oversight

Water Quality: Federal Role in Addressing and Contributing to Nonpoint Source Pollution

Published by the Government Accountability Office on 1999-02-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              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
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Resources, Community, and
      Economic Development Division

      B-281614

      February 26, 1999

      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


             Much progress has been made to restore the quality of the nation’s
Purpose      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.


             Nonpoint source pollution occurs when pollutants from diffuse sources
Background   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

             1
             The Federal Water Pollution Control Act, 33 U.S.C. §§1251-1387, is generally referred to as the Clean
             Water Act.



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                   Executive Summary




                   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.


                   The federal agencies GAO contacted reported spending about $3 billion
Results in Brief   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



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Executive Summary




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,

2
 A watershed is an area of land in which all surface water drains to a common point.



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                             Executive Summary




                             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.



Principal Findings

A Diverse Array of Federal   Among the agencies GAO contacted, total federal annual spending for
Programs Address             nonpoint-related programs remained relatively constant from fiscal year
Nonpoint Source Pollution    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

                             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.



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                           Executive Summary




                           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.


EPA’s Methodology for      Estimating the costs to control nonpoint source pollution nationwide is a
Estimating Nonpoint        difficult task. Critical information, such as identification of waters
Source Pollution Control   contaminated with nonpoint pollution and the contribution of each of
                           those sources, is not readily available at the local level, much less at a
Costs Could Be Improved    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).




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Executive Summary




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



Page 7                                  GAO/RCED-99-45 Nonpoint Source Pollution
                            Executive Summary




                            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      Under a variety of missions and legislative requirements, federal agencies
Managed or Authorized       manage, authorize, or issue permits or licenses for, a variety of activities
Activities Can Contribute   that provide public benefit but may have the unintended side effect of
                            contributing to nonpoint source pollution. The Forest Service, for
to Nonpoint Source          example, provides commercial opportunities such as timber harvesting
Pollution                   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.



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                      Executive Summary




                      In order to improve EPA’s approach toward estimating the cost of
Recommendations       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.


                      GAO provided a draft of this report for review and comment to the
Agency Comments       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.



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Executive Summary




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’srecommendation that EPA work with other agencies to develop a
watershed-based approach that can be used in developing more realistic



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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



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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.




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Page 13   GAO/RCED-99-45 Nonpoint Source Pollution
Contents



Executive Summary                                                                                    2


Chapter 1                                                                                           18
                         Nonpoint Sources of Pollution Are Varied                                   18
Introduction             Federal and State Responsibilities for Controlling Nonpoint                20
                           Source Pollution
                         Objectives, Scope, and Methodology                                         21


Chapter 2                                                                                           25
                         Key Federal Programs That Address Nonpoint Source Pollution                25
A Diverse Array of       Clean Water Action Plan to Further Address Nonpoint Source                 40
Federal Programs           Pollution
                         Agency Comments                                                            41
Address Nonpoint
Source Pollution
Chapter 3                                                                                           43
                         Clean Water Act Requires EPA to Report to the Congress on                  43
EPA’s Methodology          Water Quality Project Needs
for Estimating           EPA’s Methodology Has Several Limitations                                  46
                         Watershed-Based Approach Offers a Promising Alternative to                 48
Nonpoint Source            Estimate Control Costs
Pollution Control        Conclusions                                                                51
Costs Could Be           Recommendations                                                            51
                         Agency Comments                                                            51
Improved
Chapter 4                                                                                           54
                         Federal Activities With the Most Potential to Contribute                   54
A Variety of Federally     Significantly to Nonpoint Source Pollution
Managed or               Other Federally Managed or Authorized Activities That Can                  71
                           Contribute to Nonpoint Source Pollution
Authorized Activities    The Federal Contribution to Nonpoint Source Pollution May Be               75
Can Contribute to          Significant in Many Western Watersheds
Nonpoint Source          Agency Comments                                                            77
Pollution
Appendixes               Appendix I: Other Clean Water Act Sections Addressing Nonpoint             80
                           Pollution




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          Contents




          Appendix II: Non-EPA Federal Programs That Address Nonpoint                83
            Source Pollution
          Appendix III: Comments From the Department of Agriculture and              88
            Our Evaluation
          Appendix IV: Comments From the Federal Energy Regulatory                  101
            Commission and Our Evaluation
          Appendix V: Comments From the Department of the Interior and              104
            Our Evaluation
          Appendix VI: Comments From the Department of Commerce and                 106
            Our Evaluation
          Appendix VII: Major Contributors to This Report                           109


Table     Table 3.1: Estimated Capital Expenditures for Controlling                  46
           Nonpoint Source Pollution Nationwide


Figures   Figure 1.1: Activities Within a Watershed That Can Contribute to           19
            Nonpoint Source Pollution
          Figure 2.1: Obligations Addressing Nonpoint Source Pollution for           26
            Fiscal Years 1994 Through 1998, by Agency
          Figure 2.2: EPA Obligations Addressing Nonpoint Source                     27
            Pollution for Fiscal Years 1994 Through 1998
          Figure 2.3 CWSRF Obligations Addressing Nonpoint Source                    30
            Pollution for Fiscal Years 1994 Through 1998
          Figure 2.4: USDA Obligations Addressing Nonpoint Source                    33
            Pollution for Fiscal Year 1998
          Figure 4.1: Activities Contributing to Nonpoint Source Pollution           55
            That are Managed or Authorized by Each Agency Included in Our
            Review
          Figure 4.2: Federal Ownership of Timberland Suitable for                   56
            Harvest, by Agency
          Figure 4.3: Channel Incision From Forest Road                              58
          Figure 4.4: Forest Service Road Improvement Project                        60
          Figure 4.5: Unauthorized Roads on Forest Service Land                      61
          Figure 4.6: Acreage Available for Grazing by Federal Agency                62
          Figure 4.7: Healthy Riparian Area and Eroded Streambank                    63
          Figure 4.8: Abandoned Mines                                                65
          Figure 4.9: Recreational Visits to Federal Lands, by Agency                67
          Figure 4.10: Watersheds in Which Land Owned by the Federal                 75
            Government Exceeds 50 Percent




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Contents




Abbreviations

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


Page 16                             GAO/RCED-99-45 Nonpoint Source Pollution
Page 17   GAO/RCED-99-45 Nonpoint Source Pollution
Chapter 1

Introduction


                       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.


                       Nonpoint sources of water pollution include a wide array of land-based
Nonpoint Sources of    activities such as timber harvesting, grazing, urban development, and
Pollution Are Varied   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.


                       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.
                       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.



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                                                  Introduction




Figure 1.1: Activities Within a Watershed That Can Contribute to Nonpoint Source Pollution

    A Abandoned mine
    B Grazing
    C Hydromodification - dams/reservoir
    D Farming
    E Recreation - swimming, boating, fishing
    F Recreation - camping, hiking, hunting
    G Forest roads - recreation and other uses
                                                                                                                A
    H Silviculture - timber operations and use of forest roads
                                                                                         B
    I Urban development - runoff from lawns, parking lots, etc.
                                                                                                                    C
    J Roads, highways, bridges
                                                                                             Tributaries


                                                            G
                                                                       F
                                                                                                  D         E


                                                                            Stream




                                                        Riparian
                                                          zone
                                                                                     I                     Watershed
                                                                                                            divide
                                                  H

                                                                           Town
                                                                   J




                                                  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



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                       Introduction




                       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.


                       The nature and extent of nonpoint source pollution is essentially a
Federal and State      function of the way individuals use the land. Therefore, regulating these
Responsibilities for   activities has been a sensitive issue since land use decisions are largely
Controlling Nonpoint   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
Source Pollution       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.

                       3
                        This program also includes states that border the Great Lakes. 16 U.S.C. §1453.



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                     Introduction




                     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.


                     The Chairman, Subcommittee on Water Resources and Environment,
Objectives, Scope,   House Committee on Transportation and Infrastructure, asked us to
and Methodology      (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);

                     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).



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(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.




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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



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Introduction




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.




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A Diverse Array of Federal Programs
Address Nonpoint Source Pollution

                       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.


                       The 35 federal programs identified by the agencies represent a broad array
Key Federal Programs   of activities, reflecting diversity in both the nature of nonpoint source
That Address           pollution and the remedies needed to address it. Some programs are
Nonpoint Source        intended to deal directly with the problem. EPA’s National Nonpoint Source
                       Program, for example, provides financial and technical assistance to help
Pollution              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

                       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.



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                                       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

                                                                                                      Interior $1.44 billion
                                                                          10.1%
                                                                                                      Environmental Protection
                                                                                                      Agency $1.15 billion
                                                                            8.1%
                                                      81.2%                                          0.4%
                                                                                                     Defense $50.35 million

                                                                                                     0.3%
                                                                                                     National Oceanic and Atmospheric
                                                                                                     Administration $35.83 million



                                                                                                     Agriculture $11.54 billion


                                       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                           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




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                                       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                                                                 National Nonpoint Source
                                                                                                   Program $544.4 million

                                                                                                  Drinking Water State
                                                                                                  Revolving Fund Program
                                                                                                  $111.8 million
                                                           47.3%
                                                                                9.7%              Chesapeake Bay Program
                                                                                                  $51.57 million
                                                                                   4.5%
                                                                                                  0.3%
                                                                                                  Other programs
                                                                                                  $3.91 million
                                                               38.5%
                                                                                                 Clean Water State
                                                                                                 Revolving Fund Program
                                                                                                 $442.8 million


                                       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               Section 319 of the Clean Water Act established a national nonpoint source
Program                                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

                                       3
                                       EPA also provides grants to tribes and other jurisdictions to develop and implement nonpoint source
                                       management programs.



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                              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.

Clean Water State Revolving   EPA’s  Clean Water State Revolving Fund Program was established under
Fund Program                  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.




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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.




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.



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Figure 2.3 CWSRF Obligations
Addressing Nonpoint Source Pollution
for Fiscal Years 1994 Through 1998       Dollars in millions
                                         200


                                                                                    $151.7
                                         150



                                                                    $98.7                                       $96.3
                                         100
                                                                                                  $75.6



                                          50

                                                     $20.5


                                           0
                                                    1994            1995             1996         1997          1998
                                                                                  Fiscal year

                                       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.

The Drinking Water State               The Drinking Water State Revolving Fund Program (DWSRF) was
Revolving Fund Program                 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




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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

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.



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                         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.

Chesapeake Bay Program   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       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     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



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                                       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


                                                                                                   Environmental Quality Incentives
                                                                        10.6%                      Program $232 million

                                                                               11.2%               Other programs $245.8 million

                                                        78.1%
                                                                                                   Conservation Reserve Program
                                                                                                   $1.71 billion




                                       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.


Conservation Reserve Program           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

                                       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.




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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.



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Environmental Quality         USDA’s Environmental Quality Incentives Program (EQIP) was created by
Incentives Program            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.

Other Agricultural Programs   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

                              10
                                Pub. L. No. 104-127 (Apr. 4, 1996).



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                              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             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   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

                              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).



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                          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.

Other Interior Programs   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



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                         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   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.


                         12
                           Pub. L. No. 92-583, 86 Stat. 1280 (Oct. 27, 1972), 16 U.S.C. 1451-1465.



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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

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.



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                     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.


                     In October 1997, the Vice-President directed EPA and USDA to work with
Clean Water Action   other federal agencies and the public to develop a Clean Water Action
Plan to Further      Plan. The plan, issued in February 1998, acknowledged the progress that
Address Nonpoint     had been made in past decades by focusing largely on point sources of
                     pollution, but maintained that additional steps—and a more holistic
Source Pollution     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




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                  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.


                  The Department of Agriculture’s Natural Resources Conservation Service
Agency Comments   (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



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information provided by these officials led to a revised estimate, which we
incorporated in the report.




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EPA’s Methodology for Estimating Nonpoint
Source Pollution Control Costs Could Be
Improved
                        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.


                        Under the Clean Water Act, EPA is required to report to the Congress every
Clean Water Act         2 years on the estimated cost of carrying out the provisions of the act.
Requires EPA to         Historically, EPA’s report, known as the Clean Water Needs Survey, has
Report to the           focused on estimating the costs of construction, or capital costs, of all
                        needed publicly owned treatment works (e.g., waste water treatment
Congress on Water       plants) which are funded under the CWSRF. However, as reported in
Quality Project Needs   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.

                        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.



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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

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.



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Source Pollution Control Costs Could Be
Improved




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




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.



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Table 3.1: Estimated Capital
Expenditures for Controlling Nonpoint   Dollars in billions (1996)
Source Pollution Nationwide             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.




                                        EPA  officials acknowledge that their methodology has several limitations,
EPA’s Methodology                       including the omission of (1) the cost of controlling runoff associated with
Has Several                             other potentially significant sources of nonpoint source pollution such as
Limitations                             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                    As EPA acknowledges in its 1996 Clean Water Needs Survey report, the
Include Other Potentially               methodology considers only selected sources of nonpoint source
Significant Nonpoint                    pollution—agriculture, silviculture, and animal feeding operations. Many
                                        other sources of nonpoint pollution contribute to water pollution and
Sources                                 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,



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                             Improved




                             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.


Methodology Does Not         EPA also acknowledged that its methodology does not account for the
Include Costs of Operating   annual operating and maintenance (O&M) costs that farmers and others
and Maintaining Best         might incur in implementing best management practices and other
                             management measures to control erosion. As a result, only a portion of the
Management Practices         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       In developing the cost estimates, EPA did not fully assess the uncertainty
Not Fully Assess the         that is associated with the underlying assumptions and data used in the
Uncertainty Associated       analysis. Accordingly, EPA’s 1996 Clean Water Needs Survey report
                             presents the control costs for each source category as single point
With Estimating Control      estimates. Such a presentation, however, implies a level of precision that
Costs
                             7
                              President Clinton’s Clean Water Initiative: Analysis of Benefits and Costs, U.S. Environmental
                             Protection Agency, (Mar. 1994).



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                           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            We found it difficult to thoroughly evaluate EPA’s methodology because it
Methodology Is Not Fully   did not fully document the key assumptions and data used in its analysis.
Documented                 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.


                           Addressing the limitations mentioned previously can improve EPA’s cost
Watershed-Based            estimation methodology and resulting cost estimate, but the agency is also
Approach Offers a          considering an additional approach that would take into account the
Promising Alternative      unique characteristics of individual watersheds. Agency officials indicated,
                           however, that the added cost of this “watershed-based approach” could
to Estimate Control        constrain such an effort. A USDA official involved in similar work suggests
Costs                      that improved coordination between EPA and this agency could help
                           advance EPA’s effort.




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Current Methodology Does     EPA’s  current methodology relies primarily on data collected on a
Not Account for Unique       countywide or statewide basis—data that were collected along political
Characteristics of           boundaries rather than watershed boundaries. The practical effect of this
                             limitation is that the effects of the unique characteristics of individual
Watersheds                   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.”


Other Agencies Have Made     EPA officials told us that a significant barrier impeding the use of a
Progress in Developing and   watershed-based approach is the additional resources the approach would
Using a Watershed            require. The officials said that developing a watershed-based model to
                             estimate nonpoint source pollution costs could cost about $750,000,
Approach                     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.


                             8
                              Soil runoff is defined as soil loss in excess of the amount needed to maintain the productivity of the
                             soil to grow crops.



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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

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.



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                      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.


                      As noted in this chapter, a number of improvements can and should be
Conclusions           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.


                      To improve EPA’s approach toward estimating the cost of controlling
Recommendations       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.


                      EPA acknowledged that our assessment of the cost-estimation
Agency Comments       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



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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



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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.




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Chapter 4

A Variety of Federally Managed or
Authorized Activities Can Contribute to
Nonpoint Source Pollution
                     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.


                     In pursuit of widely varying missions and legislative requirements, federal
Federal Activities   agencies manage, authorize, or issue permits or licenses for, a variety of
With the Most        activities that provide public benefit such as recreation, timber harvesting,
Potential to         and livestock grazing. For example, the Forest Service (USFS) and the
                     Bureau of Land Management (BLM) provide for timber harvesting and
Contribute           livestock grazing on their lands as well as for recreational opportunities.
Significantly to     Figure 4.1 identifies which federal agencies included in our review manage
                     or authorize the activities identified by state and federal officials as being
Nonpoint Source      the nonpoint sources of most concern.
Pollution




                     1
                      Not all federally authorized activities occur on federal land. Licensing of private hydropower projects
                     and highways constructed with federal aid are examples.



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                                         Chapter 4
                                         A Variety of Federally Managed or
                                         Authorized Activities Can Contribute to
                                         Nonpoint Source Pollution




Figure 4.1: Activities Contributing to
Nonpoint Source Pollution That Are
Managed or Authorized by Each




                                                                                                                             ds
Agency Included in Our Review




                                                                                                                          lan




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                                                                                                                     ine




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                                                                                                                 dm



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                                                                                      e




                                                                                                               dif
                                                                                                              tio
                                                                                   ur




                                                                                                            ne
                                                                                              ing




                                                                                                          mo
                                                                                   lt




                                                                                                           ea
                                                                                                         do
                                                                                 cu


                                                                                            az




                                                                                                        cr


                                                                                                      dro
                                                                                                       an
                                                                              lvi




                                                                                                     Re
                                                                                          Gr
                                                                            Si




                                                                                                    Ab




                                                                                                    Hy
                                            Agency

                                            Forest Service                  X             X         X     X
                                            Bureau of Land
                                            Management                      X             X         X     X

                                            Fish and Wildlife Service       X             X         X     X
                                            Park Service                                  X         X     X
                                            Bureau of Reclamation                         X               X         X
                                            Dept. of Defense                X             X         X     X
                                            Army Corps of Engineers
                                                                                          X               X         X
                                            Federal Energy
                                            Regulatory Commission                                          X       X


                                         Source: Prepared by GAO using agency data.




Silviculture — Timber                    Silviculture includes the management and care of forests, such as timber
Harvesting and Forest                    harvesting, road construction, replanting, and chemical treatments. As
Roads                                    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.




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                                      A Variety of Federally Managed or
                                      Authorized Activities Can Contribute to
                                      Nonpoint Source Pollution




Figure 4.2: Federal Ownership of
Timberland Suitable for Harvest, by
Agency




                                                          88.3%                                     Forest Service
                                                                                                    49 million acres

                                                                                   7.2%             Bureau of Land
                                                                                                    Management
                                                                                    4.5%            4 million acres

                                                                                                     Defense
                                                                                                     2.5 million acres


                                      Source: Prepared by GAO using agency data.


Timber Harvesting                     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.


                                      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.



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              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.

Forest Road   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



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                                    Nonpoint Source Pollution




                                    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




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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.




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).



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Figure 4.4: Forest Service Road Improvement Project




Road improvement to reduce steambank erosion.                                Vegetation recovery.
Mulitiple culverts employed to divert and slow flow.




                                                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.




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Figure 4.5: Unauthorized Roads on Forest Service Land




Grazing                                  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.




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Figure 4.6: Acreage Available for
Grazing by Federal Agency




                                                       62.3%                                      Bureau of Land Management
                                                                                                  165 million acres

                                                                                 2.8%             Other 7.4 million acres



                                                                34.9%                             Forest Service
                                                                                                  92.4 million acres




                                    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


                                    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.



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                                         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.


Figure 4.7: Healthy Riparian Area and Eroded Streambank




Healthy riparian area.                                              Eroded stream bank from grazing activity.




                                         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.


                                         6
                                          BLM only assesses a condition trend for stream miles determined to be “functional—at risk.”



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                  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.


Abandoned Mines   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.




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Figure 4.8: Abandoned Mines




                              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




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             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   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.




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Figure 4.9: Recreational Visits to
Federal Lands, by Agency
                                      Visitor days in millions
                                      400




                                      300




                                      200




                                      100




                                         0
                                                      ice             ce                           nd             on              life
                                                 rv                rvi             rp
                                                                                     s
                                                                                                 La t          ati            ild
                                               Se                 e               o                           m             W
                                          st                   rkS               C             f
                                                                                            u o en        cla            h&
                                       ore                  Pa                my          ea gem        Re            is
                                      F                                    Ar           r                            F
                                                                                      Bu ana
                                                                                       M

                                     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.




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                    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   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



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                 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   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.



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Dams and Reservoirs   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


                      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.



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                        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



                        Several other activities managed or authorized by federal agencies were
Other Federally         identified by state and federal officials as contributing to nonpoint source
Managed or              pollution in some watersheds but were not cited as significant sources of
Authorized Activities   overall concern. These activities include a number of silvicultural
                        activities other than timber harvesting and forest roads, farming, irrigation,
That Can Contribute     federal-aid highways and roads, and military training.
to Nonpoint Source
Pollution

                        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).



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Other Silvicultural   Silvicultural practices other than timber harvesting and forest roads
Practices             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               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            The Bureau and the Corps both provide water resources for private
                      farming, primarily through the construction and operation of canals,



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                           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.


Federal-Aid Highways and   Roads, highways, and bridges funded with federal dollars may also result
Roads                      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.



                           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.



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                    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   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.




                    Page 74                                   GAO/RCED-99-45 Nonpoint Source Pollution
                                        Chapter 4
                                        A Variety of Federally Managed or
                                        Authorized Activities Can Contribute to
                                        Nonpoint Source Pollution




                                        The predominance of federal land ownership in many western watersheds
The Federal                             suggests a potentially significant federal contribution to nonpoint source
Contribution to                         pollution in those areas. Overall, federal lands account for about
Nonpoint Source                         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,
Pollution May Be                        Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming.
Significant in Many                     As indicated in figure 4.10, tracts of federal land can encompass large
                                        portions of many watersheds (shaded areas represent watersheds with
Western Watersheds                      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




                                        Source: USGS.




                                        Page 75                                   GAO/RCED-99-45 Nonpoint Source Pollution
Chapter 4
A Variety of Federally Managed or
Authorized Activities Can Contribute to
Nonpoint Source Pollution




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



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                  Chapter 4
                  A Variety of Federally Managed or
                  Authorized Activities Can Contribute to
                  Nonpoint Source Pollution




                  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.


                  The Department of the Interior said that the draft report appeared to
Agency Comments   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.




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A Variety of Federally Managed or
Authorized Activities Can Contribute to
Nonpoint Source Pollution




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.




Page 78                                   GAO/RCED-99-45 Nonpoint Source Pollution
Page 79   GAO/RCED-99-45 Nonpoint Source Pollution
Appendix I

Other Clean Water Act Sections Addressing
Nonpoint Pollution

                 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.



                 Page 80                                 GAO/RCED-99-45 Nonpoint Source Pollution
    Appendix I
    Other Clean Water Act Sections Addressing
    Nonpoint Pollution




    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.)


    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.



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Appendix I
Other Clean Water Act Sections Addressing
Nonpoint Pollution




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.




Page 82                                     GAO/RCED-99-45 Nonpoint Source Pollution
Appendix II

Non-EPA Federal Programs That Address
Nonpoint Source Pollution


Dollars in millions
                                  FY 1994-1998
                                 obligations for          FY 1998
                                nonpointa (total   obligations for
Title                             appropriated)          nonpoint Objectives
Department of Agriculture
Natural Resources
Conservation Service
Environmental Quality                      $642             $232 To provide flexible technical, educational, and financial
Incentives Programb,c                                            assistance to producers that face the most serious threats
                                          ($530)                 to soil, water, and related natural resources.
Watershed Protection and                $433.26           $80.83 To cooperate with state and local agencies in planning
Flood Prevention                                                 and carrying out work to improve soil conservation and for
                                       ($585.41)                 other purposes—such as flood prevention, and the
                                                                 conservation, development, and utilization of water.
National Resources Inventory              $70.5           $21.68 To provide statistically valid information for agricultural
                                                                 and environmental program and policy development,
                                           ($94)                 implementation, and evaluation.
Great Plains Conservation                $45.99            $3.89 To maintain soil and water resources in the 10 Great
Programb                                                         Plains States by installing corrective practices.
                                         ($40.7)                 Consolidated into EQIP in 1996.
Colorado River Basin Salinity             $31.9            $5.52 To reduce the amount of salt loading to the Colorado
Control Programb                                                 River from surface runoff and subsurface percolation of
                                        ($20.96)                 irrigation water that carries the salt in solution to the river.
                                                                 Consolidated into EQIP in 1996.
Wetland Reserve Programc                 $549.8           $218.6 To protect, restore, and enhance the functions and values
                                                                 of wetland ecosytems.
                                         (549.8)
Highly Erodible Land and                                          To remove certain incentives for persons to produce
Wetland Conservation                                              agricultural commodities on highly erodible land or
Complianced                                                       converted wetland.
Farm Service Agency
Conservation Reserve                   $9,193.6        $1,710.89 To cost effectively reduce water and wind erosion, protect
Programc                                                         the nation’s long-term capability to produce food and
(includes the Conservation              ($8,700)                 fiber, reduce sedimentation, improve water quality, create
Reserve Enhancement                                              and enhance wildlife habitat, and encourage more
Program)                                                         permanent conservation practices and tree planting.
Agricultural Conservation               $462.63           $12.29 To help prevent soil erosion and water pollution, protect
Programb                                                         and improve productive farm and ranch land, conserve
(includes Water Quality                ($369.65)                 water used in agriculture, preserve and develop wildlife
Incentives Projects)                                             habitat, and encourage energy conservation measures.
                                                                 Consolidated into EQIP in 1996.
Emergency Conservation                  $218.63           $35.68 To rehabilitate farm land damaged by natural disaster
Program                                                          and to carry out emergency water conservation measures
                                        ($207.0)                 during periods of severe drought.
Cooperative State Research,
Education, and Extension
Service
                                                                                                                     (continued)


                                       Page 83                                     GAO/RCED-99-45 Nonpoint Source Pollution
                                        Appendix II
                                        Non-EPA Federal Programs That Address
                                        Nonpoint Source Pollution




Dollars in millions
                                   FY 1994-1998
                                  obligations for           FY 1998
                                 nonpointa (total    obligations for
Title                              appropriated)           nonpoint Objectives
National Research Initiative              $28.84              $5.19 To increase the quantity and quality of science applied to
Competitive Grants Program                                          the needs of agriculture and forestry.
                                         ($456.3)
Water Quality Program/                     $39.4               $5.7 To provide educational and technical assistance
Education, Technical, and                                           programs for voluntary farmer adoption of improved
Financial Assistance                      ($26.9)                   management practices to enhance or protect water
                                                                    quality.
Water Quality Program/                    $20.38              $2.46 To measure the impact of farming systems on water
Research and Development                                            quality, identify processes that control fate and transport
                                         ($20.38)                   of chemicals and other contaminants, and determine
                                                                    social and economic impacts of alternative management
                                                                    systems.
Rural Clean Water Programe                 $.094              $.006 To address agricultural nonpoint source pollution
                                                                    problems in watersheds.
                                               (0)
Forest Service
Watershed Research Program                $69.46             $11.30 To conduct long-term studies of the effects of natural
(formerly the Watershed                                             events and land management activities on water quality,
Management and                           ($69.46)                   quantity and timing to provide a scientific basis for land
Rehabilitation Program)                                             managers’ efforts to protect and restore watershed and
                                                                    riparian ecosystems.
Agricultural Research Service
Water Quality/ Research,                  $273.8              $59.2 To measure the impact of farming/ranching practices and
Development, Information                                            systems on water quality; identify processes that control
                                         ($273.8)                   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 and Wildlife            $97.87             $24.36 To restore habitat for federal trust species through
                                                                    voluntary agreements with private landowners.
                                         ($97.87)
Off-Refuge Investigations                  $4.18              $0.86 To protect and enhance the quality of the habitat and
                                                                    environment on which fish and wildlife trust resources
                                          ($5.58)                   depend, and provide recommendations and support state
                                                                    and other federal agencies in implementing management
                                                                    actions to resolve contaminant problems.
                                                                                                                    (continued)




                                        Page 84                                     GAO/RCED-99-45 Nonpoint Source Pollution
                                     Appendix II
                                     Non-EPA Federal Programs That Address
                                     Nonpoint Source Pollution




Dollars in millions
                                FY 1994-1998
                               obligations for           FY 1998
                              nonpointa (total    obligations for
Title                           appropriated)           nonpoint Objectives
On-Refuge Investigations                $7.13               $1.4 To protect and enhance the quality of the habitat and
                                                                 environment on which fish and wildlife trust resources
                                         ($9.5)                  depend, and provide recommendations and support
                                                                 refuge managers in implementing management actions to
                                                                 resolve contaminant problems.
Clean Vessel Act Pumpout                  $40                  0 To install pumpout stations for the removal of sewage
Grant Program                                                    from boats with holding tanks and portable toilets and to
                                         ($40)                   educate boaters on the need for using pumpout and
                                                                 dump stations and where these facilities are located.
Oil Spill Responsee                      $2.2              $0.30 To minimize injuries to Fish and Wildlife-managed
                                                                 resources.
                                            (0)
Bureau of Land Management
Soil, Water, Air Management            $48.96             $13.41 To provide for the protection of watershed values (such
                                                                 as soil stability) and air quality on the public lands;
                                      ($91.50)                   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 Management                  $132.04             $32.61 To manage public rangelands to ensure their long-term
                                                                 health, natural diversity, and productivity.
                                        ($248)
Riparian Management                    $39.24              $9.88 To enhance riparian/aquatic habitat to improve water
                                                                 quality and to complete the proper functioning
                                      ($73.58)                   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 California Grant            $76.30             $17.64 To manage the following types of resources (excludes
Lands and Other Resources                                        forest management): recreation; wildlife habitat and
                                     ($143.44)                   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 Quality                $255.69             $54.58 To identify the status and trends in water quality
Assessment Program                                               conditions for major water resource areas (surface and
                                     ($300.81)                   groundwater) and the human and natural conditions that
                                                                 cause existing water quality conditions; and communicate
                                                                 findings to resource managers and policy makers.
National Trends Network                $15.09              $2.99 To provide a nationwide, long-term record of spatial and
                                                                 temporal trends in atmospheric deposition.
                                       ($8.75)
Office of Surface Mining
                                                                                                                   (continued)



                                     Page 85                                      GAO/RCED-99-45 Nonpoint Source Pollution
                                       Appendix II
                                       Non-EPA Federal Programs That Address
                                       Nonpoint Source Pollution




Dollars in millions
                                  FY 1994-1998
                                 obligations for           FY 1998
                                nonpointa (total    obligations for
Title                             appropriated)           nonpoint Objectives
Abandoned Mine Land                     $626.26            $128.09 To restore lands mined and abandoned or left
Program                                                            inadequately reclaimed prior to Aug. 3, 1977, thereby
                                       ($695.85)                   protecting society and the environment from the adverse
                                                                   effects of surface coal mining operations.
Clean Streams Initiative                  $6.52              $2.52 To clean streams and rivers polluted by acid and toxic
                                                                   drainage form abandoned coal mines.
                                         ($6.52)
Bureau of Reclamation
Colorado River Basin Salinity            $85.53             $15.52 To prevent any further degradation of the Colorado River
Control Program                                                    and limit damages.
                                        ($85.53)
NOAA
Coastal Nonpoint Pollution               $12.02              $2.24 To protect and restore coastal waters and help states
Control Program                                                    establish enforceable programs for comprehensively
                                         ($10.0)                   addressing the most significant sources of nonpoint
                                                                   pollution.
Coastal Zone Management                  $23.81              $5.15 To encourage states to manage their coastal land and
Program                                                            water resources.
                                        ($229.1)
Department of Defense-Army
Integrated Training Area                 $50.35             $20.34 To maintain and sustain training lands. These actions
Management Programf                                                indirectly contribute towards preventing nonpoint source
                                        ($95.12)                   pollution.

                                                                                                     (Table notes on next page)




                                       Page 86                                     GAO/RCED-99-45 Nonpoint Source Pollution
Appendix II
Non-EPA Federal Programs That Address
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.




Page 87                                              GAO/RCED-99-45 Nonpoint Source Pollution
Appendix III

Comments From the Department of
Agriculture and Our Evaluation

Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




                             Page 88   GAO/RCED-99-45 Nonpoint Source Pollution
                 Appendix III
                 Comments From the Department of
                 Agriculture and Our Evaluation




Now on p. 3.
See comment 1.




See comment 2.




Now on p. 6.


See comment 3.



Now on p. 18.


Now on p. 19.


See comment 4.




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                 Appendix III
                 Comments From the Department of
                 Agriculture and Our Evaluation




Now on p. 19.


Now on p. 21.


See comment 5.




See comment 6.




See comment 7.


See comment 8.




Now on p. 49.




                 Page 90                           GAO/RCED-99-45 Nonpoint Source Pollution
                  Appendix III
                  Comments From the Department of
                  Agriculture and Our Evaluation




Now on p. 54.
See comment 9.



Now on p. 61.
See comment 10.


Now on p. 67.



Now on p. 83.
See comment 11.




See comment 12.




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                  Appendix III
                  Comments From the Department of
                  Agriculture and Our Evaluation




See comment 13.




See comment 14.




                  Page 92                           GAO/RCED-99-45 Nonpoint Source Pollution
                       Appendix III
                       Comments From the Department of
                       Agriculture and Our Evaluation




Now on pp. 8 and 75.
See comment 15.




See comment 16.




                       Page 93                           GAO/RCED-99-45 Nonpoint Source Pollution
                  Appendix III
                  Comments From the Department of
                  Agriculture and Our Evaluation




Now on p. 61.




Now on p. 84.
See comment 17.




See comment 18.




See comment 19.




See comment 20.




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                  Appendix III
                  Comments From the Department of
                  Agriculture and Our Evaluation




See comment 21.




                  Page 95                           GAO/RCED-99-45 Nonpoint Source Pollution
Appendix III
Comments From the Department of
Agriculture and Our Evaluation




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



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Comments From the Department of
Agriculture and Our Evaluation




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



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Comments From the Department of
Agriculture and Our Evaluation




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.




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Appendix III
Comments From the Department of
Agriculture and Our Evaluation




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.



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Comments From the Department of
Agriculture and Our Evaluation




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.




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Appendix IV

Comments From the Federal Energy
Regulatory Commission and Our Evaluation

Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




See comment 1.

See comment 2.




See comment 3.




                             Page 101   GAO/RCED-99-45 Nonpoint Source Pollution
Appendix IV
Comments From the Federal Energy
Regulatory Commission and Our Evaluation




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

1
Guidance Specifying Management Measures For Sources Of Nonpoint Pollution in Coastal Waters,
U.S. Environmental Protection Agency, (Jan. 1993).



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Comments From the Federal Energy
Regulatory Commission and Our Evaluation




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.




Page 103                                   GAO/RCED-99-45 Nonpoint Source Pollution
Appendix V

Comments From the Department of the
Interior and Our Evaluation

Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




See comment 1.

See comment 2.




                             Page 104   GAO/RCED-99-45 Nonpoint Source Pollution
Appendix V
Comments From the Department of the
Interior and Our Evaluation




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.




Page 105                                GAO/RCED-99-45 Nonpoint Source Pollution
Appendix VI

Comments From the Department of
Commerce and Our Evaluation

Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




                             Page 106   GAO/RCED-99-45 Nonpoint Source Pollution
                 Appendix VI
                 Comments From the Department of
                 Commerce and Our Evaluation




Now on p. 20.




See comment 1.




Now on p. 38.




Now on p. 86.
See comment 2.




                 Page 107                          GAO/RCED-99-45 Nonpoint Source Pollution
Appendix VI
Comments From the Department of
Commerce and Our Evaluation




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.




Page 108                               GAO/RCED-99-45 Nonpoint Source Pollution
Appendix VII

Major Contributors to This Report


                        Jennifer Clayborne
Resources,              Michael Daulton
Community, and          Steve Elstein
Economic                Tim Guinane
                        Karen Keegan
Development             Patricia Macauley McClure
Division, Washington,
D.C.




(160425)                Page 109                    GAO/RCED-99-45 Nonpoint Source Pollution
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