Water Quality: Federal Role in Addressing and Contributing to Nonpoint
Source Pollution (Chapter Report, 02/26/99, GAO/RCED-99-45).
Pursuant to a congressional request, GAO provided information on the
impacts of nonpoint source water pollution and the potential costs of
dealing with the problem, focusing on: (1) funding levels for federal
programs that primarily address nonpoint source pollution; (2) the way
Environmental Protection Agency (EPA) assesses the overall potential
costs of reducing nonpoint pollution nationwide and alternative methods
for doing so; and (3) nonpoint source pollution from federal facilities,
lands, and activities that federal agencies manage or authorize, or for
which they issue permits or licenses.
GAO noted that: (1) the federal agencies GAO contacted reported spending
about $3 billion annually for fiscal years 1994 through 1998 on 35
programs that they identified as addressing nonpoint source pollution;
(2) some deal directly with nonpoint source pollution; others focus on
different objectives but still address the problem; (3) while EPA is the
primary agency involved in water quality issues given its role under the
Clean Water Act, many other federal agencies have programs addressing
nonpoint source pollution and, in some cases, devote a significant
amount of resources to the problem; (4) in particular, the Department of
Agriculture's (USDA) programs account for over $11 billion of all
federal funding identified by these agencies; (5) USDA officials explain
that while most of the programs identified by the agency do not have
specific nonpoint source pollution objectives, the programs' activities
nonetheless help to reduce nonpoint source pollution; (6) EPA has
estimated the annual costs of controlling three major sources of
nonpoint source pollution to be $9.4 billion, an amount that represents
one of the few systematic attempts at estimating such costs nationwide;
(7) specifically, EPA's methodology to produce the estimate analyzes
agriculture, silviculture, and animal feeding operations and estimates
pollution-control costs for these sources; (8) EPA acknowledges that the
methodology has several limitations; (9) GAO also found that the
methodology does not assess and disclose the considerable range of
uncertainty associated with EPA's control cost estimate and that it
includes insufficient documentation of its cost-estimation methodology;
(10) EPA officials told GAO that the agency is considering an additional
cost-estimation methodology, a watershed based approach, that could
provide a substantially more realistic estimate by taking into account
the unique characteristics of individual watersheds; (11) the federal
government manages or authorizes a variety of activities that result in
nonpoint source pollution and, in some cases, affect water quality; and
(12) the following five activities have been identified as those with
the most potential to contribute significantly to nonpoint source
pollution: (a) silviculture; (b) grazing; (c) drainage from abandoned
mines; (d) recreation; and (e) hydromodification.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-45
TITLE: Water Quality: Federal Role in Addressing and Contributing
to Nonpoint Source Pollution
DATE: 02/26/99
SUBJECT: Water quality
Cost analysis
Water conservation
Water treatment
Interagency relations
Water pollution control
Environmental monitoring
Land management
IDENTIFIER: USDA Conservation Reserve Program
USDA Environmental Quality Incentives Program
OSMRE Abandoned Mine Land Program
Clean Water State Revolving Fund
EPA Nonpoint Source Pollution Program
EPA Chesapeake Bay Program
USDA Colorado River Salinity Control Program
USDA Great Plains Conservation Program
Army Integrated Training Area Management Program
USDA Wetlands Reserve Program
USDA Forestry Incentives Program
USDA National Resources Inventory
NOAA Coastal Zone Management Program
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Cover
================================================================ COVER
Report to the Chairman, Subcommittee on Water Resources and
Environment, Committee on Transportation and Infrastructure, House of
Representatives
February 1999
WATER QUALITY - FEDERAL ROLE IN
ADDRESSING--AND CONTRIBUTING
TO--NONPOINT SOURCE POLLUTION
GAO/RCED-99-45
Nonpoint Source Pollution
(160425)
Abbreviations
=============================================================== ABBREV
AML - Abandoned Mine Land
ARS - Agricultural Research Service
BLM - Bureau of Land Management
CWSRF - Clean Water State Revolving Fund
CZARA - Coastal Zone Act Reauthorization Amendments
DWSRF - Drinking Water State Revolving Fund
EPA - Environmental Protection Agency
EQIP - Environmental Quality Incentives Program
FERC - Federal Energy Regulatory Commission
GAO - General Accounting Office
NOAA - National Oceanic and Atmospheric Administration
NRCS - Natural Resources Conservation Service
O&M - Operating and Maintenance
USDA - U.S. Department of Agriculture
USFS - U.S. Forest Service
USGS - U.S. Geological Survey
Letter
=============================================================== LETTER
B-281614
February 26, 1999
Letter
=============================================================== LETTER
The Honorable Sherwood L. Boehlert
Chairman, Subcommittee on Water
Resources and Environment
Committee on Transportation and
Infrastructure
House of Representatives
Dear Mr. Chairman:
This report responds to your request that we report on the federal
government's role in both controlling and contributing to nonpoint
source water pollution.
As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 7 days after the report's issuance date. At that time, we will
send copies to the appropriate congressional committees; the
Administrator, EPA; the Chairman, Federal Energy Regulatory
Commission; the Director, Office of Management and Budget; and the
Secretaries of the Departments of Agriculture, Commerce, Defense,
Interior, and Transportation. We will also make copies available to
others upon request.
I can be reached on (202) 512-6111 if you or your staff have any
questions. Major contributors to this report are listed in appendix
VII.
Sincerely yours,
David G. Wood
Associate Director, Environmental
Protection Issues
EXECUTIVE SUMMARY
============================================================ Chapter 0
PURPOSE
---------------------------------------------------------- Chapter 0:1
Much progress has been made to restore the quality of the nation's
waterways since the passage of the Clean Water Act in 1972.\1 This
progress is largely attributable to significant efforts to reduce
pollutant levels from point sources, which are those that contribute
pollutants directly to a body of water from a pipe or other discrete
conveyance. But many waters are still heavily polluted, causing
ecological damage and posing risks to human health. Continuing
problems with water pollution resulted, for example, in over 2,000
fish consumption advisories and more than 2,500 beach closings and
advisories in 1996 alone. Overall, the Environmental Protection
Agency (EPA) reports that over one-third of the nation's assessed
waters are still not meeting water quality standards. Most of these
remaining water quality problems are largely attributable to
pollutants from nonpoint sources--diffuse sources that include a
variety of land-based activities such as timber harvesting,
agriculture, and urban development.
Concerned about the impacts of nonpoint source pollution and the
potential costs of dealing with the problem, the Chairman of the
Subcommittee on Water Resources and Environment, House Committee on
Transportation and Infrastructure, asked GAO to (1) provide
background information and funding levels for federal programs that
primarily address nonpoint source pollution (i.e., those programs
identified as either focusing exclusively on nonpoint source
pollution or that devote at least $10 million annually to the
problem); (2) examine the way EPA assesses the overall potential
costs of reducing nonpoint pollution nationwide and alternative
methods for doing so; and (3) describe nonpoint source pollution from
federal facilities, lands, and activities that federal agencies
manage or authorize, or for which they issue permits or licenses.
--------------------
\1 The Federal Water Pollution Control Act, 33 U.S.C. ��1251-1387,
is generally referred to as the Clean Water Act.
BACKGROUND
---------------------------------------------------------- Chapter 0:2
Nonpoint source pollution occurs when pollutants from diffuse sources
are transported by rainwater, snowmelt, or irrigation water through,
or over, land surfaces. The pollutants, which vary widely from one
source to another, can include sediment, nutrients (chemical elements
such as nitrogen and phosphorus), pesticides, pathogens (such as
bacteria and viruses), toxic chemicals, and heavy metals. The
pollutants are eventually deposited into rivers, lakes, and coastal
waters or introduced into groundwater. Airborne pollutants,
sometimes transported long distances and then deposited in bodies of
water, are also considered a nonpoint source. Among other problems,
nonpoint source pollution has been documented as affecting aquatic
species and contaminating drinking water supplies.
The Congress has historically left the control and regulation of
nonpoint source pollution up to the states. In 1987, however, the
Clean Water Act was amended to, among other things, authorize EPA to
implement a program that provides federal funds and technical
assistance to states to develop their own nonpoint source pollution
management programs. The act also calls on EPA to estimate the costs
of carrying out the provisions of the act. Other agencies are also
authorized by various statutes to encourage more environmentally
sensitive land use practices that help reduce sources of water
pollution. For example, some federal programs use a voluntary
cost-share approach to encourage improved land use, particularly with
regard to controlling soil erosion and improving agricultural
practices.
The Clean Water Act also acknowledges that federal facilities and
activities, such as grazing and timber harvesting on federal land,
can contribute to nonpoint source pollution. Therefore, the act
includes provisions whereby federal agencies are to ensure that their
activities are "consistent" with state nonpoint source pollution
management programs. States can review certain federal projects and
activities to determine whether they conflict with the states'
nonpoint source pollution management programs. In accordance with
procedures set forth in an executive order, federal agencies are
required to consult with the states and make efforts to accommodate
the states' concerns or explain their decisions not to do so.
RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:3
The federal agencies GAO contacted reported spending about $3 billion
annually for fiscal years 1994 through 1998 on 35 programs that they
identified as addressing nonpoint source pollution. Some deal
directly with nonpoint source pollution; others focus on different
objectives (such as reducing soil erosion or preventing health and
safety risks from abandoned mines) but still address the problem.
While EPA is the primary agency involved in water quality issues
given its role under the Clean Water Act, many other federal agencies
have programs addressing nonpoint source pollution and, in some
cases, devote a significant amount of resources to the problem. In
particular, the U.S. Department of Agriculture's (USDA) programs
account for over $11 billion, or about 80 percent of all federal
funding identified by these agencies. USDA officials explain that
while most of the programs identified by the agency do not have
specific nonpoint source pollution objectives, the programs'
activities nonetheless help to reduce nonpoint source pollution.
EPA has estimated the annual costs of controlling three major sources
of nonpoint source pollution to be $9.4 billion, an amount that
represents one of the few systematic attempts at estimating such
costs nationwide. Specifically, EPA's methodology to produce the
estimate analyzes agriculture, silviculture, and animal feeding
operations and estimates pollution control costs for these sources.
EPA acknowledges that the methodology has several limitations.
Specifically, the methodology (1) does not include the costs of
controlling some potentially significant sources of nonpoint
pollution and (2) includes capital costs associated with best
management practices to address nonpoint source pollution, but
excludes the potentially significant operating and maintenance costs
associated with these practices. GAO also found that the methodology
does not assess and disclose the considerable range of uncertainty
associated with EPA's control cost estimate and that it includes
insufficient documentation of its cost-estimation methodology. EPA
officials told GAO that the agency is considering an additional
cost-estimation methodology, a "watershed-based approach," that could
provide a substantially more realistic estimate by taking into
account the unique characteristics of individual watersheds.\2 The
officials noted, however, that resource shortages were constraining
the effort. GAO found that researchers at USDA and the U.S.
Geological Survey have made progress in developing nationwide
watershed models and that improved coordination between EPA and these
agencies could help advance EPA's effort.
The federal government manages or authorizes, or issues permits or
licenses for, a variety of activities that result in nonpoint source
pollution and, in some cases, affect water quality. Pollutants
resulting from these activities include sediment, nutrients, and
heavy metals. Federal and state officials GAO interviewed identified
the following five activities as those with the most potential to
contribute significantly to nonpoint source pollution: silviculture
(specifically, timber harvesting and associated forest roads),
grazing, drainage from abandoned mines, recreation, and
hydromodification (such as building and operating dams, or modifying
rivers for flood control or other purposes). Federal activities are
of particular significance throughout the 11 Western States where the
federal government owns at least one-half the land area in about 60
percent of the region's watersheds. The five states GAO
contacted--Arizona, California, Colorado, Oregon, and Utah--reported
many water quality problems resulting from one or more of these
federal activities. In Arizona, for example, the nonpoint source
program manager said that federal activities are the primary source
of almost 50 percent of all the water quality problems in the state.
--------------------
\2 A watershed is an area of land in which all surface water drains
to a common point.
PRINCIPAL FINDINGS
---------------------------------------------------------- Chapter 0:4
A DIVERSE ARRAY OF FEDERAL
PROGRAMS ADDRESS NONPOINT
SOURCE POLLUTION
-------------------------------------------------------- Chapter 0:4.1
Among the agencies GAO contacted, total federal annual spending for
nonpoint-related programs remained relatively constant from fiscal
year 1994 through fiscal year 1998 at about $3 billion, although
obligations among some programs increased significantly during this
period. Some programs deal directly with nonpoint pollution; while
others focus on different objectives, but also serve to reduce such
pollution. In addition, some of the programs provide resources to
nonfederal entities to deal with nonpoint source pollution, such as
providing resources to farmers to implement certain land management
practices, while other programs are focused directly on addressing
nonpoint pollution occurring on federal lands.
EPA is the lead federal agency authorized by the Clean Water Act to
address nonpoint source pollution. The agency's key activities in
this regard focus on (1) providing funding to states to develop and
implement nonpoint source management programs or (2) geographic
initiatives designed to protect specific watersheds, such as the
Chesapeake Bay. EPA programs obligated about $225 million in fiscal
year 1998, or about 8 percent of total federal nonpoint source
pollution-related obligations. While overall nonpoint funding has
been stable over the past 5 fiscal years, EPA's obligations have
grown significantly. For example, obligations for nonpoint source
activities in the Clean Water State Revolving Fund Program increased
from about $21 million to about $96 million from July 1, 1994,
through June 30, 1998.\3
Other agencies' programs devote considerable resources to addressing
nonpoint source pollution, in some cases eclipsing the resource
commitment of EPA, although many of these programs do not have
specific nonpoint source pollution objectives. USDA in particular
accounted for about 80 percent of federal funding addressing nonpoint
source source pollution in fiscal year 1998. Most of this funding is
associated with activities that help reduce pollution from privately
owned land, which constitutes about 70 percent of the lower 48
states. Specifically, the two largest USDA programs--the
Conservation Reserve Program and the Environmental Quality Incentives
Program--accounted for $1.9 billion, or about 72 percent of total
obligations for fiscal year 1998. These, and most other USDA
programs, are cost-share or incentive programs, or technical
assistance programs designed to reduce erosion, improve agricultural
practices, and protect water quality. USDA officials explained that
100 percent of the activities and funding associated with these two
programs ultimately help reduce nonpoint pollution because of the
close relationship between land management, such as soil erosion
control measures, and water quality.
The Department of the Interior operates several programs that address
nonpoint source pollution with total obligations of about $1.4
billion from fiscal years 1994 through 1998. Interior's largest
program, the Abandoned Mine Land Program, accounts for almost 45
percent of the Department's total obligations for nonpoint-related
activities for fiscal years 1994 through 1998. This program focuses
primarily on reducing the health and safety risks posed by coal mines
abandoned before 1977. Other Interior programs conduct water quality
research in certain geographic locations and identify specific water
quality threats.
Programs identified by other agencies also illustrate the diversity
of federal activities that address the problem. The Department of
the Army, for example, reported obligating about $20 million in
fiscal year 1998 to repair or restore lands damaged primarily by
training exercises, such as tank maneuvering and bombing ranges.
--------------------
\3 The Clean Water State Revolving Fund Program tracks funding based
on a fiscal year running from July 1 through June 30. Therefore, EPA
could not report funding based on a federal fiscal year, as used in
this report.
EPA'S METHODOLOGY FOR
ESTIMATING NONPOINT SOURCE
POLLUTION CONTROL COSTS
COULD BE IMPROVED
-------------------------------------------------------- Chapter 0:4.2
Estimating the costs to control nonpoint source pollution nationwide
is a difficult task. Critical information, such as identification of
waters contaminated with nonpoint pollution and the contribution of
each of those sources, is not readily available at the local level,
much less at a national level. Therefore, EPA developed models to
estimate the number of possible sources and the cost of applying
management practices to reduce pollution for three categories of
nonpoint sources--agriculture, silviculture, and animal feeding
operations (those that are not large enough to be considered point
sources by EPA).
While EPA's methodology represents one of just a few attempts to
analyze this difficult problem nationwide, there is considerable
uncertainty with the resulting estimate. Some of the uncertainties
relate to potentially key factors that are not included in the cost
estimate. Citing a lack of nationwide data, for example, EPA does
not include several important categories of nonpoint sources that can
be significant contributors, at least in some areas, such as
abandoned mines and airborne sources. Also excluded are operating
and maintenance costs associated with the best management practices
implemented to control the problem. For example, in developing cost
estimates for controlling runoff from croplands, EPA assumed that
farmers would develop water quality management plans to help them
manage the application of fertilizers on their fields. The capital
costs farmers would incur to develop these plans are included in
EPA's cost estimate. However, farmers could also be expected to
incur annual costs such as those associated with testing the soil to
determine whether they are meeting the goals of the management plan,
and these costs are not included.
Some of the methodology's limitations relate to the presentation of
EPA's results. For example, EPA presents its $9.4 billion figure as
a point estimate rather than a range, which implies a level of
precision that may not be warranted in light of the limited
information behind the supporting data and assumptions. Under such
circumstances in other studies, EPA has assessed and presented
estimates as a range of values. In addition, the agency did not
fully document the key assumptions and data used in the analysis,
making it difficult to compare the assumptions and data with
published sources to assess their reasonableness. For example, to
estimate the cost of erosion control on cropland acres, EPA used
estimates of the cost of applying various soil conservation
practices. According to EPA officials, the cost data were obtained
from USDA's Fiscal Year Statistical Summaries (1985-1995). However,
without documentation of the actual data used in the analysis, GAO
could neither verify the data sources nor assess their reasonableness
in comparison with other published sources.
Finally, the methodology does not account for the unique
characteristics of individual watersheds that influence the extent to
which nonpoint source runoff actually impairs water quality. Under
EPA's current approach, for example, data are collected on soil
runoff, and the assumption is made that all runoff contributes to
pollution. Under a watershed-based approach, the soil runoff data
could be combined with data on such things as vegetative cover and
rainfall associated with specific watersheds to more definitively
determine the extent to which soil runoff may result in a water
quality problem. EPA officials told GAO that they are considering
using a watershed-based approach as an additional cost estimation
methodology but were concerned about the additional resources the
approach might require. The officials noted, for example, that
developing a watershed-based model could cost about $750,000,
compared with the $25,000 it costs to update and run the existing
model. Researchers at USDA and Interior's U.S. Geological Survey,
however, have developed nationwide watershed-based methodologies for
analyzing potential water quality problems and pollutant sources.
These efforts could be useful to EPA in developing a nonpoint source
control cost-estimation methodology that is watershed-based.
A VARIETY OF FEDERALLY
MANAGED OR AUTHORIZED
ACTIVITIES CAN CONTRIBUTE TO
NONPOINT SOURCE POLLUTION
-------------------------------------------------------- Chapter 0:4.3
Under a variety of missions and legislative requirements, federal
agencies manage, authorize, or issue permits or licenses for, a
variety of activities that provide public benefit but may have the
unintended side effect of contributing to nonpoint source pollution.
The Forest Service, for example, provides commercial opportunities
such as timber harvesting and grazing, each of which can contribute
sediment and other pollutants to bodies of water. Federal and state
officials GAO contacted identified the following five activities as
those with the most potential to contribute significantly to nonpoint
source pollution: silviculture (primarily timber harvesting and
associated forest roads), grazing, drainage from abandoned mines,
recreation, and hydromodification.
The federal government owns at least one-half of the land area in
about 60 percent of the watersheds in the 11 Western States (Arizona,
California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon,
Utah, Washington, and Wyoming) and about 22 percent nationwide. The
predominance of federal land ownership in many western watersheds
suggests a potentially significant federal contribution to nonpoint
source pollution in those areas. State officials in the five states
GAO contacted (Arizona, California, Colorado, Oregon, and Utah)
confirmed that the federal contribution to the problem, particularly
among these states, can be significant. For example, (1) Arizona
officials cited nonpoint source pollution from federal activities as
the primary source of almost 50 percent of the state's water quality
problems; (2) Oregon officials cited nonpoint pollution from federal
activities as the primary source of 50 to 60 percent of the state's
water quality problems; and (3) almost 50 percent of Colorado's
reported problems are affected by drainage from abandoned mines, many
of which occur on federal lands.
RECOMMENDATIONS
---------------------------------------------------------- Chapter 0:5
In order to improve EPA's approach toward estimating the cost of
controlling nonpoint source pollution, GAO recommends that the
Administrator of the Environmental Protection Agency direct the
Office of Water to
-- address key limitations in its approach by (1) including the
costs of operating and maintaining best management practices,
(2) assessing and disclosing the range of uncertainty associated
with its control cost estimate, and (3) more fully documenting
its cost-estimation methodology and
-- work with researchers at the U.S. Department of Agriculture and
the Department of the Interior's U.S. Geological Survey to
obtain lessons learned, data sources, and modeling approaches to
help advance EPA's own efforts to develop a watershed-based
cost-estimation approach.
AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:6
GAO provided a draft of this report for review and comment to the
Departments of Agriculture, Commerce, Defense, the Interior, and
Transportation and to EPA and the Federal Energy Regulatory
Commission. Comments from the Departments of Agriculture, Commerce,
and the Interior and the Federal Energy Regulatory Commission are
included in appendixes III through VI, along with GAO's responses.
Oral comments and other information were obtained from EPA officials
responsible for funding and carrying out nonpoint source
pollution-related activities. The agencies offered technical
corrections and clarifications on the draft report, which were
incorporated as appropriate. The Department of Defense indicated
that it concurred with the report's findings and, like the Department
of Transportation, chose not to provide specific comments on the
report. In addition to appendixes III through VI, the agencies'
comments are summarized in chapters 2, 3, and 4.
Of the five agencies providing comments, EPA, the Federal Energy
Regulatory Commission, and Interior provided overall reactions to the
report in addition to their specific comments. EPA said that the
report was factually correct and that it provided a good summary of
the current state of nonpoint source pollution that results from
federal land management and other activities. However, EPA disagreed
with GAO's recommendation that operation and maintenance costs for
nonpoint source pollution control efforts be included in the agency's
2000 "Needs Survey" report. The Commission agreed with the report's
major conclusions, saying that GAO made an "impressive effort in
presenting a very complex topic." Finally, Interior said it had
concerns with some of the findings in the draft. Interior's concerns
are discussed below along with the other agencies' specific comments.
EPA and the Departments of Agriculture and the Interior commented on
the information in chapter 2 concerning nonpoint source
pollution-related funding. Agriculture identified programs omitted
in the draft report that met GAO's criteria for inclusion (i.e.,
programs that either focus exclusively on nonpoint source pollution
or that devote at least $10 million annually to the problem). GAO
added information in the case of two programs for which Agriculture
provided the necessary funding data, but did not do so in the case of
one other because funding data were not provided. EPA indicated that
the information in this chapter was generally accurate, but officials
with the agency's Clean Water State Revolving Fund Program questioned
the nonpoint source pollution funding totals attributed to that
program. The officials cited in particular the complexity of
isolating the federal portion of the funds included in the program
because these funds are commingled with state matching funds and
funds from other sources. Supplemental information provided by these
officials led to a revised estimate, which GAO incorporated into the
report. Interior provided clarifications that were incorporated into
the report as appropriate.
EPA, the Department of Agriculture, and the U.S. Geological Survey
commented on the material in chapter 3 dealing with EPA's methodology
for estimating the nationwide cost of controlling nonpoint source
pollution. EPA acknowledged that GAO's assessment of the
cost-estimation methodology was factually accurate but disagreed with
the draft report's recommendation that operation and maintenance
costs for nonpoint source pollution control efforts be included in
the agency's Needs Survey report, to be issued in 2000.
Specifically, EPA said that including this information would
represent a major change in the scope of that particular report,
which focuses more specifically on the costs of construction of all
publicly owned treatment works in each state. For this reason, EPA
officials said that reporting this information might be more
appropriate in another report. GAO modified the recommendation,
noting that the primary concern was that the information on operation
and maintenance costs be developed and that the specific vehicle for
reporting the information was secondary. USDA's Agricultural
Research Service said that EPA's cost estimate should address
operating and maintenance costs.
The Agricultural Research Service and the Geological Survey supported
GAO's recommendation that EPA work with other agencies to develop a
watershed-based approach that can be used in developing more
realistic estimates of nonpoint source pollution control costs. The
Agricultural Research Service noted, in particular, that a watershed
approach is needed to accurately analyze nonpoint source pollution
because the degree of protection provided by natural barriers, such
as riparian zones, is specific to individual watersheds. In
addition, the Service pointed out that the effectiveness of using
various practices to control the movement of potential contaminants
can be markedly affected by site-specific conditions. The Geological
Survey added that it would be pleased to share information with EPA
and USDA concerning its own watershed-based modeling efforts.
The Departments of Agriculture and the Interior, as well as the
Federal Energy Regulatory Commission, commented on chapter 4's
discussion of federal activities that contribute to nonpoint source
pollution. The Forest Service and Interior cautioned that certain
figures, such as the percentage of land mass under federal ownership
and the number of acres devoted to grazing or other land uses, are
not necessarily accurate measures of the amount of nonpoint source
pollution attributable to federal activity. Agriculture's Natural
Resources Conservation Service added that the presentation in chapter
4 should recognize that proper management practices can mitigate the
types of impacts discussed. The studies GAO examined, together with
the data and other information GAO obtained from federal and state
officials it contacted, do in fact show that a significant proportion
of water quality problems have been linked, at least in part, to
activities occurring on federal lands. GAO acknowledges that the
degree of pollution in specific areas may depend on site-specific
characteristics such as geographic and hydrologic conditions, the
type of activities occurring and intensity of use, and management
practices applied to minimize impacts. Accordingly, as suggested by
the Forest Service, GAO modified language to characterize such
activities as "potential" contributors to nonpoint source pollution
where they have not been demonstrated to be "actual" contributors.
The Federal Energy Regulatory Commission commented that nonpoint
source pollution-related impacts can result from Commission-licensed
hydropower projects, but cautioned that in characterizing these
impacts, the report (1) carefully distinguish between the effects of
hydropower versus other activities that change the flow of water
(such as building dams for irrigation and modifying rivers for flood
control); (2) distinguish between Commission-licensed projects and
federally managed projects; and (3) recognize that hydropower is not
an original source of some of the impacts identified, but rather a
factor that can amplify the effects of other sources that contribute
nonpoint pollution. Regarding the first two points, GAO's draft did
recognize the distinctions identified by the Commission, but GAO also
made changes to the report to add further clarification. Regarding
the third point, GAO agrees that, in some instances, hydropower is
not technically the "source" of the pollution, although, as the
Commission points out, it may still be a contributor. In other
instances, however (such as situations where changes in temperature
or dissolved oxygen levels or increased downstream erosion result
directly from a project's operations), GAO noted that it is more
appropriate to characterize the project as an original source of the
pollution.
INTRODUCTION
============================================================ Chapter 1
Over a period of decades, federal laws and regulations have
established a process for the Environmental Protection Agency (EPA)
and states to regulate "point sources" of pollution. Point sources
are generally municipal and industrial facilities that discharge
pollutants via a point, such as a pipe or other conveyance, directly
to a body of water. EPA and the states issue permits to these
entities to put limits on the types and amounts of pollutants such
facilities can discharge. These laws and regulations have helped
clean up major water quality problems and reduce the amount of
pollutants directly discharged into surface waters.
However, many of the nation's waters are still not meeting water
quality standards.\1 For example, toxic algae, such as Pfiesteria
piscicida, which are associated with excessive amounts of nutrients
(chemical elements such as nitrogen and phosphorus) in waters in
Maryland, North Carolina, and Virginia, resulted in millions of fish
killed and adverse human health effects. Various pollutants have
also resulted in over 2,000 fish consumption advisories and more than
2,500 beach closings and advisories being issued in 1996 alone.
Overall, EPA reports that over one-third of the nation's waters that
were assessed by states are still impaired. Nonpoint sources of
water pollution, or diffused sources, have been identified as the
primary reason for these continued problems.
--------------------
\1 Waters that are not meeting water quality standards, regardless of
whether the sources of pollution are from point or nonpoint sources,
are also known as impaired waters.
NONPOINT SOURCES OF POLLUTION
ARE VARIED
---------------------------------------------------------- Chapter 1:1
Nonpoint sources of water pollution include a wide array of
land-based activities such as timber harvesting, grazing, urban
development, and agriculture. Figure 1.1 shows many such nonpoint
sources in a watershed setting.\2 Pollution comes from these
disparate sources via the process of rainwater, snowmelt, or
irrigation water moving over or through land surfaces. This results
in pollutants, either dissolved or solid, being transported and
eventually deposited into rivers, lakes, and coastal waters or
introduced into groundwater. Airborne pollutants, sometimes
transported long distances and then deposited in bodies of water, are
also considered a source of nonpoint pollution, as is polluted
groundwater which discharges into surface water. The types of
pollutants vary with the activity involved and include sediment,
nutrients, pesticides, pathogens (such as bacteria and viruses),
salts, oil, grease, toxic chemicals, and heavy metals.
Figure 1.1: Activities Within
a Watershed That Can Contribute
to Nonpoint Source Pollution
(See figure in printed
edition.)
Sediment is a common pollutant from many nonpoint-generating
activities and can impact water quality by contaminating drinking
water sources or silting in spawning grounds for certain aquatic
species. Another common group of nonpoint pollutants, nutrients, can
result in excessive plant growth and subsequent decaying organic
matter in water that depletes oxygen levels, thereby stressing or
killing other aquatic life. Pesticides, pathogens, and other toxic
substances associated with runoff from agriculture and other sources
can also be hazardous to human health and aquatic life. The severity
of any nonpoint impact is dependent on the amount of pollutants
actually reaching a body of water and the ability of receiving waters
to assimilate or transport those pollutants.
Nonpoint source pollution is much more difficult to track than point
source pollution. Because the sources are diffused, it is very
difficult to pinpoint the exact amount of pollutants coming from
individual sources, including that from natural sources of pollution,
particularly for pollutants such as sediment that may result from a
wide variety of activities and sources. In addition, control
practices vary in their effectiveness depending on many site-specific
characteristics such as soil type, topography, and climate. As a
result, there is much uncertainty in quantifying nonpoint source
pollution stemming from specific sources and tracking improvements
resulting from control practices.
--------------------
\2 A watershed is an area of land in which all surface water drains
to a common point. A watershed can range from less than 100 acres
that drain to a stream to many thousands of acres that drain through
hundreds of smaller streams to a large, single stream or river.
FEDERAL AND STATE
RESPONSIBILITIES FOR
CONTROLLING NONPOINT SOURCE
POLLUTION
---------------------------------------------------------- Chapter 1:2
The nature and extent of nonpoint source pollution is essentially a
function of the way individuals use the land. Therefore, regulating
these activities has been a sensitive issue since land use decisions
are largely made at the local level and influenced by state policies.
As a result, the Congress has left the actual control and regulation
of nonpoint source pollution up to the states while addressing the
importance of dealing with the problem in amendments to the Clean
Water Act in 1987. Specifically, section 319 of the Clean Water Act,
added in 1987, provides a limited federal role in addressing nonpoint
pollution. Under this section, EPA provides federal funds and
management and technical assistance to states to implement nonpoint
source management programs. In their nonpoint source assessments
completed in 1989, 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 the problems. In addition, section 6217 of the Coastal Zone Act
Reauthorization Amendments of 1990, administered jointly by EPA and
the Department of Commerce's National Oceanic and Atmospheric
Administration (NOAA), outlines a more rigorous process for states to
deal with nonpoint sources impacting coastal waters.\3 Section 6217
requires states to address significant sources of nonpoint pollution
from agriculture, forestry, urban areas, marinas, and
hydromodification. This program differs markedly from section 319 in
that states are required to include in their programs enforceable
policies and mechanisms to ensure that management measures to address
these sources are implemented.
In addition to section 319's explicit authorization of a federal
role, other agencies are authorized to encourage more environmentally
sensitive land use practices. For example, some federal programs use
a voluntary cost-share approach with private landowners to encourage
improved land use actions, particularly with regard to controlling
soil erosion and improving agricultural practices.
The Clean Water Act acknowledges that federal agencies are also
potential sources of nonpoint pollution via their facilities or
activities, or those issued permits or licenses by them, such as
grazing and timber harvesting. Therefore, the act includes
provisions whereby federal agencies are to ensure that their
activities are "consistent" with state nonpoint source pollution
management programs. States can judgmentally review certain federal
projects and activities to determine whether they conflict with the
states' nonpoint management programs. In accordance with procedures
outlined in an executive order regarding intergovernmental review of
federal programs, federal agencies are required to consult with the
states and make efforts to accommodate their concerns or explain
their decisions not to do so.\4
In February 1998, the administration proposed a new plan to address
the nation's remaining water quality problems.\5 Among the "Clean
Water Action Plan's" primary goals are to provide new resources to
communities to control nonpoint source pollution, strengthen public
health protection, and encourage community-based watershed protection
at high-priority areas. The Action Plan also recognizes the role
that federal land management agencies must play in protecting the
water resources on their lands as well as federal agencies' roles in
providing technical and financial assistance to states and private
entities to better deal with nonpoint source pollution.
--------------------
\3 This program also includes states that border the Great Lakes. 16
U.S.C. �1453.
\4 Executive Order No. 12372, "Intergovernmental Review of Federal
Programs", 47 Fed. Reg. 30959 (1982), reprinted as amended in 31
U.S.C. �6506 note.
\5 Clean Water Action Plan: Restoring and Protecting America's
Waters, U.S. Environmental Protection Agency and the U.S.
Department of Agriculture (Feb. 1998).
OBJECTIVES, SCOPE, AND
METHODOLOGY
---------------------------------------------------------- Chapter 1:3
The Chairman, Subcommittee on Water Resources and Environment, House
Committee on Transportation and Infrastructure, asked us to (1)
provide background information and funding levels for federal
programs that primarily address nonpoint source pollution (i.e.,
those programs identified as either focusing primarily on nonpoint
source pollution or that devote at least $10 million annually to the
problem); (2) examine the way EPA assesses the overall potential
costs of reducing nonpoint source pollution nationwide and
alternative methods for doing so; and (3) describe nonpoint source
pollution from federal facilities, lands, and activities that federal
agencies manage or authorize, or for which they issue permits or
licenses.
To address the first objective, we surveyed agencies to obtain
information on program purpose, key goals and objectives, program
funding and staffing levels, matching requirements, and opinions on
the potential impact of the Clean Water Action Plan. For relevant
Clean Water Act sections, we also included additional questions about
how EPA allocates funds across projects, regions, and states. We
pretested our survey with officials in the U.S. Department of
Agriculture (USDA), EPA, the Fish and Wildlife Service, and the Army
Corps of Engineers. In order to identify the most important nonpoint
source pollution programs, we asked agencies to respond to our survey
for programs meeting at least one of the following two criteria: (1)
program expenditures addressing nonpoint source pollution exceeded
$10 million for at least 1 year during fiscal years 1994 through 1998
or (2) the program primarily addressed nonpoint source pollution
regardless of program expenditures.
We sent survey instruments to over 100 programs that we identified
through our prior reports and agency background information and
discussions with agency officials at EPA; NOAA; and the Departments
of Agriculture, Defense, Energy, Interior, and Transportation. The
response rate for our survey was 100 percent.
For the second objective, we reviewed EPA's nonpoint source pollution
component of the Needs Survey, examining the analytical structure of
the models, the reasonableness of key assumptions, and the
completeness of data using standard economic and statistical
principles. We also interviewed EPA officials and contractor staff
responsible for developing and using the models and requested model
documentation. We interviewed EPA staff involved with the 1996
report as well as staff working on the report to be issued in 2000.
We consulted with experts in water quality modeling from EPA, USDA's
Natural Resources Conservation Service and the Economic Research
Service, and Interior's U.S. Geological Survey. We also reviewed
pertinent scientific literature to help identify alternative
methodologies for a conceptual framework for estimating nationwide
control costs.
For the third objective, we identified the primary federal agencies
that manage or authorize, or issue permits or licenses for,
activities or facilities that result in nonpoint source pollution by
interviewing officials at EPA; the Army Corps of Engineers; the
Federal Energy Regulatory Commission; and the Departments of
Agriculture, Defense, Energy, Interior, and Transportation. We
limited our investigation into nonpoint source pollution-generating
activities to those that are not regulated under EPA's point source
or stormwater permit requirements. For example, we excluded sources
such as construction sites larger than 5 acres or certain industrial
activities that must comply with stormwater runoff requirements to
address nonpoint source pollution.
Because quantitative data on federal agencies' nonpoint source
pollution contribution generally do not exist, we developed an array
of other indicators to help characterize agencies' possible
contributions. The primary factors were the extent of agency
involvement in nonpoint source-generating activities, the types of
impacts that result from the activities, circumstances that may
influence the impacts, and management practices that can minimize the
impacts. We developed these factors based on a review of scientific
research and discussions with federal and state officials. To
collect information on the factors, we interviewed a wide array of
agency officials, including headquarters program managers, research
scientists, and field staff, to understand the range of activities,
resulting water quality impacts, and management practices used. We
also reviewed scientific literature that described types and ranges
of impacts and results of management practices applied for specific
nonpoint source pollution-generating activities.
We interviewed water quality officials from five states with large
portions of federal land--Arizona, California, Colorado, Oregon, and
Utah--to understand how federal activities factored into state water
quality issues. We judgmentally selected these states from states
with at least 25 percent federal land in order to obtain information
on the types of nonpoint source pollution associated with a diverse
array of federal agencies. In addition, we obtained geographic data
from the U.S. Geological Survey describing the percentage of land
area owned by the federal government in watersheds across the
country. We did not verify the reliability of these data.
We conducted our work from February 1998 through January 1999 in
accordance with generally accepted government auditing standards. We
provided copies of a draft of this report to EPA; the Federal Energy
Regulatory Commission (FERC); and the Departments of Agriculture,
Commerce, Defense, Interior, and Transportation, for review and
comment. Agriculture, Interior, FERC, and NOAA provided written
comments. Their comments and our responses are included in
appendixes III through VI. EPA provided oral comments and other
information which we discuss at the end of chapters 2 and 3. Defense
and Transportation had no comments. We also provided relevant
sections of the draft report to representatives of each of the five
states included in our review to verify statements attributed to them
and other information they provided. We made revisions as
appropriate to incorporate their comments.
A DIVERSE ARRAY OF FEDERAL
PROGRAMS ADDRESS NONPOINT SOURCE
POLLUTION
============================================================ Chapter 2
As the nation's lead environmental organization, EPA implements a
number of significant programs to deal with nonpoint source
pollution. Other federal agencies, however, have also made
considerable investments in addressing the problem. USDA funding in
particular has eclipsed EPA's financial commitment by a significant
margin. Overall, the seven agencies we surveyed reported obligating
about $14 billion for fiscal years 1994 through 1998 on 35 programs
addressing nonpoint pollution.\1 Total obligations during this period
have been relatively stable--at about $3 billion each year--but
obligations at EPA in particular, increased significantly during this
period.\2 In February 1998, the administration proposed a plan
designed to more effectively address the nation's remaining water
quality problems. The Clean Water Action Plan proposed $568 million
in additional funding for fiscal year 1999, and a total increase of
$2.3 billion over the 5 years from fiscal years 1999 through 2003.
According to the Action Plan, many of its activities will augment
programs at EPA and a number of other agencies to deal with nonpoint
source pollution. Recognizing the interdisciplinary nature of the
problem, the plan also calls for closer cooperation and coordination
among these agencies.
--------------------
\1 We asked agencies to identify programs that either (1) had
expenditures addressing nonpoint pollution exceeding $10 million for
at least 1 year during fiscal years 1994 through 1998 or (2)
primarily addressed nonpoint pollution regardless of program
expenditures. Five of the seven agencies surveyed met one or both of
these criteria.
\2 Total obligations include the percentage of appropriated program
funds obligated to address nonpoint source pollution plus the
estimated dollar amount used for full-time staff, if reported by the
agency.
KEY FEDERAL PROGRAMS THAT
ADDRESS NONPOINT SOURCE
POLLUTION
---------------------------------------------------------- Chapter 2:1
The 35 federal programs identified by the agencies represent a broad
array of activities, reflecting diversity in both the nature of
nonpoint source pollution and the remedies needed to address it.
Some programs are intended to deal directly with the problem. EPA's
National Nonpoint Source Program, for example, provides financial and
technical assistance to help states develop their own nonpoint source
management programs and to fund specific projects. Other programs
are primarily focused on other objectives but indirectly serve to
address specific nonpoint source pollution problems. For example,
Interior's Abandoned Mine Land Program is intended primarily to
reclaim abandoned mines for health and safety reasons (e.g., to
address dangers such as open mine shafts), but in doing so
significantly addresses potentially contaminated stormwater runoff
from these facilities. A further distinction among these programs is
that some provide financial and technical resources to nonfederal
entities to address nonpoint source pollution such as providing
resources to farmers to implement certain land management practices,
while other programs are focused directly on addressing such
pollution on federal land. As figure 2.1 illustrates, USDA dominates
federal nonpoint source pollution obligations, with significant
financial commitments also made by EPA and Interior.
Figure 2.1: Obligations
Addressing Nonpoint Source
Pollution for Fiscal Years 1994
Through 1998, by Agency
(See figure in printed
edition.)
Notes: GAO's estimated total based on agencies' data is $14.2
billion (total and individual agency amounts may not add due to
rounding).
Many programs do not have specific nonpoint source pollution
objectives but address nonpoint pollution through other program
objectives.
EPA PROGRAMS
-------------------------------------------------------- Chapter 2:1.1
The primary EPA programs that fund nonpoint source pollution control
activities include the National Nonpoint Source Program and the Clean
Water State Revolving Fund Program (CWSRF). Overall, about $987.2
million was obligated for these programs to address nonpoint source
pollution for fiscal years 1994 through 1998. The Drinking Water
State Revolving Fund and the Chesapeake Bay programs also address
nonpoint source pollution although their portions of funding to do so
are significantly smaller than the National Nonpoint Source and CWSRF
programs. As requested, we also identified other programs authorized
by the Clean Water Act that address nonpoint source pollution in some
manner. The four other programs that we identified are focused
primarily on objectives other than nonpoint pollution, and
consequently, just a small amount of program funding went to nonpoint
pollution. Background and funding data on these programs are in
appendix I. Figure 2.2 shows the percentage breakdown of total
obligations for fiscal years 1994 through 1998 for EPA's programs.
Figure 2.2: EPA Obligations
Addressing Nonpoint Source
Pollution for Fiscal Years 1994
Through 1998
(See figure in printed
edition.)
Notes: GAO's estimated total based on EPA data is $1.15 billion
(total and individual program amounts may not add due to rounding).
Programs in the "other" category did not meet our criteria for
addressing nonpoint source pollution. An estimated $3.91 million was
obligated in four programs for fiscal years 1994 through 1998.
Obligations in the Drinking Water State Revolving Fund Program are
for fiscal year 1997 only.
The CWSRF Program tracks funds on a different fiscal year. Funds
reported are from July 1, 1994, through June 30, 1998.
NATIONAL NONPOINT SOURCE
PROGRAM
------------------------------------------------------ Chapter 2:1.1.1
Section 319 of the Clean Water Act established a national nonpoint
source program under which states (1) assessed the extent to which
nonpoint sources cause water quality problems and (2) developed
management programs to address these problems.\3 EPA was charged with
reviewing and approving these programs and is authorized to provide
grants to states for implementing their activities and programs.
Grants have been used for a wide variety of activities, including
technical assistance, financial assistance, education, training,
technology transfer, and demonstration projects. The funds also
support monitoring efforts to assess the success of specific nonpoint
source implementation projects.
EPA estimated that for fiscal years 1994 through 1998, the agency
obligated about $544 million to address nonpoint source pollution,
with obligations of $119 million in fiscal year 1998. According to
EPA, all states have approved nonpoint source control programs that
are helping to reduce nonpoint source loadings, increase public
awareness, and improve water quality. While the program's funding
was relatively stable during the 5-year period, its annual funding is
significantly higher than it was in prior years. In fiscal year
1990, for example, $38 million was appropriated for the program.
EPA uses a formula to allocate the states' share of the total federal
funding appropriated each year for these grants. The formula
considers each state's population, cropland acreage, pasture and
rangeland acreage, forest harvest acreage, wellhead protection
allotment (the acreage around a groundwater drinking source
designated for protection), critical aquatic habitat acreage, mining
acreage, and amounts of pesticides applied. The formula also
includes a set-aside for Indian tribes. Data used in the formula are
obtained from the national census, USDA and EPA data bases, and
background reports developed on related topics.
--------------------
\3 EPA also provides grants to tribes and other jurisdictions to
develop and implement nonpoint source management programs.
CLEAN WATER STATE
REVOLVING FUND PROGRAM
------------------------------------------------------ Chapter 2:1.1.2
EPA's Clean Water State Revolving Fund Program was established under
title VI of the Clean Water Act in 1987 to create, maintain, and
coordinate financial programs and partnerships to meet priority
community water resource infrastructure needs, primarily those
associated with wastewater treatment plants. Under the program, EPA
provides grants to capitalize states' funds. The states, in turn,
identify investment priorities allowed by the statute and manage the
loan program. As a condition of receiving federal funds, states
provide a matching amount equal to 20 percent of the total grant and
agree to use the money first to ensure that wastewater treatment
facilities are in compliance with deadlines, goals, and requirements
of the Clean Water Act (also known as the "first use" requirement).
In addition to federal and state matching funds, the revolving fund
is also funded by the issuance of bonds, interest earnings, and
repayments. According to EPA, federal funding currently accounts for
about one-half of total program funding. As loans are repaid, the
fund is replenished and loans are made for other eligible projects.
All states have met their priority needs and, therefore, may use
CWSRF funds to support programs to deal with nonpoint source
pollution and protect their estuaries. We reported in 1991 that only
two states were using their CWSRF funds to support nonpoint source
pollution projects.\4 Since then, however, states' reliance on the
CWSRF to fund nonpoint pollution-related activities has grown
considerably. According to EPA, 18 states currently use their CWSRFs
for this purpose. EPA is encouraging states to use CWSRF funds for
nonpoint source control and has set a goal to have 30 states doing so
by the end of the decade.
Other EPA goals for increasing CWSRF emphasis on nonpoint pollution
include ensuring that CWSRF funding decisions are made in a manner
that enables states to direct funds based on environmental
priorities--whether they be point or nonpoint in nature. Such a
strategy could be expected to place increasing emphasis on addressing
nonpoint pollution because most remaining water quality problems are
attributed to nonpoint sources. EPA has set a goal for 15 states to
be doing so by 1999. In addition, over the next 3 years, EPA plans
to increase the number and dollar amount of CWSRF loans annually for
polluted runoff control to 10 percent of all CWSRF funds loaned.
Figures provided by EPA show that federal CWSRF funds devoted to
nonpoint source pollution has increased significantly in recent
years. For example, figure 2.3 shows that funding for nonpoint
source pollution increased about 380 percent for fiscal year 1994
through fiscal year 1995.\5 EPA estimates that about $442.8 million
of the $7.1 billion appropriated to the program was devoted to
addressing nonpoint pollution for the 5 fiscal years included in our
study. Federal CWSRF funds to address nonpoint source pollution in
fiscal year 1998 was estimated at $96.3 million.
Figure 2.3 CWSRF Obligations
Addressing Nonpoint Source
Pollution for Fiscal Years 1994
Through 1998
(See figure in printed
edition.)
Source: Prepared by GAO from EPA's data.
According to EPA, it uses percentages provided by the Congress to
allocate funds to states after setting aside 1/2 percent of
appropriated funds for Indian tribes for wastewater treatment
purposes. The basis for state percentages include population and
documented wastewater treatment needs. In addition, 1 percent or
$100,000 (whichever is greater) is deducted from each state's
allotment for planning purposes--as required by section 604(b) of the
Clean Water Act.
--------------------
\4 Water Pollution: States' Progress in Developing State Revolving
Loan Fund Programs (GAO/RCED-91-87, Mar. 19, 1991).
\5 The CWSRF Program tracks funding based on a fiscal year running
from July 1 through June 30. Therefore, funds reported for CWSRF in
this report are for the period from July 1, 1994, through June 30,
1998.
THE DRINKING WATER STATE
REVOLVING FUND PROGRAM
------------------------------------------------------ Chapter 2:1.1.3
The Drinking Water State Revolving Fund Program (DWSRF) was
established by Congress under the Safe Drinking Water Act Amendments
of 1996 to help public water systems make infrastructure improvements
in order to comply with national primary drinking water standards and
to protect public health. Funds are distributed among states in
accordance with an allotment formula, with the condition that each
state receive a minimum of 1 percent of the funds available for
allotment. The allotment formula used for fiscal year 1998 reflects
the needs identified in the most recent Drinking Water Infrastructure
Needs Survey, the first of which was released in January 1997.
States are required to describe the use of funds awarded to them in a
plan that is distributed to the public for review and comment.
Fiscal year 1997 was the first year for DWSRF appropriations and the
program received $1.275 billion; $725 million was appropriated in
fiscal year 1998.
Under the DWSRF Program, states can use federal capitalization grant
money awarded to them to set up an infrastructure funding account
from which loans are made available to public water systems. In
addition to authorizing the infrastructure fund, the Congress placed
a strong new emphasis on preventing contamination problems through
source water protection and enhanced water systems management.
States have the flexibility to set aside up to 31 percent of their
capitalization grant to develop and implement programs that encourage
better drinking water systems operation to ensure a safer supply of
water for the public. The four broad set-aside categories for which
a state can choose to reserve funds are (1) administrative and
technical assistance (up to 4 percent), (2) state program management
(up to 10 percent and must be matched dollar for dollar), (3) small
systems technical assistance (up to 2 percent), and (4) local
assistance and other state programs (up to 15 percent and includes
primarily activities devoted to protecting drinking water sources
from contamination). According to EPA, states reserved approximately
21 percent of the fiscal year 1997 appropriation to fund set-aside
activities.
The local assistance and other state set-asides contain several
nonpoint source-related activities. For example, source water
protection activities, such as purchasing land as easements to reduce
the likelihood of ground water contamination, can help reduce the
generation of nonpoint source pollutants. In addition, in fiscal
year 1997, states could use this set aside to conduct source water
delineations and assessments. These activities identify the areas
around groundwater drinking water sources that must be protected to
avoid contamination and the possible sources of contamination. EPA
reported that 100 percent of the funds obligated for these
activities, $111.8 million, should be considered as addressing
nonpoint source pollution.\6 In addition to providing funding to
delineate and assess source water protection areas, the set-asides
made available by the DWSRF Program provide states with funds to
implement protection measures. These protection measures can address
all sources of contamination, which may include nonpoint sources.
EPA reports that the state program management and local assistance
and other state programs set-asides are the ones most likely to be
used for nonpoint source-related activities and can fund activities
such as education, loans to public water systems for the purchase of
land easements, and community tree planting.
--------------------
\6 According to EPA, the agency is not yet able to separate nonpoint
source pollution-related funding from fiscal year 1998 funds because
(1) the office does not yet have a tracking system in place to
determine how states use funds and (2) all states have not identified
how much funding will be used in each of the four set aside
categories.
CHESAPEAKE BAY PROGRAM
------------------------------------------------------ Chapter 2:1.1.4
The Chesapeake Bay Program, authorized by section 117 of the Clean
Water Act, is a unique regional partnership involving many different
constituencies, including federal, state and local agencies;
environmental groups; a citizens advisory group; and academia. The
program has been directing and conducting the restoration of the
Chesapeake Bay since 1983 and is focusing heavily on reducing levels
of nitrogen and phosphorus, which are key pollutants responsible for
degrading aquatic habitat and the Bay's productivity. EPA estimates
that about $52 million was obligated to address nonpoint source
pollution out of $101.4 million total program appropriations for
fiscal years 1994 through 1998.
EPA uses a formula to allocate about one-half of appropriated funds
to the key states in the Chesapeake Bay watershed--Virginia (30
percent), Maryland (30 percent), Pennsylvania (30 percent), and the
District of Columbia (10 percent). States must match federal funds
dollar for dollar. Funds may be used for various activities such as
(1) educating selected audiences on the importance of reducing
nonpoint source pollution, (2) preventing excessive livestock contact
with streams to reduce streambank erosion and direct nutrient
loadings, and (3) monitoring and tracking reduction of point source
nutrient loads. A competitive process is used to allocate remaining
program funds to specific projects.
OTHER EPA PROGRAMS
------------------------------------------------------ Chapter 2:1.1.5
A number of other EPA programs authorized by the Clean Water Act
address nonpoint source pollution although not necessarily as a
direct program objective. These include the National Wetlands
Program (section 104(b)(3)); the Water Pollution Control, State and
Interstate Program Support Program (section 106); the Clean Lakes
Program (section 314); and the National Estuary Program (section
320). These programs accounted for $3.9 million in nonpoint-related
obligations for fiscal years 1994 through 1998 and are discussed in
appendix I.
AGRICULTURE PROGRAMS
-------------------------------------------------------- Chapter 2:1.2
In the late 1980s and early 1990s, USDA began taking a dramatic shift
in emphasis on water quality issues because of adverse impacts of
agricultural production on water quality. In prior years, USDA's
water quality activities were limited in scope. In 1992, for
example, we reported that a small percentage of USDA funds were going
to water quality activities--about $62.5 million in fiscal year 1991
of $1.7 billion appropriated for 10 cost-share programs.\7 In
contrast, as shown in figure 2.4, USDA reported that the Conservation
Reserve and the Environmental Quality Incentives Programs devoted
almost $2 billion to nonpoint source pollution-related activities in
fiscal year 1998.
Figure 2.4: USDA Obligations
Addressing Nonpoint Source
Pollution for Fiscal Year 1998
(See figure in printed
edition.)
Notes: GAO's estimated total based on USDA data is $2.19 billion
(total and individual program amounts may not reconcile due to
rounding).
An estimated $245.8 million was obligated in 12 "other" programs in
fiscal year 1998. In addition to these programs, USDA provided
information, as this report was going to press, on the Wetland
Reserve Program showing $218.6 million in fiscal year 1998 funding.
While the program could not be reflected in this chart and several
other places in the report, a brief description of the program is
included in appendix II.
Most USDA programs do not have specific nonpoint source pollution
objectives, but help address the problem.
--------------------
\7 Water Quality: Information on USDA's Water Quality Cost-Share
Programs (GAO/RCED-92-139FS, Mar. 16, 1992). USDA's water quality
cost-share programs are programs that provided cost-share payments or
moneys to producers--generally, eligible farmers and ranchers--to
implement USDA-approved water quality activities on land.
CONSERVATION RESERVE
PROGRAM
------------------------------------------------------ Chapter 2:1.2.1
By far, USDA's largest source of funding for nonpoint pollution
activities is the Conservation Reserve Program, which accounted for
about 65 percent of all the federal funds identified in this report
obligated to address nonpoint source pollution for fiscal years 1994
through 1998. The program was established in 1985 and has several
objectives: reduce water and wind erosion, protect the nation's
long-term capability to produce food and fiber, reduce sedimentation,
improve water quality, create and enhance wildlife habitat, and
encourage more permanent conservation practices.\8 The program
encourages private land owners, such as farmers, to remove highly
erodible cropland or other environmentally sensitive acreage from
production and apply conservation measures to reduce and control
erosion and water quality impacts. USDA provides farmers with an
annual rental payment for the term of a multiyear contract for taking
the land out of production and cost-sharing benefits to apply the
necessary conservation measures.
Land may be enrolled in the Conservation Reserve Program by three
means: (1) a general signup, which competitively selects the most
environmentally sensitive land (most land is enrolled into the
program by this method); (2) a continuous noncompetitive signup of
highly desirable environmental practices such as filter strips (areas
of grass or other vegetation that filter runoff by trapping sediment,
pesticides, and other pollutants) and riparian buffers (areas of
trees and/or shrubs next to ponds, lakes, and streams that filter
pollutants from runoff as well as provide shade, food sources, and
shelter for fish and other wildlife); and (3) the Conservation
Reserve Enhancement Program,\9 which combines the resources of the
federal and state governments to address targeted environmental
concerns--such as the Chesapeake Bay. As of October 1998, there were
about 30 million acres enrolled in the Conservation Reserve Program.
According to USDA's response to our survey, while the Conservation
Reserve Program has no specific nonpoint source objectives,
"multiple, indistinguishable benefits for water quality, wildlife
habitat, air quality, and erosion control are achieved from all
acreage enrolled in CRP." For this reason, USDA officials explained
that 100 percent of the Conservation Reserve Program funds should be
considered as addressing nonpoint source pollution because all
activities carried out under the program involve land use practices
that help reduce nonpoint pollution. This amounted to approximately
$9.2 billion for fiscal years 1994 through 1998. Program funding in
fiscal year 1998 was estimated at $1.7 billion.
--------------------
\8 The program was established under title XII of the Food Security
Act of 1985, Pub. L. No. 99-198, 99 Stat. 1354 (Dec. 23, 1985).
\9 The program began in 1997. Since its inception, about $350,000
has been obligated to address nonpoint source pollution.
ENVIRONMENTAL QUALITY
INCENTIVES PROGRAM
------------------------------------------------------ Chapter 2:1.2.2
USDA's Environmental Quality Incentives Program (EQIP) was created by
the Federal Agriculture Improvement and Reform Act of 1996 and
combined several existing conservation programs--the Agricultural
Conservation Program (which includes Water Quality Incentives
Projects), the Colorado River Salinity Control Program, and the Great
Plains Conservation Program--into a single program.\10 The program
provides flexible technical, financial, and educational assistance to
private land owners, such as farmers and ranchers, who face serious
threats to soil, water, and related natural resources on their land,
including grazing land, wetland, forest land, and wildlife habitat.
This program provides cost-share assistance for up to 75 percent of
the cost of certain conservation practices such as filter strips,
manure management facilities, and wildlife habitat improvement.
The primary difference between this program and the Conservation
Reserve Program is that farmers do not retire land from production
under EQIP. Instead, farmers implement practices that minimize water
quality impacts that allow them to continue to use the land; and,
unlike the Conservation Reserve Program, EQIP provides cost-share
assistance and incentive payments that can be made for up to 3 years
to encourage producers to perform land management practices such as
nutrient, manure, and integrated pest management. The Conservation
Reserve Program, on the other hand, provides annual rental payments
for the land taken out of production and focuses on cropland and
marginal pasture land while EQIP focuses on a broader range of land
uses.
According to USDA, the agency obligated approximately $642 million
under this program for fiscal years 1996 through 1998. The agency
said that all of the funds addressed nonpoint source pollution,
noting that EQIP is intended to solely address nonpoint source
pollution from farms and ranches. Program funding to address
nonpoint source pollution in fiscal year 1998 was estimated at $232
million.
--------------------
\10 Pub. L. No. 104-127 (Apr. 4, 1996).
OTHER AGRICULTURAL
PROGRAMS
------------------------------------------------------ Chapter 2:1.2.3
USDA identified 12 additional programs that address nonpoint source
pollution. The environmental objectives of the programs vary,
ranging from improving scientific understanding of the nature of the
problem to direct efforts to reduce nonpoint pollution. The National
Research Initiative Competitive Grants Program, for example, provides
grants to increase the amount and the quality of science applied to
the needs of agriculture and forestry. From fiscal years 1994
through 1998, USDA estimated that about $28.8 million of the $456.3
million total appropriated program funding (plus full time
equivalents) was obligated to address nonpoint source pollution, with
about $5.2 million obligated in fiscal year 1998. The Watershed
Protection and Flood Prevention Program works with state and local
entities in planning and implementing watershed improvement projects,
such as promoting soil conservation or improving flood prevention.
USDA reported that almost 1,000 watershed projects receive funding.
In the past 5 fiscal years, this program has obligated about $433
million to address nonpoint source pollution.
Other USDA programs address such diverse objectives as measuring the
impact of farming systems on water quality, providing educational and
technical assistance programs for voluntary adoption of improved
management practices to enhance or protect water quality, and
enhancing wildlife habitat. Overall, these 12 additional USDA
programs accounted for $1.7 billion of the estimated $11.5 billion
USDA obligated to address nonpoint source pollution during the 5-year
period. These programs are discussed in appendix II. In addition,
the Forest Service noted that a portion of its budget supports
controlling nonpoint source pollution, but the agency does not track
it in a way that can be reported.
INTERIOR PROGRAMS
-------------------------------------------------------- Chapter 2:1.3
Within the Department of the Interior, programs related to nonpoint
source pollution include those administered by the Bureau of Land
Management, the Bureau of Reclamation, the U.S. Geological Survey,
the U.S. Fish and Wildlife Service, and the Office of Surface Mining
Reclamation and Enforcement. These agencies are involved in water
quality efforts because of their primary responsibilities, which
include ensuring adequate supplies of water for drinking and
agricultural purposes within arid locations of the United States,
protecting endangered and other trust species and wildlife habitat,
and reclaiming resources impaired by mining activities.
ABANDONED MINE LAND
PROGRAM
------------------------------------------------------ Chapter 2:1.3.1
Among Interior's programs, the Office of Surface Mining Reclamation
and Enforcement's Abandoned Mine Land (AML) Program provides the
greatest financial contribution toward addressing nonpoint source
pollution, accounting for nearly 45 percent of Interior's obligations
in the past 5 fiscal years. Created by the Surface Mining Control
and Reclamation Act of 1977, this program--mostly run by states with
approved programs--restores and reclaims coal mine sites that were
abandoned or left inadequately reclaimed before August 3, 1977.\11
Surface mining causes land disturbances that may result in erosion
and exposes minerals that can leach toxic chemicals, if left
inadequately reclaimed. While the act was set up to specifically
deal with coal mine reclamation, states can use funds to clean up
abandoned noncoal sites if all their abandoned coal sites have been
completed.
Interior collects fees from all active coal mining operations on a
per-ton-of-coal-mined basis, which are deposited into an interest
bearing Abandoned Mine Reclamation Fund. Expenditures from the fund
are authorized through the regular congressional budgetary and
appropriations process, and are used to pay the costs of AML
reclamation projects. Realizing that coal fees would not generate
the revenue needed to address every potential eligible site, the
Congress provided the states and Indian tribes with the flexibility
to decide which projects to fund.
The act specifies that 50 percent of the reclamation fees collected
in each state and Indian tribe with an approved reclamation program
be allocated to that state or tribe for use in its reclamation
program. Interior uses the remaining 50 percent for purposes such as
funding emergency and high-priority projects in states and Indian
tribes without approved AML programs, funding a federal abandoned
mine program in USDA, and providing financial assistance to small
coal operators (who produce less than 300,000 tons of coal annually).
According to agency officials in the Division of Reclamation Support,
about 90 percent of total program funds addressed nonpoint source
pollution problems. For fiscal years 1994 through 1998, this
amounted to approximately $626.3 million, or about $125 million each
year.
--------------------
\11 Pub. L. No. 95-87, 91 Stat. 445 (Aug.3, 1977). In 1990,
changes to the act extended eligibility to limited sites mined after
Aug. 3, 1977. Abandoned Mine Reclamation Act of 1990, Pub. L. No.
101-508, 6004, 104 Stat. 1388-289, 291 (Nov. 5, 1990).
OTHER INTERIOR PROGRAMS
------------------------------------------------------ Chapter 2:1.3.2
Interior identified 13 other programs that address nonpoint source
pollution. Environmental objectives for these programs vary from
efforts to directly control nonpoint pollution to efforts that
indirectly control the problem. For example, the Fish and Wildlife
Service's Clean Vessel Act Pumpout Grant Program directly addresses
nonpoint source pollution by significantly reducing the amount of
sewage discharged from boats. According to the Service, for fiscal
years 1994 through 1998, $40 million was awarded in grants to states
to fund the installation of pumpout and dump stations for land-based
disposal of vessel sewage. On the other hand, the Fish and Wildlife
Service's Partners for Fish and Wildlife Program indirectly addresses
nonpoint source pollution by restoring habitat such as providing
native, diverse riparian habitat (areas alongside rivers, lakes, and
ponds) for certain migratory birds and aquatic species. These
efforts help reduce nonpoint pollution by providing vegetation along
bodies of water, which helps slow stormwater runoff and trap
pollutants such as sediments and nutrients. In addition, several
Bureau of Land Management programs obligate funds that address
nonpoint source pollution on federal lands through a variety of
objectives, such as enhancing riparian habitat and managing
rangelands to protect water quality.
Other program objectives include controlling salinity in the Colorado
River and recording long-term spatial and temporal trends in
atmospheric deposition. The remaining 13 programs accounted for
about $810.7 million of Interior's total estimated $1.4 billion
obligated to address nonpoint source pollution over the past 5 fiscal
years. These programs are discussed in appendix II.
OTHER FEDERAL PROGRAMS
-------------------------------------------------------- Chapter 2:1.4
In addition to the EPA, USDA, and Interior programs, a few other
programs were identified at the Departments of Commerce and Defense
that target nonpoint source pollution problems either directly or
indirectly. These programs accounted for a very small portion, less
than 1 percent, of overall federal obligations on nonpoint source
pollution for fiscal years 1994 through 1998. In addition, some
agencies such as those at the Departments of Defense and
Transportation spend significant funds to control certain classes of
nonpoint source pollution that are regulated under EPA's stormwater
permit program that also address other nonpoint sources in the
process. However, these expenditures were not captured in our
review.
One program, administered by NOAA, is the Coastal Zone Management
Program created under the Coastal Zone Management Act of 1972.\12 The
program is a voluntary partnership between the federal government and
U.S. coastal states and territories that is intended to preserve,
protect, develop, and where possible, restore and enhance the
nation's coastal resources. The statute also encourages the
preparation of special area management plans that specify how
significant natural resources are to be protected and promote
reasonable coastal economic growth, improved protection of life and
property in hazardous areas, and improved predictability in
government decision making. NOAA estimated that of the $229 million
total appropriated funding, it obligated approximately $23.8 million
(including full time equivalents) for fiscal years 1994 through 1998
to address nonpoint source-related problems.
A second program, co-administered by NOAA and EPA, is the Coastal
Nonpoint Pollution Control Program, authorized by section 6217 of the
Coastal Zone Act Reauthorization Amendments of 1990. The amendments
require states and territories to develop and implement coastal
nonpoint pollution control programs. Once approved, these programs
are to be implemented through changes to the state nonpoint source
program approved by EPA under section 319 of the Clean Water Act and
through changes to the state coastal zone management program. To
help states develop their programs, EPA published management measures
for several categories of nonpoint pollution sources, such as
agriculture, urban, forestry, marinas, and hydromodification, that
lay out possible controls for reducing pollution from these sources.
NOAA estimated that it obligated 100 percent of appropriated funds
(plus full time equivalents)--$12 million for fiscal years 1994
through 1998--to address nonpoint source pollution.\13
The Department of the Army reported that its Integrated Training Area
Management Program integrates Army training and other mission
requirements for land use with natural resource management practices
at Army installations used for training programs. The practices are
directed at repairing existing damage to land and preventing future
environmental compliance problems. The program provides a process
for surveying and monitoring natural resource conditions, integrating
training requirements with land condition status, and rehabilitating
and repairing damaged areas. The program also provides environmental
awareness training. For fiscal years 1996 through 1998, Army
officials estimated that $50.4 million of the $95.1 million in total
appropriated funding was obligated to address nonpoint source
pollution.
Defense officials noted that the Department spends the necessary
resources addressing stormwater runoff from its facilities. While
many of these activities respond to specific industrial stormwater
permit requirements such as controlling runoff from an aircraft
maintenance facility, the officials told us that they often also
address other nonpoint sources as well. For example, Defense
officials told us that in dealing with a stormwater permit
requirement (which may include preventing pollutants from entering
into a waterway or municipal stormwater system), they will often
incorporate runoff from nearby areas that would have otherwise
remained as an uncontrolled nonpoint source. This consolidates
stormwater runoff and helps reduce the volume of uncontrolled runoff
from these facilities. Defense did not report obligations for
projects such as this, however, since funds to address nonpoint
pollution were combined with stormwater permit requirements and could
not be separated easily.
Similarly, a significant amount of the Department of Transportation's
funding is devoted to minimizing the impacts from highway
construction and operation through the Surface Transportation Fund.
For example, Transportation reported that about $288 million of these
funds were obligated in fiscal year 1998 to address stormwater
runoff. However, the majority of these funds were identified as
primarily addressing runoff from road and highway construction
projects that must meet stormwater permit requirements and thus, are
not discussed in this report. Some funds are eligible for specific
nonpoint control projects such as retrofitting roads with detention
ponds or vegetated buffers to better deal with runoff and minimize
water quality impacts. A Transportation official reported that
expenditures for these types of projects probably did not exceed our
$10 million threshold and like the Department of Defense would be
difficult to separate out from other program obligations.
--------------------
\12 Pub. L. No. 92-583, 86 Stat. 1280 (Oct. 27, 1972), 16 U.S.C.
1451-1465.
\13 No funds were appropriated to this program in fiscal years 1996
and 1997. Funds reported during these years were for full-time staff
that were used to address nonpoint source pollution. In addition, $1
million of the program's funding was provided by EPA in fiscal year
1998.
CLEAN WATER ACTION PLAN TO
FURTHER ADDRESS NONPOINT SOURCE
POLLUTION
---------------------------------------------------------- Chapter 2:2
In October 1997, the Vice-President directed EPA and USDA to work
with other federal agencies and the public to develop a Clean Water
Action Plan. The plan, issued in February 1998, acknowledged the
progress that had been made in past decades by focusing largely on
point sources of pollution, but maintained that additional steps--and
a more holistic approach--were needed to improve progress toward
achieving the nation's water quality goals. Specifically, the plan
emphasizes the need to identify and address the major pollution
sources affecting entire watersheds, whether they be from point
sources, nonpoint sources, or a combination of the two. The plan
proposes an increase in federal water quality spending of over $2.3
billion during the next 5 fiscal years. The plan also proposes to
focus federal dollars on priority problems by increasing coordination
among the many federal agencies involved in this issue.
The plan recognizes the increased importance of nonpoint source
pollution in explaining the problems affecting many watersheds,
noting that "polluted runoff is the greatest source of water quality
problems in the nation today." Accordingly, much of the plan, and a
significant portion of funding under the plan, focuses on this
problem. The Congress appropriated full funding of EPA's proposed
increases under the Action Plan. Of particular note, the plan nearly
doubles the size of the state grants provided under EPA's National
Nonpoint Source Program from its fiscal year 1998 funding of $105
million to $200 million in fiscal year 1999.
However, not all agencies received funding increases. For example,
the plan proposed increasing the funding for USDA's Environmental
Quality Incentives Program by 50 percent, from $200 million in fiscal
year 1998 to $300 million in fiscal year 1999. Instead, the fiscal
year 1999 budget decreased the funding by $26 million, to $174
million in fiscal year 1999. Also, the plan proposed an increase of
$36 million for the Army Corps of Engineers, but none of these
additional funds were appropriated.
AGENCY COMMENTS
---------------------------------------------------------- Chapter 2:3
The Department of Agriculture's Natural Resources Conservation
Service (NRCS) and Agricultural Research Service (ARS) each noted the
omission of certain programs in this chapter. Specifically, NRCS
cited the Wetlands Reserve Program and the Forestry Incentives
Program, and ARS cited certain research activities as programs that
should be added. We included programs in this chapter and appendix
II based on information we received from agency officials who were
asked to identify programs that addressed nonpoint source pollution
meeting our criteria (e.g., programs that primarily focused on
nonpoint source pollution or programs that spent at least $10 million
a year addressing nonpoint source pollution regardless of program
focus). We added information provided by USDA on the Wetland Reserve
Program and ARS' Water Quality/Research, Development, and Information
Program in appendix II. We did not include information on the
Forestry Incentives Program because program and funding data were not
provided.
Interior's Office of Surface Mining also commented on this chapter.
The office said that while it did not disagree with the data
presented, it could not verify the estimate of percent of resources
going to nonpoint source pollution for the AML Program. The data we
reported were obtained from the agency's response to our survey on
the program and subsequent information provided by the Division of
Reclamation Support. We clarified this point by providing specific
attribution to the information in the report.
EPA indicated that the information in this chapter was generally
accurate, but officials with the agency's CWSRF Program questioned
the nonpoint source pollution funding totals attributed to that
program. The officials cited in particular, the complexity of
isolating the federal portion of the funds included in the program
because these funds are commingled with state matching funds and
funds from other sources. Supplemental information provided by these
officials led to a revised estimate, which we incorporated in the
report.
EPA'S METHODOLOGY FOR ESTIMATING
NONPOINT SOURCE POLLUTION CONTROL
COSTS COULD BE IMPROVED
============================================================ Chapter 3
The Clean Water Act requires EPA to report periodically to the
Congress an estimate of the costs of carrying out the provisions of
the act. In addressing this requirement, EPA reported in 1997 that
the nationwide cost of controlling selected sources of nonpoint
source pollution would be $9.4 billion (in 1996 dollars).\1 The
estimate represents the capital costs that farmers and others might
incur in applying best management practices and other measures to
control run off from agriculture, silviculture, and certain animal
feeding operations. Although EPA's study represents one of the few
attempts to estimate control costs nationwide, EPA officials
acknowledge that their methodology has several limitations.
Specifically, the methodology (1) does not include some potentially
significant nonpoint sources of pollution and (2) includes capital
costs associated with best management practices to address nonpoint
source pollution but does not include the potentially significant
costs of operating and maintaining these practices in subsequent
years.
EPA officials told us they are considering an additional approach to
estimate nonpoint source control needs. Of particular note, the
officials said that they are considering whether to develop a
"watershed-based approach" that could better take into account the
unique characteristics of individual watersheds. Such an approach
would likely provide a more realistic estimate of the nation's
nonpoint source pollution control needs. The officials noted,
however, that resource shortages were constraining the effort.
--------------------
\1 1996 Clean Water Needs Survey Report to Congress, U.S.
Environmental Protection Agency, (Sept. 1997). The last Needs
Survey report was issued in 1992.
CLEAN WATER ACT REQUIRES EPA TO
REPORT TO THE CONGRESS ON WATER
QUALITY PROJECT NEEDS
---------------------------------------------------------- Chapter 3:1
Under the Clean Water Act, EPA is required to report to the Congress
every 2 years on the estimated cost of carrying out the provisions of
the act. Historically, EPA's report, known as the Clean Water Needs
Survey, has focused on estimating the costs of construction, or
capital costs, of all needed publicly owned treatment works (e.g.,
waste water treatment plants) which are funded under the CWSRF.
However, as reported in chapter 2, with increased emphasis on
nonpoint source pollution, states are able to use CWSRF funds for
nonpoint source control projects. As a result, EPA began also
estimating the capital costs associated with controlling several
types of nonpoint sources of pollution. According to EPA, the
report, in addition to informing the Congress on water project needs,
can help the states and EPA plan how they will attain and maintain
Clean Water Act goals by giving them a comprehensive picture of the
projects and other activities necessary to meet water quality
standards.
To estimate wastewater treatment needs, EPA has relied on the states
to document their capital needs. Because few states had
systematically documented their nonpoint source control needs,
however, EPA had to develop a methodology for estimating the capital
costs to control nonpoint source pollution nationwide. The
methodology estimates (1) the number of possible nonpoint sources for
three categories of sources--agriculture, silviculture, and animal
feeding operations--\2 and (2) the cost of applying best management
practices to those sources. EPA estimated just the capital costs
associated with these sources.\3 The annual costs that might be
required to operate and maintain the practices are not included.\4
To estimate the cost of controlling soil erosion associated with
agricultural activities, EPA used data from USDA's 1992 National
Resources Inventory database to identify agricultural lands within
each state requiring erosion control. The database, which is
compiled by USDA every 5 years, includes information on farming
activity, soil erosion, and current soil conservation practices for a
sample of acres within each state. On those agricultural lands
requiring erosion control, EPA assumed best management practices
would be applied to reduce erosion, with the least costly measure
selected first. In addition to the best management practices, EPA
assumed that farmers would develop water quality management plans to
help them manage the application of fertilizers and pesticides that
can also run off and cause water quality problems. The capital costs
associated with applying both the conservation measures and
developing the water quality management plans were aggregated by
state, and a nationwide cost estimate was calculated. Nationwide
costs for controlling agricultural nonpoint pollution were estimated
to be $3.8 billion in 1996.
Similarly, to model the needs for silviculture, EPA estimated the
capital costs associated with applying best management practices on
harvested sites on privately owned forest lands in the United States
using data from USDA's 1992 Forestry Resources of the United States.
Federal lands were not considered because these lands are not
eligible for funding under CWSRF. EPA used information from its 1992
economic analysis of the Coastal Zone Act Reauthorization Amendments
of 1990 (CZARA) to identify best management practices that could be
applied to forest lands.\5 These practices included controlling
erosion from timber access roads, stabilizing streambanks near
harvest sites, and ensuring re-vegetation of harvested sites. The
capital costs associated with implementing the best management
practices were aggregated by state, and a nationwide estimate was
derived by adding the state values. Overall, EPA estimated that the
capital costs associated with controlling runoff from silvicultural
activities on private forest lands nationwide would be about $3.5
billion in 1996.
To model the needs associated with controlling animal waste runoff
from animal feeding operations, EPA estimated the number of
operations in each state using data from USDA's 1992 Census of
Agriculture. EPA assumed that each feeding operation would require a
nonpoint source management plan for reducing contaminated runoff, and
that none of the existing feedlots had any best management control
practices already in place. The estimated cost of developing the
nonpoint source management plan and the cost of implementing best
management practices to reduce runoff represent the cost of
controlling nonpoint source pollution at these sites. Overall, EPA
estimated that the cost of controlling runoff from these feeding
operations nationwide was about $2.1 billion in 1996.
As depicted in table 3.1, EPA's estimate of $9.4 billion for
controlling nonpoint source pollution represents the sum of the costs
for the three categories of nonpoint sources. The 1996 estimate
represents a slight decrease from the 1992 estimate of $10 billion,
primarily reflecting, according to EPA, a decline in the number of
animal feeding operations.\6
Table 3.1
Estimated Capital Expenditures for
Controlling Nonpoint Source Pollution
Nationwide
(Dollars in billions (1996))
Needs category 1992 Survey 1996 Survey
------------------------------ ------------------ ------------------
Agriculture $ 4.2 $3.8
Silviculture 2.7 3.5
Animal feeding operations 3.1 2.1
Total $10.0 $9.4
----------------------------------------------------------------------
Source: EPA.
--------------------
\2 Animal feeding operations contain fewer than 1,000 animal units
(an animal unit is a unit of measurement for comparing different
animals). Large animal feeding operations, called concentrated
animal feeding operations, can be regulated as point sources under
the Clean Water Act and, therefore, would not be eligible for funding
under CWSRF.
\3 Capital costs are the upfront costs that farmers and others would
incur in implementing best management practices and other measures on
their land.
\4 EPA's methodology also does not account for certain opportunity
costs like the social welfare losses that might be associated with
reducing nonpoint source pollution nationwide. For example, removing
highly erodible cropland from production would reduce the amount of
land available for growing crops, all else the same, and increase the
price of certain agricultural goods. In response, consumers might
reduce their consumption of these goods which would represent a
social welfare loss. It is possible, however, that these losses
would be outweighed by the benefits associated with reducing nonpoint
source pollution.
\5 Regulatory Impact Analysis: Management Measures Guidance for
Nonpoint Source Controls in Coastal Watershed Areas, U.S.
Environmental Protection Agency, (Dec. 28, 1992).
\6 EPA states that this reflects a trend toward larger concentrated
animal feeding operations.
EPA'S METHODOLOGY HAS SEVERAL
LIMITATIONS
---------------------------------------------------------- Chapter 3:2
EPA officials acknowledge that their methodology has several
limitations, including the omission of (1) the cost of controlling
runoff associated with other potentially significant sources of
nonpoint source pollution such as abandoned mines and (2) the cost of
operating and maintaining the best management practices implemented
to control pollution. In addition, the methodology does not assess
and disclose a range of uncertainty associated with its single-point
control cost estimate, and does not include sufficient documentation
of its cost-estimation methodology so that reviewers could compare
its underlying assumptions and data with published sources (and
thereby more easily assess the reasonableness of its results).
METHODOLOGY DOES NOT INCLUDE
OTHER POTENTIALLY
SIGNIFICANT NONPOINT SOURCES
-------------------------------------------------------- Chapter 3:2.1
As EPA acknowledges in its 1996 Clean Water Needs Survey report, the
methodology considers only selected sources of nonpoint source
pollution--agriculture, silviculture, and animal feeding operations.
Many other sources of nonpoint pollution contribute to water
pollution and therefore may require some controls in order to meet
Clean Water Act goals. These sources include abandoned mines,
atmospheric deposition, hydromodification, and marinas and urban
areas not required to have a stormwater permit. In addition,
federally authorized activities on federal lands such as
silvicultural operations are not included since they are not eligible
for CWSRF funds. As a result, only a portion of the total costs that
would be associated with controlling nonpoint source pollution
nationwide are included.
Other studies indicate that runoff from other sources can be
significant. For example, in its 1994 analysis of President
Clinton's Clean Water Initiative, EPA estimated that there were
15,000 to 50,000 abandoned mine sites on federal lands causing water
quality problems. The estimated cost to remediate these sites ranged
from $330 million to $1.1 billion per year, in 1993 dollars ($354
million to $1.2 billion in inflation-adjusted 1996 dollars).\7
Furthermore, data aggregated by the Office of Surface Mining from
state estimates show that abandoned mines on private lands would cost
a total of an additional $2.6 billion to reclaim. EPA officials
stated that other categories of nonpoint sources were not included
because of a lack of nationwide information.
--------------------
\7 President Clinton's Clean Water Initiative: Analysis of Benefits
and Costs, U.S. Environmental Protection Agency, (Mar. 1994).
METHODOLOGY DOES NOT INCLUDE
COSTS OF OPERATING AND
MAINTAINING BEST MANAGEMENT
PRACTICES
-------------------------------------------------------- Chapter 3:2.2
EPA also acknowledged that its methodology does not account for the
annual operating and maintenance (O&M) costs that farmers and others
might incur in implementing best management practices and other
management measures to control erosion. As a result, only a portion
of the total cost that might be associated with implementing best
management practices is accounted for. In developing cost estimates
for controlling runoff from croplands, for example, EPA assumed that
farmers would develop water quality management plans to help them
manage the application of fertilizers on their fields. The capital
costs farmers would incur to develop these plans are included in
EPA's cost estimate. However, farmers might also incur annual costs
such as those associated with testing the soil to determine whether
they are meeting the goals of the management plan.
EPA has omitted operating and maintenance costs because the Needs
Survey has historically been focused on projects that can be funded
under CWSRF, and O&M costs are not eligible for these funds.
However, EPA officials acknowledge that they are not limited to
including just capital costs in their report, and that accounting for
O&M would (1) provide a more complete picture of the nation's needs
for controlling nonpoint source pollution and (2) make the Needs
Survey a more useful tool for EPA and the states in planning how they
will attain and maintain Clean Water Act goals. EPA officials told
us that they will allow states to report nonpoint source control O&M
costs, but that the Needs Survey will continue to report only the
capital costs eligible for CWSRF funding.
EPA'S METHODOLOGY DOES NOT
FULLY ASSESS THE UNCERTAINTY
ASSOCIATED WITH ESTIMATING
CONTROL COSTS
-------------------------------------------------------- Chapter 3:2.3
In developing the cost estimates, EPA did not fully assess the
uncertainty that is associated with the underlying assumptions and
data used in the analysis. Accordingly, EPA's 1996 Clean Water Needs
Survey report presents the control costs for each source category as
single point estimates. Such a presentation, however, implies a
level of precision that may not be warranted given the limited
information behind the data and assumptions. EPA officials
acknowledge that the $9.4 billion cost estimate is subject to a range
of uncertainty although they did not calculate it.
In other studies, EPA has assessed uncertainty and presented its
estimates as a range of values. For example, in its 1992 economic
assessment of management measures developed in accordance with the
CZARA, EPA estimated that the cost of controlling nonpoint source
pollution in coastal areas throughout the United States would range
from about $390 million to $591 million per year, in 1992 dollars
(about $449 million to $681 million in 1996 inflation-adjusted
dollars). In addition, in its 1994 economic assessment of President
Clinton's 1994 Clean Water Initiative, EPA estimated that the costs
associated with implementing nonpoint management programs on
agricultural lands across the United States would range from about
$595 million to $985 million per year, in 1993 dollars (from about
$638 million to $1.1 billion in 1996 inflation-adjusted dollars).
COST ESTIMATION METHODOLOGY
IS NOT FULLY DOCUMENTED
-------------------------------------------------------- Chapter 3:2.4
We found it difficult to thoroughly evaluate EPA's methodology
because it did not fully document the key assumptions and data used
in its analysis. Consequently, we were unable to compare these
assumptions and data with published sources to assess their
reasonableness. For example, to estimate the cost of erosion control
on cropland acres, EPA used estimates of the cost of applying various
soil conservation practices. According to EPA officials, the cost
data were obtained from USDA's Fiscal Year Statistical Summaries
(1989-1995). Without documentation, however, we could not verify
that the data were obtained from the publications cited, or whether
they are reasonable in comparison to other published sources.
WATERSHED-BASED APPROACH OFFERS
A PROMISING ALTERNATIVE TO
ESTIMATE CONTROL COSTS
---------------------------------------------------------- Chapter 3:3
Addressing the limitations mentioned previously can improve EPA's
cost estimation methodology and resulting cost estimate, but the
agency is also considering an additional approach that would take
into account the unique characteristics of individual watersheds.
Agency officials indicated, however, that the added cost of this
"watershed-based approach" could constrain such an effort. A USDA
official involved in similar work suggests that improved coordination
between EPA and this agency could help advance EPA's effort.
CURRENT METHODOLOGY DOES NOT
ACCOUNT FOR UNIQUE
CHARACTERISTICS OF
WATERSHEDS
-------------------------------------------------------- Chapter 3:3.1
EPA's current methodology relies primarily on data collected on a
countywide or statewide basis--data that were collected along
political boundaries rather than watershed boundaries. The practical
effect of this limitation is that the effects of the unique
characteristics of individual watersheds are not taken into account
in estimating either pollution levels or the costs of controlling
them. For example, to estimate nonpoint source runoff from
croplands, EPA used information on soil erosion and productivity to
estimate soil runoff from croplands within each state.\8 However,
this may not accurately represent the soil that actually enters a
waterbody because it measures soil runoff only to the edge of the
farm field, and not whether a water quality problem exists.
The extent to which soil runoff actually enters a body of water and
impairs water quality can vary across watersheds, depending on
factors like the proximity of land use activities to a waterbody,
soil type, slope, the duration and intensity of rainfall, vegetative
cover, and the environmental sensitivity of the water resource.
EPA's methodology does not take these factors into account and
essentially results in estimating costs to apply best management
practices to agricultural activities that result in soil runoff,
rather than on activities that explicitly affect water quality. In
contrast, a watershed-based approach allows the consideration of
unique characteristics of watersheds that influence the extent to
which runoff from a field or other source enters a waterbody or
underlying aquifer and impairs water quality.
According to EPA, such an approach can also develop information that
can help states plan more cost-effective water pollution control
strategies. In its 1996 Clean Water Needs Survey report to the
Congress, EPA stated that, reporting needs on a watershed basis would
enable states "to assess both the point and nonpoint pollution
sources in the watershed, and to address them in the most
cost-effective way."
--------------------
\8 Soil runoff is defined as soil loss in excess of the amount needed
to maintain the productivity of the soil to grow crops.
OTHER AGENCIES HAVE MADE
PROGRESS IN DEVELOPING AND
USING A WATERSHED APPROACH
-------------------------------------------------------- Chapter 3:3.2
EPA officials told us that a significant barrier impeding the use of
a watershed-based approach is the additional resources the approach
would require. The officials said that developing a watershed-based
model to estimate nonpoint source pollution costs could cost about
$750,000, compared with the $25,000 it costs to update and run the
existing model. Research activities underway at other agencies,
however, could facilitate EPA's effort.
Researchers at USDA's Natural Resources Conservation Service have
developed a nationwide, watershed-based methodology to assist
decisionmakers in identifying priority watersheds for water quality
protection from agricultural nonpoint source pollution.\9 Using
primarily the National Resources Inventory database and factors such
as precipitation and agricultural chemical use, the researchers
assessed the potential for these contaminants to leach into an
underlying aquifer or run off into a body of water. Those watersheds
having a high potential for a combination of pollution sources (e.g.,
chemical and soil loss) were identified as candidates for
conservation programs to reduce nonpoint source runoff. Although the
methodology does not assess whether the runoff enters a body of water
and impairs water quality, it goes further than EPA's current
methodology toward linking sources of nonpoint source runoff and
water quality impairments by identifying those watersheds that are
most vulnerable to water pollution. In addition, the research
suggests that a more cost-effective reduction in nonpoint source
pollution could be achieved by targeting public investments on
conservation measures in specific high-priority watersheds.
Researchers at the U.S. Geological Survey (USGS) developed a
different watershed-based approach. Their methodology statistically
correlates water quality conditions to possible sources--point
sources, applied fertilizers, livestock waste, runoff from
nonagricultural land, and atmospheric deposition of nitrogen--and
watershed attributes that affect contaminant transport (such as soil
permeability and precipitation). This approach allows for prediction
of contaminant concentrations at specific locations, as well as,
characterizing regional water quality. USGS has used its approach to
model nitrogen and phosphorus transport, and is finalizing results of
an application which assessed the most cost-effective approach to
applying controls to point and nonpoint sources to reduce nitrogen
and phosphorus loadings in coastal areas. The USGS model could be
useful for EPA's purposes in that it would allow for the development
of nonpoint source control cost estimates that focus on sources that
are linked to water quality problems.
Our contacts with researchers at USDA and USGS suggest that a
watershed-based methodology would likely yield a more realistic
estimate of nonpoint source control costs than one based on EPA's
current methodology. An official at USDA asserted that EPA's efforts
could benefit from watershed-based modeling research at USDA and
other agencies. EPA officials indicated that they were not aware of
the efforts at USDA and USGS but in discussions with us, agreed that
it would be useful to learn more about these efforts.
--------------------
\9 See Potential Priority Watersheds for Protection of Water Quality
from Nonpoint Sources Related to Agriculture, Robert L. Kellogg,
Susan Wallace, and Klaus Alt. Poster presentation at the 52nd Annual
Soil and Water Conservation Society Conference, 1997.
CONCLUSIONS
---------------------------------------------------------- Chapter 3:4
As noted in this chapter, a number of improvements can and should be
made to EPA's methodology for estimating the cost of controlling
nonpoint source pollution in order to increase its comprehensiveness
and to ensure that its process and results can be reviewed and
understood. In addition, EPA's consideration of another
cost-estimation strategy that relies on a "watershed-based approach"
has the potential to provide a more realistic cost estimate. Such an
approach also has the potential to serve as a tool for identifying
and prioritizing watersheds most likely to have water quality
problems and potentially where the most cost-effective use of
resources could be applied to reduce nonpoint source pollution. It
is unclear whether EPA will pursue this approach in its next Needs
Survey report, given the resources that would be required to do so.
However, working with USDA and USGS could provide lessons learned,
data sources, and modeling approaches, that would help shift EPA's
nonpoint source pollution control cost-estimation methodology in this
constructive direction.
RECOMMENDATIONS
---------------------------------------------------------- Chapter 3:5
To improve EPA's approach toward estimating the cost of controlling
nonpoint source pollution, we recommend that the Administrator of EPA
direct the Office of Water to
-- address key limitations in its approach and presentation of the
methodology and its results by (1) including the costs of
operating and maintaining best management practices, (2)
assessing and disclosing the range of uncertainty associated
with its control cost estimate, and (3) more fully documenting
its cost estimation methodology and
-- work with researchers at USDA and USGS to obtain lessons
learned, data sources, and modeling approaches to help advance
EPA's own efforts to develop a watershed-based cost-estimation
approach.
AGENCY COMMENTS
---------------------------------------------------------- Chapter 3:6
EPA acknowledged that our assessment of the cost-estimation
methodology is factually accurate, but disagreed with the
recommendation in our draft that operation and maintenance costs for
nonpoint source pollution be included in the next Needs Survey report
to be issued in 2000. Specifically, the agency said that including
this information would represent a major change in the scope of the
report as required by section 516(b)(1)(B) of the Clean Water Act,
which requires EPA to report on the costs of construction of all
publicly owned treatment works in each of the states. For this
reason, EPA officials said that reporting operating and maintenance
information might be more appropriate in another report. Our concern
was that the information be developed, rather than with the specific
vehicle in which it would be reported. Therefore, we have modified
the recommendation to emphasize that this information be developed,
regardless of its reporting mechanism.
EPA did not respond directly to the other recommendations that the
agency assess and disclose the range of uncertainty associated with
its control cost estimate, more fully document its cost estimation
methodology, and work with researchers at USDA and USGS to advance
its efforts to develop a watershed-based cost estimation approach.
On the last of these recommendations, EPA asked us to clarify that it
was not considering the watershed-based approach as a replacement for
existing cost-estimation activities that it believes must continue
for a number of reasons, but rather as a supplement to these
activities. We added language to clarify EPA's position on this
matter.
USDA's Agricultural Research Service shares the concern expressed in
our draft report that EPA's estimated cost of controlling nonpoint
sources of pollution does not include the operational costs
associated with the use of best management practices. The Service is
also supportive of the recommendation to use a watershed-based
approach in estimating the cost of controlling nonpoint source
pollution, noting agency research has established that the protection
provided by natural barriers, such as riparian zones, is watershed
specific. In addition, the Service pointed out that the
effectiveness of using certain practices to control the movement of
potential contaminants can be markedly affected by site-specific
conditions within watersheds.
USGS' comments elaborated on our findings regarding the issue of
uncertainty in nonpoint source control cost estimates providing
specific examples of possible uncertainty. USGS said that
uncertainty exists for many contaminants because they have not yet
been tested for controls and, therefore, control strategies for
addressing them have not been developed. In addition, USGS pointed
out that some best management practices might be effective at
controlling only certain contaminants and, therefore, some areas will
require multiple controls to address nonpoint source pollution.
Last, USGS noted that the implementation of some controls may cause
new pollution problems that will also have to be addressed. USGS
also said that it would be pleased to work with EPA and USDA to
provide insights regarding watershed-based modeling of nonpoint
source contamination and estimating costs for mitigating
contamination.
A VARIETY OF FEDERALLY MANAGED OR
AUTHORIZED ACTIVITIES CAN
CONTRIBUTE TO NONPOINT SOURCE
POLLUTION
============================================================ Chapter 4
Federal agencies manage, authorize, or issue permits or licenses for,
a variety of activities that provide public benefit but may also
contribute to nonpoint source pollution. Federal and state officials
that we contacted identified five of these activities as those with
the most potential to contribute significantly to nonpoint source
pollution: silviculture (specifically timber harvesting and
associated roads), grazing, drainage from abandoned mines,
recreation, and hydromodification. Several other activities managed
or authorized by federal agencies were identified by state and
federal officials as contributing to nonpoint source pollution in
some watersheds, such as farming and irrigation, but were not
highlighted as significant concerns.
The federal government owns about 20 percent of the land area in the
lower 48 states, and this land is concentrated in the west. As a
result, many western watersheds are dominated by federally owned land
and the associated federally managed or authorized activities that
may cause nonpoint source pollution.\1 According to the nonpoint
source program managers that we interviewed in five Western States,
many water quality problems in their states result from one or more
of these federal activities.
--------------------
\1 Not all federally authorized activities occur on federal land.
Licensing of private hydropower projects and highways constructed
with federal aid are examples.
FEDERAL ACTIVITIES WITH THE
MOST POTENTIAL TO CONTRIBUTE
SIGNIFICANTLY TO NONPOINT
SOURCE POLLUTION
---------------------------------------------------------- Chapter 4:1
In pursuit of widely varying missions and legislative requirements,
federal agencies manage, authorize, or issue permits or licenses for,
a variety of activities that provide public benefit such as
recreation, timber harvesting, and livestock grazing. For example,
the Forest Service (USFS) and the Bureau of Land Management (BLM)
provide for timber harvesting and livestock grazing on their lands as
well as for recreational opportunities. Figure 4.1 identifies which
federal agencies included in our review manage or authorize the
activities identified by state and federal officials as being the
nonpoint sources of most concern.
Figure 4.1: Activities
Contributing to Nonpoint Source
Pollution That are Managed or
Authorized by Each Agency
Included in Our Review
(See figure in printed
edition.)
Source: Prepared by GAO using agency data.
SILVICULTURE -- TIMBER
HARVESTING AND FOREST ROADS
-------------------------------------------------------- Chapter 4:1.1
Silviculture includes the management and care of forests, such as
timber harvesting, road construction, replanting, and chemical
treatments. As figure 4.2 shows, the Forest Service owns most of the
federal timberland suitable for timber harvesting. According to the
federal and state officials we interviewed, the majority of nonpoint
source pollution resulting from silvicultural activity results from
roads constructed for timber removal, although timber harvesting and
the transportation of logs from a harvest area can also contribute
significantly to water pollution. Other silvicultural practices such
as site preparation, prescribed burning, and chemical applications
were not cited by state or federal officials as significant sources
of nonpoint pollution overall.
Figure 4.2: Federal Ownership
of Timberland Suitable for
Harvest, by Agency
(See figure in printed
edition.)
Source: Prepared by GAO using agency data.
TIMBER HARVESTING
------------------------------------------------------ Chapter 4:1.1.1
Timber harvesting can be a significant source of nonpoint pollution.
However, USFS officials emphasized that the timber harvest itself is
typically a less significant cause of nonpoint source pollution than
associated activities required to transport logs from the harvest
site, such as hauling logs along trails known as skid trails. The
movement of logs from the harvest site typically involves the use of
heavy equipment, such as tractors, to haul logs along skid trails to
landings where they can be loaded onto trucks. The use of heavy
equipment and skidding of logs compacts the soil and can severely
disturb land surfaces. Rain falling on these areas tends to run off
the surface, allowing sediment to flow more easily into streams.\2
USFS is the dominant federal agency involved in timber harvesting.
However, timber harvesting on USFS lands has been declining
significantly in the past decade, from 12.7 billion board feet in
fiscal year 1987 to 3.3 billion board feet in fiscal year 1998, a
decline of over 70 percent.\3 Accordingly, associated activities such
as the use of skid trails have also declined. BLM is the only other
agency with a significant level of timber harvesting with 239 million
board feet in fiscal year 1997.
The amount of nonpoint source pollution generated by timber
operations varies considerably depending on (1) site-specific
conditions, such as the stability of the soil and the slope of the
land where the harvest occurs, and (2) management decisions, such as
the choice of log transport method, which is a key determinant of the
amount of ground disturbance that will be caused by the operation.
Forest Service research shows that nonpoint pollution generally
results from a timber harvest when there is a large amount of surface
disturbance on steep slopes or when riparian vegetation is removed or
modified. For example, clear-cutting on steep slopes in the Pacific
Northwest has led to significant increases in the number of
landslides that deposit large amounts of sediment. In addition, the
manager of the nonpoint source unit in Oregon told us that past
timber harvesting operations in the state have resulted in removal of
riparian vegetation and consequent reduction of streamside shade,
which causes elevated stream temperatures that are considered harmful
to some fish species.
Recognizing the need to reduce soil erosion and other nonpoint source
impacts resulting from silvicultural activities, the Forest Service
and BLM have moved away from the use of clear-cutting as a harvest
method. For example, clear-cutting on Forest Service lands has
declined significantly in the past 5 years, from 132,674 acres in
fiscal year 1993 to 45,854 acres in fiscal year 1997, a decline of
about 65 percent. In addition, Forest Service and BLM timber
contracts are to include requirements to implement best management
practices, appropriate to the conditions of the site being harvested,
to reduce water quality impacts. For example, a contract may require
that skid trails and landings be designed to minimize erosion or that
the lifting of logs from the harvest area occur via helicopter when
slopes are steep. Forest Service officials were confident that
existing requirements regarding management practices would, if
followed, reduce nonpoint source pollution. However, the Forest
Service does not systematically aggregate data regarding the
implementation of the requirements.
--------------------
\2 For more details, see Oregon Watersheds: Many Activities
Contribute to Increased Turbidity During Large Storms
(GAO/RCED-98-220, July 29, 1998).
\3 A board foot is a unit of quantity for lumber equal to the volume
of a board 12 X 12 X 1 inches.
FOREST ROAD
------------------------------------------------------ Chapter 4:1.1.2
Harvesting timber often requires the construction of numerous miles
of forest roads to move heavy equipment into the harvest areas and up
and down hillsides. The Forest Service has inventoried about 373,000
miles of roads on Forest Service lands. BLM has inventoried almost
75,000 miles of roads on its lands, though the majority of BLM roads
were constructed for commercial use other than forest products such
as for oil and gas, mineral, and grazing activities. About 14,000
miles of BLM roads have been constructed in Oregon and Washington
where 85 percent of BLM-authorized timber harvesting occurs. Forest
Service and BLM officials noted that few new roads have been
constructed in recent years, and little new construction is planned.
The officials also pointed out that there are many other uses for
which forest roads stay open after a harvest is completed, and the
majority of traffic on forest roads are from these other uses.
Officials from both the Forest Service and BLM told us that, overall,
roads are among the two most serious threats to water quality on
lands they manage. According to Forest Service officials and
scientific literature, roads are considered to be the major source of
erosion from forested lands, contributing up to 90 percent of the
total sediment production from forestry operations.
Historically, forest road construction standards were not focused on
reducing the potential for erosion and associated water quality
impacts. Poorly designed and sited roads can change natural stream
flowpaths, which leads to incision, or cutting away, of previously
unchanneled portions of the landscape and increased erosion. Roads
also concentrate stormwater runoff on road surfaces of exposed and
often-compacted soil, and may channel flow into adjacent ditches,
where eroded sediment from hillsides and roadbeds can be more easily
transported to streams. We observed such channel incision and
erosion on Forest Service land in Arizona. (See fig. 4.3.)
Figure 4.3: Channel Incision
From Forest Road
(See figure in printed
edition.)
Sediment from roads can contribute to water quality problems. For
example, we recently reported that forest roads were one of several
sources of sediment that led to exceedances of turbidity in drinking
water and the shut down of several drinking water systems during an
unusually heavy storm in western Oregon.\4 Scientific literature
shows that aquatic habitat and fish populations can also be adversely
affected. Mass erosion resulting from roads can lead to the filling
of stream pools, which causes them to support fewer fish and may
increase fish mortality. In addition, fine sediment can fill
crevices in stream gravel that would otherwise serve to protect
juvenile fish and provide spawning grounds.
Forest Service and BLM officials told us that they have attempted to
begin minimizing impacts from roads--within current budget
constraints and priorities. For example, the Forest Service and BLM
have formal management guidance specifying several engineering
practices that may reduce the impacts of roads on water quality.
These practices include halting timber operations in wet weather;
constructing drainage ditches, culverts, and other structures for
controlling erosion; inspecting and maintaining roads during and
after winter storms; and creating stream-side buffers to minimize
water quality impacts. Figure 4.4 shows a Forest Service road
improvement project installed to change the way the road diverted
stormwater runoff in order to reduce stream velocities and subsequent
erosion.
Figure 4.4: Forest Service
Road Improvement Project
(See figure in printed
edition.)
In addition, the Forest Service recently began developing a new roads
policy. The three key objectives of this policy are to: (1) provide
Forest Service managers with new scientific and analytical tools with
which to make better decisions about when, where, and if new roads
should be constructed; (2) decommission unnecessary and unused roads,
as well as unplanned or unauthorized roads; and (3) improve forest
roads where appropriate to respond to changing demands, local
communities' access needs, and the growing recreational use of Forest
Service lands.
One state official we interviewed expressed concern that the Forest
Service will face significant challenges in closing roads, since
signage and gates used to close them can be ignored by people wanting
to use the roads for recreational purposes. The Forest Service
already has significant problems with unauthorized vehicle use of
forests. Repeated use has created over 60,000 miles of unauthorized
roads throughout the National Forest System, in addition to the
373,000 miles of roads previously mentioned. Figure 4.5 shows
examples of unauthorized roads, which can also accelerate erosion and
can contribute sediment to nearby waterbodies.
Figure 4.5: Unauthorized Roads
on Forest Service Land
(See figure in printed
edition.)
--------------------
\4 Turbidity is a measure of sediment and other solids in water.
Certain levels of turbidity are unsafe for human consumption. For
more details, see Oregon Watersheds: Many Activities Contribute to
Increased Turbidity During Large Storms (GAO/RCED-98-220, July 29,
1998).
GRAZING
-------------------------------------------------------- Chapter 4:1.2
As figure 4.6 shows, BLM and USFS own most of the federal land
available for grazing. Officials from both BLM and the Forest
Service said that livestock grazing is among the two most significant
contributors of nonpoint source pollution on lands they manage. The
state officials we talked with also expressed concerns regarding
nonpoint pollution resulting from grazing on public lands. In
Oregon, for example, the manager of the nonpoint source unit told us
that federally authorized grazing contributes to the degradation of
about 30 percent of all impaired waters in the state.
Figure 4.6: Acreage Available
for Grazing by Federal Agency
(See figure in printed
edition.)
Note: Other includes 5 million acres for the Park Service and 1.4
million for the Fish and Wildlife Service.
Source: Prepared by GAO using agency data.
Grazing can result in nonpoint pollution in several ways. Continuous
grazing can lead to a reduction of vegetation that would otherwise
serve to protect soil surfaces from the erosive impact of rain.
Livestock may also strip vegetation from bushes and shrubs,
de-stabilizing root structures and loosening soils, making the soils
more vulnerable to runoff during a major storm event. Grazing in
riparian areas, which are located in and alongside streams, can lead
to a loss of vegetation that would otherwise serve to filter sediment
in the streamflow, stabilize streambanks, and provide shade that
moderates stream temperatures to levels tolerable for aquatic
species. Continuous grazing also leads to trampling of surfaces,
causing soil compaction. This reduces rainfall infiltration and in
turn leads to increased runoff. Trampling can also cause streambanks
to slump and erode, resulting in direct deposit of streamside soil
into waterbodies. In addition, direct deposits of manure can occur
when animals graze near waterbodies and can lead to fecal coliform
and pathogen contamination.\5
Figure 4.7 shows a streambank that is beginning to erode due to loss
of vegetation through grazing and a healthy riparian area where
grazing has been excluded. Livestock grazing is not the only source
of grazing impacts, however. Wildlife, such as elk and deer, graze
federal lands and can cause significant impacts such as loss of
vegetation and fecal coliform contamination in some places.
According to Arizona officials, uncontrolled populations of wildlife
are among the state's most serious threats to water quality.
4-7.eps> Figure 4.7: Healthy
Riparian Area and Eroded
Streambank
(See figure in printed
edition.)
BLM officials acknowledge that grazing causes damage to the riparian
stream environment. They note that almost three-quarters of the
agency's nearly 40,000 miles of riparian stream environment in the
lower 48 states have been assessed to determine ecological condition.
Of these assessed stream miles, BLM reported that 14 percent, or
almost 4,000 miles, are "non-functional" or do not provide adequate
vegetation to slow streamflows that would otherwise cause significant
erosion. Another 45 percent of the stream miles are classified as
"functional--at risk" and most are declining or have no apparent
condition trend.\6 BLM officials added, however, that the precise
impact of grazing on the riparian environment is difficult to isolate
from that of other sources.
State and federal officials told us that while impacts from current
grazing are significant in some areas, the impacts vary considerably
depending on several factors, including soil and vegetation type in
forage areas, the duration and intensity of grazing, and management
practices implemented to mitigate nonpoint source impacts. Proper
management of grazing lands can often reduce or minimize nonpoint
pollution from grazing. However, the officials we talked with said
that federal efforts to actively manage grazing are often limited by
insufficient staff and resources.
In addition to the effects of present-day grazing, many watersheds
throughout the west have not fully recovered from the heavy grazing
that occurred on public lands around the turn of the century.
Officials from California, Colorado, and Oregon said that past heavy
grazing such as in the late 1800s in each of these states has led to
long-term dramatic effects in many watersheds.
--------------------
\5 Fecal coliform bacteria (the most common member being Escherichia
coli, or E. coli) indicates that water has been contaminated with
human or animal feces and may also contain other pathogens or disease
producing bacteria or viruses found in fecal material. Some
waterborne pathogenic diseases include typhoid fever, viral and
bacterial gastroenteritis, and hepatitis A.
\6 BLM only assesses a condition trend for stream miles determined to
be "functional--at risk."
ABANDONED MINES
-------------------------------------------------------- Chapter 4:1.3
Abandoned mines are categorized as those abandoned or left
inadequately restored. Federal agencies have identified almost
100,000 abandoned mine sites on federal land across the country,
though federal inventories do not use consistent definitions of
"site." Because of varying definitions, a site may range in size from
a small exploratory hole, or single shaft, to a large area
encompassing numerous shafts and large open pits. (See fig. 4.8.)
Abandoned mines on federal land are primarily hardrock mines and
occur almost exclusively on lands managed by BLM and the Forest
Service. To date, 70,000 abandoned mines have been inventoried on
BLM lands, 39,000 on Forest Service lands, 2,500 on National Park
Service lands, and 240 on National Wildlife Refuges.
Figure 4.8: Abandoned Mines
(See figure in printed
edition.)
Mining disturbs rock surfaces and generates piles of waste rock and
mine tailings, which exposes minerals in the rock to air and water,
accelerating natural rates of oxidation. The oxidation of sulfide
minerals, such as pyrite (iron sulfide), generates strong acids,
which can drain or run off with stormwater into streams. Acidic
conditions in streams can have severe consequences for aquatic life
by interfering with biological processes such as reproduction. For
example, a Park Service study found that many aquatic species that
once existed in major portions of the Cumberland River in Kentucky
now exist only as isolated remnant populations possibly because of
acid drainage from abandoned coal mines.
Acids from mine drainage can also dissolve metals, such as copper,
zinc, manganese, and aluminum, that can be carried into surface
waters in toxic concentrations. High concentrations of metals in
surface waters can threaten ecological health. According to a Forest
Service official, a few livestock fatalities have occurred as a
result of ingesting selenium while grazing in areas contaminated by
drainage from abandoned mines on National Forest lands in Idaho. In
addition, plant growth has been severely disrupted by acid mine
drainage from the abandoned McLaren and Glengary gold and copper
mines on the Custer and Gallatin National Forests in Montana. This
loss of natural vegetation leaves soils vulnerable to the erosive
impact of rain, which can increase the amount of sediment running off
into waterbodies.
Officials we interviewed from each of the five states identified
abandoned mines as significant contributors to nonpoint source
pollution. In Colorado, for example, the manager of the nonpoint
source unit estimated that almost 50 percent of water impairments in
the state are adversely affected by acid drainage from abandoned
mines. Many of these mines occur on federal lands. Several federal
agencies have programs to reclaim abandoned mine sites and thereby
reduce nonpoint source pollution impacts from acid mine drainage.
For example, in 1997, the Forest Service obligated about $10 million
for hazardous waste projects that were targeted mostly to abandoned
mine land reclamation. In 1998, BLM obligated about $3 million
toward abandoned mine reclamation in Colorado, Montana, and Utah.
RECREATION
-------------------------------------------------------- Chapter 4:1.4
Officials from four of the states that we contacted as well as Forest
Service, Park Service, and the Fish and Wildlife Service expressed
concerns regarding nonpoint source pollution from recreation.
Recreational use of public lands and waters is currently widespread
and is increasing steadily. For example, in the past 10 years,
recreational use of the National Forests has increased 40 percent.
Figure 4.9 shows recreational use of federal lands in fiscal year
1997.
Figure 4.9: Recreational
Visits to Federal Lands, by
Agency
(See figure in printed
edition.)
Note: Data are for fiscal year 1997 except for Reclamation, which is
fiscal year 1992.
Source: Prepared by GAO using agency data.
Many recreational activities can result in direct deposits of
pollutants into waterbodies such as human and pet waste. This waste
may contain disease-producing bacteria and viruses and poses a
potential health risk for people exposed to the water. Arizona and
Oregon state officials noted that river recreation, such as tubing,
kayaking, and swimming and unauthorized dumping of sewage from boats
and motor homes, can cause high levels of fecal coliform in surface
water. Oil and gas spills from motor boats and other recreational
vehicles are also possible sources of nonpoint pollution.
Use of vehicles on public lands and roads can also cause significant
erosion. As noted previously, forest roads are often left open after
harvesting for other purposes such as recreational use. Forest
Service research has shown that increased vehicle use causes an
increase in erosion from forest roads. An estimated 1.7 million
vehicles associated with recreational activities travel forest roads
each day, over 10 times more than in 1950. In addition, land
disturbances caused by the use of off-road vehicles can also lead to
increased erosion. One BLM official told us that in extreme cases,
off-road vehicle use through stream environments can cause road-beds
to divert channel flows from streams onto the road surface.
State officials told us that recreational activities tend to cause
water quality impairments when the activity is highly concentrated in
a given area. For example, during the summer 1998, 25,000 people
assembled in a small area of Apache-Sitgreaves National Forest in
Arizona, causing severe land disturbances and increased erosion, as
well as unusually high fecal coliform levels in otherwise-pristine
forest streams. In addition, state officials said that
concentrations of campers along streambanks can lead to the
destruction of vegetation in riparian areas, in turn causing sediment
and temperature impacts to waterbodies.
With few exceptions, federal agencies do not have specific guidance
or policies for dealing with recreation and associated water quality
impacts. The Park Service has a policy dealing with recreational
boating and marinas and associated nonpoint sources. Some agencies
perform assessments and develop solutions on a case-by-case basis
once problems are identified. For example, the Park Service has
recently closed some parks to off-road vehicle and jet ski use to
reduce water quality problems. Likewise, BLM has designated specific
off-road vehicle use areas in attempts to contain the damaging
activity to small areas. However, a Forest Service research
scientist told us that little federal research is available on the
water quality impacts from recreation to help guide such decisions or
develop strategies for dealing with recreational impacts.
HYDROMODIFICATION
-------------------------------------------------------- Chapter 4:1.5
EPA's National Water Quality Inventory: 1996 Report to Congress
identifies hydromodification activities, such as channelization and
the construction and operation of dams, as contributing to the
degradation of 14 percent of the nation's impaired river and stream
miles. Three of the five states we contacted identified
hydromodification as a significant concern, and each of the federal
agencies that manage and authorize the activities--the Bureau of
Reclamation, the Army Corps of Engineers, and the Federal Energy
Regulatory Commission (FERC)--acknowledged that hydromodification may
contribute to nonpoint source pollution in some areas.
Hydromodification projects often provide important public benefits,
such as providing water to arid regions, electric power generation,
or flood protection. For example, in 1992, the Bureau estimated
cumulative flood control benefits of $8.4 billion in prevented
damages from its projects during the period 1950 through 1992.
However, state officials we interviewed noted that existing dams and
channelization projects also contribute significantly to water
quality impairments and can limit the extent to which streams recover
from water quality degradation.
CHANNELIZATION
------------------------------------------------------ Chapter 4:1.5.1
EPA defines channelization as river and stream channel engineering
undertaken for flood control, navigation, drainage improvement, or
clearing away of debris. It also includes the reduction of channel
migration potential--such as straightening, widening, deepening, or
relocating existing channels. Levees, another form of
channelization, are embankments or shaped mounds meant for flood
control or hurricane protection. The Corps manages about 8,500 miles
of levees nationwide to protect floodplain property without modifying
the channel itself but does not maintain an inventory of the total
number of channelization projects.
Managed predominantly by the Corps, federal channelization projects
can contribute to nonpoint source pollution in several ways. For
example, channel clearing operations remove vegetation that would
otherwise act as natural barriers that slow water velocities and
filter sediment and other pollutants. As a result, these operations
can cause increased downstream erosion and faster rates of pollutant
transport. Channel enlargement projects include activities such as
increasing channel depths while retaining the original bank slopes.
This may cause stream banks to slump and erode, resulting in
increased loadings of sediment. Levees, when located close to
streambanks, can prevent the movement of instream waters into
adjacent wetlands and riparian areas. This can result in increased
in-stream pollutant loadings because the natural filtration that
would normally occur is prevented.
Channelization projects have caused significant declines in the
quality of some watersheds. For example, state officials in Oregon
reported that nonpoint source pollution problems caused by
channelization projects conducted for flood control from the 1920s
through the 1950s have contributed significantly to the decline of
watershed functioning in the state.
DAMS AND RESERVOIRS
------------------------------------------------------ Chapter 4:1.5.2
The Corps and the Bureau of Reclamation operate over 900 dams and
reservoirs for multiple purposes such as municipal and industrial
water supply, flood control, recreation, and irrigation and operate
133 hydroelectric facilities for power generation. The Bureau and
the Corps are the two largest suppliers of hydroelectric power in the
nation, providing about 42 billion and 75 billion kilowatt hours,
respectively, and together account for almost 40 percent of total
hydroelectric kilowatt hours produced. In addition, the Federal
Energy Regulatory Commission regulates about 1,750 nonfederal
hydropower facilities which generate about 154.5 billion kilowatt
hours annually.
Dam and reservoir projects vary in size, type, and operating
purpose(s) and result in water quality impacts in many different
ways. Some impacts are specific to a particular type or purpose of a
project, while others may occur regardless of the project type or
purpose. For example, in some cases, deep reservoirs stratify by
temperature, resulting in a cold, deep layer that may result in low
dissolved oxygen and high concentrations of some dissolved elements
such as iron, manganese, sulfur, and nitrogen. Releases from deep
reservoirs can have significant temperature impacts on receiving
waters; federal officials said that aquatic species can be adversely
affected by these conditions if dam releases draw water primarily
from this lower layer. In addition, dams and reservoirs also cause
significant habitat modification problems for migrating aquatic
species.\7 For example, dams can be a factor contributing to
decreasing numbers in salmon populations, some of which in the
Northwest are on the verge of being endangered or extinct.
Because reservoirs trap and accumulate sediment, waters released from
reservoirs are often low in sediment, leaving them capable of
carrying more sediment (i.e., increasing erosion) from the banks and
beds of the stream immediately downstream from the reservoir.
Peaking operations of dams may result in accelerated downstream
erosion with the resulting increased flow rates.\8 However, in other
instances, dam releases may contain high levels of sediment, which
can lead to accumulation of sediment downstream as it settles out.
Bureau officials told us that downstream movement of suspended
sediment during extreme reservoir drawdown periods has been
documented at several reservoirs, including Island Park, American
Falls, and Black Canyon in Idaho, and Thief Valley in Oregon.
The impact of individual dam and reservoir projects varies
significantly, depending on the type and purpose of the project, the
streamflow and sediment characteristics of the parent streams, and
the management practices applied at a given site. Bureau and Corps
officials told us that best management practices can be used to
minimize the avoidable effects of dams on water quality. For
example, older dams can be retrofitted with systems that mix water
from different depths before release to minimize the thermal and
dissolved oxygen impacts from stratified, deep reservoirs.
FERC also plays a role in federal nonpoint pollution by issuing
licenses to nonfederal entities to construct and/or operate a
hydropower project. As required by the National Environmental Policy
Act, FERC must (1) prepare an environmental assessment or an
environmental impact statement for any license or relicensing
application and (2) describe the effects of the project on several
environmental factors, including water quality. In reviewing
licensing or re-licensing applications, FERC must weigh environmental
impacts equally with other purposes of the project.\9 FERC can
include provisions in licenses to mitigate impacts such as
requirements to conduct regular water quality monitoring, to
construct fish ladders to facilitate migration, or to prepare a plan
to control erosion.\10
--------------------
\7 Habitat modification includes activities in and around waterbodies
that change the physical structure of aquatic ecosystems such as the
locating of a dam on a river.
\8 Peaking operations, which result in larger releases of water,
occur to meet a project's particular operating purpose(s), for
example, responding to increases in demand for electricity,
regulating water levels to minimize flooding, and maintaining certain
flow levels to provide for recreation.
\9 As required by the Electric Consumers Protection Act of 1986, Pub.
L. No. 99-495, 3, 100 Stat. 1243, 1243 (Oct. 16, 1986).
\10 We reported in 1992 that FERC accepted a majority of resource
agency recommendations in the licensing or relicensing process.
Typical resource agency recommendations include minimum water flows,
construction of fish passage facilities, and installation of screens
to prevent injury or death to fish. See Electricity Regulation:
Electric Consumers Protection Act's Effects on Licensing
Hydroelectric Dams (GAO/RCED-92-246, Sept. 1992).
OTHER FEDERALLY MANAGED OR
AUTHORIZED ACTIVITIES THAT CAN
CONTRIBUTE TO NONPOINT SOURCE
POLLUTION
---------------------------------------------------------- Chapter 4:2
Several other activities managed or authorized by federal agencies
were identified by state and federal officials as contributing to
nonpoint source pollution in some watersheds but were not cited as
significant sources of overall concern. These activities include a
number of silvicultural activities other than timber harvesting and
forest roads, farming, irrigation, federal-aid highways and roads,
and military training.
OTHER SILVICULTURAL
PRACTICES
-------------------------------------------------------- Chapter 4:2.1
Silvicultural practices other than timber harvesting and forest roads
primarily include site preparation, prescribed burning, and
applications of chemicals such as herbicides. While no state
officials we interviewed identified the practices as concerns or
cited them as causes of impaired waters in their states, Forest
Service officials told us that they can contribute to problems in
some cases. Site preparation includes activities to help tree stands
regenerate. Stands are either left to regenerate on their own or are
planted. Planting can involve mechanical site preparation techniques
that involves the use of heavy equipment, such as tractors, to rake
the soil. This can severely disturb land surfaces and cause erosion.
However, according to Forest Service officials, use of mechanical
site preparation methods is declining, as the Service increasingly
relies on natural regeneration.
Prescribed burning and chemical applications, which are used to
maintain forest health, can also contribute to nonpoint pollution if
not properly managed. For example, when a prescribed burn gets out
of control, the resulting intense fire may completely burn the forest
floor, exposing mineral soil and accelerating erosion in steep
terrain. Applications of chemicals such as herbicides may pose a
risk to water quality if applied without adequate buffers or due to
drift during aerial applications. However, each of these activities
are rare on federal lands. Forest Service dedicated about 1.2
million acres to prescribed burn management (less than 2 percent of
total timberland) and chemically treated about 300,000 acres in
fiscal year 1997.
FARMING
-------------------------------------------------------- Chapter 4:2.2
While farming-related activity is cited as the source of a large
portion of the nation's nonpoint source pollution, it is a minor
contributor on federal lands. The Fish and Wildlife Service, Park
Service, and the Department of Defense reported authorizing farming
activity on small portions of the lands they manage. For example,
farming activity is permitted by the Fish and Wildlife Service on
166,000 acres within the National Wildlife Refuge System, which
constitutes less than 1 percent of the total acreage in the system.
Several state officials expressed some concern regarding nonpoint
source pollution resulting from federally authorized farming
activity; however, they told us that impacts are not a major concern
since the activity is relatively rare, especially in comparison to
private farming.
IRRIGATION
-------------------------------------------------------- Chapter 4:2.3
The Bureau and the Corps both provide water resources for private
farming, primarily through the construction and operation of canals,
laterals, and drains. Reclamation operates about 15,900 miles of
canals, 37,000 miles of laterals, and 17,000 miles of drains to
convey water for irrigation and flood control. In 1992, the Bureau
provided irrigation water to private farms covering more than 9.2
million acres of western land. According to Bureau officials, return
flows and runoff from irrigated lands may transport nonpoint source
pollutants such as sediment, nutrients, metals, and pathogens into
waterbodies.\11 Irrigation projects also contribute to salinity
problems in western waters. Corps officials told us that the agency
does not maintain a centralized inventory of irrigation activity
because it is a small part of the Corps' mission but noted that
nonpoint pollution impacts resulting from their irrigation activity
are likely to be minor.
Bureau officials told us that some Bureau-managed agricultural drains
are significant sources of pollution to water-quality-limited waters
throughout the west, including the Snake, Boise, Payette, and Yakima
Rivers. Officials from the Fish and Wildlife Service told us that
nonpoint pollution impacts due to selenium drainage from irrigation
return flows are among the most serious and pervasive irrigation
impacts occurring on lands within the National Wildlife Refuge
System. In some areas, contaminated drainwater has been linked to
waterfowl deaths, birth defects, and reproductive failures. Interior
has had an irrigation water quality program since 1985, which has
largely focused on identifying and correcting contamination problems.
--------------------
\11 It is important to note that irrigation return flows--while a
discrete conveyance of pollution to a waterbody--were specifically
exempted from point source control in the Clean Water Act, and we
have, therefore, included this category in our discussion of nonpoint
sources.
FEDERAL-AID HIGHWAYS AND
ROADS
-------------------------------------------------------- Chapter 4:2.4
Roads, highways, and bridges funded with federal dollars may also
result in nonpoint source pollution. Federal aid is provided to
state and local governments to construct and maintain roads and
highways. Almost 1 million miles of highways and roads have been
constructed and/or maintained with the aid of federal funds in the
United States. While road construction can be a significant source
of water pollution, most projects are regulated by EPA's stormwater
permit requirements for construction sites and are therefore not
discussed in this report. However, once constructed, highway
operations result in nonpoint pollution via the process of stormwater
runoff which carries with it any pollutants that have accumulated on
road surfaces such as oil, grease, and de-icing compounds.
The Department of Transportation has compiled research that provides
guidance to state and local governments for mitigating water quality
impacts from roads, highways, and bridges. Best management practices
to control this type of runoff include structures such as filters,
trenches, and ponds designed to trap nonpoint source pollutants,
minimizing the amount that actually reaches waterways. However,
because road and highway projects are decentralized, mainly carried
out by state and local governments, the Department does not have
nationwide data on the implementation of these management practices
(although implementation of such activities is typically a
requirement for receiving federal aid).
MILITARY TRAINING
-------------------------------------------------------- Chapter 4:2.5
The major sources of nonpoint pollution identified by Defense
officials are associated with maneuver bases and training areas,
especially from the use of heavy vehicles and machinery such as
tanks, artillery pieces, and amphibious assault vehicles, as well as
from large caliber firing ranges. These activities can result in
significant land disturbances and subsequent erosion following large
storms. Service officials we talked with said that impacts do occur,
and in some cases, water quality standards have been violated. For
example, Marine Corps staff have observed severely eroded roads and
vehicle crossings over streams at Camp Lejeune in North Carolina and
Quantico in Virginia. In addition, Army officials told us that
erosion is a serious problem for many Army maneuver bases located on
abandoned or degraded agricultural land where soils are highly
erodible, especially on eastern bases such as Fort Bragg, North
Carolina.
Service officials said that minimizing nonpoint source impacts is in
their best interest in order to avoid violations of state water
quality standards and to enable them to continue their critical
training missions. For example, while all of the military services
expressed some concern with metals leaching from ammunition used on
firing ranges, lead in stormwater runoff has rarely been documented.
In response to a contaminated runoff incident, the Marine Corps built
traps to collect bullets to avoid any further leaching, even though
water quality had not been impaired. Collected bullets can then be
recycled, which allows for recovery of the cost of the traps. In
addition, as discussed in chapter 2, some nonpoint sources are
addressed via Defense's stormwater permit activities by diverting
nonpoint runoff and treating it as a point source.
THE FEDERAL CONTRIBUTION TO
NONPOINT SOURCE POLLUTION MAY
BE SIGNIFICANT IN MANY WESTERN
WATERSHEDS
---------------------------------------------------------- Chapter 4:3
The predominance of federal land ownership in many western watersheds
suggests a potentially significant federal contribution to nonpoint
source pollution in those areas. Overall, federal lands account for
about 20 percent of the total land surface area in the lower 48
states. Most of this land is in 11 Western States--Arizona,
California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon,
Utah, Washington, and Wyoming. As indicated in figure 4.10, tracts
of federal land can encompass large portions of many watersheds
(shaded areas represent watersheds with greater than 50 percent of
the land owned by the federal government). Specifically, federal
agencies own at least one-half of the land area in about 60 percent
of the watersheds in the above 11 states and 22 percent nationwide.
Figure 4.10: Watersheds in
Which Land Owned by the Federal
Government Exceeds 50 Percent
(See figure in printed
edition.)
Source: USGS.
The nonpoint source program managers that we contacted in five of the
Western States reported many water quality problems resulting from
one or more of the federal activities discussed in this chapter. In
Oregon, for example, the manager of the nonpoint source program told
us that nonpoint source pollution from federal activities is the
primary source of impairment of 50 to 60 percent of the waterbodies
the state reported as impaired. In Arizona, the nonpoint program
manager said that federal activities are the primary source of
impairment to almost 50 percent of all impaired waters in the state.
Several state officials pointed out, however, that not all water
quality impacts are due to current federal activities citing past
timber and grazing practices, in particular, as sources of continuing
nonpoint pollution in their states.
Even in watersheds where there is not significant federal land
ownership or a significant federal contribution to nonpoint source
pollution, control of nonpoint source pollution by federal agencies
may promote strong federal stewardship of lands held in the public
trust and encourage strong stewardship by private landholders. EPA
officials in the interagency Chesapeake Bay Program told us that even
though federal agencies own just a small percent of the land in the
Bay watershed, they have enjoyed broad federal involvement in
restoration activities, which has helped to promote federal
stewardship of public lands and set an example for private
landholders. In November 1998, EPA and its federal partners
announced a new commitment to this stewardship, recognizing the
important role the agencies can play in the Bay watershed.
State environmental efforts can benefit from such stewardship as the
manager of the nonpoint source program in Oregon pointed out to us.
He said that weak federal commitment to addressing nonpoint pollution
discourages private stewardship. On the other hand, he noted that
strong federal stewardship of public lands can encourage private
stewardship by demonstrating commitment and accomplishments. In
addition, each of the five state officials we contacted noted that
they had good working relationships with several of the federal
agencies discussed in this report and, in these instances, were
working with their federal counterparts to address water quality
impacts.
The Clean Water Action Plan acknowledges the importance of the
federal contribution to nonpoint source pollution, outlining several
key action items federal agencies are to implement in order to better
protect water resources on federal land. Specifically, USDA and
Interior are to lead the development of a unified federal policy to
enhance watershed management on federal lands to provide for the
protection of water quality and health of aquatic systems. In
addition, federal agencies are to ensure that environmental
safeguards and appropriate water quality provisions are included in
permits, licenses, and other agreements used to allow activities to
occur on their lands.
AGENCY COMMENTS
---------------------------------------------------------- Chapter 4:4
The Department of the Interior said that the draft report appeared to
equate the magnitude of nonpoint source pollution to the amount of
federally managed land involved. The Forest Service expressed a
similar concern, noting that simply because a significant portion of
the land base in many Western States is federally managed, it does
not necessarily follow that these lands contribute a significant
proportion of the nonpoint source pollution in these states. The
Service suggests characterizing the federal contributions as
"potential" rather than "actual." As discussed in chapter 4,
information obtained from the states we contacted does in fact show
that a significant proportion of water quality problems can be
attributed, at least in part, to activities occurring on federal
land. However, we acknowledge the variability in this relationship,
noting that the degree of pollution in specific areas may depend on
site-specific characteristics such as geographic and hydrologic
conditions, the type of activities occurring and intensity of use,
and management practices applied to minimize impacts. Accordingly,
as suggested by the Forest Service, we modified language in chapter 4
where appropriate to characterize the association between a large
portion of federally owned land to contributing a significant amount
of nonpoint pollution as potential rather than actual.
On a related issue, USDA's Natural Resources Conservation Service
said that chapter 4 leaves the impression that all grazing and timber
activities cause nonpoint source pollution and suggested that the
activities in this chapter should be characterized as contributing to
nonpoint source pollution only if not properly managed. We agree
that water quality impacts can be reduced, but not necessarily
eliminated, by the use of appropriate management practices and
discuss some of these practices in each of the activity sections.
However, such practices may not always be in place. Moreover, as
pointed out by federal and state officials, as well as by Forest
Service research--and included in our report--water quality impacts
continue to result from past management practices, such as the type
of heavy grazing that occurred in the late 1800s and certain timber
harvesting practices.
FERC acknowledged that nonpoint source pollution-related impacts can
result from FERC-licensed hydropower projects, but cautioned that in
characterizing these impacts, the report (1) carefully distinguish
between the effects of hydropower versus other forms of
hydromodification; (2) distinguish between FERC-licensed projects and
federally managed projects; and (3) recognize that hydropower is not
an original source of some of the impacts identified, but rather a
factor that can amplify the effects of other sources that contribute
nonpoint pollution. Regarding the first two points, while our draft
did in fact recognize the distinctions identified by FERC, we made
additional changes to add further clarification. Regarding the third
point, we agree that, in some instances, hydropower is not
technically the source of the pollution, although, as FERC points
out, it may still be a contributor. In other instances, however
(such as situations where changes in temperature or dissolved oxygen
levels or increased downstream erosion result directly from a
project's operations), we continue to believe that it is more
appropriate to characterize the project as an original source of the
pollution.
OTHER CLEAN WATER ACT SECTIONS
ADDRESSING NONPOINT POLLUTION
=========================================================== Appendix I
In addition to the Environmental Protection Agency (EPA) programs
discussed in this report that primarily address nonpoint source
pollution, a few other programs authorized by the Clean Water Act
address nonpoint source pollution but to a lesser extent. This
appendix provides an overall description, funding levels, and
allocation methods for these remaining programs.
-- Section 104(b)(3): National Wetlands Program ($620,000
obligated for nonpoint activities out of $70 million
appropriated to the program for fiscal years 1994 though 1998.)
Overall Objective: The program's overall objective is to protect,
manage, and restore the nation's wetland resources consistent with
EPA's Clean Water Act responsibilities and to assist state, local,
and tribal governments in developing effective wetland programs.
According to EPA, a program objective is also to encourage and enable
others to act effectively in protecting and restoring the nation's
wetlands and associated ecosystems, including shallow open waters and
free-flowing streams. EPA's activities are predominantly
establishing national standards and assisting others in meeting those
standards.
Allocation Method: EPA uses a competitive process to allocate
program funds to state, local, and tribal governments and to
interstate and intertribal entities. EPA headquarters releases
yearly guidance that describes the grant program and establishes
program direction and priorities. EPA's regional offices review all
proposals and select projects that best help develop or refine
wetland protection, management, or restoration programs.
-- Section 106: EPA's Water Pollution Control, State and
Interstate Program Support Program ($2.3 million obligated for
nonpoint activities out of $418.3 million appropriated to the
program for fiscal years 1994 through 1998.)
Overall Objective: This program was created to assist states,
territories, interstate agencies, and qualified Indian tribes in
establishing and maintaining adequate measures for preventing and
controlling surface and ground water pollution. Grant funds provide
broad support for the prevention and abatement of surface and ground
water pollution from point and nonpoint sources through activities
such as water quality planning, standard setting, permitting sources,
monitoring, and assessments and enforcement.
Allocation Method: EPA uses a formula to allocate program funds to
states, interstate agencies, and tribes. Developed in 1974, the
formula is primarily based on state population and four categories of
point source pollution (municipal dischargers, industrial
dischargers, feedlots of 1,000 head or greater, and power plants).
EPA has proposed a revision of the formula to be more reflective of
current water quality impairment.\1
-- Section 314: Clean Lakes Program ($950,000 obligated for
nonpoint activities out of $5.06 million appropriated to the
program for fiscal years 1994 through 1998.)
Overall Objective: The overall objective of this program is to
provide financial and technical assistance to states to restore and
protect publicly owned lakes and reservoirs. The program has evolved
considerably over time. The program's early focus was on research
and the development of lake restoration techniques and evaluation of
lake conditions. In the 1980s, attention was shifted to identifying
sources of pollution and developing plans to deal with water quality
problems. EPA has not requested funds for this program in recent
years because the agency encouraged states in its May 1996 National
Nonpoint Source Program guidance to use section 319 moneys to fund
eligible activities that might have been funded in previous years
under section 314. About $16.6 million of section 319 funds have
been used to perform lake and reservoir work.
Allocation Method: Under this program, EPA uses a formula, a
competitive process, and other processes to allocate funds to states.
EPA used a formula to allocate a portion of the appropriated section
314 funds to each of its regions, taking into account several factors
such as the number of states per region, number of lakes/reservoirs,
land use, and nonpoint pollution problems. Each region then awarded
its portion of the funds on a competitive basis. In addition, the
Congress may include funding to a specific lake project as a separate
line item in the budget.
-- Section 320: National Estuary Program (EPA did not report
nonpoint source-related obligations for this section, noting
that the program does not specifically focus on nonpoint
pollution and therefore does not track obligations in that
way--total appropriated funding was $60.3 million for fiscal
years 1994 through 1998.)
Overall Objective: The National Estuary Program's overall objective
is the attainment or maintenance of water quality in the nation's
estuaries to ensure protection of public water supplies and the
protection and propagation of a balanced, indigenous population of
shellfish, fish, and wildlife. The program is designed to encourage
local communities to take responsibility for managing their estuaries
by encouraging stakeholders, including federal, state, and local
government agencies, citizens, business leaders, educators, and
researchers, to (1) work together to identify problems in the
estuary, (2) develop specific actions to address those problems, and
(3) create and implement formal management plans.
Allocation Method: EPA recently revised its formula for allocating
program funds to state and local governments, nonprofit
organizations, and regional planning organizations. Initially, EPA
created size distinctions and provided higher levels of funding for
large estuary projects. This size distinction was phased out in
fiscal year 1998 because experience with older programs revealed that
small estuaries can be just as complex as large estuaries depending
on such things as priority problems, the current state of knowledge
of the estuary, and cultural diversity. In addition, EPA created a
staged funding approach: programs developing a Comprehensive
Conservation and Management Plan for the estuary received more
funding than programs in plan implementation. Every year, EPA
develops specific funding guidance that explains how funds will be
allocated.
--------------------
\1 EPA is considering delaying the implementation of the new formula
in response to concerns that it places too much emphasis on reducing
runoff from nonpoint source pollution, which some claim will favor
agricultural states in the Midwest and West while reducing funds for
the Northeast and parts of the South.
NON-EPA FEDERAL PROGRAMS THAT
ADDRESS NONPOINT SOURCE POLLUTION
========================================================== Appendix II
(Dollars in millions)
FY 1994-1998
obligations
for nonpoint\a FY 1998
(total obligations
Title appropriated) for nonpoint Objectives
------------------- -------------- ------------ --------------------------------------
Department of
Agriculture
Natural Resources
Conservation
Service
Environmental $642 $232 To provide flexible technical,
Quality Incentives educational, and financial assistance
Program\b,c ($530) to producers that face the most
serious threats to soil, water, and
related natural resources.
Watershed $433.26 $80.83 To cooperate with state and local
Protection and agencies in planning and carrying out
Flood Prevention ($585.41) work to improve soil conservation and
for other purposes--such as flood
prevention, and the conservation,
development, and utilization of
water.
National Resources $70.5 $21.68 To provide statistically valid
Inventory information for agricultural and
($94) environmental program and policy
development, implementation, and
evaluation.
Great Plains $45.99 $3.89 To maintain soil and water resources
Conservation in the 10 Great Plains States by
Program\b ($40.7) installing corrective practices.
Consolidated into EQIP in 1996.
Colorado River $31.9 $5.52 To reduce the amount of salt loading
Basin Salinity to the Colorado River from surface
Control Program\b ($20.96) runoff and subsurface percolation of
irrigation water that carries the
salt in solution to the river.
Consolidated into EQIP in 1996.
Wetland Reserve $549.8 $218.6 To protect, restore, and enhance the
Program\c functions and values of wetland
(549.8) ecosytems.
Highly Erodible To remove certain incentives for
Land and Wetland persons to produce agricultural
Conservation commodities on highly erodible land
Compliance\d or converted wetland.
Farm Service Agency
Conservation $9,193.6 $1,710.89 To cost effectively reduce water and
Reserve Program\c wind erosion, protect the nation's
(includes the ($8,700) long-term capability to produce food
Conservation and fiber, reduce sedimentation,
Reserve improve water quality, create and
Enhancement enhance wildlife habitat, and
Program) encourage more permanent conservation
practices and tree planting.
Agricultural $462.63 $12.29 To help prevent soil erosion and water
Conservation pollution, protect and improve
Program\b ($369.65) productive farm and ranch land,
(includes Water conserve water used in agriculture,
Quality Incentives preserve and develop wildlife
Projects) habitat, and encourage energy
conservation measures. Consolidated
into EQIP in 1996.
Emergency $218.63 $35.68 To rehabilitate farm land damaged by
Conservation natural disaster and to carry out
Program ($207.0) emergency water conservation measures
during periods of severe drought.
Cooperative State
Research,
Education, and
Extension Service
National Research $28.84 $5.19 To increase the quantity and quality
Initiative of science applied to the needs of
Competitive Grants ($456.3) agriculture and forestry.
Program
Water Quality $39.4 $5.7 To provide educational and technical
Program/ assistance programs for voluntary
Education, ($26.9) farmer adoption of improved
Technical, and management practices to enhance or
Financial protect water quality.
Assistance
Water Quality $20.38 $2.46 To measure the impact of farming
Program/ systems on water quality, identify
Research and ($20.38) processes that control fate and
Development transport of chemicals and other
contaminants, and determine social
and economic impacts of alternative
management systems.
Rural Clean Water $.094 $.006 To address agricultural nonpoint
Program\e source pollution problems in
(0) watersheds.
Forest Service
Watershed Research $69.46 $11.30 To conduct long-term studies of the
Program effects of natural events and land
(formerly the ($69.46) management activities on water
Watershed quality, quantity and timing to
Management and provide a scientific basis for land
Rehabilitation managers' efforts to protect and
Program) restore watershed and riparian
ecosystems.
Agricultural
Research Service
Water Quality/ $273.8 $59.2 To measure the impact of farming/
Research, ranching practices and systems on
Development, ($273.8) water quality; identify processes
Information that control fate and transport of
chemical and other contaminants;
develop cost-effective, alternative
farming/ranching practices and
systems for all nonpoint source
contaminants including salts, toxic
trace elements, nutrients,
pesticides, pathogens, and other
waterborne diseases; deliver
technologies, models, decision
support systems, and management
information to enhance or protect
water quality.
Department of the
Interior
Fish and Wildlife
Service
Partners for Fish $97.87 $24.36 To restore habitat for federal trust
and Wildlife species through voluntary agreements
($97.87) with private landowners.
Off-Refuge $4.18 $0.86 To protect and enhance the quality of
Investigations the habitat and environment on which
($5.58) fish and wildlife trust resources
depend, and provide recommendations
and support state and other federal
agencies in implementing management
actions to resolve contaminant
problems.
On-Refuge $7.13 $1.4 To protect and enhance the quality of
Investigations the habitat and environment on which
($9.5) fish and wildlife trust resources
depend, and provide recommendations
and support refuge managers in
implementing management actions to
resolve contaminant problems.
Clean Vessel Act $40 0 To install pumpout stations for the
Pumpout Grant removal of sewage from boats with
Program ($40) holding tanks and portable toilets
and to educate boaters on the need
for using pumpout and dump stations
and where these facilities are
located.
Oil Spill $2.2 $0.30 To minimize injuries to Fish and
Response\e Wildlife-managed resources.
(0)
Bureau of Land
Management
Soil, Water, Air $48.96 $13.41 To provide for the protection of
Management watershed values (such as soil
($91.50) stability) and air quality on the
public lands; reduce salinity and
runoff from the public lands to
protect water quality; provide for
the legal availability of water on
public lands; provide information for
public lands, watersheds, and air
resources; and support BLM's
"Riparian Wetlands Initiative."
Rangeland $132.04 $32.61 To manage public rangelands to ensure
Management their long-term health, natural
($248) diversity, and productivity.
Riparian Management $39.24 $9.88 To enhance riparian/aquatic habitat to
improve water quality and to complete
($73.58) the proper functioning assessments of
natural indicators and
characteristics of riparian areas in
the lower 48 states by implementing
the "Clean Water and Watershed
Restoration Initiative."
Oregon and $76.30 $17.64 To manage the following types of
California Grant resources (excludes forest
Lands and Other ($143.44) management): recreation; wildlife
Resources habitat and fisheries; soil, water,
and air; and rangeland. This program
is a portion of a larger activity to
manage resources on Oregon and
California grant lands in western
Oregon.
USGS
National Water $255.69 $54.58 To identify the status and trends in
Quality Assessment water quality conditions for major
Program ($300.81) water resource areas (surface and
groundwater) and the human and
natural conditions that cause
existing water quality conditions;
and communicate findings to resource
managers and policy makers.
National Trends $15.09 $2.99 To provide a nationwide, long-term
Network record of spatial and temporal trends
($8.75) in atmospheric deposition.
Office of Surface
Mining
Abandoned Mine Land $626.26 $128.09 To restore lands mined and abandoned
Program or left inadequately reclaimed prior
($695.85) to Aug. 3, 1977, thereby protecting
society and the environment from the
adverse effects of surface coal
mining operations.
Clean Streams $6.52 $2.52 To clean streams and rivers polluted
Initiative by acid and toxic drainage form
($6.52) abandoned coal mines.
Bureau of
Reclamation
Colorado River $85.53 $15.52 To prevent any further degradation of
Basin Salinity the Colorado River and limit damages.
Control Program ($85.53)
NOAA
Coastal Nonpoint $12.02 $2.24 To protect and restore coastal waters
Pollution Control and help states establish enforceable
Program ($10.0) programs for comprehensively
addressing the most significant
sources of nonpoint pollution.
Coastal Zone $23.81 $5.15 To encourage states to manage their
Management Program coastal land and water resources.
($229.1)
Department of
Defense-Army
Integrated Training $50.35 $20.34 To maintain and sustain training
Area Management lands. These actions indirectly
Program\f ($95.12) contribute towards preventing
nonpoint source pollution.
-----------------------------------------------------------------------------------------
Note: Programs included are those identified by the agencies
surveyed that met at least one of the following criteria: (1)
expenditures addressing nonpoint source pollution exceeded $10
million for at least 1 year during fiscal years 1994 through 1998 or
(2) program activities primarily addressed nonpoint source pollution
regardless of program expenditures. Some reported programs do not
have specific nonpoint source pollution objectives but address the
problem through other objectives.
\a Obligations for nonpoint activities may include an estimated
dollar amount for full-time staff over and above appropriated funds,
if reported by the agency. In some cases, this may result in the
total amount devoted to addressing nonpoint source pollution to be
greater than the appropriated amount.
\b The Environmental Quality Incentives Program combines several of
USDA's conservation programs--the Agricultural Conservation Program
(including Water Quality Incentives Projects), the Colorado River
Basin Salinity Control Program, and the Great Plains Conservation
Program. These programs received partial appropriated funding in
fiscal year 1996 before being consolidated. In addition, some of
these programs had outlays in later years in order to service prior
year contracts.
\c The Environmental Quality Incentives Program and the Conservation
Reserve Program do not receive appropriations. These programs are
funded through the Commodity Credit Corporation. The Wetland Reserve
Program began receiving funds through the Commodity Credit
Corporation for fiscal year 1997.
\d USDA did not provide dollar amounts for this program. Instead,
USDA identified 4,720 full time equivalents out of a total of 11,800
that could be considered as helping to reduce nonpoint source
pollution.
\e No funds were appropriated to this program during this period.
Funds used to address nonpoint pollution were entirely from full-time
staff equivalents.
\f DOD only reported obligations for this program for fiscal years
1996 through 1998. According to the Department, prior to this, the
program was managed by a different office, and expenditures were not
tracked in a way that allowed for separating funding obligated for
nonpoint source-related activities.
(See figure in printed edition.)Appendix III
COMMENTS FROM THE DEPARTMENT OF
AGRICULTURE AND OUR EVALUATION
========================================================== Appendix II
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
The following are GAO's comments on the Department of Agriculture's
(USDA) letter dated January 29, 1999. Several of USDA's services
provided clarifications and technical points that were incorporated
into the report as appropriate. Within the letter, there are 21
points on which we provide the following comments.
1. The Natural Resources Conservation Service (NRCS) said that the
information in the executive summary indicating that USDA programs
represent almost 80 percent of the funding identified for nonpoint
source pollution is misleading because, as the draft points out
later, its largest program--the Conservation Reserve Program--has no
specific nonpoint source objectives. NRCS suggested that certain
information in the body of the report be reflected in the executive
summary to clarify that while activities under the program do in fact
address nonpoint source pollution, nonpoint source pollution control
is not a stated objective of the program. We have made these changes
as suggested.
2. NRCS commented that an example in the draft report where Arizona
officials reported that activities on federal lands contribute to 50
percent of the water quality problems in the state provides no
indication of the relative size of the federal contribution to these
waters. This information was provided by state officials who are
required by the Clean Water Act to routinely assess their waters for
water quality problems and identify contributing sources. While they
do not quantify the contribution of individual sources to impaired
waters, Arizona officials did indicate that federal activities were
the "primary" source of 50 percent of the water quality problems in
the state. We have added this distinction to the report.
3. NRCS requested that we revise the language in the draft to
clarify that water quality is not the sole purpose of funding for
EQIP and the Conservation Reserve Program, noting that environmental
benefits can include water quality, but may not have this benefit in
some locations. We have clarified the report where appropriate.
However, we asked agencies to report on programs that in their
opinion helped address nonpoint source pollution. By including
programs in this report, we are not suggesting that all the programs
focused exclusively on nonpoint source pollution. We recognize that
some programs simply help reduce nonpoint source pollution through
the implementation of other program objectives.
4. NRCS suggested that we add an item to our graphic depicting
possible sources of nonpoint source pollution in a watershed showing
"all vehicle traffic" as an additional possible source. We agree
that vehicle traffic is another possible source of nonpoint
pollution, however, our graphic was not intended to include every
pollution source.
5. See comment 1.
6. NRCS commented that to say that all funds for the EQIP program
went to nonpoint source may be "stretching it, since some areas do
not have enough rainfall to have runoff or be a source." We reported
that 100 percent of EQIP funding addressed nonpoint source pollution
based on information from the agency. The rationale provided by the
agency in response to our questionnaire noted that, "EQIP is intended
to solely address nonpoint source pollution from farms and ranches."
In addition, we discussed the issue of percent of program funds
targeted to addressing nonpoint source pollution several times with
agency officials to be sure that the 100-percent figure was
appropriate. Moreover, one conservation official addressed the issue
of lack of rainfall by pointing out that such areas will either (1)
not be capable of producing crops and, therefore, not be eligible for
funding or (2) be irrigated, making runoff a possibility.
7. NRCS commented that EQIP should not be characterized as a
nonpoint source pollution-reduction program. As discussed in comment
6, we reported information on the program based on information the
agency provided in response to our questionnaire. To avoid any
confusion, we have revised the text in the report to reflect language
in the final rule as suggested by the Service.
8. The draft did not include the two programs cited in this comment,
the Wetlands Reserve Program and the Forestry Incentives Program,
because agency officials initially indicated that neither program met
our criteria for inclusion. We included information on the Wetlands
Reserve Program provided later by USDA in appendix II; however, no
program and funding data were provided for the other program.
9. NRCS commented that the section heading, "Federal Activities That
Contribute Significantly to Nonpoint Source Pollution," leaves the
impression that all activities cause nonpoint source pollution. NRCS
suggested that the heading be reworded to reflect that activities
contribute when not properly managed, and remove the word
"significant." We agree that water quality impacts can be minimized
by the use of appropriate management practices and discuss some of
these practices in each of the activity sections. However, such
practices may not always be in place. We have revised the heading to
acknowledge that all the activities do not necessarily contribute to
nonpoint source pollution, but rather "have the most potential" to
contribute. We have left the reference to "significant"
contributions because this section discusses the activities that
federal and state officials identified as those with the potential to
be the most significant contributors.
10. NRCS questioned the example that "30 percent of all impaired
waters in the state of Oregon are due to grazing." We reported that
"federally authorized grazing contributes to the degradation of about
30 percent of all impaired waters in the state." This information was
obtained from the state nonpoint source pollution program manager
based on the state's list of impaired waters. As discussed in
comment 2., states routinely assess their waters for water quality
problems and identify the sources contributing to the problems, as
required by the Clean Water Act, but do not quantify the contribution
of individual sources.
11. NRCS commented that two of the programs included in the draft
did not address nonpoint source pollution, nor was it a collateral
benefit of the programs. As discussed in comment 8., we included
information provided by the respective agency program officials.
Regarding the National Resource Inventory, the agency said that the
program addressed nonpoint source pollution because it collects data
on agriculturally related natural resource elements that can be used
to provide some measure of nonpoint source pollution rates. For the
Watershed Protection and Flood Prevention Program, the agency said
that, among other objectives, the program is intended to improve or
enhance water quality and quantity and that "about 975 watershed
projects have a significant impact on nonpoint source pollution."
12. The Agricultural Research Service (ARS) commented that we did
not address the adequacy of scientific understanding of nonpoint
source pollution. Such an analysis was outside the scope of this
review.
13. ARS also commented that there was inconsistency in the type of
programs addressing nonpoint source pollution identified in our
report. See comments 8 and 11 for information regarding how we
identified programs for inclusion in the report.
14. We have added information on ARS' Water Quality/Research,
Development, Information Program, as requested.
15. The Forest Service suggested that the relationship between the
magnitude of federal lands and the proportion of nonpoint source
pollution should be conditioned in terms of potential rather than
actual, noting that management practices intended to minimize
nonpoint source pollution are prescribed for all Forest Service
projects. As discussed in chapter 4, information obtained from the
states we contacted does in fact show that a significant amount of
water quality problems can be attributed, at least in part, to
activities occurring on federal land. However, we acknowledge the
variability in this relationship, noting that the degree of pollution
in specific areas may depend on site-specific characteristics such as
geographic and hydrologic conditions, the type of activities
occurring and intensity of use, and management practices applied to
minimize impacts. Accordingly, as suggested by the Forest Service,
we modified language in this chapter where appropriate to
characterize the association between a large portion of federally
owned land to contributing a significant amount of nonpoint pollution
as potential rather than actual.
16. As an additional point, the Forest Service provided data to show
how silvicultural activity is occurring on just a small part of
national forest lands. We did include information regarding the
decline of silvicultural activities in the report; however, Forest
Service research has shown that pollution from harvest sites may
continue for decades after a harvest has been completed. In
addition, silviculture is just one of the many activities occurring
on Forest Service land that may lead to nonpoint source pollution.
While federal agencies are implementing practices to minimize water
quality impacts from current activities, agencies must also deal with
impacts resulting from past activities and practices. In several
sections of chapter 4, we acknowledge that past practices contribute
to water quality impacts.
17. The Forest Service commented that it devotes more resources to
addressing nonpoint source pollution than is reflected in the one
program included in our report--the Watershed Research Program. The
Service said that the control of nonpoint source pollution is the
responsibility of each resource program manager. While the Service
did not provide cost estimates for these activities, we have noted
this comment in the report.
18. The Cooperative State Research, Education, and Extension Service
commented that we did not discuss the research needs associated with
nonpoint source pollution. Assessing the adequacy of funding for
nonpoint source pollution research was outside the scope of this
review.
19. The Extension Service encouraged coordination among EPA and
other USDA agencies within the Department with regard to
watershed-based modeling research, but noted that NRCS was the only
agency we discussed in the report. We agree that all relevant
agencies in USDA should coordinate research on nonpoint source
pollution modeling to avoid duplication and help move scientific
understanding of the problem forward as efficiently as possible. We
included NRCS in our report because it was one of the few federal
agencies that had developed a nationwide model relevant to our
evaluation of EPA's nonpoint source control modeling approach.
20. The Extension Service suggests that we examine biases in the
states' evaluation of surface water quality problems. Such an
analysis was outside the scope of this review.
21. The Extension Service also makes some observations on, and
criticisms of, the Clean Water Action Plan and how it can be used as
a means to further address nonpoint source pollution issues. We
provided factual information about the Clean Water Action Plan since
several of its components address nonpoint source pollution, in
particular funding increases for several of the programs included in
our report. However, an analytical evaluation of the Action Plan
(including the assumptions made regarding the current understanding
of water quality problems and associated research and monitoring
needs) was beyond the scope of this review.
(See figure in printed edition.)Appendix IV
COMMENTS FROM THE FEDERAL ENERGY
REGULATORY COMMISSION AND OUR
EVALUATION
========================================================== Appendix II
The following are GAO's comments on FERC's comments on our draft
report. The Commission agreed with the report's major conclusions,
but raised three concerns regarding how hydropower is characterized
in the report. The Commission also made several clarifications and
technical points that were incorporated into the report as
appropriate. Our comments to the Commission's three major concerns
follow.
1. FERC expressed concern that a lay reader would misconstrue the
word "hydromodification" or think that the term is interchangeable
with "hydropower." We believe we have properly defined
hydromodification to make it clear that hydropower is just one
example of hydromodification activities. In each instance where we
introduce the term hydromodification, we refer to the major
categories of hydromodification--channelization and dams and
reservoirs. In addition, we provide explanations of the types of
projects included in each of the categories. For example, in the
Results in Brief, we provide the example for hydromodification, "such
as building and operating dams, or modifying rivers for flood control
and other purposes." Similarly, in the first paragraph of the
hydromodification section, we describe hydromodification activities
as "channelization and the construction and operation of dams."
Later, in the subsection on dams and reservoirs, we describe such
structures as being "multipurpose, such as providing municipal and
industrial water supply, flood control, recreation, irrigation, and
power generation."
2. FERC believes that we have misrepresented hydropower as a
nonpoint source of pollution, stating that "hydropower is not a
nonpoint source of pollutants, but rather an activity that can
positively or negatively affect the impacts of pollutants introduced
by nonpoint sources." However, as described in an EPA technical
document regarding management measures for sources of nonpoint
pollution, dams (which can be constructed for many purposes including
flood control, power generation, irrigation, and municipal water
supply) "can generate a variety of types of nonpoint source pollution
in surface waters."\1 Examples of such pollution are discussed in our
report such as increased downstream erosion and changes in water
temperature and dissolved oxygen levels that may impact aquatic life.
FERC acknowledges in its comments that hydropower projects do have
these negative effects. Therefore, in these instances, we believe it
is appropriate to portray hydropower as an original source of
nonpoint pollution. However, we acknowledge that most of our
examples regarding the impacts of hydromodification are hydropower
examples and may have overemphasized the negative impacts of
hydropower in this section. We have revised the text to recognize
that the impacts discussed may result from any of the types of
hydromodification, not just hydropower projects.
3. The Commission commented that the draft does not distinguish
between federally operated projects and Commission-licensed projects,
which are generally smaller and, therefore, should not be represented
as having the same environmental impacts. The draft did, in fact,
distinguish between Commission-licensed projects and federally
operated projects, noting the number of projects of each and, in
particular, the environmental requirements to which the nonfederal
projects are subject. Moreover, while we acknowledge FERC's point
about the relatively smaller size of FERC-licensed projects (.09
billion kilowatt hours per year versus .9 billion kilowatt hours per
year for federally operated projects), we would point out that there
is a considerably greater number of these smaller projects
nationwide--1,750 FERC-regulated projects versus 133 federally
operated projects. Beyond this distinction, however, we would add
that in many respects, the types of impacts described apply
generically to dam and reservoir operations regardless of whether it
is a FERC-licensed project, a federally operated project, or whether
the project's primary purpose is for a use other than hydropower. In
addition, as with the other sources of nonpoint pollution, the extent
of the potential impact varies significantly with site-specific
characteristics and management practices employed at the project.
(See figure in printed edition.)Appendix V
--------------------
\1 Guidance Specifying Management Measures For Sources Of Nonpoint
Pollution in Coastal Waters, U.S. Environmental Protection Agency,
(Jan. 1993).
COMMENTS FROM THE DEPARTMENT OF
THE INTERIOR AND OUR EVALUATION
========================================================== Appendix II
The following are GAO's comments on the Department of the Interior's
letter dated January 26, 1999. Additional specific comments were
provided by the individual services and bureaus within Interior and
have been addressed as appropriate. Many of these specific issues
are also discussed at the end of chapters 2, 3, and 4. Our comments
on the Department's two major concerns follow.
1. Interior expressed concern that the draft report appeared to
equate the magnitude of nonpoint source pollution to the amount of
federally managed land involved. As discussed in chapter 4,
information obtained from the states that we contacted does in fact
show that a significant proportion of water quality problems can be
attributed, at least in part, to activities occurring on federal
land. However, we acknowledge the variability in this relationship,
noting that the degree of pollution in specific areas may depend on
site-specific characteristics such as geographic and hydrologic
conditions, the type of activities occurring and intensity of use,
and management practices applied to minimize impacts. Accordingly,
where appropriate, we modified language in this chapter to
characterize the contribution to nonpoint source pollution from
federal lands as potential rather than actual.
2. Interior also points out that federal land managers are working
diligently to develop and implement new land management practices
which will conserve our natural resources and reduce the impacts of
the activities they conduct or permit on water resources. We agree
that water quality impacts can be minimized by the use of appropriate
management practices and discuss some of these practices in each of
the activity sections. However, such practices may not always be in
place. Moreover, as pointed out by federal and state officials, as
well as by Forest Service research, water quality impacts continue to
result from past management practices, such as the type of heavy
grazing that occurred in the late 1800s and past timber harvesting
methods.
(See figure in printed edition.)Appendix VI
COMMENTS FROM THE DEPARTMENT OF
COMMERCE AND OUR EVALUATION
========================================================== Appendix II
(See figure in printed edition.)
The following are GAO's comments on the Department of Commerce's
letter dated February 2, 1999. The Department provided a few
technical clarifications which were incorporated into the report as
appropriate. Our comments on the Department's two concerns follow.
1. Report modified as suggested.
2. The Department commented that in appendix II, we did not have
complete data for the Coastal Nonpoint Pollution Control Program.
Commerce clarified that additional program funding, $1 million, was
provided by EPA for fiscal year 1998. We have added the additional
funding data and its source.
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix VII
RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C.
Jennifer Clayborne
Michael Daulton
Steve Elstein
Tim Guinane
Karen Keegan
Patricia Macauley McClure
*** End of document. ***