Subcommittee on Fisheries, Wildlife and Water
Senate Environment and Public Works Committee
February 29, 2002
Testimony Submitted by
Valerie I. Nelson, PhD
Coalition for Alternative Wastewater Treatment
I appreciate the opportunity to submit testimony to the Subcommittee on Fisheries, Wildlife and Water concerning S. 1961, the Water Investment Act of 2002, which would reauthorize the Clean Water Act and Safe Drinking Water Act state revolving funds (SRFs). I am the Director of the Coalition for Alternative Wastewater Treatment, which was formed eight years ago to promote reform of federal, state, and local policies and practices concerning decentralized wastewater treatment. I would also like to present the recommendations for SRF reauthorization developed at a national workshop on integrated water resource management that was held on February 19-20, 2002 in Arlington, Virginia.
The central recommendation of my testimony is for the Congress to provide incentives in the SRF program for states to fund decentralized wastewater, distributed stormwater, and other non-point source projects. After several decades of investment in wastewater treatment plants and sewer collection systems, progress has been made by the nation in water quality protection. However, estimates are now that a majority of water quality problems stem from non-point sources. The costs of addressing equivalent amounts of non-point pollution are substantially less than the costs for point-source treatment. And yet, the states are currently directing only 4% of SRF loans to non-point source projects. This represents a serious misallocation of federal resources, and raises the question of how states can be encouraged to utilize SRF funding more cost-effectively. While EPA has issued guidance in recent years allowing states to provide SRF loans for non-point source projects, a majority of states have not broadened their eligibility lists to allow these projects to be funded.
I would suggest that the best approach for the federal government to promote a more efficient use of federal resources by the states is to create a 10% set-aside of new SRF funding for states to use for non-point source projects. This approach would maintain the flexibility in the use of the SRF which states request, but at the same time would assure greater accountability by the states to the goals and objectives of the Clean Water Act. States would be eligible to apply to the EPA for 10% in additional funds beyond the baseline allotment for the Clean Water SRF capitalization grant. Funds could be used for principal forgiveness, interest subsidies, and other creative financing mechanisms which each state would have the flexibility to develop.
The 10% set-aside proposal is modeled on the successful enhancement grant set-aside established in the Intermodal Surface Transportation Efficiency Act of 1991. Because of this initiative, successful environmental enhancements have been constructed throughout the states, and reform of transportation planning and mainstream practice have occurred more generally.
Integrated Water Resource Management Workshop
On February 19-20, 2002 a group of 35 leaders in water quality protection met in Arlington, Virginia to discuss the future of distributed and natural system approaches to integrated water resources management. Participants included public officials, engineers, academics, and environmental advocates from across the country. In recent years, much progress has been made in the development of decentralized or distributed approaches, including for example: advanced on-site and cluster system technologies and management for wastewater treatment; distributed stormwater remediation, including stream restoration; low impact development practices that retain natural infiltration/treatment zones and distribute infiltration and biorentention best management practices throughout a development; agricultural stream buffers and other best management practices; and “soft path” flood control measures such as parkland stream buffers.
Water resource management in the U.S. has been dominated in recent decades by “hard path” centralized infrastructure solutions, including sewer collection systems and treatment plants, stormwater collection and underground storage tunnels, centralized water lines and filtration plants, and stream channeling and dams for flood control. And, permitting, funding, and management of these systems have been segregated into separate agencies, rather than integrated into a holistic watershed framework.
The premise of the workshop was that this reliance on centralized solutions constructed without regard to the broader watershed and groundwater forces at work in the ecosystem has cumulatively led to major unintended consequences and environmental damage. Sewer collection systems and point-source discharges, by moving locally supplied water and infiltration/inflow water great distances to point-source discharges have led to depleted aquifers, saltwater intrusion in the coastal zone, and dried-up streambeds. Sewer systems have also promoted growth and development, with large-scale increases in stormwater runoff, and leaking sewer pipes now constitute the single greatest source of drinking water microbial contamination. Channeling to control floods has also led to disruptions in natural systems for water purification. And, finally, failure to fully utilize cost-effective water efficiency and distributed water reuse measures exacerbates the surface and groundwater impacts of water supply systems.
Distributed and natural-system or “soft path” approaches hold great promise to achieve water resource protection at substantially lower cost than traditional centralized technologies, and in particular, entail far fewer adverse impacts to public health and the environment when considered in an integrated framework. The reason is that distributed, “green” solutions to sewage and stormwater treatment rely on and blend into large, natural surface water and groundwater systems that have evolved and stabilized over centuries. Centralized approaches constitute a much larger disruption of these natural systems than decentralized approaches. For example, decentralized wastewater systems, by widely dispersing the release of treated wastewater into the soil, help replenish aquifers. Distributed approaches also provide communities with more options and greater control over development, natural resource protection, and public amenities such as parks and open space.
Workshop participants discussed the range of environmental, economic, and community benefits to decentralized and nonpoint-source approaches to water quality protection and integrated water resource management, and developed recommendations for reform of engineering practice, regulatory structures, management, and research. In addition, recommendations for the SRF reauthorization were discussed, and options from various workshop sub-groups include the following:
or soft path projects need incentives in the SRF. These would include
such approaches as:
a. a 10% non-point source set-aside of new SRF funds
b. a reduced match requirement for non-point source or distributed treatment projects
c. a reduced interest rate
d. principal forgiveness
2. Extra funding should be provided for state and local entities to cover the additional administrative costs of developing non-point source projects, as well as integrated water resource plans.
3. Eligibility should also be expanded to include:
a. monitoring costs (as already exists in the Drinking Water SRF)
b. pollutant trading
4. Funding approval should be tied to consistency with plans:
a. drinking water grants should be tied to source water protection plans
b. wastewater projects should be tied to integrated water resource plans developed by local entities
c. transportation planning links should also be required
5. States should be required to demonstrate that water quality goals are being met cost-effectively. Build assessment and feedback on environmental outcomes and cost-effectiveness into the process.
a. One suggestion was for a focus on GPRA requirements to be imposed on state SRF agreements with EPA.
b. Another suggestion
was to revitalize the CWA planning process or 303e. Bring back the better
elements of the water resources council that were dropped in the early 80's.
6. Research projects are needed on such topics as: biological integrity before and after projects; lifecycle costs of non-point and soft path approaches; fate and transport of pollutants; analysis of the impediments to integrated water resource management; soft path best management practices; effectiveness of education campaigns, land-use controls, etc.
7. Demonstration projects are needed on: integrated water resource management; regulatory changes needed to implement plans; stormwater decisionmaking; real-time water quality monitoring and technology programs, and community involvement; and others.