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				 

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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

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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

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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Chapter 1 Introduction

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix II

Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix II Results From Survey of States on Air Quality Planning

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Appendix III

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Appendix IV

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Appendix V

Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix V Expert Panel Questionnaire

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Appendix VI

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

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

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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. ***