    Environmental Protection: Federal Incentives Could Help Promote
    Land Use That Protects Air and Water Quality (31-OCT-01,
    GAO-02-12).

    Americans have become increasingly concerned about the downside
    of growth and development--increasing dependence on automobiles;
    worsening traffic congestion; and the loss of farmland, forests,
    and open space. Some are also concerned that "urban sprawl" can
    increase air and water pollution, threaten their health and, in
    some cases, their livelihood. Most local transportation planners
    and state air quality managers do not consider the effects of
    different land use strategies on air quality. They do not do so
    principally because nonpoint sources are diffuse and difficult to
    identify and measure. According to local transportation planners,
    state air quality managers, and panel members, federal agencies
    could help remove barriers to, and provide incentives for,
    assessing and mitigating the environmental impacts of land use.
    They proposed actions in three key areas: (1) financial
    incentives for transportation, environmental, and local
    decisionmakers to collaborate on land use strategies that limit
    adverse impacts on air and water quality; (2) technical capacity
    to assess and mitigate land use impacts; and (3) educating the
    public and local officials about the environmental impacts of
    their transportation and land use decisions and alternative
    development strategies that better protect air and water quality.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-02-12
        ACCNO:   A02122
      TITLE:     Environmental Protection: Federal Incentives Could Help
    Promote Land Use That Protects Air and Water Quality
         DATE:   10/31/2001
      SUBJECT:   Air pollution
    	     Environmental monitoring
    	     Land management
    	     Water pollution
    	     FHwA Congestion Mitigation and Air
    	     Quality Improvement Program
    	     DOT Transportation and Community and
    	     System Preservation Pilot
    	     DOT Transportation Improvement Program
    	     EPA Innovative Community Partnership
    	     Projects Initiative
    	     EPA National Water Quality Inventory
    	     EPA State Implementation Plan
    	     EPA National Pollutant Discharge
    	     Elimination System Storm Water Program
    	     EPA National Pollutant Discharge
    	     Elimination System
    	     FTA New Starts Program

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO Testimony.                                               **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ******************************************************************
    GAO-02-12

    A

    Report to Congressional Requesters

    October 2001 ENVIRONMENTAL PROTECTION Federal Incentives Could Help Promote
    Land Use That Protects Air and Water Quality

    GAO- 02- 12

    Letter 1 Executive Summary 2

    Purpose 2 Background 3 Results in Brief 6 Principal Findings 7
    Recommendations for Executive Action 12 Matters for Congressional
    Consideration 13 Agency Comments 13

    Chapter 1 14

    Introduction Air Pollution From Vehicle Emissions Poses Public Health and

    Environmental Risks 18 While Harmful Emissions Continue to Decline
    Nationwide, Certain

    Localities May Continue to Face Air Quality Problems 22 More Paved and Other
    Impervious Surfaces Increase Polluted

    Runoff, Thus Threatening Public Health and the Aquatic Environment 23 Some
    States and Localities Are Implementing Alternatives to the

    Prevailing Growth Pattern That Could Help Limit Environmental Impacts 27
    Federal Rules Aim to Control Harmful Automobile Emissions,

    Especially in Areas That Have Air Quality Problems 28 Federal Rules Aim to
    Protect the Nation?s Water Bodies From

    Harmful Pollutants 30 Objectives, Scope, and Methodology 32

    Chapter 2 35

    Most MPOs and Air Most MPOs and State Air Quality Managers Do Not Assess
    Whether Different Land Uses Would Result in Less Emissions 36

    Quality Managers Do MPOs Consider Future Land Use as They Forecast Travel
    Needs 36 Not Assess the MPOs in Areas With Air Quality Problems Are More
    Likely to Emissions Impacts of Estimate Emissions From Different Land Uses
    39

    MPOs and State Air Quality Managers Reported That Assessments of Different
    Land Uses in Different Land Uses Had Some Influence on Transportation and
    Protecting Air Quality

    Land Use Plans 42 Expected Growth and Stricter Air Quality Standards May
    Increase

    the Need to Consider the Impact of Land Use on Efforts to Control Emissions
    45

    MPOs and State Air Quality Managers Have Several Barriers to Overcome if
    They Want to Better Assess Emissions Impacts From Different Land Uses 56

    Chapter 3 58

    Most States and States and Localities Have Generally Not Assessed and
    Mitigated Nonpoint Source Pollution for Technical, Legal, and Resource
    Localities Do Not Fully

    Reasons 58 Assess and Mitigate the

    Many States and Localities Lack the Necessary Resources and Sources of
    Nonpoint

    Support to Assess and Mitigate the Impacts of Land Use on Water Quality 63

    Pollution but May Need Some States and Localities Have the Resources and
    Support to to Do So in the Future

    Comprehensively Assess Water Quality and Address Adverse Impacts of Land Use
    64 States and Localities May Need to Give More Consideration to Land

    Use Impacts Because of Renewed Emphasis on Improving Water Quality and
    Revised Regulations Governing It 72 States and Localities Face Additional
    Barriers to Better Assessing

    and Mitigating the Impacts of Land Use and Development on Water Quality 75

    Chapter 4 78

    Federal Agencies MPOs, State Air Quality Managers, and Our Expert Panel
    Identified Federal Actions to Help Reduce the Barriers to Linking Land Use

    Could Take Actions to and Environmental Protection 79

    Help States and EPA?s Initiatives Promote Consideration of Land Use Impacts
    on the

    Localities Better Environment, but the Agency Could Take a More Strategic
    Approach to Leverage Its Resources 81

    Consider the DOT Has Initiatives to Link Transportation and Air Quality
    Environmental Impacts

    Protection but Could Better Promote Consideration of Different Land Use
    Strategies 92 of Land Use

    The Congress Is Considering Actions to Support State and Local Growth
    Management Efforts 95 Conclusions 96 Recommendations for Executive Action 97
    Matters for Congressional Consideration 99 Agency Comments and Our
    Evaluation 100

    Appendixes

    Appendix I: Objectives, Scope, and Methodology 102

    Appendix II: Results From Survey of States on Air Quality Planning 111

    Appendix III: Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning 126

    Appendix IV: Question From GAO Survey of Local Growth Issues 142

    Appendix V: Expert Panel Questionnaire 143

    Appendix VI: Members of GAO?s Panel of Experts on the Relationship of Water
    Quality and Land Use 163

    Appendix VII: Contact and Staff Acknowledgments 166 GAO Contact 166
    Acknowledgments 166

    Related GAO Products 167 Tables Table 1: Health Impacts of the Criteria
    Pollutants Most Associated With Motor Vehicle Emissions 20

    Table 2: Major EPA Initiatives That Link Environmental Protection and Land
    Use 82 Table 3: USGS? and NOAA?s Major Water Quality and Land Use

    Initiatives 88 Table 4: Major DOT Initiatives That Link Transportation, Air

    Quality, and Land Use 92 Table 5: Numbers of Experts Who Participated in
    Each of the

    Survey Iterations, by Professional Affiliation 108 Table 6: Numbers of
    Experts Who Participated in Each of the

    Survey Iterations, by Area of Expertise 108 Figures Figure 1: Growth Trends,
    Over Time, in the Chicago- Milwaukee Area 15

    Figure 2: Contributions of Air and Water Pollution From Certain Patterns of
    Development 17 Figure 3: Proportion of 1998 Emissions From Motor Vehicles
    for

    Carbon Monoxide, Nitrogen Oxides, and Volatile Organic Compounds 19 Figure
    4: Effects of Development on Flood Potential and Stream

    Flow Levels 25

    Figure 5: Wetlands? Contribution to Improving Water Quality and Reducing
    Storm Water Runoff 26 Figure 6: The Basic Travel- Demand- Forecasting
    Process 37 Figure 7: MPOs in Areas With Air Quality Problems That Have
    Modeled Emissions From Different Land Uses 40

    Figure 8: MPOs in Areas Without Air Quality Problems That Have Not Modeled
    Emissions From Different Land Uses 41 Figure 9: MPOs in Areas With Air
    Quality Problems That Expect

    Significant Future Growth 48 Figure 10: MPOs in Areas Without Air Quality
    Problems That Expect Significant Future Growth 50

    Figure 11: Counties Expecting to Violate the 8- Hour Ozone Standard and to
    Grow Significantly 54 Figure 12: Traditional Neighborhood Design 68 Figure
    13: Innovative Neighborhood Design 69 Figure 14: Spragues Cove Before the
    Wetlands Project 70 Figure 15: Spragues Cove After the Wetlands Project 71

    Abbreviations

    ARC Atlanta Regional Commission DOT Department of Transportation EPA
    Environmental Protection Agency GAO General Accounting Agency GRTA Georgia
    Regional Transportation Authority ISTEA Intermodel Surface Transportation
    Efficiency Act of 1991 MPO metropolitan planning organizations MS4s
    municipal separate storm sewer systems NOAA National Oceanic and Atmospheric
    Administration NPDES National Pollutant Discharge Elimination System PAH
    polycyclic aromatic hydrocarbons SIP state implementation plans SUV sport
    utility vehicle TEA- 21 Transportation Equity Act for the 21 st Century TIP
    transportation improvement program TMDL total maximum daily load USGS U. S.
    Geological Survey

    Executive Summary Purpose Americans have begun to focus on the downside of
    certain patterns of growth and development- increasing dependence on
    automobiles;

    worsening traffic congestion; and contributing to the loss of farmland,
    forests, and open space. Increasingly, some are also concerned that this
    prevailing pattern of land use, commonly called ?urban sprawl,? can increase
    air and water pollution, threatening their health and, in some cases, their
    livelihood. Vehicle emissions in congested areas can trigger respiratory and
    other illnesses, and runoff from impervious surfaces can carry lawn
    chemicals and other pollutants into lakes, streams, and rivers, thus
    threatening aquatic environments. Some states and localities-

    spurred in part by citizens? lawsuits and ballot initiatives- recognize that
    growth provides housing and economic development opportunities and is
    inevitable, but would like to better manage their future land use. The
    Congress has also expressed an interest in better understanding how federal
    policies and programs affect growth and land use. In two prior reports, GAO
    discussed how a broad array of federal policies can help or hinder state and
    local efforts to limit any negative effects and the general types of federal
    assistance that states and localities want to help them achieve this goal. 1

    For this report, the Senate Smart Growth Task Force and the House
    Sustainable Development Caucus asked GAO to (1) determine the extent to
    which local transportation planners and state air quality managers
    responsible for meeting federal clean air requirements consider the

    impacts of different land use strategies on their efforts to protect air
    quality; (2) determine how, if at all, state and local officials responsible
    for water quality and land use consider the water quality impacts of
    different land use strategies and work together to limit any adverse
    impacts; and (3) identify actions the federal government can take to help
    transportation,

    air quality, and water quality officials better link land use decisions with
    environmental protection. To determine the efforts to assess land use
    impacts on air quality, GAO surveyed those officials responsible for
    managing each of the 50 states? and the District of Columbia?s plans to
    protect air quality and meet federal air quality standards from March
    through July 2001. GAO also surveyed

    1 See Community Development: Extent of Federal Influence on ?Urban Sprawl?
    Is Unclear (GAO/ RCED- 99- 87, Apr. 30, 1999) and Community Development:
    Local Growth Issues- Federal Opportunities and Challenges (GAO/ RCED- 00-
    178, Sept. 6, 2000).

    officials in each of the 341 metropolitan planning organizations nationwide
    who are responsible for designing the transportation plans to meet future
    land use needs during this time. GAO surveyed these local transportation

    planners because they have an important role in helping to protect air
    quality and ensure that the transportation plans designed to meet land use
    needs do not further degrade air quality. More specifically, these officials
    are responsible for ensuring that transportation plans do not increase
    vehicle emissions to the point that they exceed state- established emissions
    limits. Eighty- six percent of the local transportation planners and 46 of
    the

    50 states, in addition to the District of Columbia, responded to GAO?s
    surveys.

    To evaluate the efforts to assess land use impacts on water quality, GAO
    surveyed an expert panel of 32 individuals knowledgeable about water quality
    issues, land use, economics, and environmental law from March through June
    2001. GAO took this approach because, while responsibility for water quality
    rests with the states, this responsibility has been diffused among different
    organizations across the states. Therefore, it was difficult

    to consistently identify the most appropriate officials to respond to a
    nationwide survey. To select the participants for its expert panel, GAO
    reviewed available research and literature on water quality protection and
    identified noted experts. GAO then asked these experts to recommend other
    experts in their respective fields. Those experts identified most frequently
    were asked to participate in the survey, along with representatives of key
    stakeholder groups, such as federal and state water

    quality agencies and environmental organizations. The ultimate
    responsibility for deciding how land will be used in the future and whether
    to use it in ways that are protective of air and water quality rests with
    officials within each local jurisdiction. While GAO did not survey these
    officials for this report, it did incorporate the results from a

    survey it conducted with them from January through March 2000 for its prior
    report to determine, among other things, their concerns about future growth
    and environmental protection. (See app. I for GAO?s detailed methodology and
    apps. II to V for the survey questions implemented.)

    Background After World War II, the expanding U. S. population began moving
    away from traditional urban and metropolitan centers, aided by the
    construction of new roads and infrastructure on lands that had once been
    farms and

    forests. While this trend provided access to new housing, especially
    singlefamily homes built on relatively large lots, as well as new jobs and

    economic development, the homes were typically not located within walking
    distance of these jobs, stores, or other amenities, which increased
    dependence on the automobile. The continued conversion of open space for
    these land uses (often termed ?urban sprawl?) has raised concerns in recent
    years among the general public. While more immediate concerns have focused
    on traffic congestion and long commutes to work that result from prevailing
    patterns of development, some states and localities have also begun to be
    concerned about other quality- of- life impacts, including

    adverse effects on air and water quality. In response to these concerns,
    some states and localities have begun to look for alternative ways to grow-
    sometimes referred to as ?smart growth?- that encourage, for example, (1)
    redevelopment in established

    urban areas to minimize urban sprawl and (2) development that locates denser
    or geographically compact housing within walking distance of stores,
    schools, jobs, and transit systems to decrease dependence on automobiles.
    Integrating these types of land use decisions with environmental concerns
    can be a difficult task for localities, however. This can require
    collaboration among the different decisionmakers, including

    local transportation planners, environmental officials, and local land use
    officials, who each have their own, and sometimes competing, interests. For
    example, local land use decisionmakers may feel greater pressure to develop
    land in ways that promote economic development for their

    individual jurisdictions, rather than in ways that provide regional
    solutions for environmental problems. To some extent, certain land use
    patterns can contribute to poor air quality. Increased reliance on the
    automobile, especially in congested areas, can increase emissions that
    contain or create pollutants- including carbon monoxide, nitrogen oxide, and
    ozone- which have been associated with respiratory, cardiovascular, and
    other illnesses, as well as premature death.

    To protect public health, the Environmental Protection Agency (EPA), under
    the Clean Air Act, 2 has set standards- or limits- on the amount of
    allowable pollutants in the air. State air quality managers must develop
    state implementation plans for implementing, maintaining, and enforcing
    these standards. Through these plans, air quality managers establish

    emissions limits, or budgets, for vehicle emissions. Under the Clean Air
    Act, any area with air quality problems must demonstrate that its
    transportation plans will not exceed the emissions budgets or interfere

    2 Clean Air Act, 42 U. S. C. sect.sect. 7401- 7671q.

    with achieving the state implementation plan. Otherwise, the area risks the
    ability to spend federal transportation funding on some major projects. In
    transportation acts that became law in 1991 and 1998, the Congress provided
    additional incentives, including funding, to encourage local

    transportation planners to adopt projects that limit emissions and are more
    protective of air quality. Although these planners base their longer- term
    transportation plan and shorter- term transportation improvement program on
    the future growth projections that localities provide, the local
    transportation planners are not required to assess different land use

    strategies to determine if the resulting transportation plan and program
    would produce fewer emissions. Sprawl can also impair water quality. More
    paved and other impervious surfaces increase polluted storm water runoff,
    potentially threatening public health, destroying aquatic habitats, and
    hindering economic activity.

    To protect public health and the environment, the Congress passed the Clean
    Water Act. 3 It required states to establish water quality standards that,
    among other things, designate the beneficial uses, such as swimming and
    fishing, that the waters should support. States must also submit to EPA a
    list of all water bodies that do not or are not expected to meet standards.
    To implement the act, EPA established permit- related requirements and

    technology requirements for discrete, identifiable sources (point sources)
    of potential pollution, such as factories and wastewater treatment plants,
    to limit polluted discharges from these sources. In subsequent amendments to
    the act, the Congress established a grant program to encourage states to
    develop programs to combat pollution from diffuse, difficult- to- identify
    sources- nonpoint source pollution. The Congress also developed regulations
    to control a major portion of this nonpoint source pollution- storm water
    discharges. More recently, EPA

    promulgated a rule to amend and strengthen its water quality regulations.
    Under these regulations, states must identify their most severely degraded
    water bodies and the principal pollutants causing the degradation. For each
    pollutant, the states then calculate the total maximum daily load that a
    particular water body could absorb and still meet the standards. If these

    amounts are exceeded, the states determine the discharge reductions that
    each source must make. Because the revised rule has been controversial,
    however, EPA has postponed its implementation and is considering possible
    changes.

    3 Clean Water Act, 33 U. S. C. sect.sect. 1251- 1787.

    Results in Brief Our surveys showed that most local transportation planners
    and state air quality managers do not consider the effects of different land
    use strategies

    on air quality. At the local level, about three- fourths of the planners
    said they do not estimate the emissions generated by different strategies
    when selecting transportation projects. The remaining one- fourth who
    generated such estimates were predominantly in areas with air quality
    problems. This suggests that the federal requirement to demonstrate that
    transportation plans and programs conform to an emissions budget serves as
    the primary incentive to assessing the emissions impacts of different land
    uses. Furthermore, such estimates had some effect on transportation and land
    use decisions. For example, almost half of the planners who reported
    conducting such estimates revised their transportation plans as a result,

    and about a third reported that local land use plans were revised. At the
    state level, most air quality managers reported that assessments of the
    impacts of different land use strategies were not part of their efforts to
    improve air quality. The local transportation officials, as well as the
    state air quality managers, are not required to assess different land use
    strategies. The state air quality managers also reported that they do not
    assess these strategies because they believe that land use decisions fall
    under the jurisdiction of local governments and that the managers have

    little ability to influence it. The state air quality managers also said
    they lack a collaborative working relationship with local officials to
    assess the effects of different land use strategies on air quality. In the
    future, more of the transportation and air quality officials may need to
    consider land use as a means to control emissions and improve air quality if
    EPA implements, as planned, two more- stringent air quality standards. These
    officials face several barriers to further considering different land uses
    and their emissions impacts, however, including a lack of required technical
    tools.

    As with air quality, most states and localities do not comprehensively
    assess the impacts of different land uses on water quality and develop
    strategies to mitigate any adverse effects, according to members of GAO?s
    expert panel and the studies that GAO reviewed. They do not do so
    principally because nonpoint sources are diffuse and difficult to identify
    and measure and because there are few regulations to require mitigation
    efforts. In addition, communities often lack the resources as well as the

    technical, public, and official support needed for such efforts. As a
    result, according to several panel members, water quality protection and
    improvement efforts have focused more on controlling pollution discharges
    from point sources or complying with regulations, such as those recently
    promulgated for storm water. However, some communities with

    resources and public support have started to assess the health of their
    watersheds, identify nonpoint pollution sources, and implement
    moreprotective land use and development strategies. More states and
    localities may have to take such actions in the future because of citizens?
    lawsuits demanding greater progress in reducing nonpoint source pollution
    and

    because of the anticipated implementation of EPA?s revised rule for
    determining a water body?s total maximum daily load of contaminants. GAO?s
    expert panel noted that states and localities will face several barriers,
    however, including insufficient data on water quality and the benefits of
    different land use strategies, outdated local laws that hinder

    new approaches to land use, and the lack of technical tools. According to
    local transportation planners, state air quality managers, and panel
    members, federal agencies could help remove barriers to, and provide
    incentives for, assessing and mitigating the environmental impacts of land
    use. They proposed actions in three key areas: (1) financial incentives for
    transportation, environmental, and local decisionmakers to collaborate on
    land use strategies that limit adverse impacts on air and

    water quality; (2) technical capacity to assess and mitigate land use
    impacts; and (3) assistance in educating the public and local officials
    about the environmental impacts of their transportation and land use
    decisions and alternative development strategies that better protect air and
    water

    quality. EPA and the Department of Transportation (DOT) have some
    initiatives in these areas, and the Congress is considering proposals that
    would provide additional support. However, many of EPA?s actions have been
    one- time initiatives that are limited in scope and not part of a
    coordinated, overall strategy. Likewise, DOT?s initiatives were designed to
    focus on helping localities manage the emissions and congestion that result
    from the land use they select, rather than providing them with an incentive

    to consider land use strategies that reduce or eliminate these effects.
    Principal Findings Emissions Impacts of According to GAO?s survey, 75
    percent of the local transportation planners Different Land Use

    and 36 (about 76 percent) of the 47 state air quality managers do not
    Strategies Are Not Generally estimate the emissions generated from different
    land use strategies in their Assessed efforts to limit emissions and improve
    or preserve air quality. Local transportation planners consider land use
    forecasts that localities provide when they determine future travel demand.
    Most said that in addition to

    prevailing development strategies, localities? land use forecasts are
    beginning to include some alternative strategies considered to be more
    protective of air quality, such as bicycle and pedestrian trails and urban
    redevelopment, which decrease reliance on the automobile. However, local
    transportation planners and state air quality managers are not likely to
    assess the emissions resulting from different land use strategies to
    identify the mix of projects that would provide the most air quality
    protection because (1) they are not required to assess different land uses
    and many do not have an incentive to do so because they are not in areas

    with air quality problems; (2) they believe that land use decisions fall
    under the jurisdiction of local governments and that they have limited
    ability to influence them; and (3) although the transportation planners must
    collaborate with local officials when deciding on the projects to include in

    transportation plans and programs, the planners are not required to share
    the results of any emissions assessments that they may conduct with the
    local officials to help these officials select protective land uses.

    Furthermore, many air quality managers said they do not have the
    collaborative working relationship with local officials needed to pursue
    more protective land use strategies. Local transportation planners in areas
    with current or prior air quality problems, which therefore must demonstrate
    that transportation plans and programs conform to an emissions budget, were
    more likely to assess emissions from different land use strategies. For
    example, 46 percent of

    the 134 planners in areas with air quality problems reported conducting such
    assessments, while only 8 percent of the 155 planners in areas without
    problems reported doing so. However, the areas without problems covered

    by many of these planners contain at least one county that expects
    significant growth in the future and therefore could still influence land
    use decisions to accommodate this growth in ways that preserve their air
    quality. The difference between the two groups of planners suggests that
    although not specifically designed to do so, the federal requirement to
    demonstrate that emissions from transportation plans conform with

    emissions budgets serves as an incentive. The federal requirement encouraged
    certain local transportation planners to estimate the emissions generated by
    different land use strategies and factor land use into their efforts to
    achieve or maintain air quality standards.

    Local transportation planners and state air quality managers that reported
    conducting such assessments also said that they affected transportation
    plans, and to a more limited extent, air quality and land use plans. For
    example, 34 local planners changed their transportation plans by, for

    example, adding more public transit projects. Twenty- three also reported
    that land use plans changed so that, for example, development included
    housing, jobs, and shopping centered around transit stops. Likewise, air
    quality managers in four states reported that either a transportation, land
    use, or air quality plan changed as a result of emissions estimates of
    different land use strategies. Some of the remaining transportation planners
    or air quality managers who assessed emissions from different land uses but
    did not see a change in transportation or land use plans in their areas
    reported that change had not occurred principally because (1) the emissions
    reductions from such changes would not be significant

    and (2) localities making land use decisions faced more pressure to promote
    economic development, for example, than to protect the environment. Stricter
    air quality standards for two pollutants- ozone and particulate matter- that
    EPA plans to implement could increase the number of areas

    with air quality problems, which may cause more transportation planners and
    state air quality managers to turn to land use strategies to help them
    achieve or maintain air quality standards. For example, EPA estimates that,
    as of 1999, about 123 million people have been living in areas that are
    expected to violate the new ozone standard- nearly twice as many as the
    nearly 54 million who live in areas that do not meet the current standard.
    However, local transportation planners and state air quality managers face
    several barriers to assessing the emissions impacts of different land uses
    on air quality and factoring this information into transportation and air

    quality improvement plans. They lack (1) the modeling capability to assess
    and measure certain emissions impacts from different land use strategies and
    (2) a means of ensuring that the land use strategies proposed to limit
    emissions can be or have actually been implemented and that the amount of
    emissions reductions are actually achieved. Most States and Localities

    Most states and localities do not comprehensively assess the impacts of Do
    Not Comprehensively existing land use or future development on water quality
    and factor such Assess and Mitigate the

    analysis into water quality protection and improvement plans, according to
    Adverse Impacts of Land members of GAO?s expert panel and the studies
    reviewed. Urban land use is a significant contributor to nonpoint source
    water pollution, which, Use on Water Quality

    according to EPA, accounts for up to 40 percent of water quality problems in
    waters that have been assessed. However, nonpoint sources are diffuse and
    often hard to identify, assess, and control. Therefore, they received little
    federal attention until the 1987 amendments to the Clean Water Act. Section
    319 of the amended act provides states with grants to implement

    largely voluntary programs to combat nonpoint pollution. However, efforts to
    date have not been enough to significantly reduce this pollution, partly
    because the program is relatively new and has had limited funding compared
    with efforts to control point sources of pollution. While the 1987
    requirements for EPA to regulate major sources of nonpoint source pollution,
    such as storm water runoff, show promise, it is too early to determine their
    effectiveness.

    To further address nonpoint pollution and urban runoff, many states could
    better assess the impacts of land use on water quality and employ land use
    management practices and alternative development strategies to limit adverse
    effects. However, GAO?s expert panel rated the lack of funding, technical
    staff, and public and official support as important impediments to a greater
    assessment of the impact of land use on water quality. Several panel members
    pointed out that analyzing the impacts of existing and future land uses on
    water quality is technically difficult and resourceintensive,

    and that neighboring jurisdictions often do not have, or will not cooperate
    to share, funds and staff. Furthermore, some local land use decisionmakers
    do not understand the relationship between their decisions and water quality
    or feel pressure to focus on economic development rather than environmental
    concerns. Nevertheless, some jurisdictions,

    with sufficient resources and public and official support, have begun to
    employ land use management practices and development strategies that limit
    adverse effects on water quality. For example, New York City and several
    upstate counties formed a watershed partnership with other local
    stakeholders and, among other things, purchased environmentally sensitive or
    undeveloped land within the watershed to protect drinking water sources from
    impairment by polluted runoff.

    More states and localities may have to assess land use impacts and take
    similar mitigation measures in the future. In response to citizens? concerns
    about persistent water quality problems, EPA and the states are focusing
    more attention on controlling nonpoint pollution, as evidenced by EPA?s
    revised rule for determining the total maximum daily load of contaminants
    that a water body can sustain. However, GAO?s panel of experts identified

    a number of barriers that states and localities would have to overcome: the
    lack of (1) resources for assessing land use impacts and public and official
    support for land use controls and alternative development patterns; (2)
    scientific data on the quality of water bodies and on the cumulative impacts
    of land use and development practices; (3) needed technical tools, such as
    access to user- friendly models; (4) updated zoning laws, development codes,
    and other laws that allow for innovative land use

    practices; and (5) regional organizations with the authority to take a more
    comprehensive, cross- jurisdictional approach to assessing water quality and
    influencing land use to protect it.

    Federal Agencies and the The majority of local transportation planners,
    state air quality managers,

    Congress Could Take a and GAO?s panel of experts suggested a number of
    federal actions to Number of Actions to Help reduce the barriers they
    identified in order to promote more widespread

    States and Localities Better assessment and mitigation of land use impacts
    on air and water quality. First, the Congress and agencies could provide
    additional financial Consider the Environmental incentives to encourage
    assessments of the air and water quality impacts of Impacts of Land Use land
    use. Incentives could include providing more funds for transportation,
    environmental, or land use projects that were developed collaboratively with
    local transportation planners and air quality, water quality, and land use
    officials, and that minimize the environmental impacts of land use.

    Second, the agencies could provide local transportation planners,
    environmental officials, and communities with some of the technical tools
    they need to help them assess, mitigate, and prevent land use impacts. These
    tools would include guidance on land use practices that limit environmental
    effects and improved modeling practices for estimating the environmental
    impacts of different growth scenarios. Third, the agencies

    could help to better educate local land use decisionmakers and the general
    public about the relationship between air and water quality protection and
    their transportation and land use choices and encourage collaboration on
    protective land use strategies.

    The federal agencies involved in air and water quality protection have
    initiatives under way, and the Congress is considering several legislative
    changes that begin to address some of these proposals. For example, EPA has
    provided a limited number of grants to encourage land use solutions to
    environmental problems and is developing methods to measure the air and

    water quality benefits of certain land use practices. It has also publicized
    best practices and encouraged their wider use. Similarly, DOT has several
    funding programs to (1) promote transportation alternatives that limit air
    quality impacts and (2) improve transportation models so that they can
    account for the impacts of small- scale changes, such as added bicycle and
    pedestrian trails, and for the ways in which transportation projects
    encourage or discourage travel demand. The Congress is also considering
    actions to support state and local growth management efforts, such as
    providing for better coordination among federal agencies that provide
    community assistance, and financial incentives to update outmoded state

    laws that discourage innovative and environmentally protective land use
    strategies.

    While EPA?s efforts are commendable, some have not reached a large and
    diverse enough number of communities to have an impact nationwide. According
    to the manager for the agency?s smart growth initiatives, EPA

    recognized that it had limited resources and authority to help the thousands
    of existing communities with their land management efforts. Therefore, the
    agency decided to use its funds as seed money for pilot projects in select
    communities. The agency tasked the Development, Community, and Environmental
    Division within the Office of Policy with the mission of helping to promote
    smart growth initiatives and gave it limited resources. However, the agency
    decided to allow each program and regional office to determine the extent to
    which that office could assist state and local efforts and did not give
    these offices a similarly defined smart growth mission or resources. While
    these offices have undertaken a number of initiatives, they have not
    coordinated them effectively and the level of activity has varied. For
    example, one region had a smart growth agenda and workgroups from the
    various program offices, while another region had little staff support to
    undertake initiatives. The agency will not have a more widespread impact
    until it, among other things, (1) takes stock

    of its initiatives to determine which were successful and effective, (2)
    lays out a strategic and better coordinated plan for its efforts, and (3)
    requests any necessary authority and funding to implement the plan.
    Likewise, while DOT?s initiatives were designed to promote transportation
    options that control emissions, they were not designed to encourage local

    transportation planners to consider whether different land use strategies
    would result in more of these options or to encourage communities to
    consider altering land use plans as a means to implement these options.

    Transportation planners may not consider the impacts that different land use
    strategies have on emissions without additional incentives, such as making
    land use considerations a more explicit criterion for funding transportation
    projects or encouraging the planners to assess their impacts on emissions
    and to share the results with local land use decisionmakers. Recommendations
    for

    GAO is making a number of recommendations on ways that EPA and DOT Executive
    Action

    can better focus and coordinate their activities and provide additional
    incentives, technical support, and public outreach to promote a closer link
    between land use and environmental protection.

    Matters for GAO is making several suggestions on ways that the Congress may
    want to Congressional provide EPA with additional authority and funding, and
    provide states and

    localities with additional financial incentives, to limit the adverse
    Consideration environmental impacts of land use and update outmoded laws
    that prohibit the consideration of more protective strategies.

    Agency Comments EPA generally agreed with GAO?s conclusions and
    recommendations and said that they would be helpful in guiding its future
    smart growth initiatives. The agency asked GAO to better describe the role
    of the Office

    of Policy in managing EPA?s smart growth efforts. EPA also recognized the
    need to encourage its program and regional offices, as well as states and
    localities, to integrate their transportation, air and water quality
    improvement, and land use planning efforts, and assess the cumulative

    environmental impacts. DOT also generally agreed with GAO?s findings and
    recommendations. In addition, the agency asked GAO to recognize the role of
    states and their legislatures in promoting environmentally beneficial land
    use.

    Chapt er 1

    Introduction Following World War II, Americans, in increasing numbers,
    searched for the ?American dream?- a single- family home on a large lot
    located close to the countryside- in a newly developed suburban community
    away from the urban core. In 1950, nearly 70 percent of the population in
    metropolitan areas lived in cities. By 1990, more than 60 percent lived in
    the suburbs, although data from the 2000 census suggest that some cities are
    beginning to regain population. In part, increased automobile ownership, the
    building of new highways to once remote areas, and less expensive land and
    housing helped encourage the population shift to the suburbs. Suburban
    expansion has also continued, in part, because of concerns about urban crime
    and poor school systems. In recent years, urban development in previously
    rural areas and increases in traffic volume have outpaced population growth.
    For example, from 1982 through 1997, developed land increased by 47 percent
    nationwide, while the population grew by only

    17 percent. In addition, in the last 30 years, the total number of vehicle
    miles traveled grew by 125 percent, roughly 4 times faster than the rate of
    population growth, while, according to Department of Transportation (DOT)
    managers, the number of lane miles in the nation?s road system grew by only
    5 percent. Figure 1 demonstrates growth trends over time around Lake
    Michigan.

    Figure 1: Growth Trends, Over Time, in the Chicago- Milwaukee Area

    Source: United States Geological Survey.

    The prevailing pattern of development, now often referred to as ?urban
    sprawl,? generally includes low- density development that does not cluster
    housing with schools, jobs, and stores and that therefore requires
    dependence on automobiles. In recent years, Americans have begun to

    recognize some downsides to this pattern- traffic congestion, loss of green
    space, and impaired environmental quality. For example, over the last 25
    years, at least 20 of the nation?s largest cities have seen increases of 30
    percent or more in congestion. According to a 1998 federally sponsored
    study, traffic delays cause the average resident of the greater Washington,
    D. C., metropolitan area to spend 2 full work weeks a year stalled in
    traffic. 1 Recently, the public has become concerned about this congestion,
    loss of open space, and deteriorating infrastructure, as well as certain

    environmental impacts associated with this pattern of growth. For example,
    this pattern impairs air and water quality through polluted emissions from
    increased traffic and polluted runoff from impervious surfaces, such as
    roads, parking lots, and rooftops. Impaired air and water

    can, in turn, result in human health problems and ecological degradation.
    Figure 2 illustrates how such development contributes to air and water
    pollution.

    1 See T. Lomax and D. Schrank, Urban Roadway Congestion, 1982 to 1996
    (College Station, Tex.: Texas Transportation Institute, 1998).

    Figure 2: Contributions of Air and Water Pollution From Certain Patterns of
    Development

    Source: GAO.

    Air Pollution From When automobiles, trucks, and other vehicles burn fuel,
    their exhaust

    Vehicle Emissions emissions pollute the air we breathe. Over the past 50
    years, epidemiological and other studies have consistently found that
    breathing

    Poses Public Health certain pollutants from vehicle emissions contributes to
    respiratory and and Environmental

    other health problems. As a result, the Environmental Protection Agency
    Risks (EPA) has regulated these pollutants- referred to as ?criteria
    pollutants?: carbon monoxide, nitrogen dioxide, ground- level ozone, sulfur
    dioxide, particulate matter, and lead. 2 Figure 3 shows the percentages of
    vehicle emissions most associated with motor vehicles in 1998.

    2 Ozone is not directly emitted by mobile sources, but is formed by the
    airborne reaction of heat and sunlight with nitrogen oxides and volatile
    organic compounds, which, in turn, are emitted by cars and trucks. Also,
    much of the particulate matter contributed by motor vehicles is in the form
    of road dust. Vehicle emissions are not the primary source of sulfur dioxide
    and lead.

    Figure 3: Proportion of 1998 Emissions From Motor Vehicles for Carbon
    Monoxide, Nitrogen Oxides, and Volatile Organic Compounds

    Source: National Air Pollutant Emission Trends, 1900- 1998, EPA (2000). High
    atmospheric concentrations of ozone and particulate matter increase hospital
    admissions and premature deaths, damage lung tissue, and

    aggravate respiratory disease. They also increase susceptibility to
    respiratory infection; compromise immune systems; and, in some cases, can
    increase cancer risks, according to EPA. These pollutants are especially
    harmful to those with heart and lung conditions and to other sensitive
    populations, such as children and the elderly. EPA estimates that such
    health problems cost Americans tens of billions of dollars annually. Table 1
    describes the numerous public health problems associated with some of the
    criteria pollutants most closely associated with motor vehicle emissions.

    Table 1: Health Impacts of the Criteria Pollutants Most Associated With
    Motor Vehicle Emissions Pollutant Health impacts

    Carbon Interferes with oxygen absorption. Lack of oxygen impairs the
    monoxide cardiovascular and nervous systems. Symptoms include chest pain,
    headaches, dizziness, nausea, fatigue, and slower reflexes. Impairs visual
    perception, work capacity, manual dexterity, learning ability, and the
    performance of complex tasks. Affects fetal growth and tissue development.
    Results in death at extremely high concentrations. Ozone May cause temporary
    lung irritation, minor eye irritation, coughing, and pain

    upon inhalation during short- term exposure. Heavy exercise becomes
    difficult. Long- term exposure to ground- level ozone may cause structural
    lung damage, leading to chronic lung disease, lung cancer, and increased
    susceptibility to respiratory infections, such as bronchitis and pneumonia.
    May interfere with the immune system. May be an agent for infectious
    disease, since it produces more receptors for viruses. Exacerbates
    allergies. Particulate

    May cause coughing, lung tissue damage, alteration in immune systems, matter
    and respiratory and cardiovascular diseases. Aggravates existing respiratory
    and cardiovascular diseases. Raises the risk of cancer because carcinogens
    may adhere to particulates.

    Source: Our Built and Natural Environments: A Technical Review of the
    Interactions between Land Use, Transportation, and Environmental Quality,
    EPA (2001. EPA 231- R- 01- 002).

    In addition to criteria pollutants, vehicle emissions contain other
    pollutants- referred to as toxic air pollutants- that can also cause cancer,
    reproductive disorders, or birth defects in humans and wildlife. One such

    group of pollutants, known as polycyclic aromatic hydrocarbons (PAH), is
    formed as a result of the incomplete combustion of hydrocarbons in oil,
    gasoline, and other fuels. PAH levels in sediments have increased over the

    last three decades, and the most rapid increases have been seen in
    watersheds experiencing rapid growth and increased motor vehicle activity.
    Of the 30 toxic pollutants in urbanized areas that pose the greatest threat
    to public health, 40 percent come from vehicle emissions, according

    to EPA estimates. Moreover, pollutants emitted from vehicles can be carried
    hundreds of miles by air currents and form new compounds in the air that can
    be deposited on land and water when they fall back to earth. Several of
    these compounds, including some carcinogenic ones, can be taken up by plants
    or ingested by animals and eventually work their way up

    the food chain, thereby increasing the risk associated with human
    consumption of food contaminated with these pollutants.

    Air pollution from vehicle emissions can also damage ecosystems in sensitive
    waters, such as bays and estuaries. The atmospheric deposition of pollutants
    is now recognized in many areas as a significant cause of coastal water
    quality problems, the acidification of streams and lakes, and the toxic
    contamination of fish and the birds and mammals that feed on

    them. Nitrogen oxides from vehicle emissions deposited into the Chesapeake
    Bay threaten this major fish hatchery by over stimulating the growth of
    algae, which contributes to the degradation of spawning habitat. 3 Nitrogen
    oxides also combine with other atmospheric pollutants to form acid
    deposition, which falls back onto land or flows into waterways with storm
    water. 4 Acid deposition can lead to declines in fish populations and other
    aquatic species. Additionally, air pollution, such as ozone and acid
    deposition, damage crops and building materials. According to EPA, air
    pollution from vehicle emissions annually causes about $2. 5 billion to
    about $4. 5 billion in crop damage. 5

    Finally, motor vehicles emit carbon dioxide, which traps heat within the
    earth?s atmosphere. These greenhouse gas emissions are by far the single
    largest source of carbon emissions to the atmosphere. In 1999 alone,

    vehicle emissions, primarily from automobiles and light trucks, contributed
    to 60 percent of the total carbon emitted by the transportation sector,
    according to the Department of Energy. 6 The accumulation of greenhouse
    gases in the atmosphere from man- made sources is a factor in climate

    3 Nitrogen oxides generally refer to several compounds of nitrogen and
    oxygen. 4 While ?acid rain? is the commonly used term, ?acid deposition? is
    more accurate. The latter encompasses both wet deposition (through rain,
    snow, sleet, and fog) and dry deposition (through gases, aerosols, and
    particles). 5 1990 dollars converted to 1999 dollars.

    6 Diesel fuel, jet fuel, and residual oil or heavy fuel oil, used largely
    for maritime use, account for the rest, at about 20 percent, 13 percent, and
    4 percent, respectively.

    change. Although the effect of this change on human health and the
    environment is uncertain, it is believed to be significant. While Harmful
    With the exception of nitrogen oxides, the total emissions of harmful air

    Emissions Continue to pollutants, especially those from mobile sources, have
    declined

    significantly since 1970, even as the number of vehicle miles traveled
    Decline Nationwide, increased significantly. The decline has occurred
    primarily because of Certain Localities May

    cleaner fuels, emissions- control technology for vehicles, and tighter
    Continue to Face Air

    controls on industrial emissions. Despite the progress, however, air quality
    problems in certain localities continue. For example in 1999, 62 million
    Quality Problems

    Americans lived in areas that did not meet federal air quality standards. In
    addition, over the last 25 years, at least 20 of the nation?s largest cities
    have seen increases of 30 percent or more in congestion, thereby affecting
    air quality- cars can release more of certain pollutants under stop- and- go

    conditions. In addition, sport utility vehicles (SUV) have become very
    popular and currently are allowed to emit more pollutants than passenger
    cars. As a result, the growth of this vehicle market has increasingly
    contributed to vehicle emissions, exacerbating air quality problems in some
    areas. For example, local officials in the Washington, D. C.,

    metropolitan area have recently expressed concerns about increasing
    emissions in the area because of the prevalence of SUVs.

    In the future, emissions from harmful air pollutants, especially those from
    mobile sources, most likely will decrease nationwide for several reasons.
    For example, new more- stringent air quality standards for SUVs and light-
    duty trucks will take effect in 2004. More- stringent standards for heavy-
    duty vehicle engines will also be implemented in 2007 and are

    expected to further reduce emissions. 7 Further improvements in motor
    vehicle and fuel technology, including the use of alternative fuels and fuel
    cells, will most likely occur in the next 20 to 30 years, which could help
    to offset emissions from increases in the number of vehicle miles traveled
    and

    growth. However, while more stringent emissions standards will help to
    improve air quality nationwide, it is unclear whether they will be able to
    compensate for increasing vehicle emissions, owing to increased vehicle
    miles traveled in certain geographic areas. For example, a study of
    projected volatile 7 These standards are currently the subject of
    litigation.

    organic compounds and nitrogen oxide emissions in Tennessee concluded that
    these regulatory changes would not be enough to sufficiently control
    emissions through 2030 in areas where the number of vehicle miles traveled
    increased more than 4 percent. Three cities, which lie at the center of the
    largest Tennessee metropolitan areas- Memphis, Nashville, and Knoxville- had
    increases in vehicle miles traveled that exceeded 4 percent from 1990
    through 1998, the time period considered for this study. 8 In addition, EPA
    expects to implement two more- stringent air

    quality standards in the future, although currently under litigation, that
    will increase the number of counties in nonattainment for the standards.
    Therefore, certain areas may need to look for additional methods of limiting
    emissions, such as alternative ways to develop land that reduce dependence
    on the automobile.

    More Paved and Other EPA now identifies storm- water runoff in urbanized
    areas as one of the

    Impervious Surfaces leading causes of impaired water quality in the United
    States, including

    sources of drinking water, such as streams, lakes, and underground wells.
    Increase Polluted When urban storm water runs over paved and other
    impervious surfaces, it Runoff, Thus picks up pollutants, such as bacteria
    and viruses (pathogens), toxic

    Threatening Public chemicals, and heavy metals, that have been deposited on
    these surfaces and carries them into waterways. This runoff can threaten
    public health,

    Health and the Aquatic degrade environmental quality, increase the risk of
    flooding, and impose Environment

    economic costs on society. For example, pathogens in runoff- from pet waste
    deposited on streets and sidewalks, failing septic fields on residential
    properties, combined sanitary and storm sewer overflows, and other sources-
    are major contributors to water quality degradation. They can cause serious
    diseases, such as respiratory and skin infections, infectious hepatitis,
    gastroenteritis, and dysentery, in people exposed to contaminated water
    during swimming or other recreational activities, or

    through the consumption of contaminated drinking water or shellfish. EPA
    reported that states and localities issued advisories for or temporarily
    closed 459 beaches (24 percent of all reported beaches) in 1999, limiting
    recreational and other activities because of elevated bacteria levels in
    storm- water runoff. In addition, toxic contaminants contained in urban

    runoff- such as pesticides, metals, petroleum products and additives, and 8
    See Wayne T. Davis, Terry L. Miller, Gregory D. Reed, Prakash Doraiswamy,
    Anna Tang, and Pedro Sanhueza, ?VMT Growth Rates in the U. S. and Their
    Effects on NOx and VOC Emissions,? presented and published in the
    proceedings of the 94 th Annual Conference of the Air and Waste Management
    Association (June 25- 27, 2001).

    the by- products of vehicle fuel combustion- can result in advisories
    warning against consuming fish from affected waters.

    In addition to these more immediate health risks, toxic chemicals in urban
    runoff may pose long- term risks, although the extent of these risks is
    unknown. There is usually more than one contaminant in runoff, and they
    often either combine into complex mixtures or break down into new, even more
    toxic chemicals. EPA does not have health- based standards for many

    of these contaminants. In addition, EPA standards are based on long- term
    exposures of single contaminants at a constant concentration and may not
    address the adverse health effects that may result from exposure to multiple
    contaminants for long periods at low concentrations, punctuated by brief
    incidents of high concentrations that typically occur during storms.
    Therefore, the risk to humans and the environment from exposure to low

    levels of complex mixtures of contaminants remains unclear. Contaminated
    urban runoff also harms ecosystems. Toxic chemicals in urban runoff can
    reduce the overall biological diversity of aquatic systems. Urban runoff
    carries nutrients from lawn fertilizers and organic wastes into estuaries
    and lakes. These nutrients can over stimulate algae and plant growth, which
    can degrade coral reefs and important fish spawning habitats. In 2001, the
    U. S. Geological Survey (USGS) reported that in

    70 percent of its sampled urban streams, the levels of phosphorus, a
    chemical found in lawn fertilizers, exceeded EPA?s goals for preventing
    unwanted plant growth. Excess nutrients also contribute to toxic algae
    blooms, sometimes called ?red tides,? which kill marine wildlife and pose

    risks to humans who eat contaminated shellfish. Certain patterns of growth
    can also contribute to flooding or increase runoff volumes and rates.
    Because the large areas of impervious surfaces associated with this growth
    do not absorb storm water, large volumes are rapidly discharged into
    waterways, which can increase the frequency and severity of flash flooding
    and result in stream channel degradation, water temperature changes, and the
    destruction of habitat. Also, when there is not enough open land to absorb
    this water, it runs off, causing water levels to decrease during dry periods
    and reducing some water supplies. Figure 4

    shows how development increases flood levels and reduces stream flow levels.

    Figure 4: Effects of Development on Flood Potential and Stream Flow Levels

    Source: Adapted by GAO from Schueler, Controlling Urban Runoff (1987).

    Finally, large volumes of runoff increase erosion and carry large quantities
    of often contaminated sediment downstream, where it settles to the bottom of
    waterways. This sediment clogs harbors, reservoirs, streams, and navigable
    channels and degrades fish and shellfish habitat, thereby limiting
    commercial and recreational fishing opportunities. Dredging these waterways
    to remove contaminated sediment can be costly. For example, in 1997, EPA
    estimated that the U. S. Army Corps of Engineers alone spends $180 million
    annually to dredge 83 million cubic yards of polluted sediment.

    While development, including the construction of highways, roads, bridges,
    and related physical infrastructure, contributes to runoff and its
    associated problems, it may also reduce the amount of wetlands, thereby
    destroying a natural system for preventing or controlling floods and
    erosion. 9 For example, wetlands can prevent floods by acting as natural
    sponges for water and can mitigate contaminated runoff by removing excess
    nutrients and some chemical contaminants from water. Figure 5 illustrates
    how

    wetlands can achieve these benefits.

    Figure 5: Wetlands? Contribution to Improving Water Quality and Reducing
    Storm Water Runoff

    Source: EPA.

    9 See Water Quality: Better Data and Evaluation of Urban Runoff Programs
    Needed to Assess Effectiveness (GAO- 01- 679, June 29, 2001).

    Some States and Some states and localities have begun to reevaluate their
    development

    Localities Are patterns and explore alternative growth strategies. They are
    not

    considering an end to growth- recognizing that growth and development
    Implementing are inevitable with a growing U. S. population- they are just
    trying to limit Alternatives to the its adverse effects. For example, the
    population is expected to increase by

    Prevailing Growth almost 50 percent in the next 50 years, from 273 million
    in 1999 to

    404 million by 2050, according to the U. S. Census Bureau. This population
    Pattern That Could

    growth, in turn, will increase the demand for residential, commercial, and
    Help Limit

    industrial development. Environmental Impacts To help limit the impacts of
    this development, communities are now reexamining development patterns, as
    reflected by a host of ballot measures in November 2000 that was aimed at
    setting limits to suburban

    growth. In response, some states and local governments are beginning to
    consider ways to accommodate future growth that take into account
    environmental as well as economic concerns. Commonly referred to as ?smart
    growth,? these new development patterns can take many forms,

    including the following:  Transit- oriented development, which enables
    people to use public transportation to reach their jobs, homes, schools, and
    stores.  Mixed land uses that locate housing, shopping, offices, and other
    amenities near each other.  Compact development, including the development
    that fills in vacant or underused lands in cities, known as ?infill
    development,? or the

    redevelopment of underutilized or abandoned lands that may have been
    contaminated during previous use, known as ?brownfields.?  Downtown
    redevelopment focused in central business districts.  Pedestrian and
    bicycle projects along existing transportation routes or along new, direct
    routes between locations.

     Development practices that reduce impervious surfaces and increase water
    retention, such as using porous surfaces.  The preservation of important
    environmentally sensitive lands and open

    space. According to EPA, these development patterns can yield better
    environmental results than conventional growth patterns, although isolating
    the effects of each can be difficult because most of these development
    practices work together. For example, studies have shown that compact
    development and development that reduces impervious surfaces have reduced
    urban runoff volume by up to 40 percent and have

    reduced pollutant levels by about 60 to 90 percent at individual sites. 10
    Likewise, development that encourages people to walk, bike, or use public
    transit can improve air quality by reducing reliance on the automobile.
    Federal Rules Aim to

    Several federal laws are designed to limit pollutants from vehicle emissions
    Control Harmful that pose adverse health risks, especially in those areas
    that are already experiencing poor air quality. The Clean Air Act requires
    EPA to establish Automobile Emissions,

    air quality standards to protect public health and welfare. These Especially
    in Areas standards- known as the ?national ambient air quality standards?-
    That Have Air Quality

    establish limits on the amount of the six criteria pollutants that are
    allowed in the air. The states are required to develop strategies, called
    State

    Problems Implementation Plans (SIP), for implementing, maintaining, and
    enforcing strategies to attain these standards. When pollution levels exceed
    the

    standards for any of the criteria pollutants in an area of the country, EPA
    may designate that area as being in ?nonattainment? of the standard for that
    pollutant, and affected states must take measures to address the problem.

    Once the standard is reached and planning obligations achieved, the area is
    redesignated as being in attainment but must preserve this level of air
    quality under a maintenance SIP for 20 more years. 11 State air quality
    managers are responsible for developing the SIP, among

    other things. SIPs include both estimates of future emissions and
    established limits on, or budgets for, the total amount of emissions that
    can come from on- road vehicles, such as cars, motorcycles, and trucks, and
    transit vehicles, such as buses. The air quality managers lay out the ways
    in which they expect the state to achieve the national ambient air quality
    standards and adhere to emissions budgets. For example, if a state

    implements a vehicle inspection and maintenance program, the manager can
    take credit for the amount of emissions reductions expected from this
    activity to help the state achieve the standards. Managers can also take

    credit for expected emissions reductions from certain transportation control
    measures, such as high- occupancy vehicle lanes or public transit
    improvements that communities plan to implement. 10 Although low- density
    development generally allows more water to be absorbed in the soil than
    higher- density development, the greater total amount of land affected by
    low- density development, including land devoted to roads and parking

    lots, often produces a greater adverse impact on water quality. 11 42 U. S.
    C. sect. 7505a (a), (b).

    The Congress further strengthened its efforts to limit the air quality
    effects of emissions from transportation sources with the passage of the
    Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) 12 and its
    successor, the Transportation Equity Act for the 21 st Century (TEA- 21). 13
    For example, the acts gave states and localities flexibility to apply
    certain federal transportation funds to either highway or transit projects,
    thereby

    making it easier for states to undertake projects that have air quality
    benefits.

    The acts also increased the responsibility of metropolitan planning
    organizations (MPO), which are responsible for carrying out the
    transportation planning process in a metropolitan or regional area, and
    certain air quality protection activities. 14 MPOs often comprise (1) a
    policy board, which can include locally elected officials from the area; (2)
    a technical committee of professional staff from local, state, and federal
    transportation agencies; and (3) MPO staff. As part of the
    transportationplanning

    process, MPOs develop two key documents- the transportation plan and the
    transportation improvement program (TIP). The transportation plan specifies
    a 20- year vision for a metropolitan area?s transportation system. In
    contrast, the TIP is a short- term, more- detailed document that specifies
    the priority projects to be implemented in the next

    3 years and has to be updated every 2 years. In developing these two
    planning documents, MPOs are to collaborate with the public, other
    transportation stakeholders, and local officials in the area. These local
    officials could include those responsible for land use planning and

    decisionmaking. Under TEA- 21, MPOs are also to consider seven broad factors
    when developing their plans, including one described in general terms as
    protecting and enhancing the environment, promoting energy

    conservation, and improving the quality of life. The transportation plans
    and TIPs for areas in nonattainment or maintenance status are subject to
    additional Clean Air Act requirements. In these areas, transportation
    activities cannot result in total emissions that 12 Intermodal Surface
    Transportation Efficiency Act of 1991, P. L. No. 102- 240, 105 Stat. 1914
    (1991).

    13 Transportation Equity Act for the 21 st Century, P. L. No. 105- 178, 112
    Stat. 107 (1998). 14 In 1970, federal policy required the creation of
    planning agencies in areas with populations of 50, 000 or more to carry out
    cooperative planning at the

    metropolitan level. There are currently 341 MPOs in the United States.

    cause new violations of air quality standards, worsen existing violations,
    or delay the timely attainment of the standards and provisions of a SIP. All
    areas in nonattainment and maintenance for any one of four criteria
    pollutants- ozone, 15 carbon monoxide, particulate matter, and nitrogen
    dioxide- must estimate the emissions of that pollutant from the planned
    transportation activities in the area. In those areas with a SIP that also
    contains a mobile source emissions budget, estimated emissions must be

    less than or equal to the budgets. In areas without an emissions budget, the
    estimated emissions are compared with other baselines, such as the emissions
    levels in 1990. Making these comparisons is known as the requirement to
    demonstrate conformity. MPOs are responsible for determining conformity at a
    minimum of every 3 years, or when they

    update their plans or TIPs, and must submit the results to DOT, which
    reviews them and determines that conformity has been achieved. If the plans
    and TIPs do not conform to the emissions budget, the MPOs cannot, with
    limited exceptions, spend any federal funds on highway or transit

    projects that will exacerbate existing air quality problems or lead to new
    violations of federal air quality standards. However, projects related to
    highway safety, transportation control measures included in an already
    approved SIP to improve air quality, or transportation projects already
    approved or funded by the federal government can move forward.

    Federal Rules Aim to The Clean Water Act requires states to establish water
    quality standards as Protect the Nation?s

    a way of ensuring that the act?s goals will be met. These goals include
    achieving and maintaining water quality to protect and propagate fish, Water
    Bodies From shellfish, and wildlife and to provide for recreation in and on
    the water. To Harmful Pollutants

    develop water quality standards, states classify waters according to how
    they will be used- for fishing, swimming, and other beneficial uses- and
    adopt water quality criteria to protect those designated uses. Water quality

    criteria- which can be numeric or narrative- indicate the acceptable levels
    of chemicals allowed, or physical or biological characteristics required, in
    a water body in order for it to meet its designated use. Waters that do not
    meet standards are often referred to as ?impaired.?

    The Clean Water Act also established the National Pollutant Discharge
    Elimination System (NPDES), a program that controls pollutant discharges
    from industrial facilities and wastewater treatment plants, which are often

    15 These areas estimate emissions of hydrocarbons and nitrogen oxides- the
    precursors of ozone.

    referred to as ?point sources? of pollution. Under this program, EPA issues
    permits to facilities that discharge pollutants and imposes requirements for
    the mechanisms these facilities must use to reduce the amount and toxicity
    of the pollutants they discharge. Although the program did not initially
    address storm- water discharges, the Congress amended the act in 1987,
    directing EPA to also control storm water that enters municipalities? storm
    sewer systems. EPA?s 1990 regulations implementing this change, established
    the NPDES Storm Water Program and described permit application requirements.
    The program?s objective, in part, is to preserve,

    protect, and improve water quality by, among other things, controlling the
    volume of runoff from impervious surfaces and reducing the level of runoff
    pollutants to the maximum extent practicable using best management
    practices. 16 The Clean Water Act also addresses nonpoint source pollution.
    Nonpoint sources of pollution include many different types of land use
    activities,

    including urban development, agriculture, and timber harvesting. The act
    required EPA to provide states with federal funds and technical and
    management assistance to implement nonpoint source management programs. In
    their nonpoint source assessments, states identified waters that, without
    additional controls over nonpoint sources, will not meet water quality
    standards. The states also developed management programs

    to deal with these problems. The act calls for water quality goals and
    standards to be achieved through a variety of means, including the
    development of total maximum daily loads (TMDL)- that is, the maximum amount
    of a pollutant that a body of water can receive on a daily basis and still
    support its designated uses. Generally, states and localities develop TMDLs
    by analyzing the pollutants and their

    sources and determining how much the pollutants must be reduced to meet the
    standards. Under EPA regulations, the amount of required pollutant reduction
    is allocated among the point and nonpoint sources contributing

    to the water quality problem. Land use and associated runoff contribute to
    nonpoint source pollution. In July 2000, EPA promulgated a rule amending its
    regulations to strengthen the TMDL program. EPA subsequently postponed the
    rule?s implementation and is reviewing the proposal because 16 According to
    EPA, a best management practice is a device, practice, or method for
    removing, reducing, retarding, or preventing targeted storm- water runoff
    constituents, pollutants, and contaminants from reaching receiving waters.

    of concerns about its potential costs and other impacts. This rule is also
    currently the subject of litigation. In addition to the Clean Water Act, the
    Coastal Zone Amendments Reauthorization Act of 1990 outlines a process for
    states to deal with nonpoint source pollution that affects coastal waters.
    17 It requires states to address significant sources of nonpoint source
    pollution from urban areas, agriculture, forestry, marinas, dams, and
    changes in the course of rivers.

    EPA and the Department of Commerce?s National Oceanic and Atmospheric
    Administration (NOAA) jointly oversee the process.

    Objectives, Scope, and The Senate Smart Growth Task Force and the House
    Sustainable Methodology

    Development Caucus asked us to  determine the extent to which MPOs and
    state air quality managers

    responsible for meeting federal clean air requirements consider the impacts
    of alternative land uses on their efforts to protect air quality;
    determine how, if at all, state and local officials responsible for water

    quality and land use consider the water quality impacts of alternative land
    uses and work together to limit any adverse impacts; and  identify the
    actions that the federal government can take to help

    transportation, air quality, and water quality officials better link land
    use decisions with environmental protection.

    To address these objectives, we obtained information on air quality issues
    by surveying the 341 metropolitan planning organizations recognized by the
    Federal Highway Administration?s Office of Metropolitan Planning and
    Programs and the 51 state air quality agencies (including the District of
    Columbia). 18 We did not attempt to gain information from the state
    departments of transportation, which are responsible for transportation
    planning in those areas without a designated MPO. We had a high response
    rate for our surveys: 87 percent (295) of the 341 MPOs surveyed and 92
    percent (47) of the 51 air quality agencies surveyed. For certain analyses,
    we merged the MPO survey data with survey data about counties? 17 This
    program also includes states that border the Great Lakes. 18 The list
    supplied to us had 345 listed MPOs; however, 5 subsequently contacted

    us to let us know that they are not the MPO for the area, and 1 contacted us
    to let us know that it had split into two separate MPOs.

    anticipated growth from our previous study of local growth issues. 19 The
    results from the surveys of MPOs and state air quality managers are
    presented in appendixes II and III, respectively. We also obtained
    information on water quality issues from a panel of 32

    experts. To select our panel, we used a methodology that provided the
    maximum opportunity to obtain members representing the broadest possible
    range of expert views on the issues associated with land use and

    water quality. To collect data from the panel, we used a modified Delphi
    methodology- an alternative to in- person discussion that avoids certain
    biasing effects, such as the dominance of a few individuals. To obtain
    controlled feedback from the panel, we used two iterative sets of

    questionnaires on the Internet. We analyzed descriptive statistics on the
    data collected, which demonstrated a high level of agreement among the panel
    members, even across different areas of expertise, on virtually all of the
    items included in the second questionnaire. The questions posed to the

    panel and the statistical summary of their responses are presented in
    appendix V. The names and organizational affiliations of the panel members
    selected are in appendix VI.

    In addition, we drew on our own prior work on related issues. A list of
    these reports can be found in the section entitled ?Related GAO Products.?
    We also interviewed responsible officials and collected documents from the
    federal agencies administering transportation, air quality, and water
    quality programs, as well as from relevant stakeholders. Specifically, we
    interviewed and gathered documentation from officials associated with the
    following federal agencies and organizations:  EPA. Office of Air and
    Radiation; Office of Transportation and Air

    Quality; Office of Wetlands, Oceans, and Watersheds; and Office of Policy,
    Economics, and Innovation.  DOT. Federal Highway Administration?s Offices
    of Metropolitan Planning and Programs, Natural Environment, and Human

    Environment; and Federal Transit Administration?s Office of Planning.
    USGS. Water Resources Division, including the National Water Quality
    Assessment Program, the National Mapping Information Division and its Urban
    Dynamics Research Program; and the Biological Resources Division.

    19 See Community Development: Local Growth Issues- Federal Opportunities and
    Challenges (GAO/ RCED- 00- 178, Sept. 6, 2000).

     NOAA. National Ocean Service, including the Office of Coastal Management
    and the Coastal Nonpoint Pollution Control Program.  Representative
    stakeholders. The Association of Metropolitan Planning

    Organizations, National Association of Counties, the Northeast- Midwest
    Institute, the National Association of Regional Councils, the National
    League of Cities, the National Governors? Association, the Center for
    Watershed Protection, the Low Impact Development Center, the Natural
    Resources Defense Council, the Nature Conservancy, the Environmental Law
    Institute, the State and Territorial Air Pollution Program Administrators/
    Association of Local Air Pollution Control Officials, and the Association of
    State and Interstate Water Pollution Control Administrators.

    Appendix I contains a more detailed discussion of our scope and methodology.
    We performed our work from September 2000 to September 2001 in accordance
    with generally accepted government auditing standards.

    Most MPOs and Air Quality Managers Do Not Assess the Emissions Impacts of
    Different

    Chapt er 2

    Land Uses in Protecting Air Quality While land use can affect air quality,
    most of the MPOs and state air quality managers that we surveyed do not
    assess the emissions that would be generated by different land use
    strategies when developing their transportation or air quality improvement
    plans. MPOs use localities? projections of growth to forecast future travel
    needs and design the longerterm

    transportation plan and shorter- term transportation improvement program
    (TIP) to meet those needs. However, most MPOs do not consider whether
    different land uses or patterns of growth would result in transportation
    plans that are more protective of air quality. Many MPOs and state air
    quality managers do not participate in land use assessments principally
    because they are not required to do so and because most believe they have
    limited influence, since land use decisions fall under the jurisdiction of
    local governments. As a result, they may be missing opportunities to limit
    emissions and, consequently, health and environmental risks.

    Those MPOs that did estimate the vehicle emissions that transportation plans
    and TIPs would generate on the basis of different land use strategies were
    more likely to be in areas with air quality problems and under the
    obligation to demonstrate that emissions from the plan or TIP will not
    exceed established budgets. This suggests that the requirement to
    demonstrate conformity between transportation plans and TIPs and the

    emissions budget can influence MPOs to assess whether different land uses
    would help them to limit emissions. Those MPOs that did estimate emissions
    reported that their estimates sometimes influenced

    transportation plans and TIPs, for example, by adding more public transit.
    In a few instances, MPOs reported that the estimates also influenced land
    use plans. In other cases, the estimates did not have such an influence,
    perhaps because MPOs are not required to share the emissions results
    generated by the transportation plans and TIPs with local land use
    decisionmakers. In the future, more MPOs and state air quality managers may
    find it useful to analyze the impacts of different land uses on air quality.
    The number of counties with air quality violations may increase if EPA
    implements morestringent

    air quality standards as planned. MPOs and air quality managers face several
    barriers to conducting this analysis, however, such as the lack of a
    collaborative relationship with land use decisionmakers and the necessary
    technical capabilities.

    Most MPOs and State Most MPOs and state air quality managers have not
    considered the impact

    Air Quality Managers of different land use strategies on their efforts to
    improve air quality. Approximately 75 percent of the 295 MPOs responding to
    our survey

    Do Not Assess Whether reported that they had not estimated the impacts on
    emissions from the

    Different Land Uses mix of transportation projects generated from different
    land use strategies when developing their plans and TIPs. 1 Similarly, 36
    (approximately Would Result in Less

    76 percent) of the 47 state air quality managers responding to our survey
    Emissions reported that they have not yet assessed the effects of different
    land use strategies on air quality.

    They are not assessing land use strategies partly because neither MPOs nor
    state air quality managers are required to conduct these assessments when
    selecting the mix of projects for the transportation plan or TIP, or when
    developing air quality improvement plans. In addition, most MPOs and state
    air quality managers reported that since land use decisions fall under the
    jurisdiction of local governments, they believe they have limited ability to
    influence them. Furthermore, state air quality managers felt they do not

    have a collaborative working relationship with local land use
    decisionmakers, which would enable them to participate in such assessments.
    Because they did not estimate emissions, they therefore may have missed
    opportunities to determine whether another transportation mix or land use
    strategy would generate less vehicle emissions and be more protective of air
    quality. MPOs Consider Future

    As part of the transportation- planning process, MPOs must, among other Land
    Use as They

    things, forecast travel demand and determine the mix of projects to meet the
    demand. The forecasting process is illustrated in figure 6. Forecast Travel
    Needs

    1 We surveyed all 341 MPOs in existence as of January 2001.

    Figure 6: The Basic Travel- Demand- Forecasting Process

    Source: Adapted by GAO.

    As the figure shows, the travel- demand- forecasting process typically
    relies on three types of inputs- future land use data, travel survey data,
    and information about the transportation network. 2 MPOs first obtain data
    from local land use planners that predict where localities expect their
    future growth to occur. Most land use planners develop these predictions

    by relying on the judgment of local government officials and planners,
    although some use a modeling process. According to 89 percent of the MPOs
    responding to our survey, these land use forecasts are beginning to reflect
    strategies considered more protective of air quality, such as

    redeveloping brownfield or infill sites instead of developing open space. 3
    Using the model to forecast travel demand, MPOs determine the mix of
    projects they will propose in the transportation plan and TIP. MPOs are
    required to collaborate on the final plans and projects with local
    stakeholders, including land use decisionmakers and transportation
    officials. They are also required to ensure that funding is available for
    all the projects included in the plans.

    MPOs currently in areas with air quality problems- in nonattainment or
    maintenance status for either ozone, carbon monoxide, particulate matter, or
    nitrogen dioxide- must also add another step in their planning process and
    make a conformity determination. To do this, they must enter the estimates
    on the number of vehicle miles traveled that the plans will generate, as
    well as the speed of this travel, into another model- the emissions factor
    model. 4 This model estimates the expected emissions

    from the proposed transportation plan and TIP. Other data entered into the
    emissions factor model that can influence the projected emissions include
    average temperature, the composition of vehicles registered in an area (such
    as the percentage of SUVs, trucks, and cars), and the type of fuel used in
    the area. MPOs then compare the estimated emissions with their

    mobile source emissions budget to determine if the expected emissions are
    within the budget limits. If the estimated emissions do not conform to the
    budget, and the state air quality managers cannot increase the budget, the

    MPOs must take some action to control emissions, such as revising the mix 2
    Only MPOs in areas of either serious, severe, or extreme nonattainment for
    ozone, or serious nonattainment for carbon monoxide, and that have an
    urbanized population greater than 200,000 are required to use a travel
    demand model for their conformity analysis. Other MPOs must also use the
    travel demand model for conformity if they already use it to forecast travel
    demand. According to DOT officials in the Office of Metropolitan Planning
    and Programs, most MPOs use models to forecast travel demand. 3 Brownfields
    are underutilized or abandoned lands that may have been contaminated during
    previous use. Infill is development that fills in vacant or underused land
    in cities and other already developed areas. 4 MPOs must include forecasts
    of vehicle speed because the amount of emissions and pollutants varies
    according to the speed of travel. In general, emissions are greater at very
    low and very high speeds.

    of projects they have included in their transportation plans and TIPs. MPOs
    are not required to share the emissions results generated by the
    transportation plans and TIPs with local land use decisionmakers to see if
    pursuing alternate development scenarios might be a way to control
    emissions.

    MPOs in Areas With Air MPOs in areas with current or previous air quality
    problems, and that Quality Problems Are

    therefore must demonstrate conformity, are far more likely than MPOs in
    areas without such problems to estimate emissions from different land use
    More Likely to

    strategies when developing transportation plans. 5 About 62 of the 134
    Estimate Emissions MPOs (46 percent) in areas with air quality problems that
    responded to our

    From Different Land survey reported assessing the emissions impacts from the
    mix of transportation projects generated from different land use strategies
    when

    Uses developing their plan and TIP. In contrast, about 13 of the 155 MPOs

    (8 percent) in areas without air quality problems reported assessing
    emissions. Figures 7 and 8 show the differences in assessment efforts
    between areas with air quality problems and those without these problems. 5
    The classification of areas as being either with or without air quality
    problems was defined by response to survey question 7, which asks whether
    any portion of the geographic area covered by the MPO is in nonattainment,
    maintenance, or attainment for each criteria pollutant listed. Those
    responding ?attainment? to all six pollutants were classified as being

    in an ?area without air quality problems.? Those responding ?nonattainment?
    or ?maintenance? for at least one of the pollutants were classified as being
    in an ?area with air quality problems.? Because conformity is only required
    of those areas in nonattainment for ozone, carbon monoxide, particulate
    matter, and nitrogen dioxide, we confirmed that those

    classified as being in an area with an air quality problem were in
    nonattainment or maintenance for at least one of these four pollutants.

    Figure 7: MPOs in Areas With Air Quality Problems That Have Modeled
    Emissions From Different Land Uses

    Note: MPO boundaries are based on information supplied to us in the survey
    and may not reflect exact MPO borders, especially in the case of counties
    that are part of more than one MPO. If at least one county in an MPO is
    classified as being in nonattainment or maintenance for any of the criteria
    pollutants, then that MPO is considered to be in an area with an air quality
    problem for the purpose of our analysis, and the entire area covered by the
    MPO is shaded on the map. The results from Alaska

    are not included on the map for display purposes. Source: GAO?s analysis of
    survey data.

    Figure 8: MPOs in Areas Without Air Quality Problems That Have Not Modeled
    Emissions From Different Land Uses

    Note: MPO boundaries are based on information supplied to us in the survey
    and may not reflect exact MPO borders, especially in the case of counties
    that are part of more than one MPO. If at least one county in an MPO is
    classified as being in nonattainment or maintenance for any of the criteria
    pollutants, then that MPO is considered to be in an area with an air quality
    problem for the purpose of our analysis, and the entire area covered by the
    MPO is shaded on the map. The results from Alaska

    are not included on the map for display purposes. Source: GAO?s analysis of
    survey data.

    As these data suggest, although not specifically designed to do so, the
    federal requirement to demonstrate conformity appears to serve as an
    incentive for MPOs in areas with air quality problems to consider land use
    as a means to improve air quality. Atlanta is a case in point. Atlanta?s
    problems in demonstrating conformity led to new efforts to consider
    different land uses as a means to limit emissions. Atlanta?s mobile source
    emissions did not conform to its budget from January 1998 until July 2000.
    As a result, DOT, in consultation with EPA, placed a moratorium on most
    federal funding for local transportation projects during this time. In

    response to this moratorium, as well as public concerns about congestion and
    air quality and their impact on the city?s economy, the governor took a
    number of actions, including the creation of the Georgia Regional
    Transportation Authority (GRTA). This authority has responsibility for the
    approval of both land use and transportation plans in the jurisdictions with
    air quality problems. These plans are initially developed by Atlanta?s MPO-
    Atlanta Regional Commission (ARC). In June 2000, GRTA and ARC

    adopted the Joint Land Use Strategy. Under this strategy, all local
    governments in the Atlanta metropolitan region are required to develop
    transportation- efficient land use and development plans, subject to the

    authority?s approval, in an effort to limit emissions. Because the joint
    strategy is relatively new, it is too early to determine its success.

    The conformity process can also provide an incentive for MPOs to consider
    land use as a means to control emissions because the required time frame to
    demonstrate conformity is similar to the time frame needed to realize air
    quality benefits from land use strategies. Conformity needs to be
    demonstrated over the life of the transportation plan and TIP- at least 20
    years. Similarly, it takes a long period to plan for and implement land use
    strategies and to achieve their emissions benefits, as well as to plan and
    develop major transportation projects. Therefore, using different land use
    strategies that can limit emissions may help MPOs meet conformity
    requirements in the later years. On the other hand, about half of the MPOs
    and state air quality managers were also concerned about the lengthy time

    frame over which conformity should be demonstrated. For example, several
    MPOs we spoke with said that they believe that estimating emissions so far
    into the future is too uncertain and difficult.

    MPOs and State Air MPOs that reported estimating emissions from different
    land use strategies Quality Managers

    reported that these estimates had some influence on the mix of
    transportation projects and, to a lesser extent, land use plans. Similarly,
    Reported That some of the air quality managers who reported assessing the
    effects of Assessments of different land use strategies on air quality in
    their state also reported that

    Different Land Uses these assessments had some effect on land use,
    transportation, or air quality plans in areas of their state.

    Had Some Influence on Transportation and Land Use Plans

    MPOs Reported That Of those 75 MPOs (about 25 percent) who reported
    estimating the level of Estimating Emissions

    emissions resulting from different land use strategies, 34 reported that the
    Influenced Transportation estimates had some influence on the mix of
    transportation projects they and Land Use Plans

    chose for their plans. For example, some MPOs added alternative projects,
    such as public transit, that produce lower emissions than the projects that
    promote the increased use of automobiles. Those 40 MPOs that did not change
    their plans frequently reported the following reasons for not doing so: 6
    Because much of the transportation system is in place in their jurisdiction
    and DOT has already approved many future projects for

    construction, they have little ability to add or change projects to improve
    air quality.  Even if they could add or change projects, they did not
    believe that the

    emissions reductions from such changes would be significant. In addition to
    influencing transportation plans, emissions estimates from the assessments
    of different land use strategies had caused local land use plans or zoning
    to change, according to 23 of the 75 MPOs. Fifteen of these

    MPOs had also responded that the emissions estimates had some influence on
    both transportation and land use plans. For example:

     In response to air quality concerns in Rogue Valley, Oregon, the MPO is
    trying to implement transportation strategies that reduce reliance on
    automobiles and consequently reduce vehicle miles traveled and vehicle
    emissions. The MPO is working closely with local land use planners to ensure
    that different land use strategies, such as development in

    proximity to transit systems and mixed- use development, are included in the
    local comprehensive land use plan. According to requirements from Oregon?s
    Department of Environmental Protection, in order for the MPO to use such
    projects as a means to demonstrate conformity, the

    projects must be included in the local plan. This effort is designed to
    ensure local commitment to these land use strategies and to provide a
    foundation for any needed changes to local zoning or other planning
    ordinances. As a result, the MPO is developing a transportation plan that is
    compatible with the local comprehensive land use plan and that has air
    quality benefits to help achieve mobile emissions budgets. 6 One MPO did not
    respond to the question of whether emissions estimates influenced
    transportation plans.

     In Spokane, Washington- an area with serious carbon monoxide problems-
    state law requires the MPO to assess the transportation and air quality
    implications of different land uses under consideration. The MPO can help
    ensure that more protective land uses will be compatible with the planned
    transportation projects. For example, the city is planning to build a light-
    rail project, and the MPO has taken

    responsibility for developing four mixed- use sites that would be located
    along the transit line. Some State Air Quality

    The air quality managers in the following 10 states reported assessing or
    Managers Reported That

    participating in the assessment of the effects of different land use
    strategies Assessments of Different on air quality in areas of their
    respective states: Colorado, Georgia, Illinois, Maryland, Minnesota,
    Montana, New Jersey, Oregon, Pennsylvania, and Land Use Strategies Texas. 7
    These managers conducted their assessments primarily in

    Influenced Plans conjunction with MPOs, regional and local land use
    planners, and external stakeholders, such as community groups. The
    involvement of regional

    organizations is beneficial because air quality issues often require
    solutions that cross local jurisdictions. For example, regional planning
    entities, such as the Wilmington Area Planning Council, have been able to
    integrate land use planning with efforts to attain air quality standards
    because of their relationships with both state and local governments. The 10
    state air

    quality managers reported that they assessed a variety of land use
    strategies that are more protective of air quality, including infill
    development, bicycle and pedestrian facilities, open space preservation

    activities, and downtown redevelopment. Air quality managers in four states-
    Colorado, Illinois, Minnesota, and Oregon- reported that the assessments had
    some effect on one or more of the following types of plans:

     Land use and zoning. In the four states, localities included, or
    designated by zoning, different land uses that were more protective of air
    quality. Land use plans did not change as a result of the assessments in
    some of the remaining states partly because other factors, such as the 7
    Although Washington, D. C., initially indicated that it participated in
    assessing the effects of different land use strategies, it subsequently
    reported that it is not assessing any of the

    strategies listed. Therefore, we did not include them in the group of states
    considered to be assessing the emissions impacts of land use.

    need to promote economic development, had greater influence on land use
    plans.  Transportation. In Colorado, Illinois, and Oregon, managers
    reported

    adding more public transit, carpool or high- occupancy vehicle lanes, or
    bicycle and pedestrian facilities to their transportation plans.
    Transportation plans did not change in some of the remaining states. For
    example, one manager believed that changing the mix of transportation
    projects did not significantly reduce emissions. Another believed that
    improvements in fuel and vehicle emissions technology

    would achieve the needed reductions in emissions.  Air quality. Colorado
    and Oregon changed their air quality plans. For example, Colorado added more
    transportation control measures to the

    State Implementation Plan (SIP). 8 It also altered the SIP emissions budget
    by increasing the mobile source emissions budget and decreasing the budgets
    for other sources.

    Expected Growth and Many of the MPOs responding to our survey are in areas
    that include

    Stricter Air Quality counties anticipating rapid growth in the future,
    making it even more

    important that the MPOs and state air quality managers consider how this
    Standards May

    growth may affect their efforts to improve or protect air quality. 9 Those
    Increase the Need to

    MPOs in areas without air quality problems that anticipate rapid growth in
    Consider the Impact of the future might benefit the most from conducting
    emissions assessments and considering land use because their areas still
    have the opportunity to

    Land Use on Efforts to shape growth in ways that will also protect against
    future air quality

    Control Emissions degradation. However, because so few of them conduct
    assessments and

    are not required to do so, they may not realize these benefits. Figures 9
    and 8 Transportation control measures are policies, programs, and actions
    directed toward increasing the efficiency of transportation facilities and
    toward decreasing the use of single- occupant vehicles, including carpool
    programs, high- occupancy- vehicle lanes, and park- and- ride lots. 9 We
    obtained data on expected growth from our survey of 768 of the 3,141
    counties nationwide. For this survey, we obtained a list of metropolitan
    areas, as of 1999, from the

    Office of Management and Budget. From this list, we determined that 848
    counties are located in metropolitan areas. Because many counties located in
    the New England area have no county government or perform very limited
    functions, they were removed from the list of counties surveyed, reducing
    the list of counties in metropolitan areas to 768. The counties included on
    the maps represent those responding that they expect their community?s
    population to increase greatly over the next 10 years. We included a summary
    of the survey results in our report, Community Development: Local Growth
    Issues- Federal Opportunities and Challenges (GAO/ RCED- 00- 178, Sept. 6,
    2000), in appendix IV.

    10 show the MPOs in areas with and without air quality problems,
    respectively, which expect significant future growth.

    Figure 9: MPOs in Areas With Air Quality Problems That Expect Significant
    Future Growth

    Note: The MPO boundaries are based on information supplied to us in the
    survey and may not reflect exact MPO borders, especially in the case of
    counties that are part of more than one MPO. If at least one county in an
    MPO is classified as being in nonattainment or maintenance for any of the
    criteria pollutants, then that MPO is considered to be in an area with an
    air quality problem for the purpose of our analysis and the entire area
    covered by the MPO is shaded on the map. The results from Alaska are not
    included on the map for display purposes. Source: GAO?s analysis of survey
    data.

    Figure 10: MPOs in Areas Without Air Quality Problems That Expect
    Significant Future Growth

    Note: The MPO boundaries are based on information supplied to us in the
    survey and may not reflect exact MPO borders, especially in the case of
    counties that are part of more than one MPO. If at least one county in an
    MPO is classified as being in nonattainment or maintenance for any of the
    criteria pollutants, then that MPO is considered to be in an area with an
    air quality problem for the purpose of our analysis and the entire area
    covered by the MPO is shaded on the map. The results from Alaska are not
    included on the map for display purposes. Source: GAO?s analysis of survey
    data.

    In addition, in 1997, EPA introduced revisions to two air quality standards
    that it plans to implement that could increase the number of areas with air
    quality problems. 10 Previously, EPA had based one of these standards on

    the concentration of ozone allowed in the air over a 1- hour period that
    would still be protective of public health. EPA introduced, but because of
    litigation has not yet implemented, a new standard that will measure the
    amount of ozone allowed over an 8- hour period. Once this standard is
    implemented, EPA currently estimates that approximately 334 of the 3,141

    counties nationwide will not meet it and will be designated as nonattainment
    areas, including at least 187 counties that are either in attainment or
    maintenance status for the 1- hour standard. 11 The impact of the proposed
    standard is even greater, however, in terms of affected population. For
    example, in 1999, EPA estimated that more than

    twice as many people live in areas that are expected to violate the new
    8hour ozone standard than now live in areas that violate the current 1- hour
    standard- 123 million compared with 54 million. These figures may be
    underestimated, however. For example, not all counties have air quality
    monitors or the data to indicate whether they will violate the 8- hour
    standard. However, the state governor or EPA can still designate these
    counties as nonattainment for the standard if the governor or EPA believes
    that these counties cause or contribute to the violation of the 8- hour
    standard. For example, one county without data could be contiguous to a

    county already found to be in violation of the 8- hour standard. The
    governor or EPA could designate the county without data to be in
    nonattainment of the 8- hour standard because it could be contributing to
    the pollution problems of a neighboring county. 10 In Whitman v. American
    Trucking Ass?ns, Inc., 531 U. S. 457 (2001), the

    Supreme Court affirmed EPA?s authority to set national air quality standards
    at levels necessary to protect public health and welfare, regardless of the
    economic costs of implementing the standards. However, the Court said EPA
    must reconsider its implementation plan for moving from the 1- hour standard
    to the revised standard and instructed EPA to develop a plan consistent with
    the Court?s opinion.

    11 EPA?s estimate is based on 8- hour monitoring during 1997 through 1999;
    these data will change from year to year. Because of uncertainty regarding
    the implementation date, EPA is not expected to use these data to make final
    designations since more current data will be available in the future. The 1-
    hour ozone maintenance and nonattainment data are as of January 29, 2001.

    Local officials in 70 of the 334 counties likely to violate the 8- hour
    standard also expect to experience high population growth in the future,
    potentially influencing them to consider different land use strategies so as
    not to

    exacerbate their air quality problems. Additionally, counties currently in
    attainment for ozone standards located near metro areas in nonattainment,
    such as the counties around Dallas- Ft. Worth, also reported expecting a
    large increase in population over the next 10 years, which could threaten
    their air quality. To help ensure that their air quality does not degrade,
    these counties may also want to consider incorporating different land use
    strategies that are more protective of air quality. Figure 11 shows the

    counties currently in nonattainment for the 1- hour standard and expected to
    violate the 8- hour standard, counties currently in attainment for the 1-
    hour standard but expected to violate the 8- hour standard, and counties

    expecting high growth in the future. 12 12 EPA supplied the air quality data
    for this map. The map does not include counties designated as being in
    nonattainment for the 1- hour ozone standard, but for which there are no
    data to determine whether they will meet the 8- hour ozone standard.

    We gathered growth data from a previous survey of local growth issues in
    Community Development: Local Growth Issues- Federal Opportunities and
    Challenges (GAO/ RCED- 00- 178, Sept. 6, 2000).

    Figure 11: Counties Expecting to Violate the 8- Hour Ozone Standard and to
    Grow Significantly

    Source: GAO?s analysis of survey data and air quality data supplied by EPA.

    In addition to the 8- hour ozone standard, EPA plans to implement a new
    standard for fine particulate matter that could add 100 new counties to
    those that violate the current standards. If both the ozone and particulate
    matter standards are implemented, more MPOs and state air quality managers
    may need to turn to different land uses as a means to help them achieve or
    maintain these standards.

    MPOs and State Air MPOs and state air quality managers face a number of
    barriers that may

    Quality Managers Have limit their ability to assess the impacts of land use
    on air quality and factor this information into transportation and air
    quality improvement plans. In Several Barriers to

    addition to the barriers identified earlier, such as the lack of an
    incentive to Overcome if They Want assess the impacts of land use, MPOs and
    state air quality managers lack to Better Assess the following technical
    capabilities necessary to conduct the assessments:

    Emissions Impacts  According to survey results, MPOs lack modeling
    capability to From Different Land

    determine (1) the emissions reductions from smaller- scale changes to their
    transportation plans, such as the implementation of bicycle and Uses

    pedestrian facilities, and (2) the effect of various land use strategies,
    such as mixed- use or transit- oriented development, on transportation needs
    and emissions. For example, locating employment in close proximity to retail
    establishments and transit or pedestrian routes reduces the need for
    vehicles to accomplish errands typically completed on the way to or from
    work. Current models generally do not effectively predict how this type of
    development may affect travel behavior.  MPOs also lack widespread access
    to land use models, especially ones that are also integrated with
    transportation or environmental assessment models, according to a DOT
    modeling official. The

    development of integrated models that would help MPOs to assess the
    emissions effect of different land use strategies has lagged behind other
    model improvement efforts. Therefore, the MPOs have limited ability to
    conduct trade- off analyses that would help them identify possible different
    land uses and supporting transportation systems that would generate the
    least emissions. Additionally, because many land use models are costly to
    run- they require a large investment in effort, technical staff, and data-
    smaller MPOs with limited resources may find it difficult to use these
    models.  The difficulty of measuring and verifying the effect on emissions
    from

    different land use strategies can discourage interest in assessing the air
    quality impacts of such strategies, according to our survey results. MPOs
    subject to an emissions budget established by the SIP look for ways to
    reduce emissions and account for the amount of reductions.

    Obtaining credit for the reductions, however, requires that the land use
    strategies proposed to limit emissions can be or have actually been
    implemented and that the amount of reduction can be measured. However,
    according to survey results, state air quality managers cannot typically
    regulate or enforce land use decisions and, therefore, cannot ensure that
    proposed land use changes will be implemented and emissions reductions
    realized. Also, according to DOT managers, this

    lack of land use control will be a challenge for MPOs as they try to ensure
    that proposed changes to land use plans are reasonable and enforceable. It
    is also particularly difficult to ensure reductions because implementation
    can occur over a relatively long period of time. If the managers base
    emissions credits on proposed land use changes and these changes are not
    implemented, the managers must make up the credit through some other means,
    and at a later period, which can be difficult.

    Most States and Localities Do Not Fully Assess and Mitigate the Sources of
    Nonpoint

    Chapt er 3

    Pollution but May Need to Do So in the Future Most states and localities do
    not comprehensively assess the impacts of existing land use or future
    development on water quality and systematically factor such analysis into
    water quality protection and improvement plans, according to members of our
    expert panel and the studies we reviewed. They do not conduct these
    assessments and mitigation or protection efforts principally because
    nonpoint source pollution is difficult to identify and measure, and
    communities often lack the necessary resources and public support for land
    use solutions to water quality problems. Those relatively

    few jurisdictions that have the necessary resources and support from local
    decisionmakers and the public are more likely to comprehensively assess and
    mitigate water quality problems. In some cases, these efforts have included
    implementing land use and development strategies that protect water quality,
    such as updating zoning and other land use ordinances and

    reducing the amount of paved and other impervious surfaces in order to
    reduce polluted runoff. More states and localities may need to assess the
    impacts of land use on water quality in the future, according to our panel
    members and other water quality experts. Pressure is growing to improve
    water quality through the use of the Clean Water Act?s total maximum daily
    load provision. According to our panel, to conduct these assessments, states
    and localities will need help in reducing such barriers as the lack of data
    on the specific sources of water quality impairments and on the effects of
    land

    use on water quality. States and Localities Although EPA recognizes nonpoint
    source pollution as a serious problem Have Generally Not

    nationwide, states and localities generally have not assessed and mitigated
    this pollution. Most states and localities have not done so because (1) the
    Assessed and Mitigated specific causes are difficult to identify and
    measure; (2) federal regulatory Nonpoint Source requirements, to date, have
    not adequately driven mitigation efforts; and

    Pollution for Technical, (3) they often lack the resources and public and
    official support for assessments, mitigation, and prevention.

    Legal, and Resource Reasons

    Extent of and Contributors EPA estimates that nonpoint source pollution is
    the principal reason that to Nonpoint Source

    roughly 40 percent of the nation?s assessed waters are too polluted for
    Pollution Are Difficult to basic uses such as fishing and swimming.
    According to EPA?s latest Determine biennial National Water Quality
    Inventory, nonpoint source pollution from urban land use, including
    residential and commercial development and its associated roads, streets,
    parking lots, and other impervious surfaces, is a significant contributor to
    this impairment. 1 While agriculture, including grazing and concentrated
    animal- feeding operations, is generally regarded as the leading contributor
    of nonpoint source pollution nationwide from sediment, nutrients,
    pesticides, and certain other toxic chemical compounds, various pollutants
    resulting from urban land use and

    development can, in certain locations, equal or even exceed agriculture?s
    contributions. 2 The true extent of nonpoint sources? contribution to the
    impairment of water quality may be understated, however, because states have
    not been able to comprehensively assess the quality of all of their water
    resources. For EPA?s 1998 report to the Congress, states assessed only 23
    percent of the nation?s river and stream miles, 42 percent of its total
    acres of lakes, ponds, and reservoirs; 32 percent of its square miles of
    estuaries; and 5

    percent of its ocean shoreline miles. As we reported in March 2000 on our
    survey of 50 states and the District of Columbia, only 3 states indicated
    that they had the majority of the data needed to identify and assess
    nonpoint sources of pollution. 3 The states lack data partly because
    assessing nonpoint pollution is difficult. Runoff from nonpoint sources is
    caused by many types of activities, including urban land use and
    development, that take place over dispersed areas of land. In addition,
    nonpoint source runoff is episodic, primarily occurring as a result of
    rainfall or snowmelt,

    1 Pursuant to section 305( b) of the Clean Water Act, states, territories,
    tribes, and interstate commissions assess the health of their waters and the
    extent to which their waters support state water quality standards and the
    basic goals of the Clean Water Act. These jurisdictions submit their water
    quality reports to EPA every 2 years. EPA summarizes this information in a
    biennial report to the Congress, the National Water Quality Inventory. The
    most recent such report is the report for 1998, published in June 2000.

    2 See Selected Findings and Current Perspectives on Urban and Agricultural
    Water Quality by the National Water Quality Assessment Program, U. S.
    Geological Survey, U. S. Department of the Interior (Apr. 2001).

    3 See Water Quality: Key EPA and State Decisions Limited by Inconsistent and
    Incomplete Data (GAO/ RCED- 00- 54, Mar. 15, 2000).

    and, as a result, is more difficult to identify, measure, and control than
    point sources of pollution. Federal Requirements Have

    In part because nonpoint sources of pollution are hard to identify, assess,
    Not Adequately Driven and control, they received little federal attention
    until the 1987 States and Localities to

    amendments to the Clean Water Act. Before 1987, federal and state clean
    Mitigate Most Nonpoint

    water laws and regulations focused more on controlling point sources through
    permitting and the use of the best available technology to remove Source
    Pollution pollutants from discharges. In the 1987 amendments, the Congress
    directly addressed nonpoint source pollution through two new provisions. It
    created a new section 319 grant program and, for the first time, decided to
    regulate a portion of nonpoint pollution- pollution from municipal storm
    sewer systems and selected other nonpoint sources.

    Section 319 Grant Program To be eligible for grants under the section 319
    program, states, territories, and tribes must inventory their known and
    suspected nonpoint source pollution problems and develop management programs
    to adequately address them. These programs can take almost any regulatory or
    nonregulatory approach. However, for the most part, they rely on voluntary
    measures to control the impacts of land use on water quality. Their
    approaches focus on providing polluters with technical and financial
    resources to encourage them to adopt land use and other management practices
    that protect water quality. These practices might include

    preserving or installing forested and vegetative buffers along streams,
    preserving or restoring natural wetlands, and educating the public on the
    proper use and disposal of substances harmful to water quality (e. g.,
    fertilizers, pesticides, and other toxic chemicals).

    While states and localities have successfully used the 319 grants to pursue
    land use solutions to water quality problems and reduce nonpoint source
    pollution in specific waters, these efforts, to date, have not been
    successful in producing broader controls on, or reductions in, nonpoint
    source pollution. Significant reductions may not have occurred, in part,
    because

    the program is relatively new and has had limited funding compared with
    efforts to reduce point source pollution. The section 319 program received
    its first appropriation-$ 37 million- in fiscal year 1990. Annual funding
    for the program remained at a similar level until fiscal year 1995, when the

    Congress increased it to $100 million. In total, the Congress has provided
    about $1. 2 billion for the section 319 program through fiscal year 2001.
    However, as we have reported, this represents only a small fraction of the
    tens of billions of dollars that the public and private sectors have spent
    on controlling pollution from point sources. 4 Regulation of Storm Water In
    the 1987 amendments, the Congress decided to treat municipal stormwater

    Runoff From Point Sources discharges and erosion from construction
    activities as though they were point sources of pollution. 5 The Congress
    took this approach because

    the traditional means of managing these problems had a number of negative
    consequences. For example, communities traditionally built separate storm
    sewers to quickly collect and channel storm water and

    discharge it into water bodies to prevent local flooding. With more
    development, the quantity of storm- water runoff increased, and the storm
    water itself carried more pollutants- increasing downstream flooding,

    stream bank and bed erosion, and the destruction of aquatic habitat, and
    posing risks to public health. In the 1987 amendments, the Congress
    established a tiered approach for addressing certain industrial, municipal,

    and other storm- water discharges from point sources, those that enter the
    waters of the United States through a conveyance or system of conveyances,
    such as a storm sewer system. These amendments provided for a phased program
    to address the major contributors first (Phase I) and

    identify an appropriate second tier of sources at a later date. EPA
    published application requirements for Phase I for the categories of storm
    water recognized as the most damaging to the environment in 1990. 6
    Generally, Phase I sources include storm- water discharges associated with

    4 See Water Quality: Federal Role in Addressing- and Contributing to-
    Nonpoint Source Pollution (GAO/ RCED- 99- 45, Feb. 26, 1999). 5 CWA, sect.402(
    p).

    6 55 Fed. Reg. 47990 (Nov. 16, 1990).

    certain industrial activities; medium and large separate, municipal, storm
    sewer systems (MS4); and large construction sites (those greater than 5
    acres). In developing regulations for this new provision, EPA recognized the
    close

    connection between urban development and polluted runoff by stressing that
    municipalities will need to minimize the impacts of future growth.
    Municipalities would need to manage residential, commercial, and

    industrial activities in ways that limit storm- water discharges and are,
    therefore, less damaging to water quality. In its first regulations for
    stormwater management (Phase I rules), EPA sought to limit discharges from
    two broad categories: (1) MS4s serving populations of 100, 000 or more and
    (2) discharges associated with various industrial activities, including
    discharges from construction activities disturbing 5 acres or more of total
    land area. The core Phase I requirements include the use of permits,
    sitespecific

    plans, and best management practices to better prevent and control polluted
    storm- water runoff. For example, vehicle maintenance facilities must have
    plans, including employee training, to ensure that oil, gasoline, and
    antifreeze do not enter storm- water systems.

    In December 1999, EPA issued its second set of storm- water regulations
    (Phase II rules) for smaller MS4s and construction sites. 7 Small MS4s are
    defined in the Phase II regulation as any MS4 in an urbanized area not
    covered by the Phase I program. Two provisions of the Phase II rule are
    related to development. The rule requires permit coverage, including plans
    to prevent storm- water pollution, from construction sites 1 to 5 acres in

    size. In addition, the rule requires that small MS4s? storm- water plans
    include a program of post- construction runoff control for new development
    and redevelopment. Municipalities may decide to use these provisions as

    tools to address the link between their land use and water quality
    management efforts. While the provisions show promise, it is too early to
    tell how many municipalities will take full advantage of them.

    7 64 Fed. Reg. 68722 (Dec. 8, 1999).

    Many States and Our panel of experts identified several important reasons
    why land use Localities Lack the considerations have not played a more
    prominent role to date in efforts to

    improve water quality: the lack of needed resources and of public and
    Necessary Resources

    official support. (The panel also identified a number of technical and legal
    and Support to Assess barriers that we discuss later.) 8 Several experts
    pointed out that state and

    and Mitigate the local water quality officials primarily spend their time
    and resources on

    complying with existing federal and state requirements, such as ensuring
    Impacts of Land Use on compliance with point source permits and the new
    storm- water Water Quality

    management regulations. In addition, like transportation and air quality
    officials, state and local water quality officials do not try to assess and
    mitigate the impacts of different land use strategies because they have
    little direct authority over land use and development decisions and
    therefore

    believe they cannot influence them. Several experts also noted a number of
    difficulties in trying to achieve collaboration among water quality
    officials, land use decisionmakers, and other key stakeholders in conducting
    comprehensive water quality and

    land use assessments as well as developing water quality protection and
    mitigation plans. For example, one panel member pointed out that the
    responsibility for storm- water management, flood control, water quality,
    and development is often dispersed across a number of organizations. This

    makes it difficult for professionals in these organizations to pool their
    resources and work together on comprehensive assessments. Other members
    commented that such assessments are technically challenging, that they are
    resource- intensive, and that jurisdictions do not have or do not cooperate
    to share the staff resources and expertise needed to collect

    the necessary data, run models, and analyze the results. Some local land use
    decisionmakers also do not support the assessment of land use impacts on
    water quality because they do not understand the relationship between their
    decisions and water quality impacts; they, therefore, give little attention
    to this issue, according to several panel members. This is especially the
    case if there is no observable evidence of serious water quality degradation
    in their areas and the public has not expressed concerns. Without such
    evidence or public pressure, local

    officials may be unwilling to institute land use controls for fear of legal
    8 See appendix V for a detailed listing of each of the impediments to
    further considering and mitigating land use impacts that the panel as a
    whole identified and the mean group rating for each impediment in terms of
    how important and how difficult it is to resolve. The impediments discussed
    here are identified as numbers 21, 30, and 35 in that listing.

    challenges asserting that these officials have interfered with private
    property rights. Some of these decisionmakers also feel pressure to bring
    jobs and economic development into their communities, which they consider a
    higher priority than improving water quality.

    Lacking resources and support, many localities are limited in the approaches
    they take to protect water quality. Panel members identified several of
    these limitations. For example, when localities have considered the impacts
    of land use on water quality, they typically have focused more on mitigating
    the impacts of an individual development or project, rather than on
    comprehensively assessing the impacts of land use and development. Moreover,
    these localities tend to rely on the developers? engineers or consultants to
    identify potential impacts rather than to conduct independent assessments.
    In addition, localities typically include in their subdivision and
    development regulations best management practices aimed at controlling
    erosion and sediment at construction sites primarily because these practices
    are generally accepted- not because

    their effectiveness has been verified. According to members of our expert
    panel, adopting these conventional ?best management practices,? often
    despite a lack of data on their effectiveness, is generally easier than
    adopting politically sensitive but more- effective restrictions on land use
    and development. For example, it is easier to mandate the use of erosion
    control techniques, such as straw bales and silt fences on construction
    sites, than it is to require limits on paved surfaces or street widths, or
    land conservation measures to protect environmentally sensitive areas from

    development. Some States and

    Some states and localities have had the financial and technical resources
    Localities Have the

    and the support from the public and local officials needed to assess the
    impacts of nonpoint sources on water quality and implement a variety of
    Resources and Support measures to mitigate any adverse effects. These states
    and localities have

    to Comprehensively identified federal, state, local, and private funding
    sources to support their Assess Water Quality

    efforts. Often, they have undertaken these initiatives to protect critical
    natural and economic resources threatened by pollution from encroaching and
    Address Adverse development, such as drinking water sources, fisheries and
    shellfish beds, Impacts of Land Use

    and lakes, rivers, and beaches used for recreational purposes. Our expert
    panel identified a range of land management and development strategies that
    states and localities have employed. The experts ranked two broad areas of
    land use practices, in particular, as more effective in protecting water
    quality from the negative impacts of land use and

    development and, at the same time, relatively easier to implement than other
    practices.  Land protection practices- such as the purchase of
    environmentally sensitive land and the use of conservation easements to
    protect land

    from development; transfer of developments rights; and rural and natural
    resource zoning to preserve and protect prime farmland and other valuable
    resources, such as drinking water sources, from development.  Research,
    demonstrations, and innovative programs- such as

    research on the effectiveness of best management practices and other
    pollution mitigation techniques; demonstrations of the effectiveness of
    nonconventional site development techniques that emphasize the

    preservation of natural patterns of water flow and infiltration; and
    innovative development strategies, such as low- impact and zero- impact
    development that incorporate on- site storm- water management measures that
    limit polluted runoff.

    The experts also identified several relatively effective practices that they
    rated as somewhat more difficult to implement.

     Management strategies- such as adaptive management that involves
    implementing best management practices, continually evaluating their
    performance, and modifying them, as appropriate, to achieve the desired
    improvements in water quality; protecting and restoring stream banks and
    stream beds eroded by increased flows resulting from stormwater discharges;
    and limiting development in areas prone to flooding to minimize property
    losses and risks to public safety.  Site- level design techniques- such as
    using alternative driveway and

    parking lot designs that reduce the amount of paved surfaces; paving
    materials that allow rainwater to infiltrate; and designs that cluster
    buildings to preserve more open space for common areas, recreation, and the
    on- site management of storm water.  Smart growth principles and
    strategies- such as mixed- use and urban

    infill development; brownfields restoration and reuse; and comprehensive
    watershed assessment and planning to identify environmentally important
    areas that should be protected, as well as areas where future development
    should be concentrated.

    The experts judged some of the most popular and prevalent practices in use
    today as somewhat less effective in protecting water quality than those

    previously discussed, often because they are not tailored to the specific
    needs of an area or properly maintained.  Federally imposed regulations-
    such as the requirement to conduct environmental impact assessments of
    individual transportation or

    development projects that use federal funds, as well as more traditional
    federal regulatory and enforcement approaches to water quality protection.
    Nonstructural best management practices- such as maintaining storm sewer
    drains and other storm- water infrastructure, street sweeping, the

    posting of antidumping warnings on storm drains, and public education
    campaigns to promote environmentally sound use of pesticides and fertilizers
    on residential lawns and in gardens.  Structural best management practices-
    such as erosion and sediment

    control techniques at construction sites; the minimal treatment of storm
    water (e. g., skimming out oil and filtering out sediment and trash); and
    other storm water management structures, such as retention ponds and
    infiltration trenches.

    The following case studies illustrate how communities have successfully
    implemented some of the more innovative and effective strategies:
    Maryland?s efforts to protect the Chesapeake Bay. To help protect this
    critical natural resource from increasing pollution, including that

    resulting from rapid urban development in the bay?s multistate watershed,
    Maryland made a commitment to reduce the rate of growth of urban sprawl in
    the state by 30 percent by 2012. 9 To accomplish this goal, Maryland adopted
    several innovative strategies that have made it a

    recognized leader in smart growth. For example, it provides state funds for
    infrastructure, housing, and economic development only in already developed
    areas and those areas that local jurisdictions have designated

    as future growth zones. The state also has a number of programs to clean up
    and redevelop brownfields and to preserve farms, forests, wildlife habitats,
    and environmentally sensitive areas, partly to limit polluted runoff into
    the bay. Most recently, the state authorized its Department of Planning to
    challenge local land use decisions that the department determines would
    undermine the state?s growth

    management objectives. 9 The other states in the watershed, notably
    Pennsylvania and Virginia, also committed to this goal.

     New York source water protection. New York City, along with a number of
    upstate counties, local municipalities, and environmental groups, formed a
    watershed partnership to protect the water quality of several reservoirs
    that provide drinking water for about 9 million people. The

    reservoirs were threatened by agricultural land use and runoff from urban
    development. Among the innovative practices implemented were (1) a land
    acquisition program through which the city purchased properties or
    conservation easements on environmentally sensitive and undeveloped land to
    prevent development and polluted runoff; (2) a regulatory program to ensure
    that new construction followed certain practices that protect the watershed;
    and (3) a partnership in which the

    city, among other things, pays for upgrades to municipal wastewater
    treatment systems to reduce pollution from this source.  Jordan Cove
    watershed study. Waterford, Connecticut, with the support of the University
    of Connecticut and the Connecticut Department of Environmental Protection,
    and partial funding from a Clean Water Act section 319 program grant, has
    constructed two contrasting sections of a subdivision and is monitoring
    their water quality impacts over time.

    One section uses a traditional neighborhood design that includes a halfacre
    residential zoning pattern with curbs, storm drains, storm sewers, and
    asphalt streets that are 24 feet wide. The other, more- innovative section,
    among other things, clusters the housing on smaller lots and uses grassy
    drainage areas and rain gardens to detain storm water on site. 10 It also
    incorporates narrower driveways and streets made of porous materials that
    allow for the infiltration of rainwater and snow melt, and uses the latest
    storm- water treatment innovations. Researchers will monitor and sample
    water in the drainage area over time to measure the impacts on runoff
    quantity and quality from each

    section to determine if the innovative ?green development? techniques are
    more protective of water quality. Figures 12 and 13 illustrate these two
    subdivision designs.

    10 Rain gardens are vegetated landscaping features, also known as
    ?bioretention areas,? to which rooftop runoff is diverted instead of being
    connected to a conventional drainage system. When properly designed, they do
    not require supplemental water.

    Figure 12: Traditional Neighborhood Design

    Source: Jordan Cove Urban Watershed Project at the University of
    Connecticut.

    Figure 13: Innovative Neighborhood Design

    Source: Jordan Cove Urban Watershed Project at the University of
    Connecticut.

     Spragues Cove storm water cleanup. The community of Marion, Massachusetts
    obtained funding from several sources, including a

    program grant under section 319 of the Clean Water Act, and technical
    assistance from an interdisciplinary team of experts to help it build an
    artificial wetlands system. The system is intended to manage polluted runoff
    that contributed to the closure of shellfish beds and threatened nearby
    beaches. The wetlands, which were designed to store 1 inch of storm- water
    runoff with an average detention time of 14 days,

    dramatically reduced the amount of fecal coliform bacteria in the cove. This
    is expected to lead to a reopening of the shellfish beds for harvesting and
    provide long- term protection for the economic and recreational value of
    nearby beaches. Figures 14 and 15 illustrate the area before and after the
    wetlands project, respectively.

    Figure 14: Spragues Cove Before the Wetlands Project

    Source: EPA.

    Figure 15: Spragues Cove After the Wetlands Project

    Source: EPA.

    States and Localities In response to citizens? concerns about persistent
    water pollution

    May Need to Give More problems, EPA and the states are paying increasing
    attention to a provision

    of the Clean Water Act that has not been emphasized in the past three
    Consideration to Land

    decades. During this period, EPA and the states have focused on Use Impacts
    Because

    controlling point source pollution. The greater emphasis on the role of of
    Renewed Emphasis nonpoint sources in the impairment of water quality could
    increase the

    need to improve land use practices to protect and improve water quality. on
    Improving Water The emphasis has led to a renewed interest in using the
    provision of the

    Quality and Revised Clean Water Act, which requires states to identify and
    assess impaired

    waters, establish a priority ranking for them, and determine the total
    Regulations Governing maximum daily load of contaminants that the water
    bodies can sustain.

    It Under EPA?s TMDL regulations, 11 states are to identify any water bodies
    in which pollutant levels continue to exceed states? water quality
    standards,

    even after cities, towns, and factories have complied with technologybased
    standards and used the best available control technologies to limit
    discharges of pollutants from point sources. States are to set priorities
    for cleaning up these impaired waters and establish TMDLs for them. States
    can then implement the TMDLs and require permitted point sources,

    municipalities, individual landowners, and others to take actions to address
    chronic water quality impairments. 12 These actions can include tightening
    control requirements for point sources and establishing management measures
    for nonpoint sources, including runoff from urban areas, construction sites,
    and agricultural lands.

    Beginning in the late 1980s and intensifying in the 1990s, citizens groups
    filed lawsuits against EPA and states, claiming that they had failed to
    comply with the act?s requirement to protect and improve water quality by
    identifying and setting priorities for cleaning up impaired water bodies and
    for implementing TMDLs. As a result of these lawsuits and nearly 20 11 The
    TMDL provision is contained in section 303( d) of the act. A TMDL represents
    an upper level, or ceiling, on specific pollutant loads that can enter a
    water body (or an entire watershed) so that the water body will meet and
    continue to meet the states? water quality standard. TMDLs can also be used
    to allocate

    pollutant loads and necessary reductions in pollutant loadings, among
    contributing pollutant sources in a watershed. 12 A state can implement a
    TMDL to control nonpoint sources only if the state has enforceable legal
    authority upon which it can rely. States lacking such authority can enact
    laws providing for enforceable mechanisms to implement TMDLs.

    Where feasible and effective, states can also employ a variety of voluntary,
    incentive- based programs to control nonpoint source pollutants.

    consent decrees or court orders, some states have had to accelerate the
    development of their inventories of impaired waters and other states have
    had to greatly increase the number of impaired water bodies in their
    inventories that are candidates for TMDLs.

    Concerned that court orders rather than a coherent national policy would
    increasingly drive the implementation of the TMDL program, EPA launched
    several TMDL- related initiatives. For example, in 1996, it convened a 20-
    member federal advisory committee that evaluated, and made recommendations
    for improving, the implementation of the TMDL requirements. In response to
    the panel?s recommendations, EPA revised its regulations governing TMDLs,
    acknowledging that the revision was

    necessary because the provision?s implementation to date had not achieved
    sufficient water quality improvements. In its revised regulations, EPA laid
    out an overall timetable for developing TMDLs and required states to devise
    their own expeditious time tables for establishing their TMDLs and action
    plans for implementing them. EPA issued the final regulations in July 2000.
    13 However, the revised TMDL rule met with considerable controversy and

    resistance. States, affected businesses, and others protested the rule
    because of its technical challenges and costs. States may have to develop
    thousands of TMDLs to cover the more than 20,000 impaired water bodies and
    lack data on nonpoint sources and cost- effective ways to control them.
    Moreover, the process of devising TMDLs can be expensive because they can
    require the use of complex models, often costly to develop, to analyze

    the dynamics of a pollutant. EPA recently estimated that implementing the
    control actions that may be included in the TMDLs will cost between $900
    million and $3.2 billion if the most cost- effective approaches are relied
    upon to achieve necessary reductions. 14 Because of these factors, the
    Congress delayed implementing the rules, and subsequently, in July 2001,

    13 65 Fed. Reg. 43585 (July 13, 2000). 14 Cost- effective reductions could
    include the trading of pollution allowances between point and nonpoint
    sources. However, EPA also noted that if states determine that all pollution
    sources should adopt sweeping controls, TMDL implementation costs could
    reach as high as $4. 3 billion.

    EPA itself proposed to delay implementation for at least 18 months in order
    to further review the rules and consult with affected parties. 15

    Despite the uncertain future of EPA?s revised TMDL rules, states and
    localities, along with business and industry, will increasingly need to
    respond to pressure from citizens for water quality protection and
    improvement and focus on controlling nonpoint source pollution, especially
    when, as is often the case, this source provides the greatest remaining
    potential for reducing pollution. Because urban runoff is an important
    component of nonpoint source pollution, states and localities are likely to
    find it increasingly necessary to improve land use practices to reduce
    polluted runoff and protect and improve water quality.

    According to a recent study by the Environmental Law Institute, the primary
    federal and state responses to nonpoint source pollution- providing
    financial and technical assistance to encourage voluntary action- have not
    succeeded in preventing the pollution of the nation?s rivers, streams, and
    other water bodies. 16 Paying landowners not to pollute, providing free
    technical advice, and relying on voluntary adherence to best management
    practices have proven, in many cases, to be an

    incomplete strategy. Gradually, states are turning to enforceable
    mechanisms, including discharge prohibitions, the direct enforcement of
    water quality standards, pollution abatement orders, required operating
    practices, nuisance and misdemeanor prosecutions, and civil and

    administrative penalties, to supplement and complement other approaches for
    controlling nonpoint sources. The need for such action has been demonstrated
    by highly visible fish kills, endangered species listings, unacceptable
    fecal coliform levels in drinking water supplies, nutrient pollution of
    major estuaries and lakes, and pollution effects on beaches and waterfronts.
    Concerns from point source dischargers that other polluters share some
    pollution prevention obligations are also beginning to have some effect. As
    states develop TMDLs to clean up their impaired waters

    identified under section 303( d) of the Clean Water Act, the Institute?s
    study notes, many will need to use enforceable mechanisms to achieve more

    15 On October 12, 2001, the U. S. Court of Appeals for the District of
    Columbia Circuit granted EPA?s motion to hold the TMDL lawsuit in abeyance
    for 18 months while the agency reviews the rule and considers possible
    revisions. On the same date, the EPA Administrator signed a rulemaking that
    suspends the effective date of the TMDL rule until April 30, 2003.

    16 See Putting the Pieces Together: State Nonpoint Source Enforceable
    Mechanisms in Context, Environmental Law Institute (2000).

    effective control over the nonpoint source pollution discharges that
    comprise a significant source of the impairments. States and Localities In
    addition to the lack of funding and support from the public and local Face
    Additional

    officials, our experts identified a number of other barriers that they
    believe impede efforts to better assess, mitigate, and prevent the adverse
    impacts Barriers to Better

    of land use on water quality. Rated among the most important and easiest
    Assessing and of these barriers to overcome are the following: Mitigating
    the Impacts

     Lack of data. The lack of sound, scientific data collected over time of
    Land Use and impedes states? and localities? ability to determine the
    quality of their Development on Water water bodies, the major pollutants and
    their sources, and the most effective ways to reduce them. The lack of such
    data also impedes the Quality

    ability to effectively characterize the water quality impacts of prevailing
    and projected land uses and the ability to educate the public and local
    decisionmakers about these impacts. Several experts pointed out that it is
    therefore difficult to design, target, and market land use management
    practices and smart growth development strategies to improve and

    protect water quality. The panelists thought that the solution to this
    barrier was relatively clear- have the federal and state governments
    recognize the critical need for better data and provide more funds and
    technical support to collect it. Individual panelists pointed out, however,
    that because of competing needs, water quality monitoring, research, and
    data collection efforts are often not funded or are among the first
    activities to be cut, especially if the benefits are perceived to be in the
    future. Nevertheless, the renewed emphasis on using TMDLs to improve water
    quality most likely will result in the need to collect more

    of these data.  Lack of information on cumulative land use impacts.
    Similarly, the lack of information on (and in some cases, the understanding
    of) the

    cumulative impacts of land use and development on water quality makes it
    difficult for state and local officials to implement protective land use and
    development strategies. As we have noted, urban development can have a
    number of adverse impacts on, for example, the surrounding ecology and
    aquatic habitats, and on the temperature, flow,

    and geological stability of waterways. Communities lack information on the
    cumulative effect of these diverse impacts for a number of reasons.
    Conducting a cumulative assessment can be difficult and costly,

    especially since needed data and easy- to- use assessment tools are not
    readily available. In addition, most water quality monitoring to date has
    focused on only one indicator of impairment, the levels of specific

    chemicals in water bodies, and not on other, equally important indicators,
    such as the presence and health of certain fish and other aquatic organisms
    in the water bodies. Greater recognition of the importance of gathering and
    understanding all data relevant to the cumulative impacts of land use and
    greater cooperation among local jurisdictions in a watershed would begin to
    address this barrier, the experts agreed.  Legal barriers. Many local
    development codes, zoning laws, and

    building ordinances, as well as much state- planning legislation, are
    outdated, are not based on a consideration of the need for environmental
    protection, and do not allow for more innovative land use

    practices that protect water quality. Many of these legal provisions date
    from the 1920s, when the environmental impacts of land use were not well
    understood or of particular concern, and when the preference was to
    segregate single- family homes from other types of residences, such as
    apartments, and from commercial and retail activities. These laws often

    pay little or no attention to the importance of preserving trees, native
    vegetation, and existing topography or to avoiding excessive clearing,
    grading, and paving, which can alter the natural flow of water and encourage
    erosion.

    As a result, roadways and parking lots are often over- designed, creating
    far more impervious surface than is necessary and magnifying the problem of
    damaging runoff from these surfaces. Minimum lot- size requirements,
    building- setback requirements, and on- street parking requirements in these
    laws limit the ability to preserve open space and take advantage of site
    features that could retain storm water, remove pollutants, and allow for the
    infiltration of storm water into the soil to recharge underground aquifers.

    Barriers rated as important by our experts but relatively more difficult to
    overcome include the following:  Lack of technical tools. Water quality
    officials and communities lack

    access to user- friendly models, comprehensive land use data, and
    waterquality- monitoring equipment and methods. These would aid in
    accurately diagnosing water quality problems, including the impacts of land
    use and development. Communities would need to identify additional funding
    sources and access to technical staff to help them run

    the models, however, and collect and analyze consolidated water quality and
    land use data to develop water quality improvement plans that incorporate
    protective land use.

     Weak regional authorities. Although watersheds and the impacts of land use
    cross local jurisdictional boundaries, few regional organizations have the
    authority to take a more comprehensive approach to assessing water quality
    and influencing land use to protect it. According to several experts,
    appropriately empowered regional authorities- such as regional councils that
    include MPOs, clean air agencies, water quality planning agencies, and land
    use planners- could

    coordinate air and water quality planning efforts, enhance water quality
    data collection, promote sound land use and water quality management across
    local jurisdictions, and guide development in ways that are more protective
    of water quality. Otherwise, it is difficult for individual jurisdictions to
    share data and resources and to collaborate on watershed management and land
    use. Because jurisdictions tend to undertake planning, zoning, and
    development independently of each other, the consequences for water quality
    are less than optimal. For example, the siting of a large commercial mall in
    one area within a regional watershed versus another area, to better protect
    water quality, is difficult to achieve without some regional authority to
    support such a location decision.

    A number of experts noted, and studies that we reviewed confirmed, that a
    few jurisdictions, including the Atlanta, Portland, and Minneapolis- St.
    Paul metropolitan regions, have recognized the need for, and have created
    regional bodies with, authority over planning for land use, transportation,
    and environmental improvement on a regionwide

    basis. More widespread adoption of these types of regional bodies could help
    to promote the use of land use practices and development strategies that are
    more protective of water quality, the panelists agreed. Finally, our
    panelists ranked several barriers as relatively important but also
    relatively among the most difficult to overcome. These include (1) a focus
    on short- term water quality or land use planning and the lack of clear
    organizational responsibility for protecting water quality in state and
    local governmental agencies; (2) the fragmentation of organizations at the

    federal, state, and local levels on the basis of subject matter and
    geographic jurisdictions with often conflicting missions; and (3) federal,
    state, and local policies (e. g., on taxes and subsidies) that do not
    facilitate or encourage innovative development practices that are protective
    of water quality.

    Federal Agencies Could Take Actions to Help States and Localities Better
    Consider the

    Chapt er 4

    Environmental Impacts of Land Use The MPOs, the state air quality managers,
    and our panel of experts proposed federal actions in several key areas to
    help states and localities that want to consider the impacts of land use on
    their environmental protection efforts: (1) financial incentives to promote
    collaboration among transportation, environmental, and land use
    decisionmakers on protective land management strategies; (2) technical
    assistance, such as access to staff, data, methods, and models, to assess
    and mitigate the impacts of different land uses on air and water quality;
    and (3) the education of local governments and the public on ways to limit
    these impacts. EPA, DOT, and several other federal agencies responsible for
    air and water

    quality protection have a number of initiatives in these areas, and the
    Congress is considering several actions that address some of these
    proposals. Some of the agency efforts, however, have not been widespread.
    Respecting the limits of its existing authorities and funding, EPA has
    generally let its program and regional offices decide the extent to which
    they could undertake these initiatives. As a result, some of the agency?s
    efforts have been limited in scope and it has not coordinated them

    under an agencywide strategy. Such a strategy could help EPA leverage its
    limited resources more effectively and provide MPOs, environmental
    officials, and communities interested in limiting land use impacts with
    broader assistance. While DOT?s initiatives were designed to encourage MPOs
    and communities to consider transportation alternatives that reduce
    emissions, some were not designed to encourage the consideration of
    different land use strategies that could further limit emissions. To remove
    barriers to the further consideration of land use impacts, both agencies, as
    well as the Congress, could consider ways to improve the programs they
    already have and provide states and localities with additional incentives,

    technical support, and help with public outreach.

    MPOs, State Air The MPOs, the state air quality managers, and our panel of
    experts

    Quality Managers, and identified federal actions in several key areas that
    could help remove some

    of the barriers to assessing and limiting the adverse impacts of land use on
    Our Expert Panel

    air and water quality. (In general, we report those actions on air quality
    Identified Federal that a majority of MPOs and state air quality managers
    thought would help Actions to Help Reduce

    them to assess the emissions impacts of different land use strategies. We
    report those actions on water quality for which there was considerable the
    Barriers to Linking agreement among the experts that these actions are
    moderately or highly Land Use and important and effective, relative to all
    other actions the panel considered.):

    Environmental  Financial incentives. Federal funding could be allocated in
    ways that Protection

    help promote a more collaborative working relationship among MPOs,
    environmental officials, and land use planners on land management strategies
    that are more protective of air and water quality. To protect air quality,
    for example, more federal funding could be provided for those transportation
    projects that were developed collaboratively and that considered
    opportunities to limit adverse environmental effects. To better protect
    water quality, some funding could be targeted to (1) encourage greater state
    and local investment in water quality planning that aims to reduce or better
    manage urban runoff; (2) encourage the implementation of protective land use
    strategies, such

    as land conservation; and (3) promote collaborative water quality and land
    use plans that take a regional focus on environmental impacts and involve
    the relevant local jurisdictions within a watershed.

    The MPOs and environmental officials also suggested that federal funding
    should be consistent with state and local growth management initiatives and
    environmental needs. For example, consideration could

    be given to whether federal transportation funds are providing incentives to
    build additional roads and highways rather than to determine if transit
    systems would be more protective of air quality. Similarly, the panel of
    experts said that communities need more funding

    for water infrastructure; however, the funds should not be used on new
    infrastructure at the expense of repairing existing infrastructure that
    would allow for redevelopment in urban areas. In addition, the experts said
    that implementation of the TMDL rule, and any federal funding to support it,
    should not be undertaken at the expense or exclusion of developing more
    comprehensive watershed protection programs.  Technical assistance. Federal
    agencies could provide tools to help

    remove the technical barriers preventing greater consideration of the

    impacts of land use on air and water quality. For air quality improvements,
    MPOs and state air quality managers most frequently identified the following
    tools: (1) access to technical staff to help MPOs and air quality managers
    conduct analyses and modeling efforts to determine land use and related air
    quality impacts; (2) guidance, successful case studies, and more flexible
    funding for general research on how to design, implement, and measure the
    benefits of land use

    strategies that reduce vehicle miles traveled; and (3) improved modeling
    capabilities to better account for the impact on travel patterns from small-
    scale land use projects, such as bicycle and pedestrian facilities. For
    water quality improvements, the experts identified (1) support for local
    efforts to collect and analyze data on the physical, chemical, and
    biological changes in a water body that indicate the quality of that water;
    (2) funding for, or access to, technical staff and improved models to
    determine and measure the water quality impacts of different land uses and
    development strategies; and (3) basic scientific research on ecology

    and hydrology.  Public outreach. Federal agencies could better educate
    local land use

    decisionmakers and the general public about the relationships between air
    and water quality and their land use and transportation decisions. This
    could help to (1) overcome one of the barriers that a number of experts
    identified- the lack of public and official support for protective

    land use strategies- and (2) encourage a more collaborative working
    relationship among transportation, environmental, and land use
    decisionmakers. The panel of experts identified an additional role for the
    federal government in promoting protective land use strategies.

     Legal and regulatory reforms. The federal government could encourage
    states and localities to reform outdated planning laws that hinder efforts
    to conduct comprehensive land use planning, especially planning that
    considers environmental impacts.  Support for comprehensive planning.
    Agencies could also help to promote comprehensive land use planning that
    considers environmental impacts and involves all key stakeholders, such as
    local government

    officials and the public. Furthermore, agencies could encourage communities,
    as they devise comprehensive watershed plans, to incorporate measures to
    gauge actual progress in reducing pollution

    rather than focusing on the number of activities accomplished, such as the
    number of permits issued.

    EPA?s Initiatives Aware of states? and communities? increasing interest in
    better managing

    Promote Consideration future growth and limiting its adverse environmental
    impacts, EPA has a number of initiatives that provide MPOs and state and
    local environmental

    of Land Use Impacts on officials with some of the federal financial
    incentives, technical support, the Environment, but

    and public outreach they had suggested. Nevertheless, partly because of the
    Agency Could Take

    limited resources, these are one- time initiatives or not sufficient to
    reach the number of interested localities. EPA?s efforts to better link a
    More Strategic environmental concerns with land use planning, while showing
    promise,

    Approach to Leverage are not likely to have a more widespread impact unless
    they are part of a

    more strategic approach. Its Resources

    EPA Has Promoted Table 2 summarizes EPA?s major initiatives directly
    intended to encourage

    Consideration of Land Use states and localities to consider land use impacts
    on air and water quality. Impacts on the Environment

    We grouped the initiatives into the same categories of federal support that
    the MPOs, state air quality managers, and environmental officials
    identified. These initiatives are within the Air, Brownfields, Policy, and
    Water offices.

    Table 2: Major EPA Initiatives That Link Environmental Protection and Land
    Use Type of initiative Purpose Financial incentives

    Brownfield  $12. 5 million in fiscal year 2001 to help communities assess
    Assessment Grants abandoned urban sites for contamination in order to
    promote their cleanup and reuse Brownfield Cleanup

     $31 million in fiscal year 2001 to provide communities with seed Revolving
    Loan Funds money to generate funds for brownfield cleanup

    Clean Air  $1. 3 million in fiscal year 2001 to fund pilot projects,
    including Transportation growth management initiatives, that limit
    transportation- related Communities Projects

    emissions Mobile Source  $770,000 in fiscal year 2001 to educate
    communities on Outreach Assistance transportation choices that reduce
    vehicle miles and emissions Innovative  Provide communities with seed money
    for pilots that, for Communities example, promote revitalization of urban
    areas and Partnership Projects

    development practices that are environmentally sound a Smart Growth Grants b
     $300, 000 in fiscal year 2001 to build the capacity and incentives for the
    development of smart growth alternatives across organizations

    National Estuary  Provide funds in six pilot estuaries to, among other
    things, give Program Smart localities analytical tools to assess the impacts
    of various Growth Pilots

    growth scenarios and factor these data into comprehensive watershed
    protection or land use plans c

    Clean Water and  Continue to provide communities with the flexibility to
    use funds Drinking Water State for land use initiatives, such as purchasing
    land or easements Revolving Funds

    to control runoff and taking a watershed approach to infrastructure planning
    Nonpoint Source  $237. 5 million in fiscal year 2001 for states and tribes
    to Implementation

    implement nonpoint source programs; a few communities used Grants portions
    of the funds to implement protective land management practices

    Water Quality  $19 million in fiscal year 2001 to promote more innovative
    ways Cooperative of managing stormwater and sewers Agreements Watershed
    Assistance  $200,000 in fiscal year 2001 to encourage communities to work
    Grants with other organizations in watershed protection partnerships

    Chesapeake Bay  Provide funds for efforts to protect the bay, including an
    Program Grants assessment of regional land use impacts; this is a joint
    project with state and local governments and key stakeholders

    Source Water  $1. 5 million in fiscal year 2001 for grants to such
    organizations Protection Grants as the National Rural Water Association to
    help communities and water suppliers develop and implement protection plans
    for

    sources of local drinking water. EPA expects the plans to include land
    management tools, such as zoning ordinances

    (Continued From Previous Page)

    Type of initiative Purpose

    Wellhead Protection  $4 million in fiscal year 2001 for a grant to the
    National Rural Grants Water Association to help rural water systems develop
    and implement programs to protect groundwater sources of drinking water

    Technical assistance

    Guidance  Promote methods to account for the air quality benefits of
    certain land use practices in the SIP or conformity determination processes
     Summarize current research on the impacts of certain land use trends, and
    the transportation supporting them, and ways in which new development
    designs can limit these impacts, including a study showing the travel and
    transportation benefits of infill development

     Issue a guide and fact sheets, post information on a Web site, and sponsor
    roundtables and workshops on development designs that have a low impact on
    water quality; EPA is also working to promote low- impact development
    practices on federal lands or at federal facilities  Provide communities
    with assistance on ways to successfully develop and implement the TMDLs to
    restore impaired water

    bodies Water quality and land  Develop Web- based tools to provide
    communities with access use data to water quality information that is linked
    to specific geographic land areas

     Develop tools to help communities estimate the pollutant loads from
    various sources; this is a joint effort with the U. S. Geological Survey
    Better assessment  Develop methodologies to quantify the emissions and
    water methods and models quality benefits of various land use alternatives,
    starting with urban infill or brownfield redevelopment projects, followed by
    transit- oriented and mixed- use development

     Evaluate land use models to publicize those that may be currently
    available or under development to help assess land use impacts

     Provide communities with a watershed assessment model  Distribute the
    Smart Growth Index, a tool that communities can use to estimate the vehicle
    miles and emissions generated by different land use scenarios

    (Continued From Previous Page)

    Type of initiative Purpose

    Clearinghouse for best  Participate in the Smart Growth Network, a
    consortium of key practices stakeholders formed in response to increasing
    community concerns about the need for new ways to grow while also promoting
    economic development and environmental protection

     Sponsor the Clean Air Act Advisory Committee, which has a subcommittee to
    address issues related to land use, transportation, and air quality, such as
    the granting of SIP

    credits for land use measures or promoting clean air and sustainable
    communities  Sponsor conferences; host Web sites; and publish reports on
    best practices, successful grant projects, and smart growth

    initiatives that protect the environment, such as source water protection
    practices  Sponsor several projects under the National Nonpoint Source
    Monitoring Program to evaluate new technologies to control nonpoint source
    pollution

     Maintain the Nonpoint Source Partnership with states, as well as a working
    group, to identify best practices for managing runoff  Support the National
    Storm Water Best Management Practices

    database  Maintain the National Storm Water Management Center

    Professional  Sponsor the Watershed and Drinking Water Academies, which
    development provide training, including Web- based courses, and materials on
    watershed and source water management and protection practices

     Support the Center for Watershed Protection, which provides local water
    quality officials with technical assistance to help them develop and
    implement their water quality protection and restoration programs

    (Continued From Previous Page)

    Type of initiative Purpose

    Public outreach  Host several local government workshops on how to use
    zoning, tax incentives, and land preservation to promote smart growth
    initiatives that reduce runoff  Sponsor the ?Linking Land Use to Water
    Quality? program for local land use decisionmakers that uses satellite and
    other data to assess land cover, among other things

     Electronically provide examples of ordinances that localities can adopt
    for different land use practices that protect water quality, such as open
    space conservation, and erosion and sediment control  Provide effluent
    guidelines for construction and new development in order to educate the
    construction industry on requirements for limiting polluted discharges into
    water bodies

     Host workshops on how communities can find alternative funding sources for
    their water quality protection programs and achieve self- sufficient
    programs  Produce, along with the National Governors? Association, the

    electronic ?Smart Growth Toolkit,? which provides local officials with
    information to help them, for example, set a vision for future growth;
    assess the effects of different transportation, housing, and revitalization
    strategies; and consider methods to limit sprawl  Fund the development of a
    course entitled the ?National Smart

    Growth Leadership Program? for policy makers at all levels of government and
    in the private sector who will study, among other things, the contributors
    to sprawl and smart growth alternatives  Develop smart growth principles
    that communities wanting to protect water quality through better growth
    management can

    adopt  Promote the use of more comprehensive watershed approaches to water
    quality protection when possible through EPA?s grant and assistance
    activities

    (Continued From Previous Page)

    Type of initiative Purpose

    Interagency  Work with DOT on several joint research projects addressing
    coordination transportation, air quality, and land use, such as those

    discussed in table 4 on DOT initiatives  Along with other federal agencies,
    continue to implement the

    Clean Water Action Plan; under this plan, the agencies developed a unified
    federal policy for watershed management on federal lands that incorporates
    smart growth components, better coordinated their water quality protection
    programs, and issued a catalogue of available federal funding for water
    quality protection

     Work with a number of other federal agencies and professional
    associations, such as the Department of the Navy, U. S. Army Corps of
    Engineers, and the National Association of Counties, on water quality
    initiatives linked to land use  Work with the nine federal agencies that
    are part of the MidAtlantic Federal Partners for the Environment consortium,

    under a memorandum of understanding, to help interested communities better
    protect environmentally sensitive areas, such as wetlands, and redevelop
    brownfields Regulatory innovation  Under the Project XL program, d work
    with Atlanta on a method to quantify that the emissions from redeveloping an
    urban

    brownfield would be less than the emissions from developing in open space
    (as a result, Atlanta could move forward with a transportation project that
    was stalled because of the city?s air quality problems but that was critical
    for providing access to the brownfield site)

     Also under this program, work with the city of Chicago to identify
    development zones, including brownfields, low- income areas, and other
    industrial sites, and provide businesses that locate in these zones with
    economic benefits and easier ways to meet Clean Air Act requirements a The
    predecessor to this program was EPA?s Sustainable Development Challenge
    Grants program, funded at approximately $5 million per year from fiscal year
    1996 through fiscal year 1999. When funding for the program was canceled,
    EPA reconfigured and refocused it into the pilot program for Innovative
    Community Partnership Projects. EPA reprogrammed about $480,000 for grants
    in fiscal year 2000. EPA did not receive new funding for the program in
    fiscal year 2001 and instead used the

    discretionary funds it had available to issue grants that year. b According
    to EPA?s manager for smart growth initiatives, these are grants awarded by
    the agency?s

    policy office for smart growth initiatives, although individual program
    offices may also have grant initiatives that could be characterized as smart
    growth efforts. The manager added that this effort is not a formal program.
    Rather, EPA can annually decide if it has discretionary funds available to
    award these types of grants, so the amount of funds and number of grants
    each year can vary. c We were unable to determine the amount of funds
    specifically devoted to integrating land use and

    water quality decisions for several programs. d EPA created the Project XL
    program to allow pilot projects flexibility in meeting regulatory

    requirements that may hinder innovation.

    One of the initiatives listed is most directly related to encouraging MPOs
    to consider the environmental impacts of land use when devising
    transportation plans. EPA provided the Association of Metropolitan

    Planning Organizations with a grant to be used as seed money, as well as
    staff assistance, to support the efforts of six different MPOs that had
    expressed an interest in better integrating smart growth into their
    transportation- planning and travel- modeling processes. These MPOs are,

    for example, enhancing the travel demand model to capture the effects of
    different land use strategies, integrating watershed and transportation-
    planning processes, and developing regional strategies for collaboration
    with local governments. When the project is completed, EPA and the
    association plan to report on the lessons learned, including modeling and
    planning innovations, as well as collaborative strategies, that can be
    adopted more widely.

    In addition to EPA?s efforts, the U. S. Geological Survey (USGS) and the
    National Oceanic and Atmospheric Administration (NOAA) provide communities
    with technical assistance to help them consider the impacts of land use on
    water quality. USGS is responsible for conducting a significant amount of
    water quality monitoring nationwide. NOAA, under

    its Coastal Zone Management and Coastal Nonpoint programs, helps up to 35
    coastal states (including the Great Lakes states) as well as territories
    develop programs for controlling coastal nonpoint pollution, including the
    incorporation of land use controls to limit water quality impacts. The major
    initiatives for both of these agencies are summarized in table 3.

    Table 3: USGS? and NOAA?s Major Water Quality and Land Use Initiatives Type
    of initiative Purpose

    USGS technical  Under the National Water Quality Assessment program,
    assistance continue to characterize water quality conditions in more than 50
    river basins and aquifer systems, helping to understand the impacts of land
    use  Assess the chemical, physical, and biological factors affecting
    streams and aquifers in selected metropolitan areas

     Fund a cooperative program that interested states, tribes, counties, and
    municipalities can use to, among other things, help them collect and analyze
    hydrologic data needed for

    their watershed protection efforts and implementation of TMDLs  Under its
    land use trends initiative, identify and analyze land use patterns and
    changes over the past 30 years and attempt to identify the causes and
    environmental

    consequences of these changes  Under its Urban Dynamics Research Program,
    use satellite

    data, historic maps, and aerial photographs to assess the effects of growth
    over time in specific major metropolitan areas, then use this information
    and models to forecast future alternative growth scenarios and their impacts
    on pollution a NOAA technical

     Provide a total of $5 million in fiscal year 2001, under the assistance
    Sea Grant program, to promote research, outreach, and education to address
    coastal resource problems, including growth issues as they relate to water
    quality  Issue a guide on practices that coastal and lake states could

    use to achieve their established measures of water quality, by, for example,
    (1) limiting runoff and pollution from new development and construction, (2)
    determining the location of new roads and bridges to limit impacts on water
    quality, and (3) protecting watersheds through the use of local zoning or
    open space preservation in ways that will guide development away from areas
    that protect against runoff and erosion; this is a joint effort with EPA
    Monitor water quality for about 25 estuaries nationwide  Through its
    Coastal Services Center, provide states with

    tools and training, such as how to use global information systems, which
    incorporate satellite data, to manage their water quality activities  Work
    with EPA to demonstrate the best approaches for

    redeveloping coastal brownfields a According to USGS program managers, as of
    July 2001, funding for these assessments was discontinued for fiscal year
    2002.

    EPA Could More While EPA?s efforts to address the linkage between land use
    and Strategically Target and

    environmental protection have been commendable, some have not been Better
    Leverage Its Land

    comprehensively implemented, and have not reached a broad enough Use
    Initiatives and

    audience to have an impact nationwide. The manager of EPA?s smart growth
    initiatives acknowledges that the agency took a more cautious Investments
    approach because it realized that with its limited resources, it would only
    be able to directly support a small portion of the hundreds of thousands of
    communities nationwide. Therefore, it decided to use its funds as seed money
    and look for pilot projects that had the greatest potential for serving as
    successful case studies that other communities could adopt. The agency also
    wanted to be sure not to exceed its existing authorities and to respect
    localities? primary authority for land use decisions. Given these
    considerations, the agency decided to task the Development, Community,

    and Environment Division within the Office of Policy, Economics, and
    Innovation with the mission of looking for opportunities to help states and
    localities with their smart growth initiatives to the extent possible with
    the limited resources provided. The agency did not define a similar mission
    for program and regional offices, but left it up to them to determine the
    extent to which they could assist states and localities. The division was to
    provide

    program and regional offices with any assistance they requested and keep
    informed of the offices? activities. As demonstrated in table 2, the
    division as well as the offices undertook a number of initiatives. Some of
    the activities, such as the Smart Growth Network, publications, conferences,
    and partnerships with other organizations, have reached a more widespread
    number of local decisionmakers and communities, while the

    extent and impact of other activities have varied. Financial Initiatives EPA
    has had limited resources for some of its programs that link land use

    and environmental concerns, which, in turn, limits the programs? impact and
    reach. For example, under its Innovative Community Partnership Projects
    initiative- one of the programs most closely linked to promoting the wider
    use of environmentally protective development practices- EPA could support
    only 11 projects with the $480,000 in funding it made available for the
    program. Furthermore, EPA does not expect to get funding for the initiative
    in fiscal year 2002. In contrast, since 1995, the Congress has provided EPA
    with a total of about $90 million to provide

    communities with grants to assess contamination at sites. As of August 2001,
    the agency had used this to provide 399 communities with grants to assess
    brownfields in order to promote their cleanup and redevelopment.

    In other cases, EPA could better leverage the funds it has available to
    provide communities with a stronger incentive to assess and mitigate the
    environmental impacts of land use. For example, while communities can use
    EPA?s water quality grants to implement alternative land use practices, and
    several have done so, the agency did not design the grants specifically for
    this purpose. Making consideration of different land uses and their water
    quality impacts a criterion in the grant awards process could

    promote the more widespread use of its grants for land use activities.
    Technical Assistance EPA?s technical initiatives show promise but may have a
    limited impact unless the agency obtains more resources or provides more
    outreach, assistance, and marketing. These initiatives include the
    following:  Obtaining water quality data. EPA, USGS, and NOAA have each

    conducted monitoring to obtain the data needed for water quality
    improvements, but the agencies have only been able to focus on a sample of
    watersheds because of limited resources. As a result, many communities do
    not have the data needed to pinpoint the sources of urban runoff.

     Developing analytical methods. EPA?s efforts to develop methods and models
    to help communities assess the environmental benefits from different land
    use strategies, as well as to comprehensively assess watersheds, will be
    very useful to transportation and environmental planners. However, they will
    be useful only if EPA makes them widely available and provides planners and
    communities with assistance in using the tools. As an EPA water quality
    manager pointed out, the

    agency?s watershed model may be too complex for smaller communities with
    fewer resources, unless they have access to staff with technical expertise
    who can help them run the models.  Providing guidance. EPA has published
    guidance on how to account for the air quality benefits of certain land use
    practices in SIPs or conformity determinations. However, only a few MPOs and
    state air

    quality managers reported that they were more than somewhat aware of or were
    certain that they would use the guidance. They may have been unaware of the
    guidance partly because it was relatively new. Nevertheless, EPA conducted
    only a limited number of workshops on the guidance, such as a regional
    conference to introduce it, and program managers said the agency did not
    plan to spend resources on additional training or outreach.

    Individual Offices? Efforts EPA lacks a comprehensive, strategic approach to
    its initiatives that would help it better coordinate them and leverage its
    resources to achieve a more widespread impact, as illustrated in the
    following cases:

     Even though land use can impair both air and water quality, and mitigation
    measures can produce benefits for both, the program offices we spoke with
    were not always aware of the scope of each other?s initiatives. This lack of
    communication limits their ability to coordinate initiatives to take
    advantage of possible cumulative benefits. Similarly, air quality managers
    in one region reported that they had tried to

    establish a working group with the region?s water quality managers but had
    not been successful.  The level of activities that regions initiated to
    help communities seek

    land use solutions to environmental problems varied. This is of concern
    because states and localities most likely first contact regional offices for
    assistance in solving air and water quality issues, and these environmental
    problems often require a regional, rather than individual locality, focus
    and solution. For example, one EPA region in a highly developed area has
    drafted a plan to address state and local

    development issues that affect the environment, coordinated teams across its
    program offices, and conducted outreach with local jurisdictions. However,
    air quality staff in another EPA region in a highly developed area told us
    they have lost staff and have had to reduce their activities. Therefore,
    they have not had the resources to respond

    to more than a few communities? requests for assistance in using smart
    growth and land use strategies to improve air quality.

    Although states? and localities? interest in pursuing protective land use
    strategies is increasing, EPA will not be able to respond unless it develops
    a more strategic approach. Such an approach would include a more clearly
    defined agency role in providing states and localities with the assistance
    they need and the outcomes the agency wants to achieve in terms of
    environmentally protective land use practices. This approach would also
    include a plan specifying how best the agency could organize its ongoing and
    new projects among its program and regional offices and leverage its
    available resources to achieve the desired outcomes. Presenting and

    justifying this strategy to the Congress could help EPA to try to garner the
    support, authority, and funding the agency would need to implement its
    strategy.

    DOT Has Initiatives to Like EPA, DOT has several funding programs and
    technical assistance

    Link Transportation activities that can help encourage MPOs, state air
    quality managers, and

    communities to consider how their transportation choices can maintain or and
    Air Quality improve air quality. Most of these initiatives generally focus
    on reducing

    Protection but Could congestion and vehicle miles traveled, and, in some
    cases, modifying land

    Better Promote use, such as adding bicycle and pedestrian facilities.
    However, few of the

    initiatives have served as an incentive for MPOs, state air quality
    managers, Consideration of

    and communities to collaboratively assess different land uses and the
    Different Land Use transportation networks to support these uses, and
    consider choosing the network that offers the most air quality protection.
    Strategies

    Table 4 describes DOT?s initiatives to help localities select transportation
    plans that are more protective of air quality and that, to some extent,
    consider the impacts of land use.

    Table 4: Major DOT Initiatives That Link Transportation, Air Quality, and
    Land Use Type of initiative Purpose Financial incentives

    Congestion Mitigation  $1. 385 billion in fiscal year 2001 to fund
    transportation projects and Air Quality that reduce emissions in areas with
    air quality problems Improvement Transportation and

     $50 million in fiscal year 2001 to provide seed money for Community and

    projects that begin to link transportation and different land use System
    Preservation strategies with the intention of developing best practices that
    Pilot other communities can adopt SurfaceTransportation  Communities can
    use federal transportation funds to take Program pollution abatement and
    cleanup activities on certain types of projects Transportation  $545
    million in fiscal year 2001 to fund nontraditional Enhancements
    transportation projects that help to make communities more livable; about 50
    percent of the funds are spent on bicycle and

    pedestrian facilities and related projects, which help to reduce automobile
    use and congestion; about 1 percent of funds are used to mitigate the
    impacts of highway runoff Bicycle and

     Promote and facilitate the increased use of nonmotorized Pedestrian
    Program transportation, including developing facilities for the use of
    pedestrians and bicyclists a

    (Continued From Previous Page)

    Type of initiative Purpose

    Transit- Oriented  Promote this type of development by providing that
    federal Development funding under the transit capital program can be used
    for projects such as transit parks and redevelopment of historic facilities
    into transportation terminals Technical assistance

    Guidance  Clarify the required modeling for areas that need to demonstrate
    conformity; this is a joint effort with EPA  Issue a policy clarifying how
    states and localities can use federal transportation funding to assess and
    clean up brownfields

    Research  Assess the impact of neighborhood design on travel behavior and
    air quality to build better travel- forecasting techniques; this is a joint
    project with EPA

     Determine the impact of impervious surfaces from transportation systems in
    a watershed Model improvement  In the short- term, improve the travel
    demand model to account

    for changes, including (1) smaller- scale modifications to transportation
    plans, such as bicycle and pedestrian paths, and (2) ways in which various
    transportation projects encourage or reduce the number of trips people make;
    this is a joint project with EPA  Over the long- term, develop a new travel
    demand model that will better simulate travel patterns and needs; this is a
    joint

    project with EPA  Improve the capability to predict the contaminants in
    storm

    water and their impacts on the quality of receiving waters Professional

     Every 3 years, certify those MPOs that cover areas with more Development
    than 200,000 people to ensure that the transportation planners are
    implementing requirements, including the requirement to consider projects
    that ?protect and enhance the environment, promote energy conservation, and
    improve quality of life?  Develop and implement training courses on erosion
    and

    sediment control; this is a joint project with EPA Public outreach
    Continue the campaign, ?It All Adds Up to Cleaner Air,?

    designed to educate the public about ways to protect air quality, including
    ways to choose more protective transportation options; this is a joint
    effort with EPA a While this program does not receive its own funding,
    states and localities can use funds from almost all federal highway funding
    categories for these projects, and each state is required to fund a Bicycle
    and Pedestrian Coordinator position in its state DOT to promote this
    program.

    Few of DOT?s initiatives have served as an incentive for MPOs, state air
    quality managers, and communities to collaboratively assess the
    protectiveness of different land uses as a means to achieve air quality.
    Four initiatives illustrate this issue. First, the Transportation and
    Community

    and System Preservation Pilot program has the most potential to foster such
    assessments. It was designed to encourage collaboration among

    governmental, developer, and other private- sector interests, as well as
    transportation planners, to identify land use alternatives that, among other
    things, reduce the effects of land use on the environment. The program has
    resulted in a number of successful pilots. For example, Florida used its
    funds to develop a planning method to estimate the effects of land use
    strategies and alternative transportation improvements on travel choices.
    Tennessee used its funds to revise outmoded land use regulations to support
    bicycle, pedestrian, and transit projects. However, the agency might be able
    to better target funds for land use initiatives if fewer funds were
    dedicated, or ?earmarked,? beforehand. For example, funds provided in fiscal
    years 2000 and 2001 for most of the projects were earmarked and,

    according to the program manager, many of the projects were not reviewed in
    the competitive selection process.

    Second, DOT provides states with billions of dollars annually for new
    transportation projects. One of the criteria for funding under its New
    Starts transit program is demonstrating that land use plans will be
    compatible with the proposed transit project and will help contain sprawl. 1
    However, communities are not similarly required to address the

    containment of sprawl for highway and other projects. Third, the Congestion
    Mitigation and Air Quality Improvement Program provides a financial
    incentive for communities with air quality problems to alleviate them by
    designing transportation projects that reduce congestion

    and therefore improve air quality. However, the program does not encourage
    these communities to design land use projects as a means to achieve these
    goals. For example, the program?s guidance specifies a list of 17 eligible
    projects or activities that fall into two general categories; but

    these do not include projects that try to improve air quality by altering
    transportation- related land development. According to the program manager,
    however, several communities have proposed land use projects

    under the program?s provisions for experimental pilots. Under one of these
    proposals, the Minneapolis- St. Paul MPO requested program funds to purchase
    land adjacent to new light- rail stations for commercial

    development- mixing high- density housing and commercial activities.
    Although DOT ultimately approved the project for funding- stating that the
    project was related to transportation and could reduce emissions by

    1 This program provides grants for construction of new fixed guideway
    systems- such as light rail, heavy rail, and commuter rail systems and bus
    or high- occupancy vehicle lanes- or an extension to an existing system.

    reducing reliance on the automobile- the Department had some initial
    questions about the appropriateness of using transportation funds for land
    development activities. Additionally, the program was designed to provide a
    majority of the available funds for areas that already are in nonattainment
    or maintenance status. Therefore, it does not provide an incentive to
    communities in attainment to consider alternative development or
    redevelopment strategies as a means to preserve air quality. Yet, these
    communities may still have significant potential to grow and, therefore, the
    opportunity to guide development in ways that limit congestion and vehicle
    emissions.

    Finally, DOT and EPA efforts to improve travel- demand- forecasting models
    may help MPOs and communities determine the effects of transportation
    improvements on congestion and air quality. However, according to a DOT
    modeling expert, these efforts currently do not call for integrating land
    use or environmental components into the travel demand model, although a new
    land use simulation model under development may offer this opportunity in
    the longer- term. Without such integrated models,

    communities cannot consider the likely effects that their transportation
    decisions will have on land use, future growth and development, and air
    quality.

    The Congress Is The Congress is considering several legislative proposals
    that would better Considering Actions to

    coordinate federal efforts to support state and local growth management
    initiatives and remove barriers to these initiatives. Support State and
    Local Growth

     The Urban Sprawl and Smart Growth Study Act (H. R. 1739) calls for the
    Management Efforts

    Council on Environmental Quality to review how well federal agencies are
    considering the impact of their actions on urban growth and sprawl.  The
    Community Character Act (H. R. 1433 and S. 975) is intended to provide
    funding to promote improved state and regional planning,

    including the updating of outmoded state planning laws that pose barriers to
    considering and implementing different land use strategies that are more
    protective of the environment.  The Brownfields Revitalization and
    Environmental Restoration Act of 2001 (S. 350) would provide funding and
    changes to federal liability laws for hazardous waste cleanup in order to
    promote the cleanup and

    redevelopment of brownfields. The Senate passed the measure by a vote of 99-
    0. The House of Representatives is considering incorporating the Senate?s
    bill with its own bill on liability relief- the Small Business Liability
    Protection Act (H. R. 1831).

    In addition, 14 senators have requested that the President establish an
    interagency smart- growth working group, for example, to promote open space
    and farmland preservation, and to better link federal funds for highways and
    other development to state and local smart growth

    initiatives. Conclusions The general public may be more immediately
    concerned about the traffic congestion, long commutes to work, and the loss
    of open space that result from traditional patterns of development than
    about the impact of land use on air and water quality, but the issues are
    clearly interrelated. Alternative land use patterns- such as development
    around public transit or more pedestrian access to jobs and shopping- could
    help alleviate congestion (and emissions) and provide more open space,
    thereby improving air and water quality and reducing public health risks.
    Nevertheless, even the localities most interested in better integrating land

    use decisions with environmental concerns may find this to be a daunting
    task. Collaboration among the different decisionmakers- MPOs, transportation
    planners, land use planners, and environmental officials-

    and taking a needed regional approach to solutions may be difficult to
    achieve. These officials often have few incentives to assess the
    environmental impacts of land use. The assessments are technically
    difficult, especially for smaller localities with limited resources. Some
    local land use decisionmakers may not be open to greater collaboration or

    to regional land use solutions to environmental problems that cross
    jurisdictional boundaries. Some states? and localities? outdated planning
    and other laws hinder the consideration of different land uses. In addition,

    some localities may not be interested in integrating land use and
    environmental decisions because they have not yet experienced the effects of
    uncontrolled growth. On the other hand, these localities stand to benefit
    the most from an integrated approach because they can still influence future
    growth in ways that address quality- of- life concerns while protecting the
    environment. Given these barriers, forging a stronger and more effective
    link between land use and environmental protection may not

    happen on a more widespread basis without additional federal support and
    incentives. To some extent, federal laws and rules have served as an
    incentive for some states and localities to assess land use impacts. For
    example, requiring that transportation plans conform to vehicle emissions
    budgets appears to have served as an incentive for a number of MPOs to
    consider

    land use. Future federal rules for controlling ozone, particulate matter,
    and nonpoint source water pollution, if implemented, may provide similar
    incentives. Beyond rules, however, the federal government has other
    mechanisms, such as financial incentives and technical support, that it can
    use to encourage collaboration on protective land use strategies.

    To its credit, EPA has looked for ways within its existing authority and
    budget to provide states and localities with the assistance they need, and
    DOT has implemented a number of funding and technical initiatives to better
    link transportation and air quality protection. However, EPA?s initiatives
    generally have not been comprehensive and have not reached a broad audience
    nationwide. DOT?s initiatives generally have not provided an incentive to
    assess the impacts of different land uses on air quality as part of the
    transportation- planning process. By integrating its initiatives into a more
    cohesive strategy and better defining its approach and intended

    outcomes, EPA could better leverage its resources and achieve more progress.
    By better integrating land use considerations into its transportation-
    planning process, DOT could better promote air quality improvements. The
    Congress could also consider a number of financial incentives and
    legislative initiatives that would help to encourage greater assessments of
    the relationship between land use and environmental

    protection. Recommendations for

    To better assist states and localities in considering and limiting, when
    Executive Action

    possible, the environmental impacts of their land use decisions, we
    recommend that the Administrator, EPA, devise a more comprehensive and
    cohesive strategy for providing this assistance. This strategy should more
    clearly define the agency?s role and the outcomes it will achieve in terms
    of environmentally protective land use practices. The strategy should also
    specify how the agency will use its program and regional offices and
    leverage its available resources to achieve the specified outcomes. The
    agency should use this strategy as the basis for justifying needed authority
    and funding to the Congress.

    In devising this strategy, the agency should consider the following
    components:  Financial incentives. These incentives should be targeted to
    help MPOs and environmental officials collaborate with local decisionmakers
    to limit the adverse environmental impacts of land use. The incentives could
    either be funding criteria that explicitly require the

    consideration of the environmental impacts of land use or higher shares of
    funding for projects designed through a collaboration of MPOs, environmental
    officials, and communities that limit land use impacts. EPA should also
    provide financial incentives to encourage regional land

    use solutions to environmental problems- ones that take advantage of
    organizational structures already in place that include the transportation,
    air quality, water quality, and land use agencies necessary for this
    regional perspective. In providing these financial incentives, EPA should
    target a portion to those localities that have the

    most potential to achieve air and water quality benefits, such as localities
    that anticipate significant future growth.  Technical assistance. If MPOs
    and environmental officials are

    expected to assess land use impacts, the agency should provide them with
    additional technical tools, such as more access to (1) technical staff,
    especially in the regions; (2) simpler and more user- friendly models, such
    as watershed models that better assess the cumulative impacts of land use,
    as well as land use models; and (3) water- qualitymonitoring

    equipment, methods, and data, including data on biological indicators of
    water quality. The agency should also plan to better market these tools and
    educate the officials about them.  Public education. If land use
    decisionmakers and the general public are

    to collaborate on new transportation and land use strategies that are
    environmentally sound, the agency should better educate them about these
    strategies. In doing so, the agency could expand its efforts to work with
    other organizations, such as federal housing and economic development or
    private- sector agencies that already outreach to local communities.

    In addition, we recommend that the Administrator, EPA, review key rules and
    program activities- such as water infrastructure funding programs and TMDL
    requirements- to determine if they conflict with states? and

    localities? growth management efforts. The rules and programs might conflict
    by encouraging sprawl or by consuming disproportionate shares of available
    resources so that few are available to assess and mitigate land use impacts.
    The agency should also review these rules to determine if there are
    additional opportunities for states and localities to use land use as a
    means to comply with these rules.

    Furthermore, we recommend that the Secretary of Transportation consider
    undertaking the following actions to encourage MPOs to assess the air
    quality impacts of different land uses when devising their transportation
    plans to help improve and preserve air quality:

     Emissions data. To help inform local land use decisionmakers of the air
    quality impacts of their plans and increase opportunities for collaboration
    on more protective land use strategies, the agency should encourage all MPOs
    to assess the emissions impacts of their transportation plans and provide
    these decisionmakers with the results. Smaller MPOs may need assistance from
    DOT or other sources to conduct these assessments.

     Technical assistance. To increase MPOs? technical capacity to assess land
    use impacts, the agency should provide them with tools, such as more access
    to (1) technical staff, especially for the smaller, less wellfinanced MPOs,
    and (2) transportation models that integrate land use planning and
    environmental protection.

    Matters for The Congress may wish to consider the following strategies for
    better Congressional assisting those states and localities that want to
    limit the environmental

    impacts of their land use decisions: Consideration

     Provide EPA with an explicit mission, necessary authority, and additional
    funding, if possible, to implement the strategy that it devises to more
    completely and effectively assist states and localities.

     In reauthorizing TEA- 21, look for opportunities to use federal
    transportation funding as a means to encourage greater consideration of the
    environmental impacts of different land use strategies by (1) requiring such
    considerations as a part of the process to develop the

    transportation plan and TIP; (2) continuing but modifying funding programs
    already established to better link transportation and air quality so that
    they also integrate the consideration of impacts from different land use
    strategies, where appropriate; and (3) setting aside portions of federal
    transportation funds for projects that make this link,

    as well as helping to ensure that federal transportation funding does not
    conflict with efforts to control sprawl.  Provide additional financial
    incentives: (1) provide federal agencies with

    greater discretion over a portion of their transportation or environmental
    funds to encourage assessment and mitigation of land use impacts on the
    environment; (2) provide states and localities with additional funds when
    possible to obtain the technical expertise, data,

    and analyses they need to assess land use impacts and mitigate adverse
    effects, as well as develop and implement TMDLs; and (3) use funds to
    encourage collaboration among transportation, environmental, and land

    use planners, especially in developing plans that consider regional land use
    impacts and solutions.

     Look for opportunities to encourage and assist interested localities to
    revise outmoded laws and ordinances that limit the consideration of more
    protective land uses, as the Congress proposes to do for states under the
    Community Character Act. Agency Comments and

    We provided EPA and DOT with a draft of this report for review and Our
    Evaluation

    comment. We subsequently met with or received comments from representatives
    of the following EPA offices:  The Development, Community, and Environment
    Division within the

    Office of Policy, Economics, and Innovation.  The Office of Air Quality,
    Planning, and Standards.  The Office of Transportation and Air Quality.
    The Office of Wetlands, Oceans, and Watersheds.  The Office of Wastewater
    Management.  The Office of Ground Water and Drinking Water.

    In general, EPA agreed with our conclusions and recommendations and said
    that they would be very helpful in guiding the agency?s future smart growth
    initiatives. Representatives of the policy office suggested that we

    clarify that the Development, Community, and Environment Division has a
    defined mission to promote smart growth, both within and outside of the
    agency, as well as some dedicated but limited resources for this mission. As
    a result, the division has been able to have a somewhat more widespread or
    nationwide impact with some of its initiatives, such as its

    Smart Growth Network, publications, conferences, and partnerships with other
    organizations, than some of the program and regional offices. These offices
    do not have a similarly defined mission and resources, so they have pursued
    their own smart growth initiatives to varying degrees, resulting in more
    limited and nonstrategic efforts. We made this distinction where possible in
    the report. Representatives of the air offices made the point that in
    addition to the effects discussed in the report, urban sprawl increases air
    pollution by (1) increasing commuting times, (2) clogging rural roads that
    were not built large enough to handle increasing traffic, and (3) resulting
    in dispersed

    population that makes it harder to take advantage of public transportation.
    Representatives of the water office pointed out that it is very important
    for EPA to encourage its program offices, as well as states and localities,
    to integrate their transportation, air quality, and water quality planning
    efforts. This is because land use can have a cumulative impact across both
    air and

    water quality that states and localities need to consider and address in a
    more integrated manner. Each EPA office also suggested some technical
    changes throughout the report, which we have incorporated as

    appropriate. Furthermore, we received comments from representatives of the
    Federal Highway and Transit Administrations within DOT, who generally agreed
    with our conclusions and recommendations. The DOT representatives also asked
    if we could provide additional examples of where MPOs were able to

    quantify or give the magnitude of the environmental benefits achieved from
    particular land use scenarios that they considered, but we do not have this
    type of anecdotal data from our nationwide survey results. In addition, the

    representatives suggested that the report should include a more in- depth
    discussion of the role of state governments and legislatures in promoting
    environmentally beneficial land use. While we acknowledge this role, an in-
    depth analysis of all 50 state governments was beyond the scope of our audit
    work for this assignment. However, we did include a discussion of

    how outmoded state planning laws can serve as a disincentive to pursuing
    protective land uses, as well as examples of where a few state governments
    have promoted such uses. Finally, the representatives also suggested some
    technical changes throughout the report, which we incorporated as

    appropriate.

    Appendi Appendi xes x I

    Objectives, Scope, and Methodology The Senate Smart Growth Task Force and
    the House Sustainable Development Caucus asked us to  determine the extent
    to which metropolitan planning organizations (MPO) and state air quality
    managers responsible for meeting federal clean air requirements consider the
    impacts of alternative land uses on

    their efforts to protect air quality;  determine how, if at all, state and
    local officials responsible for water

    quality and land use consider the water quality impacts of alternative land
    uses and work together to limit any adverse impacts; and  identify the
    actions that the federal government can take to help

    transportation, air quality, and water quality officials better link land
    use decisions with environmental protection.

    To address the first objective, we surveyed the 341 MPOs recognized by the
    Federal Highway Administration?s Office of Metropolitan Planning and
    Programs. 1 MPOs are the entities responsible for transportation planning in
    areas with more than 50, 000 people. (The Office of Metropolitan Planning
    and Programs is responsible for regulations, guidance, and policies
    pertaining to metropolitan transportation planning.) The survey included
    questions addressing transportation planning, land use assessments, and
    federal actions that could help MPOs assess alternative land use strategies
    when conducting transportation planning. In general, either the

    transportation planner or the executive director in each of the MPOs
    responded to the survey. The projects included in these plans contribute to
    the level of emissions from mobile sources in the area. We did not attempt
    to gain information from the state departments of transportation, which are

    responsible for transportation planning in those areas without a designated
    MPO. We also surveyed the 51 state air quality agencies (including the
    District of Columbia). To identify the most qualified person within the
    state air quality agencies to contact, we obtained a list from the
    Environmental Protection Agency?s (EPA) Office of Transportation and Air
    Quality of those state officials responsible for preparing the State
    Implementation

    Plan (SIP). A SIP is a detailed description of the programs that a state
    will use to carry out its responsibilities under the Clean Air Act to reduce
    air pollution. The Office of Transportation and Air Quality is responsible
    for carrying out laws to control air pollution from motor vehicles. If the
    list did

    1 The list supplied to us had 345 listed MPOs; however, 5 subsequently
    contacted us to let us know that they are not the MPO for the area, and 1
    contacted us to let us know it had split into 2 separate MPOs.

    not identify a contact for preparing the SIP, we mailed the survey to the
    chief of the state?s air quality division or other appropriate official.

    To obtain the maximum number of responses to our survey, we mailed a
    prenotification postcard to all survey recipients about 1 week before we
    mailed the surveys. We also sent a reminder letter to nonrespondents about 4
    weeks after mailing the initial survey and a replacement survey to those who
    had not responded about 8 weeks later. We pretested the questionnaire with
    three state air quality agencies and nine metropolitan planning
    organizations in the states of Georgia, Maryland, Massachusetts,
    Pennsylvania, and South Carolina, as well as the District of Columbia.
    During these visits, we administered the survey and asked the officials to
    fill out the survey as they would if they had received it in the mail. After
    completing the survey, we interviewed the respondents to ensure that (1) the
    questions were clear and unambiguous, (2) the terms we

    used were precise, (3) the questionnaire did not place an undue burden on
    the agency officials completing it, and (4) the questionnaire was
    independent and unbiased. We had a high response rate for our surveys: 87
    percent (295) of the 341 MPOs surveyed and 92 percent (47) of the 51 air
    quality agencies surveyed. 2 The states not responding were Arizona, 3
    California, Massachusetts, and New York. The results from the surveys of

    MPOs and the state air quality managers are presented in appendixes II and
    III. To analyze those MPOs in the areas that expect significant growth in
    the future, we merged the MPO survey data with data from our previous study

    of local growth issues, conducted from January through March 2000. 4 In that
    study, we identified 768 counties of the 3,141 nationwide as being located
    in metropolitan areas. 5 These counties were asked to provide information on
    the expected change in their community?s population over the next 10 years.
    Using 1990 Federal Information Processing Standards

    2 The Nevada Division of Environmental Protection, Bureau of Air Quality,
    has air quality authority over the state, except for Clark and Washoe
    Counties, and responded accordingly. These two counties have established air
    quality programs they control independent of the state. 3 Arizona chose not
    to respond to the survey because the Department of Environmental Quality
    doesn?t have authority to prepare the SIP in all nonattainment areas. 4 See
    Community Development: Local Growth Issues- Federal Opportunities and
    Challenges (GAO/ RCED- 00- 178, Sept. 6, 2000).

    codes, we ascertained that 546 of these counties were also counties
    represented by MPOs responding to our current survey. 6 We were therefore
    able to compare for each of these counties how it responded to our survey on
    the air quality impacts of growth and whether it expected future growth. For
    the purpose of this report, we included only those counties responding that
    they expect their community?s population to increase greatly over the next
    10 years. The questionnaire item used from the local growth survey is
    reproduced in appendix IV.

    In classifying MPOs as being in areas of ?attainment? or ?nonattainment? for
    air quality standards, we referred to their responses in our questionnaire,
    asking whether any portion of the geographic area covered by the MPO is in
    nonattainment, maintenance, or attainment for each criteria pollutant
    listed. MPOs responding ?attainment? for all six pollutants were classified
    as being in an ?area without an air quality problem.? Those responding
    ?nonattainment? or ?maintenance? for at least one of the pollutants were
    classified as being in an ?area with an air quality

    problem.? Because conformity is required of only those areas in
    nonattainment for ozone, carbon monoxide, particulate matter, and nitrogen
    dioxide, we confirmed that those classified as being an area with an air
    quality problem were in nonattainment or maintenance for at least one of
    these four pollutants. If the MPO responded ?uncertain? to the

    classification for any of the four pollutants, we classified the MPO on the
    basis of EPA?s designations as of January 29, 2001.

    For our analysis of the anticipated impact of the 8- hour ozone standard, we
    used a database containing the counties currently violating the 1- hour
    standard and expected to violate the 8- hour standard supplied by EPA?s Air

    Quality Strategies and Standards Division. We did not independently verify
    these data. EPA?s estimate of the number of counties likely to be in
    violation of the 8- hour ozone standard is based on 3 years of 8- hour
    monitoring data during 1997 through 1999. The 1- hour ozone data include

    counties in violation of the standard as of January 29, 2001. 5 Initially,
    848 counties were identified as being located in metropolitan areas, however
    because some counties were part of combined city/ county governments that
    operated as cities, have no county government, or perform very limited
    functions, they were removed from the list of counties surveyed. Many of the
    counties eliminated were located in the New

    England area. 6 Federal Information Processing Standards codes provide
    unique codes for U. S. states, counties, populated places, primary county
    divisions, and other locational entities, as well as for other countries.

    To address this objective, we also interviewed cognizant officials and
    collected documented studies from the federal agencies administering air
    quality and transportation programs, as well as from relevant stakeholders.

    Specifically, we interviewed and gathered documentation from (1) EPA program
    managers in the Office of Air, Office of Transportation and Air Quality, and
    Office of Policy, Economics, and Innovation; (2) the Department of
    Transportation?s (DOT) program managers in the Federal Highways
    Administration, including the Office of Metropolitan Planning and Programs,
    the Office of Natural Environment, and the Office of Human

    Environment, and in the Federal Transit Authority?s Office of Planning; and
    (3) relevant stakeholders, including the following- the Association of
    Metropolitan Planning Organizations, National Association of Counties,
    Northeast- Midwest Institute, National Association of Regional Councils,
    National League of Cities, National Governors? Association, and the State
    and Territorial Air Pollution Program Administrators/ Association of Local
    Air Pollution Control Officials.

    To address the second objective, we identified and solicited information
    from a panel of experts. We used an iterative process (often referred to as
    the "snowball" technique) to identify potential members for the panel. We
    first contacted water quality program managers from EPA?s Office of

    Wetlands, Oceans, and Watersheds; senior officials with organizations that
    specialize in urban development and policy issues, such as the American
    Planning Association and the Urban Land Institute; and environmental law and
    urban policy experts from universities and policy think tanks, such as
    George Washington University?s Law School and the Brookings Institute. We
    spoke with these people first because, according to our literature

    reviews and agency contacts, they had principal responsibility for or major
    interest in addressing water quality and/ or land use issues. We asked them
    to identify three to five nationally recognized experts each in the fields
    of water quality management and land use planning. We then asked each of
    these experts to also identify three to five experts. We also conducted
    extensive searches of the relevant literature to identify candidates. At the
    conclusion of this process, we had identified 126 individuals. To select
    individual panelists from this pool, we applied a predetermined set of
    criteria. These criteria included (1) area of expertise- to provide adequate
    coverage of representatives from the major disciplines, such as water
    scientists and managers, land use planners, legal specialists, and

    economists; (2) the number of times an individual was recommended as an
    indicator of how well the person was known as a recognized expert in a
    particular field; and (3) professional affiliation- to ensure adequate

    coverage of the key stakeholder groups that we identified, including federal
    agencies, academic institutions, state and local practitioners, private
    consulting firms, and nongovernmental organizations. This process resulted
    in the selection of 38 experts for the panel that included a cross section
    of the various stakeholder groups and specialties. The selection process
    maximized the chances of selecting panelists that represent the broadest
    possible range of expert opinions and perspectives associated with urban
    sprawl and smart growth. The names and professional affiliations of the
    individuals selected can be found in appendix VI.

    To collect data from the panel, we used a modified Delphi technique. This
    method allowed us to systematically gather the experts? views by using an
    iterative controlled feedback process. 7 An alternative to in- person
    discussion, Delphi avoids biasing effects, such as the dominance of a few
    individuals as well as group pressure for conformity that can occur in live
    group settings. 8 As part of the controlled feedback process, we employed

    an iterative set of questionnaires using Internet- based technology. This
    technique allowed us to examine the opinions of more experts than
    logistically possible from a live panel.

    During the first iteration, we obtained each expert?s responses to an
    openended questionnaire. We asked panelists the following:  What strategies
    and practices do states and localities use to assess and

    mitigate impacts of land use on water quality in their decision making
    processes?  What were the barriers that limited this sort of consideration,
    and what

    incentives might there be to promote consideration?  What could the federal
    government do to promote the linkage between

    land use and water quality protection? After the first iteration was
    completed, we performed a content analysis on the responses to the open-
    ended questions in order to (1) summarize the responses for the second
    iteration and (2) identify unique responses or positions relevant to the
    issues involved. To maintain standards of methodological integrity, we
    performed a content reliability check on a

    7 See Harold A. Linstone and Murray Turoff, eds., The Delphi Method:
    Techniques and Applications (Reading, Mass.: Addison- Wesley Publishing Co.,
    1975). 8 See James Wright, ?Delphi-- Systematic Opinion- Gathering,? The GAO
    Review (1972).

    random set of these summaries. This process resulted in a list of items that
    best represented the range of expert views derived from the open- ended
    responses of the first iteration. We presented these results to the experts
    in a second questionnaire and asked them to evaluate and score the list of
    items on several dimensions. These dimensions, arrayed along a five- point
    scale, included feasibility, importance, and effectiveness. We analyzed
    descriptive statistics (means, medians, standard deviations, and
    frequencies) on each item in order to assess the relative cohesiveness of
    group opinion on each response to the

    second questionnaire. This analysis demonstrated a high level of agreement
    on virtually all of the items. Furthermore, there was no significant
    difference among experts on the basis of their professional affiliation.
    Because of the high level of agreement, we determined that it was
    unnecessary to conduct additional iterations in order to achieve consensus.
    We determined the group position on each item by calculating

    the average response. We chose not to use the median to identify the group
    opinion on each item because there was very little differentiation among
    responses on the basis of the median, and our analysis showed that the
    substantive conclusions would not change, in any case. The response rate for
    the first and second iterations was 84 and 76 percent, respectively. The

    number of experts not responding to the questionnaires was relatively evenly
    distributed across both the categories of professional affiliation and area
    of expertise; thus, the nonresponses do not diminish the representativeness
    of expert opinions across these groups. (See tables 5 and 6.)

    Table 5: Numbers of Experts Who Participated in Each of the Survey
    Iterations, by Professional Affiliation Number of experts

    Number of experts Number of experts

    selected and who who responded to

    who responded to agreed to

    iteration 1 of the iteration 2 of the

    Affiliation participate

    survey survey

    Federal agencies 7 7 5 Academic institutions 11 9 9 Practitioners (state and
    13 10 10 local agencies, and private organizations)

    Nongovernmental 7 6 5 organizations Total 38 32 (84%) 29 (76%)

    Table 6: Numbers of Experts Who Participated in Each of the Survey
    Iterations, by Area of Expertise Number of experts

    Number of experts Number of experts

    selected and who who responded to

    who responded to agreed to

    iteration 1 of the iteration 2 of the

    Specialization participate

    survey survey

    Water quality 24 20 18 Land use planning 6 5 4 Economics 6 5 5 Law 2 2 2

    Total 38 32 (84%) 29 (76%)

    To address this objective, we also obtained information on nonpoint source
    water pollution and related matters as well as on state and local nonpoint
    source control activities from officials of EPA, the U. S. Geological Survey
    (USGS), and the National Oceanic and Atmospheric Administration (NOAA) and
    from state government agencies; and from representatives of a range of
    associations and nongovernmental organizations. We also obtained information
    from documents, case studies, and reports prepared

    by federal and state agencies, environmental organizations, associations of
    state and local environmental officials, universities, research
    organizations, and other relevant stakeholders concerned with watershed and
    water quality protection issues. Specifically, we interviewed and gathered
    documentation from the following:

     EPA?s program officials in the Office of Wetlands, Oceans, and Watersheds
    and the Office of Policy, Economics, and Innovation.  USGS officials in the
    Water Resources Division, including the National Water Quality Assessment
    Program; in the National Mapping

    Information Division, including the Urban Dynamic Research Program and the
    Land- Use Trend Program; in the Biological Resources Division; and with the
    Mid- Atlantic Federal Partners for the Environment.  NOAA program managers
    in the National Ocean Service, including the

    Office of Coastal Management and the Coastal Nonpoint Pollution Division.
    Relevant stakeholders, such as the Center for Watershed Protection,

    Northeast- Midwest Institute, National Governors? Association, and the
    Association of State and Interstate Water Pollution Control Administrators.

    To address the third objective, we included in our survey of MPOs and state
    air quality managers questions concerning federal actions that could help
    them assess alternative land use strategies when developing transportation
    or air quality plans. For water quality, we used information derived from
    the relative rankings of items in the second iteration questionnaire
    completed by the expert panel. In addition, to determine what federal
    actions were already under way to promote the linkage between land use

    and environmental quality, we conducted interviews with and collected
    documentation from the relevant federal agencies about current programs and
    initiatives. These agencies included DOT, EPA, NOAA, and USGS. We recognize
    that other federal agencies may have activities related to land use

    and environmental quality, such as the Department of Agriculture; however,
    these activities were outside the scope of this report. Additionally, we
    collected and reviewed a wide range of documents from organizations,
    including independent research institutions, universities, nongovernmental

    organizations, and public policy organizations. We also drew on our own
    prior work on related issues. A list of these reports can be found in the
    section entitled ?Related GAO Products.? To address relevant legislative
    requirements, we reviewed applicable sections of the Clean Air Act, Clean
    Water Act, Coastal Zone Management Protection Act, and Transportation Equity
    Act for the 21 st Century, as well as related implementing regulations.

    In addition, to determine the human health and environmental effects
    resulting from air and water quality impairments linked to the prevailing
    patterns of growth and development, we conducted interviews with, and

    collected documentation and studies from, federal agencies. In addition, we
    reviewed published studies and other information on growth- related

    issues and articles from the scientific literature on air and water quality
    impacts from land use. For example, we reviewed key studies, such as Our
    Built and Natural Environments: A Technical Review of the Interactions
    between Land Use, Transportation, and Environmental Quality (231- R- 01-
    002) by EPA, The Practice of Watershed Protection by the Center for
    Watershed Protection, and various USGS National Water Quality

    Assessment program reports. We did not independently assess the validity of
    the research.

    We performed our work from September 2000 to September 2001 in accordance
    with generally accepted government auditing standards.

    Results From Survey of States on Air Quality

    Appendi x II

    Planning This appendix includes the questions and responses from our survey
    of metropolitan planning organizations. Responses are expressed as the
    number of states responding to the survey.

    Results From Survey of Metropolitan Planning

    Appendi x II I Organizations on Transportation Planning This appendix
    includes the questions and responses from our survey of metropolitan
    planning organizations. Responses are expressed in percentage of those
    responding to the survey.

    Question From GAO Survey of Local Growth

    Appendi x I V

    Issues Which of the following best describes the change you expect in your
    community?s population over the next 10 years? (Responses are expressed in
    percentage of those responding.) (0) Decrease greatly (2) Decrease somewhat
    (9) Stay about the same (46) Increase somewhat (42) Increase greatly (1)
    Uncertain (0) Other

    Appendi x V

    Expert Panel Questionnaire This appendix presents the questions contained in
    the two questionnaires completed by members of the expert panel selected for
    this study. There were two phases of this survey. The questionnaires for
    both phase I and phase II were administered over the Internet. Phase I
    consisted entirely of open- ended questions. Phase II consisted of several
    series of items derived from the responses generated by experts during phase
    I. We asked the expert panel to evaluate these items on several dimensions
    in the phase II questionnaire. The dimensions were importance, feasibility,
    effectiveness, and prevalence (note that not all series of items were
    evaluated on all dimensions). The four series of evaluated items for this
    report were:

    1. Identifying Land Management Practices and Development Strategies 2.
    Identifying Impediments to Consideration and Implementation 3. Identifying
    Incentives for Consideration and Implementation 4. Defining the Role of
    Federal Government We also calculated the average rating, across all members
    of the expert panel, for each item on the relevant dimensions for a
    particular series. These averages are reported in the tables below in the
    columns to the left of the items presented in phase II.

    1. Identifying Land Management Practices and Development Strategies: Phase
    I: In your experience, what are examples of the types of land management
    practices and development strategies considered by water quality managers
    and land use planers and implemented by decisions

    makers to mitigate adverse impacts on water quality? Phase II: In the first
    round of this survey the panel identified numerous land management practices
    and land development strategies that mitigate adverse impacts on water
    quality. We have summarized those responses into 10 items that represent
    both practices and strategies (as many of you

    pointed out, distinctions between land management practices and land
    development strategies are inexact).

    In this section we ask that you evaluate land management practices and
    development strategies along three dimensions:

    1. how effective are the land use practices and strategies in preventing or
    mitigating water quality impacts, 2. how extensively have these land use
    practices and strategies been employed to date, and

    3. how feasible it is to promote more widespread use of these practices and
    strategies. The dimensions are arrayed after each item is listed. Click in
    the appropriate circle to indicate your response.

    Two of the dimensions, in particular, need defining. By "highly effective"
    we mean that the practice or strategy has a positive effect, and little or
    no negative effect, that the practice is justifiable on its own merit, and
    is valuable. Conversely, at the other extreme, "highly ineffective" means
    that the practice or strategy has major negative effects, is not
    justifiable, and is harmful.

    By "definitely feasible" we mean that the practice or strategy is easily
    implemented, is within available resources, and is acceptable to the general
    public. "Definitely infeasible" means that it is not easily implemented,
    uses too many resources, and is completely unacceptable to the general
    public.

    Land management practices and development strategies Average Expert Group
    Scores on Rated Dimensions. a generated by experts during Phase I. The
    following items were Items were rated on a five- point scale. Lower scores
    reflect presented to experts during Phase II and assessed on higher levels
    of effectiveness, prevalence, and feasibility. See

    effectiveness, prevalence, and feasibility.

    notes below.

    Effectiveness b Prevalence c Feasibility d

    1. Research, demonstrations, and innovative programs: Examples 1. 93 3.00
    1.86 include research with artificial wetland filtering systems, smart
    growth demonstration projects, tradable development permits, and use of
    large quantities of interdisciplinary data to assess water quality and
    ecological impacts.

    2. Land protection: Examples include conservation easements and 1. 66 2.41
    1.76 preservation or conservation of land, farmland, open space, and
    wetlands.

    (Continued From Previous Page)

    Land management practices and development strategies Average Expert Group
    Scores on Rated Dimensions. a generated by experts during Phase I. The
    following items were Items were rated on a five- point scale. Lower scores
    reflect presented to experts during Phase II and assessed on higher levels
    of effectiveness, prevalence, and feasibility. See

    effectiveness, prevalence, and feasibility.

    notes below.

    Effectiveness b Prevalence c Feasibility d

    3. Smart Growth principles and strategies: Examples include 2. 00 3.45 2.00
    innovative designs for cluster zoning, conservation and largescale
    subdivisions, and runoff control measures that can be used for multiple
    purposes (e. g. parks with buffers). Examples also include a focus on
    transportation development that encourages mass transit and economic
    incentives to buy transitfriendly

    homes; and, mixed- use, infill, low- impact, new- town, traditional
    neighborhood, transit- oriented, and zero- impact development strategies.

    4. Zoning/ ordinances related to existing and new development: 2. 14 3.10
    1.93 Examples include zoning for greater density, ordinances prescribing
    irrigation practices for lawns and gardens, lot size,

    on- site treatment of wastewater (i. e., septic systems), open space,
    parking, re- forestation, setback requirements, narrower street widths,
    water quality ordinances, and wetland ordinances

    (preserve/ replace). 5. Federally imposed regulations: Examples include
    environmental

    2. 62 2.07 2.38 assessments/ impact statements, federal permitting processes
    (Clean Water Act) 401, 404, and Endangered Species Act),

    monitoring/ enforcement programs. 6. Structural Best Management Practices
    (BMP): Examples 2. 29 2.32 1.93

    include erosion/ sediment control, minimal treatment of wastewater
    (settling/ skimming), natural ground cover/ wetland detention, retention
    ponds, separation of sanitary and storm sewers, swales, underground pipes/
    curbs/ gutters, and vegetative/ riparian buffers. 7. Development
    restrictions: Examples include construction

    2. 00 3.48 2.38 standards, growth boundaries, growth restrictions, limits on
    impermeable surfaces as a total percent of developed area, and siting
    restrictions.

    8. Non- structural Best Management Practices: Examples include 2. 37 2.79
    1.90 preventative maintenance (street cleaning and regular maintenance of
    structural BMPs), pollution prevention practices, such as the minimization
    of de- icing on roadways, public education/ outreach, regular maintenance of
    sewer infrastructure, and seasonal land development moratoriums.

    9. Site- level design techniques: Examples include alternative 1. 96 3.75
    2.07

    driveway/ parking lot configuration, the use of alternative paving products,
    increased common space, one- sided sidewalks, reduced footprints and
    impervious areas, reduced street width, and the concerted use of storm water
    as a resource rather than treating it as a waste product.

    (Continued From Previous Page)

    Land management practices and development strategies Average Expert Group
    Scores on Rated Dimensions. a generated by experts during Phase I. The
    following items were Items were rated on a five- point scale. Lower scores
    reflect presented to experts during Phase II and assessed on higher levels
    of effectiveness, prevalence, and feasibility. See

    effectiveness, prevalence, and feasibility.

    notes below.

    Effectiveness b Prevalence c Feasibility d

    10. Management strategies: Examples include adaptive 1. 76 3.58 2.13
    management, storm water programs that focus on stream morphology, Total
    Suspended Solids (TSS) control

    requirements, and good planning for and management of floodplains, riparian
    buffers, storm water, and watersheds. a The scale ranges from 1 to 5; "Don't
    know/ No Opinion" responses excluded in calculations of the average. Lower
    scores reflect higher levels of effectiveness, prevalence, and feasibility.
    b The actual wording of the assessment question for each item on this
    dimension was as follows: "How effective is this practice or strategy? 1.
    Highly Effective, 2. Effective, 3. Neither Effective Nor

    Ineffective, 4. Ineffective, 5. Highly Ineffective, or 6. Don?t Know/ No
    Opinion." c The actual wording of the assessment question for each item on
    this dimension was as follows: "How prevalent is this practice or strategy?
    1. Very Prevalent, 2. Prevalent, 3. Neither Prevalent Nor Rare, 4. Rare, 5.
    Very Rare, or 6. Don?t Know/ No Opinion."

    d The actual wording of the assessment question for each item on this
    dimension was as follows: "How feasible is this practice or strategy? 1.
    Definitely Feasible, 2. Probably Feasible, 3. May or May Not be Feasible, 4.
    Probably Infeasible, 5. Definitely Infeasible, or 6. Don?t Know/ No
    Opinion."

    2. Identifying Impediments to Consideration and Implementation: Phase I: The
    questions in this section ask about factors that might limit consideration
    and implementation of any of the land management practices and development
    strategies to mitigate negative water quality effects that you identified in
    section 1.

    What technological factors such as the lack of water- quality data or
    analytical tools, limit consideration and implementation of land use
    practices and development strategies to mitigate negative water quality
    effects?

    What factors established in federal, state, or local laws (nonregulatory)
    limit consideration and implementation of land use practices and development
    strategies to mitigate negative water quality effects?

    What factors established in federal, state, or local regulations limit
    consideration and implementation of land use practices and development
    strategies to mitigate negative water quality effects?

    What institutional factors, such as the customary separation of land
    development and water quality management responsibilities into different
    divisions or agencies, limit consideration and implementation

    of land use practices and development strategies to mitigate negative water
    quality effects? What resource factors, such as funding and staffing, limit
    consideration and implementation of land use practices and development
    strategies to mitigate negative water quality effects?

    What economic or market factors, such as pressures to provide more job
    opportunities or affordable housing, limit consideration and implementation
    of land use practices and development strategies to mitigate negative water
    quality effects?

    What other factors, such as public attitudes, political leadership, or
    special interest influence, limit consideration and implementation of land
    use practices and development strategies to mitigate negative water quality
    effects?

    Phase II: In the first round of this survey, experts identified numerous
    factors that might limit consideration and implementation of land management
    practices and development strategies to mitigate negative water quality
    effects. In this section, we have listed the impediments to consideration
    and implementation produced in the first round. We ask that you evaluate
    these items along the following dimensions:

    1. how important is it that actions are taken to remove the impediment, and

    2. how feasible, or difficult would it be to remove the impediment. These
    dimensions are arrayed after each item is listed. Click in the appropriate
    circle to indicate your response.

    By "very important" we mean that removing the impediment is a first order
    priority, has a direct bearing on major issues, and must be resolved. On the
    other hand, "very unimportant" means that there is no priority, no
    relevance, no impact on major issues, and should be dropped as an item to
    consider.

    By "definitely feasible" we mean that action to remove the impediment could
    easily be implemented, would be within available resources, and would also
    be acceptable to the general public. "Definitely infeasible" means that it
    would not be easily implemented, would use too many resources, and would be
    completely unacceptable to the general public.

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On importance, lower scores reflect
    higher levels Impediments to consideration of land management practices and
    development

    of importance. On difficulty, higher scores strategies. The following items
    were generated by experts during Phase I and

    reflect higher levels of difficulty. See notes presented to experts during
    Phase II to assess on importance and difficulty.

    below.

    Importance b Difficulty c

    11. Confusion about both current and future requirements to control nonpoint
    source 2.93 2.93 pollution causes localities to be less likely to use
    innovative land use practices for fear that they will conflict with
    regulatory requirements.

    12. The focus on short- term planning and the lack of clear organizational
    1.79 3.89 accountability deter efforts to assess and mitigate environmental
    impacts of land use, especially impacts on water quality.

    13. Water quality managers and land use planners lack advanced water quality
    2.11 3.70

    models (and guidelines promoting their uniform use) that assess the impacts
    of land use practices and help inform choices of appropriate water quality
    improvement strategies. For example, there is a lack models that (1) assess
    and

    predict both site specific and cumulative effects of development on
    watersheds, (2) integrate these effects over space and time, (3) accurately
    address variables such as loading, concentration, source contributors, and
    transport of pollutants, and (4) adequately consider impacts on biotic
    factors and habitat. 14. Localities, sometimes because of limited resources,
    lack (1) effective user 1.83 3.54

    friendly models, (2) consolidated water quality and land use data, and (3)
    monitoring equipment and methods that aid accurate diagnoses of water
    quality problems.

    15. Federal and state laws and regulations are narrowly focused rather than
    2.17 3.59

    comprehensive. This imposes a ?one- size- fits- all? approach that is
    difficult to implement, and inhibits innovation and inclusive approaches to
    linking land use and water quality.

    16. Water quality managers and land use planners lack basic information that
    would 1.55 3.34

    allow them to assess the cumulative impacts of urbanization on water
    quality. Such information includes urban characteristics, ecological
    factors, habitats, flow control impacts, watershed hydrology, stream
    geomorphology and channel stability impacts, and land use patterns using
    GIS. 17. The federal government lacks any role or authority to support local
    land use

    2.61 3.82 decisionmaking that would promote consideration of the impact that
    land use has on water quality.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On importance, lower scores reflect
    higher levels Impediments to consideration of land management practices and
    development

    of importance. On difficulty, higher scores strategies. The following items
    were generated by experts during Phase I and

    reflect higher levels of difficulty. See notes presented to experts during
    Phase II to assess on importance and difficulty.

    below.

    Importance b Difficulty c

    18. Economic markets drive current patterns of development. For example,
    land is 2.07 4.41 available and cheaper in greenfields and rural areas, and
    infrastructure costs to develop there are subsidized. Developers can make
    more money building in rural locations, farmers can make money on their
    property, and home buyers prefer these locations because they get more value
    for their dollar, compared to development in infill, urban, and brownfield
    areas.

    19. Certain federal, state, and local policies do not encourage innovative
    development 1.86 3.89

    practices that may better protect water quality. For example, some existing
    tax policies, and policies that subsidize water and transportation
    infrastructure costs, encourage prevailing practices such as the development
    of more highways, rather than mass transit. 20. Certain legal, regulatory,
    and other factors promote the conventional view that 2.17 3.14

    runoff is a waste product that needs to be drained away as quickly as
    possible. These factors do not promote management techniques that treat
    storm water as a resource to be managed and that are more protective of a
    watershed's overall health.

    21. There is opposition to certain innovative land use practices among some
    1.90 3.66 members of the public, local governments, and the development
    community. This opposition stems from the perception that such practices are
    costly and limit economic growth, their quality of life, and convenience,
    such as automobile usage.

    22. Communication, coordination, and better integration of land use planning
    that 1.75 4.14

    prevents or mitigates water quality impacts is inhibited due to (1)
    institutional stovepiping, (2) conflicting missions, and (3) the increasing
    number and fragmentation of organizations at the federal, state, and local
    levels based on subject matter and geographic jurisdictions. 23. Regional
    planning agencies lack sufficient authority to help address the

    2.00 3.76 cumulative, cross- jurisdictional impacts of land use on water
    quality. 24. Government institutions at all levels are resistant to change
    and inherently have 2.11 4.04

    institutional biases, barriers, and conventions. This limits the promotion
    of innovations to better link land use and environmental quality. 25.
    Economic pressures dissuade localities from considering the water quality
    1.83 4.31

    impacts of land use decisions. Some of these economic pressures include the
    need (1) to develop land to accommodate population growth, (2) to provide
    jobs, (3) to provide affordable housing, and (4) to develop other measures
    designed to keep small towns viable.

    26. Water quality managers and land use planners lack sound, scientific data
    that 1.79 2.93 would allow them to effectively characterize the water
    quality impacts of prevailing land uses to the public and local
    decisionmakers. Therefore, local decisionmakers may be reluctant to more
    aggressively promote land uses that better prevent or mitigate water quality
    impacts.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On importance, lower scores reflect
    higher levels Impediments to consideration of land management practices and
    development

    of importance. On difficulty, higher scores strategies. The following items
    were generated by experts during Phase I and

    reflect higher levels of difficulty. See notes presented to experts during
    Phase II to assess on importance and difficulty.

    below.

    Importance b Difficulty c

    27. In some states, enabling legislation mandates that only state
    legislatures can 2.20 3.50

    grant localities authority to plan, zone, and raise revenue for land use
    that mitigates environmental impacts. This sets up generic, rigid
    requirements, such as building codes that require waivers for innovative
    practices.

    28. Interests of the development community are over- represented during land
    use 2.00 4.03 decision- making processes, which limits consideration of
    potential water quality impacts of development.

    29. In part due to a lack of funds, there is limited enforcement of existing
    land use 1.78 3.56

    regulations, such as sediment control and storm- water management programs,
    as well as new initiatives such as technology transfer and habitat
    preservation programs.

    30. Localities lack funds to implement local and regional planning
    initiatives, such as 2.10 3.41 watershed councils, regional land use
    policies, model ordinances, and watershed protection plans.

    31. The provisions in transportation law (ISTEA and TEA- 21) that were
    intended to 2.06 3.61 promote more consideration of environmental impacts
    for large transportation projects are not effectively enforced.

    32. Parochial views held by localities can discourage land use controls and
    greater 2.04 3.89 consideration of overall environmental and water quality
    impacts of land use decisions.

    33. Some state enabling legislation is dated and does not provide for such
    things as, 1.97 3.71

    comprehensive planning, land use strategies, local land use authority,
    consideration of land use impacts that cross local jurisdictional boundaries
    (e. g. coordination among jurisdictions), or consideration of environmental
    (e. g. water quality) impacts of development.

    34. Beliefs that residential development will increase the tax base create
    pressures for 2.10 3.72 localities to approve projects without due
    consideration of water quality impacts. 35. Governments at all levels lack
    people in key positions who are versed in innovative 1.93 3.26

    planning, assessment, management, land use, and water quality practices.
    Governments also find it difficult to recruit and retain qualified staff or
    to provide technical cross- training. 36. Concerns about regulatory
    ?takings?, together with strong beliefs about private 1.93 4.14

    property and water rights, discourage localities from considering land use
    practices and controls which limit environmental impacts.

    37. Large federally financed projects (e. g. water infrastructure and
    transportation 2.32 3.27

    projects) are not necessarily selected nor designed to prevent or mitigate
    environmental impacts. Additionally, environmental impact statements for
    large federal projects (required by the National Environmental Policy Act)
    are completed too late in the decision- making process- after a project is
    already on the drawing board- to be effectively considered.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On importance, lower scores reflect
    higher levels Impediments to consideration of land management practices and
    development

    of importance. On difficulty, higher scores strategies. The following items
    were generated by experts during Phase I and

    reflect higher levels of difficulty. See notes presented to experts during
    Phase II to assess on importance and difficulty.

    below.

    Importance b Difficulty c

    38. Local laws and ordinances (e. g. relating to street widths, parking
    requirements, 1.86 3.46

    and lot size requirements) are outdated, restrict innovation, and inhibit
    comprehensive assessments of environmental and land use impacts.

    39. Water quality managers and land use planners lack (1) standardized water
    quality 2.17 3.36 monitoring procedures and (2) comprehensive, long- term,
    ambient water quality and biological monitoring data (spatial and temporal).
    This deficiency limits the ability to evaluate how effectively various BMPs,
    or land uses, limit or remove pollutants.

    a The scale ranges from 1 to 5; "Don't know/ No Opinion" responses excluded
    in calculations of the average. Lower scores reflect higher levels of
    importance and lower levels of difficulty. b The actual wording of the
    assessment question for each item on this dimension was as follows: "How
    important is it to remove this impediment? 1. Very Important, 2. Important,
    3. Neither Important Nor

    unimportant, 4. Unimportant, 5. Very Unimportant, or 6. Don?t Know/ No
    Opinion." c The actual wording of the assessment question for each item on
    this dimension was as follows: "How difficult is it to remove this
    impediment? 1. Definitely Not Difficult, 2. Probably Not Difficult, 3. May
    or

    May Not be Difficult, 4. Probably Difficult, 5. Definitely Difficult, or 6.
    Don?t Know/ No Opinion."

    3. Identifying Incentives for Consideration and Implementation: Phase I: The
    next set of questions asks about incentives that might be offered to water
    quality managers and land use planners and decision makers to encourage
    consideration and use of land management practices and development
    strategies that mitigate adverse impacts on water quality. What types of
    technological support, such as new models or tools, could serve as
    incentives to encourage consideration of land management practices and
    development strategies to mitigate adverse

    impacts on water quality? What types of legal action (non- regulatory), such
    as changes in current law, could create incentives to encourage
    consideration of land management practices and development strategies to
    mitigate adverse impacts on water quality?

    What types of regulatory action could create incentives to encourage
    consideration of land management practices and development strategies to
    mitigate adverse impacts on water quality? What types of institutional
    factors could serve as incentives to encourage consideration of land
    management practices and development strategies to mitigate adverse impacts
    on water quality?

    What types of resources could serve as incentives to encourage consideration
    of land management practices and development strategies to mitigate adverse
    impacts on water quality? What types of economic or market based incentives
    could be provided to encourage consideration of land management practices
    and

    development strategies to mitigate adverse impacts on water quality? What
    other measures could be taken to create incentives to encourage
    consideration of land management practices and development strategies to
    mitigate adverse impacts on water quality?

    Phase II: In the first round of this survey, experts identified numerous
    factors that might serve as incentives to encourage consideration and
    implementation of land management practices and development strategies to
    mitigate negative water quality effects. In this section, we have listed the
    incentives produced in the first round. We ask that you evaluate these

    items along the following dimensions. 1. how important is it to take actions
    to create these incentives, and 2. how feasible, or difficult, would it be
    to create the incentive. These dimensions are arrayed after each item is
    listed. Click in the appropriate circle to indicate your response.

    Here, by "very important" we mean that creating the incentive should be a
    first order priority, and that it could have a direct and positive bearing
    on major issues. On the other hand, "very unimportant" means that there is
    no

    priority, no relevance, no impact on major issues, and creating the
    incentive should be dropped as an item to consider.

    By "definitely feasible" we mean that the incentive could be easily
    implemented, would be within available resources, and would be

    acceptable to the general public. "Definitely infeasible" means that it
    could not easily be implemented, would use too many resources, and is
    completely unacceptable to the general public.

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On Incentives to encourage
    consideration of land management practices and

    importance, lower scores reflect higher levels development strategies. The
    following items were generated by experts during of importance. On
    difficulty, higher scores Phase I and presented to experts during Phase II
    to assess on importance and reflect higher levels of difficulty. See notes
    difficulty. below.

    Importance b Difficulty c

    40. Ensure greater consultation and coordination among planning, land use,
    and 2.00 3.48

    water quality agencies, and across regions (cross- jurisdictional), in order
    to achieve comprehensive water quality improvement and land use planning.
    This could be accomplished by funding watershed associations or councils to
    increase stakeholder involvement, by creating regional institutions such as
    watershed authorities, or by sharing fiscal resources so that jurisdictions
    don?t compete for

    tax revenue. 41. Provide remote- sensing tools to reduce the cost of on-
    the- ground assessments 2.27 2.76

    and assist in better understanding of watershed- scale issues and solutions.
    42. Ensure that water quality laws and regulations integrate both water flow
    (quantity) 1.81 3.11 and quality considerations. 43. Provide local land use
    decisionmakers and the public visualization tools to

    1.96 2.67 illustrate the impacts of various land use options. 44. Alter the
    National Pollutant Discharge Elimination System (NPDES) so that it 2.44 3.78

    focuses on identifying and managing the key chemical, biological, or
    physical pollutants in storm water as well as the rate, volume, and
    temperature of storm water discharged into receiving water bodies. Current
    emphasis is on the use of BMPs, but data are lacking on the effectiveness of
    many of these BMPs in protecting water quality.

    45. Provide outreach and education that will inform decisionmakers about the
    water 2.00 2.22 quality and other environmental impacts of their land use
    decisions. Methods could include (1) providing workshops, publications, and
    guidance, (2) public recognition programs for localities that encourage
    environmentally- friendly

    development, and (3) school curricula describing the effects of urban
    nonpoint source pollution in terms relevant and understandable to children.

    46. Develop and implement better standards and criteria for ambient water
    quality. 1.69 3.58 These would include biological water quality criteria and
    standards that set minimum pollutant levels to be achieved through point and
    nonpoint source controls, as well as simpler water- quality assessment
    criteria that could serve as early indicators of impacts resulting from
    changes in land use.

    47. Develop and strengthen standards and criteria for land management- with
    more 1.92 3.64

    stringent standards for land management practices that are less protective
    of water quality- and provide guidance in their use.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On Incentives to encourage
    consideration of land management practices and

    importance, lower scores reflect higher levels development strategies. The
    following items were generated by experts during of importance. On
    difficulty, higher scores Phase I and presented to experts during Phase II
    to assess on importance and reflect higher levels of difficulty. See notes
    difficulty. below.

    Importance b Difficulty c

    48. Impose fees, charges, and requirements on developers that cover the cost
    of both 1.70 4.04 new infrastructure and services to achieve water- quality
    protection. For example, (1) levy impact fees based on projected development
    impacts (e. g. impervious cover generated), (2) build infrastructure and
    environmental mitigation costs into charges for construction permits, or (3)
    require new greenfields development to cover the full cost of extending new
    water and sewer lines, roads, and other

    services. 49. Emphasize an ecosystem (biocentric) watershed planning and
    management

    1.70 3.92 approach that integrates land use, water resource management/
    allocation, and water quality. Such an approach would encourage development
    of a

    comprehensive water resource strategy that combines water, sewer, and
    stormwater technologies and management.

    50. Promote the additional amenities popular with the public that accrue
    from land use 1.76 2.35

    practices that protect water quality (e. g. conservation of wildlife habitat
    and open space and attendant recreational opportunities, and protection of
    drinking water sources and working lands, such as productive farmland). 51.
    Revise State Revolving Fund requirements so localities can address a broader
    set 2.13 2.83

    of water quality issues. For example, provide funding on a cost/ share basis
    to states and localities that actively monitor watersheds, have targeted
    those watersheds that need continuous improvement, and implement BMPs and
    other

    land use management practices that reduce or eliminate urban nonpoint source
    pollution. 52. Provide technical assistance to localities that includes (1)
    helping localities 1.96 2.58

    determine which BMPs offer the most water quality protection from land use
    and (2) assisting localities designing retrofits to existing storm- water
    systems that pose problems. 53. Improve water quality monitoring procedures
    and data (including physical,

    1.73 2.85 chemical, and biological data) so that current, site- specific
    information is available to decisionmakers. Make available also updated
    national monitoring information, such as that provided by the former
    National Urban Runoff Program.

    54. Provide models that can simulate cumulative impacts throughout a
    watershed, 2.07 3.62

    and that also integrate transportation, land use, infrastructure, and water
    quality, to permit evaluation of the effects of alternative land uses on
    water quality. This would also include training individuals to use these
    models. 55. Help localities obtain access to qualified staff to strengthen
    their capabilities to 1.88 3.48

    conduct land use planning that considers water quality impacts. Access could
    be created by hiring employees or consultants.

    56. Require that states and localities conduct anti- degradation analyses of
    their 2.42 3.96 watersheds as a condition for receiving federal funding.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On Incentives to encourage
    consideration of land management practices and

    importance, lower scores reflect higher levels development strategies. The
    following items were generated by experts during of importance. On
    difficulty, higher scores Phase I and presented to experts during Phase II
    to assess on importance and reflect higher levels of difficulty. See notes
    difficulty. below.

    Importance b Difficulty c

    57. Provide better biological and sediment assessment tools and procedures,
    such as 1.96 2.67 Rapid Bio- assessment Protocols, that consider visual and
    user- friendly measures to assess stream quality and provide early warnings
    of degradation.

    58. Update local planning, zoning, and development law and procedures to
    favor land 1.41 3.56

    use management that protects water quality. This includes ordinances and
    standards for parking, street widths, and other aspects of land use and
    development that reflect scientific understanding of the impact of
    impervious cover

    on water quality and are based on environmental and natural resource
    considerations. 59. Provide watershed runoff simulation models that are
    relatively inexpensive and

    2.26 3.00 easy- to- use (includes training people to use the models). These
    models should allow for customization to local circumstances and conditions
    and segregation of

    jurisdictional boundaries so that a locality can address its urban runoff
    issues and assess the downstream impacts of its actions. 60. Establish
    unambiguous federal authority to mandate load reductions when states 2.46
    4.11

    fail to do so and to issue penalties when reductions are not met. 61. Use
    tax policies as incentives to implement land use practices that are
    protective 1.81 3.73 of water quality. For example, (1) increase an entity?s
    property tax rate if the amount of nonpoint source pollution it contributes
    exceeds a community?s standard, (2) employ split rate taxation or provide
    developers tax relief to

    encourage urban rather than greenfield development, (3) establish stormwater
    utilities and base charges on projected water quality impacts, and (4)
    provide property tax relief for property owners willing to permanently
    conserve land. 62. Give federal agencies the land use authority they need to
    more fully implement the

    2.65 4.00 goals of the Clean Water Act, the Safe Drinking Water Act, and the
    Endangered Species Act on federal lands that these agencies manage.

    63. Update state planning enabling legislation to allow communities to use
    1.89 3.89

    comprehensive land use planning and growth management techniques that help
    protect water quality. Examples include, adoption of state- wide land use
    management plans and the use of developer impact fees, urban growth
    boundaries, and transfer of development rights. 64. Use federal and state
    funding as leverage to promote development that is 1.78 3.27

    environmentally benign. For example, provide more funding for public
    services and facilities in designated growth/ development zones, tie
    infrastructure funding to the adoption of urban nonpoint source reduction
    measures, and subsidize only those land uses that are protective of water
    quality, such as open space preservation or the restoration of riparian
    buffers.

    65. Sponsor research, studies, and demonstration projects of environmentally
    1.85 2.22 protective development practices, such as innovative site designs
    and model development standards, and involve universities and land grant
    institutions in these activities.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a

    Items were rated on a five- point scale. On Incentives to encourage
    consideration of land management practices and

    importance, lower scores reflect higher levels development strategies. The
    following items were generated by experts during of importance. On
    difficulty, higher scores Phase I and presented to experts during Phase II
    to assess on importance and reflect higher levels of difficulty. See notes
    difficulty. below.

    Importance b Difficulty c

    66. Provide population- based or zoning- based build- out models that
    predict future 2.31 2.67 growth impacts. 67. Impose and enforce regulatory
    requirements and funding conditions to mitigate

    1.67 4.15 water quality impacts of land development. This could include
    requiring developers to assess the impacts of proposed projects and
    overseeing developers? compliance with zoning, subdivision, erosion, and
    sediment controls and protection of wetlands. This could also include
    requiring land use practices, such as riparian barriers, limits on site
    clearing, and narrower streets, that mitigate such impacts, and the use of
    planning and growth management tools, such as urban growth boundaries,
    purchase and transfer of development rights, and open space zoning.

    68. Structure federal agencies, in particular EPA, to be more
    interdisciplinary in order 2.23 3.27

    to discourage ?stovepiping? and to encourage the use of multi- purpose,
    multidisciplinary teams that can more effectively integrate land use and
    water quality considerations.

    69. Authorize localities within a watershed to use a market approach to
    control 2.81 3.42 pollution, allowing them to exchange pollution credits
    between point and nonpoint sources.

    70. Encourage regulatory innovation, flexibility, and relief where
    appropriate. For 2.11 3.24

    example, streamline permitting for land use projects selected by consensus
    of all stakeholders, including regulators and developers. Give performance-
    based pollution credits for certain land use actions, such as open space and
    wetlands preservation and for minimizing sediment runoff from development.

    71. Provide land use planners and decisionmakers training, information, and
    case 2.07 2.22 studies to help them better understand the water quality
    impacts of their decisions and be more aware of innovative land use
    practices that mitigate such impacts.

    72. Provide hardware, software, and ancillary support for fully developed
    GIS systems 2.37 2.92 that help planners assess land use impacts. 73.
    Provide resources to upgrade and replace, as appropriate, the water, sewer,
    and

    1.56 3.85 storm- water infrastructure of the nation?s cities and older
    suburbs as a means to both prevent water quality degradation and encourage
    redevelopment in these

    areas, as opposed to development in greenfields. 74. Reform state and local
    laws to better control nonpoint source pollution. This could

    1.59 3.85 be achieved by allowing state and local taxing authorities, such
    as storm- water utility districts, and mandating BMPs for construction,
    development, road maintenance, and residential uses that are proven to
    mitigate water quality impacts, and tying the receipt of state funding to
    their implementation. This could

    also include gearing regulations more to comprehensive watershed protection
    that takes into account all influences on a stream, reservoir, or
    groundwater resources.

    a The scale ranges from 1 to 5; "Don't know/ No Opinion" responses excluded
    in calculations. of the average. Lower scores reflect higher levels of
    importance and lower levels of difficulty. b The actual wording of the
    assessment question for each item on this dimension was as follows: "How
    important is it to create this incentive? 1. Very Important, 2. Important,
    3. Neither Important Nor Unimportant, 4. Unimportant, 5. Very Unimportant,
    or 6. Don?t Know/ No Opinion."

    c The actual wording of the assessment question for each item on this
    dimension was as follows: "How difficult would it be to create this
    incentive? 1. Definitely Not Difficult, 2. Probably Not Difficult, 3. May or
    May Not be Difficult, 4. Probably Difficult, 5. Definitely Difficult, or 6.
    Don?t Know/ No Opinion."

    4. Defining the Role of Federal Government Phase I: In what ways, if any,
    could the federal government (1) address any of the limiting factors and (2)
    provide any of the incentives that you described above? Please include any
    specific observations or thoughts you may have on ways that federal funding
    sources pose impediments or could be better used to provide incentives.

    Phase II: In the first round of this survey the panel identified numerous
    potential federal actions designed to address any of the impeding factors,
    or provide any incentives to land use planners and decision makers, to
    encourage consideration and use of land management practices and

    strategies that mitigate adverse impacts on water quality. We have compiled
    those responses in this section and ask that you evaluate each suggested
    federal action along the following three dimensions:

    1. how important is it to implement the federal action, 2. how feasible
    would it be to implement the federal action, and 3. how effective would the
    federal action be, in terms of costs and

    benefits, both economic and social. These dimensions are arrayed after each
    item is listed. Click in the appropriate circle to indicate your response.

    Here, by ?very important? we mean that the action should be a first order
    priority, and that it could have a direct and positive bearing on major
    issues. On the other hand, ?very unimportant? means that there is no
    priority, no relevance, no impact on major issues, and that the action
    should be dropped as an item to consider.

    "Highly effective" means that the action will have a positive effect and
    little or no negative effect, that it is justifiable on its own merit, and
    is valuable.

    Conversely, "highly ineffective" means that the action would have major
    negative effects, would not be justifiable, and in fact is harmful. By
    "definitely feasible" we mean that the action would easily be implemented,
    would be within available resources, and would be acceptable to the general
    public. "Definitely infeasible" means that it would not be easily
    implemented, would use too many resources, and would be completely
    unacceptable to the general public.

    Average Expert Group Scores on Rated Dimensions a Federal actions designed
    to address impeding factors generated Items were rated on a five- point
    scale. Lower scores reflect

    by experts during Phase I and presented to experts during Phase higher
    levels of importance, effectiveness, and feasibility. See

    II.

    notes below.

    Importance b Effectiveness c Feasibility d

    75. Provide new financial tools and financial incentives to 1.58 2. 08 2.08
    encourage greater state and local investment in water quality improvement
    planning and implementation of successful runoff management. This could
    include allowing the use of state revolving funds for cost/ share programs
    that give preference to those localities that monitor watersheds, target
    certain ones for

    continuous improvement, and implement land management practices that protect
    water quality. 76. Provide regulatory flexibility to encourage consideration
    of 2.31 2. 38 2.23

    environmental impacts of land use. This could include allowing alternative
    approaches to the TMDL rule or storm- water management regulations that
    produce equivalent or superior water quality improvements. It might also
    include consolidating and streamlining permitting processes, at least for
    those communities that demonstrate significant water quality improvements.

    77. Fund and support basic research and development on the 1.92 2. 00 1.88

    science of ecology and hydrology. This would also include the development of
    better biological assessment tools, criteria, and standards that can serve
    as indicators of degraded water quality. Furthermore, more funding should be
    provided directly to research organizations, such as universities.

    78. Encourage the Environmental Protection Agency to develop an 2.00 2. 24
    2.24

    interdisciplinary approach, both within the agency and with other relevant
    federal agencies, to encourage better links between land use and
    environmental considerations, and provide a climate conducive to the
    development of innovative solutions.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a Federal actions designed
    to address impeding factors generated Items were rated on a five- point
    scale. Lower scores reflect

    by experts during Phase I and presented to experts during Phase higher
    levels of importance, effectiveness, and feasibility. See

    II.

    notes below.

    Importance b Effectiveness c Feasibility d

    79. Fund and support studies, research, and pilots to show the 1.69 2. 12
    1.64

    benefits of various land use management practices and development strategies
    and ways to measure their long- term impacts or effectiveness. This would
    include low- impact development strategies, those BMPs that appear to
    provide the

    most water quality protection, and cost- effective retrofits to existing
    storm- water management systems. 80. Provide incentives for water quality
    managers and land use

    1.92 2. 12 2.42 planners and decisionmakers to (1) coordinate their water
    quality improvement and land use plans, (2) consider crossjurisdictional
    issues and impacts, and (3) involve all key stakeholders in the decision-
    making process. This could involve support for the creation of regional
    bodies that have direct responsibility for ensuring that land use does not
    degrade water quality.

    81. Promote comprehensive watershed planning, including 1.54 2. 04 2.04

    approaches that seek to develop water resource strategies that combine
    water, sewer, and storm- water technologies into total water resource
    planning and management. Assist these planning efforts by more clearly
    defining water quality goals and objectives and outlining requirements for
    improving water quality.

    82. Use federal funding and taxing authorities to provide incentives 1.96 2.
    04 1.92 for historic preservation, energy conservation, and land
    conservation. These would include conservation easements, protection or
    restoration of riparian barriers, and other

    conservation land uses. 83. Better integrate federal policies and grant
    programs intended to

    2.15 2. 50 2.19 help achieve water quality protection or that influence land
    use. 84. Eliminate the factors in federal infrastructure funding

    1.96 2. 08 3.12 programs- including transportation and water infrastructure-
    that encourage current patterns of growth. These patterns include
    development in greenfields instead of urban infill and redevelopment,
    highways instead of mass transit, and a focus on short- term economic gain
    instead of long- term sustainable development.

    85. Require that environmental impact analyses on federally funded 2.08 2.
    64 2.04

    projects also include analysis that considers the cumulative water quality
    and other environmental impacts of the proposed development. 86. Provide
    states and localities funds to hire, train, and maintain

    1.81 2. 04 2.69 the qualified staff they need to promote better land use
    planning that considers water quality impacts.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a Federal actions designed
    to address impeding factors generated Items were rated on a five- point
    scale. Lower scores reflect

    by experts during Phase I and presented to experts during Phase higher
    levels of importance, effectiveness, and feasibility. See

    II.

    notes below.

    Importance b Effectiveness c Feasibility d

    87. Fund and support efforts to collect and analyze the necessary 1.69 1. 92
    2.04 data (physical, chemical, and biological) to determine ambient water
    quality and the water quality impacts of alternative land

    uses. Provide tools to help obtain this data, including long- term water
    quality surveys and monitoring, GIS, and remote sensing. 88. Condition the
    provision of federal funds on states or localities 2.19 2. 23 2.88

    taking specific actions to control nonpoint sources, improve water quality,
    and achieve performance goals. For example, make grants of federal funds
    contingent on localities basing

    land use and water quality plans on good economic, environmental, and anti-
    degradation analyses.

    89. Serve as a mediator and partner with states and localities 2.46 2. 58
    2.38

    rather than as an overseer, and help them to devise their own solutions to
    concerns about the environmental impacts of land use. These concerns are
    local, and federal one- size- fits- all

    policies do not encourage tailored innovative strategies. 90. Ensure that
    the implementation of the TMDL rule does not

    1.83 2. 09 2.22 come at the expense of developing comprehensive watershed
    protection programs.

    91. Effectively implement the TMDL rule and support a national 2.17 2. 21
    2.33

    assessment of nonpoint source pollution, identification of successful source
    controls, and the creation of the necessary supporting databases. 92.
    Promote comprehensive land use planning that considers

    1.88 2. 12 2.56 environmental impacts and involves all key stakeholders.
    This should also include efforts to update state enabling legislation

    so that it provides for such planning. 93. Fund and lead efforts to improve
    modeling capabilities for

    1.88 2. 20 2.21 states and localities. This would include models that
    localities can easily adapt to reflect their unique water quality conditions
    and that measure the impacts of land use, including

    transportation patterns and changes in hydrology. 94. Provide for measures
    of watershed protection that gauge the

    1.64 1. 92 2.20 amount of water quality improvement actually achieved as
    opposed to measures of activities, such as permits issued,

    administrative actions undertaken, technologies used, or fines imposed.

    (Continued From Previous Page)

    Average Expert Group Scores on Rated Dimensions a Federal actions designed
    to address impeding factors generated Items were rated on a five- point
    scale. Lower scores reflect

    by experts during Phase I and presented to experts during Phase higher
    levels of importance, effectiveness, and feasibility. See

    II.

    notes below.

    Importance b Effectiveness c Feasibility d

    95. Serve as an information clearinghouse and educator to (1) 2.12 2. 35
    1.65 state and local governments, (2) planners, (3) the general public, and
    (4) relevant trade associations that are involved in

    land use and water quality issues. Provide information and guidance on case
    studies of ways communities have successfully linked water quality
    protection and land use, new environmental technologies, innovative
    development techniques, growth management strategies, model ordinances,

    conservation efforts, and water quality assessments and monitoring
    techniques.

    96. Promote the use of market- based approaches that encourage 2.68 2. 58
    2.78

    nonpoint source control and land uses that minimize water quality impacts.
    For example, allow localities to trade pollution credits between point and
    nonpoint sources within a particular watershed or basin.

    97. Increase funding for infrastructure and provide it in a way that 1.73 2.
    08 2.48 ensures upgrades and repairs for existing infrastructure. 98.
    Provide some federal tax benefit for renters to make it easier

    3.52 3. 73 3.09 and more attractive to rent townhouses and apartments in
    highdensity, mixed- use developments as an alternative to ownership of
    single family detached houses.

    99. Reform regulatory approaches for water quality. For example, 1.84 2. 17
    2.48 revise storm- water management regulations so that localities (1) are
    less inclined to view and manage storm water as a

    waste product that must be immediately removed, (2) are more inclined to
    consider alternatives, such as greater reliance on on- site management and
    treatment, (3) will place less reliance on implementing conventional BMPs,
    and (4) shift attention

    toward source reduction, pollution prevention, and mitigation of other
    harmful factors such as the quantity and temperature of storm water
    discharged to receiving water bodies.

    100. Make low- cost loans available to localities to implement 2.62 2. 76
    2.67

    comprehensive land use plans that consider environmental impacts or that
    target public investments to designated growth areas.

    a The ale ranges from 1 to 5; "Don't know/ No Opinion" responses excluded in
    calculations. Lower scores reflect higher levels of importance,
    effectiveness, and feasibility. See notes regarding actual wording of
    questions below. b The actual question wording is as follows: "How important
    is it to take this action? 1. Very Important, 2. Important, 3. Neither
    Important Nor Unimportant, 4. Unimportant, 5. Very Unimportant, or 6. Don?t
    Know/ No Opinion."

    c The actual question wording is as follows: "How effective would this
    action be? 1. Highly Effective, 2. Effective, 3. Neither Effective Nor
    Ineffective, 4. Ineffective, 5. Highly Ineffective, or 6. Don?t Know/ No
    Opinion."

    d The actual question wording is as follows: "How feasible is it to
    implement this action? 1. Definitely Feasible, 2. Probably Feasible, 3. May
    or May Not be Feasible, 4. Probably Infeasible, 5. Definitely Infeasible, or
    6. Don?t Know/ No Opinion"

    Members of GAO?s Panel of Experts on the

    Appendi x VI

    Relationship of Water Quality and Land Use Alex Anas, Professor of
    Economics, The State University of New York at Buffalo, N. Y. Chester L.
    Arnold Jr., Project Director, The Nonpoint Education for Municipal Officials
    (NEMO) Project, University of Connecticut, Department of Extension, Haddam,
    Conn.

    Derek B. Booth, Ph. D., P. E., Research Associate Professor and Director,
    Center for Urban Water Resources Management, Civil and Environmental
    Engineering, University of Washington, Seattle, Wash.

    James Boyd, Senior Fellow, Energy and Natural Resources Division, Resources
    for the Future, Washington, D. C. Lynda L. Butler, Vice Dean and Professor
    of Law, The College of William and Mary School of Law, Williamsburg, Va.

    John C. Clausen, Associate Professor, Forest Hydrology, University of
    Connecticut, Storrs, Conn.

    Larry S. Coffman, Associate Director, Programs and Planning Division,
    Department of Environmental Resources, Prince George?s County, Md.

    Jessica Cogan, Chief of Staff, Governor?s Office of Smart Growth, State of
    Maryland, Baltimore, Md.

    Thomas E. Davenport, National Nonpoint Source Expert, USEPA, Region 5,
    Chicago, Ill.

    Lee R. Epstein, Director, Lands Program, Chesapeake Bay Foundation,
    Annapolis, Md.

    William A. Fischel, Professor and Chair of Economics Department, Dartmouth
    College, Hanover, N. H.

    Clyde W. Forrest, Jr., Professor of Urban and Regional Planning, University
    of Illinois, Urbana- Champaign, Ill. Rodney E. Frederick, P. E., F. ASCE,
    Office of Wetlands, Oceans, and Watersheds, Office of Water, USEPA,
    Washington, D. C.

    Robert L. Goo, Federal Lands and Activities Team Leader, Nonpoint Source
    Control Branch, Office of Wetlands, Oceans, and Watersheds, Office of Water,
    USEPA, Washington, D. C. Alan W. Hallum, Manager, Water Protection Branch,
    Environmental Protection Division, Georgia Department of Natural Resources,
    Atlanta, Ga. Ralph Heimlich, Deputy Director- Analysis, Economic Research
    Service, U. S. Department of Agriculture, Washington, D. C.

    Mary Henry, Chief Ecosystems Health Branch, Division of Environmental
    Quality, Fish and Wildlife Service, U. S. Department of the Interior,
    Arlington, Va. Randall G. Holcombe, Professor of Economics, Florida State
    University, Tallahassee, Fla.

    Thomas W. Holz, P. E., Hydrologic Services Manager, SCA Consulting Group,
    Lacey, Wash.

    Vivian Kahn, FAICP, Principal, Kahn/ Mortimer/ Associates, Oakland, Calif.
    (until recently, Acting Deputy Director of Planning, City of Berkeley,
    Calif.) Eric Damian Kelly, Professor of Planning, Ball State University;
    Consultant, Duncan Associates, Muncie, Ind.

    Eric H. Livingston, Chief, Bureau of Watershed Management, Florida
    Department of Environmental Protection, Tallahassee, Fla.

    Debrah Richard Marriott, Executive Director, Lower Columbia River Estuary
    Partnership, Portland, Oreg.

    James M. McElfish, Jr., Senior Attorney (Co- Director Sustainable Use of
    Land Program and Director, Mining Center), Environmental Law Institute,
    Washington, D. C. Rolf Pendall, AICP, Assistant Professor, Department of
    City and Regional Planning, Cornell University, Ithaca, N. Y.

    John W. Peterson, P. E., CPESC, Immediate Past President, Member of the
    Board of Directors, International Erosion Control Association (IECA),
    Steamboat Springs, Colo. Walton C. Poole, Ph. D., TMDL Program
    Administrator, America?s Clean Water Foundation, Washington, D. C.

    Ann Riley, Executive Director, Waterways Restoration Institute, Berkeley,
    Calif. Peyton Robertson, Coastal Policy Team Leader, Office of Ocean and
    Coastal Resource Management, National Ocean Service, National Oceanic and
    Atmospheric Administration, U. S. Department of Commerce, Washington, D. C.

    Larry A. Roesner, Professor of Civil Engineering (Urban Water Infrastructure
    Systems), Colorado State University, Fort Collins, Colo.

    Cathy M. Tate, Research Biologist, National Water- Quality Assessment
    Program, U. S. Geological Survey, U. S. Department of the Interior, Denver,
    Colo.

    Chris O. Yoder, Senior Research Associate, Midwest Biodiversity Institute,
    Columbus, Ohio (currently on leave of absence from the Ecological Assessment
    Section, Division of Surface Waters, Ohio EPA, Columbus,

    Ohio

    Appendi x VII

    Contact and Staff Acknowledgments GAO Contact Eileen Regen Larence (202)
    512- 6510 Acknowledgments In addition to the individual named above, Carolyn
    Boyce, Elizabeth Erdmann, Scott Gannon, Brandon Haller, Mitch Karpman, Karen
    Keegan,

    Ralph Lowry, Gopaul Noojibail, Frank Rivera, and Carol Herrnstadt Shulman
    made key contributions to this report.

    Related GAO Products

    Water Quality: Better Data and Evaluation of Urban Runoff Program Needed to
    Assess Effectiveness (GAO- 01- 679, June 29, 2001).

    Air Pollution: Air Quality and Respiratory Problems in and Near the Great
    Smoky Mountains (GAO- 01- 658, May 25, 2001).

    Community Development: Local Growth Issues- Federal Opportunities and
    Challenges (GAO/ RCED- 00- 178, Sept. 6, 2000).

    Water Quality: Key EPA and State Decisions Limited by Inconsistent and
    Incomplete Data (GAO/ RCED- 00- 54, March 2000).

    Community Development: Extent of Federal Influence on ?Urban Sprawl? is
    Unclear (GAO/ RCED- 99- 87, Apr. 30, 1999).

    Water Quality: Federal Role in Addressing- and Contributing to- Nonpoint
    Source Pollution (GAO/ RCED- 99- 45, Feb. 26, 1999).

    Urban Transportation: Metropolitan Planning Organizations? Efforts to Meet
    Federal Planning Requirements (GAO/ RCED- 96- 200, Sept. 17, 1996).

    (160545) Lett er

    GAO?s Mission The General Accounting Office, the investigative arm of
    Congress, exists to support Congress in meeting its constitutional
    responsibilities and to help improve the performance and accountability of
    the federal government for the American people. GAO examines the use of
    public funds; evaluates federal programs and

    policies; and provides analyses, recommendations, and other assistance to
    help Congress make informed oversight, policy, and funding decisions. GAO?s
    commitment to good government is reflected in its core values of
    accountability, integrity, and reliability.

    Obtaining Copies of The fastest and easiest way to obtain copies of GAO
    documents is through the Internet. GAO?s Web site (www. gao. gov) contains
    abstracts and full- text files of GAO Reports and current reports and
    testimony and an expanding archive of older products. The Testimony Web site
    features a search engine to help you locate documents using key words and
    phrases. You can print these documents in their entirety, including charts
    and other graphics.

    Each day, GAO issues a list of newly released reports, testimony, and
    correspondence. GAO posts this list, known as ?Today?s Reports,? on its Web
    site daily. The list contains links to the full- text document files. To
    have GAO E- mail this list to you every afternoon, go to our home page and
    complete the easy- to- use electronic order form found under ?To Order GAO
    Products.?

    Order by Mail or Phone The first copy of each printed report is free.
    Additional copies are $2 each. A check or money order should be made out to
    the Superintendent of Documents. GAO also accepts VISA and Mastercard.
    Orders for 100 or more copies mailed to a single address are discounted 25
    percent. Orders should be sent to:

    U. S. General Accounting Office P. O. Box 37050 Washington, D. C. 20013

    To order by Phone: Voice: (202) 512- 6000 TDD: (301) 413- 0006 Fax: (202)
    258- 4066

    Visit GAO?s Document GAO Building Distribution Center Room 1100, 700 4th
    Street, NW (corner of 4th and G Streets, NW)

    Washington, D. C. 20013 To Report Fraud, Contact: Waste, and Abuse in

    Web site: www. gao. gov/ fraudnet/ fraudnet. htm, E- mail: fraudnet@ gao.
    gov, or

    Federal Programs 1- 800- 424- 5454 (automated answering system).

    Public Affairs Jeff Nelligan, Managing Director, NelliganJ@ gao. gov (202)
    512- 4800 U. S. General Accounting Office, 441 G. Street NW, Room 7149,
    Washington, D. C. 20548

    a

    GAO United States General Accounting Office

    Why GAO Did This Study

    ?Urban sprawl?- developing farmland and open space away from an urban core-
    while providing housing and economic development opportunities, can increase
    traffic, impair the quality of life, and increase air and water pollution.
    The Congress asked GAO to examine how (1) state and local transportation and
    air and water quality officials consider impacts of land use on the
    environment and (2) federal agencies can help these officials assess land
    use impacts. GAO surveyed local transportation planners and state air
    quality officials nationwide and 32 experts on land use and water quality.

    October 2001 ENVIRONMENTAL PROTECTION Federal Incentives Could Help Promote
    Land Use That Protects Air and Water Quality

    This is a test for developing highlights for a GAO report. The full report,
    including GAO's objectives, scope, methodology, and analysis is available at
    www. gao. gov/ cgi- bin/ getrpt? GAO- 02- 12. For additional information
    about the report, contact John Stephenson (202- 512- 3841). To provide
    comments on this test highlights, contact Keith Fultz (202- 512- 3200) or
    email HighlightsTest@ gao. gov.

    Highlights of GAO- 02- 12, a report to congressional requesters

    What GAO Recommends

    EPA should devise an overall strategy to help states and localities assess
    land use impacts and provide them with financial, technical, and other
    assistance.

    DOT should encourage transportation planners to assess the emissions impacts
    of their plans and share their data with land use officials.

    GAO also suggests ways the Congress could encourage a better link between
    land use and environmental protection.

    EPA and DOT generally agreed with GAO?s findings and recommendations to
    their respective agencies.

    United States General Accounting Office

    What GAO Found

    Most states and localities do not comprehensively assess the impacts of land
    use on air and water quality and develop ways to mitigate any adverse
    effects, according to survey results. Transportation officials in areas with
    poor air quality were more likely to estimate whether different land uses
    would reduce the amount of vehicle emissions from their transportation
    plans, but this is because the law requires them to ensure that their plans
    do not worsen air quality. Assessing air quality impacts is important
    because land use that increases reliance on cars can increase emissions
    containing carbon monoxide and other pollutants in certain geographic areas,
    such as developed areas that already have air quality problems. These
    emissions can cause respiratory, cardiovascular, and other illnesses.
    Assessing water quality impacts is important because land use that increases
    paved surfaces increases polluted storm water runoff, endangering water
    quality and public health.

    State and local transportation and environmental officials do not consider
    the environmental impacts of land use because

    they are not required to consider these impacts;

    land use is a local decision and they believe that they have little ability
    to influence it; and

    they lack resources, data, and technical tools, such as modeling
    capabilities.

    While cleaner cars and fuels will improve air quality nationwide, some
    congested or growing areas may still need to consider altering land use as a
    way to meet federal air and water quality standards. This is especially true
    if the Environmental Protection Agency (EPA) implements, as planned, more
    stringent air quality standards and a water quality rule (the total maximum
    daily load rule).

    Survey respondents said the federal government could help and provide

    financial incentives for transportation, environmental, and land use
    officials to collaborate on more protective land use strategies;

    technical assistance to assess and mitigate land use impacts; and

    public education on the environmental impacts of land use and transportation
    decisions.

    EPA and the Department of Transportation (DOT) have initiatives that provide
    some of this support, but others are limited in scope and not part of a
    coordinated strategy. The Congress is also considering ways to remove
    federal barriers and provide states and localities with additional
    assistance. G A O Accountability Integrity Reliability

    Highlights

    Page i GAO- 02- 12 Environmental Protection

    Contents

    Contents

    Page ii GAO- 02- 12 Environmental Protection

    Contents

    Page iii GAO- 02- 12 Environmental Protection

    Contents

    Page iv GAO- 02- 12 Environmental Protection

    United States General Accounting Office Washington, D. C. 20548

    Page 1 GAO- 02- 12 Environmental Protection

    A

    October 31, 2001 Lett er

    The Honorable James M. Jeffords The Honorable Carl Levin United States
    Senate

    The Honorable Wayne T. Gilchrest The Honorable Martin T. Meehan House of
    Representatives

    As requested, we are reporting on the extent to which possible environmental
    effects from land use and development patterns (including patterns commonly
    known as ?urban sprawl?) are taken into account in transportation, air
    quality protection, and water quality protection efforts. This report

    contains recommendations to the Secretary of Transportation and the
    Administrator of the Environmental Protection Agency (EPA). The
    recommendations address ways that the agencies can provide states and
    localities with financial incentives and technical support, among other
    things, to help them give greater consideration to the environmental impacts
    of their land use decisions.

    As arranged with your office, unless you publicly announce its contents
    earlier, we plan no further distribution of this report until 10 days from
    the date of this letter. We will then send copies to the appropriate
    congressional committees; the Secretary of Transportation; the
    Administrator, EPA; and the Director, Office of Management and Budget. We
    will make copies available to others upon request.

    If you or your staff have any questions on this report, please call me at
    (202) 512- 3841. Key contributors to this report are listed in appendix VII.

    John B. Stephenson Director, Natural Resources

    and Environment

    Page 2 GAO- 02- 12 Environmental Protection

    Executive Summary Page 3 GAO- 02- 12 Environmental Protection

    Executive Summary Page 4 GAO- 02- 12 Environmental Protection

    Executive Summary Page 5 GAO- 02- 12 Environmental Protection

    Executive Summary Page 6 GAO- 02- 12 Environmental Protection

    Executive Summary Page 7 GAO- 02- 12 Environmental Protection

    Executive Summary Page 8 GAO- 02- 12 Environmental Protection

    Executive Summary Page 9 GAO- 02- 12 Environmental Protection

    Executive Summary Page 10 GAO- 02- 12 Environmental Protection

    Executive Summary Page 11 GAO- 02- 12 Environmental Protection

    Executive Summary Page 12 GAO- 02- 12 Environmental Protection

    Executive Summary Page 13 GAO- 02- 12 Environmental Protection

    Page 14 GAO- 02- 12 Environmental Protection

    Chapter 1

    Chapter 1 Introduction

    Page 15 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 16 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 17 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 18 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 19 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 20 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 21 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 22 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 23 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 24 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 25 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 26 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 27 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 28 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 29 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 30 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 31 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 32 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 33 GAO- 02- 12 Environmental Protection

    Chapter 1 Introduction

    Page 34 GAO- 02- 12 Environmental Protection

    Page 35 GAO- 02- 12 Environmental Protection

    Chapter 2

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 36 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 37 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 38 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 39 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 40 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 41 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 42 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 43 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 44 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 45 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 46 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 47 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 48 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 49 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 50 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 51 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 52 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 53 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 54 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 55 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 56 GAO- 02- 12 Environmental Protection

    Chapter 2 Most MPOs and Air Quality Managers Do Not Assess the Emissions
    Impacts of Different Land Uses in Protecting Air Quality

    Page 57 GAO- 02- 12 Environmental Protection

    Page 58 GAO- 02- 12 Environmental Protection

    Chapter 3

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 59 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 60 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 61 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 62 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 63 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 64 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 65 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 66 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 67 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 68 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 69 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 70 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 71 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 72 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 73 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 74 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 75 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 76 GAO- 02- 12 Environmental Protection

    Chapter 3 Most States and Localities Do Not Fully Assess and Mitigate the
    Sources of Nonpoint Pollution but May Need to Do So in the Future

    Page 77 GAO- 02- 12 Environmental Protection

    Page 78 GAO- 02- 12 Environmental Protection

    Chapter 4

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 79 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 80 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 81 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 82 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 83 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 84 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 85 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 86 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 87 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 88 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 89 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 90 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 91 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 92 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 93 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 94 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 95 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 96 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 97 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 98 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 99 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 100 GAO- 02- 12 Environmental
    Protection

    Chapter 4 Federal Agencies Could Take Actions to Help States and Localities
    Better Consider the

    Environmental Impacts of Land Use Page 101 GAO- 02- 12 Environmental
    Protection

    Page 102 GAO- 02- 12 Environmental Protection

    Appendix I

    Appendix I Objectives, Scope, and Methodology

    Page 103 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 104 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 105 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 106 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 107 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 108 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 109 GAO- 02- 12 Environmental Protection

    Appendix I Objectives, Scope, and Methodology

    Page 110 GAO- 02- 12 Environmental Protection

    Page 111 GAO- 02- 12 Environmental Protection

    Appendix II

    Appendix II Results From Survey of States on Air Quality Planning

    Page 112 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 113 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 114 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 115 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 116 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 117 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 118 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 119 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 120 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 121 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 122 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 123 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 124 GAO- 02- 12 Environmental Protection

    Appendix II Results From Survey of States on Air Quality Planning

    Page 125 GAO- 02- 12 Environmental Protection

    Page 126 GAO- 02- 12 Environmental Protection

    Appendix III

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 127 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 128 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 129 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 130 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 131 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 132 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 133 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 134 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 135 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 136 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 137 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 138 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 139 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 140 GAO- 02- 12 Environmental Protection

    Appendix III Results From Survey of Metropolitan Planning Organizations on
    Transportation Planning

    Page 141 GAO- 02- 12 Environmental Protection

    Page 142 GAO- 02- 12 Environmental Protection

    Appendix IV

    Page 143 GAO- 02- 12 Environmental Protection

    Appendix V

    Appendix V Expert Panel Questionnaire

    Page 144 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 145 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 146 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 147 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 148 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 149 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 150 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 151 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 152 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 153 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 154 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 155 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 156 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 157 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 158 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 159 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 160 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 161 GAO- 02- 12 Environmental Protection

    Appendix V Expert Panel Questionnaire

    Page 162 GAO- 02- 12 Environmental Protection

    Page 163 GAO- 02- 12 Environmental Protection

    Appendix VI

    Appendix VI Members of GAO?s Panel of Experts on the Relationship of Water
    Quality and Land Use

    Page 164 GAO- 02- 12 Environmental Protection

    Appendix VI Members of GAO?s Panel of Experts on the Relationship of Water
    Quality and Land Use

    Page 165 GAO- 02- 12 Environmental Protection

    Page 166 GAO- 02- 12 Environmental Protection

    Appendix VII

    Page 167 GAO- 02- 12 Environmental Protection

    United States General Accounting Office Washington, D. C. 20548- 0001

    Official Business Penalty for Private Use $300

    Address Correction Requested Presorted Standard

    Postage & Fees Paid GAO Permit No. GI00
    *** End of document. ***