverse effects of the alternative
plans without enumerating and aggregating them for
each project and program.•
It is possible that certain of the information proposed by GFCC to be
eliminated might be of help to its public in understanding the planning
process and in’making decisions.
The description of the planning process by GFCC points out (4.F. p.
11.16) that:
A limited set of criteria were defined to select potential
projects and programs for each of the three plans formulated
in the P&S Analysis. The available data limited the appli-
cability of more sophisticated criteria. Plans formulated
under these limitations are not truly If optimal .“ However,
the NED and EQ Plans that were evolved are somewhat dis-
tinct in character, and provide a basis against which
the RA Plan can be compared.
State population projections and OBERS “C” and “E” projections were
used for the ORBC Level B report with the OBERS projections considered as
baseline.
EPA’ s interagency agreements with HUD and other agencies were not taken
into account in developing the Level B plan. ORBC states that these agree-
ments were unknown to the other agencies and therefore the effects could
not be considered. Air quality maintenance requirements were not considered.
Possible adverse water quality impacts of proposed projects were not identi-
fied in detail in the report but were included in the backup material con-
sidered during the judgmental planning process. Energy requirements were
not evaluated nor were possible impairments of downstream riparian water
rights considered.
Water Quality Management — Four major sources of water quality problems
in the Basin were identified:
Domestic sewage
Industrial wastes
4—33
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Acid mine drainage
Non-point sources
Information as to facilities needs to control discharges of municipal
and industrial wastes was supplied by the States and EPA.
Acid mine drainage is considered to be the nxst serious water quality
problem in the Basin, resulting from both active and inactive or abandoned
mines. Drainage from active mines is considered an enforcement problem
but abatement of pollution from inactive and abandoned mines will require
substantial public investment. Information and plans for control of acid
mine drainage were obtained from Applachian Regional Conunission and the
States.
Sediment from road construction, surface mines, timber harvest, agri-
culture (tilled land), grazing, oil and gas exploration, recreation, stream
bank erosion, urban development and other sources is considered to be the
major non-point source pollution problem.
The Level B Plan report presents very few quantitative data concerning
the present quality conditions of the water resources of the Basin.
The Comprehensive Coordinated Joint Plan report states that a number of
alternatives for water quality management were considered (4 .G., page C-4):
Effluent Treatment Measures
Secondary Waste Treatment
Advanced Waste Treatment
Industrial Waste Treatment
a. Best practical
b. Best available
Source Modification Measures
Nine Sealing
Land Treatment and Reclamation (including bank stabili-
zation)
Recycling
Neutralization
Individual Package Treatment Facilities (Residential
and Commercial)
Industrial Process Changes
4—34
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Operational and Regulatory Measures
Changes in tJse of Consumer Products (e.g. Pesticides
and Detergents)
Zoning and Development Restrictions
Operational Modifications to Existing Facilities o
Collector System
Centralization/decentralization of Institutions
Stream Flow Regulation
Effluent Flow Regulation
Reservoir Management
Effluent Taxes
Improved Enforcement Procedures
Other
No Action.
The report notes that “use of the water quality improvement w s
possible with existing information, but can be completed wh€ n State Wht:er
Quality Management Plans are complete” (4.G. P. N-71).
Of particular interest for future water quality manacrement in the Monon—
galiela River Basin is the conclusion that the existinq 7 da /i;) year minimum
low flows (of critical concern in water quality cont: ) - everal stream
reaches may be significantly reduced in the future due to increases in w ter
consumption for municipal, industrial, agricultural and energy productio i
demands, unless low flow augmentation is provided. Exaim.ie Jiven of such
potential reductions are (4.G., Pages N-24 and N-25):
Tygart River (Graf ton to Fairnont) - 22%
Cheat River (Rowlesburg to Pt. Marian) - 76%
Youghiogheny River (Cornelville to McKeesport) -- 36%
Monongahela River at Pittsburgh - 40%
With respect to water quality control, the Level B plan report recom-
mends:
4—35
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o Implementation of Stonewall Jackson Lake on the West
Fork River above Western, WV, for water quality con-
trol and other functions.
0 Detailed planning for Rowlesburg Lake, Preston and
Thcker Counties, WV, for water quality control and
other purposes;
o Detailed planning of several watershed projects for
water quality control and other functions;
* State determination by stream reach of minimum stream
flow requirements for aquatic life;
o State legislation to require reclamation at mire pros-
pecting sites;•
o A program of detailed planning for abandoned mine
drainage abatement as a federal/state responsibility;
0 Increased federal and state funding for abandoned mine
drainage and state enforcement programs for mine and
industrial discharges. This may require U.S. Congres-
sional legislation;
° A study of water quality and degradation in the basin,
particularly as to the effects of large and small im—
poQndxnents;
0 Development of West Virginia of recommendations to im-
prove land management practices for erosion and sedi-
ment control;
o Implementation by construction of certain municipal
sewerage facilities and detailed planning for others.
The controversial matter of interstate allocation of responsibilities
for required reimbursements to the United States by non-federal interests
is left for the recommended detailed planning studies.
The Level B Plan report notes (page 118):
The water quality recommendations were developed by
balancing existing and near term expected loads with
the water quality standards at tJ 7 day/lO year low
flow available in the streams. Effluents from in-
creased industrial activity and municipal growth will
have to fit within this overall balance and will be
accounted for through tbe National Pollutant Discharge
4-36
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Elimination System (NPDES). The major water quality con-
trol problem in the Monongahela is acid mine drainage from
abandoned mines. Economic and demographic projections are
secondary to legislative mandates for water quality control.
The manner in which the water quality standards were taken into account
is not further described. The base quality levels from which the benefits
of water quality improvements were evaluated are not stated.
Summary
The summary of the Environmental Impact Statement for the Level B
Plan describes the Plan recommendations and the environmental impacts in
the following terms:
DESCRIPTION OF ACTION : The Plan recommends Priority Group
I (0 to 5 years) implementation of one major reservoir, one
upstream watershed project, flood zoning and insurance at
13 locations, four local protection projects, 104 municipal
wastewater treatment facilties, 130 mine drainage abatement
projects, four local water supply facilities, the preser-
vation of two natural areas, and the replacement of one
navigation lock arid one lock and dam. Each specific recom-
mendation requiring Federal funds will have a detailed EIS
prepared by the appropriate agency prior to implementation.
The EIS summarized here identifies the net impacts of the
Plan as a whole.
BENEFICIAL ENVIRONMENTAL EFFECTS : The Plan provides for:
creation of 4,376 acres of flatwater lakes which would pro-
vide habitat for warm water fish and 1,615,000 annual visi-
tor days; preservation of flora, fauna, and areas of geologic
significance; sediment reduction in excess of 72,000 tons
annually; improved water quality through low flow augmen-
tation from Stonewall Jackson Lake; improved water quality
from 104 domestic sewage facilities and 130 orphan mine
projects; $12.3 million quantifiable annual benefits; in-
creased industrial and recreational activities generated by
one watershed project, one major reservoir, and two water
supply facilities; long-and-short-term jobs from the a ve;
flooding reduction from one water project, one major reser-
voir, and four local protection projects; reduced drought
risk by four projects.
ADVERSE ENVIRONMENTAL EFFECTS : The Plan would cause: inun-
dation of 4,376 acres of open and green space in a Basin of
4.5 million acres; disruption of 55 out of 11,000 miles of
existing natural stream channel by four projects; disruption
4—37
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of natural environment by users of recreation facilities;
costs of $10.2 million annually and $311.2 million total;
possible loss of 2,650 acres of coal resources and associ-
ated jobs; loss of land from the tax rolls.
OREC Staff Comments - The purpose of Level B studies is considered
to be:
The purpose of the Level B studies is defined under Public
Law 89-80, Section 201, (b) (4) as being to “foster and under-
take such studies of water and related land resources problems
in the area, River Basin, or group of River Basins as are
necessary in the preparation of the Plan described in clause
(2) of this sub—section.” Clause (2) concerns the preparation
of a comprehensive coordinated joint plan for Federal, State,
Interstate, local and Non—governmental development of water
and related resources. Further statements regarding the
purpose of Level B studies are contained in the policy state-
ment by the Water Resources Council, dated July 22, 1970. -
Regardless of whether it is titled Level B or 209, both Public
Law 89-80 and PL 92-500 recognize that comprehensive planning
is essential; that it requires a joint effort with all special
interest represented, organized formally or informally so du-
plication can be eliminated, conflicts resolved, compromises
which best meet the needs of all and do the least harm to any
can be identified and implemented; and that the analysis is
essential to determine: (1) what, in general should be done;
(2) which alternative best does what has been decided should
be done; (3) how well what has been done is doing what should be
done.
The above recognition was based primarily on the fact that
the goal above is unlikely to be accomplished by a single
agency or by a single agency funded or dominated effort.;
This recognition is based on the premise that an agency with
a special purpose can not conscientiously carry out its man-
date if it has the lead in a multi-purpose planning effort.
(Letter from ORBC dated 13 May 1976 In response to contractor’s
request for vIews on Level B planning).
The effects of upstream demands and developments constitute the prin-
ciple input front Level B planning to areawide water quality management plan-
ning. Input front areawide water quality management planning to Level B
planning should encompass land use plans and information on non-point
sources. Level B planning accelerates the planning process.
The Level B plan for the Monongahela River Basin recommends a cost—
effective allocation of. funds for water quality control.
4—38
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EPA regulations and guidelines should require states to participate
in areawide water quality management planning (Note: this now required
by 40 CFR 130).
Deviation from established water quality standards should be permitted
in Level B planning.
ORBC concurs with Section I, II, and III of WRC Proposed Guidelines
for Regional or River Basin Planning (4.P.) but does not agree with Section
Iv.
Areawide water quality management planning personnel did not partici-
pate in the Level B planning process to the extent desirable.
Public participation should be a joint endeavor between water quality
management planning and Level B planning programs.
Contractor’s Observation No. 1
It is not evident that ORBC agressively sought participation
by areawide and state water quality management planning agencies.
Such water quality agencies appear to have voluntarily participated
only to a minimal extent. The Level B planning by ORBC would
have benefitted from greater input by those agencies and the
recommendations might have been made more specific.
Apart from the information on acid mine drainage available
from the Appalachian Regional Commission and other sources it
appears that there was little information readily available
concerning discharges of pollutants fron non—point sources at
the time the Level B study was initiated.
The Monongahela Level B PlaxI can provide valuable inforina-
tion for water quality management planning, particularly with
respect to:
o potential minimum stream flow depletions due to
future water resource development and utilization
unless additional upstream water supply storage is
provided as recommended by the Level B Plan;
o the interstate nature of water resource management
problems especially as regards pollution from acid
mine drainage and sediment, and the necessity for
coordinated interstate remedial actions;
° some of the trade-offs to be considered in basin—wide
water and related land resource management;
4—39
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o prioritization of projects and programs, including those
for water quality management, in the context of overall
resource management needs and the timing thereof.
The methodology developed for application of the plan formu-
lation and evaluation procedures prescribed by the Principles and
Standards to the Level B planning process under the new approach
is reasonable and will be useful elsewhere.
The Level B Plan is in accordance with the basic essentials
of WRC Proposed Guidelines and fulfills the requirements of the
Principles and Standards.
For future planning for the CCJP, ORBC needs to:
o take full cognizance of PL 92—500, its goals, objec-
tives, mandates, and EPA implementing regulations,
particularly as regards water quality standards and
anti—degradation policy;
o place greater emphasis on water quality management
problems and on the quality impacts of water develop-
ment and utilization proposals.
o seek greater input from water quality management plan-
ning agencies; and
o incorporate areawide and state water quality management
plans and programs.
Pittsburgh 208 Area Planning
The designated Pittsburgh 208 Area includes the six counties of Alle-
gheny, Armstrong, Beaver, Butler, Washington and Westmoreland including
and surrounding the metropolitan area of Pittsburgh. Allegheny, Beaver,
Washington and Westmoreland Counties comprise the Pittsburgh SMSA. The
208 area includes the northerly portion of the Monongahela River Basin but
the greater portion lies outside that Basin. The designated area encompas-
ses about 4,500 square miles. The six county area is included in the State-
wide Comprehensive Water Quality Management Plan (C ThNP) Study Area No.
9 as defined by the State Department of Environmental Resources. Portions
are included in Air Quality Management Areas (5.A.).
Population of the designated area was 2,604,776 in 1970 and is expected
to reach about 2,851,000 by the end of the 20th century. The population
is now about 70.4% urban (5 .A.). The area is heavily industrialized.
Southwestern Pennsylvania Regional Planning Coninission (SPRPC) has been
designated as the areawide water quality management planning agency. A plan-
ning grant of $1,511,432 was awarded by EPA on June 30, 1975 (5.A.).
4—40
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At the time of interview (March 10, 1976), a 208 plan of study and
work control plan had not been completed and approved. A 208/COwAMp Work
Program was issued under date of March 15, 1976. This later program
includes the adjacent counties of Fayette, G een and Indiana as well as
the designated six—county 208 area. Essentially, it is a description and
scheduling of the tasks to be accomplished (5.C.).
A number of water quality problems were identified in the Section 208
Designation Proposal (5.A.), namely:
o Untreated and/or inadequately treated municipal and
industrial waste discharge;
o Acid mine drainage;
o Urban stream drainage, including combined sewer overflows;
o A variety of non-point sources, including erosion, agri-
cultural land runoff, feedlot runoff and de-icing activi-
ties;
o Thermal pollution;
0 Landfill leachate;
0 Excessive mineral constituent concentrations in surface
and ground waters.
Upstream interrelationships are not mentioned in the designation proposal.
Southwestern Pennsylvania Regional Planning Commission is cooperating
with the State of Pennsylvania in both the Comprehensive Water Quality Manage-
ment Planning program (COWAMP) and the State Water Plan program (SWP). These
two State planning progams are discussed later herein. SPRPC is responsible
for COWAMP and 208 planning in Water Quality Management Area No. 9 described
above.
SPRPC is providing population and other projections for SWP, Phase
II of which, development of alternatives and formulation of plan proposals,
is to be initiated soon. The interrelationships between SPRPC water
quality management planning and the planning being done by the State are
fully recognized. Most non—point source controls will be under State
jurisdiction.
Agencies that will be affected by water quality management are being
involved in the planning process.
SPRPC Staff Comments - More input to Level B planning by ORBC could
have been provided by SPRPC had sufficient funds been available.
4—41
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Greater participation by ORBC in water quality management planning
is desirable. Level B planning activities should be more visible to the
public. ORBC will, be helpful in achieving public understanding and ac-
ceptance.
Implementation of water quality management plans in Pennsylvania will
be difficult unless similar and coordinated actions are taken in West Virginia.
SPRPC staff is not familiar with WRC Proposed Guidelines.
The Level B Plan will be of little value to SPRPC insofar as Pennsyl-
vania is concerned. The same information could be obtained from the State’s
COWAMP and SW? programs. The Plan will be helpful as regards interstate
aspects although SPRPC could obtain much of the required information directly
from West Virginia agencies.
contractor’s Observation No. 2
Achievement of the water quality goals and objectives man-
dated by PL 92-500 within the designated Pittsburgh 208 area
will depend in part on control of upstream non-point sources,
particularly acid mine drainage and erosion; a considerable
portion of thepollutant load from these sources originates in
West Virginia. Control of such sources will be largely de-
pendent upon further legislative enactments and appropriations
for both studies and implementing actions by the States and
Federal Government. Coordinated interstate and Federal actions
will be necessary. Recommendations for such legislative ac-
tion on an interstate basis are included in the Level B Plan
as discussed above.
Upstream developments and use of water resources in the
three States may adversely affect the minimum stream flows within
the designated Pittsburgh 208 area. Such depletion of minimum
stream flows could be countered by providing additional upstream
water supply storage as recommended in the Level B plan, or avoided
by enacting water conservation practices and placing controls on
development, not considered in the Level B plan.
In view of the current uncertainties concerning control of
significant upstream nonpoint pollution sources and other potential
upstream effects, and the need for coordinated insterstate action,
cost—effective water quality management planning will be particularly
difficult.
The Level B plan can be of value to SPRPC in water quality
management planning for the Pittsburgh 208 area, particularly as
regards information on possible stream flow depletions. At the time
of the interviews, it appeared that this information was in fact more
readily available through the Level B Plan than through the State
of West Virginia.
4—42
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SPRPC should work closely with ORBC to achieve implementation
of the Level B Plan recommendations and in further planning for
ORBC’s CCJP.
Pennsylvania - Water Quality Management Planning
The Comprehensive Water Quality Management Planning (COWAMP) program
for the Commonwealth of Pennsylvania is conducted by the Bureau of Water
Quality Management, Department of Environmental Resources (DER). By April
1976, an application for a Federal grant for the COWAMP program had been
completed (6.C.). The COWAMP program, which was initiated in January 1974,
had been revised to accord with EPA requirements for State water quality
management planning set forth in 40 CFR 130 and 131.
The objectives of the DER planning process is stated to be (6.C.,
page 19):
The general objectives of Pennsylvania’s continuing plan-
ning process are to: (1) organize the elements of the
State’s water quality management program into an effective
and efficient force to implement state and federal water
quality management legislation; (2) describe the relation-
ships and linkages between the water quality management
program elements; (3) provide general direction for de-
velopment of specific activities to be carried out in
various program elements such as strategy development,
water quality standards development, water quality manage-
ment planning, public participation, monitoring, etc.; (4)
describe relationships between the water quality management
planning agencies and other agencies and planning programs;
(5) establish priorities and scheduling for significant
program activities.
The goals and objectives of the COWANP program are (6 .C., pages
22, 25, 26):
The overall objective of COWAMP is to establish a sound,
long-range basis for water quality management and pol-
lution control in Pennsylvania. Its scope encompasses
municipal and industrial was tewater collection and treat-
ment, abatement of combined sewer overflows, control of
agricultural and urban runoff, maintenance of groundwater
quality, acid mine drainage and disposal of sludges and
other process by—products. It calls for the inventory of
the pollution problems posed by each of the above sources;
the identification of the engineering, management, insti-
tutional, and financial alternatives available to deal with
them; and the development of an implementable program to
achieve specific water quality and regulatory objectives in
each study area. In cases where specific project or program
recommendations are not possible, recommendations will be
made for additional follow-up studies to carry forward the
COWAMP effort.
4—43
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The overall goal of the COWAMP program--is to develop a
cost—effective and environmentally sound water quality
management plan and program on a geographic and problem
specific basis. This plan and program will comply with
state and federal laws, regulations, and policies. Within
this overall goal, specific program objectives include the
following:
1. to identify environmental amenities and values
of regional, state, and national significance and
to develop potential water quality management
policies and practices that would aid in the pres-
ervation or enhancement;
2. to evaluate and where approp;iate modify existing
water quality standards to achieve federal and
state water quality objectives;
3. to identify and assess the impact of significant
point and non-point sources of pollution;
4. to identify major ground-water quality problems,
including their relationships to surface water
quality and to point and non-point sources of
pollution;
5. to establish municipal waste management priorities,
both on a regional and state—wide basis;
6. to identify the major technological, financial,
and administrative barriers to the attainment
of state and federal water quality objectives and
to reconmiend appropriate steps (including legis-
lation and regulations) to overcome them;
7. to develop new data management systems to supple-
ment existing ones for the storage, recall, and use
of socio—economic, environmental and water quality
data to facilitate the efficient operation of a
continuing planning process;
8. to develop and reconunend preliminary facility plans
on a regional basis that meet projected waste load
demands and water quality objectives;
9. to develop and recormnend preliminary institutional
and management arrangements that will facilitate
the construction of needed facilities on a timely
basis and assure their efficient and reliable oper-
ation;
4-44
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10. to determine the immediate and long-range eco-
nomic impact of recommended plans and programs
on the Commonwealth and its citizens;
11. to determine the existing statutory authority of
agencies involved in water quality management and
(where appropriate) to recommend appropriate modi-
fications to that authority;
12. to integrate to the greatest extent practicable
water quality management plans and activities
with other on—going environmental management
activities, including air quality management,
solid waste management, and water supply manage-
ment;
13. to initiate and develop the framework for a con-
tinuing planning process which provides for citi-
zen participation on an on-going basis;
14. to develop plan evaluation and update procedures;
15. to determine and reconvi end the monitoring and sur-
veillance program and strategy that will ensure
compliance with federal and state water quality
program policies.
DER has formed a policy advisory committee in each of the several study
areas into which the State has been subdivided for COWAMP. An advisory
state—wide COWAMP group has been formed consisting of representatives of
the following agencies (6.C., page 13):
Bureau of Water Quality Management, DER
Office of Enforcement and General Counsel, DER
Office of Planning and Research, DER
Governor’s Office of State Planning and Development
State Department of Community Affairs
State Department of Transportation
State Department of Agriculture
Southwestern Pennsylvania Regional Planning Commission
Delaware Valley Regional Planning Commission
Philadelphia Water Department
Environmental Protection Agency
4 45
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Chairmen, Policy Advisory Committee for each Study area.
To assure that COWAMP is properly coordinated with other DER activities,
a c( q j p management team has been formed consisting of representatives of
following DER agencies (6.C., pages 13, 14);
Bureau of Water Quality Management
Bureau of Environmental Master Plan
Bureau of Systems Management
Citizens Advisory Council
Office of Enforcement and General Counsel
Bureau of Topographic and Geologic Survey
Bureau of Air Quality and Noise Control
Bureau of Community Environmental Control
Bureau of Land Protection
Bureau of Resources Programming
Office of the Associate Deputy for Air, Water and
Community Protection.
In addition to COWANP, other interrelated planning programs are in
progress in Pennsylvania which are coordinated among themselves through a
variety of institutional mechanisms, namely (6.C., pages 15, 16):
0 The State Water Plan
o Wild and Scenic Rivers Program
0 Coastal Zone Management
0 Environmental Master Plan
o Solid Waste Management Program
0 Interim State Land Policy Plan
0 Sewage Facilities Act Plan
0 Air Quality Planning
COWAI4P appears to be fully coordinated with water quality management
planning in designated planning areas. Written agreements are developed
with areawide planning agencies prior to designation.
4—46
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State Planning Office population projections are used as baseline.
These are modified in some instances to accord with projections made by
regional planning agencies.
Alternative policies for water quality management are developed based
on studies of alternative environmental futures. Public participation is
emphasized. A common data base with the State Water Plan is used.
COWAMP Staff Comments - There was limited participation by COWAMP
staff in the Monongahela Level B planning by ORBC. Activity by the Mon-
ongahela CCJP Water Quality Work Group was limited.
COWAMP staff is not familiar with WRC Proposed Guidelines.
Usefulness of the Monongahela Level B Plan is limited; it is not rele-
vant. The interrelationships between water quality management planning
and Level B planning are principally those concerned with hydrological and
developmental effects.
States should do Level B planning for areas not within the jurisdiction
of a river basin commission. Level B planning should be properly sequenced,
prior in time, with water quality management planning and should be a con-
tinuing process. Level B planning should be more closely tied in to land
resource planning and management.
Greater funding should be provided for Level B planning studies with
allocations to participating agencies.
Level B planning staffs should have competent water quality special-
ists.
Contractor’s Observation No. 3
COWAMP staff should participate fully with the on-going ORBC
CCJP studies.
See observation below concerning Pennsylvania State Water
Plan.
Pennsylvania — State Water Plan (sWP )
State Water Planning activities in the Commonwealth of Pennsylvania
are conducted by the Bureau of Resources Programming, Office of Resources
Management, Department of Environmental Resources (DER). Planning was
initiated in 1966 pursuant to the Water Resources Planning Act of 1965.
Work by subbasins started in 1972.
The purpose of the State water Planning program is (6.8. Page 2):
4-47
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The purpose of this planning effort is to develop a flexi-
ble State Water Plan for the wise management of the Common-
wealth’s water and related land resources to meet the present
and future needs of the people of Pennsylvania, and to im-
prove the quality of life. Accordingly, the Plan provides
guidelines designed to:
1. Regulate the quantity and quality of available
water to assure adequate supplies of good water
to meet present and future needs, in consonance
with protection of the environment, as well as
the public health, safety, and welfare.
2. Develop and conserve water and related land re-
sources to meet.the residential, municipal, in-
dustrial, agricultural, electric power, navigation,
and recreational requirements, and to provide flood
damage reduction and water where necessary to meet
water quail ty management requirements;
3. Preserve the natural and scenic beauty of areas
adjacent to certain wild and scenic water areas
and streams for the use and enjoyment of present
and future generations.
4. Control and reduce the amount of [ acid] mine
drainage entering the streams of the Commonwealth
from abandoned surface and subsurface mines.
5. Establish priorities which permit needs to be
met in order of urgency.
6. Utilize the water and related land resources of
the Commonwealth toward achievement of the State’s
social, economic, and environmental goals.
The specific goals and objectives with respect to water quality manage-
ment are stated to be (6.B. pages 3-4);
Goal: Prevent pollution of the waters of the Common-
wealth, and reclaim and restore to a clean, unpolluted
condition all presently polluted waters so that probable
and planned water uses will be protected at all times.
Objectives :
a. Establish water quality standards designed to
protect all probable users of the Commonwealth’s
waters.
4-48
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b. Provide for development of water quality manage-
ment programs which include both individual and
regional waste collection and treatment systems
designed to protect and conserve the Commonwealth’s
waters.
c. Identify and develop institutional arrangements for
implementation of regional or basinwide water quality
plans.
d. Develop financing methods and programs for the pro-
vision of adequate present and future water zr anage—
ment facilities and devices.
e. Provide a basis for allocation of grant funds and
for enforcement of pollution control laws.
f. Control pollution from non—point sources, such as
sediment and agricultural wastes, and prevent pol-
lution incidents by requiring adequate product and
waste handling safeguards.
g. Develop and institute programs for control and
abatement of (acid) mine drainage from abandoned
mines.
Water quality management planning seems to be fully integrated with
water resources planning and is sequential in time. Water quality impacts
are fully evaluated. When completed, the water quality management plan
developed under the Comprehensive Water Quality Management Planning (COWAMP)
program will become the water quality management element of the State Water
Plan (6.B. page 32) (Page 47 above). In March 1976, SWP planning wasout of
phase with the COWAMP program; it was ahead by about 18 months. Problems
and needs had been identified, and alternative solutions formulated and
evaluated; release to the public was then scheduled for April 1976. SWP
and COWAMP use the same data base and same population projections.
In Pennsylvania, interbasin transfers through sewerage systems are
common. Downstream water uses under water rights in basins of origin are
frequently adversely affected through such transfers. A Stream Flow Regu-
lation Task Force has been established comprising representatives of SW?,
COWAMP, DER Legal Section, Bureau of Environmental Master PLanning and
Fish Commission. The representative of the Fish Commission acts as Chair-
man. There is active coordination -among the State resource planning agencies
and regional planning agencies.
SWP Staff Comments - The staff was not familiar with EPA regulations for
water quality management planning (40 CFR 130 and 131). WRC Proposed Guide-
lines were considered to be of little value. WRC Principles and Standards
4—49
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were judged to be of doubtful value and very difficult to apply although
the concept of identifying and evaluating trade-off s is good.
The mandates of PL 92-500 regarding effluent limitations and the
values thereof are accepted.
The value of Level B planning and plans is mostly in the area of
facilitating interstate coordination. The Corps of Engineers might be re-
sponsible for Level B planning for interstate stream basins not within the
jurisdiction of a river basin commission or interstate agency.
Benefits of low flow augmentation are much greater than EPA considers
them to be.
Contractor’s Observation No. 4
Water quality management planning in Pennsylvania appears to
be fully coordinated with comprehensive water and land resource
planning. This could well serve as an example for other states,
interstate agencies and water quality management planning agen-
cies.
The stated lack of familiarity with EPA regulations and WRC
Proposed Guidelines indicates the need for both EPA and WRC to
work closely with State agencies engaged in water resource plan-
ning including water quality management.
West Virginia
Water resource planning at the State Level had been reorganized shortly
before the time of interview and certain new personnel appointed. The
Office of Federal—State Relations in the Office of the Governor had been
designated as the State planning agency to oversee and manage water quality
management planning pursuant to Sec. 208, PL 92-500, for designated and
non—designated areas. Planning for non—designated areas is to be accom-
plished primarily by the Planning and Development Regional Councils (6.E.)
in cooperation with the Division of Water Resources, Department of Natural
Resources, and with assistance by U.S. Soil Conservation Service. A
coordinating committee is to be set up, but the communication and coordi-
nation problems were not yet worked out.
The Division of Water Resources (DWR) retains the responsibility for
State water resource planning and for planning to be accoix plished pursuant
to Sec. 303(e), PL 92-500.
DWR Staff Comments - There may be some overlap between water quality
management planning and Level B planning. The iinplementability of Level
B plans is questionable.
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State water resource planning is progressing but is limited by insuf—
ficient funds and personnel.
Maintenance of the present minimum 7 day/b year frequency stream
f lows is being attempted but depletions are frequently permitted.
Planning pursuant to Sec. 303(e), PL 92-500, will base water quality
standards, stream segment classifications and waste load allocations on
present conditions.
Present emphasis in water quality control is on municipal and industrial
discharges. Little attention has yet been given to other aspects of water
quality management.
Agricultural runoff and return- flows ate not a significant non—point
source problem. Individual sewage disposal systems, septic tanks and leach
fields, are a critical problem in certain areas where growth is rapid and
conditions for use of such systems are unfavorable. Erosion, particularly
due to highway construction, is a severe non—point source problem. Iron in
mine drainage as well as acid is a serious problem.
Control of acid mine drainage will be conducted at state level.
The value of Level B planning for water quality management planning
will increase over time. The current sequencing of the two programs is
questioned, however.
Contractor’s Observation No. 5
At the time of the interview, staff members of the Planning
Branch, Division of Water Resources, Department of Natural Resources,
indicated little knowledge of either Level B planning or of the Mo—
n.ongahela Level B plan. Likewise, there was little knowledge
indicated concerning the Urban Studies Program of the Corps of
Engineers.
At the time of interview, the staff of the Office of Federal—
State Relations in charge of water quality management planning
on behalf of the State had not had an opportunity to familiar-
ize themselves with EPA regulations and guidelines or with WRC
Proposed Guidelines and the Principles and Standards. The need
for full coordination between water quality management planning
and other aspects of water and related land resource planning
was recognized, however.
The reorganized state structure for planning may pose severe
problems in achieving the necessary coordination and integration
4— 51
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of the several activities in water and related land resource plan-
ning, particularly in view of the short time available for comple-
tion of the initial water quality management plans.
It is essential that the staffs of West Virginia agencies in-
volved with water quality management planning become familiar with
related planning programs and actively coordinate their planning
activities with such other programs. It is particularly impor-
tant that there be active participation in the ORBC CCJP con-
tinuing planning process.
Environmental Protection Agency, Region III
Representatives of Region III participated actively on the Study Dir-
ection and Plan Formulation Committee and on the Water Quality Work Group
for ORBC’s Monongahela Comprehensive Coordinated Joint Plan program in-
cluding Level B planning.
Region III, EPA Staff Comments - Level B planning and the Level B
plan are valuable in that:
it brought together and evaluated the several plans
and proposals that had been made previously and pre-
sented a recommended program with priorities based
on consensus;
o It gives projections of future water demands and
minimum stream flows; and
o provides a mechanism for coordination.
The principal value of Level B planning is for interstate streams.
More attention should be given to water quality impacts and water quality
management than was the case for the Monongahela Level B plan.
Water resource planning in Pennsylvania--both COWAMP and SWP--is
beingwellaccomplished. Planning in West Virginia had not yet been organized
under the new alignment of responsibilities.
Region III staff interviewed were not familiar with WRC s “new approach”
or with the Proposed Guidelines. Principles and Standards are not of much
value except as an exercise to identify benefits and costs, with some
quantification, and the trade—of fs to be considered.
Established water quality standards should be accepted .as baseline
conditions for Level B planning. Water quality management planning should
be regarded as one component of comprehensive water and related land
resource planning.
4—52
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Contractor’s Observation No. 6
The stated lack of familiarity with WRC’s Proposed Guidelines
arid procedures indicates the need for WRC to work more closely
with EPA’s regional Offices.
Other Agency Staff Comments
Corps of Engineers, Pittsburgh District, staff suggested that Level
B planning is helpful in that it brings together and integrates into a
comprehensive package, the proposals, programs and views of all agencies.
It provides the opportunity to prioritize projects and programs, including
those for water quality control. The District staff had no opinion regarding
the WRC Proposed Guidelines.
4—53
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REFERENCES
Central Snake Case Study
1. Central Snake River Basin
A. Idaho Department of Water Resources. Conclusions and Recom—
mendations for the State Water Plan — Part II, Snake River Basins .
March 1976.
B. Idaho Department of Water Resources. Effects of Full Development
of Existing Water Right Permits and Applications Below M.ilner
Dam on Flows of Snake River . January 1976.
C. Idaho Department of Water Resources. Newspaper supplement
describing issues in Snake River Basin. Undated.
D. Idaho Department of Water Resources. You and Water. A Summary
of Answers to the Snake River Basin Newspaper Supplex tent Question-
naire . September 1975..
B. Pacific Northwest River Basins Commission. Comprehensive Frame-
work Plans, Appendix (XIV) Columbia-North Pacific Region Compre-
hensive Framework Study . Vancouver, WA. June 1972.
F. Pacific Northwest River Basins Commission. Main Report. Columbia-
North Pacific Regional Comprehensive Framework Study . Vancouver,
WA. September 1972.
G. Pacific Northwest River Basins Commission. Minutes of the thirty-
sixth meeting. March 22, 1973.
H. Pacific Northwest River Basins Commission. Minutes of the thirty-
seventh meeting. July 12, 1973.
I. Pacific Northwest River Basins Commission. A Plan of Study for
Preparing the Comprehensive Joint Plan for the Pacific Northwest -
A Supplement to the Western U.S. Water Plan of Study . Vancouver,
WA. December 1971.
J. Pacific Northwest River Basins Commission. A Plan of Study for
Preparing the Comprehensive Joint Plan for the Pacific Northwest -
A Supplement to the Western U.S. Water Plan of Study. Appendix
C. Plan Formulation . Vancouver, WA. June 29, 1972.
K. Pacific Northwest River Basins Commission. A Plan of Study for
Preparing the Comprehensive Joint Plan for the Pacific Northwest —
A Supplement to the Western U.S. Water Plan of Study. Appendix D.
Rescoped Study Program . Vancouver, WA. March 22, 1973.
4-54
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L. Pacific Northwest River Basins Commission. September 30, 1975
Status Report. Comprehensive Joint Plan .
M. Pacific Northwest River Basins Commission. Water Quality and
Pollution Control. Appendix (XII) Columbia- North Pacific
Region Comprehensive Framework Study . Vancouver, WA. December
1971.
N. United States Environmental Protection Agency. National Water
Quality Inventory, 1974 Report to the Congress (Snake River Por-
tion). Washington, DC. 1974.
2. Ada.Canyon Counties 208 Area
A. Ada/Canyon Areawide Waste Treatment Management Committee. Grant
Application - Areawide Waste Treatment Management Planning . Boise,
ID. May 1975.
B. Ada/Canyon Areawide Waste Treatment Management Committee. Project
Control Program . Boise, ID. August 1975.
C. Ada/Canyon Areawide Waste Treatment Management Committee. Purchase
of Service Contract with the Department of Health and Welfare,
Division of Environmental Services - Appendix A, Services to be
Performed . Boise, ID. October 9, 1975.
D. Ada/Canyon Areawide Waste Treatment Management committee. Section
208 Milestone Report No. 1, July-September, 1975 . Boise, ID.
September 1975.
E. Ada/Canyon Areawide Waste Treatment Management Committee. Section
208 Milestone Report No. 2, October-December, 1975 . Boise, ID.
December 1975.
F. Ada Council of Governments and Canyon Development Council. Appli-
cation for Designation as the Section 208 Water Quality Management
Planning Agency . Boise, ID. January 1975.
G. Ada Council of Governments, Canyon Development Council and U.S.
Army Corps of Engineers. Plan of Study, Boise Valley, Idaho Re-
gional Management Study . June 1973.
H. Andrus, Governor Cecil D. Letter to Clifford Smith, Regional
Administrator, EPA, dated January 17, 1975 concerning designation
of Ada/Canyon Areawide Waste Treatment Management Committee.
r; Armacost, LV. Letter to H.J. Owen dated 26 February 1976 concerning
Boise Valley, Idaho, Regional Water Management Study. -
4-5:5
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J. Gabettas, James. Letter to Alvin S. Marsden, Ada Council of Govern-
ments dated March 24, 1975, concerning federal lands.
K. Idaho Department of Health and Welfare. Letter dated May 15, 1975,
from James A. Box, Director of IDHW to George Pattis concerning
State certification of 208 grant application of Ada/Canyon Area—
wide Waste Treatment Management Committee.
L. Idaho Department of Health and Welfare. Memorandum to Ada/Canyon
Areawide Waste Treatment Management comitttee concerning Identif i-
cation of major and natural streams and surface water bodies in
the Ada Canyon 208 area. February 4, 1976.
N. Idaho Department of Health and Welfare. Memorandum to Lynn McKee,
EPA, recommending approval of the Ada/Canyon Project Control Program.
August 12, 1975.
N. McKee, Lynn. Letter to H.J. Owen dated 24 February 1976 concerning
the status of water quality planning.
0. Minter, R. Memorandum dated January 13, 1976, to ACOG, CDC, EPA,
IDHW and USCE concerning economic and demographic projections and
analysis for the Ada/Canyon 208 area.
P. Myers,Carl. Water Planning Division, EPA. Undated letter to Ada/Can-
yon county, Idaho 208 Designation File,concerning Federal Lands.
Q. Smith, Clifford V. Letter to Governor Jthdrus, dated April 21, 1975,
approving designation of Ada/Canyon 208 planning area.
R. Train, Russell E. Letter to Governor Pndrus, dated April 2, 1975,
approving designation of Ada/Canyon 208 planning area.
S. United States Environmental Protection Agency. Background Summary,
Ma/Canyon Waste Treatment Management Committee [ undated).
T. United States Environmental Protection Agency. Evaluation of Sec.
208 Designation. Ma/Canyon Counties, Idaho [ undated).
3. State Water and Related Land Resources Planning Programs
A. Andrus, Governor Cecil D. Undated letter to heads of all State
agencies directing observation of the Objectives report.
B. Idaho Department of Health and Welfare. Draft “Statewide 208”
Workplan Outline . March 15, 1976.
C. Idaho Department of Health and Welfare. State of Idaho, Water
Quality Program Strategy . FY 1976.
4 %
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D. Idaho Department of Health and Welfare. Statewide Water Quality
Management Planning Report (annual strategy). February 1976.
B. Idaho Department of Water Resources. Application of Water Resource
Planning Grant (Title III), August 1974.
F. Idaho Department of Water Resources. Application for Water Resource
Planning Grant (Title III), June 1975.
G. Idaho Department of Water Resource. The Objectives, State Water
Plan - Part One . June 1974.
H. Indiana University School of Public and Environmental Affairs. Idaho
Report. Problems and Approaches to Areawide Water Quality Manage-
ment . 1972.
I. Opinion Research West. A Survey of Public Attitudes and Opinions
on Idaho Water Resources . Boise, Idaho. August 1975.
Monongahela Case Study
4. Monongahela River Basin
A. Ohio River Basin Survey Coordinating Committee, Ohio River Basin Com-
prehensive Survey , Main Report, Volume 1, August 1969.
B. U.S. Department of the Interior, Federal Water Pollution Control Ad-
ministration, Ohio River Basin Comprehensive Survey, Water Supply
and Water Pollution Control , Appendix D. Volume V. June 1967.
C. Ohio River Basin Commission, A Plan of Study for Preparing the
Monongahela River Basin Portion of the Comprehensive Cooridnated
Joint Plan for the Ohio River Basin . Revised September 1972.
D. Ohio River Basin Commission, Level B Plan of Study for the Monongahela
River Basin Comprehensive Coordinated Joint Plan . January 1974.
E. Ohio River Basin Commission, Monongahela River Basin Water and Re-
lated Land Resources Study Report . July 1975.
F. Gannett, Fleming, ‘Corddry and Carpenter, Inc., Engineers. Monon-
gahela River Basin Principles and Standards Analyses . Final Report.
December 1975. Prepared for Ohio River Basin Commission.
G. Ohio River Basin Commission. Monongahela River Basin Comprehensive
Coordinated Joint Plan (CCJP). July 1975.
H. Ohio River Basin Commission. Definition of the Comprehensive Co-
ordinated Joint Plan for Water and Related Resources for the Ohio
River Basin . Revised July 24, 1975.
4—57
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I. Ohio River Basin Commission. Policy Statement for Public Par-
ticipation . Adopted October 25, 1973.
J. Ohio River Basin Commission “What is Your Opinion of the Proposed
Projects and Programs?” Planning Workshop Book for the Monongahela
River Basin Comprehensive Coordinated Joint Plan . October 1974.
K. Ohio River Basin Commission. Summaries, Planning Workshops, Mon-
ongahela River Basin Comprehensive Coordinated Joint Plan .
(1) October 15, 1974, Oakland, MD.
(2) October 23, 1974, Belle Vernon, PA.
(3) October 28, 1974, Buchannon, WV.
(4) December 4, 1974, Fairinont, WV.
L. Ohio River Basin Commission. Summaries, Monongahela CCJP Water
Quality Work Group .
(1) May 21, 1973.
(2) September 18, 1974.
M. Ohio River Basin Commission. Summaries, Study Direction and Plan
Formulation Committee for the Monongahela River Basin CCJP .
(1) May 31, 1973.
(2) October 2, 1973.
(3) December 11, 1973.
(4) March 26, 1974
(5) June 19, 1974.
(6) September 19 1974.
(7) December: 5, 1974.
(8) February 26—27,1975.
N. Ohio River Basin Commission. Summary, Monongahela Working Board
Meetipq . June 10—13, 1974.
0. Ohio River Basin Commission. Comments on Level B Plan Report by
Various Agencies . November 1975 - January 1976.
P. Ohio River Basin Commission. ORBC Policy on WRC Guidelines for Level
B’Studies . Adopted January 22, 1976.
4—58
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5. Southwestern Pennsylvania (Pittsburgh) 208 Area
A. U.S. Environmental Protection Agency. Background Information.
Pittsburgh 208 .
B. Southwestern Pennsylvania Regional Planning Commission. Section
208 Designation Proposal . April 1975.
C. Southwestern Pennsylvania Regional Planning Commission. 208/COWAMP
Work Program . March 15, 1976.
6. State Comprehensive Water and Related Land Resources Planning Programs
A. Commonwealth of Pennsylvania, Department of Environmental Resources.
Applications for Title III Assistance Grants under Authority of
the Water Resources Planning Act of 1965 (PL 89-80, 79 Stat. 244) ,
for Fiscal Years 1975 and 1976.
B. Commonwealth of Pennsylvania, Department of Environmental Resources
State Water Plan , SWP-1. March 1975.
C. Commonwealth of Pennsylvania, Department of Environmental Resources,
Bureau of Water Quality Management. Federal Grant Application for
Comprehensive Water Quality Management Planning . April 1976.
D. State of West Virginia, Department of Natural Resources, Division
of Water Resources. Applications for Planning Assistance Under
Title III, Water Resources Planning Act, (PL 89-80, 79 Stat. 244) .
for Fiscal Years 1975 and 1976.
E. n Act of the West Virginia Legislature, Second Extra-ordinary Ses—
sion, 1971, Regional Planning and Development . Approved by the
Governor November 17, 1971.
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CHAPTER 5
PLAN INTERRELATIONSHIPS
Defining and evaluating the interrelationships between water quality
and water quantity planning in all aspects may add substantial complexity
to both Level B and water quality management planning studies. However,
their consideration is generally necessary if recommended plans of either
type are to realistically recognize the full range of impacts. This Chap-
ter briefly describes rudimentary interrelationships which should be con-
sidered. While those described might appear so basic as to not require
mention, experience indicates otherwise. Based on the case studies per-
formed and on the experience of. the principal investigator in water
resources planning studies in various contexts in the United States and
elsewhere, the interrelationshps discussed are often not understood, or
at least not considered.
Some of the interrelationships that should be considered in planning
for both water quality management and control, development and use of water
and related resources for beneficial purposes have long been recognized.
However, the full range of interdependencies has not been appreciated or
taken into account by all planners engaged in the manifold planning pro-
grams now in progress. The effects of lack of full understanding are
exacerbated by the fact that water quality management planning for a par-
ticular area or basin and “quantity planning” in or affecting the same
geographic area are usually done by different agencies or by persons with
different professional and administrative orientations.
Quality planning has traditionally been an activity of a water pol-
lution control agency, influenced in times past very heavily by public
health motivations and more recently by additional considerations in-
cluding quality as related to protection and propagation of fish and
wildlife, to esthetics and water—oriented recreation, and to industrial
and agricultural water supplies. In contrast, quantity planning has
usually been project oriented and has tended to view quality as either
beside the point or of secondary concern because it was the responsibility
of someone else.
Level B planning is defined as a particular scope and intensity of
planning rather than as necessarily for any onepurpose to the exclusion
of others. Until recently, the customary objective of a Level B plan
was to identify and rationalize the need for water resources projects——
generally those involving the construction of public works. Consequently,
introduction of the full gamut of water quality concerns to Level B
planning necessitates acceptance by planners of a different and more
diverse framework in which there should be a balancing of developmental
values with possible quality detriments or enhancements, and in which
5—1
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the scales may be tipped for or against a particular kind of development,
depending on overall policy considerations concerning quality protection.
In such a context, the Level B process may become a forum for reconciliation
of competing quality and quantity values in a way previously not envisioned
for this type of planning.
Water quality management planning is intended to be “comprehensive”
residual waste management planning carried on in recognition of the inter-
actions with a variety of other societal concerns such as land management,
transportation, industrial and agricultural activity, and residential
development.
Level B planning should be comprehensive as well in the context of
overall water and related resource management. It should consider both
quality and quantity. in the context of overall water resource management.
A tacit assumption of Level B planning characteristic of earlier
times was that water quality was of little or no economic value. This
outlook was a reflection of the times and conditions in which it was
conducted and was consistent with policy judgments no longer taken
as a matter of course. As these policies change, and as planners more
fully and routinely consider both quantity and quality aspects of water
resource management, both water quality management and Level B plans
will need to incorporate consideration of the economic values of waters
of different qualities in the particular setting of the basin or area
involved.
A balancing or consideration of tradeoffs may pose a problem in
ti context of quality planning. The Federal Water Pollution Control
ACt Amendments of 1972 have the dominant purpose of attaining the
water quality objectives and goals set forth in the statute. While
there are some provisions of the law which call specifically for con-
sideration of economic factors, especially those associated with com-
merce and industry, the Act appears to intend that water quality manage-
ment planning be done with the improvement and maintenance of quality as
the dominant element.
Sane of the important general relationships that should be con-
sidered reciprocally in water quality management planning and in Level
B planning are discussed below. In specific situations, a wide spectrum
of interdependencies may be significant. The importance of each inter-
dependency may vary according to the severity of water quality problems,
present and anticipated future uses of water for beneficial purposes,
and other factors peculiar to a specific area.
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Data Base
Historic records or estimates concerning hydrology, both quantity
and quality, of surface and ground waters,meteorology, water uses, land
uses, waste generation, treatment and disposal, population growth, economic
development, and recreation and other amenities, are the fundamental base
for planning and management of water and related resources. Land classi-
fication and capabilities, and areas of critical environmental concern
are of common interest in planning programs. Use of a common data base
by all agencies engaged in planning activities involving water and related
resource management is essential if the resulting plans are to be compre-
hensive, fully coordinated, and consistent with one another. Demographic,
economic, and land use projections and other generally applicable data
should also be the same as those used for types of planning not directly
related to water quantity or water quality planning. Use of a common data
base for all functional planning enables decision makers to examine al-
ternative demands for public investments on a rational basis.
Air Quality
Maintenance and improvement of air quality is mandatory under the
Clean Air Act of 1970 as amended; pending amendments would increase the
stringency of regulatory and control measures. Potential impacts on air
quality must be carefully evaluated for all demographic, economic, and
land use projections and in all planning activities. New urban and in-
dustrial developments considered in Level B planning, or which might be
induced by resource developments, could have adverse air quality impacts.
Certain methods of waste treatment, incineration of sludge and solid
wastes for example, may likewise have adverse impacts.
Regulation in the interest of air quality is lodged in the same agency
with water quality management at the federal level and in some states.
However, different administrative units and personnel usually have oper-
ational and even policy responsibilities for the water and air quality
control programs. Further, these programs are generally administered
under different statutes. Consequently, the need in both water quality
management and Level B planning is for those doing it to be fully conver-
sant with air quality requirements and plans and to take them into account.
Water Quality Standards
Achievement of water quality standards adopted by the States and ap-
proved by EPA pursuant to PL 92-500 and implementing regulations, is
mandatory. Federal, State and local water quality management planning
agencies must necessarily base their plans on the approved standards and
on the stream segment classifications and waste load allocations in accord
with the standards. As discussed below, projects and programs considered
5—3
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under Level B planning could affect such standards through additional
generation of wastes from point or non-point sources or both, or through
alteration of hydrologic regimes. The standards must be taken into
account in Level B planning, if Level B and water quality management
planning are to be complementary, and any proposal that would adversely
affect the approved standards or stream segment classifications or waste
load allocations must be fully justified and dependent on a revision of
the standards in accordance with prescribed procedures (40 CFR 130.17).
In some instances such proposals may conflict with proposals for higher
standards which are recommended as a means of decreasing the cost of
water treatment to meet Safe Drinking Water Act requirements. Con-
versely, water quality management planners should recognize that some
proposals recommended in Level B plans might be beneficial in main-
taining water quality standards.
Demographic and Economic Projections
All planning related to future management of water and related re-
sources necessarily involves projections of population growth and eco-
nomic development. All water and related resource planning activities
should be based on common projections in order that estimates of future
water demands and of resultant waste generation will be consistent.
OBERS projections could well be used for baseline conditions for
both water quality and water quantity planning. Modifications made by
individual planning agencies to accord with localized conditions and
with State and local views should be consistent for the region or river
basin.
Land Use
Projections of land uses by type and areal location to accord with
projections of demographic and economic growth are the basis for estimates
of future water needs and resultant future waste generation, and of the
need for control measures and facilities for waste collection, and dis-
posal. These projections, too, should be common for all planning activi-
ties related to water and related resources.
Hydrologic and Hydraulic Effects
Any development and use of water will alter the hydrologic regime
of the water resources involved, surface water or ground water or both,
in terms of quantity, rates of flow, water levels, quality and other
hydrologic characteristics. The effects are diverse in type, amount and
impact location, and vary with the particular situation. The impacts
may be beneficial in some respects and adverse in others as related to
5—4
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water quality management. Similarly, implementation of water quality
management plans may have significant hydrologic effects on surface and
ground waters and the uses thereof. A few generalized impacts based on the
experience of the principal investigator, are discussed to illustrate some
of the factors that should be considered in planning.
Obviously diversion of surface water for municipal and industrial
uses or for irrigation will deplete low flows downstream unless releases
from upstream storage are provided, in which case low flows may be in-
creased. But impoundments may result in significant overall losses
of water through evaporation thus increasing mineral concentrations. Re-
leases from storage to stream channels will generally change the temperature
regime; properly managed releases may result in quality improvement bene-
ficial to instream and other uses.
Additional development of ground water for beneficial use may lower
ground water levels and, in situations where ground water supports stream
£ low through effluent seepage, may thereby decrease base stream flows.
Return flows to the ground water body from use of the ground water on over-
lying lands may increase mineral concentrations which in turn may increase
concentrations in stream flows.
Conversely, use of surface water for irrigation may increase ground
water recharge through deep percolation and if of high quality, may tend
to improve existing poor ground water quality. This may in turn improve
stream base flow quality. Similar effects may result from artificial
ground water recharge with high quality water either imported or through
conservation of local runoff.
Increased stream flows from releases from storage and lowered ground
water levels due to ground water development may each result in increased
ground water recharge with alteration in ground water quality.
These hydrologic impacts of activities involving control, develop-
ment, and use of water resources for beneficial purposes are of great
significance to water quality management. The effects on stream flows
are particularly important since changes in critical low flows, the 7
day average 10 year frequency minimum flows, as illustrated in the Monon—
gahela Level B plan for example, could change stream segment classifica-
tions and waste load allocations over time. Changes in ground water
quantity and quality are of concern with respect to effluent disposal
on land. New or increased uses of water for municipal or industrial
uses or for irrigation that might be proposed in a Level B or similar
plan, would result in increased generation of wastes from point and non—
point sources with resultant increase in cost for treatment and disposal
and for control of wastes from existing point and non—point sources.
It is entirely possible that the net benefits resulting from new
or increased use of water for beneficial purposes may justify revisions
5—5
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in water quality standards. In this regard the economic value of water
quality is important.
Water quality management activities too may have significant hydro-
logic effects. changes in locations of effluent discharges to streams
such as might result from regionalization or consolidation of sewerage
systems, may decrease flows in some stream reaches and increase discharges
in other stream segments. The effects may be detrimental to some water
uses and beneficial to others.
A change in disposal of effluent from streams to land often results
in loss of water resources available for use through the large evaporative
losses resulting from some methods of land application. Land disposal may
increase ground water recharge but could impair ground water quality and
in turn affect stream flows.
Depending upon the particular technique used, control of non-point
sources of pollution such as reduction in irrigation return flows, may
cause substantial reduction in stream flows.
The interrelated hydrologic effects on water resources involved due
both to management for beneficial purposes and to water quality management
are equally of concern to Level B or similar planning and to water quality
management planning, and should be mutually considered and evaluated on a
coordinated basis. It is important too that the full range of benefits
and costs, including those resulting from hydrologic int.erdependencjes, be
carefully considered in both types of planning.
Water Rights
Riparian rights, i.e. rights to use of water for beneficial purposes
on lands which have been in continuous contact with the stream, attach
to some or all surface waters of most states. Riparian rights are neither
created through use nor lost through non-use and have not been quantified
for most water bodies. Such rights are particularly important to the
eastern, southern and mid—western states. Strict interpretation of the
riparian doctrine holds that the riparian owner is entitled to receive the
natural flow of the stream undiminished in quantity and unimpaired in
quality, subject only to the correlative rights of other riparian owners.
The overlying right to ground water is somewhat analogous to the
riparian right.
Appropriative right-s have also become vested to the waters of most
streams and other surface waters and to many ground waters, particularly
in the western states. Appropriative rights become vested through actual
diversion and use of the water and may be lost through non—use. Such
a right is for a specific amount of water to be diverted or withdrawn
5—6
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from a particular water resource at a specific place for a particular use
or uses at a specified place or places. n appropriative right to surface
water and, in some states to ground water, is now generally initiated by
following procedures prescribed by law. Many streams in the west are
overappropriated in terms of the total of permitted amounts.
Riparian rights may be impaired both in quantity and quality by
activities of those upstream. Appropriative rights may likewise be im-
paired in quantity and presumably in quality although case law is generally
not clear as to the latter.
With respect to appropriative rights, waste dischargers generally
cannot be required to continue a discharge, even if beneficial uses have
developed which are dependent on that flow.
Water rights are generally considered either explicitly or implicitly
in water quantity planning such as Level B. PL 92-500 and the implementing
EPA regulations are silent on the subject of consideration of water rights
in water quality management planning. Water quality standards established
pursuant to the statute and regulations will generally protect vested
water rights as regards quality. However, as noted in the preceding
discussion of hydrologic effects, implementation of some water quality
management plans formulated in strict conformity with PL 92—500 and the
regulations could seriously decrease the amount of water available to
satisfy vested water rights downstream. Water quality managment planning
has generally not considered water rights and the economic and social
consequences of infringement of vested rights.
It is important that water rights be fully considered coordinately
in all water and related resources planning activities.
Social Impacts
Social well—being effects of water quality management plans should
be evaluated generally on the same basis as that prescribed by WRC Prin-
ciples and Standards for Level B planning. Social impacts of water quality
management may be complementary or supplementary to those resulting from
other activities in water resources management. Here too, coordination
of planning and evaluation is desirable.
Energy Impacts
Increasing amounts of energy will be required to provide the higher
levels of treatment of wastes necessary to meet the 1983 objectives speci-
fied in PL 92—500. Likewise, greater amounts of energy will be necessary
to develop, treat and transport the increasing amounts of water required
5—7
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to meet the needs of the Nation’s growing population. For example,
meeting the requirements of the Safe Drinking Water Act will necessitate
higher degrees of water treatment with resultant greater amounts of energy
expended for many communities.
As previously noted, these are significant interdependencies among
the several aspects of comprehensive water resource management. In view
of energy deficiencies, every effort should be made among water and related
resources planning agencies to formulate coordinated plans that will tend
to minimize the total expenditure of energy.
Future availability of adequate supplies of energy is recognized as
a serious national problem. Water is a key element in most energy pro-
duction technologies in use now and expected to be employed on a widespread
basis in the foreseeable future. Water resource management plans must
consider both the requirements for water for energy production and the
effects of use of water for energy. The forecasts of energy deficiencies
and the locational flexibility of energy use make it essential that use
of water for energy be a major focus of all Level B plans, as well as
water quality management plans.
Planning Under Uncertainty
Water quality management planning and Level B planning must both be
conducted under conditions of uncertainty concerning the future of important
related aspects of management of the water and related resources. It is
highly important, therefore, that continuing coordination be maintained
with the other planning agencies and with implementing actions. Treatment
of risk and uncertainty is reflected in planning horizons, evaluation of
benefits and costs, financial plans and in other ways. Similar approaches
would aid coordination of the programs. At the least, differing approaches
to uncertainty should be expressly recognized by planning participants
and coordinating agencies.
Obviously, a high degree of flexibility must be incorporated in water
quality management plans to enable adaptation to future changes in other
aspects of management.
Summary
Despite a long time recognition that there is a need for comprehen-
sive planning, the usual approach has been for each specialty to attempt
to broaden its outlook somewhat. This is true both within and outside of
the water disciplines. The housing planner now considers transportation,
traffic, public recteation, location of industry, the environment and
law enforcement because these factors have an effect on how and where
people are likely to live. The highway planner examines the same subjects
5—8
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because they influence the need for roads and streets. The water quality
management planner must contemplate the same factors because they impact
on waste flows.
How to conduct overall societal planning is far beyond the scope of
this study and more than any legislative authorizations at the federal or
state level have yet conceived. Within the water resources field, however,
the need to comprehend both quality and quantity concerns within a single
or coordinated planning structure has been addressed to some extent.
The Level B plan, although until recently viewed almost entirely as a
developmental tool oriented toward projects, is the closest of the
several planning concepts to a comprehensive approach. This is especially
the case if it can be made in practice to give the requisite degree of
attention to quality considerations. Consequently, it is the type of
planning which should be put to use in aid of the purposes of water quality
management planning envisioned in PL 92-500.
Planning for water quality management should be viewed and accomplished
as one component of planning for comprehensive management of water and
related resources. Water quality management planning should fully con-
sider the possible effects of potential future developments for control,
development arid use of water resources in the river basin involved on
the hydrologic regimens, in both quantity and quality, of the surface
and ground waters. Likewise, the impacts of measures for water quality
management on all other aspects of the development and utilization of the
water resources involved, particularly downstream, should be evaluated.
Those engaged in Level B or similar planning for control, development and
use of water and related resources must consider and evaluate the potential
effects of their plans on quality and on waste generation, treatment and
disposal. All costs involved in these reciprocal effects should be evaluated
qualitatively if impossible to quantify.
The most cost effective plan for water quality management in a
particular area, considered by itself, may not be the best solution for the
river basin (or society) as a whole. Conversely, a plan for control,
development and use of water resources which does not properly consider
quality impacts may result in greatly increased costs for facilities and
measures to protect and maintain quality at mandatory levels. In either
case, serious mis—investments or inequities may result. The limited
financial capability in any area to implement and operate water related
programs must be carefully husbanded and judiciously allocated to achieve
the maximum benefits possible.
The objectives should be to produce fully coordinated plans for com-
prehensive management of the water resources involved, including water
quality management in accordance with federal and state mandatory policies,
which will result in the best net mix of economic, environmental and social
benefits.
5-9
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APPENDI CES
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J PPENDIX A
DESCRIPTION OF POTENTIAL CASE STUDIES
Identification by the Contractor of Level B studies for recommendation
to the Project Officer as case studies was accomplished in a two step pro-
cess. Initially, attention was given to all regional or river basin studies
either underway or completed. Studies eliminated from consideration as a
first step included Type II studies and Level B studies completed under
the “old” approach, recently initiated Level B studies and studies
heavily oriented to a single functional purpose. Level B studies re-
uiaining after this first screening included those for:
Yakima River Basin;
Hawaii (statewide);
Maumee River Basin;
Minneapolis-St. Paul (Lower Minnesota and Upper
Mississippi Rivers);
Central Snake River Basin; and
Monongahela River Basin.
The second step of the selection process included more detailed con-
sideration of each of the remaining candidate studies. Information was
collected concerning each study with respect to status, schedule for com-
pletion, area encompassed, participants, study emphasis, and other study
characteristics. Selection of the two studies recommended was then made
based on five criteria, namely:
1. Relative completeness and availability of a Level
B product prepared under the “new approach”;
2. Likelihood of access to the principal participants
in the Level B study;
3. Existence within the Level B study area of a desig-
nated 208 area and areawide planning organization,
preferably one which had at least completed a plan
of study;
4. Representativeness, to the extent possible, of other
areas for which Level B studies have been or may be
undertaken;
5. Diversity with respect to character of the area and
interests, hydrologic characteristics, and types of
problems related to water quality and water use.
A-l
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Yakima River Basin
Level B studies in the Yakima River Basin were nearly complete. The
recommended plan had been formulated and study participants were engaged
in both preparing the study report and conducting a public review of the
plan. Since the study was underway, potential for access to participants
was excellent. Study emphasis was reportedly well balanced but providing
extensive treatment of fish and wildlife. However, EPA was not significantly
involved in the study.
No areas within the Yakima River Basin had been designated by Washing-
ton’s Governor for water quality management planning by local organizations.
The Yakima River Basin is heavily agricultural with extensive irri-
gation development and significant opportunities remain for further irrigation.
The basin is similar in many respects regarding interests and hydrology
to the Central Snake River Basin.
Hawaii (statewide )
Level B studies in Hawaii had not progressed to the point of having
alternative plans although they were under active development using the
“new” approach. According to information collected, the study was heavily
oriented toward economic considerations related to tourism and in ortation
of truck crops. Consideration of water quality in the work performed to
date had been judged inadequate and an additional $40,000 was being provided
by the Water Resources Council to strengthen that aspect of the study.
As with the other studies underway, access to the participants was deemed
good. Water quality interests were represented largely by the State’s
water quality control agency and EPA was not significantly involved in
the study.
Because of its orientation toward problems of special interest to
Hawaii, the Level B study did not appear highly representative of the
types of studies which might be undertaken for other areas.
Maumee River Basin
The Level B study in the Maumee River Basin was begun and pursued
for four months under the old approach, then converted partially to the
“new” approach. At the time of investigation the recommended plan was
being prepared. Access to participants was judged good since the study
was underway. Erosion and resultant sedimentation was the principal focus
of the study with water quality accorded lesser attention.
Several urban areas within the Basin had been either designated or
were expected to be designated for water quality management planning by
A-2
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local areawide organizations including those in and around Toledo and Lima,
Ohio and South Central Michigan. The Basin provides a mix of rural and
highly urbanized areas.
While the mix of economies in the Basin are representative of what
might be found in other areas, the representativeness of the Level B
study was questionable because of the mixture of old and “new” approaches
used. The general character of the area was similar to the area encompas-
sed by the Monongahela River Basin Level B study.
Minneapolis—St. Paul (Lower Minnesota and Upper Mississippi Rivers )
A specific effort to implement the Proposed Guidelines for Level B
planning in full accord with the “new” approach was made in the study. When
investigated, the study had not yet progressed to the point of identifying
alternative plans. Water supply and water quality were principal focusses
of the study but other functions were also included. Heavy emphasis was
placed on both environmental and energy issues.
No designations had been made for local water quality management
planning within the Basin. While the Minneapolis-St. Paul area was being
considered, the established inter—local planninq organization is appointed
rather than being composed of elected officials and therefore not clearly
eligible for designation.
Access to participants was expected to be good in the event the Level
B study was chosen for investigation. The study was also representative
of others likely to be undertaken in the future with respect to the approach
employed and the character of the area.
Central Snake River Basin
Level B investigations in the Central Snake River Basin had reportedly
progressed to the point that alternative plans had been developed and a
final report was being prepared. The study used the Itnewt* approach.
Potential for access to participants was good.
The Boise urban area had been designated for water quality manage-
ment planning and the designated planning organization had prepared a project
control plan. In addition, a Corps of Engineers Urban Studies project was
underway in the Boise area and nearing completion.
Problems in the Central Snake River Basin are typical of western areas
and include water quality, maintenance of instream flows and need for water
supply. Both rural and urban areas were included in the Basin. The study
was judged fairly representative of other Level B planning which might be
undertaken in the future.
A-3
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Monon ahela River Basin
The Level B study in the Monongahela River Basin had begun using the
“new” approach prior to the availability of the proposed Guidelines. Plan-
ning was complete at the time of investigation and the recommended plan
accepted by the Ohio River Basin Commission. The plan was being re-
viewed prior to its transmittal to the Water Resources Council. Access
to participants was thought to be good.
Emphasis in the study had been placed most heavily on acid mine
drainage. Beyond that, other functional purposes had been accorded more
or less balanced consideration. A major study specifically concerning
acid mine drainage had been completed by the Appalachian Regional Commission.
Both rural and urban areas were included in the Level B study area.
Pittsburgh, lying at the downstrea n fringe of the Basin had been designated
for water quality management planning. However, little progress had been
made in developing the project work plan.
Summary
Access to planning participants was assured in all of the areas
considered.
Three of the likely candidates, Yakima River Basin, Hawaii and Minneapo-
lis—St. Paul Level B studies, did not include a local area designated pur-
suant to Sec. 208 for water quality management planning. In addition, both
Hawaii and St. Paul were engaged in development of alternative plans and
it was not assured that a relatively complete product would be available
during the course of the investigation. The Hawaii Level B study was also
known to be deficient in consideration of water quality. The Maumee River
Basin Level B study was not wholly representative of the “new” approach.
In addition to meeting all of the established criteria, selection of
the Central Snake and Monongahela Level B studies offered several useful
contrasts including:
1. representativeness of both eastern-and western situ-
ations with respect to interests and types of problems
to be addressed;
2. inclusion of a situation in which aCorpsof Engineers
urban study was in progress;
3. study leadership by a single state (Idaho) and a river
basin cc runission (Ohio River Basin Commission);
4. location of the designated water quality management
planning area at the upper and lower end of the Level
B study area.
A-4
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APPENDIX B
COMPARISON OF PLANNING REGULATIONS AND GUIDELINES
SUBJECT
Basis of Guidance
LEVEL B PROPOSED PLANNING GUIDELINES
P 1 REAWIDE AND STATEWIDE WATEF. QUALITY
MANAGEMENT PLANNING REGULATIONS
AND GUIDELINES
Statutory
Sections 103 and 204 of the Water Resources
Planning Act, Public Law 89-80 (42 U.S.C.
1962 et. seq.] Section. 209 of Federal Water
Pollution Control Act Amendments of 1972,
Public Law 92—500 (33 U.S.C. 1151].
Sections 208 and 303(e) of the Fed-
eral Water Pollution Control Act
Amendments of 1972, Public Law
92—500 (33 U.S.C. 1151].
Regulatory
Principles and Standards for Planning
Water and Related Land Resources; 38 FR
24788 September 10, 1973.
40 FR Part 6, Preparation of En-
vironmental Impact Statements: Inter-
im Regulations . Federal Register,
Vol. 39, No. 138 , July 7, 1974.
40 CFR Part 35, Grants to State and
Designated Areawide Planning Agencies —
Conditions, Policies, and Procedures ,
Federal Register, Vol. 40, No. 230,
November 28, 1975.
40 FR Part 105, Public Participa-
tion in Wat3r Pollution Control .
Federal Register, Vol. 38, No. 163,
August 23, 1973.
40 FR Part 130, Policies and Pro-
cedures for the State Continuing
Planning Processes . Federal Regis-
ter, Vol. 40, No. 230, November 28,
1975.
40 ‘R Part 131, Preparation of Water
Quality Management Plans . Federal
Register, Vol. 40, No. 230, November
28, 1975.
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COMPARISON OF PLANNING REGULATIONS AND GUIDELINES (cönt )
Proposed guidelines are heavily oriented
toward identification of the sequential
steps which are to take place in planning
and to displaying information developed
as planning proceeds. Little emphasis is
placed on how to carry out individual plan-
ning tasks. Use of the Guidelines requires
reader to be familiar with planning tech-
niques and disciplines as well as the regu-
latory base. Guidelines do not frequently
cite their statutory or regulatory base and
are intended to provide guidance in following
the intent of the Principles and Standards
rather than their direct application.
AREAWIDE AND STATEWIDE WATER QUALITY
MANAGEMENT PLANNING REGULATIONS
AND GUIDELINES
Guidelines are oriented toward dis-
cussion of major planning tasks with
respect to detailed requirements to
be met. Less information is provided
on the sequence of the planning pro-
cess. Includes many references to
statutory base and provides some in-
terpretation. Effective use of the
Guidelines requires detailed under-
standing of statutory and regulatory
base and planning procedures.
SUBJECT
LEVEL B PROPOSED PLANNING GUIDELINES
Guidelines
WRC Proposed Guidelines for Regional or River
EPA Guidelines for Areawide Waste
Basin Planning (Level B), March 1976; for
field evaluation, subject to revision.
Treatment Management Planning,
August 1975.
Objectives
Resolve near and mid—term problems and pro—
vide a basis for implementation planning.
Identify contributions of alternative plans
to national economic develoixnent and en-
vironmental quality objectives,
Identify controls, regulatory pro-
grams, and management agencies
necessary to obtain the 1983
national water quality goal and
the established state water quality
standards.
9 ,
p .,
Content, Form and
Organization
General
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COMPARISON OF PLANNING REGULATIONS ANI) GUIDELINES (con t’d)
ABEAWIDE AND STATEWIDE WATER QUALITY
MANAGEMENT PLANNING REGULATIONS
AND GUIDELINES
Treatment of Re-
lated Programs
Lists 10 other programs (including Water
Quality that should be integrated into Level
B planning. Does not describe the nature
of the relationship or how integration is to
be achieved; coordination with other programs
provided through Planning Board.
Describes relationships to other water
quality programs, other EPA programs,
and other areawide planning programs.
References other programs as sources of
information and data. Provides for co-
ordination with other programs through
required advisory committee. Regu-
lations specify information to be ob-
tained from Level B studies where
available. Agreements for coordination
of planning programs have been entered
into with several other Federal Agencies.
SUBJECT
LEVEL B PROPOSED PLANNING GUIDELINES
9,
Comprehensiveness
Is the principal document to be available
Guidelines are supplemented by large
for guidance of Level B planning other than
number of handbooks, memorandums and
several WRC policy statements. Parallel
R&D reports, some of which are relied
“procedure” documents are to be developed
on for significant guidance (e.g.,
by each WRC member agency to apply the
Work Plan Handbook, Interim Output
Principles and Standards to their relevant
programs.
Evaluation Handbook and Administrative
Memoranda.)
Level
of
Detail
Guidelines are specific with respect to
role of Level B studies and steps toward
study initiation. General in interpretation
of Principles and Standards. “Comment” in—
cluded to clarify the Guidelines. Case
studies included to illustrate application
of Principles and Standards.
Relatively uniform and detailed de—
scription of what is to be done.
Little detail on how to do necessary
analyses.
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COMPARISON OF PLANNING REGULATIONS AND GUIDELINES (con ted)
AREAWIDE AND STATEWIDE WATER QUALITY
MANAGEMENT PLANNING REGULATIONS
AND GUIDELINES
Study Funding
Federal funding appropriated annually to WRC
for transfer or disbursement. Guidelines
do not specify with respect to non-federal
funding. Usual study amount approximately
$750,000 for two year study. $200,000,000
authorized.
Not dealt with in Guidelines. Statutes
provide federal grants to designated
agencies. Grant program to states
being initiated. Graritees manage and
disburse funds. Study amounts variable
($300,000 to +1,000,000) for two year
study. Additional authorizations
pending (May 1976).
SUBJECT
LEVEL B PROPOSED PLANNING GUIDELINES
Approach to Planning
Individually identified as part of study
Not included as part of Guidelines.
Study Area De—
lineation
initiation process. Usually on hydrologic
basis, sometimes with state boundaries
bounding study reach. Generally large
areas (i.e., several thousand square miles).
Areas delineated in designation process
and statute (statewide). Designated
areas usually based on county, SMSA,
or other political boundaries.
Study Organiza-
Studies optional. May be requested through
Studies mandated by statute on rigid
tion and Initiation
RBC or other regional sponsor. Must be
recosm ended by WRC. Guidelines provide
moderately detailed description of initi—
ation process. Flexibility exists in or—
ganization and contents of Proposal to Study
and plan of study.
time frame. Planning Guidelines do
not address study organization, and
initiation except public participation
process. Organization and initiation
processes are detailed in statute and
grant application regulations
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COMPARISON OF PLANNING REGULATIONS AND GUIDELINES (coni ’d)
AREAWIDE AND STATEWIDE WATER QUALITY
LEVEL B PROPOSED PLANNING GUIDELINES MAGEMENT PLANNING REGULATIONS
AND GUIDELINES
Study Emphasis
Integrated planning to resolve problems iden-
tified in Level A studies, identify needed
Level C studies, establish implementation
priorities for program, project and manage-
ment proposals.
Implementation of regulatory systems,
coordination of construction, establish-
ment of continuing planning process to
improve water quality.
SUBJECT
9,
U I
Study Adminis-
Guidelines suggest: Planning board of Fed—
Planning Guidelines do not address.
tration
era]. and state. members; Study Manager; Plan—
Grantee manages study with Planning
sing staff; task forces; Citizens Advisory
Advisory Committee having specified
Committee and Scientists Advisory Committee.
minimum membership. Usually full time
Entire effort under supervision of RBC or
study manager with several staff mem—
other regional sponsor.
bers and task forces.
Problem
Identi—
Guidelines address selection of problems
Statutes specify problems as well as
fication
for planning. Problems are to be described
by study team, verified with local experts
as to existance and presented to public for
selection of study focusses. Problems ad—
dressed are to be regional, related to land
and water management and topics of public
concern. Very flexible with respect to types
of problems considered. No guidance pro-
vided on how to analyze problems.
minimum levels of solution for several
types of problems. Guidelines provide
direction on general steps toward ama-
lyzing the magnitude and importance
of problems.
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COMPARISON OP PLANNING REGULATIONS AND GUIDELINES (con t’ d)
Numerous alternatives may be generated in
the planning process which represent dif-
ferent ways to achieve specified National
Economic Development and Environmental
Quality objectives and mix of objectives.
ABEAWIDE AND STATEWIDE WATER QUALITY
MANAOEMENT PLANNING REGULATIONS
AND GUIDELINES
Alternatives address same objectives
but may propose different means of
accomplishment.
SUBJECT
LEVEL B PROPOSED PLANNING GUIDELINES
9,
a’
Information and Data
Principal needs for information and data are
Needs for information include detailed
Requirements and
related to problem identification, water and
information on demography, water quality,
Sources
land availability, hydrology and basin manage—
ment plans. Sources of information are Type
A and project studies, state plans, federal
and state agencies.
facilities, land use, hydrology, costs,
financial capability and legal author—
ity. Sources include other area plans,
state agencies, federal agencies, local
agencies, monitoring programs, inven-
tories and specialized investigations.
Types and Detail
Reliance placed on expert judgment. No de—
Detailed analyses of water quality;
of Analyses
tailed studies of benefits, costs, allo—
cation, cost sharing, etc. Principal
analyses are sensitivity of plan to assump—
tions, outputs of plans and interfaces
between NED and EQ plans.
legal, financial, and institutional
factors; land use: projections; etc.
No benefit analysis required. Cost-ef—
fectiveness analyses to be made.
Generation of
Alternatives
-------
COMPMISON OF PLANNING REGULATIONS AND GUIDELINES (cont’ 1 4)
Suggests optional use of Citizens Advisory
Committee (CAC) to advise on problems and
soliltions and participation of CAC chair—
man on work groups or planning board.
Suggests procedures for appointment of CAC
members. Describes purpu es and procedures
for public participation at each stage of
study.
ANEAWIDE AND STATEWIDE WATER QUALITY
MANAGEMENT PLANNING REGULATIONS
AND GUIDELINES
Largely handled in separate regulations
which provide explicit requirements.
Guidelines describe the ways to meet
requirements. Substantial guidance
on purpose and procedures.
Implementation
Continued Plan-
ning
No provision for continued planning cp’ :
where rivet basin commissions are euo ved.
Updating may be proposed whenever e ents
Dictate. Responsibility for initiating
updating not assigned.
Specific requirements for continued
piar,ninq ir.ciudine matters to Sc con—
sidered, freq iency uf upd t!ng and :cc—
sponsibi].ity for accomplishxnent.
SUB .3ECT
LEVEL B PROPOSED PLANNING GUIDELINES
9,
- .4
Selection of Final
Study team selects plan on
basis of NED and
Designated planning agency selects
Plan
EQ. Guidelines discuss
view of alternatives,
procedures for re—
plan based on cost—effectiveness to
meet legislated minimum goals. State
and EPA must approve plan. Guidelines
provide lists of points to be compared
among alternatives in making selection
and format for display of alternatives.
Plan
Evaluation
Analysis of tradeoffs with
sideration of implications
decisions.
subjective con-
of component
Cost-effectiveness to meet established
Water Quality standards.
Public Parti-
cipation
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COMPARISON OF PLANNING REGULATIONS AND GUIDELINES (cont .d)
SUBJECT
LEVEL B PROPOSED PLANNING GUIDELINES
AREAWIDE AND STATEWIDE WATER QUALITY
MANAGEMENT PLItNNTNG REGULATIONS
AND GUIDELINES
9$
Recommended Plan
Studie8 are to identif agencies which
probably should undertake implementation
based on willingness, capability, desire
and other factors. Acceptance of imple-
mentation responsibility through review
process. Monitoring of implementation
recommended. No penalties for lack of
implementation. Implementation agencies
are primarily federal—state. Items to
be implemented include further studies,
research, Level C projects, regional
growth and resource strategies.
Level B plans are an intermediate step
toward implementation. Even after
their approval, further and more de-
tailed planning and additional de-
cisions by others are usually required.
Identification of implementation agencies
having specific legal authorities is
required. Governor assigns implemen-
tation responsibilities. Implementation
arrangements including financing, legal,
and other become part of state plan.
Potential for enforcing compliance through
NPDES program and 201 grants. Imple-
mentation agencies are primarily local.
208 plans once certified by the Governor
and approved by EPA are ready for imple-
mentation.
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