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Congressional Testimony
February 28, 2002 Thursday
SECTION: CAPITOL HILL HEARING TESTIMONY
LENGTH: 1521 words
COMMITTEE:
SENATE ENVIRONMENT AND PUBLIC WORKS
HEADLINE: WATER INFRASTRUCTURE &
CLEAN WATER PROGRAMS
TESTIMONY-BY: VALERIE I. NELSON,
PHD, COALITION FOR ALTERNATIVE WASTEWATER TREATMENT
AFFILIATION: GLOUCESTER, MASSACHUSETTS
BODY: Subcommittee on Fisheries, Wildlife and Water
Senate Environment and Public Works Committee
February 28, 2002
Testimony Submitted by
Valerie I. Nelson, PhD Coalition for
Alternative Wastewater Treatment Gloucester, Massachusetts
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:
1.
Nonpoint-source 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
c. training
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.
LOAD-DATE: March 29, 2002