Legislative News
Summer 1993
owow
Office of Wetlands, Oceans & Watershed
CLEAN WATER ACT REAUTHORIZATION
SPECIAL ED!T!ON
Interagency Workgroups Develop
Administration Proposal on CWA
Eight interagency workgroups were convened
this past Spring and charged with developing an
Administration position on the Clean Water Act
Reauthorization. After an intense series of
meetings, workgroups on watershed manage-
ment; nonpoint source pollution; toxics; funding;
enforcement; permitting; and monitoring suc-
ceeded in developing papers reflecting consen-
sus positions. These papers have served as the
basis for EPA testimony at seven hearings
before the Senate Environment and Public
Works Committee this summer. The papers are
now being incorporated into a formal Adminis-
tration "Green Book," which will be used in
future discussions with Capitol Hill. The
Wetlands Interagency Workgroup, chaired by
Keith Laughlin of the White House, has been
meeting twice weekly in preparation for a final
Senate hearing on wetlands scheduled for
September.
Bipartisan Clean Water Proposal Features
Watershed Management and NPS Controls
On June 15th, Senators Max Baucus (D-MT) and
John Chafee (R-RI), Chairman and Ranking
Minority Member of the Senate Environment
and Public Works Committee, jointly introduced
S.1114, the Water Pollution Prevention and
Control Act. Acting Administrator Martha
Prothro and other Office of Water officials
regularly met with Senate staff to provide
technical advice and assistance while the bill
was being crafted. Chairman Baucus plans to
have S.1114 ready for mark-up this fall and has
pledged to bring the bill to the Senate floor
before the end of the year.
In the House, both the Merchant Marine and
Fisheries Committee and the Public Works and
Transportation Committee are expected to
introduce their own measures after the August
recess.
S. 1114 - - Watershed Management
S.1114 includes a new provision to encourage
states to undertake comprehensive watershed
management by offering financial and regula-
tory incentives. Under the proposal, Governors
would designate impaired watersheds (i.e. not
meeting water quality or sediment standards or
designated uses) or special protection water-
sheds (i.e. outstanding national resource waters
S. 1114 -- Continued on Page 4
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Grubbs Testifies at Senate Hearing on
NPS and S. 1114
OWOW’s Geoffrey Grubbs presented testimony
before the Senate at a July 21st hearing examin-
ing nonpoint source pollution. Other witnesses
included New York City’s Environmental
Commissioner Albert Appleton; Diane
Cameron of the National Resources Defense
Council; Paul Genho of the National
Cattleman’s Association; and Willard De
Golyer, a dairy fanner from New York State.
In his opening remarks, Ranking Minority
Member John Chafee said that he will consider
S. 1114 “a success” if it ultimately addresses
nonpoint source pollution and nothing else.
Chafee also noted the importance of using a
watershed approach to address nonpoint source
pollution. Full Committee Chairman Baucus
said he is optimistic nonpoint source problems
can be dealt with, because, he said, environmen-
talists and farmers are “turning from rhetoric to
constructive solutions.”
In his statement, Grubbs told the subcommittee
that nonpoint source pollutioh remains our
most dominant water quality and environmen-
tal concern. While progress has been made by
states since the enactment of Section 319 in the
1987 Clean Water Act Amendments, Grubbs
noted that states continue to list nonpoint
source pollution as the primary reason water
quality objectives are not met. Agriculture,
urban runoff and stormwater, resource extrac-
tion, hydrologic modifications, and contami-
nated sediments, he said, are the major sources
of impairments reported by states. Grubbs also
described how urbanization and development
can alter watersheds and their wetlands, caus-
ing higher and more frequent runoff with
subsequent downstream erosion, riparian
alterations and destruction of habitat. He said
the Coastal Zone Management Act (CZARA)
will help to provide a stronger mandate in the
coastal areas. Grubbs said, however, that
stronger authorities are needed. He said EPA
believes that voluntary approaches should be
NPS Hearing -- Continued on Page 7
Senate Subcommittee Hears Testimony on
Watershed Management and S. 1114
Watershed management received strong en-
dorsement during a Senate Environment and
Public Works Subcommittee hearing on July
27th, which featured Blake Anderson of the
Association of Metropolitan Sewerage Agencies
(AMSA); Char ies Gauvin of Trout Unlimited;
Curt Spalding of Save the Bay in Rhode Island;
Steve Tedder of North Carolina’s Division of
Environmental Management; and Lorna Stickel
from the Western Governors Association.
While not officially invited to testify, Acting
Assistant Administrator Martha Prothro and
OWOW Director Bob Wayland were available
to answer questions and were invited to submit
a written statement for the record.
In his opening statement, Subcommittee Chair-
man Graham said he favored a watershed
approach as a means to address nonpoint source
pollution, which he said is our most serious
remaining water resource problem. He also
credited the approach as a way to motivate and
educate communities and to tailor solutions to
meet local problems. Graham specifically
questioned witnesses about whether the ap-
proach should be “voluntary or mandatory”
and what barriers they perceive are currently in
the way of state efforts to adopt a watershed
approach.
AMSA’s Blake Anderson advocated that a
mandatory approach be adopted in S.1 114,
arguing that the bill needs to ensure there is a
level playing field and steady progress is made
toward achieving environmental goals. He
added that while AMSA endorses S. 1114 ‘s
concept of “management entities,” his organiza-
tion believes their composition needs to be very
Watershed Hearing -- Continued on Page 6
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Baucus-Chafee Introduce Wetlands Component
On July 28th, Senators Baucus and Chafee
introduced S. 1304, the Wetlands Conservation
and Regulatory Improvements Act of 1993.
Chairman Baucus intends to incorporate the
measure into S. 1114, the broader CWA reautho-
rization measure, when the bill is marked up
this fall. When introducing the bill, Baucus
cited the following four objectives: to improve
the wetlands regulatory program; to simplify
farmer/rancher compliance; to enhance state
involvement; and to strengthen wetlands pro-
tection and restoration efforts. The bill makes
wetlands protection and restoration a goal of the
Clean Water Act. It also would clarify that
activities covered under Section 404 include
excavation, ditching, channelization and other
excavation activities resulting in wetlands loss
or degradation.
In terms of regulatory changes, the bill would
tighten deadlines for permit processing and
would provide for streamlined decision-making
for wetlands within an approved wetlands and
watershed management plan. Local watershed
plans approved under the bill’s new Section 321
could be eligible to receive general permits,
provided the responsible unit of government
has the legal authority and scientific monitoring
capability to issue, monitor, and enforce permits
consistent with the federal program. In an effort
to offset unavoidable wetlands losses and to
improve the quantity and quality of wetlands
resources through restoration, S. 1304 would
authorize the use of mitigation banks, subject to
strict guidelines. Mitigation banks, for example,
would have to provide for “in-kind” replace-
ment of lost wetland functions near or within
the same watershed as the impacted wetlands.
Another safeguard would require that fees
charged for participating in the mitigation bank
reflect the full costs of replacing lost wetlands
functions and acreage, including the costs of
land acquisition; wetlands establishment;
management measures; long-term maintenance;
and monitoring.
With regard to the Delineation Manual, the bill
would require that a new manual be developed
after completion of the National Academy of
Sciences’ study, which is due to be released late
next year. In the meantime, the bill would
mandate continued use of the 1987 Corps of
Engineers Delineation manual and implement-
ing guidelines. To assist small landowners
with issues relating to wetlands identification
and delineation, the bill would authorize up to
$5 million in technical assistance.
In an effort to address issues raised by the
farming and ranching communities, the bill
would clarify that prior converted cropland,
stock ponds and areas created by irrigation are
exempt from Section 404 requirements. Addi-
tionally, the bill provides for regulations to be
issued to allow Section 404 general permits for
any activity determined by the Soil Conserva-
tion Service (SCS) to be exempt under the
mitigation and minimal effect provisions under
the Food Security Act’s swampbuster program.
Moreover, the bill directs the EPA, COE and the
SCS to develop consistent policies with regard
to wetland determinations on agricultural lands,
so that to the extent possible, a determination
made by any one agency would be accepted
under either the CWA or the Food Security Act.
The bill also includes “non-regulatory” ap-
proaches to wetlands protection and restoration.
To encourage and facilitate state involvement in
wetlands protection, the bill authorizes and
funds the development of state wetland conser-
vation plans as a more comprehensive and
integrated approach to wetlands protection at
the state and local level. To help federal and
state wetlands protection efforts to look beyond
impacts to a specific wetland and to consider the
effects on a watershed scale, the bill also encour-
ages the development of wetlands and water-
shed management plans. In addition, to achieve
the goal of protection and restoring wetlands,
the bill directs the Corps of Engineers, along
with the EPA, the USFWS, the SCS, the NMFS,
and other state and local authorities, to develop
a National Cooperative Wetlands Restoration
Strategy to coordinate and monitor restoration
efforts throughout the United States.
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S. 1114 -- Continued from Page 1
or waters with sensitive aquatic or wildlife
habitat) for comprehensive planning and
management efforts. Watershed designations,
which would be subject to EPA approval,
would be consistent with USGS hydrological
units to the extent practicable. Following EPA
guidance, Governors would designate water-
shed management entities that would be
charged with developing and implementing
watershed plans. Governors would then
submit these locally-developed plans for EPA
approval.
Plans would have to include certain elements,
including a characterization of the watershed;
identification of its problems; establishment of
short-term and long-term goals (including
allocation of pollutant load reductions among
point and nonpoint sources); selection of
activities and projects to meet established
goals; and identification of the necessary
financial and institutional arrangements to
carry out the plan. For watersheds not meet-
ing water quality or sediment quality stan-
dards, plans would have to provide for the
attainment of standards within 10 years after
the plan’s submittal. Standards would have to
met within 5 years in those watersheds with
impairments due only to point sources or
whose point source allocations were reduced
by applying controls over nonpoint sources.
In terms of incentives, S. 1114 would provide
several financial and regulatory incentives.
Projects and activities in watersheds with
approved plans, for example, would be eligible
for monies under the State Revolving Loan
Fund (SRF) and eligible to be included in the
SRF needs assessment. In terms of regulatory
incentives, S. 1114 would facilitate trading
between point and nonpoint sources and
would provide some regulatory flexibility for
point sources. Point source permitees would
be granted relief from attaining water quality
standards, but not technology-based controls
(subject to the anti-backsliding provisions of
S402 (o), as long as the approved watershed
plan had enforceable requirements to control
nonpoint sources that, in combination with the
limitations established for point sources, pro-
vided for the attainment of water quality stan-
dards. To encourage states to synchronize their
point source permits along a watershed basis,
S.1114 would allow for a one-time extension of
permits up to 4 years.
The bill would authorize EPA to delegate
authority to the states to approve watershed
plans if the state submitted a program that was
as equally stringent as required under EPA-
issued guidance. EPA would be required to
issue guidance specifying minimum require-
ments for watershed designation, legal authori-
ties and financial resources for management
entities, public participation and criteria for plan
approval.
S. 1114 -- Nonpoint Source Provisions
To address nonpoint source pollution, S.1114
would require states within 2 1/2 years to revise
their nonpoint source programs, consistent with
EPA-issued guidance. Each state program
would have to be reviewed and revised within 7
years of enactment. For new sources, state
management programs would be required to
have a schedule containing annual milestones
for the implementation of management mea-
sures, outlined in EPA guidance, as expedi-
tiously as possible, but no later than 3 years
after program approval. States would be
granted the flexibility to adopt alternative
requirements for a specific source of nonpoint
source pollution if they could demonstrate that
the alternative requirements would represent
maximum management measures within the
economic capability of the source and would
result in reasonable further progress toward the
elimination of pollution. States would also be
authorized to exempt a category of sources
listed in EPA guidance, if they could demon-
strate that the category of sources does not cause
impairment to waters within the state. Each
state plan would need to provide for the neces-
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sary legal authority to ensure enforceability.
The bill directs EPA to publish guidance within
90 days of enactment and final guidance within
180 days specifying the elements of a nonpoint
source pollution program. These would in-
clude a description of categories and subcatego-
ries of sources of nonpoint source pollution;
management measures appropriate for each
category; program implementation criteria;
methods to estimate reductions in nonpoint
source pollutant loads necessary to attain and
maintain water and sediment quality standards;
and necessary monitoring. The bill defines
“management measures” to mean economically-
achievable measures to control the addition of
pollutants from existing sources and new
sources that reflect the greatest degree of pollut-
ant reduction achievable through application of
Best Available Control Technology (BACT).
New sources would include development of a
commercial or residential site of 5 or more acres
not subject to storm water permits; road con-
struction not subject to a storm water permit;
timber harvesting or road building; and other
activities.
Not later than seven years after enactment,
states would have to review and revise their
nonpoint source management plans. Each plan
would have to provide for the necessary author-
ity to ensure implementation of management
measures for existing sources and new sources.
Where there is an approved watershed plan, the
state would be allowed to implement site-
specific water-quality plans, instead of the EPA-
promulgated management measures. Each site-
specific plan would have to be approved by the
appropriate federal agency. Plans would have
to provide for the implementation of manage-
ment measures appropriate to the site that are
economically achievable and will reduce pollu-
tion. In terms of agricultural sources, plans
would have to be developed and implemented
with the assistance of the Department of Agri-
culture. Moreover, EPA, in consultation with
USDA, would be required to publish a hand-
book within 18 months to assist in the develop-
ment of these plans. To address problems with
animal wastes, EPA would also be tasked with
developing guidelines within 2 years, in consul-
tation with USDA, for the construction of
animal waste management facilities.
If states fail to submit a nonpoint source plan,
EPA would be required to publish a regulation
providing for the implementation of enforceable
minimum control measures for categories of
nonpoint sources in the state. In terms of fund-
ing, S. 1114 would increase funding under
Section 319 by authorizing appropriations of
$300 million in Fiscal Year 1995 (FY 95), $500
million for each FY ‘96 through FY’ 98 and $600
million for each FY’s 1999 and 2000.
S. 1114 - - Water Quality Monitoring
S. 1114 would strengthen state monitoring
programs by requiring: 1) assessments to deter-
mine whether the waters of the state provide for
the protection and propagation of a balanced
population of shellfish, fish and wildlife and
allow for recreational activities; 2) identification
of waters not attaining or maintaining desig-
nated uses or water quality standards; 3) assess-
ments to determine the contribution of point
and nonpoint sources: 4) monitoring activities
conducted on a staggered basis so that there
would be continuous data collection over a 5
year period. Additionally, EPA would be
charged with promulgating regulations specify-
ing minimum elements of state programs within
2 years of enactment.
The bill also would establish a Water Quality
Monitoring Council, which would be chaired by
EPA and the USGS, to review and make recom-
mendations on the coordination and implemen-
tation of federal and state water and sediment
quality monitoring programs.
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Watershed Hearing -- Continued from Page 2
clearly defined to include all stakeholders,
including state, federal, local government,
citizens, and the environmental community.
He also said the entities need to be empowered
and that EPA needs to be a player at the table,
so that once a plan is developed, it can receive
instantaneous approval. He warned that
gridlock would occur if plans are approved
1,000 of miles away in Washington, as proposed
in S.1114.
Charles Gauvin of Trout Unlimited highlighted
the importance of addressing our nation’s
“biological deficit,” notably the threats to our
valuable fish and wildlife, particularly, the
declining salmon and trout stock in the Pacific
Northwest. He said that S. 1114 was “a step in
the right direction,” but argued that the bill
needs to be strengthened to protect and monitor
species diversity. He emphasized the need to
address “instream flows,” pointing out that
hydropower kills fish, too. Save the Bay’s Curt
Spalding praised S. 1114 for emphasizing
watershed management, but agreed with
AMSA’s remarks that the bill needs to be
strengthened to ensure adequate stakeholder
involvement in management entities. He
applauded S. 1114’s use of a set-aside for water-
shed management, but said a local match
should be required. He added that watershed
management should be mandatory for
nonattainment areas.
Representing the state of North Carolina, Steve
Tedder touted his state’s success with basin-
wide planning and described how N.C. has
realized tremendous savings and efficiencies in
adopting a watershed approach. Nevertheless,
he cautioned the Senators against adopting a
“one size fits all approach,” and he warned that
S. 1114 might hinder state’s efforts to adopt
watershed management because of the “bureau-
cratic hoops” it would put states through.
Finally, Lorna Stickel from the Western Gover-
nors Association testified that S. 1114 should
“encourage, but not mandate” watershed
management. She stressed that the bill should
emphasize performance rather than planning
and that management entities should in fact be
“coordinating bodies.” She also recommended
that the bill establish timeframes to ensure that
high quality waters are addressed, and not only
those that are impaired. When specifically
asked whether the approach should be volun-
tary or mandatory, she responded with a “quali-
fied No.” She elaborated that watershed man-
agement is not just about water quality, but also
about water quantity. She further explained that
with the right incentives, the states will make it
work and noted that, particularly in the North-
west, water resource problems are fundamen-
tally economic and quality of life issues that
must be addressed by the states and locals.
In written testimony, EPA praised the committee
for including a watershed component in S.1114
that awards states that on a volunteer basis
undertake watershed management by granting
financial and regulatory incentives. It was
noted, however, that S. 1114 should be modified
to encourage states to develop comprehensive
state programs, instead of designating selected,
individual watersheds. At a minimum, it was
recommended that to become eligible for incen-
tives, states should conduct a state-wide delinea-
tion of all watersheds; prepare an inventory of
impaired and threatened waters as well as other
waters deserving special attention (such as
estuaries, drinking water sources, priority
groundwater or outstanding resource waters);
rank all watersheds according to established
criteria; develop a process and schedule to select
watersheds for which management entities
would be established; and convene watershed
management teams that would develop and
implement watershed-level plans.
EPA also recom-
mended that
states, not EPA,
approve water-
shed-level plans.
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NPS Hearing -- Continued from Page 2
reinforced and relied upon as the first strategy
of choice, but that state programs should in-
dude compulsory mechanisms, including
enforcement authorities, if within a reasonable
time frame, voluntary measures fail to result in
implementation of management measures.
Grubbs recommended that Section 319 be
amended to bolster state nonpoint source
programs, in concert with a watershed ap-
proach. He agreed with provisions in S. 1114
that require states to update assessments of their
watersheds, but said that these assessments
should be broader. He said assessments should
cover not only impaired, but also “threatened”
watersheds and should also include major
relevant stresses on ecosystems, in addition to
chemical pollutants.
Grubbs advocated rewarding states that adopt
strong, comprehensive watershed program that
provide for expeditiously addressing stressors
in high priority areas, by granting them the
authority to adopt their own nonpoint source
management measures in lieu of national man-
agement measures. In impaired or threatened
areas where states do not opt for a watershed
approach, he said existing nonpoint source
programs should be upgraded to implement
best available management measures for catego-
ries of nonpoint sources.
Agricultural witnesses, including Judy Olson
with the National Association of Wheat Grow-
ers, testified in support of voluntary, incentive-
based approaches to address nonpoint source
pollution. She and other representatives from
the agricultural community voiced opposition to
federally-based controls and prescriptive land-
use planning and emphasized the need for
flexible measures tailored to reflect local condi-
tions. Environmentalists, on the other hand,
called for mandatory requirements, arguing for
even stronger authorities and performance
standards than those advocated inS. 1114.
Wayland Testifies before Senate on Water
Quality Monitoring and Federal Cooperation
On August 4th, OWOW Director Bob Wayland
joined a panel of federal agency experts to
discuss water quality monitoring and efforts to
enhance federal agency cooperation. The
hearing also served as opportunity for the other
federal agencies to present their views on S.
1114. The panel included James Lyons, Assis-
tant Secretary for the Department of Agriculture;
Dallas Peck, Director of the U.S. Geological
Survey; Douglas Hall, Assistant Secretary with
the National Oceanic and Atmospheric Admin-
istration; and Michael Spear, Assistant Director
with the Fish and Wildlife Service.
Wayland discussed the importance of water
quality monitoring in terms of setting strategic
goals; directing resources and establishing
program priorities; and measuring how well
goals are met. He discussed EPA ’s leadership
role in coordinating monitoring efforts by
establishing, along with USGS, a three-year
Intergovernmental Task Force on Monitoring
Water Quality (1TFM), which includes eight
other Federal agencies, and ten States, Interstate
and Indian organizations. He said the Task
Force is developing products for five major
problem areas in monitoring, including institu-
tional collaboration; environmental indicators;
field and laboratory methods ëomparability;
information management and sharing; and
assessment and reporting.
Wayland applauded S.1114’s provisions to
strengthen state efforts, including a requirement
for minimum state water monitoring programs.
He also commended the Senate for changing the
state and Federal water quality reporting cycle
from two to five years and noted that a five-year
cycle will help the states better integrate their
monitoring and abatement programs on a
watershed basis. He also praised the bill for
recognizing the importance of volunteer moni-
toring. However, Wayland questioned the need
to establish a Water Quality Council, as pro-
posed in S. 1114, arguing that its creation would
be redundant with the 1TFM, which he said, is
already carrying out an even broader mandate.
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Senate Hearing Examines Regional Issues and Great Water Bodies
On August 4th, seven panels of witnesses pre-
sented testimony during a lengthy hearing
before the Senate Environment and Public
Works Subcommittee, focusing on several
geographically-based programs, including three
great waterbody programs: the Chesapeake Bay,
Great Lakes, and Gulf of Mexico Programs. The
Clean Lakes Program and National Estuary
Program (NEP) were also a key focus of the
hearing, which sought to examine lessons
learned from these and other programs that
have undertaken watershed management.
Witnesses included Dawn Martin of the Amen-
can Oceans Campaign; Richard Wedepohi, of the
North American Lake Management Society;
Caren Glotfelty, of Pennsylvania’s Department
of Environmental Resoutces; and William Baker,
President of the Chesapeake Bay Foundation.
The Chesapeake Bay Program was a major focus
of the hearing, and witnesses described it as a
“laboratory for watershed management ap-
proaches.” Chesapeake Bay Foundation Presi-
dent William Baker spoke of the “unprec-
edented” spirit of cooperation among all of the
Bay’s stakeholders. Pennsylvania’s Carin
Glotfelty described how her state is now begin-
ning to make progress to control nonpoint
sources of pollution, particularly from agricul-
tural sources, which enter the Susquehanna
watershed and ultimately end up in the Bay.
She said that a new Pennsylvania state law, Act
6, which requires the preparation and imple-
mentation of nutrient management plans by
high density livestock farms, may serve as a
model for other states. She said the law relies
less on “command and control” and more on
shared goals, education and cooperation, and
technical assistance and that it is tailored to
allow farmers to develop plans that take into
account their crop needs, soil nutrient content,
available manure and farming practices. She
added that the program is being administrated
through the country’s conservation districts,
which are traditional allies of the farming com-
munity. Connecticut Senator Joseph Lieberman
applauded this new awareness for a broader,
ecosystem or watershed-based approach, which
he labeled a “conceptual breakthrough.” He
described how a watershed approach is being
adopted in the restoration of Long Island
Sound, and noted that Connecticut is beginning
to more fully appreciate the interconnectedness
of all systems, as he described his state’s recent
discovery that salmon migrations in the Con-
necticut River actually begin thousands of miles
away in Canada.
Numerous Senators and Representatives also
presented testimony in support of various
legislative initiatives they would like to see
incorporated into S. 1114. Senate Majority
Leader George Mitchell CD-ME) testified in
support of two bills he has introduced — S.
1199, the Coastal Protection Act, and S. 1198, the
Lake Assessment and Protection Act.
Maryland’s Senator Paul Sarbanes discussed his
proposal, 5. 567, the Chesapeake Bay Restora-
tion Act, and Senator Howard Metzenbaum (D-
OH) urged support for his bill, S. 1183, the
Great Lakes Clean Water Amendments, which
seeks to address the problems of contaminated
sediments. Subcommittee members
Launtenberg (D-NJ) and Joseph Lieberman CD-
CT) also took the opportunity to endorse their
proposals. Lautenberg’s bill, the Beaches
Environmental Assessment, Closure and Health
Act, would establish uniform procedures for
beach testing and monitoring (to measure short-
term increases in pathogens); and Lieberman’s
bill, S. 815, the Water Pollution Control and
Estuary Restoration Financing Act, would
make some modifications to the NEP, including
the creation of a separate set-aside in the State
Revolving Loan Fund for the purposes of
implementing Comprehensive Conservation
Management Plans (CCMPs). House Agricul-
ture Committee Chairman Kika De La Garza
submitted testimony in support of his proposal
S. 1566, which would formally establish the
Gulf of Mexico Program within EPA; would
create a Gulf of Mexico Commission; and would
require the Department of Agriculture to con-
duct a complete inventory of laws and regula-
tions affecting agricultural wetlands.
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